¹²³⁰⁹

Tuesday, 29 October 2002

[Open session]

[The accused entered court]

--- Upon commencing at 9.32 a.m.

JUDGE MAY: Yes. Yes, Mr. Nice.

MR. NICE: Your Honour, we've only asked the witness to remain outside because there is, I think, technically outstanding the issue of the 92 bis application in respect of which the Chamber sought a further filing from Mr. Kay. That's been provided. We haven't been in a position to provide further written material in the time available. We have, however, made available to you a draft of the proof of evidence of the witness concerned, which reveals how, of course, his evidence --

JUDGE MAY: Just a moment. We'll be handed it.

MR. NICE: I'm sorry that it hadn't found its way to Your Honours yesterday. It was provided yesterday. It may be that the better course would be to put this consideration back rather than delay evidence. But our point arising from the draft proof of evidence is that, of course, all the matters that relate to the accused are going to be dealt with by the witness using the documents that we would prefer to be produced to you by 92 bis so that you can pre-read about the structure of the organisations concerned, and I simply repeat our argument last week that if at the end of the exercise it's found that anything admitted by 92 bis could or should be the subject of further evidence, it will be possible to identify it at that stage.

And I have to say that the written filing of the amici doesn't, in ¹²³¹⁰ our respectful submission, take the argument any further and doesn't identify any reason why this material shouldn't be before you in written form ahead of the witness coming to give evidence and it will save a great deal of time if you do have the material. We have to bear in mind that technically, and indeed in practice, Judges of this Chamber can't pre-read material in the form of witness statements although they are in a position to pre-read the summaries when they are provided in advance. And therefore, there is --

[Trial Chamber confers]

JUDGE KWON: Can I make two points?

MR. NICE: Yes.

JUDGE KWON: Because of limited time in the last session, I had a very foolish question, but my concern was this: You didn't apply for the 92 bis, even if in bis form in case of C-037 or C-060, so what is the criterion? The only concern is time again?

MR. NICE: One of the concerns is time. That, of course, is a concern that we share with the Chamber and probably everybody else in the institution. What we've been doing with the first series of witnesses in this particular part of the case is tending to favour live evidence until the overall structure of the case is before you from at least one witness, and therefore we haven't in all cases been seeking out every little bit of evidence that might go in by 92 bis. I think I actually forecast that we might take this general approach at an earlier stage. If I didn't, then I should have done.

We are now looking at all the forthcoming witnesses and looking in ¹²³¹¹ detail at what part or parts of their evidence might be properly advanced by 92 bis, and you'll be having a rolling series of motions dealing with all forthcoming witnesses in much the same way as you did in the Kosovo segment of the trial. And the priority given to time is much the same. It's just that the practicalities have changed. We feel we've passed the stage where it's desirable to take witnesses always in full and we've reached the stage where we must use 92 bis wherever we properly can. In this witness, the use of 92 bis would be rather different from in the case of many other witnesses because he's really providing a library of material to which he will himself turn wherever it's necessary. It's a question of getting that library of material before you in the most convenient way.

JUDGE KWON: Very well. Then can I make another point? Being a little bit different from other Judges in the Tribunal, frankly, I'm not well familiar with the history of Croatia and Western Krajinas, so if I can hear the evidence live in the Court, I would find very useful, even if Prosecution could lead the witness.

MR. NICE: That will probably --

JUDGE KWON: I'm speaking for myself.

MR. NICE: We quite understand that, and that evidence will in any event come in some form or another from the evidence of the witness that will be given live, because of course he'll be accounting for his own part in these events as well as pointing to the part in these events of the accused and he can only do that by giving a narrative history of the events in summary form in any event. ¹²³¹² As to Your Honour's earlier point, I'm asked by Ms. Uertz-Retzlaff to draw to your attention that the amount of public documents available for this part of the case through this witness is radically different from the amount of public documents that there were available for C-037 or C-060.

JUDGE MAY: We'll consider the matter now. I gather this witness isn't due until the end of the week.

MR. NICE: At the earliest, no. Thursday, Friday. Can I, just while I'm on my feet, say I believe there are outstanding issues for resolution involving K38. It's our probably misunderstanding as to whether it's from us that you want the next initiative or whether we are awaiting a ruling from yourselves as to when that matter --

JUDGE MAY: Well, that matter is in hand.

MR. NICE: Thank you. The next witness is to be taken by Mr. Groome, and I'll hand the floor to him.

MR. GROOME: Your Honour, I have two applications prior to the witness being called. The first is, after discussing it with the witness, Prosecution is applying for a change in the protective measures. This witness has been given a new domicile in another country, a member state, has also been provided with identification papers of a different name. He no longer feels it's necessary to have his name disclosed [sic] from the public or his facial image distorted, and accordingly, the Prosecution at this time would move to withdraw or vary the Chamber's previous order for protective measures.

JUDGE MAY: Yes, we'll grant that. ¹²³¹³

MR. GROOME: And the second matter, Your Honour, is that there are several pieces of evidence that the Prosecution would seek to tender through this witness that were not identified in the May submission of the 65 ter. Four of them are photographs that this witness provided to the Office of the Prosecutor which were in turn provided to Mr. Milosevic in May, attached to the statement, but they were not identified as potential exhibits.

The second set of documents are -- involve the following: Two pieces of personal identification issued to this witness, which he produced; two lists of participants in international conferences of which this witness will testify he was one of those participants; a photograph of an arm patch; and an original military document given to this witness, which was then in turn provided to the Office of the Prosecutor. I'm suggesting at this stage, Your Honour -- or I'm requesting at this stage if I may be permitted to show these exhibits to the witness and make an application for their admission into evidence at the time -- at the conclusion of the evidence in chief, when we will do this stock-taking procedure and examine the admissibility of the exhibits.

JUDGE MAY: If there's any objection to admissibility, it can be made at the time the witness deals with the exhibit. Otherwise, for myself, I can see no reason why they shouldn't be admitted.

MR. GROOME: Your Honour, at this time the Prosecution calls Mr. Slobodan Lazarevic.

[The witness entered court]

JUDGE MAY: Let the witness take the declaration. ¹²³¹⁴

WITNESS: SLOBODAN LAZAREVIC

THE WITNESS: I solemnly declare that I will speak the truth, the whole truth, and nothing but the truth.

JUDGE MAY: If you'd like to take a seat. Yes, Mr. Groome.

Examined by Mr. Groome:

Q. Sir, can you please tell us your name.

A. Slobodan Lazarevic.

Q. Can you tell us where you were born.

A. I was born in Belgrade.

Q. And did there come a time when you moved to Sarajevo?

A. Yes, in 1956.

Q. And was that -- while in Sarajevo, did you attend university there?

A. Yes, I did.

Q. And what was your field of study?

A. Languages.

Q. And can you tell us what languages you consider yourself able to speak fluently?

A. English and French.

THE INTERPRETER: Could the speakers please be asked to make pauses between question and answer for the interpreters, thank you.

MR. GROOME: My apologies.

Q. Now, I want to draw your attention -- or can you describe for the Chamber an organisation known as KOS. ¹²³¹⁵

A. It's a JNA military organisation with two streams; one deals with internal security and one with external security.

Q. I'd ask you, if you can, to speak a little bit slower to assist the interpreters in translating.

A. I do apologise.

Q. And how did you first become aware of this JNA military organisation known as KOS?

A. In 1968, I was approached by one of the officers of the KOS to start working for them.

Q. And can you tell us the name of the person who approached you?

A. Nikola Zimonja.

Q. And how did you meet Nikola Zimonja?

A. Through my father, who used to be a member of then known UDBA, which grows into the state security.

Q. After your initial meeting with Mr. Zimonja, did you have an ongoing relationship with him?

A. Yes, throughout my life.

Q. And can you describe for us the nature of your relationship with Nikola Zimonja.

A. Mostly I had to deal with infiltration of different organisations. For example, in 1968, I was tasked with infiltrating the student movement in Sarajevo, and for example, planting the films on German tourists, for example, or infiltrating the Serbian emigres in UK, Croatia, Australia, and so on.

Q. Did you consider Nikola Zimonja to be your supervisor in KOS? ¹²³¹⁶

A. Yes, indeed.

Q. Can you give us an idea of the time that you spent in Australia, working in the Croat emigre community in Sydney?

A. Well, briefly, I have tried to penetrate the organisations. Unfortunately, I wasn't very successful. But I did spend 11 years in Australia.

Q. Did there come a time when you were asked to return to Yugoslavia?

A. Yes, back in 1993, prior to the Winter Olympics in Sarajevo.

Q. And who asked you to return to Yugoslavia?

A. Nikola Zimonja.

Q. Were you assigned to work in the -- work in connection with the Winter Olympics in Sarajevo in 1984?

A. Yes. I have been assigned to be a personal assistant to director of protocol of International Olympic Committee.

Q. And while you held this post, did you still consider yourself to be a member of KOS?

A. Yes.

Q. In 1984, were you given another assignment by Mr. Zimonja?

A. Yes. I have been given assignment to go and join Agrokomerc in Velika Kladusa.

Q. And who was in charge of that company?

A. Mr. Fikret Abdic.

Q. I'm going to ask now that a binder of exhibits containing 15 tabs - I apologise - 14 tabs be assigned a number, and I would then ask that the exhibit in the first tab be put on the overhead projector. ¹²³¹⁷

THE REGISTRAR: Your Honours, this will be marked Prosecutor's Exhibit 348.

MR. GROOME: Your Honour, I'm not sure if it's just my terminal, but when I -- I apologise. It's now up on the screen. I will be asking Mr. Lazarevic to describe a number of different people, most of which are contained in this summary diagram. I'm going to ask that it be left on the overhead projector during the course of his explanation, and at the conclusion of his description of these people, I will ask him to use this diagram to describe the relationships between the various people.

Q. Mr. Lazarevic, I want to begin by asking you about two people associated with the Republic of Serb Krajina army, and during the course of your testimony, I will refer to them as the ARSK. The first person I want to ask you about is General Mrksic. Are you familiar with General Mrksic?

A. Yes, I am.

Q. And can you describe for the Chamber who he is.

A. General Mrksic was a commanding officer of the 8th Operational Group in RSK when I joined them in December 1991.

Q. Now, when you say the 8th Operational Group, do you mean of the Yugoslav People's Army, the JNA?

A. Precisely, the JNA.

Q. Please continue.

A. I had an opportunity of meeting him again when he returned to Krajina in 1995 as a commanding officer of the RSK army. ¹²³¹⁸

Q. Did you ever have a conversation with him regarding Vukovar hospital?

A. Yes, I have.

Q. Can you please summarise that conversation for the Chamber.

A. General Mrksic always believed that it was one of his very important military victories during the conflict, and he viewed it as a hospital being taken on the fourth floor by the Croatian forces and he had given -- ordered those forces to be destroyed.

Q. And did he tell you who he gave that order to?

A. Yes, he did. Yes, he did.

Q. And who was that?

A. I think the gentleman was a major at the time, Sljivancanin.

Q. Did he tell you the words that he used when he gave Sljivancanin the order regarding Vukovar hospital?

A. Yes. For the benefit of the Court, I will say that in English and Serbian. The Serbian expression, [Interpretation] "Kill those shits." [In English] My apologies to the Court. "Kill those shits."

Q. Now, are you familiar with a person by the name of Lieutenant Colonel Mile Novakovic?

A. Yes, I am.

Q. Can you please describe who he is.

A. Mile Novakovic is also a JNA officer who spent a considerable time in RSK, the various positions within the army structure.

Q. And was he part of a Serbian military delegation at a number of international peace conferences? ¹²³¹⁹

A. Yes, he was.

Q. I want to now ask you about the 21st Corps. Can you tell us, was that a component of the ARSK?

A. The 21st Corps came into being after the JNA withdrew from Croatia. The 21st Corps actually held the responsibility in the area of Kordun, therefore the name Kordun Corps as well.

Q. Are you familiar with the 39th Corps?

A. Yes, I am. It's also known as the Banija Corps. That would be the eastern flank of the 21st Corps.

Q. And the 15th Corps?

A. 15 Corps was also known as the Lika Corps, and that would be the western flank of the 21st Corps.

Q. And is it true that the 21st Corps, the 39th Corps, and the 15th Corps are all corps within the ASRK?

A. Correct.

Q. Now, during the time period of the testimony you will give, did the 21st Corps have three different command centres?

A. Yes. On three occasions we have changed our HQ. Original was set in Topusko - that's in 1992 - on a little hill across from the compound of the UN sector compound. We have moved that HQ to Petrova Gora, used to be a JNA installation, and then from Petrova Gora to vicinity of Vojnic was the third and the last displacement of the HQ.

Q. Can you approximate for us when the headquarters was moved to Petrova Gora?

A. It would be early 1993. ¹²³²⁰

Q. And can you approximate for us when it was moved to Vojnic?

A. In the same year, at a later stage, when the Serbian MUP moved into Petrova Gora.

Q. Now, did there come a time when you as a member of KOS, JNA military intelligence, were assigned to work as part of the 21st Corps in the ARSK army?

A. Yes, indeed.

Q. And can you tell us when it was you were assigned to work there?

A. In February of 1992.

Q. And during your time with the ARSK, did you move to the different command centres as the headquarters moved?

A. No, I have not. I kept my office in vicinity of the UN compound.

Q. And where was that?

A. In Topusko, to facilitate the meeting between myself and the liaison officer of the UN.

Q. Can you describe who Colonel Bulat is for us.

A. Colonel Bulat is commanding officer, or used to be commanding officer, of 21st Corps, Kordun Corps, and also my CO.

Q. Was he somebody that you had daily contact with?

A. Every single day.

Q. Are you aware of what contact, if any, he had with the General Staff of the Yugoslav army during the time he was head of the 21st Corps?

A. He had contact on a daily basis, every morning, after the briefing of his officers. He will also report directly to the General HQ in Belgrade. ¹²³²¹

Q. Do you know of any particular contacts that he had in the Yugoslav People's Army?

A. I was present in the office when he made those calls on a number of occasions.

Q. And do you know the name of the people or persons that he was speaking to in Belgrade?

A. General Perisic.

Q. And is that Momcilo Perisic?

A. That is correct.

Q. Based on your interaction with Colonel Bulat in the 21st Corps, can you describe for us what authority he had to make decisions in his area of responsibility, in the Kordun area?

THE INTERPRETER: Could you please slow down for the benefit of interpreters.

A. Anything that had to deal with things of local importance; movement of troops from one part of Kordun to another part of Kordun would be his individual decision, he would not have to report to Belgrade. Anything which would have wider implications to the things happening in ARSK, he would have to consult Belgrade HQ and wait for approval.

Q. Can you give the Chamber some examples, specific examples, of situations where Colonel Bulat would have to consult with General Perisic before taking action in Republic of Serb Krajina?

A. For example, if attack was being contemplated against the 5th Corps, which is generally known as the area of the Bihac pocket, and it had to be in cooperation with other corps on the ground, whether they are ¹²³²² in ARSK or Republika Srpska, those are the situations where directive would be gotten from the General HQ in Belgrade.

Q. Now, when you describe the 5th Corps, are you talking about the 5th Corps of the Bosnian army?

A. That is correct.

Q. Based upon your contacts and work in the 21st Corps, are you able to describe whether or not Colonel Bulat spoke with Belgrade first or with his nominal headquarters in Knin first?

A. It would really depend on the situation. As I have said before, if the situation demanded cooperation of more than one corps, he would speak to Belgrade first and then to Knin second. Anything of a local character, he would report to Knin first.

Q. Now, I want to ask you about a component of the 21st --

[Technical difficulty]

MR. GROOME:

Q. I want to ask you about a component of the 21st Corps --

[Technical difficulty]

JUDGE MAY: We're getting the French coming through on the English channel. Let's try again.

MR. GROOME:

Q. I want to ask you about a component of the 21st Corps. Are you familiar with a unit called the anti-terrorist unit?

A. Yes, I am familiar with that.

Q. Can you describe for the Chamber what was the function of this unit. ¹²³²³

A. The function of this unit, which numbered around 40 to 45 young men generally with very extensive criminal record, was to conduct so-called "dirty jobs," "prijavi poslovi," within the AOR of the 21st Corps. And I might add that every corps had one of those units, for the same purpose.

Q. In the other corps, were these units also known as the anti-terrorist unit?

A. They might have a different names, but the reasons for their establishment was always the same.

Q. Now, you have described the members of this unit as having criminal records. Were the members of this unit official soldiers within the ARSK?

A. Yes, they have. They have been a part of the general army structure.

Q. Now, you have used the term "dirty job." Can you please describe for the Chamber the meaning of that term.

A. Well, all the task which your well-educated and normal JNA officer would refuse to do would be assigned to those units known as anti-terrorist units. Basically they are used to scare the people, they are used to create disturbances, and they are not removed from killing either Croats, Muslims, or even Serbs.

Q. Who was the commander of that unit?

A. Young man whose nickname was Paraga. His real name is Sinisa Martic, and I believe he is no longer among living.

Q. Can you describe for us who Colonel Pero Ajdinovic is? ¹²³²⁴

A. Colonel Pero Ajdinovic was a member of KOS also, but the one that dealt with internal security, and he's the one that actually formed this group originally, prior to establishment of the 21st Corps in the area.

Q. And can you tell us who Colonel Mlado Karan is?

A. Colonel Mlado Karan is also Serb KOS, internal security, who had inherited the position from Colonel Ajdinovic when he returned to Belgrade, and also to cover the command of the anti-terrorist unit.

Q. Now, when you refer to both of these men as being members of KOS, are you referring to a different KOS unit in ARSK or are you referring to the same KOS that you belonged to or belonged to in the Yugoslav People's Army?

A. I refer to the one and the same, but I like to make perfectly clear there are two strains within the corps, two lines, if you like; one that deals with internal security of the country and another one which deals with external security of the country, of which I was a member.

Q. And which branch of KOS did these two men belong to?

A. Internal security.

Q. Now, I want to draw your attention to the death of a person by the name of Dmitar Obradovic. Are you familiar with the circumstances surrounding his death?

A. Yes, I am. Mr. Obradovic was mayor of Vrginmost.

Q. And can you describe, before telling us the circumstances of his death, can you explain to the Chamber who he was and what was his role in the events of the Krajina in the summer of 1992?

A. I had the great pleasure of meeting Mr. Dmitar Obradovic on ¹²³²⁵ various occasions in his meetings with ECMM and I always found him to be extremely intelligent and in possession of a number of documents which would prove whatever he was saying at the meeting. And his idea was actually of co-habitat, meaning that the Serbs and Croats can live together in Croatia as long as the Serbs accept a Croatian government as such.

Q. What was his ethnic background?

A. He was Serb.

Q. Was he opposed to the formation of the RSK?

A. In a sense, yes.

Q. And was he in favour of peaceful reconciliation with Croats?

A. Yes.

Q. What happened to Mayor Obradovic?

A. Mayor Obradovic was ambushed and killed.

Q. Did that occur within the confines or the area of responsibility of the 21st Corps?

A. Yes. As a matter of fact, only about 200 yards away from the HQ.

Q. And was there an investigation into the circumstances surrounding his death?

A. Yes. Three bodies have carried the investigation. One was carried by the 21st Corps, one by the local police, and one by the UN international police.

