¹²⁴⁴⁶

Wednesday, 30 October 2002

[Open session]

[The witness entered court]

[The accused entered court]

--- Upon commencing at 9.02 a.m.

JUDGE ROBINSON: Judge May is indisposed today. The Chamber will continue sitting under Rule 15 bis.

Yes, Mr. Groome.

WITNESS: SLOBODAN LAZAREVIC [Resumed] Examined by Mr. Groome: [Continued]

Q. Mr. Lazarevic, yesterday we interrupted your testimony during your recounting some of your work on the exchange of bodies commission. I'd like to begin this morning by showing you a document, and it is Prosecution Exhibit 348, tab 14. And I'm going to ask that you be shown both the original B/C/S and the English translation. I'd ask you to take a look at the original B/C/S document before it's placed on the overhead projector, and after you've had a chance to look at it, I'd ask you to tell us whether or not you recognise that document.

A. Yes, I do. It was handed to me personally.

Q. And who handed you this document?

A. My CO, Colonel Bulat.

Q. And when was it that Colonel Bulat gave you this document?

A. I assume that I received it on September 25th, 1994.

Q. And has that document been in your possession until you turned it over to the Office of the Prosecutor here at the Tribunal? ¹²⁴⁴⁷

A. Yes, it was.

Q. To save a bit of time, I'm going to ask you -- it's a short letter. I'm going to ask you to take a look at the English translation and read it. If there's any part of that translation that does not comport with your understanding of the document, or you disagree with any portion of the translation, I'd ask you to indicate that and to tell us what you believe the document to say. So I'd ask you now to read this translation of that document for the Chamber.

A. "Republic of Srpska Krajina, Main Staff of the Serbian army, confirmation number 15-440 --"

THE INTERPRETER: Would the -- slow down.

THE WITNESS: I apologise. "Republic of Srpska Krajina. Main Staff of the Serbian Army. Confirmation number 15-440, 29th of September, 1994. Meeting of war prisoner exchange commissions. To be delivered to the 21st Corps (war prisoners exchange commission).

"Since the war prisoners exchange commission of the 1st Krajina Corps made an appointment to meet with a similar commission of the so-called ABiH, it is necessary that the representatives of your commission attend, too, and that they tell the Turkish commission openly that we, (RS and RSK), are one people, but that on the paper we are divided in two states.

"From the intelligence service obtain a few names of the most extremist members of the 5th Corps of the so-called ABiH, and convey them to the Turkish commission. Tell them that we have around 3.000 of their ¹²⁴⁴⁸ members that are in prison, not in a refugee camp. You have to let them know that we are not in the position to beg, but that we are those who are setting the conditions up.

"It should be checked whether there are relatives and friends of the leading military and politicians from c. Krajina among the prisoners and convey their names to them, too.

"Assistant Commander Colonel Marinko Gajic." And then there's a stamp on the bottom of the original document, received on the 29th of September, 1994, at 1530, processed at 1530, and signed.

Q. Does that translation accurately reflect the contents of the original Serbian document?

A. Yes, it does.

Q. I want to ask you now to assist the Chamber in placing that document in context, and I want to ask you a few specific questions. The reference to RS and RSK and "are one people," what did that -- can you put that into context? What was the author of this letter indicating by that?

A. Well, indicating that the Serbs on both sides of the frontier then, between the Republic of Srpska and Republic of Srpska Krajina are all Serbs, serving in one army.

Q. The portion of the letter which indicates that the Serbs have around 3.000 members in prison camps, not refugee camps, is that -- do you have knowledge whether that 3.000 were simply military soldiers that had been captured or were they also civilians?

A. I'll have to be honest and admit that I am not aware of the 3.000 ¹²⁴⁴⁹ being held anywhere in RSK, which I cannot claim for the RS.

Q. So to your knowledge, were there 3.000 soldiers anywhere within the 21st command's area of responsibility?

A. No, not that many.

Q. The last paragraph, when it talks about checking whether there are relatives and friends of leading military and politicians, can you indicate or describe for us what that meant, place that in context for us?

A. It meant very simply that if we did held anybody that was important to the other side, they should be used as a blackmail tool.

Q. And were attempts made to identify the people in custody to determine if they were related to any prominent members of the opposing side?

A. Yes. Those we held in prison have been severely questioned to establish whether there are any relationships to the leading political figures in B and H.

Q. Were there ever any attempts to identify people related or friends of prominent members who were not yet in custody, to identify them and place them in custody?

A. Not to my knowledge in RSK.

Q. I'd like to now draw your attention to May 1995, and ask you: Did you have occasion to see an order regarding the shelling of the frontier or front line near Zagreb?

A. Yes. Order issued by the President Martic was issued to all the commands of all the corps and at one of the briefings in the morning it was read to all of us. ¹²⁴⁵⁰

MR. GROOME: I apologise to the usher. I'm finished with that document. Thank you.

Q. Now, this order issued by President Martic, can you please describe what you recall about it when it was read out in the morning briefing.

A. Briefly, it stated that any case of provocation from the Croatian side or any attack from the Croatian side, all the corps deployed along the frontier from north to south should be burning on the other side, meaning that the artillery attack would immediately begin all along the frontier.

Q. Based on your experience and participation in that morning briefing, is it your belief that Mr. Milosevic had anything to do with this particular order?

A. Not to my knowledge.

Q. After -- strike that. Was this order ever implemented?

A. At one instance, yes.

Q. And was there any reaction to its implementation?

A. Yes. The unit that have opened the rocket fire on Zagreb was immediately arrested and removed from the area.

Q. And do you know who arrested them?

A. The special police from Serbia.

Q. And how much time transpired between the rocket attack and the arrest of the people who perpetrated the rocket attack by the special police from Serbia?

A. I don't think it took more than six hours after. ¹²⁴⁵¹

Q. I want to now draw your attention to the period of time in the Krajina in 1995. And before I ask you specific questions about that period of time, I would ask you to describe generally to the Chamber what life was like among the remaining Serb population in the Krajina in 1995.

A. One would have to say that life was very difficult at the time. Suddenly the supplies have somehow become less and less regular as they were before. A lot of civilians have already left the area on the pretext of going to see relatives in Serbia or whatever the reason they gave. But the people started trickling away very slowly. There were a lot of rumours going around that a Croatian attack is imminent, that we are prepared to defend every inch of the soil of the RSK. It was a war of psychosis, very, very carefully built up.

Q. Can you describe the level of violence or crimes that were non-conflict related in the Serb community at that time?

A. I had the opportunity to read the surveys carried on official basis by the army and losses that we have suffered at that particular moment in time. 80 per cent of those losses were contributed to ourselves and 20 per cent to the enemy.

Q. That means that the official statistic on who caused these crimes, who perpetrated these crimes, 80 per cent was attributed to Serbs themselves?

A. Correct.

Q. I want to draw your attention now Operation Storm and ask you to describe what Operation Storm was and where were you when Operation Storm commenced? ¹²⁴⁵²

A. The operation itself started on the morning August 5th, 1995. However, we have been informed about a pending attack two days prior, in every detail; about the time, the strength, and direction of the attack, which made me believe that we have sufficient time to regroup or increase the defence of the border itself.

Q. How did you -- sorry. How did you learn about the details of the attack prior to the attack?

A. Through my connections with ECMM.

Q. And did you pass that information on to your superiors?

A. Within minutes of receiving it.

Q. And can you tell us who you passed this information on to?

A. Originally, first was given to Colonel Bosanac who was then in charge of the 21st Corps, and then I myself personally sent a telex to Knin General HQ.

Q. And based on your experience of having lived in this area for several years, it was your opinion that there was a response that could be taken to these attack plans?

A. My understanding, yes.

Q. Please continue.

A. On the morning of the 5th of August, there was a first attack carried by the Croatian air force, actually, in the vicinity of the HQ of the 21st Corps, where I was at the time. However, the rockets released by these airplanes didn't come nowhere near to the actual HQ. I think they were directed to the HQ of the special police in Petrova Gora. Whether they hit it or not, I really don't know. At the same time, the infantry ¹²⁴⁵³ attack came from the direction of Petrinja and from the direction of Karlovac. The combat actually started on the ground itself by 8.00. At the same time, I was informed to go immediately back to the HQ of the UN, as if UN didn't know about the attack. I mean, I was supposed to go there and file a complaint about the attack from the Croatian side. I did get back to the HQ. Of course, the sector commander was aware of the attack and he was trying, through his own channels, to convey a message to the Croatian side via the HQ in Zagreb of the UN for the immediate ceasefire which, unfortunately, did not happen.

Q. Now, Mr. Lazarevic, before you describe more detail about the attack, I'm going to ask you to briefly describe for the Chamber the location of the 21st Corps, the 15th Corps and the 39th Corps, all of the ARSK army. Can you please describe their relative positions at this point in time.

A. I think I have mentioned before how narrow that section of RSK is between the B and H and Croatia. The RSK was caught kind of in the middle. And the attack was carried out on the 5th of August from both sides of the border, meaning we were attacked from behind by the 5th Corps and up front by considerable Croatian forces. The depth of the section that we defended is around 15 kilometres. The width is around 70. Considering that my eastern flank was held by the 39th Corps, which is the Banija Corps, and on my western flank Lika, or the 15th Corps, was supposed to hold the position. However, by the 9th of the 5th, in the early morning hours of the 6th, we have discovered that both of those flanks have withdrawn, that actually we have been left alone in the ¹²⁴⁵⁴ middle. By that time, we were already surrounded by the Croatian side. There were in Glina, and on the other side, they were in Vojnic, so there was no way out for us.

Q. Prior to the 15th Corps withdrawing, was -- was the 21st Corps made aware of that fact, to your knowledge?

A. No. We were not being aware of any movement of the troops.

Q. Prior to the 39th Corps being withdrawn, was the 21st Corps made aware of their withdrawal, to your knowledge?

A. Again, the same thing; we were not informed about it.

Q. I want to draw your attention now to the 7th of August, 1995. Were you personally present when a series of phone calls were made from the 21st Corps to Belgrade?

A. Yes. The meeting actually took place in the HQ of the UN. We used the satellite phones in there.

Q. And did the UN permit you to use these satellite phones or can you explain the circumstances under which you used the satellite phone?

A. We rented the space from the UN. We were paying 5.000 Deutschmarks a day to use this particular office.

Q. Was this an official agreement with the UN or was it a deal that was worked out with an individual?

A. It was a deal worked out with an individual.

Q. Okay. Please tell us about the phone calls that you witnessed.

A. In the office, at the time when it was painfully obvious that we were sacrificed as a corps, we tried to establish contact with the General HQ in Belgrade and with the cabinet of Mr. Milosevic. In the office at ^{12455 BLANK PAGE 12456} the time, it was myself, Toso Pajic, Colonel Bulat, Djuro Skaljac, and maybe one or two other persons present. The calls were made in the following order: First it was placed to the General HQ of Belgrade, General Perisic personally by Colonel Bulat. I have to say that the public announcement system was plugged in, so actually we could all listen to the telephone conversation.

Q. So we're clear: So the phone was on speakerphone and all people in the room to hear both sides of the conversation?

A. Correct.

Q. Okay. Please continue.

A. Once the contact was established with the General HQ, Colonel Bulat has given a report as a commanding officer from the war part of the country to the General Perisic and then he asked him for advice, explaining that we have been caught and encircled totally by the enemy forces, which were considerably stronger than we were, and asked him what does he want us to do, whether to surrender, whether to fight or what. General Perisic answered with one word, and that was "Persevere", and put the phone down.

Q. Did General Perisic offer any concrete assistance to the 21st Corps?

A. No, except, "Persevere." That was about all that he said at the end of the conversation.

Q. Was there another phone call made that morning or that day?

A. The next phone call was made to President Lilic.

Q. And who made that phone call? ¹²⁴⁵⁷

A. Mr. Pajic made that call.

Q. And can you please describe the contents of that phone call.

A. Again, he explained the situation and asked for advice. Again we received exactly the same answer, that was, "Persevere."

Q. Did President Lilic offer any concrete assistance to the 21st Corps?

A. Absolutely none.

Q. Was there another phone call made that day?

A. Yes. Mr. Toso Pajic made one more call, and that was placed to Jovica Stanisic.

Q. And can you tell us the substance of that call?

A. Again, explaining the situation, development over the last 24 hours above ground, and again we heard the same reply: "Persevere." At that particular moment in time, we all looked at each other and had a feeling like these three people are in the same room even though that we have had three different telephone numbers that we have used, but the answer was exactly identical.

Q. And did Mr. Stanisic offer any concrete assistance to the 21st Corps?

A. None whatsoever.

JUDGE ROBINSON: Just before you continue, Mr. Groome. Mr. Lazarevic, you said that they were considerably stronger than you were, than your forces were. Could you put that in terms of numbers for me?

THE WITNESS: Our estimate at the time was that we had ¹²⁴⁵⁸ approximately 4.000 men under arm, and I'd like to point out that none of those were professional soldiers within the RSK. Most of them actually civilians just being drawn into the conflict. At the back of us, we had a full 5th Corps of the B and H army which at the time numbered around 20.000. The both flanks, the eastern and the western flanks, the attack carried by the Croatian forces would approximate the same number of 20.000 together. In real terms, we had about 40.000 people attacking approximately 4.000.

JUDGE ROBINSON: Thank you. Continue, Mr. Groome.

MR. GROOME:

Q. Did members of Arkan's Tigers receive concrete assistance during this time period?

A. On the evening of the 6th of August, they have pulled out, not only Arkan's, but special forces of the Ministry of Interior of Serbia have pulled out from the area, from Pauk and from Petrova Gora with assistance of the MP Battalion from the 21st Corps.

Q. And can you be more specific about the type of assistance that the special forces from Republic of Serbia MUP and Arkan received when they withdrew from the area?

A. The battalion of the MPs from the 21st Corps has served as a security and led the way in withdrawal of the forces from Pauk and Petrova Gora.

Q. Do you have any personal knowledge regarding who issued the order to give them protection when they withdrew? ¹²⁴⁵⁹

A. I have no idea.

Q. Did something happen to Luna rockets that were present in the RSK at that time?

A. Those rockets were removed on the day when Zagreb was shelled, so we had no rocket system at the time of the attack, even though I have to admit the Croatian side was not aware of that.

Q. I'd ask you now to continue with what happened after this period, and I'd ask you to maybe describe for us what, if any, media campaign existed at this time regarding what was going to happen to the people in the Krajina.

A. Obviously, at the time of this attack, I'm now specifying the period of 6th and 7th of August, there were a lot of rumours running around, and of course all sides used it to their own benefit. The fact of the matter is that the 21st Corps left their position of Turanj and pulled all the way back to the actual compound of the UN, which we have surrounded and placed civilians between us and the UN. What I'm trying to picture to you, gentlemen, is that in any situation when aerial attack by the Croatian air force, the UN HQ would suffer considerable damage as well. That was the idea for proximity of our own troops there. At the time, we controlled a perimeter of around 7 kilometres. That was what was left of the RSK. Within this perimeter, as I said before, we had 4.000 Serbs armed and approximately 20.000 civilians. There was no food, no water, no electricity. All the other sectors had been deserted by then. Knin was taken over by the Croatian forces. The Croatian forces have advanced even ¹²⁴⁶⁰ further. They were approximately two kilometres away from Topusko on either side of the road, meaning from the east and from the west, and the 5th Corps has actually stopped at the border to Croatia, so they have not penetrated into the territory. If you would draw a circle around the compound of the UN, it would be probably around two and a half kilometres wide. That's about it.

We have tried many things to inform the general public about the attacks of the Croatian. The information which we received from the field were that atrocities have been started by the advancing enemy forces. One particular information I have conveyed to the CNN via the satellite phone about the attack of the Croatian air force and the members of the 5th Corps on the refugee convoy which was trying to penetrate the territory into Bosnia, withdrawing from RSK. That would happen on the 6th.

Q. Was that story covered on CNN?

A. Yes. Actually, I have personally, not only me, but a number of us was watching TV at that time.

Q. Please continue.

A. On the morning -- the morning of the 7th, it was already obvious that we cannot expect any assistance from anybody. We all firmly believed that we have been sacrificed so that somebody in Belgrade would gain some points after we have all met with our demise, being surrounded. Three of us at the time in the office, Colonel Bulat, myself, and Mr. Toso Pajic, have discussed the possibility. The least one liked by all three of us was actually going and commit mass suicide by counterattacking the forces which are approximately 8 to 1. Also taking into consideration that the ¹²⁴⁶¹ position of ourselves would also contribute to the considerable killing of the UN personnel as well.

At that time we made a decision between three of us to get in touch with the command in Zagreb via sector commander in Topusko and suggest that if we were to surrender to the Croatian side, the condition would be that we are permitted to go back to Serbia, for the convoy being escorted by the UN and ECMM and military observers, and withdraw all the way to Serbia.

Finalising of this idea came after we all disagree that would not be very wise actually to travel in vicinity of the 5th Corps because the 5th Corps would not be a part of this agreement which we are about to make with the Croatian side. So we have decided actually to travel the length of Croatia with the convoy and enter Yugoslavia at Sid area.

Q. And that's Yugoslavia in Serbia, I mean Serbia -- the Serbian part of Yugoslavia.

A. That is correct. On the morning of the 8th, all the details were finalised. The attacks have stopped in the meantime. The deal was that we first surrender the heavy weaponry - tanks, artillery pieces - and then along the way to relieve ourselves from all the other weapons. So approximately after about 25 kilometres on the road from Topusko, already deep in Croatia, past Petrinja, we were to surrender all the rest of the weaponry. Only officers were allowed to keep assigned weapons, but that was a kind of part that even Croatia didn't keep, they just took all the weaponry. In all fairness, I have to admit, it was a horrible convoy, very long, with approximately 25.000 people in the convoy. The length of ¹²⁴⁶² the convoy would probably be around 30 kilometres because you had cars, tractors, horse-drawn vehicles, and it was moving extremely slow. The only part -- the only part that we have considered to be actually threatened is when we left Glina and it was -- the convoy was passing through a couple of destroyed Croatian villages at the beginning of the conflict, and it was like a gauntlet of the Croatian army alongside of the road; the distance between each of the soldiers probably about two to three metres. And us being already disarmed but still in uniform, we didn't feel very comfortable when they started checking their weapons. I suppose it was just a kind of trying to install fear.

