¹⁹³⁸⁷

Wednesday, 16 April 2003

[Open session]

[The accused entered court]

[The witness entered court]

--- Upon commencing at 9.03 a.m.

JUDGE MAY: Yes, Mr. Milosevic.

WITNESS: WITNESS B-1[Resumed]

[Witness answered through interpreter]

THE ACCUSED: [Interpretation] Mr. May, as you have given me a very short period of time to ask my questions, I can only ask a few. But I should like to draw your attention and have you understand with respect to the events that the witness is testifying about that from the document on the Muslim side, which I received from the opposing party there pursuant to Rule 68, and it is page 01025180, on that page it talks about the events in Glogova on the 9th of May, 1992. And from that document, one can see that they were in fact local paramilitary forces. That is evident from that document.

I just wish to give you this as reference - I quoted the page number - for it to be clear --

JUDGE MAY: Why don't you ask the witness about that?

THE ACCUSED: [Interpretation] Well, I referred to their own document to make this clear to you and to throw light upon the answers given by the witness.

Cross-examined by Mr. Milosevic: [Continued]

Q. Mr. B-1701, in your previous statement you said that these people ¹⁹³⁸⁸ were killed by a woman from Kravica. Why did you change that assertion of yours and why do you then go on to speak of the fact that it was the army that did that?

A. As we have maintained, I said when it began on the 9th of May, that genocide, it was the women. They worked together. And I stand by it. She was a soldier. She was wearing a Yugoslav People's Army uniform, and I stand by what I said.

Q. Please. In paragraph 13 of your statement, you say: "In my previous statement it says that a woman killed them from Kravica. But I should like to explain here that I didn't see her actually firing."

A. Yes. I didn't see her personally fire when she fired at that young person Mensur, but I saw personally her fire at Camil, and then she turned from Camil towards Mensur and I think she shot him. Nobody else did. Because as soon as she turned towards me, her pistol was raised up in the air like that and I saw the smoke or whatever coming out of the barrel, so I was able to conclude that nobody else had fired except her. And she was a soldier of the Yugoslav People's Army and was wearing a uniform.

Q. All right. And a moment ago, I asked you whether you knew that it was the local paramilitary unit. And in the document itself which has come in to us from the Muslim side, it names names and identifies the people.

A. Well, I don't know any of these paramilitary units. All I can do is recognise the Yugoslav People's Army unit, and that is the army, as far as I'm concerned, and I recognise nothing else. ¹⁹³⁸⁹

Q. All right. But you say you know -- knew the woman.

A. Yes, I knew the woman. She was a cleaning lady at Potocari in a company there, in a transport company. And I knew her by sight. I didn't socialise with her, but I knew her by sight. I knew her like that.

Q. Well, what was the woman's name?

A. I apologise, I don't know the name. I can't tell you the name. I'd be lying if I said I could, and I don't wish to lie.

Q. Yes, I quite respect that, but you're talking about a woman, and then you say -- and you say you didn't mention the army, and then suddenly afterwards you mention the army.

A. From the very first moment she was with the army and she was wearing a uniform, from the first, and that's what she did.

Q. Now, when you say the army, do you mean that woman too? Do you include that woman?

A. Well, yes. She was a soldier too, and it was all the army, as far as I was concerned.

Q. Then you go on to enumerate other people, somebody nicknamed Riba Milo, Zaric, Radic, Pera, and all the rest.

A. Yes, people I saw around.

Q. And then you name several people there.

A. Yes, that's right.

Q. Are they all people from your neighbourhood?

A. Yes, all in the municipality. They were all my neighbours.

Q. Thank you, that's all I wanted to hear. They were all your neighbours. ¹⁹³⁹⁰

A. Well, the Bratunac municipality. I recognise the people. I didn't see them do anything; I didn't see them beat anyone or provoke anyone or things like that, I don't want to say that. No, I didn't see that.

Q. All right. Now, this happened on the 9th of May; right?

A. Yes, the 9th of May.

Q. Do you know that there were conflicts -- I mentioned Bijecevo, that is a neighbouring village, where various Serbs were killed on the 6th of May, for example.

A. No.

Q. And then again on the 7th of May.

A. No. Well, how could I know that? I said yesterday that I was in such a bad state that I was urinating blood and I had to hide in a bunker. That is to say I hid in the ground. I dug out a hole and it was like a bunker.

Q. Yes. I'm asking you, are you aware of the fact that the conflict was two-sided, and quite obviously -- and I have a piece of information here which I received from the opposite side over there, Mr. May. And it is page 017975, where we can see the 6th of May, the 7th of May, the 8th of May, the 9th of May, and that includes the day when this particular event took place, the one that the witness is testifying about. So I'm asking you whether you know that there were conflicts --

JUDGE MAY: What are you alleging? You say you have this piece of paper. We don't know what it is. And then you say we can see the 6th, the 7th, and the 8th of May. Now, what are you alleging occurred on those ¹⁹³⁹¹ days? So clarify that so the witness can understand what you're putting.

THE ACCUSED: [Interpretation] It was on those days that there were clashes, that clashes took place, and I have a list of the casualties, the victims. And it says, "Provisional List of Victims of Muslim Terror Over the Serbian People." That's the title of the document. And then it says April 1992, in May, the 6th of May, the 7th of May, 8th of May, 9th of May.

JUDGE MAY: Who put this forward? What is this document that you're referring to? Can you help us, Mr. Groome? It's apparently one of your documents that you disclosed to him.

THE ACCUSED: [Interpretation] Their numbering is 01 --

JUDGE MAY: Just a moment.

MR. GROOME: Your Honour, we're going to try to pull out the document now. I would just say generally, Your Honour, the fact that the Prosecution had the document in its possession really says nothing about its provenance in and of itself. I will inquire about the provenance of this particular document and report to the Chamber as soon as I can.

JUDGE MAY: Yes. In any event, what is suggested? Let's try and move on. It says -- just a moment, Mr. Milosevic. Let's try and do something for the witness.

Do you know anything these conflicts alleged to have taken place on the three days before what happened in the village?

THE WITNESS: [Interpretation] No, I don't remember that at all, nor do I know about that. This is the first time that I'm hearing of it.

JUDGE MAY: Yes. Well, if it's true. One doesn't know. ¹⁹³⁹² Yes. Let's move on, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. And do you know Ramo Babajic? His father's name was Omer. He was from Glogova. Your own local from Glogova village.

A. Ramo Babajic, yes, I do know him.

Q. Well, do you know that he was an extremist of the SDA party and that he participated in the attacks and killings of Serb civilians?

A. No.

Q. Including Magasici and so on.

A. No. No. Nor did that man ever have any weapons or bear arms. I don't know if he's still alive. I'd like him to be so that he can come here and tell you. That man never -- no, come on. Never.

Q. All right. Thank you very much. That is what it says in the document.

A. No. I stand by this. That is not true. No, no, not for Ramo either. Don't -- I'm not going to say what I don't know. Don't put things in like that.

Q. Well, I don't know about these events. I only have what I have on paper. 010807 is the number -- the page number.

JUDGE MAY: One at a time. Now, the accused is putting some piece of paper he has got to you. There's no evidence where it comes from and no reliance can be placed on it at the moment, but deal with, if you would, with the allegations which he makes.

Yes, Mr. Milosevic. You've got five minutes left.

THE ACCUSED: [Interpretation] Well, that's very short. Too short. ¹⁹³⁹³ I should like to be given at least a few more minutes for me to get through several of my questions.

MR. MILOSEVIC: [Interpretation]

Q. Now, do you know Ejub Golic, for example? His father's name was Mustafa, he was from Glogova also.

A. Golic Ejub. It wasn't Mustafa, his father's name was Latif.

Q. All right, but do you know the man?

A. Yes, I do.

Q. Do you know that he slit the throat of Marko Micic who had been detained, captured?

A. No. How could I know that?

Q. And that he led operations against a number of villages in the Bratunac municipality, precisely that civilian from Glogova?

A. No. I know nothing about that.

Q. You know nothing about that?

A. No, nothing. Because I had to receive medical treatment when I went to Potocari. I had to be treated for the state I was in. How do you expect me to know things like that?

Q. The page is 0 --

THE INTERPRETER: Could the accused please repeat the page number.

MR. MILOSEVIC: [Interpretation]

Q. And it is the numbering of the opposite side.

JUDGE MAY: You're asked to repeat the page number, please. It's not being interpreted.

The microphones are down, Mr. Milosevic. We'll just have to wait. ¹⁹³⁹⁴

THE ACCUSED: It is switched off.

JUDGE MAY: We will have to adjourn.

--- Break taken at 9.19 a.m.

--- On resuming at 10.19 a.m.

JUDGE MAY: Mr. Milosevic, you've got ten minutes more. We'll sit for an hour and a half, we'll then take a 20-minute break and then sit for the rest of the time scheduled.

THE ACCUSED: [No interpretation]

THE INTERPRETER: Can you hear? Are you getting any translation? Can you hear the English on this channel?

THE ACCUSED: [Interpretation] I see that my question wasn't recorded on the transcript so I'll repeat the question. This is it:

MR. MILOSEVIC: [Interpretation]

Q. Let's clear up this question of uniforms, Mr. 1701. Do you know that the entire Territorial Defence wore the same military uniforms, army uniforms, and that they had the uniforms in their own homes? That's where they kept them.

A. No, I don't know that they had this uniform, the Yugoslav People's Army uniform. The Territorial Defence had quite a different -- quite different clothing. It was a little thinner.

Q. I don't know that it was different from the JNA, but tell me this then: Do you happen to know that in the Bratunac municipality the entire Territorial Defence was, to all intents and purposes, all the command posts were held by Muslims? Do you know that? Are you aware of that?

A. No. ¹⁹³⁹⁵

Q. Have you heard of Sabit Mujkic, for example, who was commander of the staff of the Territorial Defence?

A. No, I haven't heard of him. I wasn't interested.

Q. I'm asking you about the Bratunac municipality.

A. No. When I received this Territorial Defence clothing and handed it back, I didn't really know those people, nor did I recognise them.

Q. How about the deputy commander for operative affairs and training, who was also a Muslim, and his name was Hadzic Dzemo?

A. No. I've already told you I don't know any of those people. I worked in Drina, Srebrenica, in Sumarstvo. I really don't know any of the people working in the municipality.

Q. All right. The one who issued the uniformed who was the logistics assistant, Becirevic Mevludin, do you know him?

A. No, I don't know any of them. I would just go there, sign my name, sign the receipt, get the clothing, get the uniform, and the same process when I took it back.

Q. And do you know that the commanders of the companies of Territorial Defence for your area, Konjevic Polje and Glogova and Ranca and all the other areas, Potcaus and Suha and all the rest of the places were all Muslims?

A. Well, I don't know any of that.

Q. All right. Then I'm not going to ask you about that. What about this name, does that ring a bell: Avdic Senahid from Glogova, and his father's name was Idriz. Do you know him?

A. Yes. ¹⁹³⁹⁶

Q. You do, right. Do you know that he is on the list of criminals that took part in the attack on Magasici?

A. That's the first I hear of it. The man was ill and everything.

Q. But for your record, it is on page 00678871. And did you mention Meho Cosic?

A. No, I don't remember. I don't know that man nor did I mention him. He's not in my memory. I did not.

Q. Very well. So -- but you know these other ones?

A. No, I'm not saying I know them. I don't know him. I don't know that man.

Q. Okay. And do you know Avdo Golic from Glogova?

A. Avdo Golic, yes, I know him.

Q. And do you know that he too is on the list of people who were killing and looting in Magasici?

A. Avdo Golic.

Q. Yes.

A. How can you say that? He was executed on the first -- on the 9th of May in Glogova. So don't make things up. He was executed at the same time when they shot at me.

