²⁶⁵⁸⁸

Monday, 15 September 2003

[Open session]

[The accused entered court]

--- Upon commencing at 9.06 a.m.

JUDGE MAY: Yes. We'll have the witness.

MR. GROOME: Your Honour, the Prosecution calls B-179.

JUDGE MAY: While the witness is coming, Mr. Groome, one minor housekeeping matter. We had handed in on Friday directive number 7 concerning Srebrenica. I understand that that will formally be produced in due course. I think it's really rather early to produce it at the moment, so it may be that we'll just simply hand it back.

MR. GROOME: Yes, Your Honour.

JUDGE MAY: Thank you. And we are having problems with the -- this distorted microphone, as you know, with leakage, so we must make sure that witnesses understand that they should not speak early, and perhaps you could try and instil that in them.

MR. GROOME: I will remind the witness, Your Honour.

JUDGE MAY: Yes.

MR. GROOME: Your Honour, while we're waiting, the Prosecution will be tendering a binder of 13 exhibits to be used with this witness. Could I ask that a number be assigned.

JUDGE MAY: Yes. If we could give it a number.

THE REGISTRAR: Prosecution Exhibit 539, Your Honour.

[The witness entered court]

JUDGE MAY: If you would like to take the declaration. ²⁶⁵⁸⁹

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

JUDGE MAY: If you'd like now to take a seat.

THE WITNESS: [Interpretation] Thank you.

WITNESS: WITNESS B-179

[Witness answered through interpreter] Examined by Mr. Groome:

Q. Sir, before I begin my examination of you, I would like to remind you of the following: Part of the protections extended to you by the Chamber are -- is a distortion of your voice. In order for that to be effective, it's very important that you watch the person asking you questions and make sure that this little red light on the top of their microphone is off when you answer the question. Do you understand that?

A. Yes.

Q. Now, we can begin by asking you to take a look at Exhibit 539, tab 1. My first question to you is: Is that your name on the top of that page?

A. Yes.

Q. And the last line on that page, does that indicate the position that you held that's relevant to your testimony here today?

A. Yes.

Q. Can I ask you to describe in a sentence or two what was the Association of Emigrant Serbs.

A. The Association of Serbs and Emigrants of Serbia was an organisation for aid to Serbs outside Serbia, actually, in the diaspora. ²⁶⁵⁹⁰ It worked on humanitarian aid and providing supplies for the battlefields of Croatia and Bosnia. It also transported humanitarian and military supplies and aid.

Q. Sir, did there come a time when the name was changed of that organisation?

A. Yes. The Association of Serbs was originally called the Association of Emigrants of Serbia. Later, the name changed to the Association of Serbs and Emigrants of Serbia.

Q. Now, before I ask you to talk about your testimony in detail, I'm going to ask you the names of four people, and if I could ask you, in simply a sentence, identify the position that each of these people held. The first person I'd like to ask you about is a person by the name of Branislav Crnjevic -- Crncevic, sorry.

A. Brana Crncevic was the president of the Association of Serbs and Emigrants of Serbia.

Q. Can you describe what, if anything, you know about his relationship to the accused, Mr. Milosevic.

A. Yes. I do know that in those days they were good friends, and I know that Brana often went to see Mr. Milosevic. On one occasion, I myself drove him in my car to the house of Mr. Milosevic. In front of the house I dropped him off.

Q. The person by the name of Milan Prodanic. Can you tell us briefly who he was.

A. Milan Prodanic was the head of the 6th department of the state security department of the MUP of Serbia. ²⁶⁵⁹¹

Q. What can you tell us about his relationship to Jovica Stanisic?

A. He was directly subordinated to Jovica Stanisic, and they were in permanent contact. They discussed the work and supplies issues.

Q. And a person by the name of Lieutenant Colonel Bora Stanisic. Can you tell us what you know about him?

A. Lieutenant Colonel Bora Stanisic was in the command of the town military post 5055 and was in charge of the military warehouses in Bubanj Potok.

Q. Are you aware of any family relationship between Bora Stanisic and Jovica Stanisic?

A. I don't know that they were in any kind of family relationship.

Q. And the last person I'd like to ask you about is Mr. Tepavcevic.

A. I met Mr. Tepavcevic only once in the MUP of Serbia. He was to have worked with Bora Stanisic before even Prodanic, but they didn't get on for some reason, and so he didn't work with Tepavcevic but with Milan Prodanovic.

THE INTERPRETER: Could the witness approach the microphone, please?

MR. GROOME:

Q. Sir, could I ask you to sit up a little bit closer to the microphone so that it may pick up your voice a bit more clearer. During the course of my questioning to you, I will refer to the Association of Emigrant Serbs as "the association," and my first question to you is where precisely did the association have its offices?

A. The offices of the association were in Nusiceva Street, number 4, ²⁶⁵⁹² Belgrade.

Q. Now, I'd like to ask you to describe for the Chamber any prominent visitors that came to the office during the time that you were at the office.

A. Yes. Various politicians would come. The leaders from the Republic of Serbian Krajina and from Republika Srpska would also come, as would members of the government of Serbia and people from the MUP of Serbia.

Q. Now, if I could ask you to be a bit more specific. With respect to political leaders, can you describe the party or parties that those leaders belonged to?

A. Mostly they belonged to the SPS and to the democratic party of Karadzic, the Serbian Democratic Party led by Karadzic.

Q. Now, you have described leaders from the Republic of Serb Krajina and from Republika Srpska. Can I ask you to identify the names of individuals from both of those entities?

A. I can say that from the Republika Srpska, Goran Hadzic would come often, and from Republika Srpska, various politicians. Whenever there were meetings, I could not attend nor could the others.

Q. Are you able to identify the names of any of the other people who came from Republika Srpska?

A. I can. Krajisnik would come frequently.

Q. Anyone else?

A. I once met with Biljana Plavsic in the government of Serbia, and then I drove her to the airport at Batajnica. She would come too. ²⁶⁵⁹³

Q. Now, you've identified members of the Serbian MUP as also visiting the office. Are you able to identify any particular names of people from that organisation?

A. Yes. His name was Isidor. He would set up the equipment for communications, radio equipment for communication with Krajina. Above the offices there was a centre for monitoring developments in Republika Srpska and in the Republic of Serbian Krajina.

Q. You are describing a person from the Serbian MUP setting up communications equipment. Do you know where those lines -- where the other end of those lines were located specifically?

A. What do you mean the other end? I didn't quite understand.

Q. You said that these lines were set up to monitor events in the Serbian Krajina, I believe. What I'm asking you is do you know in what particular location the other end of those communication lines were terminated, a particular organisation or a particular place?

A. There were radio communications, and the antennas were placed on the roof, and there were connections with various commands in the Republika Srpska and the Republic of Serbian Krajina.

Q. During the period of which you have knowledge, were there ever any members of the JNA or the VJ visiting the association?

A. As far as I know, a security officer came who worked in Korenica, but I cannot recollect his name, from the army of Yugoslavia.

Q. And during the time that you're familiar with, was there ever anybody from the Serbian Ministry of Defence who visited the association's offices? ²⁶⁵⁹⁴

A. From the Defence Ministry, no one came. From the army, as far as I know, they didn't come to the association itself. Brana went to meetings, but they didn't come to the association.

Q. Can you please describe what you know about meetings with members of the association and members of the Ministry of Defence. How frequently, and where were those meetings held?

A. They were held on a daily basis. Every morning, there would be meetings in the state security of the MUP of Serbia where they would review information from the battlefront. And then Milan Prodanic would go to Bubanj Potok where he held meetings every afternoon with Boro Stanisic as to what should be sent where, to what part of the battlefront.

Q. Now, before I leave this topic of the association's offices, were there ever any members of paramilitary organisations that you saw visit the office?

A. Yes. From Novi Sad, Lajnovic Dugi came, who later was killed. I remember him well coming there. Captain Dragan would also come.

Q. Any others?

A. I can't remember. Kojic from Borovo Selo.

Q. Now, was there ever a time that Mr. Crncevic informed you about some special lines or telephone lines that he had installed in his office?

A. It's not a matter that he told me about; I saw those telephone lines. There were special telephone lines with Mr. Milosevic and the state security of the MUP of Serbia.

THE INTERPRETER: Could the witness speak up.

THE WITNESS: [Interpretation] These are special telephones, ²⁶⁵⁹⁵ so-called red telephones, not ordinary telephones.

MR. GROOME:

Q. Sir, the people doing the translation are asking if you can speak a little bit louder. They're having difficulty hearing everything that you say.

Could I ask you, the line that was connected to the -- I believe you said the Serbian state security or the MUP of Serbia, can you tell us, do you know who it was, whose office, that line was connected to?

A. At the other end of the line was the state security of MUP Serbia and Mr. Milosevic. The line was directly connected to them. Brana Crncevic had direct communication with them, not using regular lines but those special telephones.

Q. Did Mr. Crncevic ever tell you what the purpose of having those direct lines was?

A. The purpose of the direct lines was to know exactly what was happening on the theatre of war. Many people came to Brana Crncevic's offices to inform him about developments on the front and then he would convey that information to the state security and the former president, Slobodan Milosevic.

Q. Now, before I ask you detailed questions about the activities of the association, can I ask you, in summary fashion, to describe for the Chamber the portion of assistance that was rendered that you, I think believe -- I think you referred to it as "battlefield supplies." Can you give the Chamber some sense of what quantity of battlefield supplies or military equipment passed through the -- passed through the association to ²⁶⁵⁹⁶ the battlefields of Bosnia and the Krajina.

A. I can say the exact number from Bubanj Potok in the 1992 -- in 1992 towards the end of the year. I think that more than 1.200 trucks of weapons and ammunition passed through Bubanj Potok, and transports by matica -- by the association participated. Then there were also vehicles of the MUP of Serbia that were engaged, as well as private transporters, and trucks were coming from Serbian Krajina and from Republika Srpska. And there was more than 1.200 heavyweight trucks. Not small ones of four and a half tons but those with more than 20 tons carrying capacity.

Q. Now, the military equipment that was distributed by the association, do you know from where it came?

A. A part of it were radio stations, and these radio stations were received by the association from Serbian societies all over Europe and the world. Actually, the military equipment, the weapons and ammunition, they came from Bubanj Potok 2.

Q. Can you please be more precise about what was at Bubanj Potok. What type of facility? Who owned it? What type of facility was at Bubanj Potok from which the association received weapons and ammunition?

A. Bubanj Potok number 2 is one of the largest warehouses of ammunition and weapons in the former Yugoslavia. It supplied -- it provided weapons. These are large underground depots. There are hangars above ground. In addition to those depots, there is Bubanj Potok 1, which was used as a training ground and shooting range, and it is from there that people were sent to the front, and the two facilities about -- are about 2 kilometres apart. ²⁶⁵⁹⁷

Q. Bubanj Potok 2 where the ammunition and weapons were stored, who owned that facility?

A. The warehouse was owned by military post 5055, that is the command of the city of Belgrade.

Q. What, if you know, was the relationship between the MUP of Serbia and either Bubanj Potok 1, the training facility, or Bubanj Potok 2, the storage facility?

A. The relationship between the MUP of Serbia and the warehouses was such there were only two men involved, Bora Stanisic and Milan Prodanic. Milan Prodanic came with the orders what should be carried and Bora Stanisic prepared the transport convoys and sent them off to the front. So the link with the state security of MUP in the MUP of Serbia was that a very small circle of people in the former JNA actually knew what was going on in Bubanj Potok, at least as far as I know. The same applies to the MUP of Serbia. A very small circle of people were aware of that.

Q. What percentage of the weapons and ammunition that were distributed by the association came from Bubanj Potok 2, from VP 5055?

A. A very large per cent. It's not negligible. Nowadays, you could supply, well, one-third of the former Yugoslavia, say, as regards manpower. The figure speaks in itself. One thousand two hundred trucks in 1992. These are heavy trucks. You could arm a great many men.

Q. Can I ask you to simply list the names of any people who significantly contributed to the distribution of weapons from Bubanj Potok. You've mentioned Bora Stanisic already. Are there any other officers, either military or civilian employees, whose names should be ²⁶⁵⁹⁸ recorded here as being involved in this?

A. Yes. Bubanj Potok had a total of five persons. There was Dule Malusic. He was a sergeant in the military police. Then there was also a man called Rile. He was a civilian military person employed by the army of Yugoslavia. Then there was a man called Brka, and then there was a man called Buca who died. He was actually the main person in charge of warehouses in Bubanj Potok and he died during the war, but how he died is something that has never been explained.

Q. Was there any particular piece of military equipment or weaponry that had to be purchased separately from what was received from these military warehouses?

A. Yes. The former JNA did not have silencers only, because this was not part of regular requirements. This was manufactured in Kaludjerica near Belgrade; a privately owned workshop manufactured them. The payments for these silencers were made, as far as I know, by the state security of the MUP of Serbia.

JUDGE KWON: Mr. Groome, if you could clarify a couple of things with the witness.

MR. GROOME: Yes, Your Honour.

JUDGE KWON: First, whether Bubanj Potok is the name of a military facility or a name of a place. Secondly, whether it is in Belgrade or near Belgrade.

MR. GROOME: Yes, Your Honour.

Q. Sir, if I may clarify those points that Judge Kwon is inquiring about. Let's take Bubanj Potok. The place that you're referring to as ^{26599 BLANK PAGE 26600} Bubanj Potok 1, was that the official name or simply the name of the place where it was located?

A. This is a locality. This is where the place actually was. It's outside Belgrade, a few kilometres on the road to Nis. You get off the highway, after a few kilometres Bubanj Potok 1 is on the left-hand side. Bubanj Potok 2 is on the right-hand side. But the two facilities are divided. Both belonged to the army of Yugoslavia.

Q. Sir, Bubanj Potok 1, did it have any official name, let's say, at the gate or any official address that you can recall now?

A. As far as I know, no. Quite simply, it was called Bubanj Potok 1. When you received call-up papers for mobilisation, it would say Bubanj Potok 1. That's where you were mobilised to.

Q. And does the same hold true for Bubanj Potok 2?

A. No. Bubanj Potok 2 was a closed facility. It only consisted of storage facilities for military equipment, nothing else.

Q. Now, the weapons that -- and ammunition that the association received from Bubanj Potok 2, did it have a place where the association itself would temporarily store those weapons prior to them being distributed in Croatia and Bosnia?

A. In some cases, yes. We had some parking space at the Belgrade fairgrounds or, rather, the entrance to the Belgrade fairgrounds on the right-hand side. This is where some old workshops existed before. And then we were given this parking space so that vehicles could be parked there before they went to Republika Srpska and Republika Srpska Krajina. For a while while Kertes was in the MUP, we had -- we had their hangars ²⁶⁶⁰¹ too in Makis, and that also belonged to the MUP of Serbia.

