27870
Wednesday, 22 October 2003
[Open session]
[The witness entered court]
[The accused entered court]
--- Upon commencing at 9.04 a.m.
JUDGE MAY: Yes, Mr. Nice. Mr. NICE: I have no further questions of the witness. There are two administrative matters before cross-examination. The first, it would greatly assist us if we could know how much cross-examination there may be of the witness in order to make arrangements for calling or not calling the next witness, who would be travelling some distance to The Hague.
JUDGE MAY: Yes. Well, we have in mind three hours, but then the amicus may have some questions. I don't know who's representing the amicus today. Well, we'll give some time for Mr. Tapuskovic. Mr. NICE: It looks as though the whole day may be consumed.
JUDGE MAY: I would have thought effectively the whole day is going to be taken up.
Mr. NICE: And 30 seconds, with your leave, in private session.
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[Open session]
THE REGISTRAR: We're in open session. Mr. NICE: Your Honours, I think I've explained I have no further questions of this witness. I understand there are some observations that she wishes to add to the evidence she gave yesterday, and I'll sit down while she makes those observations.
JUDGE MAY: Mrs. Gajic-Glisic, if you want to add something to your evidence, now is your opportunity to do so.
THE WITNESS: [Interpretation] I should like to say that everything that I wrote down in my book entitled "The Serbian Army," published in five editions, and everything that I made a note of, I did publicly in the cabinet of the minister of the army, pursuant to permission from General Simovic. I should also like to say that he authorised it all twice; the first time was for the Nin publishers and the 27873 second time was for the book itself. And I would like to say that what you have before you, all the documents you have before you and the book, that that is thanks, first of all, to General Simovic, and also thanks to President Milosevic, of course, who could have prohibited it all and put a ban on it had he wanted to.
I continued to maintain that I did my best to make a note of all the facts and it was just supposed to be a report to my people and I never imagined that this would be evidence in a court of law. I should also like to state that in agreement with the Prosecutors, we agreed, in fact, that I should be a witness here and that I should say everything not only as a witness for the Prosecution but everything else that I know about what was happening during that period of time. So I am ready and willing to answer any questions to the best of my knowledge and as far as I am able.
JUDGE MAY: Very well. Yes, Mr. Milosevic.
WITNESS: DOBRILA GAJIC-GLISIC [Resumed]
[Witness answered through interpreter] Cross-examined by Mr. Milosevic:
Q. [Interpretation] Mrs. Glisic, in the examination-in-chief -- I don't think my microphone was switched on, was it?
JUDGE MAY: Yes. Mr. MILOSEVIC: [Interpretation]
Q. Ms. Gajic-Glisic, in the examination-in-chief you skimmed through some matters briefly, so I should like to ask you now to give us some more 27874 detailed explanations about some of these issues, to make them clearer, and in order to make certain distinctions which I just saw some intimations of in your explanations, probably due to the shortness of time you were not able to go into them in any depth. But before I do so, before I go on to my questions, I should like to ask you something with respect to your status. I'm sure you know that until yesterday morning, until you entered this courtroom, you were treated as a protected witness by -- and you had a pseudonym and we were also told that we would be having a closed -- a private session. Did you ask for that?
A. Yes.
Q. Well, how come that you suddenly changed your mind and decided to testify in open session?
A. My sons asked that of me. They said, "This is an opportunity, an occasion to take -- to state that you're not a spy, to take all this onus away from you."
Q. And when did you make the decision, yesterday or earlier?
A. Yesterday morning I asked the gentleman, Mr. Nice, whether I could ask Their Honours before I begin, Your Honours, can I now speak quite openly and frankly? Because that's what my sons have asked me to do.
Q. Very well. Thank you. I asked you that question because when you had the protection -- protective witness regime, I was given some very limited information about this because nobody is supposed to know who the witness is except my two associates. And then, of course, it is very difficult to collect the necessary information and material I need. But 27875 BLANK PAGE 27876 you've clarified that issue, and I have no questions.
A. I do apologise to you, but my life is an open book. In my 17 books, I have described my life, and I shall be happy to tell you anything you need to know about my life publicly.