Q. And by virtue of your position in the 21st Corps, did you have contact or were you involved within the investigation into his death?

A. Yes, I have been, but more as an observer and helping hand in the ¹²³²⁶ case there is some misunderstanding, language barrier or anything like that. But I was present during the initial investigation of the murder.

Q. The investigation conducted by the 21st Corp, what conclusions did they draw regarding how Mayor Obradovic had been killed?

A. The official statement was that the Croatian terrorists have penetrated our border along the Kupa River, came to the vicinity of Topusko and shot Mayor Obradovic.

Q. You said that's an official statement. Was there another finding of the people who investigated his death from the 21st Corps?

A. Yes.

Q. And what was that?

A. It was done by the anti-terrorist group.

Q. Did there come a time when you heard members of the anti-terrorist group discussing the killing of Mayor Obradovic?

A. As a matter of fact, yes. They have said to me on a number of occasions that that was a very patriotic thing to do at the time.

Q. Now, at the time that Mayor Obradovic was killed, can you tell us what was your title within the 21st Corps, and describe briefly your responsibilities.

A. I had a rank of lieutenant colonel and I was a liaison officer between the 21st Corps and any international organisation on the ground; UN or International Red Cross or ECMM, or anybody else, for that matter. Even a journalist, if they would come, they would report to me first.

Q. And in connection with this killing, were you charged with the duty of forwarding to the United Nations or informing the United Nations ¹²³²⁷ the official finding that Mayor Obradovic had been killed by Croatian terrorists?

A. Yes, I have. Actually, I have been given a letter of protest to take to the HQ of the UN and hand it personally to the general -- General Musa Bamayi, and he was a sector commander of sector north, which covered precisely the same area as the 21st and the 35th Corps.

Q. At the time you handed over this letter of protest, did you know its contents to be false?

A. I was well aware of it.

Q. I want to now direct your attention to the police in the Republic of Serb Krajina. Can you please describe for us what you know about the police structure of the Republic of Serb Krajina during the time you were there.

A. Well, in real terms of police force, it was established along the same lines as any other police force in any other country, meaning they had their many servants, they had their different departments, they had their state security within the police department, which were directly responsible to the state security of Serbia, they would have their police stations, they would have their -- which are based generally on the same area as the different sectors of the UN were deployed.

Q. Each of these sectors, did they have deputies responsible for the sectors?

A. Yes. They would have a deputy who was responsible directly to the Ministry of Interior, who was Milan Martic at the time; also there would be a chief of police stations who would be responsible to the deputy, the ¹²³²⁸ deputy then in turn to Minister of Interior.

Q. Can you describe what the duties and responsibilities would be for each of these deputies for each area.

A. Sorry. I'm not quite understanding the question.

Q. How many deputies were there for each area of responsibility?

A. To my knowledge, I know of four: That would be sector north, sector south, sector west, and sector east.

Q. In each one of these individual sectors, how many deputies were there?

A. There would be one deputy who was responsible directly to the Minister of Internal Affairs, Mr. Martic, but there would be a number of police stations which would have their own chief of police within the station.

Q. This deputy, or the deputy for each sector, was that person responsible for the activities of uniformed police officers?

A. Yes. Also for the civilian-dressed officers as well.

Q. Now, during your time in the Krajina, did you form an impression regarding who was paying for the police in the Republic of Serb Krajina?

A. They have been paid from the same source as the army did.

Q. And how do you know that?

A. Well, on a number of occasions I was there when what we generally term a money man would arrive from Belgrade with amount of money for distribution where each of the commanders would get the names of the people he's supposed to pay, go to the paymaster, collect the amount of money for his unit, and then distribute this money to the members of the ¹²³²⁹ unit.

Q. Would this same paymaster be responsible for dispersing money to both police units and ARSK units?

A. To my knowledge, yes.

Q. Was there an event during which the paymaster was robbed on one occasion?

A. Yes, indeed. On evening of August 6th, 1995, during withdrawal of the Serb forces from Krajina, the paymaster claimed that within the convoy he was robbed of all the pays for everybody within the army and police.

Q. So after he claimed to have been robbed, were any police officers paid that pay period?

A. No, nobody got paid.

Q. Can you describe for us who Milan Martic was, briefly.

A. Milan Martic is a man who had a rather dramatic success in a very short period of time; from being a commander of a very small police station in the middle of nowhere, around Knin, that numbered approximately four men, to becoming president of the RSK.

Q. Prior to being station commander -- or I'm sorry. In between his positions as station commander and president of the Republic of Serb Krajina, did he hold other high-profile positions?

A. Yes. He was Minister of Internal Affairs prior to becoming president of the Republic.

Q. I want to now ask you to describe for the Chamber what relationship, if any, existed between the ARSK and the RSK police.

A. Can you repeat the question, please? ¹²³³⁰

Q. I want you to describe, if you can, what was the relationship between the army and the police in the RSK.

A. Well, at the very beginning, the army had the upper hand in everything that was happening. When I'm talking about the beginning, I'm talking about 1992. Later on, with the presence of the special forces from Serbia, that power has gone into the hands of police.

Q. Now, are you familiar with the implications of the Vance plan on the army in the RSK?

A. Yes.

Q. And can you describe for us what the Vance plan required regarding the military.

A. Vance plan required total demilitarisation and demobile of all units within the RSK. Us being co-signatories of the plan, what we did, we changed the uniform overnight from military olive-green into the police blue and within a very short period of time, I'd say within ten hours, we have repainted all the military vehicles into the blue colour, being representing the police.

Q. Did the Vance plan put any restriction on the size of the police forces in the RSK?

A. Not that I was aware of.

Q. During this period of transformation, were you issued an identification card describing you as a member of the RSK police?

A. Yes, I have been issued a card, and also I have been asked to remove my uniform, military uniform, and start wearing civilian clothing during this time. ^{12331 BLANK PAGE 12332}

Q. And at the time you were issued an identification card for the RSK police, were you still a member of the JNA KOS unit?

A. Absolutely. I mean, basically nothing has changed. We just changed the colour of the uniform.

MR. GROOME: Your Honour, at this time I would ask that the witness be shown Exhibit 348, tab 2. It's a photograph, and I'd ask that be placed on the overhead projector.

Q. Mr. Lazarevic, do you recognise the photograph that's now on the overhead projector?

A. Yes, I do.

Q. And do you recognise the people that are in that photograph?

A. Yes, I do.

Q. Can you please, going left to right --

MR. GROOME: I'd ask the usher maybe to remain with the witness for a minute.

Q. I'd ask you, moving from left to right, can you please identify them to the Chamber.

A. The person I'm pointing right now, it's me. Next to me, standing, is General Satish Nambiar, who was UN force commander for all of the area of the UN. General -- actually, there is another colonel here, a Polish colonel, but his name really escapes me, I can't remember. And here in the corner, unfortunately it's not very bright lit on my monitor here, you can see General Novakovic. Interesting part which I'd like to draw attention to, this is the time when we have actually demob'd and changed the uniforms into police. There is only shoulder patch you can see here ¹²³³³ written "milicija" in Cyrillic.

Q. I'm going to ask you to take a pen and circle the shoulder patch that you've just described as containing the words "police."

A. [Marks]

Q. And you've used the word "milicija." Can you please describe the translation of that word for us.

A. It's "police."

Q. The handwriting on this photograph, is that your handwriting?

A. Yes, it is.

Q. Thank you.

MR. GROOME: I'd now ask that Prosecution Exhibit 348, tab 3, be placed on the overhead projector.

Q. Mr. Lazarevic, do you recognise what is depicted in Prosecution Exhibit 348, tab 3?

A. Yes. This is my police ID.

Q. And was that issued to you at a time when you were a member of the Yugoslav army?

A. That is correct.

MR. GROOME: When it's convenient, that can be removed from the overhead projector.

Q. Now, Mr. Lazarevic, I'd like -- or ask you to describe for the Chamber the command structure of these military people that are now appearing in police uniforms.

A. I'm not following you.

Q. Did these former military people, did they fall into the command ¹²³³⁴ structure of the police? In other words, did they then take their orders from the local station commanders or did they have some separate command structure to the police?

A. Well, they were never really a part of the police force as such, because they retained their ranks in a commanding chain within the military. What they did, they simply changed the uniform overnight, but the chain of command remained the same, and that was the JNA chain of command.

Q. Now, were you familiar with an incident around March of 1992 when a large number of these men were brought back to Belgrade for a particular assignment?

A. Well, March 1992 begins the withdrawal of the JNA as such back to the -- back to Bosnia, and through Bosnia back to Serbia proper really. A number of officers was left behind, and they are the regular JNA officers. Also, the HQ in Belgrade would go through the files of every JNA officer and by the place of birth, if the place of birth was in Krajina, or RSK, they would be sent back to Krajina for the stint of duty the length of six months, and then they had option either to return to Belgrade or to continue their service in the field.

Q. In addition to what you've just described, was there a specific event in which volunteers were asked to volunteer to go to Belgrade to work on a specific project?

A. Yes, but it was the police force, not the JNA.

Q. Please describe what the police -- first let's clarify. What police force are you going to speak about? ¹²³³⁵

A. Regular police from the RSK.

Q. And can you describe what happened?

A. There was -- actually, there was an order issued from Belgrade, order/request, if you like, that each of the sectors would send approximately 100 uniformed police officers to Belgrade. For that purpose, Belgrade has sent brand-new uniforms which are the same as the proper Serbian police would wear. Totally new uniforms. And they were to be transferred on the buses to Belgrade and to deal with demonstrators on the street in Belgrade.

Q. And the demonstration, was that a demonstration against Mr. Milosevic?

A. Yes, sir.

Q. And approximately how many altogether of these Republic of Serb Krajina police were outfitted with Republic of Serbia police uniforms and transported to Belgrade?

A. I know for the fact that the area of the 21st Corps, or area of Kordun, had supplied 100 men for this particular task, and to my general knowledge, each of the other sectors have given the same number. So I would put the number to four to five hundred in total.

JUDGE MAY: Can you deal with the time that this happened, Mr. Groome, please.

MR. GROOME: Yes, Your Honour.

Q. Can you give us your best approximation or the actual date, if you know, when this occurred?

A. Well, I don't know if the Court is aware of how many ¹²³³⁶ demonstrations were there on Belgrade streets in this particular period of time. This one that I'm talking about has taken place in late 1992.

Q. Now, were you aware of how the men were selected, how these 500 men -- 400 to 500 men were selected to go to Belgrade? What was that process like?

A. The bigger, the better.

Q. Were you present when anything was said to the men to -- in the section process?

A. Well, it was a kind of standing joke at the time, because they were selecting really huge blokes, like you know, anything over six-two, to assign them to Belgrade and deal with the demonstrators, and most of them actually were joking, like, they're going to go over there and beat the living daylights out of the anti-communist demonstrators.

Q. Now, the Republic of Serb Krajina police, did they also have a state security division or a DB?

A. Yes. They had the head of this DB in RSK, in my sector, anyway, was a gentleman by the name of Milos Pajic.

Q. Now, when you say that he was in charge of it, was he the person who was named as the head of the RSK DB?

A. On paper, yes.

Q. Based on your experience, did you come to believe that somebody else was in fact in charge of the RSK DB?

A. Absolutely.

Q. And who was that person?

A. Mr. Toso Pajic, who was to become Minister of Interior of RSK in ¹²³³⁷ 1995.

Q. And can you describe what, if any, relationship you had with Toso Pajic.

A. I always found Mr. Pajic to be a very pleasant, well-educated, and a kind of diplomatic person. I had to deal with him on a daily basis during my stay in Krajina, simply because he was also named as a liaison officer to the UN but like my police counterpart.

Q. And during your daily contacts with Mr. Pajic, did he discuss what, if any, relationship he had with the DB of the Republic of Serbia in Belgrade?

A. On numerous occasions he stated that he actually works for Jovica Stanisic, who was head of the state security in Serbia proper.

Q. Did he describe for you how often he was in contact with Jovica Stanisic?

A. Virtually, on a daily basis. On a few occasions, I was in his office. He had a direct telephone line to Mr. Stanisic.

Q. Did he have a nickname or other name that he used when he referred to Jovica Stanisic?

A. Yes. He considered him to be his "Daddy," and generally referred to him always as "Daddy."

Q. During the course of your conversations with Toso Pajic, did he also use a term to refer to Mr. Slobodan Milosevic?

A. Yes, he did.

Q. And what term was that?

A. "Boss." ¹²³³⁸

Q. During the course of your relationship with Mr. Pajic, did he ever describe for you his relationship with the Serbian DB?

A. What my understanding was, that Mr. Pajic was actually full time employed by the DB in Serbia, because simply when we had returned to Belgrade in August 1995, he just resumed his old office in Belgrade within the DB structure.

MR. GROOME: I'd ask now that the witness be shown Prosecution Exhibit 348, tab 4, and that it be placed on the overhead projector.

Q. Do you recognise, Mr. Lazarevic, what is depicted in that photograph?

A. Yes. The place is a hotel in Topusko, and the three persons sitting there are, I'll go from left to right: That would be Mr. Toso Pajic, when he was chief of police of Vojnic, so that would be very early 1992, I'd put it down around May to June of 1992. This Danish officer here, I remember he was Danish, but he was in charge of IPTF, but I don't remember the name. And there's me, liaison officer of the 21st Corps.

Q. And is that your handwriting on the exhibit?

A. Yes, it is.

MR. GROOME: Thank you. That can be removed from the ...

Q. Do you know a person by the name of Djuro Skaljac?

A. Yes, I'm very familiar with Mr. Djuro Skaljac.

Q. Can you please describe for the Chamber who he is.

A. Djuro Skaljac is another police officer who was the second in charge in Vojnic. He was assistant to Mr. Toso Pajic. At a later stage, Mr. Skaljac has become a liaison police officer with Mr. Abdic in ¹²³³⁹ Belgrade.

Q. Now, I want to ask you about one political figure from the Republic of Serb Krajina, and that is Mr. Goran Hadzic. Can you tell us briefly who he was.

A. Mr. Hadzic was elected president of the RSK. I have attended quite a few meetings within RSK and also outside the RSK, the international meetings.

Q. Did Mr. Hadzic ever describe for you the nature of his relationship with Mr. Slobodan Milosevic?

A. Well, I think if I describe to the Court a little incident that happened probably will give the best picture of what he really felt. During one of the meetings in Norway that we had with the Croatian side, with the participation of the UN, of course, we had a little recess, we were sitting in an office separate from the other delegations, and Mr. Hadzic was sitting at another table, playing solitaire. Somebody knocked on the door and two ambassadors walked in; it was American ambassador at the time to Croatia, Mr. Galbraith, and a Canadian ambassador whose name I cannot recall, and addressed him as --

THE INTERPRETER: Slow down, please, for the interpreters.

A. I do apologise. Ambassador Galbraith addressed Mr. Hadzic as "Mr. President," which I translated to him as "Mr. President." Without lifting his head from the cards, he turned around and told me, "Well, tell him I'm not a president, I'm just a dispatcher." And I believe at that particular point in time Mr. Hadzic actually realised that he's just dispatching messages from somebody else to this meeting. ¹²³⁴⁰

MR. GROOME:

Q. I want to now ask you about institutions, federal institutions in the former Yugoslavia, and I want to ask you a little bit more about your organisation, KOS, in the Yugoslav People's Army. Now, you described yourself, Colonel Pero Ajdinovic, and Colonel Mlado Karan as all being members of KOS assigned to work in the RSK; is that correct?

A. That is correct.

Q. During the course of your work with KOS, did you come to be familiar with a term known as "black funds"?

A. Yes, I have. Actually, the Serbian expression for it is "crni fondovi."

Q. Can you describe what this term "black funds" refers to?

A. It simply meant that you had a large amount of money at your disposal for which you did not have to sign or explain how it has been spent.

Q. Did you come to learn where much of this funding came from?

A. Very early in the 1960s and 1970s, those funds were provided by the company by the name of Genex, General Export/Import, which everybody knew that it was actually a DB front outside of Yugoslavia.

Q. And you're describing now this company as having this association with the DB. Did, despite that fact, did this company also provide funds which were used by members of KOS in the Yugoslav People's Army?

A. At certain locations, yes, specifically if it required a larger amount of money.

Q. Can you describe for the Chamber the basis of your knowledge ¹²³⁴¹ regarding black funds and other -- these financial matters related to KOS.

A. Well, I'll take myself personally. I have never signed for any receipt of the money from 1968 until 1995, and yet I have been financed on a regular basis.

Q. The beginning of your testimony, you described a number of overseas assignments that you had. Did you have access to what you're terming black funds during those periods of time as well?

A. Yes. I would supply a request for a certain amount of money and then I would pick up, without any questioning, the amount that I have requested, without signing for it.

Q. Without going into any great detail, could you list for the Chamber some types of specific expenses which would be -- which black funds would be used for?

A. Well, usually to deal with the people from other countries. Whether it's bribery, whether it's buying off documents, whether it's buying off weapons; depending really on the situation.

Q. Can you describe -- did you also have access to more legitimate sources of funding in the course of your work with KOS?

A. Oh, yes. Once I have arrived in the Kordun area, I have been placed on a payroll of the RSK.

Q. And for monies that you received for legitimate activities, can you describe the process for requesting and receiving those monies?

A. Yes. There would be an "X" amount of money with a receipt, which was a formal receipt, which I would have to sign that I have received the money. ¹²³⁴²

Q. If you made a request for some black funds to, let's say hypothetically, buy some information, was it expected that you would then produce that information shortly afterward?

A. Absolutely.

Q. Did you ever have occasion to discuss with Mr. Zimonja a request that you had for a large amount of black funds?

A. Yes. One of the incidents that comes to mind was an offer to buy a very extensive number of weapons and listening devices from Ukranian battalion.

Q. And what did he tell you regarding his ability to provide you with those funds?

A. He said the amount within itself would not pose a problem for them; however, that the army is not interested and that I should refer it to the DB.

Q. And did the DB become involved in this proposed purchase of weapons from the Ukranian battalion?

A. After being given permission by Colonel Zimonja to go and visit Mr. Toso Pajic and to pass the offer to him, the phone call was made to Mr. Stanisic in Belgrade, to which reply was that hold onto it for a couple of days and he'll get back to Toso Pajic, and that was the last I heard of it. Whether they bought it or not, I really don't know.

Q. My last question to you regarding black funds is: When you were overseas, can you describe for us briefly how black funds would be sent to you?

A. It was rather a simple system and very workable. Within every ¹²³⁴³ embassy, no matter where it is - the Yugoslav Embassy, that is - there was always a little Yugoslav club adjacent to the embassy which would have a security officer in there. You would go in there, introduce yourself, show the passport and then ask are there any messages for you. I remember, for example, the London one. There was a number of pigeon holes with the letters of the alphabet and, "L" for Lazarevic, if they had anything in there, they would give it to me.