Q. Now, an earlier witness has talked about a location that he described as an overpass in the vicinity of the fairgrounds. Are you familiar with an overpass, an elevated highway, in the vicinity of the fairgrounds?

A. This is right underneath the overpass. It's underneath the highway, the loop of highway is called the Gazelle. It's on the left-hand side. It's at the very entrance into the Belgrade fairgrounds.

Q. So the location you're describing as where the trucks would be parked, this is under a highway. Is that what you're describing?

A. Well, perhaps you can put it that way, although it's a bit to the left compared to the highway, because there was this big haul of the Belgrade fairgrounds that the matica used for humanitarian aid, medicine and things like that, and that was right underneath the highway loop, and I don't know whether that's what you had in mind.

Q. Now, in addition to this storage facility, were -- did the association ever transport weapons directly from facilities belonging to the Serbian MUP, and if so, can you please identify the location of those facilities?

A. I can identify them. There was a warehouse in Ostruznica that belonged to the MUP of Serbia, and that is where transports directly started as well. Later on, a warehouse was made towards the very end in Lipovica. The army of Yugoslavia gave this to the MUP of Serbia. This is E on the road leading to Barajevo.

Q. Sir, I am now going to ask that you be shown Exhibit 539, tab 2. ²⁶⁶⁰² It is a document dated the 1st of September, 1992. Can I ask you to look at it and tell us whether you recognise the document; and if so, please comment on its contents.

A. Yes. This is what the association got, 10.000 litres of diesel fuel for meeting its own needs, and it was by way of coupons for the month of September.

Q. This fuel that the association received, was it used in the distribution of -- solely for the distribution of humanitarian aid, as indicated in this document?

A. No. No. All this fuel was obtained for military and civilian aid. Also, we used fuel from military storage facilities. Bubanj Potok 2 had a gasoline station of their own, and we got fuel from there. And no payments were made for that fuel; we simply received it.

Q. I ask that the witness be shown Exhibit 539, tab 3, and I'd ask you the same question, sir: If you can identify this document; and if so, please describe its -- its meaning to the Chamber.

A. This is a document of the Ministry for Communications with Serbs outside Serbia. The address is Nusiceva number 4, and this gives approval to take over 2.500 litres of fuel in accordance with the decision of the ministry of the government of Serbia.

Q. If I can now ask you to take a look at Exhibit 539, tab 4. It is an undated piece of paper containing a list of numbers. Can I ask you to describe what is the significance of the names and phone numbers contained on this exhibit.

A. These are telephone numbers of Jugopetrol, Beopetrol, and the ²⁶⁶⁰³ Nafta gas company from Novi Sad. There were contacts with them when certain amounts of fuel were required. These are the direct telephone numbers of the general managers of Jugopetrol, Dragan Tomic; the director of the former Beopetrol, Mileta Nedjo; and contacts were made with him, if necessary, to take over fuel from their storage facilities or gasoline stations.

Q. Sir, so that the record is clear, I've just been asking you questions about military equipment and ammunition. Would it be fair to say that significant amounts of humanitarian - purely humanitarian - aid were also distributed by the association to those people in need in both the battle-torn areas of Croatia and Bosnia?

A. Yes, certainly.

Q. Can I ask you to take a look at tab 5 of Exhibit 539, and my question to you is in this document dated the 19th of June, 1992, is this not a record of one such shipment of purely humanitarian aid going to Sarajevo?

A. Yes. This aid was sent to Sarajevo. The government of the Republic of Serbia was sending humanitarian aid to Sarajevo. These are different amounts of sugar, flour, oil, everything else that was sent to the area of Pale and Sarajevo.

Q. If I can now ask you to take a look at tab 6 of 539. Can you please identify this document - it's a document dated the 17th of June, 1992 - and describe its contents for the Chamber.

A. This is a document of the Red Cross of Serbia to the government of the Republic of Serbia, to the Ministry for Communication with Serbs ²⁶⁶⁰⁴ Outside Serbia. This is a document requesting that humanitarian aid be brought to the Red Cross warehouses from where matica trucks were supposed to transport it to Pale and Sarajevo.

Q. Were you involved in one such convoy that transported humanitarian aid from Belgrade to Pale near Sarajevo?

A. Yes.

Q. During the course of that convoy or your duties to deliver that convoy, did you have a meeting with Mr. Radovan Karadzic?

A. Yes. In that particular case, I actually met with Radovan Karadzic in Pale. Biljana Plavsic and Radovan Karadzic. I had some problems precisely with Radovan Karadzic, because he would not allow me to take a number of trucks that were intended for Sarajevo to Sarajevo itself. He asked for all the trucks to be unloaded in Pale. I opposed that. I would not allow all the trucks to be unloaded in Pale because it was written on the trucks themselves by the Red Cross people that this aid was sent to Serbs, Muslims, and Croats. Actually, to Merhamet and Caritas, the charity organisations.

Q. If I could now ask you to look at Exhibit 539, tab 8. Do you recognise this document?

A. Yes, I recognise this document too. This is a document that was received by the Association of Serbs from the public security station in Donji Lapac in Lika, specifying all the equipment they needed for this police station of theirs in Donji Lapac. Most of this is military materiel.

Among this materiel, inter alia, silencers were being requested ²⁶⁶⁰⁵ for automatic rifles; 35 for sniper rifles, for 7.9-millimetre rifles, and for Scorpios silencers as well, 15 pieces.

Q. Sir, this document, is this document an example of the types of documents that would be sent to the association requesting ammunition and military equipment?

A. Yes.

Q. Now, you've testified earlier about Mr. Prodanic and Bora Stanisic having meetings. Can I ask you to describe where they would have those meetings and with what frequency.

A. The meetings between Milan Prodanic and Bora Stanisic at first took place at the warehouse of Bubanj Potok 2. There was a small office within the hall itself. It's a makeshift office, a very small one. It was made mostly for the winter, because these hangars are very cold during the winter. However, these conversations could be overheard as well because it wasn't a properly built room.

Later on, these meetings were held at the matica hall every afternoon at the Belgrade fairgrounds. That's where humanitarian aid was kept.

Q. You've testified that the meetings that were held at Bubanj Potok 2 could be overheard. Did you yourself ever overhear those conversations; and if so, could I ask you to just briefly summarise the types of subjects that were discussed at those meetings.

A. Well, at these meetings supplies with ammunition and weapons in parts and Bosnia and Croatia, that's what was discussed; what was necessary, what amounts, what kind of weapons, what kind of ammunition. ²⁶⁶⁰⁶ For the most part, that is what these meetings dealt with.

Q. You testified earlier about other meetings that were held at the state security building. Can I ask you to be more specific in telling us who would attend these meetings and with what frequency these meetings were held?

A. Well, meetings at the state security took place every day or, rather, every morning. As far as I know, these meetings were held including the following people: Milan Prodanic, Jovica Stanisic, Tepavcevic, and for a while Mihalj Kertes while he was at the federal MUP. I don't know about the rest but as far as these people are concerned, I heard that they attended these meetings. Mr. Milosevic was also informed about these meetings every day, because I know that when they had discussions in my presence, Mr. Milosevic would have to be informed about these meetings every day.

Q. Can I ask you to describe for the Chamber how it is you know about these meetings that were held every morning in the state security?

A. Well, of course I know, because when additional amounts of weapons were requested, whenever Prodanic came to Bubanj Potok 2, he would say at the meeting we received information as to what was necessary in which part of the front line so that these deliveries could be made from Bubanj Potok itself. Because the MUP of Serbia itself did not have such large storage facilities and so many weapons in order to be able to send all of this to the front line. Actually, all the military equipment that came from the former Yugoslav republics, from Slovenia, from Croatia, from Macedonia, for the most part was brought to the Bubanj Potok storage facilities and ²⁶⁶⁰⁷ the other storage facilities around Belgrade. So for such weapons -- so as far as these weapons were concerned, they didn't have to be accounted for. There would always be a certain amount that could remain within the storage facility of Bubanj Potok 2 and thus be accounted for. And these weapons didn't have to be recorded, the other ones. As for all these weapons that were needed, over a certain period of time the Territorial Defence of Serbia was abolished. These weapons of the Territorial Defence of Serbia were taken to the front line, actually.

Q. The front line where, if you know?

A. Republika Srpska and Republika Srpska Krajina, all these places there where of course there were headquarters that received this equipment. At first all of them were civilians. These were not military personnel. It wasn't professional policemen or military personnel who were involved. These were ordinary citizens who were establishing the so-called Territorial Defence at the time, and this ammunition and these weapons were sent to them.

Q. The meetings at the state security office of the Serbian MUP, did Mr. Crncevic ever go to those meetings?

A. I think he went to these meetings only on a few occasions. He would come to work very late in general. He was a late sleeper in the morning, as far as I know. And the meetings were held early in the morning.

Brana Crncevic went to see Jovica Stanisic, I know that. They were good friends. They even visited each other at home.

Q. When he -- you say that he would go see or visit Jovica Stanisic. ²⁶⁶⁰⁸ Was this a social visit or a business visit, and where precisely would he go see Mr. Stanisic.

A. To the MUP of Serbia. It is a purely business relationship. It's not a private relationship, personal.

Q. Now, you testified --

JUDGE KWON: Wait a second, please. Mr. B-179, you said that Mr. Milosevic must have been receiving the daily report from the meeting. Could you elaborate on how you came to know that a little more? You said that you had overheard something. What is it that exactly you heard from their conversation?

THE WITNESS: [Interpretation] Well, I heard in Bubanj Potok conversations between Milan Prodanic and Jovica Stanisic, that the president, Mr. Milosevic at the time, had to be informed about everything that was being done. After all, Mr. Milosevic, although he did not command the army, the supreme defence command, it was the MUP of Serbia that was under his command and the state security.

JUDGE KWON: So is it your assumption that Mr. Milosevic received the daily report from them?

THE WITNESS: [Interpretation] It's not my assumption. It's the truth. He received reports. I heard that he received reports from Milan Prodanic, from the state security of Serbia, from the head of the state security of Serbia. It's not an assumption. I heard this with my very own ears.

JUDGE KWON: So could you tell me what you heard at that time exactly. ²⁶⁶⁰⁹

THE WITNESS: [Interpretation] At that time, I mean on various occasions, I heard that Mr. Milosevic had to be informed about everything that was being sent to the front line. The meetings themselves were held at the state security of the MUP of Serbia in this small circle of people. Milan Prodanic came from these meetings to Bubanj Potok, and he directly conveyed this to Mr. Jovica Stanisic and to Mr. Milosevic.

JUDGE KWON: Thank you. Mr. Groome, apart from that, I think you haven't dealt with the paragraph 19 in the summary and the following paragraphs. Was it your intention?

MR. GROOME: No, Your Honour. Thank you for pointing that out. I'll return to that now.

JUDGE KWON: Thank you.

MR. GROOME:

Q. Before I return to questions that I inadvertently omitted, when you would hear Mr. Prodanic refer to conversations with Mr. Milosevic, what term did he use sometimes to refer to Mr. Milosevic?

A. They called him "Dad." They would say, "That is what Dad ordered."

Q. Now, prior to the association receiving weapons and ammunition from Bubanj Potok 2 and distributing it, would -- who would have to give permission for those weapons to be released from Bubanj Potok 2 and given to the association?

A. You mean permission in terms of having the weapons handed over to the matica so that they could then be transported further to the front line? Is that what you mean? ^{26610 BLANK PAGE 26611}

Q. Precisely.

A. Well, I should put it this way: In order to load the weapons onto the trucks, it was Lieutenant Colonel Bora Stanisic from Bubanj Potok who gave orders to that effect. Then it was sent to Bubanj Potok, and then weapons and ammunition were boarded on those trucks. If necessary, medicine and blankets and food were added on to the trucks in the hall of the matica, and then from there the trucks went to different frontlines. It was the MUP of Serbia that issued orders concerning this, and I can explain in which way, so that -- I mean, we did not need any special permission for these transports in order to cross checkpoints of the Ministry of the Interior. Policemen were always informed that such-and-such vehicles would be passing there, and nobody checked these vehicles in any way.

Q. Who would Lieutenant Colonel Bora Stanisic receive his orders from? Would it be his military superior or someone else?

A. No. No way. It would not be his military superior. It would be the MUP of Serbia; Milan Prodanic specifically and directly.

Q. Just so it's clear, what is your understanding about how orders to distribute weapons belonging to the JNA and VJ, what would have been the regular course of that order to give out such weapons?

A. Well, it should have been going through the Ministry of Defence and the army of Yugoslavia. However, it didn't go through the Ministry of Defence of Yugoslavia or the army. That would have been the proper course. However, this proper course was bypassed in this case. This work was not supposed to be known about by a great number of people. Only a ²⁶⁶¹² small number of people knew about it in the circle that I dealt in.

Q. Now, if I can change the subject and ask you: Were you personally involved in some convoys that distributed weapons to the Krajina?

A. Yes.

Q. How many times?

A. Well, a number of times. I went twice to Zvecevo. I was on convoys led by Bora Stanisic. Sometimes -- for a while, in fact, these convoys started from Bubanj Potok every Friday, would come back on Saturday. Those were pretty large convoys. I usually went to a hospital in Bucje, near Zvecevo, where I dropped off medicine, blankets and other aid, but sometimes I went all the way to Zvecevo where military equipment was stored for that part of the battlefield, the front line. Also, there was one convoy that I led myself instead of Bora Stanisic. It included four trucks that carried ammunition for Podnoble [phoen] at the time of battles in Slavonski Brod and Bosanski Brod.

Q. Can I draw your attention to the first time you were involved in one of these convoys. Can I ask you to describe how many trucks in total were involved in the convoy, and can you give us some idea about which percentage of those trucks were carrying humanitarian aid and which were carrying military equipment?

A. You mean for Zvecevo.

Q. Yes.

A. Well, usually there would be ten to 15 trucks. One truck would be carrying only humanitarian aid and other trucks would carry military assistance. ²⁶⁶¹³

Q. Were you ever involved in a convoy in which the Serbian state security had provided the trucks to transport the material?

A. Certainly. In most of these convoys, the trucks of the MUP of Serbia were involved. It is true that their trucks were slightly smaller. Those were Mercedes trucks, Mercedes 12 and 13. Their carrying capacity was slightly lower, but they were usually used for carrying supplies within the convoys. Also, there was a time when the MUP of Serbia had a Renault trailer truck that was brought from the front line as war booty. And I know that they were not able to start it for a while because this cab of the truck was operated by remote control.

Q. Now, if I can draw your attention to the Republika Srpska, that part of Bosnia. Are you aware of convoys, similar convoys being sent into areas in Bosnia?

A. Yes. They sent supplies to all parts of Bosnia, from Sarajevo all the way up to Herzegovina. There were liaison persons, contact persons designated by the MUP of Serbia. They were mainly civilians. As for Sarajevo itself, the liaison was a woman nicknamed Beba, who before the war used to own a cafe in Sarajevo, in Ilidza.