Q. This is 0085055. This is the page number.

A. You can only ask me about the things I've decided to talk about. Don't ask me about things that didn't happen. Avdo was shot, executed. So we can see immediately that that is not correct. All these questions are not right. None of it is right. This question proves it.

Q. And do you know Esad Ibisevic from Glogova? ¹⁹³⁹⁷

A. Yes, I do. Ibisevic Esad.

Q. Was he involved in killing, looting, burning houses in surrounding villages?

A. Which villages? What do you mean? How can I know that?

Q. Do you know anything his activities?

A. I know that Esad Ibisevic was in Tuzla in prison.

Q. Before the war and everything, what was he doing?

A. He was in prison in Tuzla.

Q. I see. He was in prison in Tuzla. So he was a criminal.

A. How can I know what he was doing and why he was in prison?

Q. But he is here on the list of people.

A. But that is not true. He wasn't there, nor did he participate. You see how you're asking me questions. There are no records. There's nothing.

Q. I'm telling the Court, not you.

A. Don't say things that don't exist. It is page --

JUDGE MAY: One at a time.

MR. MILOSEVIC: [Interpretation]

Q. It is on page 00678857.

JUDGE MAY: What is this list that you're referring to, Mr. Milosevic? Where does it come from?

THE ACCUSED: [Interpretation] I received it from the opposite side, Mr. May.

JUDGE MAY: And what does it purport to be?

THE ACCUSED: [Interpretation] It is a list of war criminals, ¹⁹³⁹⁸ consisting of more than 300 names who participated in the killing of Serbs in the area, and I asked him about this one from Glogova.

JUDGE MAY: Just a moment. Just a moment. It may be that we're going to find out what it is, where this comes from.

MR. GROOME: Your Honour, we will look for these numbers that were just recently mentioned. Before we had the technical problem, Mr. Milosevic mentioned another document and I do have information for the Chamber on that.

The number was -- the ERN number was 00017954 to 8085. The title of that document is "Memorandum on War Crimes and Crimes of Genocide in Eastern Bosnia Committed Against the Serbian Population from April 1992 to April 1993." That was prepared by the Yugoslav State Commission for War Crimes and Genocide and was submitted to the United Nations by the accused's own government. And I can -- the Prosecution cannot attest to anything about the reliability of that document.

JUDGE MAY: Of course. It's something put forward by the Serbian side, allegations.

Yes, Mr. Milosevic.

THE ACCUSED: [Interpretation] And this document, Mr. Groome, 01025179, and I quoted page 01025 --

JUDGE MAY: Let's not waste time. They're looking for that. You can tell us, if you can, what that document is.

THE ACCUSED: [Interpretation] It's a document provided by the Muslim side, not the Serb side, saying that these are activities by local paramilitary formations. That is not a document of the Serbian side, and ^{19399 BLANK PAGE 19400} I have that document here with me.

JUDGE MAY: Yes. Well, the Prosecution will try and find it. Yes. Let's go on.

MR. MILOSEVIC: [Interpretation]

Q. You speak about the events that took place then. How far is the bus station from the shopping centre?

A. About 250 metres, roughly.

Q. And you say you saw Deronjic at the bus stop.

A. Yes. When they were chasing me along the road, I didn't dare look left or right, he was standing there at the bus station with a couple of soldiers as we passed by.

Q. So passing by. So you went to the commercial centre and the Deronjic you mention as a person in a negative light, he was 250 metres away at the bus station.

A. He was at the bus station. Don't confuse me. I was saying at the bus station, together with two other men. And from there I was forced up there where the men were separated from the women.

Q. Tell me, so that man wasn't present at all when these things were happening at the shopping centre.

A. How are you asking me these questions? I was telling you, as we were passing by, he was at the bus station together with maybe seven or ten people, and from there I was forced up to Mujo Osmanovic's house. After a while, he came again in a car. He just looked around, turned his car around, went back to the same spot at the bus station. Zaim Beganovic's house is there and Rabin Golic [phoen] told me that he held a ¹⁹⁴⁰¹ meeting and he sent him home to get a rifle and he didn't have a rifle. And he told me this two days later, when he found me lying there. And he said --

Q. But you're telling us about the return of weapons. You said that you surrendered weapons on the 5th of May and there were only three policemen.

A. Yes. There were three policemen at the gate. That's what I'm saying. But there were many of them along the macadam and asphalt roads.

Q. Very well, but those policemen were both Serbs and Muslims.

A. What do you mean when they had separated by then? The civilian police had all been separated. No one was working any more.

Q. Very well. You're saying that you tried to escape together with Ramiz Cosic but the bullet hit Ramiz, he fell, and you were the only person who survived what was going on; is that right?

A. No, it's not right. Ramiz was not with me nor was I with him when he was killed. I heard later that Ramiz was killed as I went towards Srebrenica. That is not right. Don't ask me questions that are not right, that are quite the opposite.

Q. That's what I'm talking about.

A. I'm also talking about that. Don't say that. The man asked me about these things.

Q. In point 31, you say -- I'm not asking you things that you didn't say.

In paragraph 31, you say what I have just asked you. "Serb soldiers told us to run towards the wood," and so on. ¹⁹⁴⁰²

A. You're confusing me. You're mixing up things that happened maybe 15 or 20 days later when the man was killed.

Q. But didn't you say a moment ago that you didn't see Ramiz being killed?

A. How could I see it?

Q. You say that you were told that Ramiz was killed, and you didn't see it.

A. His father told me when he found him.

Q. Wait a moment, please. That's why I'm asking you. You say here: "I saw the head of Ramiz Cosic being blown off."

A. Yes, Ramiz Cosic. Because he was on my right side. You're mixing up Ramiz Cosic and Ramiz Gerovic. These are two different things for me.

JUDGE MAY: You must bring this to a close. You can ask two more questions.

THE ACCUSED: [Interpretation] It's very hard to select two questions.

MR. MILOSEVIC: [Interpretation]

Q. You were a member of the Muslim army of Bosnia and Herzegovina, weren't you?

A. Yes, I was. I don't know exactly when, I don't know the date. I joined -- I couldn't walk, I couldn't do anything. I was peeling potatoes so I could get food to eat.

Q. And do you know how many times this Magasici was attacked by Muslim forces, and that the persons who committed crimes have been identified; that is, Osmanovic, Junuz, Meho from Magasici; Osmanovic ¹⁹⁴⁰³ Saban; Hasanovic Camil [phoen]; Carmin Adica [phoen]; Naket Nasir [phoen]; Babjic Ramo [phoen]; Smajlovic Rahiden [phoen]; Osmanovic Hajrudin. They have all been identified for attacking and killing Serbian civilians, all civilians in Magasici that you have spoken about. Do you know anything about that?

A. No, no.

JUDGE MAY: Yes, Mr. Kay. Questioned by Mr. Kay:

Q. Witness, I'm going to ask you some questions about the 9th of May. And on that day, some of the people who were attacking the area had masks on and others did not. Is that right?

A. They all had masks over their faces, and I couldn't see any one of them without a mask when the village was attacked.

Q. I'm looking at a statement you made to the Prosecution on the 2nd of March of last year, and in that statement you say: "The Serbs were mostly wearing masks, but some were not." Is that right?

A. I don't know how to explain it. I only saw Deronjic who didn't have a mask on his face. As for the others, they all were masked.

Q. And after you've said that some of the Serbs were not wearing masks, you name some people from the Glogova district whom you recognised from the 9th of May, and you knew they were Serbs. Do you remember that?

A. You mean later on when I saw Milo Riba and the others, is that what you're referring to?

Q. That's right. On the 9th of May --

A. Yes. Yes. They weren't attacking anyone. They were not ¹⁹⁴⁰⁴ insulting anyone or anything at all.

Q. You saw someone you knew as Milo Riba, who used to have a private truck, but he was wearing a --

A. Yes.

Q. -- SMB uniform?

A. Yes. They were all in SMB uniforms, each and every one of them.

Q. You saw Zaric Milan. He was a house painter.

A. Yes. Yes, I did.

Q. You saw Radic Gojko. He was a driver.

A. Yes, yes.

Q. For the Drina company.

A. Srebrenica.

Q. You saw Pero, who was a taxi driver.

A. Yes, I did.

Q. You saw Miroslav Deronjic?

A. Yes, but he was in another group. He wasn't with them, those that had masks over their faces.

Q. Don't worry where people were. I'm just asking you about those you describe as the attackers on the 9th of May. It doesn't matter what they were doing, it's just who they were. Do you understand?

A. Yes, I understand. Those men didn't have masks over their faces. They didn't attack anyone, they didn't say anything to anyone. I was just being forced up there with my dear mother. That's all I know about that.

Q. But they had uniforms on?

A. Yes. They were wearing uniforms of the Yugoslav People's Army. ¹⁹⁴⁰⁵ All, each and every one of them. Let's not talk about uniforms. All those soldiers were wearing the uniform of the Yugoslav People's Army.

Q. But you knew those people, those names I've given you, were not in the army. They were neighbours of yours. They were local people.

A. All neighbours. I knew them. I knew that they weren't officers. I never saw them in uniform before. Milo Riba helped me a lot when I was building my house. It is hard to imagine that this happened.

Q. Miroslav Deronjic you describe as being a leader of the attackers at the time; is that right?

A. I don't know whether he was the leader. I can't say that. I didn't know that he was a leader nor what he was doing. I just saw him there when we were being executed. When we carried the bodies and came back for the second group, he again came wearing a SMB officer's uniform of the Yugoslav People's Army and a beret on his head.

Q. You saw Deronjic giving orders on that day.

A. No. No. He wasn't issuing any orders. He was just standing still and observing things. He didn't speak a word, that man.

Q. Had he given orders to you before the 9th of May?

A. He wasn't issuing orders at all. He just came. He held two meetings, as far as I can remember, that's all, that we shouldn't panic, that nothing would happen, that we should surrender our weapons, that our weapons would be returned to us after they had been checked, and that was all. He didn't say anything more to us. That was it. At least, I don't remember while I was there. Now, later on, whether he came and spoke to the president of the local community, I don't know about that. ¹⁹⁴⁰⁶

Q. However, on the 9th of May when you first saw Deronjic, he was wearing civilian clothes when you first saw him; isn't that right?

A. Yes, civilian.

Q. And then he put on a uniform later.

A. Later. I saw him in uniform when we were down there after the execution. When we were carrying the bodies and when we came back for the second group, he was wearing a SMB officer's uniform with a beret on his head. He didn't say anything to anyone. He was just standing at attention and watching people.

Q. Do you know if people -- if it was common in your area for people to keep their old army uniforms if they'd be in the TO or if they had been in the regular army?

A. No. You had to hand it in immediately. If you don't hand it in, the police would chase you around.

Q. At this time, lots of people were wearing old JNA uniforms, weren't they?

A. I don't know. I couldn't notice anything or observe it. Who would wear it? Only these soldiers that I saw. I couldn't see anyone else. And I didn't know who they were. They had socks over their heads. How could I recognise them?