Q. Mr. Lazarevic, before you continue, can you give us some idea about the composition of this convoy? Is it just military members of the 21st Corps or are there also Serb civilians taking part in this convoy?

A. The convoy was of a mixed nature. There were military and civilians. And the civilians were not only from Topusko. Actually, there were a lot of civilians coming from deeper within Krajina, like the Slunj area, then further down. As they were pulling back or pulling out from their own position, they would actually end up in Topusko because Topusko was like, you know, the end of the road, because we were -- by then, we were already surrounded from all sides. So the convoy itself would be, as I said, approximately numbering 24.000 bodies, out of which 20.000 were civilians; you know, elderly people, ladies, kids.

Q. Did there come a time when this convoy reached the border of Serbia?

A. I was approximately a fifth car in the convoy, so I was about ¹²⁴⁶³ among the first ones to reach the actual border between Republic of Croatia and Yugoslavia. I was asked by Toso Pajic and by Colonel Bulat to stay behind -- two police officers, our own police officers, and two police officers from the Croatian side and just to check the number of the people as they are going through, which took about eight to nine hours.

Q. Do you recall the approximate number of the people that passed from Croatia into Serbia?

A. In all honesty, I have to say that we've been on the road for approximately 72 hours, so that part was totally unclear to me. I know I have been writing names down. I was asked to write just the first names of the people, no surnames, no ranks, no whether they belonged to the army or not. It was just a kind of verification that the Croatian side had asked to have, at the end of the day, confirmation of all the people that have gone across if our side would claim later on that the number of people were taken out of the convoy and maybe taken to a prison or being shot or something like that.

Q. Are you able to approximate that number for the Chamber?

A. I believe that I stood there and about 15.000 people have gone through.

Q. And that would be 15.000 people, both civilian and military?

A. Correct.

THE INTERPRETER: Interpreter's note: Would you please observe pauses between question and answer.

MR. GROOME:

Q. Mr. Lazarevic, can you now describe what you observed on the ^{12464 BLANK PAGE 12465} Serbian side of this border.

A. I have been first to get there, but I was approximately the last one to leave Croatia at the end tail of the convoy. As soon as they have crossed the road, I parked my car in Yugoslavia this time, and I slept in the car beside the road for about four to five hours. When I woke up, I decided to continue towards Belgrade. As soon as I have reached the highway known as Bratstvo-Jedinstvo, or Brotherhood and Unity Highway, this is when you encounter the first toll booth like set up before you enter the highway. On this side, on this side facing Croatia, actually, there were units of the police from Serbia stopping all the vehicles in convoys and searching them thoroughly, including the persons within the vehicles. Anything that resembled anything to do with the military was immediately confiscated and taken away.

On the other side of the ramp, they had set up a little Red Cross station with fresh water, milk for the kids, bread, and things like that. But you can imagine the slowness of the process if each individual car or vehicle or pedestrian, even, being totally searched before we actually can reach the other side and have a glass of water or glass of milk. So it was a very painful and slow process. Most of the people in the convoy had been protesting vigorously against the Serbs because we just couldn't figure out if Croatia decided not to search the convoy for 72 hours as we moved through Croatia, why is it suddenly that we have to be searched so thoroughly by our own police? Nevertheless we had to put up with it, and after finally making it through the gate and entering the highway, we started moving toward Belgrade. ¹²⁴⁶⁶ I was driving a Mercedes at the time, so I had the opportunity to move faster than most of the convoy, meaning that I have reached Belgrade ahead of the rest of the convoy that was very slow moving.

Q. Can you describe what, if anything, you observed at the exit ramps to the highway?

A. The moment we reached Belgrade, the exit ramp of the highway was blocked off by the police and all the traffic was directed further south. As the convoy moved further south, every other exit was also blocked off by the police, so the convoy actually had to keep on moving without stopping anywhere. The general direction of this movement was Kosovo.

Q. So if a person who had fled the Krajina had family in Belgrade and wanted to stay with them, were they permitted to do that?

A. No, sir.

Q. Where were those people being forced to go?

A. As I said, along the highway, deeper south, general direction of Kosovo.

Q. Were there any representations made regarding what awaited the refugees down in Kosovo?

A. Absolutely nothing. You had just a bunch of police at every exit, showing the movement of the convoy to continue down the highway.

Q. Did there come a time -- strike that. Did you travel on the highway through Belgrade?

A. Yes, I have.

Q. Did there come a time when you were able to get off of the highway? ¹²⁴⁶⁷

A. As I said before, I was moving much faster than the rest of the convoy, and those that have left the Croatia before I did, obviously had moved even further up front. So there was a section of the road that I was driving now that had no convoy in front of me or no convoy behind me, and I reached vicinity of Krusevac, where I have spotted an exit which was not guarded by the police, and this is when I swung off the road and left the highway.

Q. Without telling us the name of the person you went to or their relationship to you, did you go somewhere when you were able to get off of the highway?

A. Yes. Straight to the house of this person.

Q. And how long did you remain at this person's house?

A. 24 hours before the police showed up at the front door.

Q. And the police that showed up, were they ordinary, uniformed Republic of Serbia police?

A. Yes, regular police.

Q. And what happened?

A. I was asked to get dressed up and leave with them to the police station. I have repeatedly asked why, and they said, "Well, we have no answer for you, but the commander of the station will inform you." When I was taken by these two police officers to the station, there were a number of people from Krajina around the station already, mostly women and children crying their eyeballs out because all the men were put on the buses.

Q. Did you identify yourself and your position to the police? ¹²⁴⁶⁸

A. Very much so. Actually, there was -- in the room which was questioning every individual where is he from, there was a member of the state security with the police commander, to whom I have identified myself, given my military booklet, my driver's licence, my ID, to establish the fact that actually I am not from Krajina, that I was born in Belgrade, therefore I'm a citizen of Yugoslavia. And this gentleman from the state security told me, "Okay. You turn around and you go home now." I asked if I can use the phone so I can call the people to come and pick me up because the police brought me down. These people turned up around 3.00 in the morning and took me away. Unfortunately, the very same day in the early hours of the morning, around 10.00, the police turned up at the gate again and took me away again.

Q. Where were you taken this time?

A. Straight to Krusevac.

Q. And were you taken there alone or with other people?

A. There was a bus load of us going to Krusevac who were there, and I believe there was some kind of either school or something like that, because there was a couple thousand people already. It was like a gathering centre.

Q. And what happened at that location?

A. The people held in this location were all people from RSK of military age, meaning from like age of 18 to about 60.

Q. And what is the ethnicity of these people?

A. They're all Serbs.

Q. Please continue. ¹²⁴⁶⁹

A. We were loaded on the buses there. Each bus had an escort of four police officers, including the driver. Each bus was full of people, only sitting, nobody standing but, I mean, every seat was taken by an individual. I think we left around noon, as this huge convoy of buses taking us somewhere. When we tried to establish some sort of a conversation with the police officers on board the bus, they simply would not answer where we are being taken.

Q. Now, can you approximate for us the number of buses in this convoy?

A. In the convoy that left with me was approximately 12 buses.

Q. And did you perceive that you were free to get off this bus if you wished?

A. Absolutely nobody was allowed to leave the bus, not even go to the rest room.

Q. Please continue.

A. We kept on driving and it was getting dark, and we still didn't know which direction we are going. At one point, the lights from the bus have shown a road sign which was Dalj on this road sign.

Q. Could you please spell that for us?

A. D-A-L-J.

Q. Please continue.

A. We realised - some of us that knew - that we actually are going to the Arkan's camp.

Q. And where was Arkan's camp located at that point in time?

A. In Dalj. ¹²⁴⁷⁰

Q. Did you -- did there come a time when you did eventually arrive at Arkan's camp?

A. Yes. We arrived there. The whole camp was in total darkness. However, there were a number of people standing and yelling the names of the people on the bus, because obviously they were supplied with the names by the convoy leader or whoever gave them the names. And as the people were descending from the bus, they were sent to run through a gauntlet of Arkan's Tigers, who were beating them at the time as they were running through. At the time that somebody called my name, I stepped off the bus but immediately somebody walked up to me in the dark and -- somebody who recognised me or somebody who knew me -- and pulled me aside and said, "No, you don't go that way. You're not one of them," meaning I'm not a Croatian Serb but being a Serbian Serb, even though myself personally didn't make a distinction as such. And I was taken around the gauntlet, straight to the office of Colonel Pejovic and Captain Sarac, which I knew from a previous encounter in the RSK, and they were aware that I am originally from Belgrade, so I was kind of put aside, so I didn't go through this severe beating on arrival.

Q. Did you come to learn the purpose of these men being brought, these Serb men being brought to Arkan's camp?

A. Apparently somebody had an idea that these people need to be retrained by Arkan, and that was like original virgins, whatever, brought there. I find out later on that Arkan has been paid 100 Deutschmarks per head of the Serbian brought in for retraining.

The situation within the camp were atrocious. People were ¹²⁴⁷¹ severely mistreated on a daily basis, property were taken away from them, their IDs were taken away from them; they have become just numbers. I'll give you instances: For example, there were three telegraph poles in front of Arkan's HQ to which every single day there were at least three Serbs chained to the post and anybody who went past can beat them.

Q. Can you please describe for us how it was you learnt that Arkan was being paid to retrain these men.

A. The very same night when I arrived to -- I will freely use "concentration camp," because that's what it was. Excuse me.

Q. Take your time.

A. The very same evening that I arrived to the camp, myself, I had seen a JNA officer, which I have approached and identified myself and asked for a location of the commander of the 21st Corp or any corps of the RSK. I was told by this gentleman that a joint command has been formed in Vukovar and that he will inform the necessary officers about my being held in this in this concentration camp.

JUDGE ROBINSON: Can you explain your characterisation of this place as a "concentration camp"?

THE WITNESS: First of all, there were no freedom of movements. The whole camp was surrounded by barbed wire. It was heavily guarded by the armed men. People were mistreated 24 hours a day, beaten up severely, made to carry huge rocks, about the size of a human with the weight of approximately 60 or 80 pounds, and at any given time if they dropped this rock, they would be beaten again.

MR. GROOME: ¹²⁴⁷²

Q. Did there come a time when you learnt the purpose of this retraining? What was to happen to these men after they had been trained by Arkan?

A. My understanding was they will be pushed up front to fight the Croatian forces again, but this time at the back of them they would have Arkan units who would shoot them in the back if they decide to withdraw.

Q. Mr. Lazarevic, did there come a time when you were able to secure your own release from this camp, using your own contacts?

A. On the fifth day, a vehicle came from Vukovar joint command to take me away from this camp, and I was taken there. At this time, when I walked in the command, I was very, very disappointed. I just couldn't believe that the Serbs can do to the Serbs what they were doing, and I have asked immediate discharge from the forces. I was told to go and see Colonel Karan, who was in charge of internal security KOS, and he suggested, he said, "Well, I can't give you this discharge. What I can give, I give you a pass to go to Belgrade, and then you don't have to come back. You can go for medical check-up, just don't come back." I said, "This is not the way I want to leave the army, not by deserting it," I said, "I want a full discharge." I requested a vehicle from the command to take me straight to the Ministry of Defence of the RSK, and I went there and I raised -- I tell you, gentlemen, I did raise hell over there to get a discharge, which I eventually did, and then I sat on the first bus back to Yugoslavia.

Q. During your time at the camp, did Arkan himself address the group?

A. Yes. Each group -- I have to tell you that every day the buses ^{12473 BLANK PAGE 12474} were coming. This is not just my convoy when it came, but on a regular basis, everybody morning and every evening, another bus load and another bus load of these poor people would come in.

JUDGE ROBINSON: Of what ethnicity?

THE WITNESS: Serbs.

MR. GROOME:

Q. Can you approximate for us, during the time you were there, how many people, how many Serbs altogether you saw?

A. Over a period of four days, at least two and a half thousand.

Q. Can you please describe for us what Arkan said to your particular group.

A. Well, he lined up the group and then told them: "For the five years [Realtime transcript read in error "five days"] we have supplied you with weaponry, we have supplied you with food, with the manpower, with the officers, and yet you wouldn't even fight, in the end."

Q. And when he used the word "you," did you take that to be a reference to those people in the Krajina?

A. Yes, sir.

MR. GROOME: Your Honour, I have no further questions of Mr. Lazarevic at this time.

JUDGE ROBINSON: Mr. Lazarevic, how long did you stay in the camp?

THE WITNESS: Your Honour, I stayed there for five days.

JUDGE ROBINSON: And what was your treatment generally?

THE WITNESS: It was regular treatment. I mean, nobody bothered me whatsoever. I was just put aside over there, waiting for somebody to ¹²⁴⁷⁵ come and pick me up from the camp.

JUDGE ROBINSON: You said something in the earlier part of your testimony today that I'd like to ask you about. Having made three phone calls to Belgrade and on each occasion you were told to persevere, your assessment was that somebody wanted to sacrifice you to score points. I think that was the term that you used.

THE WITNESS: That is correct, Your Honour.

JUDGE ROBINSON: Can you explain that for me?

THE WITNESS: Well, we believed, by the answers which we have received and a silent refusal of any assistance whatsoever, whether it was air force or ground troops or -- that we left there, leaving us open to try and mount a counterattack and die in the process. A lot of civilians would have been killed. The media could use that as pointing out that the Croatian side is no different than the Serbian, or even worse than the Serbian side in committing these atrocities against the civilians and the unarmed population in Krajina.

JUDGE ROBINSON: I see. Thank you.

MR. GROOME: Your Honour --

JUDGE ROBINSON: Yes, Mr. Groome.

MR. GROOME: I believe there's an error in the transcript. Before we get too far ahead, I'd ask that maybe the stenographers check it. It's on page 25, line 17. I believe the witness said five years, and it's been recorded as five days.

JUDGE ROBINSON: Yes. That correction will be made. Mr. Milosevic, your turn for cross-examination. I ask you, when ¹²⁴⁷⁶ you're cross-examining to avoid, as best you can, speeches, questions which are too long. Make your questions as short as possible. Avoid narratives and concentrate on asking short questions. You have about four hours and 50 minutes, which you do not have to use. Please proceed.

THE ACCUSED: [Interpretation] Thank you, Mr. Robinson, especially for this warning to take care how much time I will use up Cross-examined by Mr. Milosevic:

[Witness answered through interpreter]

Q. [Interpretation] I see from your statement that you claim that as a very young man you started working for the KOS.

A. Yes, that is correct.

Q. That dates back to 1968, as I understand it.

A. Yes.

Q. This activity of yours was never interrupted until the end of the war --

A. Actually, it continued until 1999.

Q. 1999?

A. Correct.

Q. From 1968 to 1999?

A. Let me be precise: Until the 22nd December, 1998.

Q. All right. And all this time, from 1968, you filed your reports to a person by the name of Nikola Zimonja; is that correct?

A. Yes, for the most part, correct.

Q. What do you mean, "for the most part"? Did you file reports to someone else as well, but reports to him were regular? ¹²⁴⁷⁷

A. Correct.

Q. How frequent were your reports to him in this entire period, from, let's say, 1968 to 1992, when I see that you joined the army of the Serbian Krajina? At the time you were a liaison officer and your activity was more intensive. But how often did you submit reports to Mr. Zimonja?

A. A minor correction: When I put on the uniform in December 1991, I put on the uniform of the JNA, not the army of the Serbian Krajina. And the reports were as frequent as my assignments.

Q. But in terms of time, how frequent, how regular, were these reports?

A. From 1991 to 1998, my reports were at least --

Q. I'm not talking about that period. I'm talking about from 1968 to 1992.

A. Once a week.

Q. Regularly, without interruption, throughout those years?

A. No. There were periods when I didn't file any reports at all.

Q. How long were these periods?

A. There were some that lasted a year, a year and a half.

Q. What were those years when you filed no reports?

A. It's very difficult to remember when precisely, but let's say in 1985, 1986, or in 1983 there were regular reports during the Winter Olympics, and in 1979 I didn't submit any reports at all. What I'm trying to say is that I drew up reports if I had anything specific to report. I didn't make any contact if there was no need for that.

Q. I understand. You joined the army in end 1991, and later, in the ¹²⁴⁷⁸ beginning of 1992, if I understood you correctly, you were already part of this corps commanded by Colonel Bulat, which was, as you describe here, the 21st Corps of the army of the Serbian Krajina, Republic of the Serbian Krajina; is that correct?

A. Yes, it is.

Q. At the very beginning of your testimony yesterday, you explained that Colonel Bulat had direct contact with Perisic, without strictly adhering to his vertical chain of command with the headquarters of the Serbian Krajina army; he went straight to Perisic.

A. What I said in my testimony was that he had direct contact with Colonel Perisic along the line, which was a direct connection between the 21st Corps and the headquarters in Belgrade, and along another line he had contacts with the headquarters of the army of the Republic of Serbian Krajina.

Q. How do you know that?

A. I was at the office when he made his phone calls to Perisic.

Q. What were those occasions?

A. The one that comes to mind first was the one that related to the joint attack with the 5th Corps of the Serbian army.

Q. When was that?

A. I believe it was in 1993. It is also fair to say that there were several attacks of this kind, so I don't remember now what specific attack it was at that time.

JUDGE KWON: Just a second. Mr. Lazarevic -- ¹²⁴⁷⁹

THE WITNESS: Yes, Your Honour.

JUDGE KWON: Could you put a pause between question and answer.

THE WITNESS: I do apologise.

JUDGE KWON: In the transcript I note that Mr. Perisic is referred to as "Colonel"; is it right?

THE WITNESS: No, he's a general.

JUDGE KWON: General Perisic. It was in line 8 of page 29. Okay. Proceed.