Q. Sir, can I ask you just to simply list the different locations in Bosnia that you have personal knowledge that convoys of weapons were sent to these locations.

A. Well, supplies were sent to Knin, Gracac, Licka Osijek, also Banja Luka, to Nevesinje in Herzegovina, to Trebinje, although these are very remote places looking from Belgrade, but Belgrade supplied that part of the front line as well. Maybe there were other sources of supplies, but I ²⁶⁶¹⁴ didn't know about that other part.

Q. And with what frequency did these convoys go into Bosnia? Can you give us a -- was it every week, every month? Can you give us some idea of the frequency with which they travelled to Bosnia?

A. Well, convoys went practically on a daily basis. They came and went from Bubanj Potok practically every day. They would come back from the front line, from Croatia and Bosnia, and then they would -- these trucks coming from these areas would load supplies and drive it back to their own locations. Trucks came and went every day.

Q. Now, the convoys that went to Bosnia, did they go before the conflict broke out, after the conflict broke out, or both?

A. Well, let me tell you. Before the conflict, one truck -- I mean, before the conflict in Bosnia, one Scania truck from the association took from Bubanj Potok weaponry to Sarajevo before the conflict broke out in Sarajevo. It was a Scania truck driven by Zeljko Rajcevic who is a professional driver of the association, a refugee from Western Slavonia.

Q. Now, can I ask you to describe what was the arrangement with the people who would receive these weapons? Would they have to pay for these weapons? What would happen when the weapons were delivered to the locations in Croatia and Bosnia?

A. No. This weaponry was not paid for. It was just received.

Q. Would the people receiving the weapons have to sign that they had received them?

A. Yes. Everybody had to sign a receipt issued by the command of the city of Belgrade, military post box 5055, and it accompanied on a ²⁶⁶¹⁵ compulsory basis every truck that was sent out. All these receipts had to be signed for the entire amount contained in the truck, ammunition and weaponry.

MR. GROOME: I ask that the witness be shown Exhibit 539, tab 12.

Q. Sir, I'd ask you, can you identify this document, how it is you identify this document, and describe its contents.

A. This is one of the receipts of the military post 5055, the Belgrade city defence command. It concerned 82-millimetre shells for mortars. The quantity indicated is 225, and that fitted into one van. I personally took it over from Bubanj Potok.

Q. Is that your -- is that your signature?

A. Yes. This is my signature, meaning that I received it and delivered it to the man who was designated to me from Gabos.

Q. Sir, this document has at the top of it for the following materiel received for temporary use. A number of the documents seem to refer that some of this equipment was loaned rather than given outright. My question to you is: Were you ever involved or ever aware of similar transportation carrying back weapons and ammunition from the places from where it was distributed to -- from the places it was distributed?

A. No. By no means I never returned these weapons.

Q. Was there ever an occasion when you were making a delivery or involved in a delivery when Arkan and his men sought to join the convoy?

A. Yes. It was our first travel to Knin, first journey. The first convoy, when it was very difficult to reach Knin and Banja Luka. It was the first convoy that set out for Knin, included me. There was a meeting ²⁶⁶¹⁶ at a petrol station where I was supposed to meet up with the rest of the convoy that did not belong to my organisation.

I had behind me my part of the personnel in my vehicles, and when I came to this petrol station outside of Belgrade, I was met by the vehicles and the men belonging to Arkan. When I realised that those were Arkan's men, knowing what they were doing and what they were dealing with, I ordered my men to start their trucks and to return to the depots where we had started from.

However, after awhile, Arkan came with 10 to 15 of his men who were pointing his guns, his automatic rifles, at me and my men. He slapped me, and he told me to order my trucks to start and drive on. In order not to risk the lives of my men, I had to do as he said. Arkan accompanied that convoy up to Modrica, and then he probably returned to new Belgrade; whereas I continued my journey across Plitvice all the way to Knin and only --

Q. Sir, that's sufficient detail with Mr. Arkan's involvement in the convoy.

You mentioned the association transporting radio transmitters. I just want to ask that you be shown tab 7 of 539. Without going into too much detail, is this document a receipt for a quantity of radio transmitters given to the Republika Srpska?

A. Yes. This is a receipt referring to radio transmitters that I gave to Biljana Plavsic for the headquarters of Republika Srpska, and it is directly related, intended for Radovan Karadzic.

Q. Did Mrs. Plavsic sign that receipt? ²⁶⁶¹⁷

A. Yes.

Q. Now, did there come a time when General Mladic asked to see some of the people involved in the supply of the VRS with weapons? Again, the detail of the conversation is not as important as just telling us when and where it was you met General Mladic.

A. Well, I was at Bubanj Potok 2 when we received a telephone call when it was said that General Mladic wanted to see us, to see who was supplying him with weapons, who was doing that part of the work, and he was waiting for us in a coffee bar near the new Belgrade municipality building, and that was the first time I saw General Mladic in person.

Q. Now, was there an occasion when you were asked to escort a truckload of Republic of Serb Krajina dinars from Belgrade to Knin?

A. Yes. I was told to send a truckload, and it was again a Scania truck, which is a closed truck, not with a tarpaulin but it had a completely closed box. They told me to load it with money. Those were the first Krajina dinars printed at the mint in Topcider. It was driven again by this man Jovo, who was a refugee from Western Slavonia. He went to the mint and took over between seven and eight tons of banknotes that we sent to Knin.

Q. On --

A. Also, we carried back from Knin a certain amount of money of all currencies - German marks, dollars, et cetera - and they were driven to the mint at Topcider. That was on the way back.

Q. Now, you've testified about being able to pass through checkpoints without any difficulty. I'd ask that you be shown tab 9 of 539 and ask ²⁶⁶¹⁸ you, are you able to identify this document?

A. Yes, I recognise this document. It concerns a bus with Vukovar licence plates, which I drove myself. I have a licence for driving trucks, and I was driving refugees to Lazarevac to a centre for accommodation of refugees, and these used to be barracks for accommodation of miners from that area. The very name of Brana Crncevic made it very easy for us to make our passage anywhere.

Q. Whose responsibility was it to notify border crossings and checkpoints, to arrange for the unimpeded access of the trucks transporting weapons for the association?

A. That was done by Milan Prodanic, head of the 6th administration of the state security of the MUP of Serbia.

Q. Now, during the embargo against the Republika Srpska, was there any significant change in the level of supplies that went from the association to areas of Bosnia-Herzegovina?

A. Well, there was no particular change. It continued, but the vehicles had to be removed from Bubanj Potok. They couldn't stay on long. One or two trucks at most would come in at a time, and then they had to be removed after being loaded so as to prevent leakage of the information that this loading was being done there.

Q. Now, you've testified earlier about being aware of meetings held in the state security and also of Mr. Milosevic being notified or wanting to be kept informed about the transportation of these weapons. Are you able to say that during the embargo these meetings continued or are you not able to say? ²⁶⁶¹⁹

A. Yes. Meetings were held even during the embargo. At that time, the meetings were held on the premises of the association, namely, this hall at the Belgrade fairgrounds that belonged to the association.

MR. GROOME: I'm going to ask that the witness now be shown Exhibit 539, tab 10.

Q. And I'm going to ask you, sir, if you're able to identify this document, and if so, please describe its contents.

A. This is one of the applications by Brana Crncevic to the Ministry of Defence of the Republic of Serbia in Nemanjina Street, that is, the government building of Serbia, applying for 15 automatic rifles, eight pistols, four automatic Skorpio pistols, and 500 9-millimetre rounds for pistols.

This was approved, and it says here precisely that this was settled and that Boro should give it to the association. In fact, he gave it directly to me, and I distributed it.

MR. GROOME: I ask now that the witness be shown 539, tab 11.

Q. Sir, this is a series of documents. The specific detail of the documents isn't as important as whether or not you're able to identify what they are; and if you are, can you summarise the general nature of these various documents.

A. These are again the documents of military post 5055 concerning the weapons and ammunition that I took over on behalf of the Association of Serbs and Serbian Expatriots.

Q. And the equipment described in those documents in tab 11, would it be fair to say that that equipment was ultimately then redistributed by ²⁶⁶²⁰ the association to places in Bosnia and Croatia?

A. No. These weapons and ammunitions were directly meant for the association. It didn't go to Bosnia or Croatia. It was given to people who worked for the association and for practice purposes, because our staff, our people, were taken to target practice because they had to undergo training.

Q. So these documents represent equipment directly issued to the association for the purpose of its distribution, not for actual distribution to a third party itself; is that correct?

A. Precisely.

Q. Now, was there ever a time when the association was requested to transport actual paramilitary members, members of paramilitary units, to areas in Bosnia and Croatia?

A. Yes. On a couple of occasions, Brana was asked to secure trucks for members of various formations that were sent from Bubanj Potok 1. Brana was one of the few people who had enough authority for his requests to be met whenever he asked transport companies like Lasta or any others for trucks of their own to be given to us.

MR. GROOME: Finally, I'd ask that the witness be shown tab 13 of 539.

Q. And once again, sir, I'd ask you if you can recognise this document.

A. Yes. This is a thank you note addressed to me from the army of Yugoslavia for my commitment and self-effacing efforts in lending assistance to members of the Territorial Defence and the Serbian people ^{26621 BLANK PAGE 26622} who were exposed to Ustasha terror and genocide. This was issued by military post 5055, it was signed by Colonel Radoslav Blazic, but honestly I don't even know who that person is.

Q. Sir, I have no further questions for you. I would remind you that when you're being asked questions by Mr. Milosevic, that you keep an eye on the red light on his microphone and only begin your answer after that light has been turned off.

And if I could advise the Chamber, the only particular areas of sensitivity the Prosecution ask be taken in private session would be the specific job description and title of this witness in the association as well as any other questioning about the previous court proceedings which are listed on page 14 of the summary. Other than that, it is the Prosecution's position that none of it will compromise the identity of the witness.

JUDGE MAY: Yes. The registry raised the question of which matters should be under seal.

MR. GROOME: Yes, Your Honour. If I could identify those at this stage. They would be tab 1, tab 3, tab 4, tab 9, tab 11, tab 12, and tab 13.

JUDGE MAY: We will take the usual adjournment now. It will be for 20 minutes.

Witness B-179, could you be back in 20 minutes, please, to go on with your evidence. Could you remember this: During the course of those adjournments, don't speak to anybody, please, about your evidence until it's over. ²⁶⁶²³

THE WITNESS: [Interpretation] Thank you.

JUDGE MAY: We will adjourn now.

--- Recess taken at 10.28 a.m.

--- On resuming at 10.51 a.m.

JUDGE MAY: Yes. Mr. Milosevic, we've decided you should have one hour and a half for cross-examination of this witness. That should be ample time provided you don't argue with him and waste time with other peripheral issues.

THE ACCUSED: [Interpretation] I hope I won't waste time on peripheral issues, Mr. May, though this witness is telling untruths from beginning to end, and therefore, I will have to examine him in some detail, so I'm not sure that I will be able to fit my cross-examination with your envisaged hour and a half.

JUDGE MAY: The witness can deal with your first suggestion. Witness B-179, you've heard what the accused has alleged. He's alleged that you've been telling untruths from beginning to end. Is that so or not?

THE WITNESS: [Interpretation] If he is a liar, I am not. I do not lie.

JUDGE MAY: Very well. Yes. Cross-examined by Mr. Milosevic:

Q. [Interpretation] Mr. B-179, I see you gave this statement to the investigators on the 11th and 12th of March, 2003. Is that right?

A. Yes.

Q. You say that the motive for giving this statement to the ²⁶⁶²⁴ investigators is to show that Serbs are not a genocidal people. You say, "My motivation for contacting and deliver these documents are to show that the population of Serbia are not the genocide type of people." Is that right?

A. Yes.

Q. This is in your statement. Do you have your statement?

A. No, I don't, but it doesn't matter.

Q. Tell me, what does this word "genocide" mean?

A. Genocide is killing of one people, Mr. Milosevic. You, as the President of Serbia, inflicted the greatest damage and genocide to your own people, the Serbian people.

Q. I'd like you to have a look at your statement, Mr. B-179, and to mark on it the places, paragraphs, or sentences in which you acted in accordance with this motive, that is, your motivation, as you say, to show that Serbs are not genocidal.

JUDGE MAY: Cross-examination is not a form of trick or anything like that or any sort of test for the witness. Now, if you want to ask the witness questions, you can, but he cannot possibly comply with that suggestion.

Now, rephrase your question.

THE ACCUSED: [Interpretation] The question, Mr. May, was to ask the witness to point to parts of his statement which corroborate what he says he's doing.

JUDGE MAY: I heard that, and I've told you that you cannot ask that question. It's not a test for the witness. It's not a proper ²⁶⁶²⁵ question, or a trick which you seem to be playing. Now, you can rephrase your question if you want to ask it, or you must move on to a new one.

THE ACCUSED: [Interpretation] Very well, Mr. May. I'll move on to other questions.

MR. MILOSEVIC: [Interpretation]

Q. Tell me, why did you say that for you there is no written trace that you ever took part in any kind of war operations?

A. I'll answer that question. According to the war assignment, I come under the military post 5055. Nowhere in my military booklet is it indicated that during the war I took part in the work of any unit of the VP 5055. Also, you know very well that all the documents for Bubanj Potok were burnt. I heard with my own ears when it was stated, that is a conversation between Bora Stanisic and Milan Prodanic who said that all those documents had been destroyed by fire.

Q. You mean there were minutes of those conversations between Stanisic and Prodanic and then they were burnt?

A. No. Minutes were not kept of their conversations, but the documents of VP 5055 that were sent to the front accompanying weapons and ammunition, those documents that went with the transports were burnt.

Q. Mr. B-179, you point out also that on many occasions you risked your own life for the convoys to reach places that were under siege; is that right?

A. Yes.

Q. Tell me, who could have killed you, as you say that you were risking your life? ²⁶⁶²⁶

A. Who could kill me? Among others, they could have killed me in Western Slavonia. Whenever we went to Zvecevo in a convoy, fire was opened at us from artillery weapons. Also, there were quite a lot of tricks when I was driving the truck to Sarajevo on the way there and back. If you remember the first convoy of the government of Serbia sent to Pale, Cvijan was on television announcing that a convoy of aid was leaving for Pale that morning. I didn't go early, as planned intentionally, but I left at noon, and instead of my column, another column was framed. Eleven drivers were killed from Milici who were transporting ore. I was told that the road to Milici from Zvornik was safe. I went around a different way. Instead of via Milici, I went via Sekovici to Vlasenica.

Q. Mr. 179, you say that you risked your life to reach the places that were under siege; is that right?

A. Yes.

Q. Who held those places under siege?

A. If you mean -- I can give you the example of Mirkovci. On one occasion, I was tasked to drive Dr. Aco Todorovic from the Emergency Ward and two technicians, only one arrived. However, when I reached Sid, the driver who was to take them over with other medical equipment didn't dare go. He was elderly man, and he was frightened, and he didn't dare go to Mirkovci.