Q. Later on, you joined the BH army as a cook; is that right?

A. Yes. Yes.

Q. And how long did you work for the BH army?

A. About three months after Srebrenica fell. I peeled potatoes. I couldn't do much. My hands hurt, my back; I wasn't in good health, I ¹⁹⁴⁰⁷ wasn't fit. My hand is still not all right. I had to work a little so I would get aid to be able to feed my family. There were five with me that I had to look after, though I wasn't really able to do it properly.

Q. But for how long did you work for that army?

A. About five months. Not more, I'm sure. After Srebrenica fell, that is when I joined.

Q. Thank you.

MR. KAY: No further questions. One other matter to help over the names that were given. I don't know if Mr. Groome has been able to see document 00799571 in English. It's a list on the same subject, and it's one that I was able to pick up. I don't know if that helps the

Prosecution.

MR. GROOME: We'll look at that document as well. Re-examined by Mr. Groome:

Q. Sir, in the course of your testimony over the last two days you've mentioned two people by the name of Ramiz. The person with the name Ramiz who was next to you at the river when you were shot at and Ramiz was killed, what was his last name? Give us his full name, please.

A. Cosic Ramiz.

Q. The other Ramiz that you mentioned in your testimony, Ramiz Gerovic, you were not personally present --

A. The other Ramiz, yes.

Q. You were not personally present when he was killed, were you?

A. No. No. No. ¹⁹⁴⁰⁸

Q. Now, Mr. Kay has asked you about the names of four men who you mentioned in your statement as people that you recognised. Can you tell the Chamber in a sentence or two the circumstances under which you saw those four men on the 9th of May.

A. Milo Riba and the others. You're referring to them, are you? Is that what you're asking me about?

Q. Yes, sir. Without going into great detail, can you just briefly describe how it was you came to see those men and recognise those men, and what you saw them doing.

A. I was being herded along the asphalt. They were on the right-hand side in front of the school, and that is how I recognised them. They came to the road, they were quiet, they didn't say anything.

THE INTERPRETER: Sorry, we didn't understand what the witness say. He used a word "okahani" [phoen].

MR. GROOME:

Q. Sir, could I ask you to repeat the last portion of your answer. The interpreters had a bit of trouble hearing it.

A. As I was going along the road, on the right-hand side -- I was going on the right-hand side, and to the right of the schoolyard they were going, and they reached the asphalt road, and we were going on with women. There were lots of us. And they stopped there and were observing us. They didn't say anything at all. Ah, they were very sad. They looked sad, as if they were about to cry.

Q. Now, there's been a great deal of discussion about uniforms and whether they were old or new and whether people were allowed to keep them ¹⁹⁴⁰⁹ after they left the service of the JNA. The question I have for you is: You've mentioned seeing a number of tanks, a number of armoured personnel carriers in the town at the time of the attack. My question is: Prior to April of 1992, did you see these vehicles, these tanks, these armoured personnel carriers, in the town of Bratunac or in Glogova prior to April of 1992?

A. I would see those vehicles in Bratunac in front of the fountain -- Fontana, parked there, and down there, close to the hospital or health centre. That is where those vehicles were. There were lots of troops. They were all wearing JNA clothing with light machine-guns. At the department store, there was a soldier on every corner and a woman with him. And all their weapons were on the ready. And that is how I passed. I didn't go back to Bratunac again.

Q. Sir, can you tell the Chamber, what is the earliest point in time that you can recall seeing this level of military machinery in the town of Bratunac?

A. That day when I went to Bratunac, I saw them. That's it. I went to report to my company, right behind the police station. That is where my company was. I went to the company to see what they wanted of me, and that's when I saw them.

Q. As far as you could tell, the tanks, the armoured personnel carriers, were they vehicles belonging to the Yugoslav People's Army?

A. Who else could they belong to? They couldn't belong to anyone else.

MR. GROOME: I have no further questions. ¹⁹⁴¹⁰ Your Honour, just an observation regarding a number of documents that have been used in the cross-examination. I have been able to get details of some of them, just awaiting details on others. But many -- the other documents that the -- Mr. Milosevic referred to was a document. All I can find out about it was that it was submitted by an individual. The general rule or general policy of the Office of the Prosecutor is that it has accepted reports and submissions by parties, and has used them as an investigative tool to identify crimes that the Prosecutor should investigate. It's never been the Prosecution's position that these documents themselves or these reports prepared by individuals or individual groups have any great evidential value in and of themselves. They're just matters to be further investigated by the office. They've just been provided to the accused and the amici as part of our obligations under discovery of Rule 66 and 68.

JUDGE MAY: In relation to this witness, various statements were referred to, and it is clear, I think, that they should probably be exhibited. These are the statements which he made.

MR. GROOME: Yes, Your Honour.

JUDGE MAY: The witness.

MR. GROOME: Is Your Honour thinking about the OTP statement as well as the earlier statement?

JUDGE MAY: Yes.

MR. GROOME: Yes. The Prosecution would have no objection to that.

JUDGE MAY: Yes. Let that be done. It may be that you could get ^{19411 BLANK PAGE 19412} us copies of those statements. We've got them already. We'll get the next -- since the Prosecution -- we'll have the next Prosecution number, I think might be as convenient as anything.

THE REGISTRAR: Prosecutor's Exhibit 431, Your Honour.

JUDGE MAY: Yes, thank you. Witness B-1701, that concludes your evidence. Thank you for coming to the International Tribunal to give it. You are now free to go.

MR. GROOME: Your Honour, could I just ask, with respect to those exhibits, that they be tendered under seal.

JUDGE MAY: Yes, of course.

[The witness withdrew]

MR. NICE: Your Honour, the next witness has the pleasure of protection. Very little of her evidence will be the subject of an application for private session, and I'll turn to that in just a second. But first, in light of the problems this morning, does the Chamber still want to deal with administrative matters in the third session or, given the real priority of ensuring that this witness is finished before the long Easter break, might it be preferable to put administration back to the end of her evidence tomorrow?

JUDGE MAY: Yes. We will do that. And so that everyone knows the position, I might not have made myself clear yesterday when I was addressing you on the length of submissions from the Prosecution. What I have in mind is that we should begin with the 92 bis witnesses.

MR. NICE: Certainly.

JUDGE MAY: Then the Foca transcript witnesses, and only finally ¹⁹⁴¹³ get on to the matters as far as time and disclosure are concerned. If we deal with them in that way, at least we will deal with those matters which we should --

MR. NICE: Certainly. And the other matters are the subject of written motions in any event.

Before the witness comes in, and this may be a policy the Court would prefer with all witnesses where there is any application for private session, I identify the limited amount of material that she would want in private session. Are we presently in private session?

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

MR. NICE: May we go into private session for these purposes.

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THE REGISTRAR: We're in open session.

MR. NICE: ¹⁹⁴¹⁷

Q. Witness B-129 - paragraph 1 and 2, Your Honours - is it right that you worked in 1993 for the Party of Serbian Unity not out of political affiliation but because it was a well-paid job?

A. Yes, that's right.

Q. Was your work initially limited to election matters, there being no war activities concerned?

A. Yes.

Q. Did you have contact with the man Arkan?

A. Yes, I did. During the election campaign, yes.

Q. Were there also some members of his Tigers unit that worked in the same office as you?

A. Yes, because most of them who were in the Serbian Volunteer Guards during the election campaign were given different things to do within the party.

Q. In the autumn of 1994, did you start to work at the headquarters of the SSJ and SDG in Belgrade?

A. Yes.

Q. Can you give the expansion of both those titles? SSJ being?

A. SSJ is the Party of Serbian Unity. And the SDG is the Serbian Volunteer Guard.

Q. Also known as?

A. The Tigers.

Q. Did your work bring you into regular and close contact with Arkan, his office being one floor removed from yours but he tasking you -- giving you tasks as long as -- as well as many other people every day, or several ¹⁹⁴¹⁸ other people every day?

A. Yes. I would see him every day, and most of the day he would spend at the headquarters of the SDG, the Serbian Volunteer Guards. So we often saw each other.

Q. Paragraph 6. Did you, perhaps along with others, take phone calls for Arkan?

A. Yes.

Q. And did he have a secretary?

A. Yes, he did. He had a secretary, his own personal secretary.

Q. And was the placing and receiving of calls done by you and others through that secretary?

A. Sometimes I myself would answer the phone, the incoming telephone calls, and sometimes it would be his secretary and then she would pass the line on to him.

Q. Did you keep a diary?

A. Yes, I did. It was my diary of daily duties, my agenda for today, what duties I had on each particular day.

Q. The first extract from your diary we'll look at is tab 2 of Exhibit 432, please. It will come up on your screen if it's not there already.

What, as a matter of fact, is this?

A. This is the stamp of the former commander of the -- the late commander of the Serbian Volunteer Guard, Zeljko Raznjatovic, which I used when I had to write a letter in his name, an answer, a response to somebody or give approval for something, that kind of thing. ¹⁹⁴¹⁹

Q. Exhibit 391, tab 7, please. The exhibit has already been looked at. What do you see on the bottom right-hand part of that document?

A. What I can see there is the signature of the commander, Zeljko Raznjatovic, Arkan. And he signed that in Erdut, which means that it is the same signature except for the fact that this is written in his own hand, his own personal signature.

Q. Paragraph 10. On what date was the group known as the Tigers established and where?

A. The group was established -- the date at which the Serbian National Guard was formed is taken to be the 11th of October, 1990. And the place of its establishment, the establishment of the guards, is the monastery of Pokajnica, a monastery near Belgrade.

Q. And was that date, the 11th of October, celebrated every year since then, a certain number of years, as the date of the anniversary of the foundation?

A. Yes, that's right. It was celebrated every year. Sometimes the celebrations would be held in Erdut and sometimes in the monastery of the Pokajnica itself, depending on where the guards were at that time.

Q. How many men initially took the oath appropriate to that group, and then name some of those initial ones that you can now recall.

A. There were about ten of them. However -- or, rather, first of all there was Zeljko Raznjatovic, Arkan. Then there was Nebojsa Djordjevic, nicknamed Suca. Then there was Nenad Markovic, also known as Sicko. Sasa Pavlovic, also known as Crvko; and Dragan Petrovic, also known as Kajman; and others. ¹⁹⁴²⁰

Q. Tab 3, please, of Exhibit 432 is a photograph.

A. On this photograph we see Nebojsa Djordjevic, as known as Suca.

Q. Perhaps it can go on the overhead projector as it hasn't found it's way into the computerised system.

I won't take time on it. We'll come back to the photograph in a minute when the system is back in its normal operation. Can we turn then to tab 4, which again I think is not on the computerised system. The Chamber may wish to look at that. Can you tell us, please, Witness B-129, what this list is and how it's been composed.

A. This list contains the names of the members of the Serbian Volunteer Guards. Then we have the names of the Red Berets. When I say "Red Berets," I mean the special unit of the state security service.

Q. Did you compose this list yourself? Was it provided to you? Explain, please.

A. I compiled the list myself with the names of the people that I would see or hear about during my work in the SDG, the Serbian Volunteer Guards, so when I was going about my daily duties.

MR. NICE: The Court will see on the first sheet names with which it will perhaps already be familiar in part, such as -- looking at the third column, Veliki Rambo, and further down, Mali Rambo. Over the page, third entry, Zika Crnogorac; fourth from the bottom, Legija. Next sheet, three up from the bottom, Kajman, to whom there will be further reference. Arkan himself at the bottom. And then on the last -- the next sheet, four up from the bottom, Frenki. And on the last sheet, three up from the ¹⁹⁴²¹ bottom, Legija.