MR. MILOSEVIC: [Interpretation]

Q. So from 1992 until 1993, you never heard Bulat speaking to Perisic; right?

A. No, not with my own ears. I wasn't there.

Q. And this happened in 1993?

A. I sincerely believe it was.

Q. Wasn't it in 1994 and 1995, since you later described these events as happening in these years?

A. No. It was one of the earlier attacks.

Q. Earlier attacks. And it was 1993?

A. Yes. I'm sure it was in 1993.

Q. I'm only trying to establish a time frame for the events you're talking about.

THE INTERPRETER: Interpreter's correction. The attack was on the 5th Corps of the Bosnian army.

MR. MILOSEVIC: [Interpretation]

Q. You started working for KOS of your own free will, didn't you? ¹²⁴⁸⁰ You said that you accepted this work after your discussion with this person Nikola Zimonja, in your youth, and that's how had you started your work as a spy. Did that happen of your own free will?

A. Absolutely. In fact, I was very enthusiastic when I started working. I was delighted.

Q. And do you imagine it was not difficult to find out that even Nikola Zimonja himself, at the time when he engaged you, as you say, was a student himself and had nothing at all to do with the KOS?

A. I didn't know that. He was introduced to me as the lieutenant of the Yugoslav army.

Q. Who introduced him that way?

A. My own father did.

Q. And you didn't know he was a student; is that what you're saying?

A. Absolutely not.

Q. All right. Fine. So you saw Nikola Zimonja for the first time in 1968; right?

A. Yes, right.

Q. That's what you say.

A. Yes.

Q. You see, I have a piece of information here that tells me that you met Nikola Zimonja for the first time in 1995.

A. That is quite an incorrect piece of information, Mr. Milosevic.

Q. I just want to test it, see if it's right. You explained to me a moment ago that up until 1991, except for the pause you made in 1984 and then one year of pause later on, you sent in your reports regularly to ¹²⁴⁸¹ Zimonja. Do you happen to know, for example, that Nikola Zimonja, from 1971 up until 1980, was undergoing education in the former Soviet Union? Does that mean that you sent those reports to him to the Soviet Union in that nine-year period, from 1971 to 1980?

A. No, Mr. Milosevic. I would send in my reports to the Yugoslav Embassy and they were to further hand them on. The reports probably went to somebody else, because I would never hand in my reports to Mr. Zimonja personally. I would leave the reports in the embassy.

Q. All right. I asked you a very specific question. I asked you who you sent your reports to, gave them to, and you said yesterday all day that you gave them to Zimonja. Now you say that you sent them in to Zimonja, and when I ask about that nine-year period and tell you that he was doing some education in the Soviet Union, you said that you did not give them to Zimonja.

A. Mr. Milosevic, the reports that I sent in were addressed to Zimonja. Now, who was getting those reports, I don't know. I thought they were going to Zimonja. Whether anybody was authorised to take the reports over on behalf of Zimonja, I can't know that. I don't know.

Q. All right. So many things that you claimed yesterday throughout the whole day in fact I suppose you base them on assumptions, like you do this particular fact and point, or perhaps --

JUDGE ROBINSON: Yes.

MR. GROOME: It's a characterisation --

THE INTERPRETER: Microphone, please, Mr. Groome.

MR. GROOME: It's a characterisation of Mr. Lazarevic's evidence. ^{12482 BLANK PAGE 12483} He's certainly entitled to ask him about specific facts that he believes the witness assumed, but certainly to make a broad statement that everything that the witness said was based on assumptions I believe is an improper question.

JUDGE ROBINSON: I don't think it's really a question. It was more a comment.

Continue, Mr. Milosevic.

THE ACCUSED: [Interpretation] Well, I have to respond to the opposite side, Mr. Robinson, because if I were to present generalised statements --

JUDGE ROBINSON: I have dealt with it. I have told you to continue. Continue.

THE ACCUSED: [Interpretation] Very well.

MR. MILOSEVIC: [Interpretation]

Q. You yourself say, Mr. Lazarevic, that he, and I'm thinking of Zimonja here, in 1990 was nominated the military attache to Czechoslovakia; is that right?

A. Yes. That's Mr. Zimonja you're talking about.

Q. Right.

A. Yes, according to what Mr. Zimonja told me, that he was appointed.

Q. As he was appointed military attache in 1990, then, how can you claim that Zimonja was at a meeting with you in 1991 in Vojnic and Samarica at the beginning of 1992, when he was in fact the military attache at that time in Prague?

A. He attended those meetings, Mr. Milosevic. Whether he was still ¹²⁴⁸⁴ there in capacity of military attache to Czechoslovakia, whether he had been replaced by that time, I don't know and I'm not interested, but the fact remains that Colonel Zimonja was present at those meetings.

Q. All right. Fine. Tell me this, then: Let's go back to your assignments. Your first assignment, as you yourself say, was to spy on your colleagues, fellow students, during the 1968 demonstrations. Is that right?

A. Spying is an ugly word. The term we used was we infiltrated.

Q. Well, I agree that it's a very ugly word, but that is the contents of substance, as I understand it, of your work entailed. As you were a student and as your statement -- and until yesterday morning you were a protected witness at that, it has been redacted and I wasn't able to see what faculty you graduated from, where and when.

A. Philosophy, Sarajevo.

Q. The faculty of philosophy in Sarajevo; is that right?

A. Yes, that's right.

Q. What group?

A. Languages.

Q. Tell me: For your first assignment and from the time you began your work, were you paid for it?

A. Yes.

Q. So a moment ago you said you were delighted with the work you were doing, and when we make up this whole picture we now see that you were paid for your work. So the basic motive -- or rather, the motive for your involvement was money; right? ¹²⁴⁸⁵

A. No, that's not correct, Mr. Milosevic.

Q. What was your motive, then?

A. Purely ideological.

Q. So how much of it was ideological, how much was it lucrative?

A. Well, money wasn't important for me at that time.

Q. All right. Yesterday we heard from you that you received a new identity here, a new country of residence, and so on and so forth. I assume that you were given money too. So in this situation and in this particular instance, the motive wasn't a new identity and money, but it was ideological; is that it?

A. If, Mr. Milosevic, if I were to have to say why I did what I did, fully disclosing my personality as just an attempt to establish the truth of the events that took place in 1991 that I was present at, and my identity, where I am residing, is completely irrelevant to this trial.

Q. Yes, I understand that it is irrelevant, but what I'm asking you is this: How far was the motive of, how shall I put it, the material side, material gain, relevant, the material gain that stems from a new identity, a new country of residence, I assume a new job, for you and your family? Although it is irrelevant, as you yourself say, with respect to your testimony, but how relevant is it as a motive?

A. Mr. Milosevic, at this point in my life, I am living from one salary, pay cheque, to another, so if you are trying to insinuate that somebody has paid me a large sum of money for me to appear here today, you're quite wrong.

Q. All right. Fine, Mr. Lazarevic. So to all intents and purposes, ¹²⁴⁸⁶ as you began doing this in your student days, this was your in early youth and you spent your entire life, as you yourself claim and state, working, spying on your colleagues, fellow students to begin with, then you spied on your colleagues from work, I can see from the rest of the explanations you gave here, and finally, you spied on your co-combatants, your fellow fighters, during the war in Croatia; right?

A. Mr. Milosevic, there's something lacking there in your question, and that is who issued the orders to me to spy. I did not work for some minor service. I worked for the intelligence service of Yugoslavia, working on Yugoslavia's internal and external security. So to say that I was a spy is not quite logical in that sense, because I was in fact working for my own country, the country that you yourself belonged to at that time.

Q. Well, that's why I'm asking you, Mr. Lazarevic, precisely because I find it strange that somebody was working in KOS and that nobody knows him in KOS, nobody knows about him, including, in 1995, the man who you refer to constantly.

You say in your statement that for a period of time you were in London. Did you spend some time in Canada?

A. Never.

Q. You were never in Canada?

A. No.

Q. And while in London, you were in charge of the Serb emigres there; right?

A. Yes. ¹²⁴⁸⁷

Q. Now tell me: Your impressions at that time and your opinions now, how far was the Serb emigre population nationalistic at all, nationalistically disposed? How far was it a political opposition to the present authorities in Yugoslavia?

A. To a very minimum extent.

Q. I see. A very minimum extent.

A. Yes, that's right.

Q. And what is your impression? How far were the Serbs anyway anti-Croat disposed at all and were they ever anti-disposed against the Croatians or Croats? Did you ever feel that?

A. Where? Where do you mean?

Q. Well, when you were spying on the Serb emigres.

A. That wasn't the object of my assignment. The object of my assignment was to find who was in the leadership of those organisations and what their future plans were, if they had any, and whether they had any links with the emigres or other emigres or, rather, people within Yugoslavia, not whether they were anti-Croat disposed. Actually, at that time, they were anti-Tito.

Q. You mean anti-regime. They weren't anti-Croat or anti-anything else, they weren't confronted on that basis with anyone; right?

A. Yes, you're quite right there.

Q. Now, was there any nationalism and nationalist confrontation in what you saw with the Croatian emigres? And I'm thinking of the Ustasha emigres.

A. Yes, that was very strong and very pronounced. ¹²⁴⁸⁸

Q. I see. You say very pronounced.

A. Yes.

Q. Do you know the role played by the Croatian Ustasha emigres in the events that took place before the break-up of Yugoslavia?

A. I'm partially aware of that, yes.

Q. How far was this anti-Serb feeling which otherwise burgeoned in Croatia in 1989 and 1990, prior to the elections and after the elections, how far was that -- did that have its influence on the Ustasha emigres and how much did they wield influence on the citizens and political parties, et cetera? So how far did this sentiment affect the Serbs not only in the Krajina but all over Croatia?

A. Are we talking about any of the Croatian emblems, the chequerboard emblem, radio stations, singing of songs or whatever?

Q. Well, I'm not only talking about those emblems and the singing of nationalistic songs, although I do mean that too. I'm talking about dismissals from work, placing mines and bombs in apartments and houses, the killings, the fact that people were taken off, and something that the Croatian press is quite freely writing about today. I'm sure you read the Croatian press. And there's talk of that quite openly now and discussions that are being held there now. So everything that went on along these lines, did that have any affect and influence on the Serbs, not only in the Krajina but throughout Croatia?

A. Probably it did, yes.

Q. And do you know, because you say you worked for KOS, so do you know just how many members of the Ustasha emigres at the end of 1989 and ¹²⁴⁸⁹ beginning of 1990 returned to Croatia, and how far they wielded an influence on official Croatian policy and the policy towards the Serbs, first and foremost?

A. Well, I do have some knowledge, but it would be ludicrous if you thought that I knew everything. Unfortunately, I don't know everything, although I would have liked to have known everything. But the fact is that I did know some of the members of the Ustasha emigres who were present in the areas I moved around in, and specifically, for example, the leader, or rather, the commander of Karlovac. One of the Brate Brajdic and two others that had come in from Sweden. They were well known people in the very rigid stance they had towards Serbs and Serbs in Yugoslavia, and so on and so forth.

Q. All right. The brothers you mentioned that had come from Sweden that were rampant in those parts, you say you don't know much about them, because, as far as I was able to understand, you were in Topusko and Vojnic.

A. Velika Kladusa, Mr. Milosevic.

Q. Right.

A. Before the conflict.

Q. Right, before the conflict in Velika Kladusa, and after that in Topusko and Vojnic. So you don't know much about the events that I'm asking you about, because you weren't -- you couldn't have known and seen everything from where you were.

A. Yes, mostly I got my information from others. At some of these events I was present myself. ¹²⁴⁹⁰

Q. How, then, from your positions in Velika Kladusa and Vojnic, you have a whole image and picture of the state of affairs in the Republic of Srpska Krajina about the alleged Serb crimes, about all kinds of, as far as I was able to hear from you yesterday, crimes that were committed and the casualties of those crimes. You were an interpreter, you say, and as such a liaison officer with the UN, so how were you able, from that position and that place, to have all these myriad information that we heard about yesterday?

A. Well, the information I presented yesterday relates to the period from February 1992 until August 1995, when I was the liaison officer, which meant that I was in constant contacts with the United Nations commands on the territory of the 21st Banija Corps. So most of those reports were accessible to me on a daily basis.

Q. Well, it is from those UN reports, is it, that you draw your conclusions, you deduce, if I can put it that way, and bring conclusions as to the political intentions and political leadership of the Republic of Srpska Krajina, of Serbia itself, of Yugoslavia, of the general political state of affairs, the military state of affairs and all the rest of it? Is that the basis from which you drew all this information, all your explanations?

A. I said at no point that the groundwork and foundations of my knowledge were United Nations reports. Most of the events that I describe I was present at myself, personally, and the events that were talked about during the briefings, early-morning briefings at my command and headquarters. So it was a compilation of knowledge and information, not ^{12491 BLANK PAGE 12492} only from a single source, but from a number of sources, including my own personal experience.

Q. All right, then. How come in those personal experiences of yours there is nothing -- I don't wish to make a comparison, but for instance, we had here a journalist. His name was Jovan Dulovic. He also knew nothing about the great crimes that were perpetrated against the Serbs, for example. So you too have nothing and know nothing about the crimes perpetrated against the Serbs, but you explain here and give explanations to the effect that Serbs were criminals, thieves, that they burnt houses, tortured, that they set mines; that they didn't want anything that was good. They didn't want peace, they didn't want a truce of any kind, that they undermined each and every initiative to move forward. How come you make that kind of --

JUDGE ROBINSON: Yes.

MR. GROOME: This is an inaccurate characterisation of what the witness testified to yesterday, and I don't see a question being posed to the witness at this time.

JUDGE ROBINSON: Mr. Milosevic, I remind you --

THE ACCUSED: [Interpretation] Let me reformulate that question.

MR. MILOSEVIC: [Interpretation]

Q. The thousands of Serbs that were killed, did the Serbs themselves kill them? Because you say and said a moment ago they were responsible for 80 per cent of their own victims in the Krajina between 1992 and 1995. Or was this committed, these crimes perpetrated by the revamped Ustasha movement? ¹²⁴⁹³

A. What I said, it refers to the 21st Corps, Mr. Milosevic. They were not generalised figures. I spoke about an analysis of the deaths that occurred within the 21st Corps. These figures do not relate to the whole of the Balkans or of the RSK or Croatia or Serbia; I'm just talking about the territory that I was -- had operative assignments in.

Q. So the figures just relate, as you say, to where you were, whereas all the other observations relate to the entirety of the events that took place in Yugoslavia, in Croatia, the Republic of Srpska Krajina, the Srpska Republic and Serbia proper; right?

A. Only what applies to Kordun. I never gave a general statement here that would cover everything, the entire territory. If I gave evidence, I talked about events where I was present personally.

Q. All right. Let us then turn to other issues. In 1984, as you claim yourself, you started, again on orders of KOS, working for Agrokomerc in Velika Kladusa; is that right?

A. Yes.

Q. And you say that you were in charge of foreigners and that later on you switched and started working in the production area.

A. Yes. I was in research and development department.

Q. And throughout the time, based on my information, you worked there as an interpreter, and your wife's name is Zorica?

MR. GROOME: Objection, Your Honour.

JUDGE ROBINSON: Yes, Mr. Groome.

MR. GROOME: Can Mr. Milosevic state the reason why it's necessary to identify this man's wife, given the history of this witness? How is ¹²⁴⁹⁴ that relevant?

JUDGE ROBINSON: Yes, but is he giving evidence in private session or no?

MR. GROOME: Your Honour, this witness is in a unique situation in that he has been relocated. Unless there's some relevance to mentioning the wife's name, I would ask that the question be stricken, and if there is some relevance, that it be taken in private session.

JUDGE ROBINSON: Mr. Milosevic, can you explain the relevance of this?

THE ACCUSED: [Interpretation] Well, Mr. Robinson, I am here challenging what the witness said, namely, that he went to work for Agrokomerc pursuant to KOS orders, that he started working -- because he started working as an interpreter there, he got that job through his own contacts, whereas his wife worked as a physical education teacher.

JUDGE ROBINSON: Out of an abundance of caution, we'll go into private session for this question.

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[Open session]

MR. MILOSEVIC: [Interpretation]

Q. So you're claiming that Belgrade was already concerned at that time regarding the safety of Agrokomerc because it was already under the control of the Muslims at the time?

A. Yes. This is how it was portrayed to me. ¹²⁴⁹⁸

Q. And when you say "Belgrade," are you referring to the federal government or Republic of Serbia?

A. I'm referring to the Main Staff of the JNA and KOS.

Q. And if there was a concern, do you think that the reason for that was that Agrokomerc was under the control of Bosnian Muslims, or was it because of the financial scandal that broke out and started shaking this huge company that was established in that area?

A. I didn't go into reasons for sending me there.

Q. You didn't go into these reasons; however, you stress the nationalist aspect and not the financial one that was well known in Yugoslavia at the time.

A. There was a large amount of foreign nationals in Velika Kladusa, and that was quite an important piece of information at the time.

JUDGE ROBINSON: Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. A high number of foreign nationals?

JUDGE ROBINSON: We are at the time for the break. Mr. Lazarevic, we're going to take a break for half an hour.

[Trial Chamber confers]

JUDGE ROBINSON: We take the break for 20 minutes. During the break you're reminded not to discuss your evidence with anybody.

--- Recess taken at 10.30 a.m.

--- On resuming at 10.51 a.m.

JUDGE ROBINSON: Mr. Milosevic, you'll continue with your cross-examination. ¹²⁴⁹⁹

MR. MILOSEVIC: [Interpretation]

Q. Since you say yourself that you followed the activities of Sulejman Ugljanin at the time in Velika Kladusa concerning the SDA, tell us, please: What was that party all about?

A. I don't quite understand your question. What do you mean, what was the party all about? What kind of a party the SDA was?

Q. Yes.

A. It was a nationalist party.

Q. And in addition to this nationalist character of this party, were there also elements of Islamic fundamentalism?

A. Yes, absolutely.

Q. Who did Ugljanin meet with in Velika Kladusa area?

A. With Fikret Abdic.

Q. I didn't hear.

A. With Fikret Abdic.

Q. All right. And were any Serbs members of the SDA?

A. I didn't know about that.

Q. You worked in Velika Kladusa normally, legally, under your own legal name?

A. Yes, that's right.

Q. Please explain to us: How was it that you, as a Serb, were able to attend those meetings of the SDA in order to be able to follow Sulejman Ugljanin's activities?