That time, I asked the president of the municipality, Ljilja Popovic, as no one wanted to go with them, I continued with them to Mirkovci, and I passed through various barricades. I also crossed the Sarajevo airfield amid shooting, but my people didn't kill anyone. ²⁶⁶²⁷

Q. But who held those places under siege?

A. The Croatian army.

Q. So this means that Serbs in Croatia in many places were besieged.

A. Yes, they were.

Q. Did the Serbs attack the Croats and place themselves under siege or were they attacked and that is how they came to be under siege?

A. Mr. Milosevic, one could give you a very lengthy answer to that question. I've seen so much that I don't know whom to trust any more. I'll give you an example from those very Mirkovci. On that journey to Mirkovci, I was escorted by two tanks, a van that I drove, and another truck that was transporting weapons. Look at this absurdity of yours. In that truck there were weapons for Mirkovci. It was distributed to the citizens of Mirkovci. And in Mirkovci, you had one of the major warehouses of weapons and ammunitions. I think you are very familiar with this location, Vrapcana. I had a lot of trouble with offices of the state security of the army of Yugoslavia because of that warehouse.

Q. To tell you the truth, I don't know anything about Vrapcana and storage of weapons there.

A. You will understand, because from Vrapcana it was the Croatian army that was supplied with weapons and ammunition. An officer, a JNA officer, a captain would transport weapons to Vinkovci every morning in four trucks. In those days, he was the commander. The commander in Mirkovci was Belgan [phoen]. We asked those trucks to be searched one day and the captain would not allow it. And it is common knowledge when ²⁶⁶²⁸ trucks leave what they look like when they're full. You can see how heavy they are when they weigh down on the wheels, and you can see what they look like when they're empty. So you were arming both sides.

Q. We were arming both sides, were we?

A. Not we, but you.

Q. Very well, B-179. I hear that assertion for the first time. Now, tell me, please, as you say in paragraph 2 of your statement, you were a member of the Serbian Renewal Movement.

A. I was never a member of any party, of the League of Communists or any of your parties, but I joined the Serbian Renewal Movement precisely to topple your regime in 1998.

Q. Is it true that as a member of that party, the Serbian Renewal Movement, SPO, you must know that the SPO headed all the opposition activities directed against what you call the regime?

A. Let me tell you something, Vozdovac municipality, where I reside, the SPO was in power and the SPS and JUL. So you can't say that the opposition was in power. You were in power. I felt the consequences very well on my own back. Your authorities first tried to seize my house, then to destroy my --

Q. Let's not talk about your house and who wanted to seize your house, et cetera. I really wouldn't like to go into such things here now. As a volunteer during 1991, 1992, 1993, that is the period you're testifying about, you worked as a volunteer in the Association of Emigrants; is that right?

A. Yes. I was a volunteer in that association. When aid was asked ²⁶⁶²⁹ for Borovo Selo, Brano Crncevic announced over the media an appeal for help to Borovo Selo and to assist the refugees crossing the Sava River. I had a large boat that I made myself with two engines, Yamaha and Mercury, and I made a gift them to Borovo Selo and went there myself.

Q. Do you know how many volunteers in the course of 1991, 1992, and 1993 were sent by the SPO to the front in Croatia?

A. No. I had no interest in statistics.

Q. And do you remember when Vuk Draskovic founded the so-called Serbian Guards? I assume you know that.

A. I know something about it. I think there were offices also in Nusiceva Street. That is Vuk Draskovic's offices, close to the matica, in fact. As I say, I was never involved in politics. It never interested me.

Q. But Vuk Draskovic in those days was a politician who said that every hand that isn't a Serbian hand should be cut off.

A. No.

Q. You don't remember that statement of his? Was that a call for conflict and war or not?

JUDGE MAY: He doesn't remember the statement, so there's not much point asking him that.

THE ACCUSED: [Interpretation] Very well.

MR. MILOSEVIC: [Interpretation]

Q. Just to establish the real motives for your testimony, in addition to testifying here, as you yourself said, you are my political opponent. That's how you described yourself; isn't that right? ²⁶⁶³⁰

A. Mr. Milosevic, when you came to power, to be quite sincere, I thought an intelligent man had come to lead the Serbian people.

Q. Will you please answer my questions briefly.

A. Why briefly? I have to give you a full answer. I can't give you a yes or no answer. But with subsequent developments, I drew my own conclusions and an opinion about you, and formed an opinion about you.

Q. Is it true that you came to the Emigrants Association upon your own initiative, disturbed by the fact -- by the well-known event when Mr. Seskocevic [phoen] drowned, a man from Borovo Selo, because his boat capsized? And you contributed to the humanitarian fund for refugees from Croatia your own boat, you offered your own boat to transport people from Borovo Selo; is that right?

A. Yes. I gave them a metal boat that I made myself. It was for 12 men. A bullet couldn't pierce it because it was made of steel sheeting.

Q. And then you volunteered to transport refugees from Croatia and humanitarian aid through the only then established refugee camps; is that right?

A. Yes.

Q. And it was assumed at the time that, as a patriot, you wanted to help the humanitarian activities of the matica, of the association; is that right?

A. The humanitarian aid to the whole people, not just the matica.

Q. I'm talking about the humanitarian activities of the matica, of the association, which was distributing aid all over. That is not in dispute. ²⁶⁶³¹

A. No. No, it is not in dispute.

Q. Tell me, please, is it true from one humanitarian activity you didn't return? You stayed in Mirkovci of your own free will for a couple of months?

A. It is not true.

Q. According to information I have, you stayed there for a couple of months, and you did arms trading over there. Is that right?

A. No, it's not right, Mr. Milosevic. I entered Mirkovci nine times and left Mirkovci. Now, what kind of weapons could I trade in? Where would I get the weapons from?

Q. You enumerated enormous quantities of weapons that you allegedly transported.

A. I did.

Q. So that's why I'm saying you had them if you claim that you were transporting them.

A. I think I said a moment ago that I went to Mirkovci accompanied by a truck with weapons that was distributed in Mirkovci. I didn't say that I was transporting those weapons.

Q. Very well, Mr. B-179. (redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) ^{26632 BLANK PAGE 26633}

MR. GROOME: Your Honour.

JUDGE MAY: Yes. Yes.

MR. GROOME: Could I ask that this be redacted and any remaining questions about the specific position this witness held be taken in closed session or private session.

JUDGE MAY: Yes. Do you have any more questions on this topic, Mr. Milosevic? If so, we'll go into private session.

MR. MILOSEVIC: [Interpretation]

Q. Is it true, Mr. B-179, that convoys were organised occasionally when humanitarian aid had been gathered from various quarters, including from Serbs in the diaspora, and for the drivers, volunteers were chosen, and it could be a representative of the company who had collected the most food or sanitary material or even Serbs from the diaspora who were willing to go with that convoy of aid organised by the Emigrants Association?

A. No, that's not true. All -- I led all the transports with my men who were armed. No one else could have taken those transports. I headed all those transports of humanitarian aid from the Serbs Association.

JUDGE MAY: Deal with the other point the accused makes. He alleges that convoys were organised occasionally when humanitarian aid had been gathered from various quarters. Is that an accurate description of what was happening or not?

Yes. Could you answer, please.

THE WITNESS: [Interpretation] I see, you're asking me. Well, let me tell you, it was like this: I would take a humanitarian convoy from Vojvodina when the locals were sending aid for the Lika battlefront. It ²⁶⁶³⁴ consisted of 18 trucks. Those were those occasional convoys. What affected me most in those convoys, let me tell you straight away, when I reached the final destination, Gracac, it was requested that things would be loaded onto other trucks and taken to shops, to outlets, instead of being distributed to the people.

THE ACCUSED: [Interpretation] Can I move on, Mr. May?

JUDGE MAY: Yes.

MR. MILOSEVIC: [Interpretation]

Q. Mr. 179, Mr. Groome asked you to mention all the places you went to, and I wrote down here what you said. You say that you went twice in convoys that went to Zvecevo.

A. Yes.

Q. So that's right. But you didn't get to Zvecevo itself. You stopped somewhere; isn't that right?

A. No. I handed over my equipment at Bucje. That was equipment for a hospital, but I continued to Zvecevo with the rest of the convoy.

Q. When you handed over what you had for Bucje, there was a hospital at Bucje wasn't it, Mr. 179?

A. Yes, that's right.

Q. So you gave blankets and medicines and things of that sort to the hospital; is that right?

A. Yes.

Q. So you did not bring any weapons to Bucje, you gave them medical equipment, blankets and other things that a hospital needs?

A. Not me, but Bora Stanisic took the convoy further. I mentioned ²⁶⁶³⁵ that. And the other part of the convoy that went to Zvecevo was ammunition and weapons.

Q. All right. So you went twice in these convoys to Zvecevo. Once you went in a convoy to the region of Bosanski Brod; is that right?

A. I led that convoy. It was a purely military convoy. It wasn't humanitarian.

Q. All right. From what I see here, you say that you were in a convoy that went to Zvecevo -- rather, two for Zvecevo, one for Bosanski Brod and one that went to Sarajevo; is that right?

A. Inter alia, yes.

Q. Did you lead any other convoy except for these four that you mentioned?

A. Yes. I can list more if you wish.

THE INTERPRETER: The interpreters cannot hear the question.

JUDGE MAY: Repeat the question, would you, please. We're having some trouble with the monitors here. I take it that the transcript is still running. I'm told that it is.

Yes. Could you repeat the question, please, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. It was my understanding on the basis of what you said that you were in two convoys for Zvecevo, one convoy that went to the area of Bosanski Brod and one convoy that went to Sarajevo. That is what you mentioned in response to the questions put to you by Mr. Groome. Tell me now, what were these other convoys in addition to the four ones that you mentioned? What were the other ones that you were involved ²⁶⁶³⁶ in?

A. I can mention others. You probably remember the number of people in Smoluca, between 4.000 and 7.000 of them that were surrounded for months. I also led the humanitarian convoy that went to Smoluca. Is that perhaps incorrect as well?

Q. This is the first time I see you, and it's the first time I've heard of you. How can I say whether it was correct whether you led a convoy or not.

(redacted) (redacted)

A. Yes.

Q. And then you claim that -- you claim that you held a position for which I claim, according to the information provided by the matica, never even existed.

A. Well, officially for you none of us who were involved in this line of work existed.

Q. And you claim that this kind of position did existed and that you actually held that job?

(redacted) (redacted)

(redacted)

Q. All right. That does not explain at all what I'm asking you right now. In tab 9, you provided an authorisation given by the Matica of Emigrants, and you can see that it was signed by Brana Crncevic, president of the matica, and it says here in tab 9 that this is an authorisation ²⁶⁶³⁷ enabling a vehicle, a bus, TAM, registration plates such-and-such. It can be used on behalf of the Centre of Serbs and Emigrants of Serbia, Nusiceva 4 Belgrade, for the needs of refugees from Croatia. So you have this document where it says that you, as a bus driver, namely that this bus and that you as its driver have the job of meeting the needs and helping emigrants from Croatia, refugees from Croatia; is that right?

A. Yes. That is only one of the authorisations given for transporting persons, refugees, actually, to the prefabricated buildings of the Lazarevac mine. And what you've been claiming, that I never had that job and that I never received payments for it, I have a document, and I would like you to see it. The matica paid me.

JUDGE MAY: Wait a minute, you're giving evidence to a court, not a private conversation with him.

Do you know anything about this, Mr. Groome? What is it?

MR. GROOME: I'm not sure what document the witness is referring to now, Your Honour.

JUDGE MAY: Have we got anybody who can help translate it here? I doubt it.

MR. GROOME: I would be able to have it translated within the hour, Your Honour.

JUDGE MAY: We'll try and deal with this, Witness, by -- if you would hand it over to Mr. Groome, he can have a look at it and then we'll try and put it to the accused in a moment, but let's deal with it by starting with Mr. Groome. ²⁶⁶³⁸ Yes. Mr. Milosevic, go on.

MR. MILOSEVIC: [Interpretation]

Q. As regards this document, as far as I managed to understand what you were saying a few minutes ago, this is a document that confirmed that they paid you your salary; is that right?

(redacted) (redacted)

(redacted) (redacted)

Q. Mr. 179, that's the information I have --

JUDGE MAY: Now, look, if you're going to ask any more questions about the witness or his jobs, you must do so in private session. Now, you know those rules.

Now, do you want to ask any more questions along those lines?

THE ACCUSED: [Interpretation] Well, I just want to clarify this, Mr. May, but let's wait then and take a look at this document and then I'll put questions in connection with that.

JUDGE MAY: We'll go into private session for this.

THE ACCUSED: [Interpretation] There is no need for it.

JUDGE MAY: We will go into private session, and then we'll see if we can go into open session.

[Private session] (redacted)

(redacted) (redacted) ²⁶⁶³⁹ (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

[Open session]

THE REGISTRAR: We're in open session.

MR. MILOSEVIC: [Interpretation]

Q. All right, Mr. 179. You say that during the war, the matica distributed to the Serbs in Croatia some assistance and that 80 per cent were donations given by Serbs who lived abroad. Is that what you said?

A. Yes. Humanitarian aid.

Q. That's the kind of assistance I'm talking about, because that is what the matica dealt with, humanitarian aid.

And then you say that the government of Serbia financed the matica. Do you know for how long the matica has been in existence?

A. I know that it's been in existence for a very long time. I don't know exactly how many years.

Q. So you don't know. ²⁶⁶⁴⁰

A. No, I don't.

Q. Then I'm not going to ask you about that. And is it correct then, Mr. B-179, that Serbs, regardless of whether they were Serbs from the diaspora or Serbs from Serbia itself, used the matica, the association, to send humanitarian aid through it in various forms to Serbs in Bosnia and to Serbs in Croatia?

A. Yes. The matica was used for that. Who else? At any rate, all assistance coming from the diaspora went through the matica for the most part. After awhile the bureau of the Government of Republika Srpska was opened, and then part of this aid went through them. I can also tell you that there were two trucks that were used by the matica were actually given to this bureau of the Government of Republika Srpska so that they could use them for this aid. These were actually trailer trucks from Bugojno.

Q. Let's clarify this, Mr. B-179. Matica did receive donations, financial donations, from citizens of Serbia, from emigrants, and used that money to buy food, medicine, and other things that they sent by way of humanitarian aid; is that right?

A. Yes, that's right.

Q. The matica decided how and in which way it would use the money it received by way of donations, and they used that money to send aid to those they thought were needy.

A. Yes.

Q. Is that right?

A. Yes. ²⁶⁶⁴¹

Q. Is it correct that this money was used as humanitarian aid only and no weapons were ever bought from that money?

A. As far as I know, that's correct. Weapons were never bought.

THE INTERPRETER: Microphone, please.