On the other hand, if I had to forward any information or a report, I would go there, place an envelope, seal it, and place it in this "L" hole, and somebody would obviously, you know, send it where it was supposed to go.

My request for funds would go absolutely the same way. I would write down the request, explain why I need this amount of money, place in envelope, put in the pigeon hole and maybe two days later come back and collect the money.

Q. Mr. Lazarevic, I'd like to move from this topic and now ask you to describe for us the relationship between the Yugoslav People's Army, the ARSK - the army of the Republic of Serb Krajina - and whatever you are able to describe for the Chamber regarding the VRS, the army of Republika Srpska.

A. Personally, my experience has shown that we are not talking about three different armies, we are talking about one and only army, and that's the JNA. Whether the name was VRS - Vojska Republika Srpska - or RSK army - Vojska Republika Srpska Krajina - was totally irrelevant in real terms, because all the supplies and the finances would come from Yugoslavia, ¹²³⁴⁴ Serbia, if you like.

Q. During your time at the 21st Corps, did you come to know how -- or come to see supply convoys coming from the Yugoslav Armija in Serbia to the area of the Krajina?

A. Yes, indeed. As frequent as at least once a month.

Q. And what was the name of the route that was taken?

A. Well, they would start from Belgrade, for example, and go through Posavina corridor, which is also known as "Zila Kucavica" in Serbian language, because that was the only corridor that connected the RSK with Serbia proper. Commonly go through there and arrive to our territory, and as it went through, to each of the command it would arrive to -- for example, if the convoy arrives to the area of 39 Corps, it would release a number of trucks by request of the 39th Corps, the rest of the convoy would continue, come the 21st Corps, we would take a number of trucks which were assigned to us, the rest of the convoy would continue to Lika Corps. And along the way prior to coming to us, I assume they would also release some of the trucks along Bosnian route.

Q. When you say the Bosnian route, can you be more specific about --

A. Meaning the supplies to the army of Republika Srpska.

Q. And how do you know that?

A. Well, the manifest which would -- well, I have to clarify something to the Court here. Along all these major arteries, there was always a number of checkpoints manned by the police and the military. One of those checkpoints was in the vicinity of my post, which was very close to the UN. The reason why I frequented that particular point was because ¹²³⁴⁵ I didn't want too much of a harassment to the UN, so I tried to prevent that. At one particular instance I was there when a convoy actually arrived, they had a manifesto with them which showed that the convoy started with 30 trucks but at the time when they arrived to this particular checkpoint, they had probably around 15 trucks within the convoy, which is natural to assume that the 15 had been left behind at different stages of the route.

Q. Now, in your answer to a question a few minutes ago, you used the word "Zila Kucavica." Can you please translate that for the Chamber.

A. Well, it's "jugular vein," really. If you cut that one off, the life is gone. Given kind of a poetic description of this corridor, which if you cut it off, the life would simply die in RSK.

Q. Based upon your observations of these convoys during your time with the 21st Corps, are you able to estimate for the Chamber what percentage of weapons used by the 21st Corps were supplied from the Yugoslav army at that time?

A. To be very conservative, I would place that 80 per cent of the weaponry was supplied from Yugoslavia.

Q. During your time in the 21st Corps, were you ever aware of joint operations between the ARSK and the VRS, the army of the Republic of Srpska?

A. Yes, on a number of occasions.

Q. You can you describe some of those for the Chamber now.

A. Usually during the attacks on the Bihac pocket against the 5th Corps of the Bosnian army. The area of Bihac pocket was surrounded by the ¹²³⁴⁶ five corps. Three of those corps were from RSK and two corps from Bosnia, meaning Republika Srpska; 1st Krajina Corps and the 2nd Krajina Corps from the VRS, 39th Corps, 21st Corps, and the 15th Corps from RSK army.

Q. Based upon your knowledge of standard operating procedure and your actual experience in the 21st Corps, can you describe for the Chamber at what level that type of coordination would have to be decided at.

A. It had to be decided at the level of the General HQ in Belgrade. That was not a simple action. It required a lot of coordination and preparation.

Q. Were you present in 1995 at a parade in Slunj in which VRS military equipment was displayed in a parade of which one of the participants was the 21st Corps?

A. Yes. I attended that particular ceremony.

Q. I will ask you about that ceremony in greater detail later in your testimony. Could I ask you to describe what significant pieces of military equipment were present that you recognised as being from the VRS.

A. A large number of the rocket systems that came, including the multi-rocket launchers, Luna rockets, were actually convoyed from Bosnia or Republika Srpska into RSK for this specific purpose. They were brought in in the morning and they left Krajina the same day, in the afternoon, after the parade.

Q. I want to go back and ask you one more question regarding the convoys. During your experience with these convoys, did it ever come to your knowledge whether the manifests that you've described for us falsely described the contents, the actual contents of the trucks? ¹²³⁴⁷

A. Well, on a number of occasions when, for example, it would declare as being humanitarian convoy. It would contain purely military elements in it, like ammunition or additional automatic weapons and stuff like that.

Q. During your time serving with the 21st Corps, were there other members of the Yugoslav army assigned to work there on a temporary basis?

A. Within the RSK?

Q. Yes.

A. Well, apart from the JNA officers, not any particular units.

Q. Can you describe the approximate number of JNA officers that were assigned to work in the ARSK on a temporary basis?

A. I would put it down to a full hundred per cent.

Q. So is it your testimony that all of the officers in the army of the Republic of Srpska Krajina were actually active members of the Yugoslav army?

A. Absolutely.

Q. And how long would be the average stay of one of these officers before returning to the Yugoslav army?

A. The minimum was a six-months tour.

Q. During the course of your time at the 21st Corps, did you come to know some of these officers?

A. Oh, yes, on a daily basis.

Q. And would it be fair to state that their places of residence were from throughout Yugoslavia, not simply the Krajina?

A. Oh, yes. Mostly would be actually stationed in Belgrade ¹²³⁴⁸ originally, but there were people from Krusevac, from Nis, Dragojevac; all the places down further south in Serbia.

Q. Did these officers receive any enticements or extra benefits by virtue of their service in the ARSK?

A. Apparently, yes.

Q. Well, can you tell us how you know? If you know what enticements they received, how do you know it?

A. Well, let's start with being highly paid compared to the officers of the RSK army, which were promoted by Knin, not to mention that all of these people, officers, decided to stay longer than six months would be virtually guaranteed to receive the key to an apartment upon their return to Belgrade, or to wherever they came from.

MR. GROOME: I'm going to now ask that the witness be shown Prosecution Exhibit 348, tab 5. I'd ask that the Serbian original be placed on the overhead projector and be placed in such a way that Mr. Lazarevic can see the signature on the second page.

Q. Mr. Lazarevic, I'd ask you to take a look at that document and ask you: Do you recognise the signature of the person who signed that document?

A. Yes, I do.

Q. And who do you recognise that signature to be?

A. Major General Mile Novakovic.

Q. And are you familiar with his signature?

A. I have seen it frequently enough.

JUDGE MAY: Mr. Tapuskovic, yes. ¹²³⁴⁹

MR. TAPUSKOVIC: [Interpretation] I would like to caution about one thing. This document originates from 1994, and the Prosecutor has, all the time until now, been talking about 1995, as well as about events from 1992, and later he did not continue to deal with documents related to the Croatian indictment after 1991. We have been examining documents related to events after 1992, including this one, which is from 1994.

JUDGE MAY: Yes. Go on.

MR. GROOME:

Q. Have you read this document?

A. Yes, I have.

Q. Can you please describe for the Chamber what this document is, and describe its import to us.

A. This has to do with new recruits for the army from the RSK. A number of young people, by the time they reach 19, because in Yugoslavia we always had a compulsory national service, they would come of age when they're supposed to do their national service. Now, this particular document will give the number and the area from which these people are supposed to come from and go to. The suggestion by the General HQ of Belgrade was to keep them in the area simply for two reasons: One, we need the manpower in uniform, with weapons. We can train them on the ground in real combat situation and instead of having 18 months of national service, we would cut it down to nine months, because it will take like double time in value.

Q. And am I correct in stating that that document memorialises the ¹²³⁵⁰ fact that a person would receive credit for their service in the ARSK throughout Yugoslavia?

A. No, not from this document, no. But this is a general consensus. It was always like that in wartime. Any time that you spend in war is counted as double time towards your pension, or in this instance, towards your national service.

Q. Thank you. I want to now ask you about the state security service in the Republic of Serbia. You've already mentioned Mr. Stanisic. I want to ask you: Were you aware -- become aware that Mr. Stanisic was present in the RSK at any time you were there?

A. Yes. I think I had the opportunity to meet the gentleman on two or three rather informal occasions in Knin.

Q. And were you aware that he was present in relation to a dispute between Mr. Babic and Mr. Martic?

A. Yes, indeed, and I believe that particular meeting with Mr. Stanisic came from Belgrade carrying specific message from Mr. Slobodan Milosevic to Mr. Babic.

Q. And how do you know that?

A. From a general discussion with the people attending this particular meeting.

Q. Now, in addition to the times that you met Mr. Stanisic informally in the Krajina and this meeting that you've just described for us, did you also become aware of other times that Mr. Stanisic was present in the Krajina from your conversations with other officers?

A. Toso Pajic would be the one, for example, to tell me that "Daddy ¹²³⁵¹ was here yesterday" or "Daddy is planning to come next week" or something like that. But since I was not a part of the police force, I never attended those meetings, but I'm pretty certain that Mr. Stanisic did come reasonably frequently to Krajina.

Q. As best you're able, can you approximate for the Chamber the first time you became aware Mr. Stanisic was present in the Krajina? And tell us the period of time -- or in other words, the last time that you were aware he was present in the Krajina.

A. That would be very difficult for me to say. I know at the beginning those visits were more frequent, I think probably due to organisational problems than anything else. At a later stage, Mr. Stanisic had his deputies, or his right hands, or whatever you want to call them, who were actually present on a daily basis within the RSK.

Q. Now, when you say "the beginning," can you give us what time period you're talking about?

A. I would place that early 1990 through 1991.

Q. Did there ever come a time when Mr. Toso Pajic showed you a document from Mr. Stanisic regarding cooperation with Fikret Abdic?

A. Yes. It was a time when, for unknown reason to me, Fikret Abdic and Belgrade have reconciled. And the letter which arrived from Belgrade, not only through Stanisic, through Toso Pajic also, through the military channels, was to establish a good neighbourly cooperation with Abdic's forces, which were actually boarding with the 21st Corps area.

Q. Were you personally opposed to this cooperation?

A. Yes, I have. Not only me, but a number of officers were opposed ¹²³⁵² to it.

Q. Now, just to be clear: Fikret Abdic is a Bosnian, a Bosnian Muslim, who at some point entered into an alliance with members of the Serb Krajina; is that correct?

A. That is correct.

Q. Mr. Frenki Stamatovic, do you know that person?

A. Yes, I have met the gentleman also on a number of occasions.

Q. Can you please describe for the Chamber who he is.

A. Mr. Stamatovic was also, for some unknown reason to me -- it's also spelled sometimes Simatovic and Stamatovic. I know him as Stamatovic, some people know him as Simatovic, but it's one and the same person, in any case. He was actually in possession of our former HQ in Petrova Gora. That's when he formed his own HQ with the special forces of the police from Serbia.

Q. Can you describe what knowledge you have about these special forces?

A. Special forces were deployed in our area prior to establishment of a new HQ on the Bosnian side, in the vicinity of Velika Kladusa, code-named Pauk, meaning "spider."

Q. These special forces, did they wear a particular emblem to identify themselves?

A. Yes, a very distinguished-looking emblem, different to the regular RSK. It's an upside down sword with a Serbian flag beneath.

MR. GROOME: Your Honour, the next exhibit I'd ask that the witness be shown is a photograph of an insignia. I would ask that a new ^{12353 BLANK PAGE 12354} number be assigned and that we designate it tab 1, as I expect that there will be additional insignias introduced during the course of the trial.

THE REGISTRAR: Your Honours, this will be marked Prosecutor's Exhibit 349.

MR. GROOME:

Q. Mr. Lazarevic, I'd ask you to take at look at what is now on the overhead and has been marked as Prosecution Exhibit 349, tab 1. Do you recognise what is depicted in that photograph?

A. Yes. It's a shoulder patch on uniform of the special forces of the police from Serbia deployed in RSK.

Q. And would members of this special forces unit attached to Frenki Stamatovic uniformly wear this identifying patch?

A. Yes.

MR. GROOME: I'm finished with that exhibit. Thank you.

Q. Are you familiar with a person by the name of Colonel Bozovic?

A. Yes. I have had the displeasure of meeting this gentleman only once, but I have seen him frequently.

Q. Can you describe for us who he was and what unit he belonged to?

A. He belonged to unit from MUP Serbia, Ministry of Interior Affairs of Serbia. His rank was colonel. A very short-tempered, very interesting person. I have met him on a number of occasions within the HQ of the 21st Corps in discussion with Colonel Bulat. Once when I had a meeting with him personally, it did not end very happy.

Q. Can you approximate for us the period of time when you would see him regularly in the 21st Corps? ¹²³⁵⁵

A. From 1993 to 1995.

Q. And the times that you would see him, would he be wearing the patch that you've just pointed to as Prosecution 349, tab 1?

A. Yes, and would also carry a rank of colonel on his shirt pocket.

Q. I want to now ask you about what, if any, knowledge you have regarding Mr. Arkan. Do you know who Arkan is?

A. Mr. Zeljko Raznjatovic. Yes, I'm familiar with the person.

Q. And can you describe whether or not you actually met him, and describe for us the circumstances of that meeting.

A. Well, it was early 1992, in Hotel Topusko. JNA officers had a meeting how to alleviate the problems of the war, which, by signing all these differences per agreement, came to resemble the normalcy, how to improve the living standard in the area. During this particular meeting in Hotel Topusko, Mr. Raznjatovic walked in with three or four of his bodyguards and created a very unhealthy atmosphere by attacking these officers, saying, "You should be going out and fighting instead of planting trees." And you can tell, by looking at the faces of the people, they were actually afraid of him.

Q. Were you aware of any connections that Arkan may have had with the state security service of the Republic of Serbian MUP?

A. Yes. Well, Raznjatovic had a number of arrest warrants throughout Europe that I was familiar with, and yet he was never arrested in Yugoslavia, on request by the Interpol. So he was well protected in Yugoslavia.

MR. GROOME: Your Honour, that might be a good place to break, if ¹²³⁵⁶ the Chamber is considering a break at 11.00.

JUDGE MAY: Yes. We'll adjourn there. Mr. Lazarevic, in this adjournment and any others there may be during your evidence, please don't speak to anybody about your evidence until it's over. That does include the members of the Prosecution.

THE WITNESS: Yes, Your Honour.

JUDGE MAY: Thank you. Would you be back, please, at half past.

THE WITNESS: I will do so.

--- Recess taken at 10.59 a.m.

--- On resuming at 11.31 a.m.

JUDGE MAY: Yes, Mr. Groome.

MR. GROOME:

Q. Mr. Lazarevic, we ended this morning's session with you describing what you knew about Arkan. Are you able to describe for us what, if any, relationship Arkan's group, Arkan's Tigers, had with the army of the Republic of Serb Krajina?

A. Well, Arkan's forces were deployed in the Pauk HQ and were then put with the MUP of Serbia and the members of the 21st Corps.

Q. I'm going to ask you a number of detailed questions about this Pauk unit later in your testimony, but could you, in a sentence or two, describe for the Chamber: What was Pauk?

A. Pauk was an HQ established on the Bosnian side which the 21st Corps totally disclaimed as being part of us, which would allow for the members of the 21st Corps actually to go and fight against Bosnian 5th Corps on the Bosnian territory. ¹²³⁵⁷

Q. Now, this Pauk unit, can you tell us what units were combined to make this Pauk headquarters?

A. Yes. The members of the 21st Corps, officers and fighters; the members of Abdic's own forces; the members of Arkan's Tigers; and the members of the special police from Serbia.

Q. Now, during your observations or your knowledge of what occurred in Pauk, did you see Arkan's Tigers and members of the 21st Corps cooperating?

A. Oh, yes, indeed.

Q. I want to draw your attention to an incident in a bar. Were you present in a bar when an incident arose with some of Arkan's Tigers?

A. Well, we're talking about a UN bar which was specifically for the UN members. The duty officer of the UN HQ came to my hut, it was late at night, like 1.00 or 2.00 in the morning, and told me that they have a problem with some Serbian soldiers. Me thinking probably, you know, when he says Serbian, meaning the RSK, I put a uniform on and brought in a jeep, went into the bar to find four members of Arkan's forces in there having drinks and taking cartons of cigarettes and refusing to pay for it.

Q. How did you know that they were members of Arkan's group?

A. By their uniform.

Q. And what did you do after arriving at this UN bar?

A. Well, the only possible thing I could do - because I couldn't deal with them - so I went back to the nearest phone and called my own HQ and asked for Colonel Bulat to be brought to the phone.

Q. Prior to calling Colonel Bulat, did you attempt to resolve the ¹²³⁵⁸ situation by speaking to these members of Arkan's Tigers directly?

A. They're the kind of people you don't talk to.

Q. And were you able to contact Colonel Bulat?

A. Yes. Within about ten minutes they woke him up, he spoke to me briefly. I told him what problem I had, or rather, what the UN had, and he said to remain in vicinity and somebody will come there and fix it.

Q. I just remind you, if you could slow down the pace, as an aid to the interpreters.

A. I do apologise again.

Q. After speaking to Colonel Bulat regarding this problem, what, if anything, happened?

A. Well, about 30 minutes after I have concluded my conversation with Colonel Bulat, a jeep arrived, and in the jeep was a Colonel Pejovic, who was Arkan's colonel, with probably three or four members of his, I assume, MPs. I briefly explained what happened, he walked into the bar. I was following behind. He walked up to these four soldiers that were creating this disturbance. They stood at attention, he slapped each one of them so hard he actually brought them down to their knees. And the other MP just picked him up and took him out of the bar. I have never seen him again.

Q. Based upon your observations regarding this incident, did you conclude that Colonel Bulat had been in contact with Colonel Pejovic?

A. Yes. Actually, I came to understand he was in contact with Pauk HQ.

Q. Now --

JUDGE ROBINSON: Sorry. Do you mean to ask whether he was in ¹²³⁵⁹ contact before he came to the bar?

MR. GROOME: No, Your Honour. Perhaps I'll try to clear it up with this question.

Q. The question I was asking you, Mr. Lazarevic, was: Do you know how Colonel Bulat was able to have Colonel Pejovic and some other members of Arkan's men come to the bar to deal with the situation?

A. There was a direct telephone line in Colonel Bulat's office with Pauk.

Q. And Pauk was the joint command that you described for us that included Arkan's men?

A. Yes, sir.

Q. Now, did there come a time that you were present with the RSK Minister of Defence, Mr. Dusan Rakic, when you came to have a meeting, or Rakic had a meeting with Arkan?