A. I didn't attend private meetings of Sulejman Ugljanin, but I did attend public meetings that were held at the local soccer field. ^{12500 BLANK PAGE 12501}

Q. All right. Since you said yourself that you spent seven years there, using your own legal name, yesterday you described an event when you were in a cafe, and this was just prior to what you described as an assignment when you had to eliminate the emigres from Sweden, the brothers Brajdic, and then yesterday you told us that two officers entered the cafe, that they were drunk, if I understood you well, and that they said something about Greater Serbia, and in a way they got you involved in that and compromised you. Is that right?

A. Everything you said was correct except for one thing: I wasn't present in a cafe where the attack was supposed to be carried out, but I was in another cafe.

Q. All right. But at any rate, was it right?

A. Yes.

Q. You said that two officers came in, they were drunk, and said something about the Greater Serbia.

A. Those were two officers from the JNA.

Q. All right. From the JNA. And what did they say?

A. They said that this whole area where we are now will be Greater Serbia soon.

Q. All right. That's what you said yesterday and this is what is contained in your statement regarding that event. This is on page 7. You said that: "I happened to be in a cafe on the 21st of December, 1991, three days prior to the planned ambush, when a captain entered the bar wearing a JNA uniform, completely drunk. As he entered, he started yelling, 'Brother Serb.' It was clear that he was addressing me because I ¹²⁵⁰² was the only Serb in that establishment. I tried to ignore him, but it didn't fool anyone. I immediately left the bar, went back home, and through -- contacted police station in Vojnic on the radio. I told Ajdinovic what had happened. He told me to go and calm down the captain and that he would send someone to collect him," and so on. So yesterday you said that two people came and spoke about the Greater Serbia, and in your statement you say that it was the JNA captain who came in, drunk, and said to you, Brother Serb, "Brate Srbine." In Velika Kladusa, everyone knew that you were a Serb - you just told us that you used your legal name - so how could this have compromised you when he called you Brother Serb?

A. He didn't just call me Brother Serb. He also kissed me and then he spoke how all of this will be Serbia one day. And I simply completed what I said in my statement.

Q. All right. But isn't it clear that there is a great difference between what you wrote in your statement and what you said here?

A. I don't see any great discrepancy here. I just see that I added some details.

Q. Do you mean that the details are the difference between one captain or two drunk officers?

A. I said two officers in my statement three years ago.

Q. Well, your statement here reflects just one person and one captain, so are you saying that this is another mistake in your statement?

A. No. There is no mistake in my statement. I spoke about two drunk officers. It is possible that later on, when the statement was ¹²⁵⁰³ translated, there was an error made, but I don't want to go into that.

Q. All right, Mr. Lazarevic. Tell me, please: How did you come to leave Agrokomerc?

A. I was accused of taking some documents from the office of Mr. Fikret Abdic.

Q. That you took some documents from the office of Mr. Fikret Abdic?

A. Yes.

Q. And is it true that you were fired from Agrokomerc due to some debts that amounted to 30.000 German marks and that when -- and that you fled in 1991 to the village of Gejkovac?

A. That's absolutely not correct. Upon leaving Agrokomerc, I remained in Velika Kladusa for that entire year, working in my own company.

JUDGE ROBINSON: Mr. Milosevic, and Witness, I can sense that the speed is working a hardship for the interpreters, so you must observe a pause between question and answer, both of you.

THE WITNESS: I sincerely apologise, Your Honour.

MR. MILOSEVIC: [Interpretation]

Q. So you didn't spend three months in the home of the Lakic family?

A. The Lakic family? I never heard of them.

Q. And tell me, please: Is it true that you had -- you owed 2.000 German marks to Toso Pajic, and to Djuro Skaljac you owed 1.500, and to another person 3.000 German marks?

A. That's all incorrect.

Q. All of it? ¹²⁵⁰⁴

A. Yes, all of it.

Q. All right. In the beginning of 1990, you established your own company, for which you say was financed by KOS.

A. Partially.

Q. What does "partially" mean?

A. "Partially" means that part of the equipment was paid by the JNA money.

Q. You said that in 1990, beginning of 1991, KOS left you alone.

A. Yes, more or less they did.

Q. I understood that you started working on your own free will, based on what you just told us, and now you're telling us that they left you alone. Does that mean that prior to that they harassed you, or does this "leaving alone" mean something else?

A. Working for KOS was no harassment at all. It was part of my nature.

Q. All right. On page 6 you describe an alleged meeting that you had in Vojnic at the police station with Zimonja, Ajdinovic, Pajic, and Lukic; is that correct?

A. Not Lukic; Skaljac.

JUDGE ROBINSON: Mr. Groome, do you have the statement?

MR. GROOME: Yes, I do, Your Honour.

JUDGE ROBINSON: I think we should have copies.

MR. GROOME: I'd also ask that witness be provided a copy. It's a lengthy statement and seems unfair for him to be asked particular sentences. ¹²⁵⁰⁵

JUDGE ROBINSON: Yes. Let that be done.

MR. GROOME: Your Honour, I have one copy here. I'll have somebody photocopy -- copies for the Chamber and we should have them in the next five minutes.

JUDGE ROBINSON: Thank you. Fine.

MR. GROOME: And I would ask that Mr. Milosevic please tell us is it the Serbian copy or the English copy when he refers to a particular page number. It will be helpful.

THE ACCUSED: [Interpretation] All right.

JUDGE ROBINSON: Yes.

THE ACCUSED: [Interpretation] Right.

MR. MILOSEVIC: [Interpretation]

Q. I'm asking you again: Isn't it true that at that time Zimonja was a military attache in Prague?

A. I don't know about that. All I know is that he attended that meeting.

Q. You say at the police station in this line of untruths that you are saying here, none of these people had any status in the police force. Was that the military command?

A. Not correct. Toso Pajic was the chief of police in Vojnic, and Djuro Skaljac was his deputy.

Q. Answer me: Was it the military command pulled out from Karlovac because they were under constant siege and attack by Croatian paramilitary formation?

A. There was not a military command in Vojnic. It was in a different ¹²⁵⁰⁶ place at the time.

Q. Does that mean that this Operative Group was pulled out of Karlovac where it was exposed to attacks by Croatian paramilitary formations?

A. I really don't know.

Q. Do you know that the task of the then command was to accept parts of the JNA that had been blocked in barracks in Jastrebarsko, Karlovac, and Zagreb?

A. All these events that you are mentioning, Mr. Milosevic, happened before I moved to the Republic of Serbian Krajina.

Q. All right. You claim that Zimonja, who was then in Czechoslovakia, said that Croatians and Muslims are working together to establish paramilitary groups and that these groups are a greater threat to civilians than to the JNA.

A. No. In the report that I made, it said lesser threat, not greater. I remember that I did not attach great importance to those elements in Velika Kladusa.

Q. Further on, you say that you felt yourself that it was your patriotic duty to help the organisation of the self-defence of Serb civilians. Is that true?

A. Yes. I always felt that.

Q. So what was the threat to them exactly when they needed to organise self-defence?

A. Establishment of very nationalist parties, such as the SDA and the HDZ, which did not conceal their animosity to the Serbian population. ¹²⁵⁰⁷

Q. Does it mean unequivocally, then, that Serbs in Krajina and in this area of Zazine were jeopardised by the rising Croatian and Muslim nationalism?

A. Of course they were.

Q. You assert that at that meeting the plan of attack on Cetingrad was also discussed.

A. Yes.

Q. And as you say, Ajdinovic advocated that everybody should be locked up and killed by shelling. Is that correct?

A. Yes.

Q. Is it correct that in Cetingrad there were no Serbs at all?

A. I don't know.

Q. What happened to Serbs from Cetingrad? Were they expelled?

A. I already said that I don't know about any Serbs being in Cetingrad at all at the time I'm speaking about.

Q. All right. You say that you got the task to form a secret group at that meeting, which you say consisted of you, Mile Bosnic and a person named Zeljko, who you know nothing else about.

A. It was not about forming a secret group. It was about organising Serbs in Velika Kladusa for any contingency.

Q. What kind of Serb it is if you don't know anything but his name?

A. I'm talking about Mile Bosnic. His wife was a hairdresser. This Zeljko person was a driver to Mile Bosnic and he had no major role.

Q. On page 7, you said that at the police station in Vojnic you were issued with equipment and weapons for this secret group. ¹²⁵⁰⁸

A. That's not true. The weapons were issued for a specific assignment we got.

Q. Which specific assignment?

A. Elimination of Ustasha emigres and those helping them.

Q. Who was supposed to carry out the task?

A. Myself and two JNA officers.

Q. Is that the assignment where your cover was blown by somebody telling you "Brother Serb" in a cafe?

A. More or less. There are more details that I didn't mention in the incident when they entered the cafe.

Q. How could they have blown your cover if you had lived in Velika Kladusa for a long time by then and everybody knew you were a Serb?

A. I wasn't active politically.

Q. And by addressing you as Brother Serb, he proclaimed you politically active; is that so?

A. Yes, you're right.

Q. You say that you were supposed to distribute weapons to them and see them every day. Did you do that?

A. The weapons I received were issued for my use, and it was stored at the apartment where I lived. And who was I supposed to meet on a daily basis?

Q. I'm asking on the basis of your statement. You got three rifles. They were not all for your personal use, were they?

A. I got one Scorpio with a muffler, an automatic rifle with two cartridges, a pistol, and four hand grenades. ^{12509 BLANK PAGE 12510}

Q. These rifles mentioned in the statement, you didn't get?

A. Mr. Bosnic received them for other Serbs.

Q. All right. Look up your own statement and you will see it is not correct either.

A. Which page, Mr. Milosevic?

Q. I'll find it. Give me a second. I'm sorry to waste time in this way, but ...

Here it is, on page 7. "In this period I was invited to the police station in Vojnic." The beginning of page 7. "At the police station in Vojnic I was issued with weapons and other equipment; a Scorpion with silencer, three automatic rifles (Yugoslav version of AK-47), a pistol, four hand grenades, ammunition, and two Motorola radios. All of these things were given to me in a bag by a uniformed policeman as I left the station. I was told that I should notify Bosnic and Zeljko, last name unknown, to be ready to go into action should I contact them. I was to distribute weapons to them and I was supposed to meet with each of them at least once a day to see if they had heard or seen anything suspicious. If they had, I was to report it to Vojnic. Otherwise, I was told to return to Velika Kladusa and await further instructions." End of your quotation. Of your statement, by the way. You claim it is not correct.

A. No, this statement is correct. But, Mr. Milosevic, two minutes ago when you asked the question, you asked me: Did you meet with them every day? And I was assuming that you were talking about JNA officers who were supposed to carry out that assignment, because that question ¹²⁵¹¹ seemed to refer to that statement which was actually never carried out. Mr. Bosnic was a family friend and I could have seen him every day. And his driver as well, because he was always with him.

Q. I quoted this because you said earlier that those three rifles were received by you for your own personal use, and I asked what for, and you said it was not correct.

A. I'll repeat again what I said. I said I got a pistol with a muffler for my own personal use, rifles, four hand grenades, two Motorolas, et cetera. The three automatic rifles mentioned in my statement were given to Bosnic for other people.

Q. How can you read this differently? It says here, "I was invited to Vojnic and at the Vojnic police station I was issued with weapons and other equipment; a Skorpion with silencer, three automatic rifles, a pistol, four hand grenades, ammunition, and two Motorolas."

A. So where is the difference between your statement and my statement?

Q. This is not my statement. You say that you did not receive three rifles.

A. Let's rewind a little. You say that I got it for my personal use and I'm saying that they were given and intended for Mile Bosnic; Motorolas, hand grenades, a pistol, yes.

Q. Yes, but you also got rifles.

A. I did, but they were given to Bosnic.

Q. You said a moment ago the rifles were given to someone else, not you. You can look up the transcript later. I don't want to waste time ¹²⁵¹² over this.

Tell me one other thing: What was the name of that policeman who issued you with these weapons and equipment?

A. I don't remember.

Q. You don't know?

A. No.

Q. Are you sure that somebody issued these weapons and equipment at all?

A. Of course I'm certain.

Q. You describe the attack on Cetingrad.

A. Precisely.

Q. Please, what date did the attack happen?

A. As far as I can remember, it was late October. In 1991.

Q. Who made or who could have made the decision to attack Cetingrad?

A. The JNA.

Q. You said it was made by Ajdinovic, Pajic, Skaljac, and Zimonja.

A. They made the recommendation to the General Staff of the JNA in Belgrade.

Q. Are you aware that the decision on that attack was made by the headquarters of the Territorial Defence that was in Vojnic at the time, whereas Vojnic was not in the RSK at all at the time?

A. I don't know that the Territorial Defence had anything to do with if. Did they have artillery or was the artillery in the hands of the JNA? All I know is that two high-ranking officers of the JNA analysed the situation on the ground, submitted their report to the General Staff in ¹²⁵¹³ Belgrade, and then the attack followed. That's all I know.

Q. All right, Mr. Lazarevic. If you had only read newspapers from that time, or if you had only asked anyone, you would know now that it is not true. The attack on Cetingrad was on the 28th of November, 1991.

A. Mr. Milosevic, we are talking about things that happened 12 years ago. You can't expect me to remember the exact date, hour, minute and the rest. All I know, it was cold, it was winter.

Q. All right, then. The fact that this piece of information you quoted is incorrect has no importance, does it?

A. That's not quite true. I know the event happened. I was there. Whether it was in late October or in November is not so important to me.

Q. It was on the 28th November. Anyway, why did the attack happen?

A. I don't know.

Q. Do you know that the attack was caused by the fact that paramilitary formations in Cetingrad, several days before the attack, killed Lieutenant Colonel Rankovic and later, out of fear, and almost without a fight, left Cetingrad?

A. That's interesting, because the information I had was that this lieutenant colonel was killed with a bullet in the back.

Q. In Cetingrad?

A. I know -- I heard that he was killed by Serbian forces. Intentionally or not, I don't know.

Q. He was not killed in combat?

A. He was killed outside of Cetingrad, and the medical report said that the bullets came from the back. ¹²⁵¹⁴

Q. And then Croats, after the matter of Rankovic, left Cetingrad almost without a fight, because Serbs had killed him.

A. I don't understand.

Q. You claim that Rankovic was killed by Serbs.

A. I'm not claiming anything. Those were the rumours, the stories that made the rounds. Mr. Milosevic and Your Honours, I want to state very clearly once again: My testimony refers to events which I attended personally and not events that happened in Cetingrad while I was in Velika Kladusa. I can't give you any information on that.

Q. But you still speak about it. You refer to it in your statement. You can't say now that you know nothing about it. You said that Zimonja's plan was favoured and accepted and the corridor was left for the population of Cetingrad to leave.

A. That's all I know.

Q. When was the last time you were in Cetingrad before the attack?

A. I never really was in Cetingrad. I was in transit towards Plitvice twice.

Q. How can you say it was undefended except for perhaps a few men with small arms? How can you say that when you have no direct knowledge, as you say now?

A. I talk about things that I heard on the ground.

Q. Oh, so you heard about it. And tell me: Who were the people who defended Cetingrad?

A. I don't know that it was defended at all. I keep saying that the attack was carried out. I know I was standing on a hilltop with a group ¹²⁵¹⁵ of other people, that we were watching the explosions in the skies, and that the inflow from Cetingrad into Velika Kladusa ensued after that.

Q. And who was this -- who were these men who ran away to Velika Kladusa?

A. Some of them were armed, some were not.

Q. Do you know the extent of destruction in Cetingrad and the amount of casualties? Do you have any information on that?

A. No, I don't.

Q. You didn't take part in the attack?

A. No, I didn't.

Q. Did Brajdic brothers, whom you mentioned as Croatian extremists from Croatia, also flee Cetingrad?

A. Yes.

Q. And in mid-December 1991, you got the assignment to kill them; is that true?

A. Them and anyone else who happened to be in the cafe at the time.

Q. How can you explain -- a very simple question here: How can you explain that you, as an interpreter, a civilian, got an assignment to kill someone?

A. I didn't think of myself only as an interpreter or a civilian in those events, one; and second, the assignment I received boiled down to the fact that I was on the ground at the time, that I was familiar with that part of Velika Kladusa, that I was familiar with the persons in question, and I was supposed to be one of a threesome.

Q. You mean to say that this threesome was formed and you were one of ¹²⁵¹⁶ this threesome to commit a murder?

A. I wouldn't put it that way. You are putting things in a different context, and I can't explain it. It is a fact that the task was issued to eliminate someone. It is also a fact that it never happened. Another fact is that I left Velika Kladusa before anything happened, and eventually the assignment was never carried out. And in any case, I would have found a pretext to avoid it, whatever happened.

Q. So you accepted this assignment and a threesome for liquidation was formed, of which you were a member.

A. More or less, you are right.

Q. And you say, on page 8, paragraph 5, that some ten days later, another unknown officer, more precisely, a military policeman of the JNA, drove you to Samarica, in Banija, an isolated and very safe place in a national park between Petrinja and Bosanski Novi, which served as headquarters, operative headquarters of the JNA.

A. I'm trying to find this paragraph. Please bear with me.

JUDGE ROBINSON: Have you found it, Mr. Groome?

THE WITNESS: I'm still looking. It would be of very great help to me if Mr. Milosevic would actually tell me which page I'm searching for.

JUDGE ROBINSON: Page 8, paragraph 5, but I haven't found it in my text.

MR. GROOME: Is Mr. Milosevic referring to the Serbian version or the English version? Because the pagination will differ.

JUDGE ROBINSON: Is it the Serbian version, Mr. Milosevic? ¹²⁵¹⁷

THE ACCUSED: [Interpretation] I'm talking about the Serbian version, yes. Second paragraph from the top, page 8. "After these ten days passed, a military policeman showed up and told me to go with him. We drove to Samarica, in Banija, which was the headquarters of the JNA 8th Operational Group."