MR. MILOSEVIC: [Interpretation]

Q. Is it correct that humanitarian aid often came in the form of food, medicines, clothing, and other things that were needed and that were then again sent through the matica to the places where the population was in greatest peril?

A. That is correct. There was a hall at Belgrade fairgrounds where all these things were accumulated and then sent further on by way of humanitarian aid.

Q. All right. This hall at the Belgrade fairgrounds where all the aid came to, this was primarily clothing, medicine, food, blankets; other things that were needed. There weren't any weapons there; isn't at that right?

A. Well, not really. Once I brought some 120-millimetre mortars to that hall from the warehouses, the military warehouses.

Q. You brought mortars to the hall of the Matica of Emigrants?

A. Yes, I did.

A. From your testimony here and from the documents that you provided, I saw that you stated that the only exception was when a few radio transmitters were taken to some headquarters in Croatia and Bosnia, and you proved that by way of some document, and you say it was signed by Biljana Plavsic. Is that right? ²⁶⁶⁴²

A. Yes. Yes. That's right. But there is another thing. You forgot that I also had parking space for trucks at the entrance into Belgrade fairgrounds, on the right-hand side. That is where the vehicles with ammunition and weapons were.

Q. It is not clear to me. Could you please explain this to me. Where did these vehicles with weapons and ammunition come from to the parking space of the matica? What were they doing in the parking space of the matica?

A. Well, let me tell you. Precisely because they were not supposed to spend any time in Bubanj Potok, they were not supposed to spend any time at the MUP warehouses. They had to be kept in innocent locations, if we are going to call them that. As a matter of fact, even at my own plot of land sometimes these trucks with ammunition and weapons were kept so that the public could not be aware of them.

Q. You kept such trucks at your very own plot of land? Did somebody from the matica tell you that you should keep trucks with weapons and ammunition on your own plot of land?

A. Bora Stanisic and Milan Prodanic did. Don't tell me that Milan Prodanic was not acting on your instructions.

Q. I did not have any -- as far as I know, Milan Prodanic is an official of the state security.

Tell me now, this document that you provided here in relation to the radio transmitters and you say that it was signed by Biljana Plavsic, is this a document that you gave to the investigators or did the investigators give this document to you? ^{26643 BLANK PAGE 26644}

A. No. I gave this document to the investigators. I picked up Biljana Plavsic that time at the government of Serbia. I used my own car to take her to the airport in Batajnica where she boarded a helicopter, and that's where she signed this document for me that she received these radio transmitters.

THE INTERPRETER: The interpreters did not hear the question.

THE WITNESS: [Interpretation] Yes.

MR. MILOSEVIC: [Interpretation]

Q. Where did these radio transmitters come from?

A. They by JAT aircraft from Germany, Yugoslav Airlines aircraft from Germany.

Q. All right. Tell me now: You say that the president of the matica, Brana Crncevic -- was Brana Crncevic. He's a writer otherwise. You know that, don't you?

A. Yes.

Q. He's a well-known writer.

A. Yes.

Q. You say that he was a member of the Socialist Party of Serbia.

A. Well, I'll tell you now, now, whether he was a member of the Socialist Party -- you answer my question: Was he at the congress of the Socialist Party of Serbia in Sava centre as an associate member of the Socialist Party of Serbia?

Q. Brana Crncevic was never a member of the Socialist Party of Serbia, and he could have been there as a guest at some event, including the congress itself, but he was never a member of the Socialist Party of ²⁶⁶⁴⁵ Serbia.

A. He used to say that he was an associate member. I don't know what it means to be an associate member.

Q. He could not have said that he was an associate member because he was not a member.

JUDGE MAY: This is just a waste of time, this kind of discussion. Let's move on.

THE ACCUSED: [Interpretation] All right.

MR. MILOSEVIC: [Interpretation]

Q. Is it clear to you that Brana Crncevic could have been only one of the many guests there? In no other capacity could he have been there because he was not a member.

JUDGE MAY: No. This is a point you know about, whether he was or not a member. The witness doesn't. So what is the point of wasting time like this on it?

MR. GROOME: Your Honour, I have that document now returned to court if the -- I'm not sure -- I can summarise basically what it is. It is unclear to us at this stage its relevance, but it's basically a contract signed between the -- this witness and other person of a fund that seems to have some dealings with the association or the matica.

JUDGE MAY: Very well.

MR. GROOME: It's there if the Chamber --

JUDGE MAY: Just remind me what the matica association is.

MR. GROOME: It's the Association of Serbian Emigres.

JUDGE MAY: It's also known as the matica. ²⁶⁶⁴⁶

JUDGE KWON: I think "matica" is translation of "association."

MR. GROOME: In Serbian, yes.

JUDGE MAY: Yes.

MR. GROOME: A proper translation is being done now. I'm not sure it will be down within the next few minutes, but it should be down before the cross-examination concludes.

JUDGE MAY: It may not matter for the moment. Is this a matter which should be dealt with in private session? We'll deal with the document.

MR. GROOME: I think it should be, Your Honour, yes, if the accused is going to ask questions about this document.

JUDGE MAY: Let us go into private session, and let the accused see the document.

[Private session] (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted) ²⁶⁶⁴⁷ Pages 26647 to 26650 - redacted - private session. ²⁶⁶⁵¹ (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted)

[Open session]

THE REGISTRAR: We're in open session.

MR. MILOSEVIC: [Interpretation]

Q. So this document by way of which the fund of the Serbian Association Nikola Tesla from Zurich is sending some equipment cannot be evidence that the Association of Emigrants of Serbia used its own money to purchase that equipment. Would it be fair to say that all donations ²⁶⁶⁵² received by the Association of Emigrants of Serbia were used to buy humanitarian aid for those who were in the greatest need?

A. Yes. That's precisely what we said. That is not in dispute. That is the truth.

Q. Thank you. Thank you very much. Are you aware, since you are talking about Brana Crncevic, do you know that he was at that time deputy to the Assembly of Serbia but as an independent deputy, a non-party candidate? He was not a member of any party, including the Socialist Party of Serbia.

A. I know that he was an assemblyman, but whether he was independent or not, I don't know. I never was involved in politics. I was not interested, and I'm still not interested.

Q. In paragraph 7 of your statement, you say that in relation with the activities you were involved in, that you know that the Association of Emigrants transported more than 1.200 trucks with ammunition, weapons, and humanitarian aid to Krajina and the territory of the Republika Srpska. Do you say that here?

A. What I said is this: Among other things, the Association of Emigrants was involved in the transport of these 1.200 trucks. MUP vehicles and civilian vehicles and vehicles that came from the battlefield were also involved, not only the association.

Q. I want us to clear up one thing here. The Association of Emigrants of Serbia dealt in humanitarian aid. It did not deal in nor did it own any weapons that it could have sent to anyone. Is that true, Mr. 179, or not? ²⁶⁶⁵³

A. Well, Mr. Milosevic, then why would I or my men get these weapons?

Q. We'll come to that because that is the only specific matter related to weapons and the Association of Emigrants. That's tab 10, and I would like you to look at it. It's signed by Brana Crncevic. It's possible that such a document exists.

"Please issue for the purposes of the Association of Serbs and Serbian Emigrants for escorts of convoys and security to issue the following things: 15 automatic rifles, 8 pistols, 4 automatic pistols, 500 rounds and appropriate ammunition."

So 15 automatic rifles, 8 pistols, 4 automatic pistols, and 500 rounds. But it is specified very clearly for the purposes of escorting convoys and security. We are talking about the security of those convoys carrying humanitarian aid. Is that correct, Mr. 179?

A. Yes. This is the only document that passed through regular procedure, through the ministry, and there are many other documents.

Q. And if the association disposed of large amounts of weapons, as you say, why would it need to apply for these small amounts of weaponry for its own security?

A. It had to apply because these people had to have appropriate licenses for carrying these weapons. And in order to have these licenses, you had to prove to the Ministry of Defence that you had received these weapons. In the beginning, it was Boro Stanisic who signed these licenses, and later on I got blanks of these -- blank forms of these licenses and I issued them myself and distributed them.

Q. For the purposes of securing convoys. Let me read here in ^{26654 BLANK PAGE 26655} handwriting. "Boro, please issue them by numbers under receipt valid up to two months, after which they should be returned."

A. Yes, but that was only pro forma. "Bora" is Bora Stanisic from Bubanj Potok.

Q. Is that what's written here. He must have been somebody who was authorised to order the person in charge to issue those weapons; is that correct?

A. Yes. That must have been somebody in the government, and who from the government signed it, I don't know. You are in a better position to know than I am.

Q. All right. Is it then clear from these documents that you produce here that the only weaponry applied for by the Association of Emigrants is the weaponry needed by men who were securing its convoys, because the convoys were travelling on unsafe roads through Croatia and Bosnia and Herzegovina and needed security; is that correct?

A. Yes, Mr. Milosevic. This assumption of yours is correct. The association did have a humanitarian line of work, but it had another line of work as well which you keep avoiding. Why don't you ask me a question about that part?

Q. Well, I have information here that Brana Crncevic had never any contact whatsoever with any military post, including this military post 5055, in his capacity as president of the Association of Emigrants. He had nothing to do with it. As far as I can see, he didn't even address this military post for this weaponry for securing convoys. He wrote to the Defence Ministry. ²⁶⁶⁵⁶

JUDGE MAY: Let the witness answer these assertions. Yes, Witness B-179.

THE WITNESS: [Interpretation] Well, you see, Mr. Milosevic, you claim one thing and I claim another.

Brana Crncevic was a very good friend of both you and Jovica Stanisic, and as far as I know, you met very frequently. For you to deny something that I know about is not really possible. I even met up once with Jovica Stanisic when Boro got his rank of colonel. He was involved in the same line of work involving weapons and ammunition, and Crncevic was there and Jovica Stanisic and Milan Prodanic was there.

Q. So what is that supposed to confirm? Do you mean that it confirms that Brana Crncevic maintained special relations with that military post 5055?

A. Not the military post 5055 but with the MUP of Serbia, the state security department, and with you.

Q. He was a good friend of Jovica Stanisic, and he's a good friend of mine - Brana Crncevic, I mean - but that has nothing to do with what we're talking about here. You even go --

JUDGE MAY: You don't dispute that he was a friend of yours, Crncevic; is that right?

THE ACCUSED: [Interpretation] It is well known, Mr. May. Brana Crncevic is a well-known writer, president of the Emigrants Association of Serbia. He was my friend. But that has nothing to do with his alleged activities that he allegedly engaged in arms trafficking, et cetera.

MR. MILOSEVIC: [Interpretation] ²⁶⁶⁵⁷

Q. You say that you drove Brana Crncevic to my house?

A. Yes.

Q. Witness 179, let me tell you that Brana Crncevic was never in my house, never.

A. Is your house, Mr. Milosevic, across the road to the former president of Yugoslavia, that writer?

Q. He is in a different street. Quite close by, but in a different street that is at right angles to my own street.

A. Yes, very close. I know I drove him to your place. He told me that I was driving him to his place.

Q. I don't believe that he could have said that, because he never went to my house.

A. So you never had whisky together?

Q. We certainly did, but not in my house. Brana Crncevic was never in my house.

JUDGE MAY: We've heard that. We've heard the witness's response. He says that he took this man there.

MR. MILOSEVIC: [Interpretation]

Q. That is an absolute falsehood. Brana Crncevic was never in my house.

A. You said that whatever I said was not true.

JUDGE MAY: Sometimes you must understand that constant repetition of a point doesn't improve it.

THE ACCUSED: [Interpretation] Very well, Mr. May. What then can I say about this allegation: Slobodan Milosevic, Jovica Stanisic, Brana ²⁶⁶⁵⁸ Crncevic, and Mihalj Kertes and some others usually met in the morning at the premises of the state security and discussed deliveries to the SAO Krajina and Republika Srpska.

MR. MILOSEVIC: [Interpretation]

Q. Did you say that?

A. Yes.

Q. Mr. 179, I'm being accused here as an autocratic ruler that everyone came to consult. I don't see how now you should give a completely different impression. Can you imagine me beginning my working day by going to the state security service to meet with various people in that service, and then I go to my own office? Don't you understand how nonsensical that is?

A. I certainly didn't make your own timetable. I'm saying what I heard about meetings.

Q. That I first go in the morning to the security service and then to my office?

A. No, not every morning but occasionally. I didn't say you went there every morning.

Q. Meetings in the state security service could be attended by people working in that service and not by someone else. What would Brana Crncevic and Mihalj Kertes be doing there, not to mention me? Where did you get that idea from? Who gave you this information?

A. Well, I was in the state security at MUP Serbia on one occasion with Mihalj Kertes.

Q. Were you there perhaps when I was attending a meeting? ²⁶⁶⁵⁹

A. No. I heard that from Milan Prodanic, your man.

Q. I see. You heard that from someone.

A. Not someone, from Milan Prodanic, head of the 6th department of the state security of the MUP of Serbia. Maybe you're going to tell us that you don't know him or that he doesn't know me.

Q. How do I know who Milan Prodanic knows and who knows Milan Prodanic? I am telling you that this is absurd when you say that I, in the morning, go to these premises --

JUDGE MAY: You've made that point, and the witness has given his answer, so let's move on.

THE ACCUSED: [Interpretation] Very well.

MR. MILOSEVIC: [Interpretation]

Q. Let's clear up a few more matters, please. You say that you met with Radovan Karadzic in a rather strange manner. Actually, it is true that not once but several times that we from Serbia did send humanitarian convoys to the citizens of Sarajevo on a non-discriminatory basis, which means to both Serbs, Croats, and Muslims. You're aware of that, I assume.

A. I led the first convoy that went there.

Q. The first convoy. I see. So then you know that Serbia sent a convoy to the citizens of Sarajevo, both Serbs, Croats, and Muslims; is that right?

A. Yes, I know that.

Q. Very well. Now, from what you say, it emerges that the convoy was stopped or, rather, that Karadzic met with you to stop the humanitarian aid and then that you demanded of Karadzic that the very next day he ²⁶⁶⁶⁰ should remove obstacles and barriers and patrols from the roads, and then he got scared and removed them and allowed you to go on.

A. It's beautiful really the way you've interpreted this. Let me put it in a slightly different way. This aid from the government of Serbia, a part was for Pale and the second part for Sarajevo. When I arrived at Pale, the first thing that I was told was to go to Karadzic's villa for dinner. I sent some of my men to that dinner, but I stayed behind with two other men to secure the vehicles, and then later on I went to that villa too. And the first problem was that my men were disarmed at the entrance to this villa, and I was very angry, which that meant they didn't trust my men with weapons and they were armed, which meant that I didn't trust those men either.