Q. Let's just clear up some matters first, some things that I think have remained fairly -- have not been described sufficiently because of your -- the briefness of the time you had. First of all, the question of volunteers. May we observe -- or rather, is it true and correct that there is a drastic difference between volunteers, the ones you dealt with in the sense of assistance or recording and keeping records of them and the paramilitary formations which you just mentioned by the by yesterday. You mentioned certain formations such as the Dusan Silni, the White Eagles, Paroski, Mauzer, et cetera, and you said yesterday that they weren't within the system and that you had nothing to do with them nor did the ministry have anything to do with them. Is that right?
A. Yes.
Q. So there the difference is quite clear; right?
A. Yes.
Q. Now, what you say about volunteers applies exclusively, therefore, to the volunteers who signed up to the JNA or the Territorial Defence; is that right?
A. Yes.
Q. The JNA in 1991 was a regular army of the Socialist Federal Republic of Yugoslavia throughout its territory; isn't that right?
A. Yes. 27877
Q. The Territorial Defence, depending on where it was under the command of the Territorial Defence of the municipality in which it was a Territorial Defence; is that right?
A. Yes. The commanders of those staffs, commands, were the presidents of the local community or municipality, and all together they were under the command of the JNA, and I don't think I'm wrong there.
Q. Very well. Now, with respect to these other units which you mentioned, you also mentioned, for instance, the Serb Volunteer Guards of Zeljko Raznjatovic, Arkan.
A. Yes.
Q. And you also mentioned Captain Dragan; is that right?
A. Yes.
Q. Do you know that that Serbian Volunteer Guard of Zeljko Raznjatovic, Arkan, was under the command of the Territorial Defence of Eastern Slavonia, Baranja, and Western Srem?
A. Yes. But it was also linked up with the MUP of Serbia, and the MUP of Serbia from time to time would mobilise certain members for assistance to the Serbian Volunteer Guards.
Q. I don't know about that, so I'd like to ask you to explain it to me. Because as far as I understand it, you received that information from Simovic. On what grounds were you able to conclude that the Serbian Volunteer Guards was linked up to the MUP of Serbia?
A. I got that information, first of all -- or rather, we received that information from Minister Zoran Sokolovic. Now, if you will give me a little time, I would like to give you an example to illustrate how I 27878 know this.
Q. Well, tell me, please, but just briefly, because I have to take care of my time.
A. I received information that I was to find a mobilised recruit quickly for personal reasons, and I was told that his wife was in a very difficult situation, that she was actually dying, and that he had been mobilised and I was asked to find him and have him return to Belgrade. As a wife and mother and woman, I did my very best to find the unit he had been mobilised into, but we failed to find him in any of the war units of the army. And then General Simovic asked, "Well, Zoran, where can we find Pelovic? Who mobilised him in the first place?" and I said, "You General; we did, General." And he said, "How come you?" "Well," they said, "we sent him to help Arkan." And I rang up Arkan's headquarters and Mr. Pelovic told me, "Well, my mother gave birth nine times and I came here to fight. You don't suppose that I'm going to desert and leave home [as interpreted] just because my wife is going to give birth." And then Mr. Zoran Sokolovic said, "Well, we mobilise occasionally members from the reserve force of our police to provide assistance to Arkan's volunteers." So it is the present-day president of the Party of Serbian Unity, in fact, that's the man I'm talking about, and that was the information I had and I apologise to the Prosecutors for the fact that I have some personal, very deep emotional ties with the daughter of Professor Dr. Citic [phoen] from the medical military academy. She was married to Mr. Pelovic, in fact, and Dr. Citic at that time operated on my son. And I did my utmost to have this man returned from the battlefield. 27879
Q. Well, Pelovic was in contact -- actually, he was in the Party of Serbian Unity, that is not at issue.
A. The Party of Serbian Unity was, Mr. President, formed later on.
Q. Yes, that is quite true. But I don't know that he recruited on the part of the ministry. All he did was -- I think he independently, as a patriot and an intellectual, became involved in some assistance over there.
A. I apologise, but he was president of the King Alliance of boxers, I think. I don't know the sports organisations. But as such he was on the war list of the police, the Serb police, in fact.