A. Yes. I was a personal escort to Minister of Defence at the time, Admiral Rakic.

Q. And can you describe where this meeting was.

A. It took place in Erdut.

Q. And who else was present at this meeting?

A. I still believe that it was a chance meeting, because we were driving through -- we had a meeting in the sector east with the sector commander there, but as we were driving through Dalj, passing the petrol station, and there was a diner within the petrol station, I believe belonged to Mr. Raznjatovic, minister asked to stop the car because he saw Arkan there and the gentleman by the nickname of Badza. ¹²³⁶⁰

JUDGE ROBINSON: What did your job as personal escort entail?

THE WITNESS: Well, I was to translate for the Minister of Defence in his meeting with UN sector commander of sector east.

JUDGE ROBINSON: Thank you.

MR. GROOME:

Q. Now, this meeting, you've mentioned a person by the name of Badza, Arkan, and Minister Rakic. Was there anybody else present?

A. A number of Arkan's men were in the restaurant, obviously.

Q. This person you've referred to as Badza, do you know his real name?

A. I believe it's -- he was a high-ranking police official from Serbia, and his name was Stojkovic or Stojilkovic or something like that.

Q. Now, before I continue with your testimony, I'm going to ask that you return to the exhibit that is on the overhead, Prosecution Exhibit 348, tab 1. And if I could -- while we view on our monitors, I'm going to ask you to take the pointer. I'm going to ask you to describe now the relationships between the different people that you've testified about. And before I do that, I want to ask you about this exhibit. Is this exhibit based upon a sketch that you drew describing the relationships between the people named in this diagram?

A. Yes, it is.

Q. I'd ask you to begin with the green box on the right marked "JNA/VJ." Could you please describe for us the different relationships between the people.

A. The green box has a heading of JNA or VJ because the Yugoslav army ¹²³⁶¹ changed its name to Vojska Jugoslavije later on. At the General HQ Main Staff, you have General Momcilo Perisic. And then you have your KOS command, you have two strains; one to the left is internal security, or the sector north RSK, Colonel Petar Surla and Colonel Mlado Karan. On the right-hand side, you have external security of the KOS, Colonel Nikola Zimonja. Following down, you go to General HQ in Knin, with General Celeketic and General Mile Mrksic connecting straight to the 21st Corps at which head is the commanding officer Colonel Cedo Bulat, and then you have me, C-001 here, being a liaison officer to Colonel Bulat.

Q. Now, you say connecting to Colonel Bulat. What does the line connecting to Colonel Bulat indicate?

A. There's a line that goes on both ends. If you follow to the left, you go straight to General HQ, and to the right goes to the internal security. And from internal security to actual General HQ.

Q. Now, just so the record is clear, C-001, was that the code-name that you believed you would be testifying under here today?

A. Yes.

Q. So any reference to C-001 is really a reference to yourself; is that correct?

A. That is correct.

Q. Now, underneath your C-001, there are three names that are bracketed and that there's a line connecting them. Can you please describe what that line represents.

A. That's the infamous anti-terrorist unit at which head was Colonel Pero Ajdinovic. Below that, you have the name of Sinisa Martic, with the ¹²³⁶² nickname Paraga, and one of the fighters, Jovo Vojinovic, who became my personal friend during this time. And you can see the line going straight up to the internal security of KOS.

Q. And what does the fact that the box for the 21st Corps, that fits wholly within the box for the JNA/VJ. What does that indicate?

A. It indicates it's one and the same.

Q. I'd ask you now move to the blue box to your left, marked "SDB Serbia." Can you please describe the relationships depicted in that part of the diagram.

A. At the head of the SDB Serbia at the time was Mr. Stanisic, Jovica. His direct assistants were Frenki, also known as Simatovic or Stamatovic, followed by Colonel Ulemek, or Legija, and Colonel Bozovic. And then within the circle you also see Mr. Toso Pajic was the chief of police and liaison officer of the RSK, and his direct line goes to the SDB Serbia Mr. Stanisic, and RSK MUP, Minister of Internal Affairs, also Milos Pajic, head of state security. And all connected directly to Jovica Stanisic.

Q. Now, the centre of the diagram is a yellow box with the word "Pauk HQ Bosnia." Can you please describe what the lines connecting that box to other parts of the diagram indicate.

A. Well, the yellow box you could also see is directly connected to the 21st Corps, also to the Arkan's forces, which represented by Colonel Pejovic and Captain Sarac, and again directly to Colonel Bozovic, Colonel Ulemek, Stamatovic Frenki and Jovica Stanisic along the line there. At the head of the HQ in Pauk is Major General Mile Novakovic, Fikret Abdic's ¹²³⁶³ forces, 21st Corps under Novakovic. So actually, when you look at it, it's all well connected.

Q. Thank you. I'm finished with that particular exhibit. Now, Mr. Lazarevic, during the time that you spent in the 21st Corps, did you become aware of a policy regarding the Croat population in the area of responsibility in the Kordun area?

A. As a matter of fact, when I came to the area of the 21st Corps, which, as I said before, was the December 1991, most of the Croats were no longer in the area. There were some isolated pockets and small villages that still had some inhabitants, mostly elderly and sick. Talking to the other members of the corps and from my first-hand knowledge of the things there, the policy was to get as many Croats as possible out of the territory.

Q. Was there a difference of opinion between certain elements, Serb elements there, regarding how this should best be accomplished?

A. In my meetings with Colonel Ajdinovic and Colonel Zimonja, for example, when we discussed this as being a problem, there were two different approaches to the problem. One was a more violent one, which was suggested by Colonel Ajdinovic, and that was just, you know, eliminate them, kill them all and be done with it. Colonel Zimonja was for a more diplomatic approach: Have them leave the area under protection of JNA.

Q. And both of these men, with this difference of opinion, were both members of Yugoslav army KOS division?

A. Yes, sir. Two different strains, though.

Q. When Ajdinovic advocated this killing of Croats, was he referring ¹²³⁶⁴ to Croat soldiers or was he referring to the Croat civilian population?

A. Saying "Croats" meant to me anything that is Croat, whether civilian or military. What you have to take into consideration, there were no military elements within the RSK or the Croatian army, there were only civilians remaining behind, so if he said Croats, he meant the civilians.

JUDGE ROBINSON: Mr. Groome, let him explain his reference to two different strains, the two colonels --

MR. GROOME: Yes, Your Honour.

JUDGE ROBINSON: -- of the JNA but of different strains.

MR. GROOME:

Q. Can you remind us about the two different elements of KOS and describe that again for us.

A. Colonel Ajdinovic representing the internal security, dealing with internal security matters of the country; and Colonel Zimonja dealing with external elements, meaning emigres, people like that, outside of the country.

Q. Can you give us an example of a typical task that would be assigned to the external branch and a typical task that would be assigned to the internal branch, to help us understand the distinction between the two.

A. Well, the external part, which is also known as the intelligence part of the KOS, was dealing with the potential threat against Yugoslavia outside of Yugoslavia; whether it's in Canada, Australia, Great Britain, or whatever, in the world. Ajdinovic's side, or internal security, as the ¹²³⁶⁵ name implies itself, any danger to Yugoslavia within the border of Yugoslavia.

Q. You've described at the beginning of your testimony certain work that you performed in Great Britain and in Australia. Would members of Ajdinovic's branch be assigned to those types of tasks?

A. Certainly not.

Q. Now, during these discussions regarding what to do about the Croat population, were there ever any representatives of the Serbian DB present, such as Toso Pajic or others who you've described earlier in your testimony?

A. Well, it was considered to be a general problem for the sector that we were in, so you had police members present there, also the members of the DB, namely, Mr. Toso Pajic and Djuro Skaljac would be attending those meetings.

Q. Can you characterise for us their approach to this problem of the remaining Croat population?

A. Well, both of them were people from the area, so they were deadly against using of force because, I don't know, maybe they anticipated in the future they would live with them again as neighbours or whatever the case might be, so they didn't want anything really, really bad to happen to these people.

Q. Now, did part of this policy also include the suggestion that some Croats be permitted to remain in the area?

A. Generally, there were three reasons why those people were still in the area. First, and the most important as far as the 21st Corps was ¹²³⁶⁶ concerned, was the public relation part of it, meaning if any of the foreign organisations like ECMM or International Red Cross wanted proof that the Croats were still living in the area, they not had all been exiled, not all been killed, I would take him, with the other members of the delegation, to those villages and show them the living people there. That would be one reason.

The second reason, that was to deal with the internal security. If things were too calm, internal security had, of course, had a reason where and how to create the problem which would escalate into breakage of ceasefire agreement, for example.

And the third one, last but not least, it was always a source of the civilians for exchange with the Croatian side for the Serbian civilians.

Q. I'll ask you to tell us a bit more about the second reason. And you've testified that the presence of these people were essential in order to escalate into a breakage of a ceasefire agreement. Can you please describe in greater detail what you mean.

A. Well, I have personally attended 27 meetings with the Croatian military side in Turanj crossing area, which is a point between Karlovac and Vojnic, where we have signed a ceasefire agreement which most of them would be broken before the ink got dry on the document. If I were to put the ratio of those things, probably 4:1 Serbs versus Croats. So for every four broken, one would be a Croatian broken one. Having people along the Kupa River -- I know whether the Court is aware, the Kupa River is a natural border between the RSK and Croatia. It's a heavily mined area, ¹²³⁶⁷ virtually impossible to penetrate. So those villagers living there, as I said they would be used -- in one particular instance, an elderly couple was murdered, really, on the pretext that they were giving signals to the Croatian forces across the river by a small candlelight in the window.

Q. Were you called upon to go to the scene where this elderly couple had been killed?

A. Yes, because the complaint came through ECMM and I had to lead a number of ECMM members to the area and that was the first time I went there myself. We observed the position of the window, the vicinity of the possible observant from the other side, from the Croatian military side, and it was really impossible for anybody to see a candlelight in the window at a distance of two kilometres

Q. Did there come a time when you came to learn who was responsible for the murder of this elderly couple?

A. Yes. A gentleman by the name -- and I use "gentleman" very freely in this context, Jovica Vojinovic.

Q. And what unit did he belong to?

A. To the unit led by the Colonel Ajdinovic, known as anti-terrorist unit.

Q. And how did you come to learn that this man was responsible for the murder of this elderly couple?

A. We became kind of friends after a while. Mr. Vojinovic had a wife who was a Croatian national living in Karlovac and he always pleaded with me to try to get her exchanged so she can come and live with him in RSK, which eventually I succeeded in doing. So he always felt that he owes me ¹²³⁶⁸ a lot and he always presented him -- presented me to his friends as being somebody very important in that respect, that I can help them with their families. So they kind of liked me, they get close to me, and this is when I would hear all these different stories or things being admitted personally by some of the members of the anti-terrorist unit.

Q. And in case it's not clear from the record, what was the ethnicity of this elderly couple?

A. They were Croatians.

Q. And did he tell you what his -- did he tell you whether he was involved in the murder of this couple?

A. Well, he claimed that he personally threw them into the well.

Q. Now, prior to asking you about a number of events, I'm going to ask that a map be placed on the overhead projector. It is page 20 of the map book that the Chamber has. This particular copy I would tender into evidence, under the regime that was established by the Chamber last week, as 336.SL, the initials of the witness. This copy does have some markings that he has made on it that I believe will be of assistance to the Chamber as he testifies about certain events.

JUDGE MAY: I'm sorry. I'm not sure I'm with the suggestion of how we deal with this. It's in the map book, which we have.

MR. GROOME: This is a photocopy of page 20 from the map book.

JUDGE MAY: Yes. What are you proposing? How are you proposing we exhibit it?

MR. GROOME: That it be given the number 336, which is the map book, ".SL" to indicate it's a copy of the map book that this witness has ¹²³⁶⁹ marked on.

JUDGE MAY: I don't know if that's the most convenient way of dealing with it. It may be more simpler to give these various additions to 336 numbers. I don't know if we've given -- I don't remember us dealing with this before.

MR. GROOME: We didn't deal with it regarding maps, but we did deal with this issue regarding I believe it was a photograph, and I had suggested to the Chamber that I would be asking different witnesses to mark up copies of the same photograph, and this was the regime that was established.

JUDGE MAY: Very well. We'll do that.

MR. GROOME:

Q. Mr. Lazarevic, I'd ask you to take a look at a copy of page 20 of 336, and I would ask you to first point out the original headquarters of the 21st Corps, Topusko.

A. Well, that tiny little dot there is Topusko.

Q. And where was the location of the office of the liaison officer of the 21st Corps?

A. On the top of the hill just above the hotel in Topusko.

Q. I'd ask you to indicate for us where Vojnic is, the third and last headquarters for the 21st Corps.

A. Just here.

Q. And you have marked that in your handwriting on that photocopy of the document?

A. That is correct. ¹²³⁷⁰

Q. Can you please show us where the Serbian MUP headquarters was located.

A. Located in Petrova Gora, which is here, and also they had their -- part of their HQ inside Bosnia, where the Pauk was, which is about here. It was like a split command between these two points.

Q. And I will ask you later in your testimony about a parade held on St. Vidovdan Day, June 28th of 1995. Can you indicate on the map where that parade or celebration was held?

A. In the town of Slunj, just here.

Q. And have you marked that in your own handwriting on this copy of the map?

A. Yes, I did, sir.

Q. Now, you've told us about the Kupa River. Is that river visible on this map?

A. Unfortunately, it did not come through, but the line should go approximately like this.

Q. And is that the line --

A. This particular line, as I stated before, it was a kind of natural frontier between Croatia and the RSK, and our side of the Kupa River was heavily mined. And then you had a few of these little villages. Unfortunately, on this map they're not marked. But they're between Popovic Brdo, which is here, all the way down to Gornji Sjenicak, Sjenicak Lasinjski, and there's a number of small villages in between.

Q. Of the locations that you have marked on Prosecution Exhibit 336.SL, which of these are in Croatia? ¹²³⁷¹

A. Can you repeat the question, please?

Q. Of the locations that you have marked, can you tell us which ones are actually in Croatia?

A. All except Pauk.

Q. And where is Pauk located?

A. Right here.

Q. Thank you.

MR. GROOME: I'm finished with that exhibit.

Q. Mr. Lazarevic, the first event that I want to draw your attention to is in 1990, and it is regarding a log barricade. Did you ever have occasion to be present at a log barricade?

A. Yes, I have. Out of curiosity more than anything else.

Q. Can you describe for us approximately where this barricade was erected.

A. It was in one of the roads leading to Knin area. It was back in 1990. I took a car and drove down with my wife. As I said, I wanted to see for myself what is it all about. I came to a number of felled trees positioned on a road that you actually had to drive like in a zigzag sort of thing, you can't go straight through, and there were a number of people standing at those barricades. They were not dressed in uniforms; however, they were armed, they had automatic weapon with them. Along both sides of the road there were a number of cars and trucks parked, which I had observed that some of them had Belgrade number plates on them, and also some of the trucks had JNA number plates on them. Me being a Serbian, I stopped there and I talked to the people and it was painfully clear that ¹²³⁷² those people actually come from Belgrade by the accent and by the general lack of knowledge of the area.

Q. Was the barricade that you witnessed, or you stopped at, was that part of what was purported to be a spontaneous event popularly known as "the log revolution"?

A. That's what it appears to be. How spontaneous, I don't know.

Q. After -- let me ask this question first: Did you speak to some of the men manning the log barricades?

A. Yes, I did.

Q. And did you speak to them about where they were from?

A. Yes, I did.

Q. Can you give us some idea of the percentage of people at the barricade that you stopped at were local, from the area, and how many were from outside the area?

A. I would safely place that percentage at around 75 to 80 per cent outside the area, meaning either from Belgrade or elsewhere.

Q. Now, after visiting this particular barricade, did you have a conversation with Colonel Zimonja about the log barricade?

A. Yes, I had, and he laughed the whole thing off, saying that the most of the people manning the barricades are actually from Belgrade, they were engaged over there. And according to Colonel Zimonja, they were paid 100 Deutschmarks a day for tending those barricades.

Q. Now, during this period of time in 1990, were you -- or did you form a company that engaged the services of Serbian interpreters?

A. I have formed a company, was the only employee within it, so no ¹²³⁷³ other interpreters within the company.

Q. And can you please describe for the Chamber the circumstances under which you formed this company.

A. It's a kind of long story, involved Mr. Abdic as well.

Q. Well, from where did you receive the financial backing to form this company?

A. Part of it came from the black funds of Colonel Zimonja.

Q. And what was the name of this company?

A. YUIntra. It was kind of made from Yugoslavia Interpreting and Translating, YUIntra.

Q. And perhaps at this stage, would you just give us an idea of what was the purpose of setting up this company generally, and we can ask more specific questions later, if necessary.

A. Well, Colonel Zimonja believed I had a bona fide reason for staying in the region after losing the job with Agrokomerc. They needed me there. So the only thing -- I mean, Agrokomerc was the only employer in the area, so to stay there, there was a need to form something that would keep me there. So the company was the simplest solution.

Q. And was the purpose of your remaining in the area to continue your work with KOS?

A. Absolutely.

Q. Now, I want to draw your attention now to the early summer of 1991 and ask you whether during that time period Colonel Zimonja asked you to attend a meeting in Vojnic.

A. Yes. ¹²³⁷⁴

Q. Can you first begin by telling us who else attended that meeting.

A. A message came through a civilian person for me to go straight to Vojnic. Vojnic is only about 15 to 17 kilometres away from Velika Kladusa, where I was at the time. When I arrived there, the meeting was held at a local police station, in the office of Mr. Toso Pajic. The other persons which I remember distinctly were Djuro Skaljac, Colonel Ajdinovic, Colonel Zimonja, and probably another two or three police officers which I don't really remember their names.

Q. The police officers whose names you cannot remember, were they local police officers or from outside the area?

A. They were not local police officers.

Q. Were you able to tell whether they were from somewhere in the Krajina or from some other part of Yugoslavia?

A. Actually, they have never taken place in the discussion, they never talked, they were just there observing, I guess.

Q. Now, can you tell us, in general terms, what was the topic of discussion at this meeting?

A. Well, I was to describe the general situation in Velika Kladusa area, because the JNA contemplated an attack on a town called Cetingrad, which is just outside of the Bosnian border on the Croatian side, probably about two to three kilometres.

Q. What was occurring in Cetingrad at this time? Was there armed conflict going on there at the time?

A. Not at the time, no. But there was a very strong presence of Croatian emigres from Sweden organising the HDZ, the political, and some ^{12375 BLANK PAGE 12376} paramilitary, according to the intelligence report given by Colonel Zimonja.

Q. Were different proposals for an attack on Cetingrad discussed at this meeting?

A. Yes. There were two suggestions, and both of these suggestions were forwarded to General HQ in Belgrade to make a final decision. One proposed by Colonel Ajdinovic was to encircle the whole town, and then use the artillery, saturation bombing, and then just come in with a force and clean out the city. That was one.

The other one, proposed by Colonel Zimonja, who was more interested in intelligence part of it, he wanted to leave a little corridor open between Cetingrad and Velika Kladusa for people to be able to leave the area prior or even during the artillery attack.