I'm alerted by -- oh, yes. I'm invited to draw your attention on --

JUDGE MAY: Just help us with that Legija name. It hasn't been clear, but it appears he's got two names.

MR. NICE:

Q. Can you help us, please, Witness B-129, with the nickname Legija. To whom was that associated?

A. Legija relates to Milorad Ulemek or Milorad Lukovic. His real surname was Ulemek, however, as he had fled from the Foreign Legion during 1994, on the 3rd of September, in fact, when he married, he took his wife's surname, which was Lukovic. So it's one and the same person but he goes by two different surnames.

Q. We're now looking at the photograph --

THE INTERPRETER: Microphone, please, Mr. Nice.

MR. NICE: My apologies.

Q. We're now looking at a photograph, Witness B-129. Please tell us who is shown.

A. On this photograph we see Nebojsa Djorjevic, nicknamed Suca, one of the founders of the Serbian Volunteer Guard.

Q. Are you able to identify any of the others in the background?

A. No, I can't say.

JUDGE MAY: The Guard seems to have been described as a Volunteer Guard but also as the National Guard. Have I got that right?

THE WITNESS: [Interpretation] No. This Guard was only known as ¹⁹⁴²² the Serbian Volunteer Guard, the SDG, or the Tigers. The Srpska Dobrovojacka Garda.

JUDGE MAY: So any reference to the National Guard is to something else; is that right?

THE WITNESS: [Interpretation] Yes.

MR. NICE: I understand that there may be problems with the playing of the intercepts which will mean we will have to return to those later. I'll just check with the technical booth whether there is a problem.

And, Your Honour, while we're waiting for information on the state of the technical booth or its ability to deal with the intercepts, I'm also asked to draw to your attention on that last tab, the list, on page 1, the fifth entry, which is Raja Bozovic, is a name that's going to be referred to. On the third sheet, the third entry, Vasa Mijovic; the 6th entry, Sasa Pavlovic. And on the next sheet, in the middle of the page, Mladen Sarac, and then the two Ulemeks that we've already dealt with. Apparently, Your Honour, there is no audio coming out of the intercepts so that we hope that can be remedied over the break. And although it will enforce some discontinuity on the evidence, I'm sure that we can fit those intercepts in when we come to them at a later stage. In your summary, therefore, if you'd be good enough to go to paragraph 18.

Q. Having looked at the list we have, Witness B-129, Crvko and Sicko, can you tell us a little bit about them, please.

A. Sicko and Crvko, in addition to being the founders of the Guards ^{19423 BLANK PAGE 19424} were wounded in 1991 in Tenja, which is Eastern Slavonia. After that, they were not able to go to the front any more so that their duties linked to the SDG, the Serbian Volunteer Guard, was at the headquarters in Ljutice Bogdana street, number 1. And I would meet them on a daily basis. I would come in to them. And Sicko was in charge of analysis.

Q. Did they speak to you of their experiences with the Tigers on operational duty; and if so, where did they tell you that they had been engaged?

A. They spoke about all the operations in Eastern Slavonia in 1991. They did not speak about how the operations evolved themselves, but they said where they were, such as Tenja, Borovo Selo, Mirkovci, the Tenski Antunovac, and all the smaller places in Eastern Slavonia, with the exception of Vukovar. They would always say that the Guard was never in Vukovar.

Q. Did they tell you anything about activities in Bosnia or the Krajina?

A. Yes, they did. They spoke about that too, about Bosnia, but they spoke about Bosnia and Krajina as did Arkan and some of the other members who happened to be at the headquarters of the SDG. They would also talk about Bijeljina, Zvornik, Brcko. That was in the course of 1992. And Krajina in January and February of 1993.

Q. What detail did they provide you of what they'd done?

A. As far as Bijeljina is concerned, Arkan himself said he had gone at the invitation of Biljana Plavsic to assist the Serb people in Republika Srpska and that their assignment was to disarm the Muslims, ¹⁹⁴²⁵ especially in the village of Janja, which is near Bijeljina, next to Bijeljina.

Q. This is dealt with at paragraph 62, but I take it now for speed. When he told you that, did he say who was in charge of the Bijeljina operation?

A. You mean Arkan?

Q. Yes.

A. He didn't say who was in charge, but he did say that he defended Bijeljina with Mauzer, that is to say Major Mauzer, who was also at the beginning in the Serbian Democratic -- in the Serbian Volunteer Guard, the SDG, and then he went on to for the Panther unit later on.

Q. Was there somebody called Cobe, I think it's Cobe, first name Slobodan whose last name wasn't known but his code name was Cobe, who was also involved?

A. Yes. In all those operations, he was in them all, and later on he was in Brcko or, rather, Celici which is a place near Brcko where Cobe was wounded. And he talked about these operations because he worked in a bakery, so we bumped into each other every day.

Q. And since you've already told us about involvement in Bijeljina, Zvornik, and Brcko as described by Arkan and others - paragraph 61 - on whose orders, as you were informed, were the Tigers working when they went to these various places?

A. Could you repeat that question, please? I don't think I understood it properly.

Q. My mistake. These early operations in Bijeljina, Zvornik and ¹⁹⁴²⁶ Brcko, who gave the order that they should go and work there?

A. Arkan would always say that without orders from the DB, the state security, the Tigers were not deployed anywhere.

MR. NICE: Your Honour, I'm told that the intercepts are now available to us. Can we go back, then, to paragraph 13. There are a couple of intercepts to play, and although sometimes we deal with it by transcripts alone, I think the total of somewhere up to about nine minutes may be worth having in full on this occasion. If we decide that it's not or it seems to be unduly wearisome, we can proceed by way of the transcript.

The first intercept is to be found transcribed at your tab 5, and I'd ask the witness to have before her a transcript in whichever language she finds most convenient, but probably the B/C/S, and we'll follow it in the English.

[Intercept played] [Voiceover] B: Good morning. Good morning, Biljana Plavsic speaking. Is Zeljko there, please?

X: He's not here, Mr. Rus is here. Will he do?

B: Yes. Put him through, please.

R: Hello.

B: Good morning.

R: Good morning. My great respect, ma'am. Rus speaking.

B: How are you?

R: The commander's bat man.

B: I know, I know. ¹⁹⁴²⁷

R: I'm just getting ready to attend the raising of the flag.

B: Oh, the raising of the flag. I won't keep you long.

R: No, no, not at all. Please, what can I do for you?

B: I just wanted to ask, Zeljko is not around, is he?

R: Well, you know what? I would be very much obliged if you could tell me when you'd like to call again so that I would know to call him.

B: You know why I am --

R: He was away --

B: Never mind, then. I'll tell you what it's about. I returned to my base where I come from. But I still haven't reached my house because a small section is blocked. But I wanted just to ask him in principle, if there was a call to come here, would that be possible?

R: Listen, ma'am, I don't have enough authority to speak on his behalf.

B: I know, of course.

R: But I'll make sure that he gets your message immediately.

B: Yes. Pass it on. And when I get to my flat, I'll --

R: Call him?

B: Yes. But then I won't ask him this. I will only ask will you bring those goods, if possible.

R: Of course, of course.

B: Is that right?

R: Of course. Listen, ma'am, if it's possible for you to call in about two hours. It's 8.00 now. If you could call in about two hours, ¹⁹⁴²⁸ I'll tell him.

B: All right.

R: In about an hour.

B: All right, all right.

R: I hope it's not too much to ask.

B: All right.

R: I am really sorry that the situation is as it is. He's really -- you know, he always attends the raising of the flag but he went to bed very late.

B: All right. Tell me, what's it like in Zvornik? Can you tell me that?

R: Excuse me?

B: What's it like in Zvornik? Has Pejo gone there?

R: Well, I don't know. He should go there as well. The situation, the whole situation, since there are all kinds of rumours. He must be here, the poor fellow. He really doesn't have time for everything and for himself. I'll convey to him all that.

B: All right. If I call from another phone, then I'll just ask whether he can deliver those things to me so we know in principle if he can. And then we should discuss it.

R: Fine.

B: All right. Say hello to him, and thank you.

R: Thank you. And it was a honour talking to you. Thank you very much.

MR. NICE: ¹⁹⁴²⁹

Q. Witness B-129, are you able to recognise the voice of the man speaking?

A. It is Rus.

Q. Full name was Vladimir Homa?

A. Vladimir Homa, Rus. He was a major by rank. He was killed in 1993 at Celici near Brcko. He was very close to the commander.

Q. To whom Mrs. Plavsic was clearly seeking to speak. The reference to raising of the flag twice and the fact that Arkan would attend the raising of the flag identifies Rus as being where?

A. In Erdut. In Erdut, every morning the flag was raised, and in the evening it was lowered.

Q. But elsewhere was it possible -- at other locations of the Tigers, was it possible to raise a flag or was it only at Erdut?

A. Only in Erdut.

Q. We can see the nature of the inquiries that Mrs. Plavsic was making. Are you able to assist one way or another with the goods that she's referring to when she says, "I'll ask that you bring those goods"?

A. I don't know anything about that.

Q. The reference on the second page to Pejo, who is that?

A. The reference is to Marko Pejic, also known as Pejo. He was a general by rank in the Serbian Volunteer Guard, and he participated in operations in Bijeljina, Zvornik, and Brcko.

Q. And finally, I think, on this, I asked you whether you recognised the voice, but I must just check. Do you recognise the voice or is it simply that you know the man Rus and from the context of the transcript ¹⁹⁴³⁰ can say who is speaking?

A. From the transcript, I can conclude that it is the -- Rus speaking, because I did not have occasion to meet Rus. But Arkan frequently spoke about him.

MR. NICE: Your Honour, I'm reminded by Ms. Wee that it's possible for you to follow the transcripts on the screen under the system, if you wish to.

JUDGE MAY: Yes. That intercept, of course, is subject to a ruling on admissibility.

MR. NICE: Your Honour, yes.

Q. There then comes tab 6, which is two transcripts. Transcripts of two intercepts. If we can play the first one.

[Intercept played] [Voiceover] L: Captain Legija speaking. I'm calling from Sarajevo.

X: Well, where have you been?

L: Is 99 there?

X: 99 is sleeping, having a little rest.

L: When will he get up?

X: I don't know. Give me your number. You should be returning.

L: Yes.

X: I know that, too. Ljubinko called to see how you could return. Basically, you have to return somehow.

L: I know. That's why I'm calling.

X: I'm glad.

L: We feel like crying over here. Tell 99 that I will call in ¹⁹⁴³¹ two hours.

X: That you will call in two hours? So around quarter to 8.00? Phone about 1900 or a quarter past. I think he has something to attend to at 1930 hours.

L: All right.

X: Are you all okay?

L: Yes, apart from two men.

X: Are they in Pale?

L: Yes.

X: Say hello to Bojovic.

L: Bye.

MR. NICE: If we can just pause there.

Q. Are you able to recognise either or both of those voices?

A. Yes.

Q. Namely?

A. Captain Legija is Milorad Lukovic or Ulemek, because in 1992 he had the rank of captain and I recognise his voice. "99" is the wartime code for Zeljko Raznjatovic, Arkan. And the female voice is of that Snezana Kalinic who was the personal secretary of Zeljko Raznjatovic, Arkan. And she left the headquarters in March 1994. Ljubinko, the man that is mentioned as Ljubinko, is Ljubinko Jevtic, a general by rank in the Serbian Volunteer Guard.

Q. So that on this intercept we have Captain Legija from Sarajevo seeking to contact Arkan, known as 99, through his secretary, with the conversation we see. ¹⁹⁴³²

A. Yes.

Q. The second conversation, please.

[Intercept played] [Voiceover] L: Hello, Commander. Hello, Commander.