JUDGE ROBINSON: It's page 9 in the English text, the beginning of the second paragraph.

THE WITNESS: I've got it, Your Honour. I'm reading it now.

MR. MILOSEVIC: [Interpretation]

Q. And then you go on to say that it was very secure and it was a place between Petrinja and Bosanski Novi. "It was very secure and served as the JNA's operational headquarters for the northern part of Croatia," and so on and so forth.

Now, the headquarters of the operational group -- have you found it, Mr. Lazarevic? Have you found the passage?

A. Yes, I have. I found your version and now I'm looking at the English version that I have before me here. [In English] So what is the question? [Interpretation] So what is the question?

Q. The question is the following, Mr. Lazarevic: Once again you are thinking things up, because the headquarters of the 8th Operational Group was not at Samarica but at Petrova Gora. So why are you speaking untruths?

A. In February, March, 1992?

Q. Precisely when you say that the headquarters of the 8th Operational Group was at Petrova Gora and not at Samarica, and there are ^{12518 BLANK PAGE 12519} documents to bear that up.

A. Mr. Milosevic, I was told that it was at Samarica.

Q. All right. Quite obviously you have very characteristic answers when you're not telling the truth. You go on to say the following: Thanks to Zimonja at the time, you suddenly became a lieutenant colonel, got that rank. Is that what it says, "suddenly," in my report?

A. No.

Q. No, it doesn't. I'm asking you: Suddenly you were accorded a rank, and it was lieutenant colonel of the JNA --

JUDGE ROBINSON: Now, Mr. Milosevic, let us know the page to which you refer in the statement so that we can follow it.

THE ACCUSED: [Interpretation] I'm talking about that same paragraph, Mr. Robinson, and this is what he says: "I was given a uniform with a JNA's lieutenant colonel's rank," and in brackets, "As later to become the RSK army." "And given a room in a house at the headquarters. Zimonja was not present but it was obvious that he was responsible for my preferential treatment."

MR. MILOSEVIC: [Interpretation]

Q. Mr. Lazarevic, you know that two civilian persons with a university degree, whether they be doctors or interpreters, engineers or whatever, professionals in their field, they're always given some military rank by way of status, to denote their status, even interpreters, who went as civilians sometimes to the United Nations detachments, they would get ranks too, the rank of lieutenant or whatever, to give them some sort of status. So they weren't actually soldiers, the rank and file, but ¹²⁵²⁰ officers. So you, as an interpreter, were given this rank as a designation and not as an actual position and rank in the headquarters. You performed the function of an interpreter for English because you spoke English.

A. Yes. I didn't have any command functions at the headquarters.

Q. So you were a liaison officer - that was your function - with people who speak the same language as you do yourself; is that right?

A. Yes.

Q. Now, at that time -- let me first ask you: Was Bulat the commander there and then?

A. No, he wasn't.

Q. But did you hear him talk to Perisic on that occasion?

A. No.

Q. Do you claim that the army of Republika Srpska was formed from the JNA, or rather, that the JNA became the RS army?

A. Part of the equipment and manpower, yes.

Q. All right. When the JNA withdrew from Croatia, JNA members stayed on there who were from the region; is that right?

A. Yes.

Q. You were from Belgrade and you were an interpreter; right?

A. No. I was a liaison officer.

Q. All right. A liaison officer with the United Nations?

A. And the ECMM, and the Red Cross, et cetera.

Q. So with international organisations.

A. Quite right, Mr. Milosevic. That's what I was doing. ¹²⁵²¹

Q. So what I'm saying is the officers that were from the Krajina stayed on in Krajina to form the army of the Republic of Serbian Krajina; right?

A. Right.

Q. How, then, do you claim that the army of Republika Srpska Krajina was part of the army of Yugoslavia?

A. By virtue of its formation, by virtue of the orders it received, by virtue of the fact that it had brought in the convoy, equipped it with weapons, fuel, food, et cetera.

Q. Let's distinguish here between some sort of assistance from actual command, the function of command. Do you claim that the General Staff of the army of Yugoslavia was in command of the army of the Republic of Serbian Krajina?

A. I'm saying that the General Staff of the JNA was in command of the officers who were serving their time in the Krajina region and in the army.

Q. How can you claim that?

A. Because there was a constant link between the General Staff of the army in Belgrade and the headquarters of the Krajina army, and Belgrade paid the officers directly from Belgrade.

Q. Let's leave aside material assistance and remuneration. Do you claim - and please give me a very precise answer - that the army of Republika Srpska Krajina was part of the Yugoslav army, the army of Yugoslavia, and that the General Staff of the JNA commanded the army of Srpska Krajina? ¹²⁵²²

A. Yes, that is what I'm saying.

Q. You know that that is a lie, don't you?

A. No. I consider that to be a greater truth than the truth of you and me sitting here, Mr. Milosevic.

MR. GROOME: [Microphone not activated].

THE INTERPRETER: Microphone, please, Mr. Groome.

MR. GROOME: This characterisation of this witness's testimony as a lie is improper comment and is not a question posed to this witness. He asked the witness his opinion regarding a matter, and the witness replied.

JUDGE ROBINSON: I think he's entitled to put it to him that he's telling a lie. It's for the witness to answer.

Continue, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Do you know that the army of the Republic of Srpska Krajina had its headquarters, its main staff?

A. Yes.

Q. Do you know that the Republic of Srpska Krajina had its supreme defence council?

A. Yes, I know that too.

Q. So what connection did the supreme defence council of the army of the Republic of Srpska Krajina have with the General Staff of the JNA or the supreme defence council of Yugoslavia?

A. Through the chain of command, Mr. Milosevic.

Q. Mr. Lazarevic, never were you able to see this kind of chain of command and identify it because it simply didn't exist. How are you able ¹²⁵²³ to make that conclusion?

A. I have to repeat to this Tribunal every -- it was in contact with the JNA and headquarters from Belgrade, the officers that came from Belgrade on a daily basis practically, and the ones that left the Krajina went to Belgrade and the new contingent coming from Belgrade was a constant supply.

Q. You even said yesterday that officers were coming to replace each other on a six-month basis.

A. Yes.

Q. Is it true that the officers who were members of the JNA remained there and became part of the structure of the army of the Republic of Srpska Krajina? They were there throughout the war, they remained there, and nobody went to and fro, from Belgrade and the Krajina, or replaced each other after six-month term of office, and the people you mentioned didn't leave after six months, they were there all the time, because they were people from the Krajina originally; is that right or not?

A. You're not correct there. You're partially right but not right in all things because you know full well, just like I do, that the General Staff of the JNA would send officers regularly to do a six-month term of office by virtue of the place they were born in and then they would be returned to their own commands regardless of where they were. You know that and I know that.

Q. Mr. Lazarevic, what I know is something that is quite contrary to what you know, and that is what I'm saying that I'm saying and asking you the questions I'm asking you. Of course, we will have every opportunity ¹²⁵²⁴ to clarify the matter fully in due course.

So is it not true that just a part of the officer corps of the JNA, that is to say those who were from the region originally, after the withdrawal of the JNA from Croatia remained on in the Krajina and became active members of the army of the RSK?

A. The command component of the army of the RSK was made up by active officers of the JNA.

[Technical difficulty] Active officers. They continued wearing a uniform upon their return to Belgrade in the month of August.

[Technical difficulty]

JUDGE ROBINSON: We are getting French. Can it be resolved?

JUDGE KWON: Yes. Go on, Mr. Milosevic. Let's try.

MR. MILOSEVIC: [Interpretation] Very well.

Q. You claim, on page 8, paragraph 6, that at the beginning of 1992, Samarica was visited by Zimonja and said that the JNA said -- would withdraw from Croatia to Bosnia and that Belgrade had approved for the European Community Monitoring Mission, the ECMM, to enter into the area from Sisak and Karlovac; is that right?

A. Yes, that's right.

Q. When you say "Belgrade," I assume you mean the presidency of the SFRY.

A. Mr. Zimonja used the word "Belgrade" and I always assumed that he meant the Main Staff, the General Staff, and not the political structures.

Q. Well, I assume you know that the civilian structures at that time, ¹²⁵²⁵ the Presidency of the SFRY, as it was called, was in command of the army and was the collective supreme commander.

A. I do not assume anything, Mr. Milosevic. I'm just saying with great certainty what I know.

Q. Now, what you state, the withdrawal of the JNA and all rest of it, all the other things you state, does that mean that the peace plan was respected, both in the military and political sense, and that the SFRY and the JNA demonstrated that there were no aggressive intentions vis-a-vis Croatia, and that was all according to the Vance plan?

A. Mr. Milosevic, part of the JNA did withdraw. It is an indisputable fact that that same army, the JNA, left its officers behind to form the army of the RSK and that it left its heavy weaponry there for that army to use; therefore, yes, the plan was partially fulfilled, Mr. Milosevic, but not completely.

Q. All right. Tell me this, Mr. Lazarevic: As the JNA was composed of - while Yugoslavia existed I'm talking about - of the citizens from all the republics, when the crisis started and the Federal Republic of Yugoslavia established, its citizens or, rather, the citizens of Serbia and Montenegro returned to the territory of that same Yugoslavia. Similarly, the citizens of Serb ethnicity in the Republika Srpska Krajina stayed on on their territory, so also did the citizens of Croatian nationality stay on and formed the command cadres of their armed forces, so Muslim officers that had once been in the JNA remained in their own locality and became commanders of the Muslim army. All right. Let's not mention the Mujahedin now and anybody else from outside. I'm just talking ¹²⁵²⁶ about the internal elements and factors. Does that mean that the JNA formed --

JUDGE ROBINSON: Mr. Milosevic, you're speaking too --

THE INTERPRETER: Microphone, please.

JUDGE ROBINSON: Rule of thumb: Any time you exceed three or four sentences, it's going to be difficult for the witness to answer. Formulate a question.

MR. MILOSEVIC: [Interpretation]

Q. All right. Very well. Did the same thing happen with the Croatian officers who remained officers in the armed forces of Croatia, or the officers who remained in the armed forces of the Bosnian Croats or the remaining officers who stayed on in Alija Izetbegovic's army, did the JNA form all those armies, establish them all?

A. There is an essential, substantial difference once again, and Mr. Milosevic, you're only partially right. It is true that the redistribution of the JNA meant that the Croatian officers joined the Croatian army, the Bosnian officers joined the Bosnian army. However, in none of these cases did the JNA of its own free will leave its weaponry and officers, for example, in Croatia, nor after the dismemberment were there any contacts between those armies and the General Staff in Belgrade, whereas there were daily contacts between the officers of the RSK army with Belgrade. That is why I say you're partially right.

Q. You have absolutely no possibility of knowing about any type of daily contact that was held between officers and the General Staff in Belgrade. I assume that they must have had daily contact with the Supreme ^{12527 BLANK PAGE 12528} Command of the army of RSK and not with the General Staff in Belgrade. And even if were such a vertical chain of command and line to be organised, it had to go through the main headquarters of the ARSK because, otherwise, it couldn't have happened and wouldn't have happened in any other army.

A. Mr. Milosevic, it happened in this particular army.

THE INTERPRETER: Microphone, please, Judge Robinson.

JUDGE ROBINSON: Are you able to say how many JNA officers were left behind to form the RSK?

THE WITNESS: Your Honour, I would place it at a hundred per cent for the high-ranking officers.

JUDGE ROBINSON: All of the high-ranking --

THE WITNESS: Yes; all the generals and all the colonels.

JUDGE ROBINSON: Continue, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. All right. Now, were all these officers who stayed behind, who remained, were they all from that region originally?

A. I assume that they were, yes.

Q. So they stayed on in their own territory, on their own land, in their own towns and villages where they had come from, in the areas they were born and lived their whole life, their fathers and grandfathers lived in that locality; is that right?

A. Mr. Milosevic, it is illusory for you to try to claim that I met all the officers on the territory of Srpska Krajina. I just spoke about the ones that I had known. Whether they were all born and bred there, I ¹²⁵²⁹ really can't say. The ones that I knew, yes, they were. The ones that I knew were born there, they left the region, might not have been there for 40 or 50 years and then came back on assignment when the conflict broke out.

Q. Do you think they were given an assignment to go back or did they feel the need to go back, just like you said that you felt it to be your patriotic duty to defend and protect this area, just like the officers who had gone through an officer's training course, felt that same duty just the kind of duty that you felt yourself, or were they ordered by somebody else?

A. Unfortunately, Mr. Milosevic, not everybody was a patriot. Some people came for very selfish reasons, for example.

Q. What did you say?

A. I said for selfish reasons.

Q. Let's not go into those selfish reasons now. I haven't got time for that. But tell me this: Zimonja, on that occasion when he said that the JNA was withdrawing from Croatia, et cetera, et cetera, he said to you that you would be following Mile Mrksic, accompanying him, who, as you say, was the commander of the 8th Operative Group at the time, when you went to meetings with the observers; right? So how many meetings did you attend of that kind with Mr. Mrksic?

A. Probably about 20, at least.

Q. And in what capacity did you attend those meetings?

A. As an interpreter to General Mrksic, because the liaison officer at that time was Colonel Momcilo Krstic. I was his assistant, his deputy. ¹²⁵³⁰

Q. Right. Precisely so. So at those meetings you were not accompanying Mile Mrksic actually but you were accompanying the liaison officer who, from time to time, would invite you to attend meetings of that kind in your capacity of interpreter; is that right?

A. Mr. -- or rather, General Krstic didn't speak a single language except Serbian, and neither did General Mrksic. So when the liaison officer attended meetings that were attended by General Mrksic, I would also be there as an assistant to help out as an interpreter to the general and not to Mr. Krstic.

Q. In your capacity as interpreter.

A. Yes.

Q. Mr. Lazarevic, in a large portion of your statement, on page 9, 10, 11 -- you can find it there. Anyway, in those pages you describe how you allegedly fooled the representatives of the UN and the observers, how you tried to recruit them to -- tried to do business with them, get them drunk, you supplied women to them, extracted information from them, and so on. So tell me, please: Since everything that we heard yesterday is completely untrue, how can we at all verify -- how is it possible at all to verify any one of your allegations that can be found throughout these pages of your statement, except for the story of yours -- once you sift through the story, the only fact that remains is that you were an interpreter, and you have a very eloquently told story. So you are coming up with big items here, that you used to get the UN representatives drunk, that you used to do business with them, supply them with women, extract information from them. So how is it possible to come up with some ¹²⁵³¹ allegations which are quite large?

THE WITNESS: Your Honour, would it be possible to go into the closed session where I can actually name the names of the people that I worked with on the part of the UN?

JUDGE ROBINSON: Yes. Closed session.

THE ACCUSED: [Interpretation] Mr. Robinson, he is not testifying in a closed session. I don't see the reason for a closed session.

JUDGE ROBINSON: I have made that judgement. Closed session.

THE REGISTRAR: Your Honours, we're in private session.

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THE REGISTRAR: Your Honours, we're back in open session.

MR. MILOSEVIC: [Interpretation]

Q. In addition to you saying how you recruited them, got them drunk, bribed them, did business with them, supplied them with women and so on, in another part you say that some representatives of the UN and monitoring mission after a while started cooperating not out of those low-based motives but because they became convinced of the valid cause of the Serb struggle.

A. Yes. That was done out of their convictions.

Q. Since you said how you deceived them, did you in fact deceive them regarding the valid cause of the Serb struggle?

A. Mr. Milosevic, I never lectured officers of the UN in order to make them believe this or that. Those who made conclusions based on their own convictions did so on their own free will, without any influence of mine. You are suggesting that I in fact had a much greater power than I did.

Q. No. I'm claiming something completely contrary to that, because based on what you're saying, it seems that you know everything about the war in Croatia, about the policy of Yugoslavia, Serbia, my own role, the role of the Main Staff, and everything else, when in fact you know nothing about this because you were an interpreter in the command where you worked as a liaison officer. You in fact fabricated all this. So, Mr. ¹²⁵³⁴ Lazarevic, I'm claiming something completely opposite of what you are saying. I'm not saying that you know everything, no.

JUDGE ROBINSON: Let the witness comment on that. It has been said that this is an entire fabrication.

THE WITNESS: I will repeat again, Your Honour, for the benefit of the Court here: Everything I have stated in my statements is absolute truth.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Lazarevic, on page 9, last paragraph, you say that Mrksic, while he was still in the Krajina, told you about his impressions from the Vukovar battlefield, and he confided in you regarding all of that.

A. No. I never claimed that, Mr. Milosevic. I simply said that I was present when he spoke about that.

Q. And what did he in fact say there about doing there?

A. His conviction at the time was that he had accomplished a very important military victory.

Q. Since you say that he boasted about this - this is the term that you used - he boasted about something that was dishonourable; he boasted about killing a civilian - is that what he did? - about ordering a crime to be carried out or something similar?

A. No. He boasted about having accomplished what he wanted in his attack on the hospital.

Q. Were you perhaps tempted to ask him how many Croatian extremists, Ustashas, members of the ZNG, and other organisations, withdrew after the surrender of Vukovar and dressed into medical staff clothing in order to ¹²⁵³⁵ portray themselves as the medical staff and the wounded? Did you then ask him how many Serbs these Ustasha groups killed at the time in Vukovar? Did you have information regarding that?

A. Mr. Milosevic, I was not in a position to put questions to General Mrksic. I was there, the dinner was going on, members of the command were there, officers talked amongst themselves. I was sitting nearby and I was able to hear, however, I did not actually participate in the conversation and I don't know everything that went on in Vukovar.

Q. You don't know what went on in Vukovar, but this is what you're giving evidence about. Do you know that it is exactly Mile Mrksic -- were you able to eavesdrop about this while they were talking at the table?

A. Mr. Milosevic, I wasn't eavesdropping, I was sitting there in an official capacity while the dinner was going on. I was not eavesdropping. I was sitting there and I was able to hear something that was said quite loudly. I wasn't there, listening to something that I wasn't supposed to hear. Mr. Mrksic loud and clearly said about his impressions from Vukovar, so I wasn't eavesdropping.