Q. Prior to this discussion about Cetingrad, were there any actual incidents, that you are aware of, of paramilitary fighting coming out of the town of Cetingrad?

A. No, not prior to the JNA attack.

Q. When was it that the JNA -- or did the JNA attack Cetingrad, and when was that?

A. Eventually, they did. It was in October. I was in Kladusa with other people from Kladusa, observing the actual -- you know, the lights in the sky from the artillery shelling, and immediately after the attack has started, the influx of refugees from the Croatian city of Cetingrad started arriving to the Bosnian city of Velika Kladusa.

Q. And was it clear to you, by the nature of the attack, which one of ¹²³⁷⁷ the alternatives or proposals had been adopted for the attack?

A. It was rather obvious that the suggestion of General -- I'm sorry, Colonel Zimonja was accepted, because there was a corridor open for these people to leave through.

Q. Now, based upon standard operating procedure and your experience of the 21st Corps, at what level would the decision have been taken regarding which proposal to implement?

A. It would have to be on the level of General HQ in Belgrade. We also have to remember, at the time it was still official JNA as a force on the ground.

Q. Now, I want to draw your attention to December of 1991 and ask you whether you were assigned to a specific task regarding two brothers by the name of Brajdic.

A. Yes, I have. I have -- as I said, I attended a number of meetings in Vojnic in that particular period. Quite frequently, actually. On one of these meetings, since the influx of the Croatian in Velika Kladusa was worrying, it was suggested that some of these more prominent figures on the Muslim and the Croatian side should be eliminated, and possibly in one attack.

Q. And were you ever assigned to eliminate any of these people?

A. The task was given to me as knowing the area, being there, and two JNA officers. One was a rank of captain, another was the rank of lieutenant.

Q. And who gave you this assignment?

A. Colonel Ajdinovic. ¹²³⁷⁸

Q. And what specifically was your assignment?

A. Well, there's a little coffee-come-restaurant, if you like, in Kladusa called King, and it was to happen on Christmas Eve, on the 25th of December, when all these people would be there, celebrating prior to going to the midnight mass, I guess. And we were to approach from three sides, park the car in the vicinity, approach the restaurant from three sides and open fire from automatic weapon to everybody inside.

Q. Did you carry out this assignment?

A. No, I did not.

Q. And why not?

A. Four or five days prior to the attack, these two officers came to Velika Kladusa fully dressed in JNA uniform, and as I was sitting in one of the coffee bars with a number of prominent Muslims from the local area, they came to me. They were drunk and they were carrying on about me being a great Serb and everybody should respect me for it, and all this will be part of Serbia, and generally they made it very uncomfortable for me. So I refused to deal with them any further after that. I didn't take them to be serious at all.

Q. Now, at this particular time, you are still wearing the uniform and officially associated with the Yugoslav People's Army; is that correct?

A. No, that is not correct. I'm a civilian at the time.

Q. Did there come a time, upon the direction of Zimonja, that you joined the ARSK, the army of Republika Srpska?

A. Yes. That came on the 22nd of December. ¹²³⁷⁹

Q. In what year?

A. 1991.

Q. During your time as a member of the ARSK, did you receive a salary?

A. Well, it was more -- in ARSK, yes, I have received a salary. But there are some additional funds involved as well.

Q. Can you tell us the different sources of funds that you received during your tenure with the 21st -- the ARSK army.

A. It was a general salary given to all the officers and the soldiers of the 21st Corps through the paymaster, and also I have received additional funds directly from Colonel Zimonja for which I have never signed for. In the first instance, yes, I would sign like any other regular officer drawing his salary and signing for it.

Q. In early 1992, did you have a conversation with Colonel Zimonja regarding the fact that the JNA would be pulling out of Croatia and moving troops from Croatia into Bosnia?

A. Well, it was a generally known thing that it is going to happen prior to the arrival of the UN forces on the ground. The general conversation that we had at the time was how to organise people who are leaving behind, who are not leaving with the JNA. Personally, what am I supposed to do there, what is expected from me?

Q. And did he discuss with you what was expected of you?

A. Yes. Actually, his task given to me was to go to the Samarica HQ, which was the HQ of the 8th Operational Group of JNA, led by General Mrksic, and to report to him as his liaison officer for the ECMM. ¹²³⁸⁰

Q. And did you do that?

A. Yes, I did.

Q. And approximately how many times did you work as an interpreter for Mrksic?

A. I would put between February, March, April, probably 20 or 30 times.

Q. Now, continuing in 1992, did there come a time when you were instructed by Colonel Zimonja to attempt to recruit UN and ECMM staff for intelligence purposes?

A. That was part of a daily routine really.

Q. Can you please describe what your understanding of your assignment was.

A. Well, to establish a kind of relationship where it would be easy for me to obtain necessary information, military side of it, through the UN HQ. That would involve, for example, a radio room, personnel with usually after the rank of sergeant, military observers, sometimes not to report what they had seen already, different battalion commanders. Well, really, I mean, anybody who was available.

Q. Can you briefly describe for us the process that you would undertake to recruit somebody working for the UN or ECMM.

A. It would be necessary for me to spend a considerable time with that. It wouldn't happen in a day. I would have to get to know them for two or three weeks, get as close to them as I possibly can, being really friendly, doing all the favours they ask for, approving everything they need, providing escorts for them in the sense of security, so they really ¹²³⁸¹ felt that I'm a part of the team, I'm really helping them out. And at the same time, trying to find the weakest points in each of the members, which can be used for either purpose of a blackmail at some later stage or to exploit at any given time.

I have to tell the Court that some of these people actually readily accepted to work with the Serbian side, some from purely ideological points, they believed in the Serbian cause; some of them for the reason of money; some of them for different reasons. I'm not saying everybody was, you know, possible to buy, but some have been.

Q. Now, did you also receive instruction from Colonel Zimonja to report and track the activities of ECMM monitors?

A. Oh, yes. It was a daily task for me. If there were -- see, at the very beginning, the ECMM were not allowed to sleep over in RSK. They would be escorted in the evening across to and back to Croatia, back to Zagreb, and they would return the next morning. But eventually the green light was for them to stay within the area and I would move in a hotel where they were and I would be there virtually 24 hours with them.

Q. And what was the purpose of you monitoring ECMM personnel?

A. Well, control the movements of the ECMM, meaning more or less they would like to have full independence of movement, which they never really had, because they either would have a military escort or a police escort with them if they're going into the field. I would be there in the sense of monitoring who they talked to, who they stopped, where they stopped, who made telephone calls on their mobile phone in the vehicle they had. So generally, it was just to monitor whatever they do and report, daily. ¹²³⁸²

Q. Would you characterise your work during this period as facilitation or obstruction of their mission?

A. As a sword with two very distinct differences. I was to facilitate as far as allowing them to move freely so I can find out who they get in touch with, and yet make it as difficult as possible for them to see everything they want to see. So there is a part of obstruction and part of facilitating. So it kind of worked hand-in-hand.

Q. Can you give us a specific example of how you would obstruct the work of an ECMM?

A. Let's assume that in the evening they would inform me they need to go to certain specific area the following morning. That is their routine. And during the night, if we didn't want them to go there, we would create a little incident in the vicinity of the place and when they would turn in the following morning and say Can we go there? We would say, No, we can't go there because there is this major ceasefire being broken during the night there and that is out of limit area right now. Things like that.

Q. And the incident that you -- that would be created, who would create it, who would execute it?

A. Well, there was one unit who was responsible for all disturbances there, and that was the anti-terrorist unit.

Q. Did there come a time during this period that you had a conversation with Colonel Bulat regarding this obstruction of the work of the ECMM?

A. Yes. It was very clearly and very specific that they should not be allowed to carry their task, whatever their task was. ¹²³⁸³

Q. And did he indicate to you at whose direction this task of obstruction came from?

A. Well, the obstruction was actually more demanded by Toso Pajic than it was by Colonel Bulat. He was more concerned by the state security than the military itself. All our units were deployed well away from the road, so ECMM driving along the road couldn't see much to report to the Croatian side, yet from a security point of view, the DB was more concerned about who they talked to and who they're dealing with. So it was actually the both sides -- I mean, the DB and the military were concerned about freedom of movement, which is guaranteed to the ECMM and yet it was obstructed by us.

Q. Did Toso Pajic indicate at whose direction he was implementing this obstruction?

A. By Jovica Stanisic.

MR. GROOME: I'd ask now that Prosecution Exhibit 348, tab 6, be placed on the overhead projector.

Q. Mr. Lazarevic, I'd ask you to look at this picture and tell us: Do you recognise the people depicted in it? Can you please describe if you recognise the people who are in the picture?

A. Well, the gentleman with the profile over here, I really can't remember who he was, and I can't see it on the photograph. The gentleman next to him is Colonel Tarbuk, Slobodan, he was the commanding officer of the 39th Corps. The gentleman next to him in the blue beret is Brigadier General Musa Bamayi of Nigeria, who served as a sector commander of the UN. Next to him is chief of staff of the 21st Corps, Colonel Cedo ¹²³⁸⁴ Radovanovic. Then we have Toso Pajic. On his shoulder, you can see the police patch there. And then me as liaison officer. That was one of the meetings within the UN building.

Q. And is that your handwriting?

A. Yes, it is.

MR. GROOME: I'm finished with that exhibit. Thank you.

Q. Now, also in 1992, were you given the task of recruiting interpreters that would be used by international organisations working in the Krajina?

A. It was obvious at the time once the UN moved into the area there will be a number of job openings for the local populace, from interpreters down to the dishwasher or cleaners, whatever the case might be. And it was of interest to us to monitor those working for the UN for the benefit of gathering intelligence through them.

Q. And from whom did you receive this instruction?

A. Again it was a joint operation of the state security and intelligence part of the military.

Q. And can you tell us the names of the people who specifically communicated to you?

A. Colonel Nikola Zimonja and Mr. Toso Pajic.

Q. And can you describe how you carried out this assignment.

A. In official form, a letter was forwarded to the UN HQ in Topusko, saying that if they advertise for the positions there and they have people showing interest for them, they have to be cleared by police to prevent the criminal element of being employed within the UN. So they would like ¹²³⁸⁵ to have our own background check of the people. What we really wanted to know is who is expected to work there so we can get in touch with them first.

Q. And did the United Nations comply with this request to provide the names?

A. Unwillingly, yes.

Q. And what happened after you were provided with the names of these people?

A. I would have a little briefing with them, addressing their inner patriotic thoughts about what they are actually doing, they are doing it for the benefit of their own country, gathering information about military movements, about Croat movements. Because it was no secret that the military observers which would be travelling along the border or the DMZ, the demilitarised zone between Croatia and RSK, would observe also the movements of the troops on the other side. Coming back to the UN HQ in Topusko, they would write their reports and if any of our people could get their hands on that report, great.

Q. Did some of these people take UN reports and provide them to you?

A. Yes.

Q. If one of these interpreters that you approached refused to cooperate in the manner you've described, what would happen?

A. He would be discredited and not be permitted to work for the UN.

Q. Can you describe for the Chamber what percentage of these interpreters do you have first-hand knowledge and first-hand experience with? ¹²³⁸⁶

A. Within the area of the 21st Corps?

Q. Yes.

A. 35 to 40, at least.

Q. And is that all of the interpreters or were there other interpreters that you did not have contact with?

A. Within the 21st area Corps, there were no other interpreters. They had to go through me.

Q. And of those 35 to 40 interpreters, how many were working for you gathering intelligence?

A. All of them.

Q. What would you do with the intelligence information and documents, if provided, that you received from these interpreters?

A. Let me first try to describe very briefly what interpreter's job was there. They would attend the meetings between the local politician, for example, local Red Cross, the UN, and I would have all these other interpreters attending those meetings because I couldn't personally be there. I can't be physically in all those places. So I would have them go and come back and report to me about what was discussed at the meeting, what decisions were made, if any was made, and then I would compile all these reports in one major report which was sent to my HQ. I would do those in triplicate, really, because one was going to Colonel Zimonja, one was going to the HQ Colonel Bulat, and one was going to Toso Pajic.

Q. So a copy of your report was going to KOS in Belgrade; is that correct?

A. That is correct. ¹²³⁸⁷

Q. One of the copies went to Toso Pajic, who you've testified was working for the Serbian DB?

A. Correct.

Q. And then the last one went to Colonel Bulat, who was in charge of the 21st Corps; is that correct?

A. And it was his area of operation.

Q. I want to now move to 1993. Did you have occasion to attend a number of international conferences designed to try to come to some agreement regarding peace in the Krajina?

A. Yes. I have personally attended four of those.

Q. Prior to -- or during your attendance at these international conferences, were you still an active member of KOS?

A. Yes, and active member of the RSK army. I mean, I was part of the command.

Q. Prior to leaving for these conferences --

A. I do apologise.

Q. Please have water or ...

A. It's okay. Thank you.

Q. Prior to leaving for these conferences, were you issued any false identification documents?

A. Yes. I have been issued with three passports. All three would indicate that I was not -- two would indicate I was not born in Belgrade but born in Knin, and one would be an original one with place of birth and date of birth and everything else.

MR. GROOME: At this time, Your Honour, I would ask that the ¹²³⁸⁸ witness be shown Prosecution Exhibit 348, tab 7.

Q. Mr. Lazarevic, before it is placed on the overhead projector, I'd ask you to leaf through the several pages of this exhibit.

A. Do you want me to speak about them as I go through?

Q. I would ask you to select the page where it indicates where you were born, and that is the page that I would ask be placed on the overhead projector. And I would ask you to indicate for us, using the pointer, where it indicates your place of birth.

A. 26th of February, 1947, Knin.

Q. And is that false information regarding your place of birth?

A. Yes. This passport was issued to me on the 21st of June, 1993. You can see that on the bottom of the page, where I'm pointing now. The purpose of this passport was to attend international meetings and prevent anybody asking why is a person from Belgrade attending a meeting that deals with the Krajina? So this shows a passport that says you were born in Knin so you have full right to be there.

Q. Who gave you this passport?

A. Both of these passports, this one and the other one -- this one here, for example, which is -- if I can show that. This one here is passport of service. I had two passports. One was a diplomatic passport and the other one was a civilian passport.

Q. And that document is also Prosecution Exhibit 348, tab 7.

A. And both of these passports, actually three passports, were issued to me in Belgrade.

Q. And who actually gave you, physically handed you the passport? ¹²³⁸⁹

A. Secretary of then President Hadzic.

MR. GROOME: I'd now ask that Prosecution Exhibit 348, tab 8, be placed upon the overhead projector.

Q. Do you recognise the people depicted in this photograph?

A. Some of them, yes. Actually, I recognise all of them, but I remember only the names of some of them.

Q. And the handwriting that is on this photograph, is that your own?

A. Yes, it is.

Q. I'd ask you to go from left to right and indicate who the people are depicted in this photograph.

A. The first chubby, bald guy, that's me. Next is Admiral Dusan Rakic. He was then Minister of Defence of the RSK. The gentleman at the back, I know he was to do something with security of President Hadzic, same as this guy here. And that's President Hadzic, and that's his secretary, private secretary. She is the one who gave us the passport and the money while we were there. Anyway, this photograph is taken in Norway during one of those supposedly secret meetings between the Serbian, Croatian, and the UN. And this large gentleman here, I also can't remember who he was really. I don't think it's somebody important. I don't remember.

Q. Thank you.

MR. GROOME: I'm finished with the exhibit.

Q. Mr. Lazarevic, prior to talking about specific conferences that you attended, I want to ask you to describe in general terms the procedures involved prior to attending one of these conferences. And can ¹²³⁹⁰ you describe for the Chamber how it -- you would come to learn that you were going to be going on one of these conferences?

A. Let me begin with the request for a conference would usually come through the UN. The Croatian side would place a request to the UN Zagreb HQ, which in turn would inform the sector HQ of the UN in the sector which I was in if the meeting had to do something with the area of the 21st Corps. That would go the same for the 39th. On a general level, if it was to do with -- on the level of the government, then the Knin would be informed about the request by the Croatian side that they are willing to have a meeting.

We would then proceed in arranging the delegation, the military and the civilian. We would request an agenda to be given to us in advance about what are we going to discuss during this meeting, usually under the pretext we need to get prepared for those meetings by knowing what's on the schedule of discussion.

Q. Who would this request be made to? This request for an agenda, who would this request be directed to?

A. To the UN.

Q. And would the UN comply with this request and provide a proposed agenda?

A. Yes. There's nothing strange in asking for an agenda in advance really.

Q. Please continue with your description.

A. Once all these little details were sorted out, it was expected from us, as a delegation, to be at least 48 hours prior to departure to ¹²³⁹¹ wherever we're going, to be in Belgrade. We would usually be placed in Hotel Mladost, which is in the central part of Belgrade, in any case, which was always considered to be a home away from home for anybody coming from RSK, because I had never seen anybody paying any bills in this hotel if he had an RSK ID with him.

They would have a series of meetings there. The head of delegation would go to Mr. Milosevic's cabinet for the instructions. The head of military would go to a military, to the HQ, for the instructions, because already, as I said, we had the agenda in advance. So these people would go, they would be advised how to and what to do during the meeting. They would come back, refer to us, tell us what is requested from the rest of the delegation.

Myself personally would have a meeting with Colonel Zimonja, which he would give me a specific assignment during the meeting, whether it happened in Austria or Switzerland or Norway.

Q. After these members of the delegation received their individual briefings, would there be a joint meeting held in the Hotel Mladost?

A. Yes, in the conference room.

Q. And who would attend these meetings?

A. All the members of the delegation.

Q. And what would be discussed at these meetings?

A. Whatever they were briefed, whether in cabinet of Mr. Milosevic or the General HQ.

Q. Now, were these informal meetings or were they chaired by someone?

A. They were usually chaired by whoever was head of the delegation at ¹²³⁹² the time.

Q. And do you know if minutes were taken of these meetings?

A. Yes.

Q. And what was done -- do you know what happened -- or first let me ask you: What kind of minutes were taken? Was somebody writing down verbatim what was said or was somebody simply writing down notes?

A. Just a short reminder what we discussed, what we agreed upon, which we eventually sent to Knin, what the general consensus of the delegation is.

Q. And would these minutes be sent anywhere else that you're aware of?

A. I'm not aware of.

Q. Over the course of the delegations that you attended, and can you tell us how many altogether you attended?

A. I attended four; two in Geneva, one in Austria, and one in Norway.

Q. Did a general pattern of instruction to the delegates emerge over the course of these four peace conferences that you attended?

A. Very much so. They all look alike. The idea was not to agree on anything. That was very simple to follow.

Q. Now, after this meeting in Hotel Mladost, how would the delegate -- members of the delegation travel to wherever it was they were travelling? Would they travel together or separately?

A. No. We would travel together by the UN flight; the UN would provide a plane for us.

Q. And in the different locations of where the conference was held, ¹²³⁹³ would the delegation remain together?

A. At all times.

Q. Now, during the course of these conferences, were members of the delegation required to keep regular contact with Belgrade?