Q. Yes. But I assume that it was voluntarily that he joined the Serb Volunteer Guards. It wasn't the police that could send him to the Serbian Volunteer Guards because the Serb Volunteer Guards was never a formation of the police force.
A. Mr. Zoran Sokolovic at the time claimed it was.
Q. I'm afraid that you might have misunderstood Sokolovic, because that is impossible. But I assume that you are speaking in good faith and to the best of your knowledge.
A. Yes. I am speaking in good faith, and I would like whole-heartedly, first of all, to help you and my people, but primarily by telling the truth.
Q. Yes, absolutely. So that's the only way that can be done. Tell me this now, please: All the things you did with the volunteers, that the Ministry of Defence did vis-a-vis the volunteers, was it in conformity with the laws, the rules? 27880
A. Yes. Yes.
Q. Now, Mr. Nice even asked you whether I knew about some provision or decree that is brought in by the government or the ministry.
A. Yes. Provisions are enacted by the government at the proposal of the various ministries.
Q. Now, as far as Captain Dragan is concerned, he was here and said that he came from Australia alone. Nobody called him or invited him to come. And he wasn't within the composition of the Ministry of the Interior at all.
A. He said differently to us at meetings, and if you would like, I should be happy to show you the original -- my original notes, in fact, that I typed out and brought to your cabinet. And Their Honours can ascertain and establish that those notes date back to those times. So I don't know the other side of the coin; all I know is what he told us.
Q. Well, I assume you know that Captain Dragan exclusively became involved as an instructor on different occasions and so probably in that capacity with respect to the training of individuals from the police. But that has nothing to do with his participation as a volunteer somewhere on the battlefront, outside Serbia.
A. He told us that he was sent or invited by Mr. Radmilo Bogdanovic, and that was all directed by Jovica Stanisic, and that with him there were another six in that first departure for Knin, there were six more specials from the state security who were in Knin as instructors.
Q. He testified here in this courtroom and said that he had come alone himself and that he worked exclusively and as an instructor, that he 27881 BLANK PAGE 27882 was not in any combat, did not take part in any combat operations.
JUDGE MAY: Well, that's not my recollection of the captain's evidence. I seem to recollect that he was involved in a combat operation involving a police station. We can check it out. But in any event, I mean, the important thing here is what he may or may not have said to this witness. That's what's relevant. What he said here is not relevant necessarily to that.
THE ACCUSED: [Interpretation] Very well, Mr. May. Mr. MILOSEVIC: [Interpretation]
Q. You say that Stanisic orchestrated that, his arrival. And you know that in 1991 Stanisic was not head of state security.
A. As far as I remember, Mr. Stanisic at the time was the chef de cabinet of Mr. Zoran Sokolovic, and the head of state security was Mr. Janjackovic. I had very good cooperation with Mr. Zoran Janjackovic, and with Mr. Stanisic I just had several conversations with him over the phone with our special telephone line.
Q. All right. As far as my information tells me, he wasn't even Sokolovic's chef de cabinet. But never mind, we're not going to pursue the point.
A. Mr. President, if you would like to see them, these are notes from Botic's villa, from the meeting held there. I wrote that because my conscience dictated that I take these notes without any intentions or any thought of having an opportunity at some point in the future to show them. So these are my notes from that period, from the meeting with Captain Dragan, and he speaks about his combat activities there in that area over 27883 there.
Q. So he is providing you, actually, with information about what was going on and where he was involved; is that right?
A. Yes, that he was involved in combat action.
Q. But he is providing you with information. So this is a sort of debriefing of Captain Dragan by the service and by you too from the ministry, to get to know what was going on in the area.
A. Well, I see the meeting -- or rather, the meeting was organised by the police and state security, and he was brought to Botic's villa by a police car.
Q. Yes, I understand that. But let's clear this up. They were gathering information, intelligence, about what was going on over there. He was over there, so then he provided you with the information you wanted to know from the defence and the police, to tell you what was going on over there. So this link, this connection actually boiled down to providing you with information about -- and intelligence about what was going on over there. Had you sent him there, I assume you would have known what was going on over there and you wouldn't have expected him to have to tell you.