Biljana Plavsic was there with her sister. She knew me. And then she asked me to wait until she went to see Karadzic. She went to see him, and then he invited me to come upstairs to his office. I went there. They required that all the humanitarian aid be unloaded at Pale. There was a debate, quite a fervent one. Four trucks of that convoy were supposed to go to Sarajevo. At first, he wouldn't allow those trucks to go to Sarajevo, and then he called up someone -- no, not someone, Djuretic. He was one of the assistants for Serbs outside Serbia. And I knew Djuretic personally.

He asked Karadzic on the phone who was there, and he told him my first and last name, and then Karadzic gave in and allowed those four trucks to leave for Sarajevo. At great difficulty and in spite of heavy fighting on the Sarajevo airstrip, I managed to reach Sarajevo without any ²⁶⁶⁶¹ serious problems. I reached the police station at Ilidza. I couldn't go any further, and those four trucks were unloaded there.

Q. Witness 179, without offence, I have no intention of insulting you. My questions are based on what you wrote in your statement. So let me remind you what you wrote in your statement on page 5. I think you have that statement in front of you.

This is in paragraph 15, which is quite a long one. I won't read it all.

"The aid was meant for all ethnic groups, not only Serbs. I stopped in Pale and had a meeting with Radovan Karadzic who wanted to stop me from going to Sarajevo. He wanted me to hand over that aid to the Red Cross in Pale. I knew his wife was the president of the Red Cross in Pale, and I also knew that they used to sell the humanitarian aid they received in the warehouses. I told him that I would leave for Sarajevo the next morning and that he should remove his patrols from the road because I would shoot if I saw anybody in uniform." So you went to Karadzic who wanted to keep the humanitarian aid. You threatened to shoot, and then they got scared and removed everything, and you were able to reach Sarajevo. Isn't that right what emerges from this paragraph? You say: "I managed to deliver the aid in Sarajevo."

A. Yes, that is true. I said that I would shoot if anyone stood in my way. Don't believe that I'm lying. I know very well what I was doing and what I'm saying.

Q. Witness 179, I'm just quoting what you said. "To remove patrols from the roads because I would shoot if I saw anybody in uniform." ²⁶⁶⁶²

A. Yes. If he stood in my way, I would shoot.

Q. And then in the face of such a threat of yours, they let you go on to Sarajevo.

A. I don't know whether it was because of this threat or because of the conversation with Djuretic from the Ministry for Serbs outside Serbia, but I said what I said and I stand by what I said.

Q. Is there any document whereby Brana Crncevic, as president of the Emigrants Association, or anyone on -- anyone else on his behalf signed any kind of permission or authorisation for the transportation of weapons?

A. Brana Crncevic did not, but I did.

Q. I see. You signed on behalf of the Brana Crncevic.

A. No, in my own name but on behalf of the Association of Serbs. That was my part -- a part of my duties.

Q. Would you be kind enough to show me what it is that you signed on behalf of the Association of Serbs. I see tab 11 here. Four automatic rifles, two pistols, two automatic pistols. This is linked to the request that we quoted from a moment ago; isn't that right?

A. Yes, but there are other requests too.

JUDGE KWON: [Microphone not activated]

THE ACCUSED: [Interpretation] In this document which seems to be a photocopy, Mr. Kwon, and which has the number ERN 03269340, it is a handwritten document. Under number 1 is an automatic rifle, 7.62, four pieces. And then a 7.62 pistol, semi-automatic, 2. Then a pistol 7.62, automatic 2, and then the rest has to do with bullets or rounds. That is what is linked to this letter of Brana Crncevic's where he ²⁶⁶⁶³ says: "We request that for the needs of the Association of Serbs for the escort of the transport and its security you issue the following," and we see that less was issued than requested. And it says: MORS, which I assume, means the Ministry of Defence of the Republic of Serbia; isn't that right?

JUDGE KWON: Yes, but English translation says the number of quantity of pistols at 12. Whether OTP can confirm that.

THE ACCUSED: [Interpretation] Mr. Kwon, I hope that you yourself, regardless of the fact that this document is in Serbian, you can see the numbers in column number 5, and the heading for that column is "Quantity" and the numbers are indicated by hand, 422, and then the ammunition.

JUDGE KWON: Yes, I see that.

THE ACCUSED: [Interpretation] Now, how they translated that, I --

JUDGE MAY: Mr. Groome, perhaps you'd look into that. It does seem to be inaccurate.

MR. GROOME: Yes, Your Honour. I would concede that it does appear to be to somebody misread the way the person made the 2 as really being a one and a two.

JUDGE MAY: So we need a new translation.

MR. GROOME: Yes, Your Honour.

JUDGE MAY: Yes, Mr. Milosevic.

MR. MILOSEVIC: [Interpretation]

Q. Then the other receipts, the one with the ERN 341, ending with 341, refers to six rifles, then the other one two rifles, and then when you add all that up, it roughly amounts to what you requested. ²⁶⁶⁶⁴ On the back side of this receipt, I assume, are the names of the people to whom these weapons were issued, and I suppose the serial numbers of those weapons. Is that right, Mr. 179? It's just one of the documents.

THE INTERPRETER: Microphone, please.

MR. MILOSEVIC: [No interpretation]

JUDGE MAY: There is some difficulty about the interpreters hearing. Can we start again, please.

THE ACCUSED: [Interpretation] I was saying, Mr. May, that in tab 10 is the letter from Brana Crncevic requesting these 15 rifles and eight pistols for the escorts and security of a convoy, and this was addressed to the Ministry of Defence. And then in tab 11, we have the receipts whereby those weapons were issued. On the first one, four plus two plus two; on the second receipt six rifles; and on the third receipt two; which means a total of 12. One could add up the other items, but all this fits within the context of this letter requesting weapons for the escort and security of a convoy, and it all amounts to some 15 weapons.

JUDGE MAY: Just a moment. Just a moment. That's your interpretation. Let the witness answer it.

THE WITNESS: [Interpretation] Mr. Milosevic, it is true that that was requested of the Ministry of Defence, but also there are many, many things whereby the Ministry of Defence was sidestepped, has nothing to do with the Ministry of Defence. You just read out what is there, but I have many more such documents.

MR. MILOSEVIC: [Interpretation] ^{26665 BLANK PAGE 26666}

Q. I'm referring to tab 11. I was going from one document to the next. I can't read what I don't have in front of me.

A. You see, Mr. Milosevic, I have a permit to carry weapons and ammunition which doesn't exist among these documents, and I have a licence signed by Bora Stanisic for a M-84 machine-gun, a heavy machine-gun. You won't find that weapon anywhere here. Then I have a licence for a pistol, CZ-799. Also you won't find that in these documents. What I'm trying to say is something else: There were documents, these minor quantities, to account for them, but for the others, you won't find them.

Q. Surely, Mr. 179, to cover such vast quantities of weapons that you say you transported cannot be accounted for by this collection of receipts which, when added up, amounts to 12 or 15 pieces of weaponry. Surely this request of Brana Crncevic asking for some weapons for the security of the transport and your own personal safety cannot account for that large quantity.

A. Mr. Milosevic, that applies to only that part of the weaponry. I had a far larger number of documents. I don't know whether you know that you searched my house, looking through my dirty linen and everything else, and that you seized a good number of those documents.

Q. Mr. 179, I heard of you for the first time and saw you for the first time today, and be sure that I did not search your house.

A. But people from the state security did.

Q. Do you know how an apartment can be searched?

A. I do know that very well.

Q. There has to be a judicial order. ²⁶⁶⁶⁷

JUDGE MAY: We're going to have to break there. Mr. Milosevic, you will have ten minutes left.

We will go into private session to deal with an administrative matter.

[Private session] (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) ²⁶⁶⁶⁸ (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted) (redacted)

(redacted)

--- Recess taken at 12.18 p.m.

--- On resuming at 12.45 p.m.

[Open session]

JUDGE MAY: We are in open session. Yes, Mr. Milosevic.

THE ACCUSED: [Interpretation] Mr. May, I cannot finish the examination of this witness within ten minutes.

JUDGE MAY: Well, do what you can.

THE ACCUSED: [Interpretation] All right.

MR. MILOSEVIC: [Interpretation] ²⁶⁶⁶⁹

Q. Mr. 179, please give me brief answers to my questions. In paragraph 8, you said that the military equipment came from military post code 5055 in Bubanj Potok which was the storage facility of the command of the town of Belgrade, city of Belgrade; is that right?

A. I really have a problem. I'm receiving the English interpretation.

Q. Should I repeat my question?

A. I didn't hear it.

Q. In paragraph 8 of your statement, you say that the military equipment came from military post code 5055 in Bubanj Potok, which was the storage facility of the command of the city of Belgrade; is that right?

A. Yes.

Q. And do you have any proof that a certain type or amount of weapons from this source was delivered, as you claimed, through the matica to the Krajina or Republika Srpska?

A. I have travel authorisations.

Q. I did not see among your papers here, the ones accompanying your statement, a shred of evidence to support this claim of yours, so I'm asking you whether you do have any proof.

A. I do have proof. You saw from the approval of the Ministry of Defence itself. You see that there is only one document concerning the giving of weapons to the matica for meeting the needs of our people.

Q. That is the evidence that we already discussed, and that is a set of receipts issued for purposes of providing security for transports on the basis of an order that is -- and the number is on each and every one ²⁶⁶⁷⁰ of them. That is 332/2, dated the 20th of June, 1991.

A. Yes.

Q. So is that the only proof that you have?

A. No. There's also Gabos concerning the 82-millimetre mortar shells.

Q. All right. If you say that you have this evidence concerning 82-millimetre mortar shells --

A. Yes.

Q. Tell me then, please -- take that document, then. That is a page ending with the numbers 8383. You say that you personally received these mortar shells, the ones that are specified in this document; is that right?

A. Yes.

Q. Who did you receive them from?

A. Well, you see, at that time it was not allowed to have people sign, those who gave them to you. It was Boro Stanisic who gave them to me, but it does give the number, the military post code number 5055.

Q. As far as I can see here, please look at 8, 9, 10, items 8, 9, 10 on this document. Tell me, which weapons were issued, who is the order issuing authority? Who received this? All of these spaces are empty, Mr. 179?

MR. GROOME: Your Honour, if I may be of assistance. Mr. Milosevic and the witness are talking about two different documents. The document Mr. Milosevic has referred the witness to is tab number 12.

JUDGE MAY: Yes. ²⁶⁶⁷¹

MR. MILOSEVIC: [Interpretation]

Q. Item number 8, handed over. Number 9, received; 10, order issuing authority. And the space there is empty, all three boxes.

A. It is correct all three spaces are empty, because no signatures were placed there. That was the beginning when the war had just started, but the receipt was issued by military post 5055 and, also, there is the stamp of the matica.

Q. The stamp that you placed and your signature. But as opposed to the other receipts where persons signed their names, those who issued orders, who received this, who handed it over, and also mention is made of the order that is relevant. Here all these spaces are empty.

A. Well, this proves that I am one of the people who did not exist at that time of yours.

Q. Mr. 179, this proves that that is a forgery.

A. No. No. I never forged any such thing, nor did any such thing ever cross my mind.

Q. All right. Can we agree at least that here in the spaces assigned for "issued by," "received by," "ordered by," there is nothing written in these boxes?

A. We can agree on that.

Q. Now look at the document whose ERN number ends in 385. This is a receipt too. Is it clear that what is written here, "Rifles are taken over and returned --"

JUDGE MAY: Let the witness have the document.

MR. MILOSEVIC: [Interpretation] ²⁶⁶⁷²

Q. It says -- it says, "Received, handed over, and order issuing authority."

MR. TAPUSKOVIC: [Interpretation] Your Honours, if I can help, this is tab 11, the one but last receipt.

JUDGE MAY: Thank you.

MR. MILOSEVIC: [Interpretation]

Q. It says: "Issued by," "received by," "ordered by," all of it is written, and it also says that the weapons are taken over and returned to Bubanj Potok for the needs of the convoy of the government of the Republic of Serbia. Is that right?

A. Yes.

Q. So it says on this document, like on the others, that for the weapons received, they should, rather, be returned to Bubanj Potok and that this is for the needs of the government of Serbia.

A. Yes.

Q. Were these weapons also issued on the basis of document 3/132/2?

A. Possibly. Possibly, but I doubt it. I doubt it, because a great many weapons were issued while the Ministry of Defence was sidestepped.

Q. But on the receipt it says KOGB, and the number is number 3/132/2. All of this pertains to the weapons that were requested for providing security for the convoy. Is that right or is that not right, Mr. 179?

A. All the receipts that were issued by the command of the city of Belgrade have this designation KOGB, and also at the request of the government of the Republic of Serbia. However, as far as I know, the ministry of the Republic of Serbia, the Ministry of Defence did not take ²⁶⁶⁷³ part in this, and they could not have known about this because this was known by a very small circle of people.

Q. Oh, so the Ministry of Defence did not know about this? Only you knew about it and a few other people, and me.

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

Q. Oh, very well. But you don't have a shred of evidence for that.

A. You will receive evidence.

Q. Well, now is the time for you to provide this proof because you are testifying now.

Tell me now, you also gave a letter here addressed to the Association of Emigres - 0290873 is the ERN number - and the head from Donji Lapac, a certain Dusko Vojvodic, is sending this, and he is asking for some military equipment from the Association of Emigres.

JUDGE MAY: Let the witness have the appropriate tab.

MR. GROOME: It's tab 8, Your Honour.

JUDGE MAY: Yes. Let the witness have it.

MR. MILOSEVIC: [Interpretation]

Q. Uniforms, blankets, automatic rifles and the rest are requested here; is that right?

A. Yes.

Q. Tell me now, in addition to the Association of Emigrants, is any other state authority mentioned here, either of Yugoslavia or of Republika Srpska?

A. No. No one is mentioned here, but it is well known. This came to the Association of Emigrants, to Brana Crncevic. He gave me this ²⁶⁶⁷⁴ document, and with this document I went over to Bubanj Potok, and I handed it over to Bora Stanisic. Bora Stanisic handed this over to Milan Prodanic, and then decisions were made as to where things would be sent.

Q. Please. Do you have any evidence that the matica addressed the JNA or the Territorial Defence of Serbia or the Ministry of Defence in relation to this request? So the matica is requesting weapons for providing security for the convoy, and they are not sending a request in relation to this; is that what you're claiming?

A. Yes, that's precisely what I'm claiming. I've been telling you all the time that the Ministry of Defence was sidestepped. Very few people knew about these supplies and these convoys, and it's impossible that you did not know what the state security of the MUP of Serbia was doing, Jovica Stanisic and Prodanic.

Q. You do not have a single document to prove this. I'm asking you - so I'm not going to claim anything - can you show a document which confirms that you --

JUDGE MAY: All of this argument. You're arguing with the witness again, wasting time. He gives his evidence. He's not to be argued with. Now, you can ask him about the document, of course, but that's as far as it goes.