A. Only if they encountered a problem.

Q. Can you explain to us in general terms how this contact was maintained?

A. Well, in any of these meetings, whether it was held in Vienna or in Switzerland, we would have a separate room for adjournment during the meetings. At any given time during the meeting, we could ask for a recess. Let's say that the Croatian side had put a proposal about something and we're not prepared to give an answer immediately. We would say okay we've got to draw back, into our own little office over there, we will discuss amongst ourselves for a while, we'll come back to you and give you an answer. At the time which we were using in the office would be to get in touch with Belgrade, we were assured that the lines, telephone lines in the office were secure line, meaning nobody can overhear our conversation. And then the contact would be established with Belgrade, saying, well, this is what we have encountered, this is the request, what are we going to do about it? In some instances, the answer was just refuse. Simple as that. But if we're cornered, we run out of excuses, what do we do then? Well, then sign but make a stipulation that it has to be confirmed or approved by the General Assembly once you get back to RSK.

Q. During these breaks in the conference when phone calls would be ¹²³⁹⁴ made to Belgrade, would you be present in the room?

A. I would be in the same room where all of us are.

Q. Would you be able to hear at least the -- your side of the telephone conversation?

A. Oh, yes. I mean, they're not big rooms. They might be, I don't know, two metres by three metres. And you would have, like, ten, fifteen people sitting around the table.

THE INTERPRETER: Could the speakers please slow down for the benefit of the interpreters.

MR. GROOME: My apologies.

THE WITNESS: My apologies.

MR. GROOME:

Q. Over the course of the four conferences, were there some people in Belgrade that were regularly contacted?

A. On the level of Mr. Milosevic's cabinet, yes.

Q. Can you please go through the name of each person who was regularly contacted and tell us who it would be that would contact that particular person.

A. At the meetings which were attended by the then President Hadzic, my understanding, he was speaking to Mr. Lilic at times, to some other unknown people from the cabinet of Mr. Milosevic that I really don't know. Anything to deal with the state security would be directed to Jovica Stanisic. Anything to do with the military part would be directed to General Perisic.

Q. Please continue. ¹²³⁹⁵

A. It all really depends upon the situation. I'm not talking that every meeting involved all these people to be phoned but if the event was purely military, then during our break we would call General Perisic and discuss the problem if there is a problem, or Stanisic or whoever. But mostly it was a political problem, so it was discussion with the cabinet.

Q. Can you describe for us what types of problems for which Mr. Stanisic would be contacted and discussion had?

A. Well, at one stage it was suggested by the Croatian side that we should have a model village which would have Serbs and Croats put together in this village under the auspices of the UN and to prove to the world that they can live together as they did before.

Q. Now, you've mentioned that Mr. Lilic was one of the people that was contacted. Is this the then-president of the Federal Republic of Yugoslavia, Zoran Lilic?

A. Yes, but he was referred as a postman.

Q. Who referred to Mr. Lilic as a postman?

A. Mr. Hadzic and Mr. Toso Pajic.

Q. And do you know why Mr. Lilic was referred to as a postman?

A. Carrying the messages from Mr. Milosevic.

Q. Did they or you believe that he was making any decisions himself regarding the situation at the peace conference?

A. I don't believe that Mr. Lilic made any decision in his entire life.

Q. Now, if an agreement was to be communicated to the United Nations or to the other side, was there a caveat to making an agreement or binding ¹²³⁹⁶ the Serb side?

A. I was always very clear before even the meeting started that no decision will be made by the end of the meeting. Even if there is one, we shouldn't go away with it.

Q. Could you explain for us the rationale, if you know, underneath this policy of not committing or making any agreement at these peace conferences?

A. Even officers are just people, so we would sit after the meeting, or even during the meeting or during the break and talk about it ourselves, and it was very obvious to us that Belgrade has no intention of settling the matter between the RSK and Croatia. As long as there is a problem over there, it will take the public view away from what is happening to Yugoslavia at the same time, meaning the great political unrest, the economic problems and so on. So as long as you have this brethren fighting for their bare survival in Croatia, the public eye would be on the RSK. So the idea was as long as we have a problem over there, people will look over there. So we don't want resolution of the problem.

Q. Was there any policy regarding an attempt to appear cooperative despite this reluctance to commit to anything?

A. Oh, yes. We were always very friendly at those meetings. We always seemed to agree on everything. But once we left the meeting, it would become painfully obvious we did not agree on anything, because there would be a call for another meeting and another meeting and another meeting.

MR. GROOME: I want to ask now that the witness be shown ^{12397 BLANK PAGE 12398} Prosecution Exhibit 348, tab 10. And I apologise. We're taking it a little about out of order. But I'd ask that the first page of that document be placed on the overhead projector.

Q. Mr. Lazarevic, I'd ask you to take a look at that document and ask you: Do you recognise what that document is?

A. Yes. This is a list of delegations from the UN and the Serb delegation and the Croatian delegation attending one of the meetings on the 16th of June, 1993, in Geneva.

Q. And are you listed as one of the participants of that meeting?

A. Right down at the bottom of the page you can see "Mr. Slobodan Lazarevic, interpreter." Part of the military. I have to also stress there is another page to this document - I don't know whether you people have it or not - which would list the civilian part of the Serb delegation and the civilian part of the UN and the civilian part of the Croatian delegation.

So this one here would actually be a military, because if you look at the top, from the UNPROFOR, you will find out that the force commander; the chief military observer General Bo Pellnas; Bjorne Hesselberg, Brigadier General, a very fine officer. He was a commanding officer of the sector north of the UN. And then Major General Petar Stipetic, and us; Colonel Kosta Novakovic, who was head of delegation. I also might add that he's a part of KOS of internal security. Colonel Milos Krnjeta, who is a part of KOS but of intelligence part, meaning external security. Colonel Nikola Krosnjar who was a part of the information centre of some description. And then me, down at the bottom of the list. ¹²³⁹⁹

Q. So that the record is clear, there's Colonel Kosta Novakovic is not the same Mile Novakovic you referred to earlier in your testimony.

A. No, no. They're two different persons. One is a general and one is a colonel.

Q. And at the time of this delegation, Colonel Novakovic, Colonel Krnjeta and yourself were all members of some branch of KOS of the Yugoslav army?

A. Very much so.

Q. Mr. Krosnjar, you said that he worked for -- or Colonel Krosnjar, worked for an information centre. Which army?

A. RSK, officially.

Q. Did you -- or do you know from personal knowledge that he was really a member of some other organisation than the ARSK?

A. I think this is the first time and the last time I ever met Colonel Nikola Krosnjar, so I can't really saying anything about him. The other two I got to know pretty well. Colonel Kosta Novakovic, I know him quite well; and Colonel Milos Krnjeta also.

MR. GROOME: At this time I'd ask that that exhibit be taken away and that Prosecution Exhibit 348, tab 11, be placed on the overhead projector.

Q. Mr. Lazarevic, I'd ask you to take a look at this exhibit and ask you to tell us whether you recognise what this exhibit is.

A. Also one of the lists of the delegation, and I can see familiar names here.

Q. I ask you first to tell us the date of this particular delegation. ¹²⁴⁰⁰

A. 20th of July, 1993. I believe this is the first meeting in Geneva. It was very short and very brief. Or second. Okay, let's say second. And I'll tell you why; because it's a larger delegation. The first one last only one afternoon, the meeting itself, so it has to be second.

Q. Can I ask you to read down the names of the Serb delegation and please tell us, if you know, what unit or units they belonged to.

A. Start from the top. You have Colonel Kosta Novakovic, who is the head of delegation in this instance, and he is a member of the KOS internal security. Then you have Milos Krnjeta, also colonel, who was depicted as his assistant, but he's a member of the intelligence part, meaning the external security. Then I have Nikola Krosnjar. He is a head liaison officer, which is news to me, to be perfectly honest. Colonel Cedo Radovanovic was a chief of staff of Kordun Corps at the time.

Q. Before you move on, Colonel Krosnjar, do you know anything about what unit he was assigned to or his background?

A. All I know that he came from Knin. I really have no idea what he was doing in Knin.

Q. Okay. Please continue.

A. As I said, Colonel Cedo Radovanovic is chief of staff of the Kordun Corps, 21st Corps. He was just an ordinary JNA guy. I mean, he did not belong to KOS whatsoever. There are officers who never belonged to KOS.

Q. But at this particular time, in 1993, is he a member of the Yugoslav army or the army of the Republic of Serb Krajina? ¹²⁴⁰¹

A. All these members of delegations are a part of the RSK army officially, and yet they all actually JNA officer or probably at that time VJ.

Q. Please continue down the list.

A. There's a lawyer, which I don't really remember, something to do with the legal department. Then another barrister, Mr. Petkovic, and I believe he had something to do with energy, he was a Minister of Energy or something like that within the RSK because one of the point of agenda was to discuss the problem of the turbines, power station. Then it's me down at the bottom, interpreter and liaison officer, sector north.

MR. GROOME: I'm finished with that exhibit.

JUDGE ROBINSON: Is that a reference to you as a professor?

THE WITNESS: Yes.

JUDGE ROBINSON: And that's factual?

THE WITNESS: No, it's not, sir. Somebody told me it looks good on paper.

MR. GROOME:

Q. Did you have anything to do with the creation of this document?

A. This document? No.

Q. Yes. I'm going to now ask that Prosecution Exhibit 348, tab 9, be placed on the overhead projector before the witness. Mr. Lazarevic, I want to ask you now just to comment on each specific conference that you attended. When was the first conference that you attended?

A. June 16, 1993, in Geneva. ¹²⁴⁰²

Q. And can you describe what preparation was involved prior to the conference, and if it's in the nature -- if it's the same as your general comments earlier, please just indicate that it was. No need to repeat.

A. It's general: Come 48 hours in advance, get the instructions, go to meeting, come back, don't resolve anything. That's -- sorry. That is as brief as I can get.

Q. What topics were discussed at that conference?

A. I believe the first meeting was very brief one, was actually probably one that would originate the next one. I believe we stayed in Geneva only about three hours and this one had to discuss the ceasefire agreements, why they need the DMZ because the units, the troops of the both sides in the conflict were still too close to each other.

JUDGE ROBINSON: From whom did you get the instructions?

THE WITNESS: From the military part in Belgrade, from the head of delegation who went to the General HQ to discuss this.

MR. GROOME:

Q. The next column in this summary table indicates a number of people. Are these the names of the people that you can recall as being present at the Geneva conference on the 16th of June, 1993?

A. I believe this is to be corrected. Goran Hadzic heading the delegation from the Croatian government, military personnel from both sides.

Q. And during the course of this particular negotiation, was there regular phone contact with Belgrade to receive instructions and to keep them informed? ¹²⁴⁰³

A. Yes, indeed.

Q. After returning from this conference, what, if any, post-conference activities were engaged in?

A. Goran Hadzic would have a press conference on arrival to Surcin airport. Each other member of the delegation would go straight back to the hotel to be debriefed about the meeting. Myself, personally, would have a meeting, a separate meeting, with Colonel Zimonja and debriefed by Colonel Zimonja of whatever happened during the meeting.

Q. And do you know who would be responsible for the debriefing of the individual members of the delegation?

A. Depending on the part of the delegation. If it's a civilian delegation, they would be debriefed by the civilian part, meaning Mr. Milosevic's cabinet. If it's a military part, it would be general HQ. If it's the part of the state security, it would be by the DB.

Q. Now, when was the next conference that you went and attended?

A. That was very soon after. It was July 1993, 16 July 1993.

Q. And aside from what you described for us as general preparations, was there anything unique about the preparations for this conference?

A. No. The modus operandi was the same.

Q. And what were the topics that were discussed at this conference?

A. Well, it was general topics again about, you know, ceasefire being broken here and there, how to make sure it doesn't happen again, how to establish the wider DMZ, the demilitarised zone, how far to pull back. We have found ourselves in this particular meeting in a very strange position. The Croatian military has demanded the 21st Corps to put all ¹²⁴⁰⁴ its artillery weapon to the distance of 25 kilometres from the DMZ, which we couldn't possibly accept because that would put us 15 kilometres inside Bosnia. Our sector was a very narrow sector. I don't think the width was more than 16, 17 kilometre. So if the other side proposes to pull the force 25 kilometres away, it puts us in another country. So that was one of the nice reasons to refuse something like that. I mean, it physically was impossible anyway.

Q. I draw your attention to the next column in that summary table. Does that accurately reflect the members of the delegation, or the members of the participants in that conference, as best as you can recall?

A. Yes. Yes, indeed. The thing about this delegation, they grew to be bigger and bigger as each next meeting evolved.

JUDGE ROBINSON: Who met the expenses for each delegation?

THE WITNESS: I believe Belgrade paid for the lot, because we were given money in Belgrade in dollars.

MR. GROOME:

Q. The money that you received in Belgrade, would you have to sign for that money?

A. No.

Q. During the course of that conference, was the communication between the delegation and Belgrade maintained as you have described?

A. Yes. Nothing really changed. The procedure was always the same: Arrive 24 hours prior to the conference, get briefed, establish how you're going to -- when you get there, how you're going to behave, what you're going to say, come back, end of story. ¹²⁴⁰⁵

Q. And after the conference, what activities took place?

A. Again, Mr. Hadzic would have his press conference. For some reason, he liked them. The rest of us, we would go straight to the hotel, waiting to be debriefed. The following day, if we were all done with our debriefing, we'll take our separate ways back to RSK.

MR. GROOME: Your Honour, I'm between conferences now. Is that a convenient place to break?

JUDGE ROBINSON: Before we break, Mr. Lazarevic, let me take you back to an earlier part of your testimony today, where you said you and, I believe, two others had received instructions to get rid of some Croats and some Muslims, and you had planned to do this when they were seated in a bar, I think.

THE WITNESS: On the eve of the 25th.

JUDGE ROBINSON: Evening of the 25th. You did not carry it out because you lost confidence in your two colleagues because, among other reasons, they were drunk.

THE WITNESS: Your Honour, the main reason is for it is I have never killed prior to that day or after that day in my life, so that was the main reason of my trying to find a way to get out of this assignment. Even today I'm not sure how serious were the people giving instructions about assignment or not, but I didn't feel confident in carrying it out.

JUDGE ROBINSON: But I think you anticipated my next question, which would be: But for the loss of confidence, would you have carried out the attack?

THE WITNESS: I would find a reason not to carry it in the end. ¹²⁴⁰⁶

JUDGE ROBINSON: Thank you.

JUDGE MAY: We'll adjourn now. Half past 2.00, please. We'll continue then.

--- Luncheon recess taken at 1.02 p.m. ¹²⁴⁰⁷

--- On resuming at 2.30 p.m.

JUDGE MAY: Yes. Mr. Groome, we have to finish today at 20 to 4.00 because one of our number has a hearing after this. If you could get through the witness -- I don't complain about the speed at all, but the further we can get the better, obviously.

MR. GROOME: I'll do my best, Your Honour.

Q. Mr. Lazarevic, we left off with you describing what occurred in the conference in Geneva on the 16th of July, 1993. I now direct your attention to the next conference that you attended. Can you please tell us when and where that conference was.

A. The third meeting was between the 20th and 22nd of July, 1993, in Vienna.

Q. And where was that? Oh, I'm sorry. With respect to the preparation for that conference, was it similar, or anything unique about the preparation for that conference?

A. Absolutely identical to the two previous ones.

Q. And can you tell us what were the topics for discussion at that conference?

A. It was in general the same topic we discussed before: The demilitarised zone, the displaced people, possibility of working on those model villages.

Q. Was Goran Hadzic at that conference?

A. Yes, he was.

Q. The communications with Belgrade, were they maintained during this conference? ¹²⁴⁰⁸

A. Yes.

Q. And after the conference, can you describe what, if any, activities were engaged in?

A. We would fly back to Belgrade and each of us would be debriefed after our arrival.

Q. I want to now draw your attention to the next conference. Can you tell us when and where that was.

A. That was carried out on the 12th of September, 1993, in Norway. I really don't know the location. It's supposed to be like a very, very secret meeting, even though, after the meeting was concluded, there were approximately 250 reporters waiting for us. So it wasn't all that secret really.

Q. Now, the preparation for this particular conference in Norway, did you attend the preconference meeting on this occasion?

A. Yes. In Belgrade, Hotel Mladost.

Q. Did you attend any briefing with Zimonja prior to this conference?

A. Yes, I have, and I have been given a specific task for this last meeting that I attended.

Q. And can you describe for us what that specific task was.

A. One member of our delegation was considered to be a security risk, and that member is Admiral Dusan Rakic, so I was tasked with being very close to him throughout the meeting, on all days, and to follow who is he meeting outside of the official part of the meeting with, on the Croatian side.

Q. And why was he judged to be a security risk? ¹²⁴⁰⁹

A. His family still lived in Zagreb at the time, his wife and his two sons who were just about the army age.

Q. Now, in terms of preparation, did you learn that it was part of the preparation for the Norway conference that Hadzic and Rakic had met with Mr. Milosevic prior to the departure of the delegation?

A. That was my understanding from discussion with them.

Q. Can you explain what it was they told you that indicated to you that they had a meeting with Mr. Milosevic.

A. Well, they claimed they had been talking to the boss and the boss told them do such and such and such, gave them explicit orders about actually not completing anything during the meeting.

Q. What was the topic for discussion or negotiation in this particular conference?

A. I remember it, and the main topic of discussion was some kind of autonomy within Croatia for the RSK.

Q. And I want to direct you to the fourth column on the exhibit. Does that -- do those names there represent the names of the people that you can recall as being present at that conference?

A. Yes, indeed, sir.

Q. During the preparations for the Norway conference, was there any reference made to this being a shopping trip?

A. It was a standing joke among the delegation members, because they hardly had changed from the original delegation. The number only increased. We were given sufficient funds to actually do the shopping, and to my amazement the place we were was like a Sunday and they had ¹²⁴¹⁰ engaged the mayor of this little city in Norway to open a little shopping centre for the members of the delegation to go in and buy stuff.

Q. Now, during the course of the negotiations in Norway, was there regular communication with Belgrade?

A. Throughout the day.

Q. And can you recall for us any of the people, the names of the people who were being contacted in Belgrade throughout the day?

A. I believe that Mr. Goran Hadzic had contacted cabinet of Mr. Milosevic. Whether he spoke directly to Mr. Milosevic or not I don't really know, but he did speak to the cabinet.

Q. And who -- please continue.

A. Also the military side of the delegation has spoken to the General HQ in Belgrade concerning some military matters.

Q. Do you know who in the military headquarters was contacted?

A. It was General Perisic.

Q. Do you know if on this occasion Jovica Stanisic was contacted by anyone?

A. I believe that is the case.

Q. And you believe that based on what?

A. On being in the room when those calls were placed.

Q. Now, upon your return from Norway, were you debriefed, as you had been in the past?

A. Yes, I have. This debriefing took a bit longer than the previous three.

Q. And approximately how long did it take? ¹²⁴¹¹

A. Two days.

Q. And were other members of the delegation debriefed at that time as well?

A. Yes, sir.

Q. Did there come a time during the course of the negotiations in Norway when Krnjeta made a statement to the delegation regarding this pilot village of -- this interethnic pilot village?