A. Well, he began talking of his own bat. The meeting began that we were engaging him to train volunteers in Bubanj Potok.
Q. That's a different matter altogether, whether you're going to engage him for training volunteers, but the meeting that you were having and the notes you made from the meeting meant collecting information from him as a man who was present in the area at the time, and that's what he 27884 talked about here; isn't that right?
A. Well, you could put it that way too.
Q. All right, then. Now, something else, please: Please, as we are talking about volunteers, we have now drawn a clear distinction between those volunteers that you kept records of and the paramilitary formations that had nothing to do with the state. Is this correct?
A. Yes.
Q. I would like you now to briefly go through a few documents that I have here and to tell me whether they confirm that, as far as volunteers are concerned, all this was in compliance with the regulations. For example, I have here instructions on the receipt of volunteers into the Territorial Defence.
A. Yes, I am familiar with this document.
Q. Please take a look at it.
A. Could you please just help me by telling me the tab number.
Q. I have not received this from those who called you to testify.
JUDGE MAY: Just a moment. This may be a document which the accused has got and you won't have.
So, Mr. Milosevic, if you hand it over so the witness can have a look at it.
Mr. MILOSEVIC: [Interpretation]
Q. Please take a look. Here it talks about the way in which volunteers are accepted, about their health checkups, their security checks. All these aspects are familiar to you, I assume, but please take a look at this instruction and tell me whether it's authentic or not. 27885 This is an instruction on the receipt of volunteers in the Territorial Defence.
A. I have the method of admission of volunteers to the Territorial Defence under tab 12(A), and I think that here --
JUDGE MAY: Could you -- I'm sorry, we must -- we must try and follow this in a fairly orderly way; otherwise, we shall get in a muddle. Could you just look at that document which Mr. Milosevic has given you. Could you confirm, if you can - or if not, say so - that it is what he described, that it's authentic. He says it's an instruction on the receipt of volunteers in the Territorial Defence. Can you confirm that that is right, please?
THE WITNESS: [Interpretation] Yes, I can.
JUDGE MAY: Perhaps before -- just while you've got it, could you help us with this so we can identify the document. Who gave the instruction? Who was it to? And what is the date?
THE WITNESS: [Interpretation] On the -- pursuant to Article 9 and so on of the law on defence, Official Gazette of the Republic of Serbia, number 45/91, the minister of defence and the command of the Territorial Defence of the Republic of Serbia have issued an instruction on the admission of volunteers to the Territorial Defence.
JUDGE MAY: Have we -- is there a date on it anywhere?
THE WITNESS: [Interpretation] Not on the document itself, no. At least, I don't see one. But I think that I have the law on defence from that period, and -- this is the same instruction here from the law that was published during the period while I was the chef de cabinet, and it's 27886 a valid document, Comrade President, if you remember. Mr. MILOSEVIC: [Interpretation]
Q. Yes. That's why I'm giving you this instruction, so everyone can see that there is no mystification here. An instruction was given as to how people were admitted, what conditions they had to fulfil, that they had to go through training, that they had to be fit, that they couldn't be under 18 or over 60, that according to the regulations - and I marked this - they had to undergo a security check.
A. Yes. But this instruction was issued only a little later, a little bit after volunteers began to arrive, because this was adopted in July. The instruction was signed by General Tomislav Simovic, who was officially appointed minister of defence on the 26th of September, at the Serbian parliament. And these documents that you have given me are practically a page from this book.
Q. Is this identical?
A. Yes.
Q. In that case, there's no issue. This -- these instructions are in accordance with the law. Is that correct?
A. Yes. This is the law under which we operated.
Q. Yes. Very well. So this is not contested.
JUDGE MAY: [Previous Translation Continues] ... Do you want that document exhibited, although it's documents?
THE WITNESS: [Interpretation] I will hand you the whole law.
JUDGE MAY: Thank you very much. But we have got -- just for a moment. We've got an awful lot of paper in this case, so we're trying to 27887 BLANK PAGE 27888 keep it down to a minimum. But thank you for volunteering that. If you'd like just to keep it for a moment. And then if something turns on it, we'll, of course, come back to it.