A: Fire away, Legija.

L: I just wanted to ask you about the matter that Bojke called you about this morning.

A: Well, we can't find the stinkers anywhere.

L: All right, but since he told me to call you.

A: Yes. Tell me that we haven't yet found the stinkers for that.

L: All right. I'll try something from here.

A: It would be good if they could do something from there. But what was it?

L: Did Bojke explain things this morning?

A: Yes.

L: That's how it is. We cannot stand still. There's nothing we can do. This place is full of war profiteers. It's as if someone went to Belgrade now and went to Badza and told him you are this and you are that. That's how it is here.

A: Yes, yes.

L: They look at us now as if we had fallen from the sky. A certain Mladic has now appeared. I quarreled with him up there today.

A: What happened with Mladic?

L: We stopped 7.200 refugees. We stopped them. I suggested ¹⁹⁴³³ that Mladic exchange them for the barracks over there. They said all right, all right. He called Panic and Panic said that they should be released but that we were a humane people, et cetera. When they said that, Mladic said that I should see about it with my men.

A: What did he say?

L: That I should see with my men. I told him I have done my job and the fact that you are playing at diplomacy with them over the phone and they have screwed you again, that's not my job, and I left. Later, he called me again, saying we should have a civilised discussion and should not quarrel. I then explained everything to him. But then again, these people here, this command up here, they are not registering us. They refuse to accept who we are and what we are. I don't want to quarrel any longer. They will soon arrest me.

A: Well, if that is how it is, what are you doing there? They really are stinkers.

L: I made thousands of suggestions and tried thousands of other ways to include these people here, but it was no use. We haven't been in action for two days now because I do not want to go into action and lose one man every day for no reason, and we're still at a standstill. It's terribly stupid. I don't know. This Karadzic guy is up there too. They all embrace those Muslims. They are negotiating with them. I captured 7.200 people for them. I said Fikret Abdic too that they are Serbs from these -- they cut the throats of about 200 Serbs. Tell them that these are the Serbs who survived and that they stopped them, that because of that slaughter, they are looking for -- that they stopped that convoy and ¹⁹⁴³⁴ are asking for the release of all the soldiers from the barracks. They negotiated, and these people screwed them again.

A: Another betrayal, then.

L: They should have released these soldiers at 8.00 this morning, but when the convoy left the barracks, Juka's men -- there's someone called Juka, some guy who is the leader of the Green Berets. He started shooting at them and they turned back. All of our men were afraid and decided to let them go.

A: Damn them.

L: I was barely able to persuade Mladic to retain the convoy because for as long as the convoy is in your hands, their side will not attack. He then started blathering again. I haven't got the patience to quarrel with them here. They all quarrel about who will be in command, and no one wants a discussion on how to attack and launch an offensive to finally bring about the fall of Sarajevo. I have spoken to Sulc and Bajke, and I think the best solution is to return there.

A: That would be best. See if you can take a helicopter from there.

L: I'll try with this main colonel.

A: See what you can do.

L: All right, bye.

A: Bye.

JUDGE MAY: When you've dealt with this tape, this intercept, we'll take a break, the tape's got to be changed.

MR. NICE: ^{19435 BLANK PAGE 19436}

Q. Can you recognise their voices?

THE REGISTRAR: Your Honour, we need to break right now, I apologise.

JUDGE MAY: All right. We will adjourn now. Twenty minutes.

--- Recess taken at 11.48 a.m.

--- On resuming at 12.08 p.m.

MR. NICE:

Q. Witness B-129, reviewing what is the second part of tab 6 of Exhibit 432, a transcript of the video we most -- of the intercept we most recently heard, are you able to recognise both voices?

A. Yes.

Q. Namely?

A. They are Legija, Milorad Lukovic or Milorad Ulemek. And the second voice was the commander of the Serbian Volunteer Guards, Zeljko Raznjatovic, Arkan.

Q. At an early part of the transcript we see two references to the "stinkers." Was that a term that may have other meanings but was used by them in conversation to mean something in particular?

A. When the commander used that expression, he had in mind the members of the DB, state security, or members of the police.

Q. We see it used later in a context which may make it hard. This is on the second page for the Court. After a long answer by Legija where there's an answer which goes: "Well, if that's how it is -- if that's how it is, what are you doing there? They really are stinkers." Can this same word mean something else, or in their context would ¹⁹⁴³⁷ -- or in their use would it always mean the DB?

A. In principle, it meant that it referred to members of the DB. But in this context, it can also mean something else. So the expression itself wasn't always used to refer to the DB members.

Q. No. It's simply -- it can be simply a bad word, a term of abuse?

A. Yes.

Q. If we look at the beginning of the transcript, the very first substantive observation by Legija, he speaks about somebody called Bojke. Who was he?

A. Bojke was in fact an officer, and his surname was Bojovic. I myself never met him, but Snezana Kalinic, the secretary, told me that he was an officer of the Serbian Volunteer Guard during the operations in Bosnia and Herzegovina.

Q. Finally, on particular matters of the transcript, at the end of the transcript, the second page, six lines up from the bottom there's a reference to Legija having spoken to Sulc and Bajke, and our interpreters in the English booth did read out the word "Sulc." Do you have a view as to whether it should be Sulc or whether it should be someone else or can't you assist?

A. As I understood it, as I understood Legija in that particular conversation, what it should be is Suca. Suca and Bojke.

Q. And when you say it should be that, is that from the context you say it should be that or from what you were able to hear of the intercept itself?

A. Based on what I heard in the conversation. ¹⁹⁴³⁸

Q. Then finally because we've the content in mind, I think the position is you're not able to give any particular overall context for this intercept; is that right? You can't interpret it for us beyond what it says itself?

A. No, I can't.

Q. Your knowledge of the Tigers' involvement in and around Sarajevo being what?

A. It referred just to the Treskavica operation, Treskavica 95.

Q. Very well. Perhaps it's convenient to pick up tab 7 straight away as we've had the first use of a number for Arkan, number 99. Do you produce as our tab 7 a chart which contains, in a slightly redacted form, a number of the call-signs that were in use by the Tigers or the SDG in the time that you were working for them?

A. Yes. I compiled this list myself.

Q. And we can see the sign 66 for Mihajlo Ulemek, 99 for Arkan, Tiger-1 for Legija, and so on. Very well.

THE INTERPRETER: Mr. Nice, could you please come closer to the microphone.

MR. NICE: Certainly. Sorry.

Q. I come to a number of particular topics. Special Tigers. Tell us about them in a sentence or so, please.

A. The Special Tigers or Super Tigers were formed in 1993, while the first camp in Erdut was in existence. And their commander was Milorad Lukovic, Legija. And that particular unit was supposed to be a sort of special unit within the frameworks of the Serbian Democratic Guard -- I'm ¹⁹⁴³⁹ sorry, Serbian Volunteer Guard. And some of their members provided security. When I say provided security, what I mean is they worked as bodyguards for certain individuals.

Q. When the Tigers were on operation, was a military police unit created? If so, to what purpose and effect?

A. Always when the guard was in the field, on the ground, within the frameworks of the SDG a unit was set up of the military police, which was assigned to members of the SDG. It was made up of their members. And the purpose for forming that particular unit was to prevent the SDG members from looting and from mistreating the civilian population, from getting drunk and so on. So to act in any way contrary to the code of conduct of the SDG.

Q. And were those military units ad hoc being disbanded when the action was terminated?

A. Yes. The military police would be disbanded after every SDG operation came to an end.

Q. Arkan's attitude to prisoners, please. Can you tell us about that?

A. Arkan would always say, during the time that I was in the Serbian Volunteer Guard, that they did not have prisoners. But in the course of 1991 and 1992, for example, there was a man who was put in charge of exchanging prisoners of war, and his name was Vojkan Djurkovic. We referred to him as Voja Bijeljina because he was from Bijeljina. I know about that because that man was later on engaged in the work of the party of democratic unity, Serbian Democratic Unity. ¹⁹⁴⁴⁰

Q. What was your understanding of Arkan's phrase that he did not or they did not have prisoners?

A. I and all the rest understood this as meaning that those prisoners of war were in fact killed.

Q. Paragraph 24. Membership of the SDG and its numbers. We're going to hear about the opening of the second Erdut camp in 1995, and about that time, how many, roughly, Tigers were there?

A. What period of time are you referring to? Could you be more specific, please?

Q. May 1995.

A. In May 1995, there were about 100 Tigers, but all of them at that particular period were in Velika Kladusa, engaged in a secret operation which was put into effect together with the DB of the Republic of Serbia under the leadership of Radojica Bozovic, nicknamed Raja.

Q. We'll come to that later. I'm just concerned about numbers. You've told us about how many, roughly, took the oath at the beginning. Did the numbers of Tigers rise and fall over time or did they just go up or what?

A. It went up.

Q. And the total number of people by 1995 was approximately how many do you say, how many Tigers?

A. If we're thinking about the period during the summer of 1995 after the operation, after the Storm operation in Krajina at the end of August, if we don't count those who were forcibly mobilised, the population who was forcibly mobilised, in the guard in Erdut there were about 1.000 ¹⁹⁴⁴¹ members.

Q. On joining, did volunteers have to fill in a form and be interviewed?

A. Yes.

Q. Was there any check done on criminal records?

A. We would conduct an interview with them. And there was a form on which we would note down their basic credentials, and then we would talk to them ourselves and we would try not to recruit people which we would see straight away were drug addicts or had other psychological problems. And as to whether some of them had criminal records with the police, we didn't have the ability to check that out.

Q. Apart from yourself and others, was the man Sicko involved in the selection of new members?

A. Yes.

Q. We've dealt with the numbers, the recruitment. The disbanding of the Tigers, when was that?

A. Do you mean the first time or the second time?

Q. The second time. No, sorry. Well, in March or April of 1996 were they disbanded?

A. Yes. That was the end of the Serbian Volunteer Guard. March or April 1996 was the date when they left the camp in Erdut.

Q. And at that stage, did at least two of their members join another unit in the Serbian DB?

A. Yes, that's right. Milorad Lukovic, Legija, and Nenad Bujosevic, nicknamed Big Rambo. ¹⁹⁴⁴²

Q. The unit they joined was called what?

A. That unit was called the Red Berets of the state security of the Republic of Serbia.

Q. The JSO?

A. Yes.

Q. We've dealt with call-signs. Paragraph 28 just, though, to complete it. You've produced the chart that you have of call-signs. Were those call-signs or some of them at any event subject to change during operations, for security reasons.

A. These signs, the ones which I have before me, did not change. The only thing is -- the only signs that were changed were the signs which they used in the field, amongst themselves. So they used it for radio communication.

Q. And when they were operational, did the Tigers carry lists of codes with them for communication by radio?

A. Yes. And that was part of their equipment. Every one of them, on their left hand above the elbow, would have a piece of plastic attached to their arms, and they have a partition where the code is introduced and extracted. So whenever they would go into an operation of any kind, the officer leading them would assign them new codes.

Q. When they went on operations, what did the Tigers have to do with their own personal, genuine identification documents?

A. The ID cards would be left either at the headquarters in Belgrade, they would leave them behind, and afterwards -- and they could do this in Erdut, too, at the Erdut headquarters once the Erdut centre was opened up ¹⁹⁴⁴³ again. We would then take those ID cards of theirs and their personal belongings, pack them all up, place them in envelopes with their names written up on them and we'd store them in a cupboard, and they would be given separate membership cards of the Serb Volunteer Guard with just their names on them and their photograph and blood type.