A. At one stage, Colonel Krnjeta suggested that we should accept a proposal in forming of this pilot village and at any given time Krnjeta would engage the anti-terrorist unit and maybe shoot a couple of Croats and a couple of Serbs in the village, irrelevant who, but create a psychosis of fear so that nobody actually would come back to this particular village. That would be the end of the project.

Q. You just used the term "psychosis of fear." Was that a term that was used when Krnjeta addressed the members of the delegation?

A. I think I just quoted Colonel Krnjeta when I said "psychosis of fear."

Q. So it was your understanding that any commitment to this village was premised on the ability to, once the delegation returned, that this psychosis of fear could be created back in the area, undoing the commitment?

A. That was made very clear during our meeting in the office.

Q. Was that discussion held at the same time when there was regular communication with Belgrade?

A. Yes, sir. ¹²⁴¹²

Q. Now, for this particular negotiation, was Goran Hadzic assigned an advisor?

A. I believe the gentleman's advisor had the same name as Mr. Slobodan Milosevic; also Milosevic.

Q. Do you recall his first name?

A. Either Miso or Savo. I'm not really certain. But I'd say Miso Milosevic.

Q. Was this the first time that this other Milosevic came to one of the conferences that you were present on?

A. No. The same person attended two meetings previously in Geneva and he was assigned to us as a host to these meetings.

Q. Do you know anything about this person; where he's from or what institution he worked for?

A. Absolutely nothing, but there was guesswork going around the room among the delegates that he's probably brother of Mr. Slobodan Milosevic. By appearance of the man, it didn't look like President Milosevic at all.

Q. Did there come a time during the Norway negotiation that this other Milosevic made a reference or a comment about a phone conversation that he may have had with Mr. Milosevic here in Court?

A. Yes, he did.

Q. Can you tell us what it was he said?

A. Well, at the time, he said whatever we do, to keep one thing in mind, and that is at the conclusion of the meeting, nothing should be resolved, that we should come back without a resolution.

Q. And how did he -- or what word did he use that you understood to ¹²⁴¹³ mean that he was referring to Mr. Slobodan Milosevic, here in the Court?

A. Up to that point in time, everybody, when they referred to Mr. Slobodan Milosevic, referred to him as the boss or in the full name. But the people who were closest to him, as far as we were concerned within the delegation, he was referred to as the boss.

Q. And did this other Milosevic, the advisor, use that phrase when recounting this instruction?

A. Actually, he used a very short version of the name, saying "Slobo."

Q. Now, after returning from Norway, did you become aware or observe any activities which appeared to you to be attempts to undermine some of the progress made during the peace negotiations?

A. Well, I can only talk about the area of the 21st Corps. Yes, there were quite a few incidents happening very fast, one after the other, which would create fear within the population, and at the same time stop any possible further negotiation with the Croatian side.

Q. I'm going to ask you to describe some of these, and I'd just remind you to please slow down the pace for the interpreters.

A. Okay. The ones that come to mind would be mining of the railway line. It was supposed to be our very first trip of the train after the beginning of the conflict. The train did hit the anti-tank mine. A lot of people got killed and injured in the process, and it was blamed on a Croatian terrorist.

Q. Now, with respect to this particular incident, can you please assist us by being more specific about the place and the approximate time ¹²⁴¹⁴ or date when this occurred.

A. I know it was wintertime. I know it was between Glina and Vojnic. That is the railway which used to connect Karlovac and I assume Petrinja. I'm not very familiar with the area. But it was the railway line that existed prior to the conflict, and it stopped being in use once the conflict had started in the area, and that was supposed to be the first time that the plane -- the train had been put in operation. That was the first and last time.

Q. Do you know who was responsible for the planting of the mine on the railroad tracks?

A. Well, later on, I did find out. At the time, I was again called to go to see Colonel Bulat at his headquarters, but I would be given a formal letter of complaint to be taken to the sector commander of the sector north.

Q. And you said that later you found out who was responsible. Can you begin by telling us how it was you found out who was responsible.

A. Well, it more or less came to me it was a simple deduction. The place where the anti-tank mine was placed, how far it is from possible penetration of the Croatian side, how possible for Croatian terrorists would be to get in, how quickly we have deployed our forces in the area to search the immediate area where the mine was planted. All those things didn't produce any result. Now, considering it was wintertime, we have come to considerable area which had no footprints or anything in the snow which would make it perfectly clear that nothing came from that side, so it had to be from within. ¹²⁴¹⁵

Q. Is there another incident which you're aware of around this time period?

A. Yes. There was also supposed to be a friendly soccer match between the local population and the UN, in Glina, and somebody has mined all of the soccer pitch, placing those little round anti-infantry mines which are not really supposed to kill but to maim, to take your foot away, and it was discovered just prior to the beginning of the match. Of course, the match was postponed. It was never played again.

Q. Did you come to learn who planted those anti-personnel mines on the soccer pitch?

A. Again, I come to the same conclusion, and it was confirmed later on by the people who actually have done it themselves.

Q. And who were those people?

A. That would be anti-terrorist group from the Banija Corps in this particular instance.

Q. And how did you learn that it was that particular anti-terrorist group for the Banija Corps?

A. These two groups, one which was assigned in our own corps, in 21st Corps, and the one which was in the Banija Corps, were actually friends before the war. The same aged kids. The average was probably about 21, 22. And they had a meeting place which was a bar, just kind of halfway between Kordun and Banija, where they would meet almost on a daily basis and exchange information.

Q. And did you have any conversation or have a conversation with any members of this unit? ¹²⁴¹⁶

A. Yes, I had.

Q. And what was it that was said to you that indicated that they were responsible for planting these mines in the soccer pitch?

A. Well, they said it was told to them -- or issued an order to them but also it was made absolutely certain to them that nobody would be hurt by it, meaning that it will be discovered in time. But they were asked to do it during the night. Actually what they did is just went around with a basket and tossed them around in the grass. They have little round, green in colour.

Q. Were you asked or instructed to file a complaint regarding this incident?

A. Yes, indeed.

Q. And what was the nature of the complaint?

A. Again, we claimed that the penetration of the Croatian or, as the term was used at the time, "Ustasha" elements had penetrated our border, went deep inside and planted those mines. And we actually blamed the military observers of the UN who were deployed along the frontier, they haven't seen anything.

Q. Is there one last incident regarding a water tower?

A. Yes. Again, it was a mine planted -- a number of mines, actually, planted around the water tower, and one of the villagers taking his livestock to graze in the vicinity actually stepped on one and got killed.

Q. And what was the ethnicity of the man who was killed?

A. That was a Serbian man.

Q. Did you come to learn who planted the mines around the water ¹²⁴¹⁷ tower?

A. This time it was our own anti-terrorist unit from the 21st Corps.

Q. And how did you learn that fact?

A. From a personal discussion with the leader of this little unit, with Paraga.

Q. And on this occasion, were you instructed to file a complaint with the United Nations?

A. Yes. Before I even discovered what happened, I mean who committed these things, I would be called in to the HQ by Colonel Bulat, given the letter of complaint, and I would drive immediately to the UN compound and hand it to the sector commander there. It was beginning to be a joke between the sector commander and myself because he didn't believe that our forces would permit such easy access to the terrorists from the other side.

Q. This particular complaint, did it make an allegation as to who was responsible for the planting of the mine at the water tower?

A. An official complaint?

Q. The complaint that you were instructed to give the United Nations.

A. Yes; officially it was blamed on the Croatian side.

Q. Now, you were present in this area at the times of these events. Did these events have the desired effect in creating what you've previously testified to as a psychosis of fear?

A. Yes, very much so. Because I have to point out that during all these meetings, the situation was very relaxed in RSK. The meetings are ongoing, something is happening over there, we have really demobilised a ¹²⁴¹⁸ considerable number of soldiers, sent them home to do their field work or whatever they do. And then after each of these incidents, we would mobilise everybody because, you know, you have to look for these units of the Croatian terrorists that have penetrated the borders, you have to search for them in the forest; so everybody would be back in uniform, back on duty.

Q. I want to now draw your attention to a later period after that. Were you called upon to participate in a plan to expel 75 elderly Croat villagers in the area of your responsibility?

A. Yes, I have taken a personal part in it.

Q. Can you please describe, first of all, the planning involved in the operation.

A. Well, somebody came up with the bright idea how to get rid of the remaining Croatian population in the area, and that is to approach the UN and International Red Cross and ask them if they can assist us to have them transferred to Karlovac hospital because we are unable within the area to give them proper medical attention. So the whole idea was put forth to the UN as being a humanitarian convoy.

Q. Approximately how many people are involved in this plan? I mean the targeted people to be moved to Karlovac.

A. Approximately around 75, but the people involved in it would be the members of the 21st Corps, the police in the area of the Kordun Corps, International Red Cross, the military observers, the UN. So there was a lot of people involved in actually implementing the idea.

Q. And would it be fair to say that these Croats were elderly people? ¹²⁴¹⁹

A. Yes. I don't think anyone was younger than 70.

Q. Based on your experience and standard operating procedure, what level would have to become involved to agree on and implement a plan of this nature?

A. A plan of this nature involving all these international bodies would have to be -- green lights would have to be given by Belgrade.

Q. Did the plan go forward?

A. Yes, it did.

Q. And can you describe your participation in the actual execution of that plan.

A. My part was to get in touch with all these international bodies and give them the details of the plan, together with what we expect them to do, what kind of assistance we need from them. The general framework of the whole thing was a humanitarian convoy going from RSK, carrying Croatian nationals into Croatia for medical attention. The thing that we did not tell them, and that was the idea that they will not come back.

Q. Was there a planning meeting held to discuss the specifics of this operation?

A. I have virtually come to the tail end of the planning itself, when it was -- when it came to the point that the international structures have to be informed about it, that's when they used me as a liaison officer, me and Mr. Toso Pajic, to deal with international police.

Q. Did you have a conversation with Mr. Toso Pajic regarding this event?

A. Yes, indeed. ^{12420 BLANK PAGE 12421}

Q. Did he indicate to you whether or not Mr. Jovica Stanisic was involved in the planning of this event?

A. Well, he also had information like that Daddy is informed about these things that are happening here, without in so much as saying, Yes, I talked to him today or yesterday. But he referred, as he was discussing this matter prior.

Q. Colonel Bulat, did you have a conversation with Colonel Bulat regarding this operation?

A. Yes, because he was the one who was giving me instructions about it.

Q. Did he indicate to you what, if any, contact he had with General Perisic regarding this matter?

A. Yes. Again, on all levels in this operation, the people in Belgrade were informed, from the civilian down to military down to the state security.

Q. And just finally on this matter: Was this operation executed in a manner that was satisfactory to the people who planned it?

A. Yes, to the both sides. The UN was very impressed because they were under the impression they were helping out a humanitarian thing. My own side was also very happy because they got rid of these 75 civilians which they had no use for really. So it all ended up, you know, everybody being happy except those Croats.

Q. Was this plan replicated in other instances around the same time, in other areas that you're aware of?

A. I'm not aware of any other instances. ¹²⁴²²

Q. I want to now ask you to describe in a little greater detail the institution of Pauk, or Spider. When did you first become aware of this joint command?

A. It was late 1993, when there was a sudden influx of these uniformed men, uniforms I had never encountered before. Talking to them in our own language, it was obvious they're not from the area. Also it was obvious they're not a paramilitary unit as far as we're concerned because they were given a free passageway, and also they were given our old HQ in Petrova Gora.

Q. And who was the commander of the Pauk command?

A. General Mile Novakovic.

Q. Now, you've testified earlier that the 21st Corps was involved, members of the special forces of the Serbian MUP, Arkan's Tigers, and Fikret Abdic's men.

A. That is correct.

Q. Were there any other units at any time that you were aware of were involved with this Pauk command?

A. Yes. Some of the units of the 39th Corps, some of the units of the 15th Corps, some of the units of the 1st and the 2nd Krajina Corps in the Republika Srpska. That usually would happen when they had a coordinated attack on the 5th Corps.

Q. So to be clear, the 39th and 15th Corps are corps of the ARSK?

A. Correct, sir.

Q. And the 1st and 2nd Krajina Corps are both corps of the VRS or army of Republika Srpska? ¹²⁴²³

A. That is correct.

Q. Now, in your role as liaison officer, were you ever called upon to answer questions regarding Pauk and were you ever given instructions on how you should respond to inquiries about Pauk?

A. Yes. I have been called frequently by the sector commander, General Hesselberg, who was then commander of sector north. One particular instance he called me in his office. When I arrived, he tossed a little service booklet at me across the table and it had to do with artillery piece. I have looked at this military booklet and it had to do with JNA weaponry. General Hesselberg claimed that that was given to him by members of the 5th Corps. That was a piece of artillery they have taken away from Abdic's forces during the recent combat. I said it was probably a piece of artillery left behind by JNA. When he asked me to open this little booklet to the service page of it, unfortunately there was a stamp of the Nis Corps, which is approximately, I don't know, 1.200 to 1.300 miles away, and this specific piece of artillery was serviced there about a month prior to being captured in the area of the 5th Corps.

Q. And the Nis Corps would be based in the city of Nis in Serbia; is that correct?

A. Yes, that's correct.

Q. And can you please establish a time frame for when General Hesselberg confronted you with these service records?

A. Very late 1993.

Q. And officially, you've told us that the service record indicated service within a month -- ¹²⁴²⁴

A. Prior to the capture of this piece of artillery.

Q. Officially, how much time had elapsed between the JNA's official withdrawal from this area?

A. Over two years.

MR. GROOME: I'm going to now ask that the witness be shown Prosecution Exhibit 348, tab 12. I ask that the original Serbian copy be placed on the overhead projector.

Q. Mr. Lazarevic, you've testified at great length about Colonel Bulat. During the course of your duties, did you become familiar with his signature?

A. Yes. I have seen many orders signed by himself.

Q. Have you had an opportunity to review carefully this document marked as Prosecution Exhibit 348, tab 12?

A. Yes.

Q. Do you recognise the signature on the bottom of that page?

A. That is Colonel Bulat's signature all right. But this is when he was chief of staff of Pauk, not during his commanding of the 21st Corps.

Q. Can you please describe for the Chamber the significance of this document and summarise its contents.

A. Very briefly, this document was done in a number of copies which were to be sent to the 21st Corps, 39th Corps, Tactical Group 2, Tactical Group 3, command of Pauk, and artillery of the 21st Corps plus to the command of the Western Bosnia, which are actually Abdic's forces. The order itself, what it contains within itself is to supply information about the inventory of the weapons and ammunition within all these ¹²⁴²⁵ commands.

Q. I want to draw your attention to the first paragraph after item 6, and I want to ask you: Is there a reference to MUP units in the document?

A. Yes. The last paragraph would read that during the regular inventory taking would also include the units of the MUP, the Ministry of the Interior, and also the units of the Republika Srpska, meaning the Bosnian -- Serb -- Republika Srpska, the Serbian side in Bosnian conflict.

MR. GROOME: Thank you. I'm finished with that exhibit.

Q. Now, during the course of your duties, did you have occasion to actually visit Pauk headquarters?

A. Yes, I have, and actually, I had a permanent pass given to me by Colonel Bulat. That was the only way that I actually can go to Pauk.

Q. And what was the purpose of your visits to the Pauk headquarters?

A. The very first visit was related to the request by the General Pieters. He was a Belgian general stationed in Zagreb. I don't really know what his function was within the UN, but at one stage he insisted on meeting with General Novakovic, and me being liaison officer in 21st Corps, I was asked to inform General Novakovic about this meeting. I went back to my own HQ, talked to Colonel Bulat and he said why don't you go, you know, to Pauk command and let him know yourself, and then you can bring him back.

Q. I want to ask you now to --

THE INTERPRETER: Would it be possible to slow down.

MR. GROOME: Apologies again.

THE WITNESS: Sorry. ¹²⁴²⁶

MR. GROOME:

Q. I want to ask you now to speak in greater detail regarding the make-up of the forces in Pauk. Can you estimate for us the number of soldiers from the 21st Corps that were assigned to work in the Pauk joint command.

A. I believe that the members of the 21st Corps were numbered about 400 strong. I would place MUP to about 200, in Arkan's to about 100. And I have no knowledge of how many of Abdic's forces were there.

Q. Now, when you say MUP contributed approximately 200 --

A. Yes.

Q. -- was this the MUP of the RSK or the Serbian MUP?

A. That was actually the special force of police from Serbia proper, headed by Colonel Bozovic, Colonel Ulemek, also known as Legija - apparently he was a former Legionnaire - and Frenki Stamatovic. Frenki Stamatovic held the command in Petrova Gora while the others were across the border in Bosnia.

Q. The members of the 21st Corps, did they wear any insignia or other identifying mark that they were from the 21st Corps when they were serving in the Pauk headquarters?

A. They have been asked to remove them.

Q. Why was that?

A. Well, we did not really want international community to know that the members of the 21st Corps are actually involved in a Muslim versus Muslim conflict on the other side of the border.

Q. Was there a policy that you were aware of regarding what would ¹²⁴²⁷ happen in the event that a member of the 21st Corps would either be captured or killed during operations conducted under Pauk?

A. The order was very simple. If I were to be called by the UN HQ and -- for this reason: Maybe the 5th Corps is holding a number of prisoners who claim to belong to the 21st Corps, I would deny the fact. And instruction given to me was to tell them they were either deserters or volunteers who have voluntarily crossed the border and joined the forces of Fikret Abdic.

Q. Can you describe for us what was the command relationship between Fikret Abdic's men and the Serbian members of Pauk? Did one command the other?

A. I believe that Abdic's forces were actually under the command of the MUP from Serbia.

Q. While you were -- or in the aspects of Pauk that you were exposed to, did you ever see Novakovic give any orders to any of the units of the Serbian special forces?

A. No, I have not.

Q. How about with respect to Arkan's Tigers?

A. Again, the same answer: No, I have not. My belief was that he couldn't even command them if he wanted to.

Q. With respect to the Serbian MUP and Arkan's Tigers, did they wear any identifying insignia that identified them as members of those two respective groups?

A. My information was very clear in that respect. If they were to be engaged in combat, all the recognisable patches should be removed during ¹²⁴²⁸ the combat. However, once they would cross again into the RSK, they would wear their own patches on the shoulder, which was the upright sword with the Serbian flag. Because on occasion I've seen them coming in for supplies.

Q. I want to now show you a document that has been previously marked for identification, and that is Prosecution 347, tab 5. And I want to show you a particular excerpt from that, and the number at the top of the page is 02094552 and 53.

MR. GROOME: I would ask that the witness be shown the original Serbian copy.

Q. Mr. Lazarevic, I'd ask you to take a look at this document and tell us: Do you recognise what it is?

A. It looks like a war diary on a day-to-day.

Q. I want to direct your attention to certain entries and ask for your comment. I want to direct your attention to the entry for 1510 hours.

A. 1510?

Q. Yes. I'd ask you to, at this stage, work from the English version if we've made an error and not included the page from this original Serbian. On the entry from 1510, is there a reference to your organisation, the 21st Corps?