Q. Well, the waiter who waited there was also there in an official capacity, and let's say he was serving soup, and since he has ears, he was able to hear.

A. The waiter was a military personnel person, just like I was, and was present there in that capacity.

Q. Well, do you know that Mile Mrksic, regarding not only Serbs but Croats who remained to live in the Krajina area, organised medical health care services for them, that in fact he took care of the health of ^{12536 BLANK PAGE 12537} population living there? Are you aware of that?

A. No, I'm not.

Q. However, you said in your statement, and also in your evidence, that Serbs, the TO of Krajina, the police of Krajina, all of those people who were armed and those who were not armed, worked actively on expelling all Croats from that area. That's what you say.

A. Yes. That was the impression I got upon arriving in Krajina, and I put that in my statement. I said that when I came to Krajina there was a very small number of Croats living there.

Q. Let me just take a look at my notes. Just a minute, please. Therefore, in view of the fact that everyone was supposed to be expelled from there, tell me, please: Do you know of a village called Bijeljina, which is some ten kilometres from Topusko?

A. No, I don't remember that name.

Q. Do you know that 37 Croatian families remained to live in that village, that they spent the entire war on their property, and only those who set on fire Serb houses fled from there?

A. I know about only one village near Topusko. I think that I mentioned this in my statement that there were Croats in Topusko who put white sheets on their windows, and they remained living in Topusko. I don't know if it's the same village that you're talking about.

Q. It might not have been the same village. There were many villages like that. Do you know in fact that Croats lived in Knin, in Knin itself, and according to a protected witness, a very important one whose name I don't want to mention now, this witness personally saw them and believed ¹²⁵³⁸ that they were given equal treatment in every respect, even though this witness testified against me, just like you. So there were Croats in Knin itself. All right. You don't know about this village, but do you know how many Croatian families remain in the village of Gredjani?

A. Yes. I know that village because the members of the ECMM visited this area very frequently. I believe that this is a village on the Kupa River.

Q. Do you know the Muza family, Slavko and Kata, from Topusko, since you visited Topusko? And I'm asking you now about Topusko.

A. No. I can't remember them now.

Q. Do you know that the soldiers of the RSK, who tried to provoke them because their son, Ivica Muza, also known as Svabo, that was his nickname, set fire to Serb houses, so therefore the Serb soldiers provoked the parents of this arsonist, and pursuant to the order of Ajdinovic, whom you accuse of commanding a unit in charge of dirty jobs, that these soldiers were arrested because they harassed this Croatian family? Do you know about this event?

A. No.

Q. Are you saying that Ajdinovic commanded this unit that did dirty jobs?

A. Yes, that's what I'm saying.

Q. Do you know of Croatian villages called Lukinic, Buncici?

A. Mr. Milosevic, you are now mentioning villages that probably exist in that area. I'm not a person from that area. I did spend a part of my life in that area; however, I didn't study geography. I don't know about ¹²⁵³⁹ all of these villages. I didn't record these villages and their population. I don't know what the ethnic composition of these villages is. This was not part of my job.

Q. All right. But part of your job is quite clear to us, based on what you're saying. I am now giving you names of a number of villages from the area where you claim to know everything that went on, and it seems that you know nothing of what went on except for things that corroborate this false accusation.

A. Mr. Milosevic, you are saying now that I'm lying and you are saying the truth. I can turn it around and say that it's vice versa. I'm quite sincerely telling you that I don't know. I've never heard of these villages that you are mentioning.

Q. So you are claiming that what I say to you about Lukinic, Buncici, residents of those villages who lived throughout the war there peacefully, I also mentioned Bjeljevina, Gredjani, and these villages, and you're claiming that that's a lie?

A. Mr. Milosevic, I'm claiming that there were no Croats living peacefully at that time in RSK.

Q. Mr. Lazarevic, there was nobody living peacefully in Krajina during the war. You're not going to deny that.

A. I'm not going to deny that. It is true that nobody lived peacefully, especially not Croats during that time.

Q. And as regards the truth, the only advantage I have is that I'm telling the truth.

A. Mr. Milosevic, we will leave it to the Court to decided who is ¹²⁵⁴⁰ telling the truth.

Q. What I am saying is something that a lot of people know a lot about.

A. I can say the same about what I'm saying.

Q. Mr. Lazarevic, when I say a lot of people, I mean millions. On page 12, paragraph 5, you say that after demilitarisation, and nothing changed, and that the KOS and DB remained active in RSK. Is that right?

A. What I'm saying is that the army, overnight --

THE INTERPRETER: Could the witness please repeat the answer.

MR. MILOSEVIC: [Interpretation]

Q. I took you to say that KOS was part of the JNA army, and the DB from Serbia, that they remained there and continued working in RSK.

A. Yes.

Q. So that's what you're claiming?

A. Yes.

Q. Do you know that the army of RSK had its own intelligence and counter-intelligence service, even before the war?

A. Yes, that's right. Every republic had that.

Q. Are you aware that at the level of RSK there was their own state security service?

A. Yes, but it was directly subordinated to the state security of Yugoslavia.

Q. How can you claim that?

A. They submitted their reports to them, they asked for advice. ¹²⁵⁴¹

Q. Did you see any report of that nature?

A. I did not see any reports, but I had an opportunity to talk to the people who worked in the state security of RSK and had direct connection with Mr. Stanisic, or Stamatovic, and so on.

Q. How do you know that? Did you ever attend a meeting? Have you ever seen Jovica Stanisic in your life?

A. Yes, I did in Knin.

Q. And who did he meet with there? Did you see?

A. Mr. Babic, Mr. Martic; a number of people. I attended dinners, not official conversation --

Q. So what if he came for a visit and had dinner? What are you testifying about that?

A. You only asked whether he was there or not.

Q. What is your testimony when I ask did you ever attend a meeting between them? Because you're saying something about reporting as the grounds for your testimony.

A. I'm saying that I was in the presence of Mr. Toso Pajic, in his office, many times when he spoke to Jovica Stanisic.

Q. Was he giving him a report?

A. Yes.

Q. So you attended a telephone conversation between Toso Pajic and Stanisic?

A. I wasn't the only one.

Q. But Pajic, Surla, and the others were working for the DB in the RSK, in the Yugoslav army? ¹²⁵⁴²

A. Yes.

Q. But from that area, they are locals of that area?

A. Correct, but they were still officers of the JNA.

Q. The JNA had ceased to exist when the Federal Republic of Yugoslavia came into existence and when the army of Yugoslavia was established, consisting of citizens of Montenegro and Serbia. I suppose that you are well informed about that as well, since you know a lot about things that you couldn't really know about.

What is the presence of the Yugoslav army in the RSK you are talking about?

A. I'm talking about the presence of units in the MUP of Serbia. What secret units are you talking about?

Q. Do you mean that the secret services of the MUP of Serbian Krajina cooperated?

A. Yes.

Q. What is odd about that cooperation? So what if they cooperated? You should know, since you work in that area, that secret services of the USA and Russia also have cooperation. There is cooperation between secret services of various states, even between Yugoslavia and the United States. So what if there is cooperation between such services?

A. It all depends to what level this cooperation reaches.

Q. So it's all about level; right? And I suppose you know the level of that cooperation as well.

A. I suppose so.

Q. And you know the substance of that cooperation? ¹²⁵⁴³

A. I'm saying all the things I know about that. I know that Mr. Toso Pajic talked to Stanisic. I know that upon return to Belgrade, Toso Pajic continued to work in the DB.

Q. Mr. Lazarevic, after these events that you described towards the end of examination-in-chief, do you know that in Serbia there were a million refugees? Out of those million refugees, do you know how many thousands upon thousands found employment? Those who were policemen found work in the police force, doctors found work in health centres, teachers found employment in schools, depending on vacancies available. So what if a policeman who was at the same time a refugee after the events you described, found employment in the only line of work he knows anything about?

A. You seem to forget, Mr. Milosevic, that at that time, people who came as refugees to the territory of Yugoslavia had no right to be issued with an ID, had no right to employment because they were considered as aliens, they could not enrol their children in schools because they had no official status in our country. So please don't tell me what rights they did and didn't have. I know that they were denied all the rights normally enjoyed by Yugoslav citizens.

Q. Mr. Lazarevic, do you know that many people who were driven out - and that was the general feeling in Serbia, beginning with the early 1990s - were in many ways privileged, as far as employment is concerned, compared to Yugoslav citizens? I know that Sadako Ogata told me that the status of refugees is very good in Serbia. Now you're telling me that these people were disenfranchised in Serbia, based on a single incident ¹²⁵⁴⁴ you mentioned here, and even that, I would say, is doubtful.

A. Mr. Milosevic, I'm speaking about the years I spent in Belgrade, from 1995, 1997, 1998, and 1999. The people I spoke to at the office of the exiled government of Serbian Krajina in Belgrade, I know from speaking to them that they had no rights at all. They were unable to register their vehicles they drove to Serbia. For years they were unable to be issued with IDs, because an ID would mean that they got Yugoslav citizenship. They couldn't do that. You cannot deny the fact that in 1995 those people were arrested and taken back to the war zone and battlefields outside of Serbia. You know, and you should tell the Court, that some of these people sued your government because you made those refugees go back to the front line.

Q. Mr. Lazarevic, that is not true at all. There were all kinds of excesses there. There probably were. Whenever hundreds, thousands of people are involved, injustice and excess is a common occurrence. But it was not official policy. You can't claim that.

A. Unfortunately, it was.

Q. It could only have happened in individual cases. But please tell me this: Since you say that services were cooperating between them, did you attend a single meeting, for instance, between Surla and Vasiljevic?

A. No.

Q. You didn't attend a meeting between Stanisic and Pajic either?

A. No.

Q. You didn't attend a single meeting between those people who were supposed to be cooperating? ^{12545 BLANK PAGE 12546}

A. I attended some meetings, but not meetings between any of the people you just mentioned.

Q. Okay. Stanisic and Pajic you were able to recognise; right?

A. Pajic I saw every day.

Q. But you didn't attend a single of their meetings?

A. I wasn't supposed to. They worked for the police.

Q. How do you know these meetings ever happened?

A. They probably happened during visits by Mr. Stanisic.

Q. Let me get this correctly. When you say "probably," does that mean it is an assumption of yours? Are you basing your claims on any sort of fact?

A. It is a fact that Mr. Bozovic and Mr. Simatovic had regular meetings at the 21st Corps, and I doubt very much that they held those meetings of their own free will, by their own decision, without instructions and decisions from their superiors.

Q. You are talking about a time when the Republic of Serbian Krajina cooperated with the autonomous province of Western Bosnia, Fikret Abdic, and Serbia; is that what you're talking about?

A. I'm talking about an intense presence of units of the MUP of Serbia.

Q. Do you know that another protected witness and participant said that those were exclusively volunteers and mercenaries who helped out the army of the autonomous province of Western Bosnia, as instructors, and this area was in peaceful relations with both Krajina and Serbia? Do you know about that? ¹²⁵⁴⁷

A. I know something different, Mr. Milosevic.

Q. All right. You know something different. Yesterday an exhibit was produced here, namely, an excerpt from a videotape of a military parade in Slunj. Is it true that this military parade was broadcast on television?

A. Yes.

Q. Is it true that it was no secret?

A. Correct.

Q. Is it correct that when such festivities take place - St. Vitus Day is a great holiday - guests are invited?

A. Correct.

Q. So what is odd about it, odd enough to produce it as an exhibit, to see that there are guests from Serbia, police officers from Serbia, guests from the autonomous province of Western Bosnia, also officers from Abdic's army, Muslims, in addition to officers from Republika Srpska --

JUDGE ROBINSON: It's not for the witness to comment on the evidence in that way. He can't say whether it was odd to have the exhibit produced. It was produced by the Prosecution. That's not a proper question for him.

THE ACCUSED: [Interpretation] All right. It is an appropriate question, Mr. Robinson, whether it was a public event. It was a public event, and the witness confirmed it. Is St. Vitus Day a great holiday? Yes. Do you invite guests for holidays? Yes, you do. Do you invite guests from Serbian autonomous province of Western Bosnia, Republika Srpska? Yes, you do. They were there. And whether it is odd or not, I ¹²⁵⁴⁸ don't even have to ask, because it was an ordinary event, and I don't see its relevance to the purpose for which it was used here.

MR. MILOSEVIC: And what I said, as you well know, is correct, Mr. Lazarevic.

Q. On page 13, paragraph 2, you claim that I had my own envoys in the Republic of Serbian Krajina who made sure that all of my wishes are fulfilled. Tell me, please, who were these envoys of mine in Republic of Serbian Krajina? Name them, please.

A. People who came frequently from Belgrade, people who were present on the ground, anyone who was in the Republic of Serbian Krajina, Mr. Milosevic, was accountable and responsible to you.

Q. Is that what you think?

A. Oh, yes.

Q. Do you think that people who came to the Republic of Serbian Krajina of their own accord, in order to help, to contribute in some way, to assist in combat, in industries, and anywhere else, do you think they were all responsible to a centre in Belgrade?

A. Of course.

Q. What is bad about that? How could those people have survived without assistance from Serbia? What is bad about Serbia helping them?

A. I don't understand what you're driving at.

Q. What would they eat?

A. Better to ask what they would shoot with.

Q. Since you ask that question and you deal with military issues, as I see, do you know that even in the doctrine of the former SFRY, and in ¹²⁵⁴⁹ the actual disposition, an enormous quantity of weaponry was deployed in Croatia and the BH, which was a central republic, and after 1948, military industries were withdrawn from other areas and concentrated in the Bosnia-Herzegovina? Their military stocks were much higher than those in Serbia.

A. In small depots of the Territorial Defence, yes. I don't know about any large depots.

Q. Do you know for how long this Croatian general drove in a jeep through a warehouse through the depot in Knin, after the fall of Knin? Do you have any idea how large the depot was?

A. No, I don't.

Q. That's exactly what I'm putting to you. You don't know. Tell me, on the basis of what do you claim, as you explained here yesterday, that you were there somewhere in the vicinity of Knin when the so-called log revolution was carried out, that you saw 80 per cent of people who were not locals, and you described, very graphically here, what it all looked like. You talked about that yesterday, didn't you?

A. What is the question?

Q. Did you say that yesterday, that you personally saw that?

A. I don't know if I used the words you used, graphic or not graphic. All I know is I said that I went there personally, out of curiosity more than anything else.

Q. You were explaining that you saw that with your own eyes; is that correct?

A. Yes, correct. ¹²⁵⁵⁰

Q. I will tell you now what it says on page 13 of your statement since you are not telling the truth again. Look at page 13, please. First of all, you were never there at all, and you spent a lot of time yesterday explaining that.

THE ACCUSED: [Interpretation] Page 13 of 38, paragraph 2, starting with the third sentence. First comes the part I already quoted: "Milosevic had his own envoys in Knin who made sure that all his wishes were fulfilled. His representatives were almost always SDB agents. They had been in the Krajina from the beginning and the supposedly spontaneous revolt against Croatian authorities in 1990 was orchestrated from Belgrade."

Then you go on to say: "Zimonja told me at one point that when, in August 1990, log barricades were put up around Knin, they were largely manned by members of paramilitary units and from Serbia. Many of the men were actually from Belgrade, and according to Zimonja, they were paid 1.000 Deutschmark to block the roads.

"This was the first step towards establishing the Serb autonomous region around Knin, and although it was portrayed in the Belgrade press as a spontaneous action of the local Serbs to defend themselves, in reality it was planned and initiated by Belgrade. The SDB was far ahead of the local population in making these things happen. Their agents created the incidents and then the press used them to stir up the civilian population and to create a climate of fear that was so necessary in order to make the war happen."

From this we see that what you are claiming here, you are claiming ¹²⁵⁵¹ that Zimonja said, not that you saw it yourself. That's one thing. And second, let me ask you, Mr. Lazarevic: What paramilitary formations existed in 1990 in Serbia anyway? At that time, in Serbia, there was no one who had the faintest idea that the conflict would happen at all. What kind of paramilitary formations are you talking about in 1990? Do you know of a single paramilitary formation in Serbia that was in existence in 1990.

JUDGE ROBINSON: Before the witness answers, after the witness answers we'll have to take the break.

Go ahead, Mr. Lazarevic.

A. The establishment of paramilitary formations in Serbia, when it began, who was in charge, and the rest, I don't know. I wasn't in Serbia then. It is a fact that very early on in the area of Knin, White Eagles appeared, Seselj's volunteers, Dragan's volunteers. There were all sorts of jokes about that: If you ask a Serbian guard when to open fire, he says, When I see more than two men in the same uniform. If they are in different uniforms, everything is okay.

MR. MILOSEVIC: [Interpretation]

Q. Mr. Lazarevic, I asked you a serious question.

A. I gave you a serious answer. I wasn't in Serbia at the time to know how and when it was established.

Q. You are now saying in public for everyone to hear that this log revolution in August 1990 was organised by paramilitary formations from Serbia.

A. I said it was organised by the state security service. I didn't ¹²⁵⁵² talk about paramilitary units organising it. I only said that the barricades were probably manned by paramilitary members from Serbia.

JUDGE ROBINSON: I remind the witness not to discuss his evidence with anybody during the break. We break for 20 minutes.

--- Recess taken at 12.19 p.m.

--- On resuming at 12.42 p.m.

JUDGE ROBINSON: Before you continue, Mr. Milosevic and Mr. Lazarevic, I have a special request from the interpreters to ask that you observe a pause between question and answer. They have been having immense difficulty in keeping up with the speed at which you're both speaking, since you speak the same language. So in the interests of the health of the interpreters, and indeed their own human rights, I'm going to ask that you make a very special effort to observe a pause between question and answer.

THE WITNESS: Your Honour, I promise I will be very careful from now on.

JUDGE ROBINSON: Yes, Mr. Milosevic. Continue.