Q. What uniforms did the Tigers have?

A. The Tigers had two types of uniform; one was green camouflage, the type of uniform was the NATO type of uniform. And other type of uniform was a black one, and that one was used for night operations.

Q. What headgear did they use with either of these uniforms?

A. When we talk about the green uniforms, the officers wore the red beret, whereas the rank and file, the ordinary soldiers, would wear green caps. But both of them had the insignia the SDG, the Serbian Volunteer Guard, on them. However, when they used the black uniforms, they would have the Balaclava hats -- socks on their heads, known as Fantomka, the phantom mask.

Q. The unit's shoulder patch, did that have a picture of a tiger on it?

THE INTERPRETER: Mr. Nice, could you please repeat it into the microphone.

MR. NICE: Yes.

Q. Did the shoulder patch have a picture of a Tiger on it?

A. Yes.

Q. When they were on operations in Treskavica and Velika Kladusa, what if any patches did they have? ¹⁹⁴⁴⁴

A. I know for sure that in Treskavica and Velika Kladusa they didn't have the insignia of the SDG, the Serbian Volunteer Guard, because they were told prior to leaving that they weren't allowed to use those. That means that in Velika Kladusa, what they had was insignia used by the army of Fikret Abdic.

Q. You've told us a little about discipline. What sanctions for breach of the code were imposed? For example, if a Tiger was caught drinking?

A. The punishment for drinking was the most rigorous. It was 100 lashes on the backside. But everyone in the Erdut camp would watch this, even those who just happened to be there, happened to be visiting. And even I myself witnessed this on two occasions.

Q. Arkan's expressed views on the unfolding of events there, what were his views about Republika Srpska and the RSK and so on?

A. Arkan was in favour of defending the Serbs in the RS and the RSK, but he was also in favour of keeping those territories that had been captured at that time. And I'm talking about the period I was there in 1994 and 1995, and not to go on to win over new territories.

Q. Are you aware of the things he said in October 1993 at the foundation of his party?

A. Do you mean about the Republika Srpska and Republika Srpska Krajina or do you mean --

Q. Yes, I do.

A. He was not satisfied with the policy being waged at the time in the Federal Republic of Yugoslavia and in the Republic of Serbia, because ¹⁹⁴⁴⁵ he considered that all Serbs should unite but that that unification did not mean trouble for the other peoples living on the territory of the former Yugoslavia.

Q. Before the war, for whom had Arkan worked?

A. Before the war, he worked for the DB, the state security of the then Yugoslavia, although -- actually, the SFRY.

Q. Did you hear this from him or from someone else?

A. From him -- I never heard this from him personally, but I heard it from a person whose nickname was Kale. And she worked in an agency for the security of Delije. Kale would often speak about that, that the two of them worked together. And this could be deduced from the respect that the late commander had towards Kale.

THE INTERPRETER: Interpreter's correction: Not "she," "he."

MR. NICE:

Q. The Serbian DB: To what extent were the Tigers dependant on support, permission or authority of the Serbian DB for what they did? What did Arkan say about this?

A. The state security, the DB, whenever it didn't have enough men for the front, it would take some of the members of the Serbian Volunteer Guard. Or if they didn't have enough men to take up a certain position, then they would engage members of the Serbian Volunteer Guard. The most important thing in this respect is that the Guard could do nothing on its own, nothing without permission from the DB of Serbia. And as far as the frontline goes, they did as best they could there.

Q. So that, for example, when they were on operations in Eastern ¹⁹⁴⁴⁶ Slavonia in 1991, or in Bosnia in the following year, as what or in what capacity did the Tigers go on operation?

A. They were in the capacity of the reserve force of the MUP of Serbia or, rather, the DB of Serbia, state security.

Q. Contacts between Frenki and Arkan, did they happen?

A. Yes.

Q. With what sort of frequency, to your knowledge?

A. When operations were under way, that is to say when the Guard was in Velika Kladusa and Treskavica during the Banja Luka operation, those contacts or telephone conversations were at least twice a week, twice weekly.

Q. What methods of calling Frenki were available to you?

A. There were two telephone numbers. One telephone number was linked to his office, that is to say was to his secretary, Sladjana. And the other number was a duty number of the state security of the Republic of Serbia. At the beginning, we would just have to give the code, and that was Pauk, meaning "spider." And this related to the Pauk operation in Velika Kladusa.

However, several months later, a couple of months later, it would be enough for us to say where we were calling from and then we would be linked to his office.

Q. Tab 8 of Exhibit 432 on the screen or available in hard copy. Does this show the two telephone numbers you've been speaking of, and does it come from your diary?

A. Yes, that's right. The first number, telephone number, is the ^{19447 BLANK PAGE 19448} duty officer, and the second telephone number is Frenki's office.

Q. Border crossings next. When it was necessary to organise crossing of equipment, vehicles, people into Republika Srpska, what was done? What did you do?

A. When something needed to cross via Raca, this would usually happen at night, because at that border crossing, usually there was UN control. I just needed to announce the vehicle, that is the licence plates, the number of the licence plates, and nothing more than that. They were not interested in what was inside or who was inside. It was sufficient for me to tell them the licence plate numbers or, that is, the word of the Serbian Volunteer Guard was sufficient.

Q. Frenki's secretary Sladjana, as you've told us, how often did you speak to her?

A. During an operation, two or three times a week.

Q. What, if anything, did she tell you about the chains of command that affected Frenki; to whom he responded, and so on?

A. She always said that Frenki was in charge of the unit for special operations and that he could decide about certain things but that, without the approval of Jovica Stanisic, he could not take any decision.

Q. So that for example, Velika Kladusa, if you were informed or if you were told things from which you had an understanding, where did the authority for that come?

A. Are you referring to the organisation of the Tigers for Velika Kladusa?

Q. Yes. ¹⁹⁴⁴⁹

A. In November 1994, Arkan told me that I should call up men on a certain list. At that point in time, I didn't know why. After calling these men up, Arkan told me that Frenki had been asking for men to reinforce his units in Velika Kladusa. So that on the 4th of November --

Q. Pausing there --

A. -- the first group left.

Q. Pausing there. Perhaps my error, but we'll come back to it. The operation itself, the overall operation, would that be something, as you understood it, within the authority of Frenki or would that have required the approval or instruction of Stanisic, or don't you know?

A. I cannot say with certainty, but Frenki was also on the ground in Velika Kladusa so that Jovica Stanisic should have known about it.

Q. Before we turn from the topic of your conversation with Sladjana, Frenki's secretary, did she say anything about the accused Milosevic in this trial and his relationship to either Stanisic or Frenki?

A. No.

Q. What meetings, if any, did -- or did you become aware of between Arkan and Frenki, and who went to see whom?

A. I knew about the meetings during the Velika Kladusa operation, though they were less frequent then. But more frequent meetings were held during the Banja Luka operation, because they were afraid that Banja Luka would fall into the hands of the enemy. So that Arkan frequently went to see Frenki during that period of time.

Arkan always went to see Frenki. I saw Frenki only once, and that was very early in the morning in front of our headquarters at the parking ¹⁹⁴⁵⁰ space.

Q. You've mentioned already - paragraph 46 - that when operational, the Tigers were -- went as reserve members of the Serbian DB. Did they actually get DB identification cards or not?

A. No. They kept their own over there. I mean, those of the Serbian Volunteer Guard.

Q. What happened when Tigers were wounded so far as cards, medical cards, and their reserve membership of the DB is concerned?

A. If someone was seriously wounded, he would be admitted at the VMA, that is the medical academy hospital, or a civilian hospital and there would be no problems. But there would be problems for subsequent treatment. In that case, I would call up Sladjana, and I would send her the medical card, the health card of the wounded combatant which she would stamp with the stamp of the reserve force of the MUP of Serbia, which means that they would cover the expenses of his medical insurance.

Q. The camp at Erdut was reopened in 1995. What vehicle licence plates was Arkan able to use at that stage?

A. The state security gave him licence plates which are identical with those used by the MUP of Serbia.

Q. And was he able to put them on and off vehicles as necessary or as useful?

A. Yes.

Q. Were those plates used for the transport of weapons, and if so, did it have the effect of avoiding interference by the police?

A. Yes. But when talking about weapons, I am referring only to ¹⁹⁴⁵¹ pistols, because the only things that went from Belgrade to Erdut during operations were pistols or uniforms, because other weapons were given to them in Erdut.

Q. Were Vukovar and Belgrade licence plates also available at that time?

A. Yes, because our vehicles had the mark of the Serbian Volunteer Guard and the tiger on the front part of the vehicle so that the regular police - and I am thinking of the regular police force - did not dare to stop those vehicles.

Q. With the reopening of the Erdut training centre, what was the telephone connection between the Belgrade headquarters and Erdut?

A. Between the headquarters in Belgrade and Erdut, there were a couple of telephone lines. A couple of them had the code number had to be dialed, but there was one line that had the same number as the Belgrade telephone numbers so that we didn't have to dial the area code for Erdut. Plus we had a radio station, a radio transmitter whereby we were directly linked to Erdut.

Q. And whose approval was required or what body's approval was required for this radio station?

A. According to our rules and laws, by the MUP of Serbia.

Q. Moving on to 1996, were you contacted, along with others, by Frenki's secretary at the time when the Tigers had now been disbanded?

A. Yes.

Q. Were you interviewed and were you subject to questions about your political beliefs, including about the accused in this case? ¹⁹⁴⁵²

A. Yes.

Q. The views you expressed as to this accused, were they positive or negative?

A. They were negative from their point of view.

Q. What happened so far as the interview or job interview was concerned and the consequence of that?

A. I did not get the job because I didn't share the political opinions of the authorities in power at the time in the Republic of Serbia. But I believed then too that the state security was an institution protecting all the citizens of Serbia and not just the members of one party.

Q. The first name of the man who interviewed you was?

A. Milanko.

Q. Others who were similarly contacted for possible recruitment by Frenki's secretary included?

A. There was Milorad Lukovic, Legija, and Nenad Bujosevic, the Big Rambo.

JUDGE ROBINSON: Can I ask the witness what is the basis of her conclusion that the reason for her not getting the job was her political views?

THE WITNESS: [Interpretation] Because when you filled in this form, you would have to wait for the contents to be checked out. After that, you would be called again to the building in Kneza Milosa street, and there I was told that I was not suitable because I had participated in the demonstrations of 1991, 1992. ¹⁹⁴⁵³

JUDGE ROBINSON: Thank you.

MR. NICE:

Q. Page 10, paragraph 52, money and support for the SDG. Did the SDG initially or at some stages have sponsors who provided money and supplies?

A. There were people who would provide money on a voluntary basis, and also goods. When I say "goods," I mean food, clothing, hygienic supplies and other supplies for the Serbian Volunteer Guard.

Q. The largest contributors, to your knowledge, being?

A. The largest sponsors of the Serbian Volunteer Guard were Giovani Di Stefano, also the Karic brothers.

Q. Arkan also had some companies of his own. Did money from those companies go to the SDG company through which sponsors' money was channelled?

A. I would like to ask you if you could formulate that question a little more clearly.

Q. Was there an SDG company, and if so, did donations pass through that company?

A. Yes. Some donations, if they were in the form of funds, would go through the SDG company. Not always all the funds. Some were given personally into the hands of Arkan. And in the event of objects or goods, they would directly arrive at our headquarters of the Serbian Volunteer Guard.