[Trial Chamber and registrar confer] Mr. MILOSEVIC: [Interpretation]
Q. Mrs. Gajic-Glisic --
JUDGE MAY: We have a torn bit of facts here, but we will put it together. We will admit it. We'll let the Prosecution have a look at it. We'll give it the next D number.
Just a minute.
THE WITNESS: [Interpretation] May I?
JUDGE MAY: Let the registrar go first.
THE REGISTRAR: Defence Exhibit 203, Your Honour.
JUDGE MAY: Yes. Yes.
THE WITNESS: [Interpretation] This is document number 19, which I have already given to the Prosecution
Mr. NICE: We will have better versions probably of this document, complete versions. We'll make them available.
JUDGE MAY: Yes. And when the complete version is available, it can be substituted for what the accused has handed in. Yes.
THE ACCUSED: [Interpretation] This is the complete version. But because it was faxed, it's a little torn into three bits. But nothing is missing. It contains everything from the preamble to the signature.
THE WITNESS: [Interpretation] This is correct, Comrade President. 27889 All the paragraphs start with the same words.
Mr. MILOSEVIC: [Interpretation]
Q. Yes. And they're in the same order.
A. Yes.
Q. There was one thing I wanted to clarify with you, but please let us go more expeditiously.
JUDGE MAY: [Previous Translation Continues] ... have you now got a complete version?
Mr. NICE: Got it. And in English. But, of course, not copied at the moment in enough numbers for everyone, because we don't know what documents are going to come up.
JUDGE MAY: Very well. If that can be put -- that can be put together with the original exhibit. We'll rely on the registry to clear it up.
Yes, Mr. Milosevic. Mr. MILOSEVIC: [Interpretation]
Q. Mrs. Gajic-Glisic, if possible let us try to save time. So please could you please go through some other documents I have here now. There is also an instruction here on the admission of volunteers to the JNA of the 13th of September, 1991. And this instruction was signed by the Federal Secretary for National Defence, which also contains all these aspects of their admission in accordance with the law and also emphasises - and I have underlined this here; it's paragraph 5 - it underlines there must be a security check when admitting volunteers according to the rules of the security service, and these must be strictly 27890 adhered to. And the same provision exists in the instruction we have just seen. Is this correct?
A. Yes.
Q. For this reason, I find it impossible to believe, and I would say it's just a rumour that people were released from prison to be sent to certain units.
A. I simply said what Minister Zoran Sokolovic told us in the cabinet of the minister of defence. I am familiar with the decree you mention. Unfortunately, I don't have a copy here, because we were not part of the JNA. The Ministry of Defence of Serbia was separate from them.
Q. Of course. And you had no competence over the JNA.
A. No.
Q. Look at this instruction, please. You're probably familiar with it. Because I wish to tender it into evidence. This is a complete document, and the fax has not messed it up.
JUDGE MAY: While the witness is looking at it, Mr. Nice, I have a recollection of seeing this document. I may be wrong. Mr. NICE: Your Honour's recollection is, as ever, spot on. I think it's Exhibit 406, tab 14, if information coming to me is accurate.
JUDGE MAY: We'll let the witness comment on it.
THE WITNESS: [Interpretation] Yes. I have seen a similar document in the Office of the Prosecutor, and the way in which the stamp has been placed on it and the words "military secret, confidential," and the seal at the bottom, all this, except that the signature is illegible, 27891 indicates that -- it's in compliance with the way things were done at the time. So I'm 99 per cent sure that this is an authentic document. Mr. MILOSEVIC: [Interpretation]
Q. May I draw your attention to another document, which is in fact a photocopy --
JUDGE MAY: Let us -- let us just make sure that we get this right and in order. That has been exhibited. We will make a note of that, but I would be grateful if the Prosecution would check the number and perhaps make sure --
Mr. NICE: Certainly. I'll check. I haven't yet --
JUDGE MAY: Yes. Mr. NICE: Mr. Theunens, who's been able to advise me and is usually master of the documents, suggests 406, tab 14.
JUDGE MAY: Yes. We will admit this one. It may be a slightly different version of the same. But we can note -- it will be on the transcript -- that it's the same number.