MR. MILOSEVIC: [Interpretation]

Q. So to round off the question we were discussing and to conclude: You say and claim that all the events in 1990, in 1989 as well, and all the nationalistic hysteria in Croatia and the persecution of the Serbs, the pressures brought to bear on them, the fact that they were thrown out of the constitution, that the Serbs weren't bothered by that at all but the SDB people came in and organised the log revolution. Is that what you're saying in fact? ¹²⁵⁵³

A. No, that is not what I'm claiming. I never mentioned what you said in the first part of your question. But in the second part of the question, yes, it was organised by the DB; or to put it in simpler terms, it was organised in Belgrade.

Q. I see. Now, how do you explain the fact that yesterday here in this courtroom you discussed at length what you had seen, you described what you had seen, and then you say you had heard it from Zimonja, you heard that some people in the SDB were there?

A. In my original statement, I said that I had seen it myself.

Q. So this isn't your real statement, then. This is not the original statement, the one that I received.

A. Well, I don't know what you have received. I know what I said, what I stated.

Q. All right. Let's move on as we've spent quite enough time on that question.

On page 13, paragraphs 3, 4, and 5, you describe how I kept the JNA under my control through the mediation of KOS. Is that right, Mr. Lazarevic?

A. Mr. Milosevic, which paragraph are you referring to?

Q. I'll tell you in just a minute -- right away. Page 13, paragraphs 3, 4, and 5 --

JUDGE ROBINSON: Mr. Milosevic, just read one excerpt from it so that I can know exactly where you are speaking.

THE ACCUSED: [Interpretation] Well, all right, Mr. Robinson. I will read it out. Paragraph 3, page -- ^{12554 BLANK PAGE 12555}

JUDGE ROBINSON: Just read one sentence so I can -- I'm having difficulty finding it.

THE ACCUSED: [Interpretation] "Milosevic's relationship with the JNA was different than with the SDB. In some ways it was obvious that there was some strain there. But the army nevertheless cooperated with him and also carried out his wishes."

JUDGE ROBINSON: Thank you. Thank you.

MR. MILOSEVIC: [Interpretation]

Q. And the paragraph ends -- I just want to read this out loud: "Those who did not agree with him were excommunicated, and they were replaced by ambitious younger officers, such as Mile Novakovic, Mile Mrksic, Ratko Mladic, who saw linking themselves to Milosevic as a way of getting ahead quickly," and so on and so forth.

Mr. Lazarevic, do you know what post I held at that time, the time that you're describing?

A. If I remember correctly, you were President of Serbia at that time.

Q. Yes, that's right. And do you know that the presidents of the republics in the former Yugoslavia had absolutely no competence in the army?

A. Mr. Milosevic, you were at the head of the army at that time and you know that full well.

Q. That's what you claim, and you're claiming that in order to, how shall I put it, support this false indictment. But Mr. Lazarevic, do you know that I never even knew any of these people at that time? I knew the ¹²⁵⁵⁶ military chief, General Veljko Kadijevic, I knew the head of the General Staff, Blagoje Adzic, and that was all. Those were all the people that I knew in the army at the time, when we're talking about individuals. Of course, somebody from the various receptions and celebrations that were held I might have known, but where do you get the idea from? Did you read it in the indictment and then interpret it in your own way or do you have any actual knowledge about that?

A. I did not read the indictment against you, nor is it my intention to read it. I am here today to present the facts that I know about. And the fact remains, Mr. Milosevic, that even I - let me recognise this in front of the Tribunal and say it loud and clear - that I was delighted with you back in the days of 1988 and 1990. I looked up to you. But unfortunately, things changed since then.

JUDGE ROBINSON: [Previous translation continues]... answer the specific question put by Mr. Milosevic, which was at that time --

THE WITNESS: I apologise, Your Honour. I don't even know what the question is any more.

JUDGE ROBINSON: The question is that Mr. Milosevic is saying that at that time he did not know any of those people.

THE WITNESS: That's what he claims. I believe he did.

JUDGE ROBINSON: You believe he did.

THE WITNESS: Yes, sir.

JUDGE ROBINSON: Thank you.

MR. MILOSEVIC: [Interpretation]

Q. All right. Of the ones that you mention here, I really didn't ¹²⁵⁵⁷ know any of them, the ones you stipulate. And you go on to say the following: That I gained the support of KOS early on. This made it easier for me to control the army, for two reasons: "The first was that KOS was responsible for making recommendations on postings and promotions of officers. It was impossible for an officer to advance if KOS opposed him. In this way, Milosevic," you state, "could control assignments and command positions by making his desires known to KOS." Tell me this, now: Who was the chief of KOS at that time, so that I can know who it is that I informed of my desires?

A. I really can't remember.

Q. Well, I can't remember either.

A. Well, then we're in the same position, Mr. Milosevic, aren't we?

Q. We're not in the same position, Mr. Lazarevic, because you claim that you know something and then you just seem not to remember. You even claim that I exercised my control because the families of the military officers lived in Serbia. Imagine that, if you will. What you want to say is, I suppose, that I issued threats to the families of the military and held the JNA under control in that way, by blackmailing them.

A. What I said was that the officers that appeared in Krajina did have their families in Serbia. They did not have their families with them in Srpska Krajina. So what?

Q. So what if the families weren't with them? What has that got to do with my alleged control of the officers? Tell me of a single military man, because his family was in Serbia, did something that I wished them to do. Give me a name, one name, that you know of me telling him to do ¹²⁵⁵⁸ something and then threatening him with his family being in Serbia, et cetera, et cetera.

A. I never said that.

Q. You never said that?

A. No, Mr. Milosevic, I didn't. What I did state was that you had a regular influence on the army, an extraordinary influence on the army.

Q. I can't find the families that we mentioned, unfortunately. But as I have some time tomorrow, I have an hour and 50 minutes, as far as I understand it, or one and a half hours, we'll see how the balance stands, what Mr. Robinson is going to tell us about my time, the time I have left, not to waste time now.

But to go back to the question that I have already quoted several examples of -- I'm not going to give you any more examples, but tell me this: On page 18, paragraph 6, you claim that in the RSK there was a constant policy of expelling the Croats, following orders from Belgrade. That's what you say, words to that effect.

A. Yes.

Q. And do you believe that? Did they really have this policy of expelling the Croats?

A. Events on the ground prove that that was so, yes.

Q. So tell me something about those orders. Who issued the orders to expel the Croats from the Republic of Serbian Krajina?

A. You, Mr. Milosevic.

Q. Oh, I see. Me. Well, give me an inkling of how you came to learn of those orders of mine that never existed. How did you come by that ¹²⁵⁵⁹ idea? Did anybody tell you that I had issued orders to expel the Croats from the RSK at all?

A. Mr. Milosevic, you are the creator of the policy and politics in Serbian Krajina. You pulled the strings of the events that took place there.

Q. Mr. Lazarevic, apart from the fact that the opposite side is claiming that, do you have any arguments to bear that out? Give me an argument to bear it out. Let me ask you in quite concrete terms: How come, if that was indeed my policy, throughout the ten years of the Yugoslav crisis it was only Serbia that retained its national structure, and during the war in Croatia it was not the Croats that were expelled, during the war in Bosnia the Muslims were not expelled; therefore, how come that during that ten-year period, if there was a policy of ethnic cleansing, the kind that these people here have fabricated and are accusing me of, in certain parts outside Serbia while I was the president of Serbia, in Serbia none of that happened? How do you explain that?

A. Mr. Milosevic, I have not come here today to hold political analyses of the events. What I know as being facts is that you stood behind everything. You were at the back of it all. Now, whether you wish to accept that or not, that's not my problem, and I state that once again.

Q. All right. But I'm asking you quite specifically. You say that the orders came from Belgrade. When I asked you what orders from Belgrade, you said my orders. So go on, then. Give me some basic proof of any kind of order of that kind existing, to the effect that the Croats should be expelled from the territory of the Republic of Srpska Krajina. ¹²⁵⁶⁰ And I have quoted several examples of villages in your own particular region, in which you claim you knew everything that went on, where the Croats lived quite peacefully throughout that time. So how can you claim and explain that now? I am talking about material facts; you are talking about some kind of verbal assertions made.

A. Which material facts do you possess, Mr. Milosevic? You weren't there. I was. The fact is that while I was there, and let me repeat this again, you orchestrated the policy over there, in talking to high-ranking officials with the offices of the state security service, in my talks with people who had come from the territory of Serbia, briefings in Belgrade before we went to the international meetings and exchanges, it was always Mr. Slobodan Milosevic who was the key factor.

Q. We'll come to that. We'll come to those briefings, Mr. Lazarevic, and we'll clear that matter up as well. There's no problem along those lines. But you haven't answered my question yet. Did you yourself talk to anyone? You have just enumerated some high-ranking JNA officers, high representatives of the state security service, et cetera. Did any of them ever tell you that they had talked to me personally and received any similar orders, any orders of that kind? Did anyone actually ever tell you that?

A. Directly, no.

Q. They didn't tell you.

A. Not directly.

Q. How did they tell you? Indirectly?

A. They would say Belgrade wants that or Belgrade wishes that. ¹²⁵⁶¹

Q. You mean that Belgrade wishes to expel the Croats from their homes?

A. "Belgrade" was synonymous with you, Mr. Milosevic. "Belgrade" meant you.

Q. Oh, I see. That's rather a large synonym and lots of them to replace me. But all right. Now, how were these orders issued that allegedly Belgrade issued and you listened to this in the talks that you had? How did you learn of them? How were they announced? How were these orders issued, announced, and put into practice? Give me an example of that.

A. I think I've already quoted an example. During my testimony yesterday in my response to the Court about what happened when 75 civilians were dislocated to the hospital in Karlovac and they never returned.

Q. Oh, come on, Mr. Lazarevic. Yesterday you described, for example, the fact that 75 elderly men and women, for whom you said, if I remember correctly, that nobody was under the age of 70, they were all over 70 years old, and that it was through the mediation of the International Red Cross and the United Nations that they were transferred to the hospital for their own health, for their own good. And you turned something like that into saying that it was tantamount to deportation.

A. It was deportation, Mr. Milosevic.

Q. Mr. Lazarevic, do you know that for any movement of the population, any displacement of the population, in which the International Red Cross mediated, or the UN, there had to have been a statement on the ¹²⁵⁶² part of people who wished to move somewhere else, to go somewhere else, saying that they wanted to leave. Nobody could coerce them into that. And documents of that kind exist in the Red Cross.

A. Yes, those documents, Mr. Milosevic, show that they went to hospital to have a medical examination. They thought they would go back to their own houses the next day. However, they did not go back.

Q. Did anyone forbid them to go back?

A. Yes.

Q. Who forbid them to go back?

A. People in the Republic of Srpska Krajina. We did.

Q. When you say "we did," who do you mean "we"? Who could have prevented these people from going back? You said that it was through the mediation of the International Red Cross and the United Nations that they were taken away for recuperation to hospital and that they were then forbidden to return. This first point probably did take place and this was a humane act towards elderly people, people who were all over the age of 70. And now as to whether somebody came back or wished to come back or came back later or didn't come back at all or died in that hospital or went further on to stay with the family, how can you possibly know about this?

A. Because I was present there.

Q. You were present when they were forbidden to come back?

A. I was present when the requests were made for them to return, through the UN, and the ways that we avoided them from returning.

Q. How did you do that? ^{12563 BLANK PAGE 12564}

A. We would create an incident at the border crossing.

Q. So you would create an incident and not let them come back?

A. No. We would say it was impossible for them to come back because of the situation on the ground.

JUDGE KWON: Slow down, please.

MR. MILOSEVIC: [Interpretation]

Q. I'm very sorry that you are turning a humanitarian action into a deportation. However, that is probably your purpose. You said at one point here -- I don't know if I'll be able to find this portion. And I remember that you stated that in your statement. Yes. On page 9, you say, page 9 out of 38, you say: "We did everything in order to prevent them from discovering the truth, and we would always, on several occasions, serve misinformation to them. It was amazing to us how often they believed what we were saying, but --" and this is the key of what I want to read to you -- "but if you keep repeating the same lies again and again, it seems as if anyone would eventually conclude that it must be true."

Mr. Lazarevic, is that the method you recognised in this institution here, with this false indictment against me; that if you keep repeating the same lies all over again that in the end you would eventually convince people that it's true?

JUDGE ROBINSON: Don't answer that question. Next question.

MR. MILOSEVIC: [Interpretation]

Q. In that same paragraph, you say that within the 21st Corps -- ¹²⁵⁶⁵ actually, it doesn't matter which paragraph it was. You talked about this yesterday. Therefore, that within that corps, there was a unit that, as you say, was tasked with performing dirty jobs, as you call them, and that Ajdinovic was in command of that unit and that it had an official name of a unit for anti-terrorist activities within the 21st Corps.

A. Yes, that's right.

Q. Can you tell me how many people that unit numbered?

A. I think it was 40 to 45 people.

Q. 40 to 45?

A. Yes, approximately.

Q. And at what period of time did Ajdinovic command -- was in command of that office?

A. Beginning of 1992.

Q. Beginning of 1992. Do you know that at that time in Rijeka -- he was in Rijeka at that time and left Rijeka with the 13th Corps?

A. Who did that?

Q. Ajdinovic.

A. I wasn't aware of that.

Q. Are you saying -- but you're saying that he was in command of that unit. And do you know his rank?

A. Colonel.

Q. And colonel would be in charge of a unit that had only 45 people. That was a platoon.

A. Mr. Milosevic, you are forgetting that that was a special unit.

Q. I'm not forgetting anything, but I know that special platoons are ¹²⁵⁶⁶ not commanded by colonels. So you don't know that at the time Ajdinovic was in Rijeka and left Rijeka together with the 13th Corps. Now, tell me, please: What premises did that unit use?

A. The last ones I remember were located in a building on the road between Vojnic and Vrginmost. It was in a separate house. They had their own security, personnel there, and they stayed there.

Q. All right. Can you give me the name of at least one member of that unit?

A. The leader, the commander of that unit, was somebody called -- with a nickname Paraga.

Q. What was his name?

A. If I remember well, Sinisa Martic.

Q. So was he in charge of that command or was it Ajdinovic? You say that leader. I don't know what that means in a military sense. Does that mean he was commander of that unit?

A. Yes, but the commander of the unit takes orders from his superiors, and his superior was Colonel Ajdinovic.

Q. And what was the position held by Ajdinovic, according to you?

THE WITNESS: I'm sorry, Your Honour. It appears that I don't get the questions any more in my headphones.

[Technical difficulty]

JUDGE ROBINSON: Would the registrar have that checked out. Yes. Proceed. Ask the question again, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. What was the position held by Ajdinovic? You told us that he was ¹²⁵⁶⁷ in command of that unit, and now you're saying that another person, nicknamed Paraga, was the commander but he took orders from Ajdinovic. So in that staff where you served as an interpreter, what position was held by Ajdinovic?

A. In the staff itself, he had no position, as far as I remember. He came and left.

Q. So out of all the members of that unit, you only know that commander nicknamed Paraga, nobody else?

A. Jovica Vojinovic, and I only know nicknames of the rest, not their full names.

Q. Very well. We'll get to that later too. On page 18, paragraph 6, you speak about placing mines on the soccer field, assassination of the mayor of Vrginmost, placing of explosives on the railway between Vrginmost and Glina. Can you tell me who issued orders and when, for this?

A. I can only give you my assumptions concerning these events, because I was informed of these events after they took place. When I went to the staff of the 21st Corps in order to lodge an official protest to the UN forces.

Q. Let's take it easy, please. As far as I understand this, the Serb side protested with the UN because Croatia in fact carried out this sabotage operations.

A. That was the official version, Mr. Milosevic.

Q. Now, how do you know that this official version was not true?

A. Based on the investigation that was carried out. ¹²⁵⁶⁸

Q. And did you have in your hands a finding of that investigation, or did you learn of this subsequently; learned, heard, and didn't in fact have any direct information regarding this?

A. Mr. Milosevic, every event, a negative one, in the area covered by the 21st Corps, the command of the 21st Corps, through its liaison officer, which -- who was me, would lodge a protest regarding that with the UN. As far as the investigation is concerned, there was the international police on the ground at the time that carried out its own investigation. There were also military observers of the UN. There were four battalions of them. And in the end, we also had there the 21st Corps. Now, how I came to know who the perpetrators were, from the perpetrators themselves.

Q. Now, who were the perpetrators? You said from the perpetrators themselves you learned about who did that. Who were these perpetrators?

A. The special anti-terrorist unit.

Q. And they informed you about that, and you just told us a minute ago that you only knew Paraga out of all of them. Did Paraga inform you of this?

A. In the talks that took place in cafes, in their headquarters, in their command post and so on.

Q. So you heard that in your talks with them; however, you can't name any of them except for Paraga?

A. I gave you another name of a gentleman who became a close friend at the time; Mr. Jovica Vojinovic. There were a number of those young people that moved about and were only known by their nicknames. They ¹²⁵⁶⁹ didn't have their names written on their uniforms so that one could tell who is who.

Q. All right, Mr. Lazarevic. It is clear here that you are only talking about things that you heard in various conversations and talks in cafes, as you called them. However, you did not attend or were not present during any official investigation, you were not present where any official order was issued or when anything was carried out officially. Isn't that right?

A. No, that's not right.

Q. So what functions did you attend? Why are you talking to us about cafes? Can you tell us what official functions did you attend, what official reports have you received? Why are you bringing up cafes and informal talks here?

A. I told you how I came to the conclusion. I told you that I did so based on my conversations with them. But I also told you that I was present as an interpreter, as a liaison officer, whichever way you want to call me. I was present when investigations were carried out by the UN, because at the time, the UN personnel were not able to move about freely as they wanted. They always had to have either military or police escort with them.

Q. So I don't understand. This is not an answer to my question. So what is it that you learned through an official function? Was there a report by the UN stating that this was carried out by Serbs?

A. In a way, yes.

Q. Well, tell us: Was there such a report or not? ¹²⁵⁷⁰

A. I told you: In a way, there was. And please allow me to give you a more detailed answer.

JUDGE ROBINSON: [Previous translation continues]... the accused reminded to observe the pause. I can sense the stress in the interpretation. These interpreters are under immense stress by carrying on at that speed. You must observe a pause.