Q. Did Arkan have companies himself; and if so, did those companies contribute money through the SDG company?

A. The SDG company or, rather, in addition to that company, there ¹⁹⁴⁵⁴ were the Delije, the Delijes. It was a security agency and a trading company. And the funds from the cake shop and the bakery would be driven every morning to the Delije company which was situated in Vase Pelagica street, number 54 at Dedinje.

Q. Let's turn to cash. Was cash received for the Tigers; and if so, where did it come from and who brought it?

A. Are you referring to the sponsors or to the state security?

Q. No, no. State security now. Paragraph 54.

A. During the Banja Luka operation, cash arrived at the headquarters from the state security in Belgrade. There were two ways in which this was done: Either one of the officers of the Serbian Volunteer Guard would go to fetch the money to the Kneza Milosa street, or Milanko would bring the cash to our headquarters.

Q. On how many occasions did you see cash brought? What sort of sums of money were involved on each occasion?

A. During the Banja Luka operation, money was delivered about ten times, and there was between 3 and 4 million Deutschmarks, because I and a couple of others counted the money. And we would place it in envelopes and pack these envelopes for the soldiers in Erdut, whereas the rest of the money would be placed by Arkan in the safe deposit -- safety deposit box in his office. So this was newly printed money that had just come out of the mint.

Q. Did you ever see Arkan himself arriving with cash?

A. Yes. Sometimes he himself would go to fetch the money.

Q. What did he say to you, if anything, about the origin of that ¹⁹⁴⁵⁵ money?

A. He would just tell me that he had brought the money from the DB and that it was up to me to organise the counting of the money and to make sure that all soldiers in Erdut would receive their salaries out of those funds.

Q. Next topic, Exhibit 432, tab 9, on the screen now, an entry from your diary.

In December 1995, at a celebration for -- of St. Nikola, was there a distribution of pistols?

A. Yes. The commander distributed to the officers and men who had in any way assisted the guards, he gave them pistols with an inscription. On the 19th of December 1995, which is St. Nikolas Day, and that is the patron saint of the Serbian Volunteer Guard.

Q. I think you took some part in organising the delivery of the pistols, but after the ceremony was over, did some of the Tigers with their pistols leave via Sid?

A. Yes. Most of them went via Novi Sad. Only three members went via Sid. There they were stopped by a patrol. The three of them, Sicko, Crvko and Kajman, plus the driver, they were taken into custody to the police station. I was called up, I called up the commander, and I'm referring to Zeljko Raznjatovic, Arkan, who said that I should tell the commander of the police station that they were Tigers. After that, the police commander released them but they kept the pistols. And then the next day I was told to call up Rodja, or Puzovic, from the republic SUP and to ask him to intervene for the pistols to be returned, and that is ¹⁹⁴⁵⁶ what happened. A couple of days later, the pistols were returned to the headquarters and they were returned to the owners who had received them on the 19th of December during the Slava or observation of St. Nikolas Day.

Q. Exhibit on the screen, Exhibit 432, tab 10. This shows us what, please, Witness B-129?

A. This is something else. Are you referring to this that says the republic SUP? Oh, okay.

Q. Yes.

A. It is noted here that I need to find Rodja in the republic SUP through the federal. Why is the federal mentioned? Because in a certain period of time, the republic SUP moved into the building of the federal SUP. So it was up to me to find this Rodja in room number 103.

Q. Then if we go to tab 11, please. What does this show us, if anything significant?

A. It shows that Rodja or Puzovic, because I couldn't find them just then, that if I find them, I should connect him to office number 99, which was the code for the commander.

Q. We'll move on now then from these matters to some operational matters. Paragraphs 61 and 62. You've already told us about Bijeljina, Zvornik, Brcko, and Major Mauzer. But can we look at one particular photograph that's been exhibited before. It's Exhibit 411, tab 6. What can you tell us about this, please? This is a photograph from Bijeljina.

A. No. This is Brcko.

Q. Sorry. Very well. Brcko then. What can you tell us about it? ¹⁹⁴⁵⁷

A. On the photograph is Srdjan Golubovic. His nickname was Max. He's a member of the Serbian Volunteer Guard, and he was later involved in the Velika Kladusa operation. After this photograph, the commander was angry with Max that the photograph -- photographer had taken a photo of him trying to turn around a woman who was already dead when he approached her with his rifle to turn her over.

Q. What was Max's response to that?

THE INTERPRETER: Microphone, Mr. Nice.

MR. NICE: Sorry.

THE WITNESS: [Interpretation] As far as I know, there was none.

MR. NICE:

Q. Did he give any explanation for the death of the woman?

A. No. He just said that when he arrived, she had already been -- she had already passed away.

Q. Paragraph 65. Did you see anything of Radovan Stojicic, known as Badza?

A. No.

Q. What, if anything, did you learn of his relationship or the development of his relationship with Arkan?

A. I know that during the operation in Eastern Slavonia during 1991, they were very close. And there is even a photograph of the two of them together in the camp at Erdut. However, during 1993, that is the end of 1993 and the beginning the 1994, Badza, and I'm referring to Stojicic, took over the camp of the Serbian Volunteer Guard in Erdut, and Arkan was furious about it. ¹⁹⁴⁵⁸

Q. What was the -- apart from the fact the camp was taken over, what was his particular concern at what had happened and what was his view on the camp that was being taken over? What was his view of its professionalism or modernity or whatever?

A. I didn't understand your question.

Q. Well, Arkan was unhappy that Badza had taken over the camp. What was Arkan's view of his contribution to the camp and of what sort of camp he had created?

A. The first camp of the Serbian Volunteer Guard was one of the most modern camps in the former Yugoslavia, because it was devised by Arkan as a training facility for the special unit. And there was what was called as a rubber town inside it. People who are well-versed in military matters will know what I'm talking about when I refer to a rubber town as related to a training centre.

Q. Very well. Did Arkan's other interests, including his interests in smuggling, have anything to do with the change in relationship between him and Badza?

A. Yes. And on several occasions in front of us at the headquarters, he said that smuggling most influenced their relationship because, as he said - and I'm meaning Arkan - Badza wants to keep everything to himself and for himself.

Q. In May of 1995, was Arkan informed that help was needed in the Krajina region as a result of Operation Flash, and was it this that led to the reopening of the camp or of a camp at Erdut in any event?

A. Yes. ^{19459 BLANK PAGE 19460}

Q. And this second facility was in slightly a different position, I think. Is that right?

A. Yes, because this second camp was along the riverbank itself.

Q. Once this had been opened, did you have to visit it regularly?

A. I would go there often. And if Arkan was at the front, it was my job to go there every weekend.

Q. And did you take supplies from Belgrade?

A. I would take the supplies too when I went, although there was a kombi van which would go every day from Erdut to Belgrade and vice versa, Belgrade-Erdut.

Q. Very well, let's go back a bit in time now and look at Velika Kladusa more comprehensively. On the 4th of November, 1994, did Arkan inform you of something, or did Arkan inform the Tigers generally of something?

A. Yes. He informed me that I was to call up people from a list. And I did call them up and told them to come to headquarters. They all came, they all responded, and nobody asked why. After that, the commander told me that Frenki had told him that he needed men to resupply his unit. In the space of two days, we rallied up about 40 men. At the time, I myself did not know where they were going. On the 4th of November, 1994, that first group of men left. Their leader, that is to say the commander of that unit, was Legija, and in the unit was Suca and Big Rambo and others.

According to their stories, they first went to a camp of the MUP of Serbia or DB of Serbia, which was located on Mount Tara, Bajina Basta. ¹⁹⁴⁶¹ And after spending seven days there, they were transferred to Velika Kladusa itself.

In that period of time, I myself learnt where they were, but otherwise it was a secret operation.

MR. NICE: The Court can see the location of Velika Kladusa on tab 20 on the far western side -- left-hand side of the map.

Q. Reflecting the secrecy, how were the men who went dressed? What happened to -- how were they dressed first?

A. You mean at the front.

Q. Yes. Well, first of all on their way there.

A. First of all, they were dressed in their civilian clothing. When they arrived, when the bus arrived, the MUP of Serbia bus to pick them up from in front of our headquarters, and Arkan himself told them, actually, that they could use and would use uniforms, the uniforms of the Serbian Volunteer Guard, but that they were not allowed to place any insignia with the Tigers on their arms. No arm patches with the tiger insignia.

Q. Was Arkan able to go himself? If not, who led the operation in Velika Kladusa?

A. Arkan was not able to go there himself because most of the people knew what Arkan looked like. So the Tigers were led by Legija, and the members of the DB were led by Radojica Bozovic, nicknamed Raja.

Q. That was the first deployment. Was there a second group of Tigers that went off? Paragraph 77. And I'll come back to look at the exhibits in a second.

A. Yes, that's right. The second group left on the 18th of November, ¹⁹⁴⁶² 1994. It was a smaller group. There were a little under 20 men in it. And their leader, their commander, was Colonel Mihajlo Ulemek.

Q. You've told us about the departure from Mount Tara, but I'm not sure if you've told us -- you have. You told us it was a Serb DB bus.

A. Yes.

Q. Let's look at a couple of exhibits before me move on. Exhibit 432, tab --

JUDGE KWON: Mr. Nice, if you could help me. Could you remind me of the relationship between Milorad Ulemek and Mihajlo Ulemek.

MR. NICE: I think I'll ask the witness to do that.

JUDGE KWON: If the witness can help us.

MR. NICE: Yes.

THE WITNESS: [Interpretation] Mihajlo Ulemek and Milorad Ulemek are two different people. Mihajlo Ulemek was a man of about 60 years of age, and from the very beginning, that is to say from 1991, he was in the Serb Volunteer Guard, whereas Milorad Ulemek is the Milorad Lukovic or Legija man, and he joined the SDB later. Is that enough?

JUDGE KWON: Thank you.

MR. NICE: Your Honour, I'm obliged to Ms. Pack for reminding me that we can find this in your chart, I hope. Tab 4. You can see them both there, on the second to last page.

Q. If we now look at tab 12. If the witness can have the -- or we can see the Cyrillic version on the screen. And if the English version can be available perhaps on the overhead projector, and we can switch to that for those who will be following in English. ¹⁹⁴⁶³ This document, dated the 26th of February, 1995, later than the period you've been dealing with so far, is this a document that you had not seen before you came here to prepare to give evidence?

A. No, I had not seen it. I see it now for the first time. However, Legija, and I mean Milorad Lukovic, with the Serb Volunteer Guard, was in Velika Kladusa. With part of it, anyway. And he was there right up until August 1995, which means up to the Storm operation. They were there all the time. Some people would go on leave for a time and return, but Legija and most of the unit was there permanently in Velika Kladusa.

Q. Now, this document from him, headed "Regulating Subordination in the Army of Western Bosnia," can you help us with its or its interpretation? It deals with forming and organising the ZB army, "A system of command and control was established to which the Pauk Command was our superior command."

Are you in a position to explain that in a little more detail for the Judges?

A. Yes, of course. The Pauk operation in the SDG meant a clandestine operation waged in Velika Kladusa. And that was also, when I called up to begin with, the DB, when I would say the word "Pauk," they would transfer me to Sladjana's or, rather, Frenki's office. So Pauk was the code name of the operation which included the state security and the SDG. In the lower bottom corner, we have Colonel Legija's signature. At the time, he was a colonel, but after the Velika Kladusa operation, which means in August, when he returned, he was accorded the rank of general, general.