A. Yes. "To order the commander of the 21st artillery detachment to open fire."

Q. Drawing your attention to the entry under 1540 hours, is there a reference to Bozovic? ¹²⁴²⁹

A. Yes. It states very clearly that Bozovic is requesting fire to the following sectors, and all the sectors mentioned are on the Bosnian side.

Q. Would it be considered ordinary or customary for a member of MUP, of a police department, to direct the fire, artillery fire, of a military unit?

A. Not unless he had full permission from Belgrade.

Q. Is there anything in that log to indicate that Bozovic was questioned regarding his authority to call for such fire?

A. None that I can see.

Q. I want to draw your attention to an entry of 1730 hours and ask you: Does that reference Legija, a person you've mentioned in your testimony here today?

A. Yes. It very clearly states that Legija was leading the 2nd Battalion in the operation and then made analysis of the combat for the day.

Q. And who was he to work with regarding that direction?

A. It does say a joint meeting, so it's natural to assume it's a joint meeting with representatives of all the commands there.

Q. And is there also a reference in that entry to the replenishment of Legija's supplies?

A. Yes.

Q. Would that be considered unusual, for a military unit to be giving supplies to a police unit from another country?

A. Under normal circumstances, it would be absolutely impossible, but ¹²⁴³⁰ we were not living under normal circumstances at the time.

Q. I want to draw your attention to just two more entries, one at 1915 hours, and does that indicate or list the supplies that were provided to Bozovic?

A. It's a very long list here really, but one that I can notice immediately that Bozovic was given two 60-millimetre mortars and 82-millimetre mortars from the 21st Corps.

Q. Is there any other Bozovic that you're aware of other than the Bozovic you've testified about from the Serbian MUP special forces?

A. No. That is not a very familiar name in the area.

Q. And the final entry I would seek your comment on is the entry of 2145 hours, and is there reference there to the insertion of a special unit of MUP?

A. That refers to the 39th Corps, if we are looking at the same page.

Q. I would draw your attention to the last paragraph in that entry. Oh, yes. 1615, special unit of the MUP, Ministry of Interior. Yes.

Q. Thank you.

MR. GROOME: I'm finished with that exhibit. I'd now ask that the witness be shown Prosecution Exhibit 348, tab 13.

Q. I'd ask you to take a look at this document and ask you: Do you recognise what it is?

A. Yes, I do. It's a visitors log. I probably signed it myself on a couple of occasions.

Q. And it's for people visiting what location?

A. That is for people visiting the command of Pauk. ¹²⁴³¹

Q. Do you recognise some of the names on that log?

A. I think the most prominent one would be Abdic Fikret on this list.

Q. I'd ask you to take a quick look at the two pages that I've provided you and ask you: Do you see Mr. Abdic's name on that list more than once?

A. Yes. There's an entry for the May 18th, 1995, Thursday. Abdic Fikret again. Well, actually, I know quite a few people here because they're all from Velika Kladusa.

Q. And are they people that you knew to be members of the Pauk command?

A. Some of them, yes. Not all of them. These are actually visitors to the Pauk command. On the right-hand side of the document actually you can see who they went to see, so the people listed on the right-hand side would be the members of the command, and the left-hand side are the visitors.

MR. GROOME: Thank you. I'm finished with that particular exhibit.

Q. I want to now ask you to describe in greater detail the location of the Serbian MUP headquarters that were part of the overall Pauk command.

A. There's one that was placed in Petrova Gora. It was a former JNA military installation with some high-tech -- it's actually monitoring telephone calls in Zagreb and stuff like that. It was a building which was two storey high above the ground and it had seven storeys below the ground. ^{12432 BLANK PAGE 12433}

Q. And where was the other -- was there another Serbian MUP headquarters as part of the joint command, other than Petrova Gora?

A. In Pauk. The remainder of the command was in Pauk, in Bosnia.

Q. And how far away from the Croatian-Bosnian border was this second command?

A. Well, the Petrova Gora is probably around five to six kilometres away from the border, and the Pauk command is probably around 800 metres inside the border.

Q. During the times that you were at Petrova Gora, can you describe for us what, if any, armed people, armed troops, you saw using that facility or guarding that facility?

A. One could go to Pauk or to Petrova Gora only by invitation once it was taken over by the MUP Serbia. So only one time I went there I know that the perimeter of it was consisting of the members of MUP Serbia and Arkan's Tigers.

Q. I'm going to put some names to you and ask you whether you ever saw any of these people present at Petrova Gora. A person by the name of Pejovic.

A. Frankov Kolu [phoen], belongs to Arkan's Tigers.

Q. How about a Captain Sarac?

A. Second in command to Mr. Pejovic, Colonel Pejovic.

Q. You've testified earlier about Colonel Bozovic. Did you ever see him at this location?

A. Not in Petrova Gora, but I met him in Velika Kladusa itself.

Q. Now, can you describe for us what, if any, knowledge you have ¹²⁴³⁴ regarding the types of weaponry that the Pauk command had under its control?

A. Well, they had a far superior weapon than we had which was issued to us by the JNA. Most of their weaponry was either Heckler or Koch, which was very hard to get in Yugoslavia at the time, so I assume they must have bought it from outside of Yugoslavia. The size of weaponry would either consist of Sexhauer [phoen], which is another weapon which is not produced in Yugoslavia. I know that we within the 21st Corps had all locally produced weaponry, but apparently the MUP Serbia had far superior weaponry than we did.

Q. Did Pauk have any tanks or armoured vehicles under its control?

A. Not that I know of.

Q. Were you familiar with where the stores for Pauk were kept?

A. Well, they would come for their supplies back into the RSK.

Q. Where was that in relation to your office?

A. Well, not to my office, but in relation to my house, it was across the road.

Q. And would you see units coming and going to be supplied from that storehouse?

A. On a very regular basis. Very early in the morning, between 8.00 and 9.00, they would be parked there. During the night, the trucks would deliver the supplies, and in the morning, they would be there to pick them up.

Q. The trucks that supplied the warehouse, can you tell us what, if anything, about the type of vehicle and who owned the vehicle? ¹²⁴³⁵

A. The military type trucks with VJ number plates on them.

Q. And can you tell us some of the units that you saw coming to the stores to receive stores from this location.

A. I've only seen Arkan's units coming to collect the stores over there. Whether they were collecting for somebody else in Pauk, I don't know, but they have taken much more than they needed for the numbers that they had.

Q. I want to now draw your attention to St. Vidovdan Day, the 28th of June, 1995, and ask you whether you were present at a celebration of that day.

A. Was that a question to me?

Q. Yes.

A. I'm sorry. Yes, I was present there. It was a big parade.

Q. And for those of us who are not familiar with the Serbian Orthodox calendar, can you briefly describe the significance of St. Vidovdan Day?

A. I have to be very honest, I'm not a very religious person but I believe it had something to do with the Kosovo battle.

Q. Would it be fair to say that it is one of the more significant days on the Serbian Orthodox calendar?

A. It would be a very important date for them.

Q. Can you describe for us what occurred at that celebration generally, or briefly.

A. Well, it was -- since it was televised live, it was to produce a parade which would show to both the Croatian side and the Bosnian side how well we're equipped with weaponry, including the rocket systems, taking ¹²⁴³⁶ into consideration that Asaj [phoen] was only 28 kilometres, as the crow flies, away from us, that would be a very serious threat to Zagreb itself. So it was all planned of creating this, you know, we're big and strong.

Q. After arriving here in Holland, were you given the opportunity to look at a videotape that depicted the celebration that you were present at?

A. Yes, I have.

Q. And can you tell us approximately how long was this celebration altogether?

A. I believe it took something like four to five hours.

MR. GROOME: I'd ask now that the witness be shown what has been previously marked as Prosecution Exhibit 347, tab 7. I'd ask that the witness be shown, it's a video cassette tape.

Q. And I'd ask you to look at the label on that video cassette tape.

A. Yes. I have marked it in my own handwriting that this is a tape that I have seen.

Q. And what date is on that?

A. October 21st, 2002.

Q. Is that the date you viewed that videotape?

A. That is the date I viewed this tape, yes.

Q. And did you view -- did you mark "C-001" and the date on that videotape label as it was taken out of the video recorder?

A. Yes, I did, right down at the bottom of the label.

MR. GROOME: Your Honour, just a point of clarification: The Prosecution will be seeking to introduce the entire tape, although it does ¹²⁴³⁷ not believe it's necessary for the Chamber to view it at this stage. But the witness has viewed the tape and has identified the entire two-hour tape as being a fair depiction of that. So we would be seeking to introduce the entire tape. I will be asking a short excerpt to be presented here in Court.

[Trial Chamber and registrar confer]

JUDGE MAY: Yes, we'll admit that. The registrar will give it the number.

THE REGISTRAR: Your Honours, the videotape in its entirety will be tab 7, and the excerpt, which was originally tendered and admitted on the 22nd of October, will be tab 7A, which is an excerpt of this video.

MR. GROOME: Tab 7A has been cued up in the video booth, and at this time I would ask the director to play that video excerpt.

Q. And Mr. Lazarevic, I would ask you, as the video is playing, if you would please narrate for the Chamber what it is that's taking place on the video.

[Videotape played]

THE WITNESS: Well, this is during the parade itself. You can see president of the Republic of RSK at the time, Mr. Milan Martic, inspecting the troops. There's Red Berets here, supposed to be a special unit. Only this picture, if you can freeze frame, you can see actually the members of the --

MR. GROOME: I will be showing you some frozen stills from this video. If we can just let the video run and please continue to narrate.

THE WITNESS: Fine with me. Okay. He's going back to the podium ¹²⁴³⁸ and now the procession will start. That's General Mrksic behind him, just about to salute everybody there, President Martic. And now the actual parade has started.

MR. GROOME:

Q. Can you describe anything that is unusual --

A. Well, on this particular photograph here you see Captain Dragan, who was one of the paramilitary leaders at the very beginning, 1991, 1990, and then he went back to Belgrade, and this is the first time I've seen him after 1991.

Q. I'd ask you to comment on the licence plates that you see.

A. The truck that just went through had letter "Z" in Cyrillic, meaning it belongs to the 21st Corps. Each corps had a letter assigned to them.

Q. What kind of equipment are we looking at?

A. The multi-rocket launcher right now, and you can see the "Z" and I can't see the numbering but it's there. And again, one of our own. But if you look at the rocket system, those are the ones that came from the Republika Srpska, from the army over there. And yet on all those vehicles you don't see any number plates because they were removed prior to taking part in the procession.

The Luna rocket is there. Terrible, obsolete weapon. At ten kilometres, they miss the target by 500 metres. That's why it makes it more dangerous. A number of journalists there filming the whole parade. I think it's only fair to say that all these weapons was removed after the parade and sent back to Bosnia, to Republika Srpska. Also we ¹²⁴³⁹ didn't have an air force really, so ...

Q. Why were the number plates removed from the vehicles from Republika Srpska?

A. Well, this podium here was actually a three-part podium, and on the left-hand side from President Martic over there would be the foreign dignitaries, like members of the ECMM, members of the UN, and those people probably used their cameras and film it and analyse it later on and could see the number plates and that would be proof of the origin. If you didn't have any number plates you couldn't place them. You had to take it at face value and say yes.

Now, there's an interesting photograph here. General Mile Novakovic and introducing President Martic to the Pauk command there. The first two persons over there were Colonel Bozovic and, after that, Colonel Ulemek, known as Legija. These gentlemen here, they're all Bosnians. When I say "Bosnians," I mean members of Fikret Abdic's forces. That is part of the Pauk command being introduced to President Martic.

And General Mrksic right now.

MR. GROOME: Okay.

Q. I'm going to show you some stills from that excerpt we just saw so that you can be more precise in your identifications of the people present, and I would ask you to take a look at this photograph.

MR. GROOME: And I would ask that it be marked as Prosecution Exhibit 347, tab 7.1, which is what it was given the other day when it was shown to witness C-020, but we also include ".SL" to indicate that this ¹²⁴⁴⁰ witness has marked the exhibit.

A. On this photograph here with the back turned is President Mile Martic there. General Mrksic is to his left, also with his back turned, saluting Colonel Bozovic and Colonel Legija, or Colonel Ulemek, Legija was his nickname. So you have Martic, Ulemek, Bozovic, Mrksic.

Q. And that is your handwriting indicating the names of these people?

A. Yes, sir.

Q. I'd ask that you be shown Prosecution Exhibit 347, tab 7.3.SL. Is that your handwriting on this photograph?

A. Yes, sir.

Q. Can you please indicate who is in this photograph.

A. Facing in the middle of the photograph is President Mile Martic. Behind him is General Mile Mrksic. Behind, you can only see the face of General Novakovic, and here in the corner is General -- sorry, Colonel Kosta Novakovic. But this time he was running the military information centre in Knin. That's Kosta Novakovic.

MR. GROOME: I ask that the witness be shown Prosecution Exhibit 347, tab 7.4.SL.

Q. Is that your handwriting on this photograph?

A. Yes, sir.

Q. Can you please describe who is depicted in this photograph.

A. President Mile Martic, General Mile Novakovic, and you have on the top of the photograph, you have Djuro Skaljac, who was second in command of the police in Vojnic, directly under Toso Pajic and later became liaison officer in Pauk. Actually, on this photograph, you can see the ID ¹²⁴⁴¹ hanging from his shirt up front. That would refer to Pauk command. And with his back turned to us is General Mile Mrksic.

MR. GROOME: I ask that the witness now be shown Prosecution Exhibit 347, tab 7.5.SL.

Q. And can you tell us who is depicted in this photograph?

A. Captain Dragan.

Q. Now --

MR. GROOME: I'm finished with that exhibit. Thank you.

Q. Did there come a time when you were appointed to be a member of a three-person commission for the exchange of bodies?

A. As a matter of fact, I was a member of the commission from the very beginning in 1992, but it grew up into a real commission on the level of the RSK and it was run from Knin by a gentleman called Savo Strbac.

Q. Did there come a time when you were called upon to become involved in a proposed exchange of bodies, of soldiers from the Banija Corps that were lost in the Bihac pocket, that were killed in the Bihac pocket?

A. Yes, sir.

Q. And how many men were killed belonging to the Banija Corps of the ARSK in the Bihac pocket?

A. 100 was offered for exchange.

Q. And can you help fix this in time. When was this?

A. That would be in 1994. It was very cold, so I'd say early 1994.

Q. Can you describe what you did to facilitate the exchange or the retrieval of these hundred bodies.

A. Mine was actually to first originate a meeting with the members of ¹²⁴⁴² the 5th Corps, a similar commission on their side and their own liaison officer so we can start implementing this exchange because the families -- they wanted their dead fathers or sons or brothers or whatever they had there. And the problem was actually that we did not have that many bodies from the other side belonging to the 5th Corps, so it was given to me to get as many bodies as I can, irrelevant of the area where they were taken and to bring them back into the area of the 39th Corps and exchange them for these hundred members of the 39th Corps.

Q. And can you describe for us how it was that you went about this task.

A. Well, I virtually knocked on every door given the opportunity. I originally went to the 21st Corps, to my own CO, asking him for advice, what is the next thing to do. He told me to go and see Toso Pajic because there are some dead bodies kind of buried around. I went to see Toso Pajic and he referred me to Djuro Skaljac, his second in command. We then picked up, I believe, two prisoners - they were both Croatian nationals - took me outside of Vojnic to a little deserted place by the river there and pointed out to the area when these two Croatian nationals should start digging. They dig out -- they did dig out four bodies. The problem that I had with them, first they were in a high state of decomposition, so it was not something that happened recently in a combat situation. Obviously they were there for a considerable number of months. And the second even more worrying thing was that all four bodies had their hands tied with wire up front, which would suggest they were executed, that they did not actually die in a combat situation. But being pressed for the bodies, ¹²⁴⁴³ nevertheless I took those four, removed the wire, and put them in the body bags.

Q. Did you obtain another 90 bodies from other graves in the area?

A. Yes, sir, but those are the known gravesites of the real combat members of the 5th Corps that were killed in recent actions.

Q. Now, even with this 90 plus four bodies, did you still need to identify or secure six other additional bodies for the exchange?

A. General agreement between the 5th Corps and the 39th Corps was one for one, meaning as many as we offered, that's how many we're going to get, one for one sort of a thing. So it was still six short.

Q. And did you go -- did you at some point -- or at some point were you directed to speak to one of Arkan's Tigers regarding securing six more bodies?

A. Yes. I was directed to go there by Colonel Karan Mlado, who was internal security officer for the 21st Corps, and he usually would have information where the people were held as prisoners or people being shot or something like that. So he directed me to go to Pauk command and speak to Colonel Bozovic and Colonel Pejovic. One was the MUP Serbia -- Bozovic was MUP Serbia, and Pejovic was Arkan's Tigers. See if they can assist.

Q. What happened when you spoke to Pejovic?

A. I spoke first to Bozovic and Bozovic told me if you need dead. You go and fight and bring your own dead. So that was a very brief meeting. He wouldn't help us in this matter no matter how much I pleaded with him. I wasn't doing this for myself; you know, for the families. Then I was sent then to go to separate like a little subcommand, if you ¹²⁴⁴⁴ like, where Colonel Pejovic was, and then he sent me to his second in command, Captain Sarac, who calmly said he doesn't have any dead bodies however he does have six live ones and I can have them if I need them badly enough.

Q. What did you do?

A. The whole commission just turned around and walked away. We drove back and then we were told to come back the following morning.

Q. And did you go back to Captain Sarac the next morning?

A. We went back to the Pauk command which told us there are bodies ready for us, as Captain Sarac commanded. We went there and there were six dead bodies lined up which appeared to be very freshly killed.

Q. When you say "freshly killed," did it appear to you that they had been killed in the period since you last left the Pauk command?

A. I would say they were killed about an hour before we came the second time.

Q. What happened then?

A. Again, these bodies now were too fresh compared to all the other bodies to be taken straight for the exchange, so I have advised my command about it. They told me to take the bodies back to the Vojnic nevertheless and place them in a fridge and then conduct the exchange late at night the same day.

Q. And did you do that?

A. Yes, we did, but with the five that I picked up, I had only 99. So when we came to the place where the meeting was set up with the 5th Corps, they brought big trucks. We lined them up along the road, 99 on ¹²⁴⁴⁵ our side, they took one, put it back on the truck and they left 99 on the road. So it was 99 for 99.

MR. GROOME: Your Honour, I'm about to go into an entirely different area.

[Trial Chamber confers]

MR. GROOME: Your Honour, I'm just mindful of the time before embarking on a new area.

JUDGE MAY: Yes. I think that would be a convenient moment. How much longer do you anticipate?

MR. GROOME: I would expect approximately 40 minutes, Your Honour.

JUDGE MAY: Thank you. We'll adjourn now. Mr. Lazarevic, would you please be back tomorrow morning at 9.00 --

THE WITNESS: Yes, Your Honour.

JUDGE MAY: -- to continue your evidence. Thank you.

--- Whereupon the hearing adjourned at 3.40 p.m., to be reconvened on Wednesday, the 30th day of October 2002, at 9.00 a.m.