THE ACCUSED: [Interpretation] I'm not arguing. I'm not arguing, Mr. May. I am asking the witness whether he can show me any document confirming whatsoever.

JUDGE MAY: That is the matter of argument. He's produced the documents he has. It is for you to ask him about it. There's no need to ²⁶⁶⁷⁵ argue with him further when he has produced here what he has.

THE ACCUSED: [Interpretation] Mr. May, isn't it clear that this kind of request could have lost its way and reached the matica? It's not that that the matica had any weapons at their disposal. That's why I'm asking the witness whether he had any document.

JUDGE MAY: He has told you that the matica was distributing the weapons. You dispute that, and so there is really very little point in going on and arguing about it. He has given his evidence quite plainly. Here was the matica distributing weapons all over Croatia and Bosnia. You say that's not true. We will have to make our minds up where the truth lies.

THE ACCUSED: [Interpretation] All right.

MR. MILOSEVIC: [Interpretation]

Q. Let me just clarify the following point: You claim that the matica did not address itself to the government or other official authorities, but that they directly took weapons from the 5055 storage facility and that they were allowed to do so?

A. Yes.

Q. All right. You also claim that the command of the military post also issued weapons and military equipment to the matica without any kind of certificate?

A. Not to the Matica. They gave it to me, and I took it further on to the front line.

Q. Do you have any kind of certificate to prove that? So it was issued to you without a certificate? ^{26676 BLANK PAGE 26677}

A. Mr. Milosevic, I have travel authorisations here, and I also have work authorisations here and you can also see that they bear the stamps of 1055 here and of the Territorial Defence of the Republic of Serbia and the stamps of the matica, the Association of Emigrants of Serbia, and I drove vehicles with weapons of the -- with the registration plates of the Yugoslav People's Army and military licence plates, civilian licence plates, and you cannot tell me that this is not correct when this is correct, and everybody knows that full well.

Q. I'm not talking about your travel authorisations now. Does that prove that you carried weapons?

A. In the travel authorisation, there are also -- there are only the numbers of the vehicles.

Q. Numbers of vehicles. And then you were allowed to be involved in transport, and you transported humanitarian aid of the Matica of Emigrants.

A. Yes.

Q. And I assume that the Association of Emigrants did not have weapons but humanitarian aid.

A. And then why would the matica use registration plates of the Yugoslav People's Army?

Q. The Association of Emigrants, as far as I know, begged everybody for assistance in terms of transportation vehicles for transporting humanitarian aid. Everybody, private owners, the army, state organs, economic organisations, because they themselves did not have any such thing. Is that right or is that not right? ²⁶⁶⁷⁸

A. No, it's not right, Mr. Milosevic. Precisely from the matica a MAN trailer truck went that belonged to the Bugojno forwarding company of the MUP of Serbia and I precisely gave this vehicle that was used by the Ministry of the Interior, that is to say, the state security for transporting military equipment and weapons.

Q. That is what you say, Mr. 179, because you said that on the basis of this order 3/132/2 -- do you at least have that order on the basis of which these weapons were being issued and this would cast more light on the nature of the receipts that you provided here, and then we could perhaps establish what all of this is about, because so far we've established only that these were rifles for providing security for convoys, and that's the only thing that's registered?

JUDGE MAY: Look, Mr. Milosevic, that's what you allege. We've heard the witness's evidence as to what it was that was being transported, but you've got -- we'll allow you two more questions. You've already had over the time which we allotted. Now, two more questions.

MR. MILOSEVIC: [Interpretation]

Q. All right, then. Then I'll put this question: To whom did you deliver, since you say you were delivering weapons to Zvecevo, to whom did you deliver them in Zvecevo?

A. As far as I remember, it was -- whether he was a lieutenant colonel or colonel, I'm not sure, but he was from the Novi Sad Corps who had come to Zvecevo.

THE INTERPRETER: The interpreter couldn't hear the question.

THE WITNESS: [Interpretation] No, no. ²⁶⁶⁷⁹

MR. MILOSEVIC: [Interpretation]

Q. All right, then. Tell me one more thing. You state that you had carried money from the Topcider mint to Krajina.

A. Yes.

Q. Was it at the time when the dinar of the Republic of Serbian Krajina was introduced?

A. Yes.

Q. Does it mean, then, that the mint of the National Bank of Yugoslavia at Topcider provided services for the needs of the Republic of Serbian Krajina?

A. I don't know whether they provided services. All I know is that I was ordered to load up the money and carry it there.

Q. To whom did you deliver the money?

A. Frankly, I don't know. I know Jova Danilovic drove the truck with the money. I only added one padlock to avoid possible problems. He delivered to somebody in Knin. To whom exactly, I don't know. All I know is that there was another amount of money with foreign currencies loaded up there and carried back.

Q. Who gave you that money? Who handed it over to you?

A. Nobody handed it to me. They handed it to my driver. My driver signed for it, that he received it.

Q. What did he sign?

A. He signed that he received banknotes for Knin, a full truckload, seven to eight tons of dinars.

Q. For the Republic of Serbian Krajina. ²⁶⁶⁸⁰

A. Yes.

Q. So money intended for the Serbian Krajina.

A. Yes. The money printed in Topcider.

Q. But the driver went alone. You didn't go with him and you don't know to whom he handed it over.

A. I didn't accompany him to the mint at Topcider, but I led that convoy up to Knin, and then to whom he handed over that money in Knin, I don't know, because it was his job to hand it over.

Q. So you led the convoy, but you don't know to whom the money was handed over?

A. I don't know. To somebody at the bank there.

JUDGE MAY: The witness has answered as best he can. Yes, Mr. Tapuskovic.

MR. TAPUSKOVIC: [Interpretation] Thank you, Your Honours. Questioned by Mr. Tapuskovic:

Q. [Interpretation] But I would like to go back to this topic from paragraph 21 of your statement regarding this money. If you would be kind enough to look at your statement. You said in the first sentence: "I remember that on one occasion I transported a whole truckload of RSK dinars to Knin. This must have been seven to eight tons of freshly printed RSK dinars."

So you say that you drove that money personally.

A. Yes.

Q. And then a couple of sentences on, you say: "I was the first one to deliver RSK dinars to Knin." And then: "I do not know why these ²⁶⁶⁸¹ deliveries took place, because I was just the driver. I do not remember to whom I delivered the money." Whereas here you -- here in the statement you said that you drove and you handed it over. How do you explain the discrepancy between this and what you said just a second ago?

A. There is a slight error here. I'm telling you that the money was taken there by the truck driver Jovo Danilovic and I was the one leading the convoy. There was always a leader of the convoy.

Q. You said you delivered the money. If you had delivered the money and you are denying it now, there must be a document to prove it, because it's a huge amount of money, and then a huge amount of foreign currency was taken back. Is there a document to prove that this amount of money - because it's huge - was taken and handed over there? Do you have that document or does somebody else have it, somebody who drove the money?

A. It was signed by Jovo Danilovic, because he would take it to Knin and he would leave the document to Belgrade on his way back.

Q. All right. Then I have a couple of more questions about this set of documents under tab 9. We see here an authorisation from which it is evident that you took over a truck, a bus, and it says that this vehicle would be (redacted) .

A. Yes, yes.

Q. Was anyone able to drive a vehicle that didn't belong to them without having an authorisation, a document? I'm not talking about arms deliveries, I'm talking about driving regulations because of routine controls. Did you have to have an authorisation as somebody who was not the owner? ²⁶⁶⁸²

A. No, I didn't.

Q. Didn't you have an authorisation for every vehicle allowing you to drive it, because it didn't belong to you?

A. I'll give you an example of this bus precisely. This bus came from Vukovar, and I got this pass because I was the only one who had the licence to drive the bus, and I used this bus to drive refugees to their destination.

Q. You explained that earlier. I wouldn't like to come back to that. Let us just discuss the document from tab --

MR. GROOME: Your Honour, I've requested a redaction be made, but may I remind Mr. Tapuskovic not to mention the witness's name on the record.

MR. TAPUSKOVIC: [Interpretation] I did not mention the witness's name.

MR. GROOME: It's at line 13:10:47.

JUDGE KWON: You mentioned the driver's name.

MR. TAPUSKOVIC: [Interpretation] Yes, but only as a driver. I didn't mention his name and surname. I can't understand. I can't explain this error. I don't believe I made it.

Q. But in this tab 10 we discussed already that the weapons that were requested were requested for purposes of security of convoys and all these documents under tab 11 concern precisely those weapons requested for security details for convoys and drivers; isn't that right?

A. I will try to give you a more detailed explanation now. When we drove military convoys, we did not need any authorisations. Civilian ²⁶⁶⁸³ transports were another matter. When you were transporting civilians or civilian property, it was a different matter.

Q. Why am I asking you this? You said you led three convoys plus one in relation to those besieged Serbs. There were three or four convoys.

A. There were some more, but it doesn't matter.

Q. It does matter, Witness, because if you look at paragraph 15 -- no, paragraph 7, you say: "While I was," this and that, "the unit transported more than 1.200 truckloads of ammunition and weapons that had been taken from Bubanj Potok." Then a couple of sentences down, you say: "I know this personally because I participated myself in the transport." This is mentioned after your reference to 1.200 trucks. How do you explain this if you were involved in only three or four convoys?

A. You're trying to set a trap for me. I said something entirely different. I said that in 1992, 1.200 trucks were transported from Bubanj Potok, carrying ammunition and weapons. And I said vehicles from the Association of Emigrants were involved but also vehicles from the MUP of Serbia and other civilian vehicles.

Q. Look now at paragraph 17. You say: "When these weapons were transported, the receivers of the arms had to sign for it when we delivered it. When I picked up the weapons in Bubanj Potok -" and you say when - "I was always given the name of the receiving party. I think I will be able to find the receipt for the weapons, and I will contact the investigator when I do."

That is something you say in the statement drawn up in March this year. ²⁶⁶⁸⁴ You cannot mention any contact related to the weapons received in Krajina or in Bosnia by the Serbs from these areas.

A. You are very wrong, Mr. Tapuskovic. I had major problems. My family received threats in this period. From my first contact with the Hague Tribunal, I received an anonymous call telling me that I would be killed. I had to hide my family away because we were receiving threats. Every night telephones would ring and the caller would ring off immediately.

Q. That is not without reason.

A. Let me tell you my story to the end. You will receive these documents. I will find them. Part of these documents are still in existence. I kept documents in various places. I had to conceal a part of them, but I was not able to collect them before my travel to The Hague, but I will pick them up, and I will bring them.

Q. Thank you for this explanation. But today in response to different questions, you already answered that you do not have these documents because everything was burnt in your home, and on another occasion you said that everything had been removed from your apartment. How can you produce them if you don't have them any more?

A. You are wrong, Mr. Tapuskovic. I said the documentation from the military base 5055 had been burnt. It wasn't burnt in my apartment. And it was during searches of my apartment that a part of my documentation was removed. I said it loud and clear. Please do not try to confuse these two things. Nothing in my house was burnt. It was the documentation of military base 5055 that was burnt. ²⁶⁶⁸⁵

Q. Thank you for this. You mentioned today for the first time that you met Mladic, Krajisnik, Tepavcevic, Lajnovic, Buca, Brka, Isidor and other people, and you never mentioned before that you had any meetings, any encounters with the people you mentioned here.

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

Q. You mentioned that you met Stanisic.

A. Yes.

Q. And you hadn't mentioned it before. The same goes for Mladic. You mentioned the paramilitaries of Lajnovic and Tepavcevic and you had not mentioned any of these persons before.

A. I will try to give you an explanation of this. When I gave my first statement in Belgrade, it was in the offices of the ICTY, precisely at the time when the Prime Minister of Serbia was killed. And my meeting there was cut short, and I got my first opportunity to explain certain things when I came here.

Q. One of the Judges was interested in this topic that I'm going to cover now. You say that somebody conveyed certain information to Slobodan Milosevic, but here in paragraph 11, you already spoke about this, and you said in no unclear terms that Slobodan Milosevic talked every morning with the persons you mention here about arms deliveries to Krajina. If he participated directly in these discussions, why would he need to be informed about them? Can you explain this for the benefit of the Judges?

A. Yes, I can very easily explain. I said that he did not always attend. He sometimes attended, and on other occasions he was briefed. I think he was perfectly clear on this, and you are confusing things. ²⁶⁶⁸⁶

MR. TAPUSKOVIC: [Interpretation] Thank you. Thank you.

JUDGE MAY: Yes, Mr. Groome.

MR. GROOME: Your Honour, there is one document that I would ask to be added to the binder of exhibits to be used with this witness, and I'd ask that the witness be shown this document now. Re-examined by Mr. Groome:

Q. Sir, that is document containing two identification cards. I'd like to draw your attention to the identification card on the lower part of the document. Sir, whose identification card is that?

A. That is an identity card of the Association of Serbian Emigrants concerning assistance to Serbian refugees.

Q. And is that your identification card?

A. Yes.

Q. I'd ask you to look at the second page which is a copy of the reverse of that card. Does that bear your name and the stamp of the association?

A. Yes. We can see my name here and the stamp of the association and my personal identity card number.

MR. GROOME: Your Honour, I would tender that under seal, and I have no further questions.

JUDGE MAY: And that will be tab 14.

THE REGISTRAR: 14, Your Honour Questioned by the Court:

JUDGE KWON: Mr. B-179, what is your base of knowledge when you say that more than 1.200 trucks of ammunition had been transported? ^{26687 BLANK PAGE 26688}

A. It is based on the conversations between Bora Stanisic and Milan Prodanic that I overheard that took place in Bubanj Potok when they were saying that we had managed to transport over 1.200 trucks full of ammunition and weapons with great success to Republika Srpska and the Serbian Krajina.

JUDGE KWON: If you could tell me when it was.

A. It was towards the end of 1992.

JUDGE KWON: Thank you.

THE ACCUSED: [Interpretation] Mr. May.

JUDGE MAY: Yes, what is it?

THE ACCUSED: [Interpretation] Well, just in relation to this document that Mr. Groome introduced a minute ago, since it wasn't introduced before my cross-examination.

JUDGE MAY: Yes. What is your question?

THE ACCUSED: [Interpretation] Well, there are two documents here, actually. I suppose that the witness can see that, because he received this a couple of seconds before I did.

Further cross-examination by Mr. Milosevic:

Q. [Interpretation] So the first document is a copy of his personal identity card, the kind that every citizen of Yugoslavia has?

A. Yes.

Q. And we see here that this identity card was issued in December 2000?

A. Yes.

Q. It has nothing to do with the time that you are testifying about; ²⁶⁶⁸⁹ is that so?

A. Mr. Milosevic, I changed my identity card. The identity card that I had was taken by the office of the ICTY when I was giving my statement. That is why these don't correspond. My old card and my new card. They made a photocopy of my new card.