Q. And although you probably made this clear, the purpose of this ¹⁹⁴⁶⁴ operation was what so far as Fikret Abdic's men were concerned?

A. The operation consisted of the following: The DB and the SDG trained his men, although in the final instance it didn't boil down to that. Actually, they had two killed fighters. So they also took part in the operations as well.

Q. We move on to tab 13, with His Honour Judge Kwon's question just in mind. We now see a document a little earlier in time, the 18th of December, 1994, the content of which may not be particularly significant or weighty, but it's signed by Mihajlo Ulemek. It comes from combat group 2, and it authorises somebody called Sead Cufurovic to drive his Zastava 648 vehicle with provisions, on a stretch of road between Ponikve and Topusko. The significance for you of this document which you hadn't seen before coming here, in light of what you've been able to tell us about an operation known as Pauk.

A. I did not see this document. I've never seen it, I am looking at it now for the first time. Topusko was a place where the Guard and all its members would go out for supplies - for example, if they needed any kind of supplies or food - and this was signed by Mihajlo Ulemek, as we see, because he was the only man who could give permission as the boss, as the head of the military police, for anybody to move around in that part of the territory.

And another thing that links this document with the SDG is the last sentence, in which he says that he will be escorted by Cica, Cica Pera. Not Petar Cica but Cica Pera. And Cica Pera was a member of the SDG who, with another group, went to Velika Kladusa. So he went with ¹⁹⁴⁶⁵ Mihajlo Ulemek in this second group. They went to Velika Kladusa together.

Q. Thank you. Paragraph 80. Were the Tigers involved with another group in Kladusa led by Raja Bozovic?

A. Yes. They acted together over there.

Q. And that's a Serbian DB group. Did they wear red berets, or were they known as Red Berets?

A. They were known as the Red Berets. Now, whether they actually wore red berets in Velika Kladusa, I can't really say, I can't answer that question. Although I do know that the Tigers, during the Velika Kladusa operation, wore caps which looked like the ranger type of cap. So they weren't the standard type, usual type of cap worn by the army, by soldiers.

Q. In addition to those, that group by Bozovic, was there a group from Banja Luka; and if so, by whom was that led?

A. Yes, there was a group led by Ljuban Ecim. It was a group from Banja Luka.

Q. In the field, who had superiority as between Legija and Bozovic?

A. Bozovic.

Q. And how do you attribute him to the DB? How do you know he was of the DB?

A. During the operation, the Velika Kladusa operation, when Radojica Bozovic would come to Belgrade, he would come to us at headquarters too. And he said he had come to greet us and to convey to the commanders that his fighters were okay and ask whether they needed anything or we needed ¹⁹⁴⁶⁶ anything.

Q. You've told us of Arkan's difficulties in going to Velika Kladusa. What about Frenki? Did he go there?

A. Yes, Frenki did go to Velika Kladusa. I know that from what the members of the SDG said. And I also know it because Sladjana told me.

Q. When Tigers returned from Velika Kladusa in the course of this operation, can you tell us what they had to do about their personal documentation, how they were contacted when they had to return, and also what was done and through what organisation if they were ever to receive parcels, things like that.

A. Could you be more specific and concrete when asking your question.

Q. I'll break them down into smaller questions. When they came back from the front, what did they do with their personal identifications, their Tiger identifications?

A. I see. When they went on leave, which would usually last about a fortnight, the SDG ID cards, I mean the SDG ID cards, they would drop those off at the headquarters, and in return, they would receive their own personal documents, IDs. And a day or two before leaving again, Sladjana would call me up and tell me to get them ready in the next two days. Usually a bus would arrive at about 7.00 in the morning, and then the procedure would be the same; they would leave their IDs and take up the SDG ID cards.

Q. And finally, the last part of the three-part question I asked you earlier: If somebody wanted to send something to a Tiger when he was in Velika Kladusa, how was that organised? A parcel, for example. ¹⁹⁴⁶⁷

A. I would call up Sladjana and ask her if possible to either send a message or a letter or a parcel. She never refused. That means that the driver would take it to the building in Kneza Milosa street, and she says the driver would usually come out, she would take over the package or whatever, and she would give it to the driver to take to the person, to transport to the person in the field.

Q. How were those Tigers fighting for Fikret -- fighting to -- or assisting Fikret Abdic? How were they paid?

A. Their monthly salary amounted to 1.500 German marks which at that time was a great deal of money.

Q. Where did the money come from?

A. Where it came from; how do you mean?

Q. How did Fikret Abdic get the money to pay them, if you know?

A. I don't know that. I really can't say.

Q. What did you hear from people at the front about the mechanism whereby the money was handed over?

A. When they would be in the field, Legija would go into the building where Fikret Abdic was, he would take the money, and afterwards he would pay out the money to all the soldiers. If there were wounded soldiers, then the money would go via the DB and reach our headquarters, and later on I would hand the money out to the wounded soldiers, that money that had come from Velika Kladusa. Sometimes I would send a driver or one of the other wounded soldiers, because all the soldiers knew where our offices were, and then one of the wounded soldiers would go and take the money and distribute it amongst themselves. ¹⁹⁴⁶⁸

Q. What Tiger or DB casualties were there in Velika Kladusa? Paragraphs 87 and 88.

A. The Tigers had two casualties; Dimitrije Jasek, Mitar, and Jugoslav Micic, Juka. Whereas on the DB side there was a high-ranking officer who was killed, Kojic, and they later named the Kula camp after him. I'm thinking of the JSO camp in Kula.

A. After our own fighters were killed, and I'm thinking about Dimitrije Jasek and Jugoslav Micic, we weren't allowed to place an obituary saying where they had died, where they had been killed. All we could say was they had died defending Serb lands.

Q. Were prisoners detained in the Kladusa area?

A. Yes.

Q. Who operated the prison?

A. According to the tales told by the wounded soldiers, everybody was in charge of the prison; Fikret's men, the DB men, and members of the Guard, because they were all active there together.

Q. What, according to what you were told, was the treatment of the prisoners like?

A. Most of the prisoners succumbed to their wounds received from beatings several days later.

Q. You've dealt with the ranger hats worn by the Tigers in Velika Kladusa, so I'll turn to another topic.

Mihalj Kertes, what involvement if any did he have with Arkan that you were aware of?

A. Well, it was like this: Mihalj Kertes was always called when ¹⁹⁴⁶⁹ there was a truck coming in from Bulgaria or Macedonia and when it had problems at the border crossing. The truck was either carrying cigarettes or alcoholic beverages. After that, a gentleman, Dejan Lekic from Transped, a state company, transport company, would call me up and tell me to tell Zeljko to call Kertes. Dejan Lekic would always give me the number of the number plates of the truck and the name of the driver driving it. Then I would convey this to the commander, and in the course of the day the truck would be allowed to pass the border crossing. After that, from the border crossing onwards, the truck would be driven straight to Erdut, and it would be like -- actually, it didn't undergo any customs procedure. They would just place a stamp signifying that the goods had entered Eastern Slavonia, and part of the goods would be kept at the duty free shop at the petrol pump in Erdut, whereas most of the goods would be returned to Serbia and sold there, sold to people who would come to our headquarters and who knew that we had the goods, that the goods were available. So those cigarettes and the whisky would come from Erdut in a kombi van, in one of our own kombi vans that would communicate between Erdut and Belgrade.

Q. And this trafficking in tobacco and alcohol was in reality Arkan's business, wasn't it?

A. Yes.

Q. Did he, to your knowledge, use the money from that business to support in part the guards by uniforms or supplies or things like that?

A. Yes. Because all the money was kept at the headquarters. It would be kept in a safe. And whenever the SDG did not -- company did not ¹⁹⁴⁷⁰ have any money to pay for something that it needed to pay, they would take the money out of the safe deposit and pay for the medicines, uniforms, clothing, or whatever.

Q. An associated topic, tab 14. Yes, tab 14. Was there a general known to you called Loncar?

A. Yes. General Dusko Loncar.

JUDGE MAY: I'm sorry to interrupt. Just to help us, is this the Loncar who turns up in Kosovo? Is there a different one?

MR. NICE: Just one moment. First of all, it's a question I want to ask the witness about that and I'll come to that in a second.

Q. What do you know about this general's origins and the force for which he was in service?

A. General Dusan Loncar was commander of the Sremska Baranska Corps in Eastern Slavonia during 1995. He is a man who was at the time about 60 years of age. So I'm talking about the period of 1995. He was in charge of the Yugoslav army in Eastern Slavonia. And the guards were often told to contact him because he supplied us with weapons, oil. When I say "oil," I mean fuel for vehicles. And a part of the money was also received from the Yugoslav People's Army.

MR. NICE: Your Honour, I think the position about this particular officer is that he is the person who features later, and we do have material to connect him with the 40th personnel centre in Belgrade. That will be before you in due course if it's not before you already. Thank you very much.

Q. Now, if we look at tab 14 of Exhibit 432, tell us about that, ^{19471 BLANK PAGE 19472} please, insofar as it requires much explanation.

A. I was called up from Erdut by a colonel called Puki. I can't remember his proper name and surname. He was in charge of the administration in our centre, and he asked me to convey to the commander that General Loncar was stalling with the salaries. What he meant was that General Loncar was not providing the amount of money that the Yugoslav army provided for the soldiers in the Serbian Volunteer Guards who were in Erdut. He was not providing the money in time.

Q. You've dealt with money and in your earlier answer dealing with General Loncar, you dealt with weapons and oil in general terms. Did the weaponry include heavy weaponry and ammunition that he supplied or organised the supply of?

A. What exactly do you mean when you say "heavy weaponry"?

Q. Did he supply all the weaponry that came to Erdut in this period of time?

A. Yes. Rifles, automatic, semi-automatic, grenades, explosives. There were no tanks or anything like that, because they were not needed for operations by the guards.

Q. And this was all, as you understood it, coming from the VJ at that time?

A. Yes.

Q. And Loncar's headquarters was where?

A. Loncar's headquarters, where he acted together with Legija, was in Trpinja. It's a small locality in Eastern Slavonia. And the two of them shared the command headquarters as far as Eastern Slavonia was concerned. ¹⁹⁴⁷³

JUDGE MAY: And of course Puki has appeared in the evidence. I seem to remember his death was one of the matters which was dealt with. I may be wrong about that, but a man called himself Colonel.

MR. NICE: Your Honour is ahead of me there on recollection, but I'll look it up for tomorrow.

JUDGE MAY: I think that's the man.

MR. NICE: Yes. Would it be convenient to move on?

JUDGE MAY: Well, it's now time.

MR. NICE: We've made very good progress, I think. We've got four pages to do --

JUDGE MAY: Yes.

MR. NICE: -- which I'll try and take as swiftly as I can. There are no more exhibits that will take time, I think, of the kind -- of the intercept kind.

JUDGE MAY: Yes. Well, we must complete this witness tomorrow, so if you would go as rapidly as possible with the evidence in chief, that will leave us with two and a bit hours for cross-examination, if it's required to take that long. Any time over, we can deal with administrative matters.

Witness B-129, I should have told you before, or should have warned you: Don't speak to anybody about your evidence until it's over, please, and that does include the members of the Prosecution team. Could you be back tomorrow morning at 9.00 to finish your evidence. We will adjourn until then.

--- Whereupon the hearing adjourned at 1.46 p.m., ¹⁹⁴⁷⁴ to be reconvened on Thursday, the 17th day of April, 2003, at 9.00 a.m.