THE WITNESS: I sincerely apologise, Your Honour, but sometimes replying to Mr. Milosevic takes immediate reaction.

JUDGE ROBINSON: But you speak the same language, so it's there's a natural inclination to reply immediately. I think you have to exercise some discipline.

Yes, continue. Who was to speak? You had asked the question and ...

THE ACCUSED: [Interpretation] Mr. Lazarevic said that he wanted to explain what I asked him about, and if he has forgotten in the meantime, I can continue, if you feel no need to explain.

A. I don't feel a need to explain, but if you wish, I can explain for your sake.

MR. MILOSEVIC: [Interpretation]

Q. There is no need to explain anything for my sake. You mentioned the UN and I asked you whether there was a report of the UN claiming that this had been done by Serbs. You said in a way, yes. And then I asked you: Yes or no.

A. I said in a way, yes, and I will now explain my answer. The reports showed the places where these incidents took place were deep ¹²⁵⁷¹ enough in the RSK territory to make it technically impossible for Croatian forces to penetrate the border along the Kupa River, which was heavily mined. There were many designated and not designated minefields. And after the incidents, the investigation was launched immediately. The army of the RSK went on the ground. They looked through the forest to see whether they can find enemy forces. They never established where they had come from and where they had gone, so that the final finding of the UN investigation was that there was not enough evidence to prove that the Croatian side had carried out what we're claiming they have, but there were many clues pointing to the fact that we carried this out ourselves.

Q. So the insufficiency of evidence, the lack of sufficient evidence that this had been carried out by the Croat side is interpreted by you as the confirmation of the fact that this has been carried out by the Serb side. Now, please tell me: Which soccer station was mined? Can you tell me, which one was it?

A. In Glina.

Q. In Glina?

A. Yes.

Q. On page 18, paragraph 6, you say the same thing, that that unit in charge of dirty jobs placed mine on soccer stadium, or on the soccer field. Now, please tell me: Why is it that on the very next page, in paragraph 2, you say that these mines had been placed in a football stadium, a football field, in Topusko? So it's a completely different location. Mr. Lazarevic, is it a fact that amidst a number of fabrications, you have forgotten what you said on the previous page? ^{12572 BLANK PAGE 12573}

A. I'm sorry, but this is not something that I stated. Please allow me to find this in the original. I only described one incident of placing mines, and that pertained to Glina. I never said that the soccer field in Topusko was mined as well.

Q. You say, on page 19: "A football match in Topusko was planned. Night before that pate mines were placed on the field and then they were accidentally discovered immediately prior to the match and then the match was cancelled." So are you saying that you didn't state that?

A. Mr. Milosevic, I gave one statement, and that pertained to the football field in Glina. How Topusko came into picture, I have no idea.

Q. All right. I'm very glad that we found something that you claim you had not stated in your statement, and this is not a lonely example of that.

Do you know that Dmitar Obradovic, the mayor of Vrginmost, and an honourable man, wore, until the very last day, the uniform of the TO of Krajina?

A. No. I met him when he wore civilian clothes.

Q. All right. You met him, but do you know that other than when you met him and he wore civilian clothes, he wore the uniform of the TO Krajina until the very last day?

A. No, that's not true. He wore civilian clothes until the last day.

Q. All right. Do you know that, together with his fellow citizens, he participated in liberating Serb villages from blockades?

A. No, I'm not aware of that.

Q. You're not aware of that. All right. Now, why are you claiming ¹²⁵⁷⁴ that this unquestionably honourable man was killed by Serbs? Why do you claim that?

A. Based on information from the ground.

Q. What kind of information do you have?

A. Conversations with perpetrators and Colonel Ajdinovic was pointed to as the organiser. There were plannings of several murders that I attended personally. The murder happened 250 metres away from the command of the 21st Corps, a very short distance from the headquarters of the United Nations in a section of the road which is very busy and which links Topusko with the main road towards Glina. And it happened at 9.00 a.m. The forces of the 21st Corps went out the very moment they learned about the murder, five minutes after, they combed the surrounding area and they didn't find any of the two men who committed the attack, because investigation showed later that the man had been shot at from two different places. The shooting was directed at the vehicle driven by Obradovic.

Q. So it was an ambush?

A. Yes.

Q. And this ambush was the work of this platoon, this detachment that you speak about?

A. Yes.

Q. But you have no proof of that.

A. I told you about the proof I have.

Q. Well, if that sort of proof was acceptable, prisons would be full. Explain, please: This mining of the area, the planting of mines ¹²⁵⁷⁵ around the water tower, the story is incredible. It's preposterous. People are planting mines to their own detriment and killing themselves; is that it?

A. No.

Q. Again you mention Ajdinovic and you say that Serb peasant would take his cows or goats there, and one of them would step on the mine, or even the person himself would step on the mine. The story would spread around quickly and the government would blame Croatian terrorists. Is that correct?

A. Yes.

Q. Don't you think it is preposterously cheap and simply criminal --

A. No.

Q. -- to kill your own people, innocent people in every respect, just in order to achieve what? To blame who? Accusations against Croatian authorities were much more serious than the planting of mines that would kill one single person. Tell me: What could be the possible purpose of such an action? What could possibly justify it?

A. Creating the psychosis of fear that would eventually result in stopping the negotiations with the Croatian side.

Q. And what was the purpose for that? What would they achieve?

A. Demilitarisation, separation of forces, to a distance of ten kilometres in depth, et cetera.

Q. So you claim that this unit was killing its own civilians to maintain the tension and the atmosphere of fear, to prevent reaching an agreement? ¹²⁵⁷⁶

A. Yes. You put it very well.

Q. Couldn't they avoid the reaching of an agreement even without killing peasants?

A. As far as I can remember, an agreement was never reached.

Q. Well, they could have failed to reach it even without killing innocent peasants.

A. You seem to be making a connection between two unrelated incidents.

Q. You are describing this event wherein this peasant took his sheep -- took his cows or goats to graze there and one of them would step on it. Anyway, I can't understand why you are telling these things. Do you know at all who these terrorists - and I have information that it was Croatian terrorists - who it was that they killed at this water tower?

A. I don't know. I know that a minefield was laid, I know a civilian was killed, I know a Serb civilian stepped on one of the mines.

Q. Do you know that at the water tower it was a guard that was killed by stepping on a mine, and Velibor Matijasevic, president of the Socialist Party of Glina -- do you remember a socialist party was formed there in Banija, in Kordun? Bora Mikelic was the president at that time, in 1990, at the beginning of 1991.

A. I wasn't involved in politics. I don't know about that.

Q. Very well. You are not aware of that. You don't know who was killed, you don't know that it was the president of the socialist party who was killed there, but you do know that it was done by the people who you claim did it. ¹²⁵⁷⁷

A. Precisely.

Q. All right. On page 19, you say that Jovo Vojinovic, to whom you referred yesterday as a friend of yours, killed an elderly couple. You don't have to look for it. It's on page 19, paragraph 3. You said yesterday the man was a friend of yours. You said that Jovo Vojinovic threw him into a well and bragged about it.

A. Yes.

Q. According to the information I have, a similar incident did happen, but you are misrepresenting it, just as you are misrepresenting everything else, and you are groundlessly and falsely accusing this friend of yours, Jovo Vojinovic. Why are you doing that?

A. It is not groundless. Mr. Vojinovic told me personally that he had done it, so it's not groundless. It is based on the statement of the man who did it.

Q. All right. Where did it happen?

A. In one of the villages along the banks of the Kupa River.

Q. Do you know that a similar incident happened involving not an elderly couple, but two women; two women, not a couple?

A. Somewhere else? What's the question?

Q. Do you know about this incident?

A. That's not the case.

Q. Yes, that was precisely the case. Two women were thrown into a well, as you said, according to the information I have gathered, and it was in the village of Brodja [phoen].

A. I don't understand the question. What are you asking me? ¹²⁵⁷⁸

JUDGE ROBINSON: Mr. Groome is on his feet.

MR. GROOME: In fairness to the witness, can we either have a place and date identified or can the witness be shown a copy of this information? It seems rather vague information to expect the witness to be able to answer, and it's regarding two women.

JUDGE ROBINSON: Yes, Mr. Milosevic. Can you be a little more specific?

THE ACCUSED: [Interpretation] I can be more specific. Since I'm not in a position here to defend anyone, or accuse, I'm only defending the truth, I can say that according to the information available to me --

MR. MILOSEVIC: [Interpretation]

Q. Do you know that the Prosecution authorities conducted an investigation and found out that this crime was perpetrated by a conscript, also a Serb, Branko Miljkovic, not Jovo Vojinovic, your friend. He was a member of the anti-terrorist units, and it was done for purposes of gain, not as part of anti-terrorist activity. And it was qualified as murder out of base motives. That is the most serious type of crime. And the man spent the rest of the time until the fall of Krajina in prison.

A. Do you allow for the possibility, Mr. Milosevic, that there were more than one incidents of the kind, that we are talking about two different incidents? I am claiming that the incident mentioned in my statement is something I learned about from the horse's mouth, from the mouth of the man who did it and who said that he had killed an elderly couple who had been accused of making signals to the Croatian side using candlelight from their window. About these two women you're talking ¹²⁵⁷⁹ about, I know nothing about that. I know only about the incident that I refer to.

Q. This information that I'm quoting is something I received in response to your claims, and it seems to be a similar event, and the man involved was accused, convicted, and sent to prison.

A. You said it yourself. A similar incident. That means there was more than one.

Q. No. I'm saying that I'm talking about something similar to what you made up.

JUDGE ROBINSON: Mr. Milosevic, I think you have taken this as far as you can. The witness has given his answer. He says that he was speaking of another incident. I think you must move now to another area.

THE ACCUSED: [Interpretation] All right. You are right, Mr. Robinson. There's no point in dwelling on this.

MR. MILOSEVIC: [Interpretation]

Q. Have you heard of Croatian Minister Zulic who was captured during fighting around the village of Losinj?

A. No.

Q. So you are not aware that it was precisely Ajdinovic who took him over and handed him over to Croatian authorities immediately afterwards?

A. There is an incident that comes to mind, a similar one, that is, the arrest of a Croatian colonel who had, by mistake, crossed over to our sided, near Turanj, was taken into custody by the military police and was later exchanged for a colonel of ours. That is an incident that seems to be similar to the one you are talking about. ¹²⁵⁸⁰

Q. All right. I named a line of -- a number of villages, Lukinici, Buncici, and a number of other villages in the same area, villages populated by Croats who lived peacefully throughout the war. So if there had been a unit which was supposed to expel Croats from this area, would all the Croats from these villages have been expelled or not?

A. No. I just gave you a number of reasons why they were not.

Q. So when they are expelled, they are expelled on orders from Belgrade, for purposes of ethnic cleansing?

A. Yes.

Q. When they are not expelled, they are not expelled on orders from Belgrade to make Belgrade seem good, look good?

A. Yes.

Q. Whatever the Serbs do, they commit a crime. They simply have no choice, whether you expel them or not expel them, you are always the one at fault. Do you know that on the 4th of July, 1991, in Topusko, 250 members of the ZNG, the Corps of the National Guard, arrived on buses, and Serbs, although forming a majority, had to leave the place?

A. On the 4th of July, 1991, I was not in Topusko.

Q. You were in Kladusa?

A. Yes.

Q. Tell me, please, Mr. Lazarevic, how far it is from Topusko to Kladusa.

A. 17 kilometres, thereabouts.

Q. 17?

A. Maybe I'm mistaken. 15 or 17. ^{12581 BLANK PAGE 12582}

Q. You, who are an intellectual, following events, living in Kladusa, you don't know of an event which happened only 17 kilometres away from you?

A. I'm saying I cannot comment because I wasn't there.

Q. You were not there when all these other events you spoke about happened. You speak from the words of others.

A. You are wrong, Mr. Milosevic. What you are talking about was shown on television. Everybody in Bosnia and Herzegovina had the occasion to watch the arrival of Martic's special units. All of that was shown on television. I just don't want to comment on something about which I had no official information, nor was I present when it happened.

Q. I already asked one of the previous witnesses, but he didn't take my point. Maybe you will. Do you know that famous saying that the greatest lying is done during elections and after hunting and fishing?

A. I don't know about it.

Q. Otto von Bismarck said that people lie the most during elections, after hunting, and during the war.

JUDGE ROBINSON: We heard that one before.

MR. MILOSEVIC: [Interpretation]

Q. Does it seem true to you that most -- the greatest lies are told during the war?

A. That seems very probable.

Q. Regarding this event in Topusko - you didn't hear about because it was on the 4th of July - do you know that not a single Serb house was left intact in Topusko? ¹²⁵⁸³

A. I know that when I entered Topusko, most of the buildings were torched. Were they were Serb or Croatian, I don't know.

Q. Do you know that the majority population of Topusko was Serb?

A. Yes. I was there before the conflict once.

Q. And do you know that the majority population was Serb?

A. I wasn't interested in the ethnic make-up of Topusko.

Q. Do you know about the Serb village of Miljevici? Do you know where it is? Do you know that it was razed to the ground, destroyed, and looted in the same way?

A. No, I don't.

MR. GROOME: Your Honour, Mr. Milosevic, throughout the course of the morning, has referred to villages. Prosecution Exhibit 336 is a commercially available map. May I suggest -- and I've made -- taken the liberty of making some photocopies for Mr. Milosevic so that he can use with the witness. I think, in fairness to the witness, he should be presented with a map. On the single page that I have, there are at least a hundred villages. Perhaps if Mr. Milosevic could indicate on the map the village that he is asking the witness about, it will facilitate the witness's ability to answer his question. And I have some photocopies here, if Mr. Milosevic or the Chamber wishes.

THE ACCUSED: [Interpretation] I don't believe --

JUDGE ROBINSON: Would you be facilitated by the maps?

THE ACCUSED: [Interpretation] I don't believe Mr. Lazarevic needs a map to find his way around Topusko, Vojnic, and Kladusa. He lived there for such a long time that he surely doesn't need a map. ¹²⁵⁸⁴

MR. MILOSEVIC: [Interpretation]

Q. Tell me, please: Do you know that while the ZNG was occupying Topusko, 11 Serbs were killed?

JUDGE KWON: The witness hasn't answered the question. You need the map, don't you?

THE WITNESS: I would prefer, Your Honour, to have a map to actually try to locate these places that Mr. Milosevic is talking about. He relies on my geographical knowledge of the area, which is very poor.

JUDGE ROBINSON: Let the witness have the map.

MR. MILOSEVIC: [Interpretation]

Q. All right. Can you find Topusko, or shall I show it to you? Do you need to find it on the map for this question? So go 17 kilometres from Kladusa and find it.

A. Yes. And what's the question?

Q. The question is: Do you know that 11 Serbs were killed in a short interval, when Topusko was occupied by the Croatian National Guard, a well-known paramilitary formation?

A. No, I don't know of that detail.

Q. Fine. And do you know -- it is a related question. You don't know, is your answer to the first question. Do you know that not a single Croat was killed or wounded when the town was taken over by the police and army of the Republic of Serbian Krajina?

A. I don't know about that either.

Q. So you are not aware that the Croatian National Guard killed 11 Serbs when they occupied Topusko; and later, when the army and police of ¹²⁵⁸⁵ Serbian Krajina entered Topusko, not a single Croat suffered from it?

A. Look, Mr. Milosevic, nobody sent reports to me from the ground about what was going on in Topusko at the time. I could only see what the television reported, and that's all.

Q. All right, Mr. Lazarevic. Do you know of a single crime committed by Ustasha and paramilitary Croatian forces in that territory?

A. Yes.

Q. On page 15, you say that you don't know of a single incident when Croatian terrorists made incursions into the territory of Krajina.

A. That much is true. I'm not talking about attacks of the Croatian army.

Q. Operation Flash, Storm, et cetera.

A. That will be subject-matter for other trials. I don't want to go into that.

Q. So what do you know? You said that you were aware of crimes committed by Croatian and Ustasha forces on the territory of Serbian Krajina. What exactly do you know about it?

A. The Medoc pocket was an example that hit me very hard, for instance. It was an attack that was aimed at scorched earth, and I know about it. I was there at the time. I also know about it from reports.

Q. Do you know, in addition to what I cited yesterday, in the neighbouring area to Topusko, do you know about the murder of eight civilians, elderly and children, in a canyon in Slunj, in June 1992?

A. June 1992? I don't know. But you can be certain that if that had happened then, I would certainly have been informed by my command. ¹²⁵⁸⁶

Q. As you see, you were not informed, and you think of yourself as a well-informed man.

A. It couldn't have been.

Q. Do you know about the murder and massacre of 13 members of Territorial Defence on a bridge in September 1991?

A. I know about that. I talked to one of the survivors.

Q. How about 11 members of Territorial Defence that happened in October between Sturlic and Cetingrad? They were murdered in October of that year.

A. I heard you very well. My answer is no.

Q. That was in your immediate vicinity.

A. In October 1991?

Q. As far as time is concerned, it was not very close to you, but between Cetingrad and Sturlici, that area was close to where you were.

A. Provided that I was in Kladusa, it's 11, not 12, kilometres.

Q. Yes. About ten kilometres. And in October 1991 you were in Kladusa.

JUDGE ROBINSON: We are coming to the time for the break. We'll take the break now and we'll resume tomorrow at 9.30. Mr. Milosevic will have one and three-quarter hours of cross-examination.

Do you have a witness after?

MR. GROOME: Yes, Your Honour. The Prosecution does have a witness afterwards. I neglected, before I finished my questioning, just to do that stock-taking exercise that Judge May had suggested. I'm ¹²⁵⁸⁷ prepared to do it now or tomorrow morning, whichever pleases the Chamber.

JUDGE ROBINSON: I think tomorrow morning. We'll take the adjournment, and I remind the witness that he is not to speak to anybody about his evidence during the break.

--- Whereupon the hearing adjourned at 1.46 p.m. to be reconvened on Thursday, the 31st day of

October 2002, at 9.30 a.m.