Q. Leaving that aside, I only want to note that this first document is a copy of the personal identity card issued in December 2000.

A. Yes. And it bears a different identity card number. If you would be kind to look at it, it says M -- registration number --

JUDGE MAY: What is the point?

MR. MILOSEVIC: [Interpretation]

Q. You don't have to read the number.

JUDGE MAY: Just a moment. Now, what is the point of this? The accused points out accurately it's dated 2000. We waste time in this case in this sort of way.

MR. GROOME: Your Honour, the Prosecution isn't offering or isn't tendering the top document. The Prosecution is only tendering the image on the bottom half of this page, which is the identification card for the association which the accused has alleged he never held the position in.

JUDGE MAY: Yes. Very well. No. We're going to bring this to an end.

You wanted to say something, Mr. Witness. Did you want to add something?

THE WITNESS: [Interpretation] Nothing. I just want to thank you.

JUDGE MAY: Yes. We're going to bring this to a close. ²⁶⁶⁹⁰

THE ACCUSED: [Interpretation] Let us clear up this second matter too, then.

MR. MILOSEVIC: [Interpretation]

Q. This second ID card has on it the Matica of Serbs and Emigrants of Serbia, with a photograph, which is quite unclear, and below that it says "aid to Serbian refugees." That is what it says. And on this other page, on the reverse side, it says the name and last name of this witness. So the entire document only relates to the fact that it is the Matica of Emigrants of Serbia and Serb Refugees, and the name of the witness with a number that I am not familiar with, and it does not coincide at all with the other number in the other document. So it says nothing else. That's all that is said in this document.

A. May I clarify? On the reverse side of this ID card is my ID card number while I was working in the matica. So this is the old ID card number. An ID lasts ten years. I had to change it because it had expired. And that is why the number of the ID card on the upper document does not coincide with the number on the reverse side of the other document. Mr. Milosevic must know this very well. He's just pretending not to.

JUDGE MAY: We're not going to pursue this any further. The issue, in any event, has not been whether the -- whether there was any involvement with the matica. The role has been the role of that association -- the issue has been the role of that association. We really must bring these matters to an end.

Witness B-179, that concludes your evidence. Thank you for coming ²⁶⁶⁹¹ to the Tribunal to give it. You are free to go. But just wait, if you would, until we've pulled down the blinds, please.

THE WITNESS: [Interpretation] Thank you, too.

THE ACCUSED: [Interpretation] I have an objection regarding you personally.

JUDGE MAY: No. You can make an objection -- you can make an objection to some part of the evidence, but you can't make an objection to me personally.

Now, what is the objection you want to make?

THE ACCUSED: [Interpretation] I wanted to say that you're allowing this witness to use a rather common language which is not appropriate for civilised behaviour, rather crude language used on several occasions, in fact.

JUDGE MAY: Such crude language as there may have been has not been interpreted, so we've not been able to follow it. If there had been an objection earlier, we would have dealt with it. Yes. Thank you, B-179, if you'd like to go now.

[The witness withdrew]

MR. NICE: While we're waiting for the changeover of witnesses, can I use the time for two very short administrative matters?

JUDGE MAY: Yes. If you'd like to go, Mr. B-179.

MR. NICE: First, we've reviewed the position about the witness Harland in light of the amicus objections to the document or a substantial part of it being subject to 92 bis. We think there's force in their argument and that what would be left to be 92 bis is really not worth ²⁶⁶⁹² troubling you with, and therefore in reality we think that the whole of the evidence should be given viva voce and we shouldn't trouble you further. I'm sorry to have taken your time thus far.

JUDGE MAY: Well, a sensible concession if I may say so.

MR. NICE: Second thing is the lists on witnesses need not be prepared because there is not real prospect of there being time to call them are in preparation. I hope to have the lists to you by the end of business today, courtesy copy or otherwise, and I hope that will be helpful to cover both list A and the 92 bis witnesses, although I think there may be yet further names on the Bosnia 92 bis list whom we will be able to suggest later on needn't be subject to preparation, but we're doing out best to minimise preparatory work.

JUDGE MAY: It might be helpful, speaking for myself, if we could simply have a list of those witnesses in addition of the witnesses who you intend to call between now and the end of the case.

MR. NICE: Yes, certainly. It's of course to be found on list A, but --

JUDGE MAY: I know, but I have to say for myself I find it confusing because in it there are all the witnesses you have called.

MR. NICE: We did that intentionally so that you could have a continuing document, but if you find it more helpful we can simply strip out and republish with all those names deleted, leaving the numbers for the witnesses frozen at what they were for ease of reference amongst yourselves or with your legal others or with us. I'll have that dealt with in one way or another today. ²⁶⁶⁹³

JUDGE MAY: If would you.

MR. NICE: We are also hoping to get to you today a filing on the witness list, deletions and additions that I hope will basically take us to the end of the case subject to other eventualities. But Mr. Ierace will be taking the next witness, and I'll hand it over to him.

[The witness entered court]

JUDGE MAY: Yes. If the witness will take the declaration, please.

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

JUDGE MAY: If you would like to take a seat.

THE WITNESS: Thank you.

WITNESS: AERNOUT VAN LYNDEN

JUDGE MAY: Yes, Mr. Ierace.

MR. IERACE: Yes, thank you, Your Honour. Examined by Mr. Ierace:

Q. Are you Aernout van Lynden, Baron Aernout van Lynden?

A. I am.

Q. What is your occupation?

A. I'm currently working as a lecturer at the American university in Bulgaria.

Q. Were you previously, for some 22 years, a war correspondent?

A. Yes.

MR. IERACE: Your Honour, most of the witness's testimony in the ²⁶⁶⁹⁴ Galic trial has been admitted pursuant to Rule 92 bis (D). Some further material has been admitted pursuant to Rule 92 bis (A). I will present a summary of combined evidence. Some matters which do not qualify for admission under those rules will be the subject of viva voce evidence. Four brief news stories or parts thereof which were filed by this witness will also be shown. In relation to the witness's background, Baron van Lynden, a Dutch national was born in London in 1954 and was educated in the United Kingdom. As a -- he was a war correspondent who covered the Yugoslavian conflict for Sky News, a satellite news service including Croatia in 1991 from the Serb side and the siege of Sarajevo. He had previously covered the war in Lebanon, the Iraq-Iran war from both sides, and the Gulf War. Prior to becoming a war correspondent in 1978, he was an officer in the Dutch Marine Corps, specialising in mortars. He stayed in Sarajevo on the Bosnian side between May and August 1992. In September 1992, with the assistance of Dr. Karadzic, he spent three and a half weeks on the Bosnian Serb side. He was again in Sarajevo from the end of October until late December 1992. Thereafter, he visited Sarajevo sporadically for a few days at a time, except after the first market -- Markale market incident in 1994 when he stayed for a few weeks. In relation to the settlement of Dobrinja, he marked its position on a map as being to the west of the city alongside the airport and gave evidence that it was separately besieged, being cut off from the rest of Sarajevo until June 1992, when Bosnian forces took control of the nearby Mojmilo hill.

In relation to the layout of Sarajevo generally, the witness has ²⁶⁶⁹⁵ stated that it was an elongated city lying in a valley along the Miljaka River. The Bosnian Serb forces held the high ground and were able from those positions to fire along the streets which intersected the main east-west thoroughfare, Marsal Tito Boulevard. Accordingly, an alternative pedestrian route was developed to enable the inhabitants to traverse the city along the valley floor on an east-west access, in particular at the valley's narrowest point which was the central city area in the vicinity of Marin Dvor and the Marsal Tito barracks where the Bosnian held part of the valley floor was about a kilometre wide and immediately adjacent to the Bosnian Serb-held Grbavica. This route involved utilising building cover and anti-sniping barricades and has been indicated on a map which is Annex II to the witness's 92 bis statement.

The witness has given evidence that whilst residing on the Bosnian Serb side in September 1992, with the permission of General Mladic, his Sky News team spent ten days touring various Bosnian Serb front-line positions around Sarajevo, escorted by two Bosnian Serb military policemen. As they did so, the witness was introduced to the various company commanders. These officers wore their JNA uniforms displaying their JNA ranks, having changed their badges from the JNA to the Bosnian Serb army.

During this tour, he noticed that the Bosnian Serb gunners from their commanding positions were able to personally sight their targets rather than rely on observers, thereby enabling more accurate fire. The topography also allowed relatively few infantry forces backed ²⁶⁶⁹⁶ up by artillery to keep large numbers of Bosnian troops committed to the defence of Sarajevo.

At Grbavica along the Miljaka River which delineated the opposing forces at that point, he was shown several sandbagged positions in apartment blocks operated by uniformed soldiers armed with machine-guns and what he recognised to be sniping rifles and in radio communication case with spotters who apparently assisted them to locate targets. In one fourth-floor position they utilised a dummy decoy. Elsewhere in Bosnian Serb held Grbavica he saw mortars, tanks, armoured personnel carriers, which are known as APCs, and vehicle-mounted anti-aircraft artillery. The state hospital. The witness described the state hospital as being positioned in front of Marin Dvor square as were the Bosnian Parliament Buildings and in a direct line of site and fire from the Bosnian Serb forces in Grbavica. His news team stayed there from May to August 1992, camping in the shelled out upper floors because it gave them an ideal filming position of the city and the surrounding hills which were occupied by the Bosnian Serb forces.

The hospital continued to function from the lower levels. From there, in the four days and nights following the evacuation of the Marsal Tito barracks in June 1992, they filmed the city being shelled indiscriminately from Bosnian Serb positions. He estimated that over a thousand shells from heavy weapons including anti-aircraft artillery fell on the city each night. All tracer rounds were seen coming into the city.

The witness contrasted the saturated fire which was concentrated ²⁶⁶⁹⁷ on the Marsal Tito barracks following its evacuation with indiscriminate fire where shells would land randomly all over Sarajevo. In his opinion, this random fire was directed at the city generally and those who lived in it. Its effect was inculcate fear in the city's inhabitants. In this period during these four days and nights, he observed the Unis towers which were twin commercial towers of 35 to 40 storeys high near Marin Dvor square being almost completely destroyed by Bosnian Serb shelling even though up until that time they had not been a source of fire by Bosnian forces. He witnessed a steady stream of casualties coming into the state hospital, filling the emergency ward and corridors. During his stays and visits to Sarajevo during the war, the witness observed other instances of deliberate attack of civilians and civilian facilities by Bosnian Serb forces. In mid-July 1992, he witnessed a sniping incident. At about 4.00 p.m. on Marsal Tito Boulevard, he observed two men and a woman dressed in civilian clothes lying on the ground in place which was open to Bosnian Serb positions. The woman wore a skirt and had with her what appeared to be a shopping bag. All three people appeared to be in their 40s and had been shot. Two were moaning. He was told by bystanders that initially one was shot, then a person who went to assist, and finally a third person who went to assist those two. The witness observed a Bosnian APC arrive, but before it could provide cover to the three adults, at least two single shots struck them. The two men were killed. He does not recall whether the woman survived. The second incident concerned an apartment block shelling. On the 5th of December, 1992, while driving along Marsal Tito Boulevard, the Sky ²⁶⁶⁹⁸ News team observed a high-rise apartment block near the road which accommodated several hundred people, including children, being hit with incendiary rounds that were coming from the direction of the nearest Bosnian Serb positions, which were to the south of the Miljaka River. They stopped and filmed the incident and spoke to the residents, determining that the building had not been used by the defending military forces according to the residents and, therefore, in the witness's opinion, was not a military target.

While the fire department attempted to put out the ensuing fire, the building continued to receive incendiary rounds at levels lower than the firefighters.

While driving on the Bosnian side, the witness observed that mortars would on occasion land either in front of his vehicle or behind his vehicle, leading him to conclude that his vehicle was being sniped, so as to speak, by Bosnian Serb mortar crews.

In relation to the Jewish cemetery, on two occasions the witness visited the positions of Bosnian Serb forces in the area of the Jewish cemetery, which was positioned on the confrontation lines and overlooked the southern part of the city, in particular, Marin Dvor. On one visit in February 1994, he met the local commander, a person known as Aleksic. He observed that his troops were not uniformed and were armed with non-standard weaponry. He was informed, that is the witness, was informed by his Bosnian Serb minder who accompanied him from the Pale headquarters that Aleksic and his men nevertheless came under the command of the local Bosnian Serb army commander. ^{26699 BLANK PAGE 26700} Prior to the first Markale market incident which was on the 5th of February, 1994, it was not possible to cross Marin Dvor square safely, the witness said in his evidence, since it attracted fire from Bosnian Serb forces on an almost daily basis. The fact that it was possible to walk across it in March 1994 during the cease-fire which immediately followed the Markale market incident confirmed to the witness that Aleksic was indeed subject to a centralised command and control system. In relation to the Bosnian army, the witness observed that the Bosnian army in the city had significantly less weaponry than did the Bosnian Serb forces. He had seen a tank on the Bosnian army side, and in February 1994, at a weapon collection point set up in the city, he saw 120-millimetre mortars but no artillery. He observed that the Bosnian army was multi-ethnic in its composition, including people who were identified as being Serbian or Croatian as well as of the Muslim faith. In the early stages of the conflict, he noted that the Bosnian army was not consistently outfitted in uniforms. In mid-1992, he met a Bosnian paramilitary by the name of Juka Prazina who the witness estimated had 200 to 300 men under his command. They were armed and un-uniformed except that they tended to wear black. As to military targets in the city, on occasion he would visit various Bosnian army officers which were located in what as far as he could tell had previously been non-military office buildings. On one occasion he saw a mortar that had been set up in the grounds of Kosevo Hospital.

As to conditions in the city by May 1992, the shops were empty and ²⁶⁷⁰¹ food had to be brought in. Some tried to grow vegetables for themselves, but many lived in apartment blocks and, therefore, were unable to do so. When on the Bosnian Serb side of the confrontation lines, in particular in the area of Grbavica, the witness had observed anti-sniping barricades, and he was informed that civilians on that side were being shot by snipers from the Bosnian side of the confrontation lines. He asked to be taken to the hospitals to see the victims but was not taken. As to prisons on the Bosnian side, the witness was aware of the existence of prisons in Sarajevo. He asked the Bosnian authorities for access to those prisons but was never given access. Your Honour, that concludes the presentation of the summary of the evidence. At this point I would show -- seek to show four video clips or some parts, but I note the time.

JUDGE MAY: Yes, I think that would be a convenient moment to stop for the day. We will adjourn now. Twenty minutes. Baron, could you remember, please, not speak to anybody about your evidence, not that you've given any so far, until it is over.

THE WITNESS: Yes, Your Honour.

JUDGE MAY: Did I say 20 minutes? Adjourned for the day.

--- Whereupon the hearing adjourned at 1.49 p.m., to be reconvened on Tuesday, the 16th day of

September, 2003 at 9.00 a.m.