[Trial Chamber and registrar confer]
THE ACCUSED: [Interpretation] Look --
JUDGE MAY: Just a moment, while we sort this out. We'll get a new D number for this one.
Is it the same? Very well. Further inquiries show that it's the same, so we don't need a new number.
Yes, we'll look at the next document. Mr. MILOSEVIC: [Interpretation]
Q. Are you aware that the instructions were issued pursuant to a 27892 decree issued by the government of the Republic of Serbia? Mr. Nice was mentioning a decree law, but there is no such thing. There is simply a decree on the conscription of volunteers. And in Article 1, it says that this -- that it prescribes the way in which volunteers may join, and then it goes on to talk about replenishing the JNA with volunteers in accordance with the federal regulations. So this is fully in compliance, and it was issued on the 14th of August, 1991. This is a photocopy of the Official Gazette, which is authentic. It's an authentic Official Gazette in which laws are promulgated and all legal and physical entities interested in legislation receive this. Would you take a look at it, please.
JUDGE MAY: Again, I think that's a document we've had, the 14th of August, 1991, Republic of Serbia. Again, my recollection is that we've had it.
Mr. NICE: We'll search for it.
THE WITNESS: [Interpretation] Yes. This is a document -- or rather, the document I was talking about. I apologise for calling it a decree law. I am an electro -- technical engineer, so in my vocabulary this is what we called in the cabinet, this is what we called it. We were doing something that was in accordance with the law. So yesterday, and when preparing to testify here, I always said that everything that I did and everything that we did there we did pursuant to documents and regulations, and as I was told, with President Milosevic's knowledge. We didn't do anything behind Comrade Milosevic's back. Mr. MILOSEVIC: [Interpretation] 27893 BLANK PAGE 27894
Q. Everybody did their job, I hope, Ms. Gajic-Glisic.
A. I hope so too. I worked sincerely. I worked from my heart for the defence of the poor Serbian people on the war-affected territories.
Q. Mrs. Gajic-Glisic, there is one other thing I would like us to clarify: You know that the state organs responded on several occasions to the existence of several paramilitary formations and they endeavoured to -- to get everything done in accordance with the law and to eliminate these formations. You yourself said -- we won't list them again -- that these units were not part of the system, that they had nothing to do with the state, and as you say later in your statement, it was organised by various parties and so on.
A. Yes. And I described this in detail in my book, and I would like to draw attention to the period -- or rather, to the chapters in which Pejicic talks about the way volunteers were organised by the Serbian Renewal Movement, and they were sent there bypassing the legal regulations.
Q. As far as I remember, the Serbian Renewal Movement was the largest opposition party of the time.
A. Yes.
Q. Please look at the decree issued by the Presidency of the SFRY. Mr. NICE: The last exhibit, Your Honour, I think is 406, tab 13.
JUDGE MAY: Tab 13. Very well. Mr. NICE: Thank you to Mr. Whiting for tracking that one down, and I'll hand the original, or the accused's version, back.
THE ACCUSED: [Interpretation] Mr. May, this is not my version. 27895 It's the official text from the Official Gazette, which was officially applied. The Official Gazette publishes exclusively regulations --
JUDGE MAY: Yes. We have that. We have it, Mr. Milosevic. We'll just see if it's the same.
[Trial Chamber and registrar confer]
JUDGE MAY: Yes. It's the same, and so we don't need a new number for that. And you can have the -- your fax back. Mr. MILOSEVIC: [Interpretation]
Q. I draw your attention to the order on recruiting volunteers during an imminent threat of war of December 1991. And this mentions all these criteria that we've talked about. And I will read you only paragraph 7 and 8. I hope you are familiar with this as well. What's this? Oh, this is it in English, instruction. Very well. I'm glad I also have it in English. It's good to accumulate as much paper as possible.
So paragraph 7, the volunteer units that are now engaged outside the units of the JNA. So there was a constant problem of various units that were outside control. You remember this?
A. Yes.
Q. This is an effort on the part of the Presidency to put everything under control, everything -- and it was very difficult to do this in that chaos, and it says that these units and volunteers that are now performing certain military tasks or are within the units of the JNA have to regulate their position in the armed forces and bring it into compliance with the provisions of this order. And on the territory for which the units of the 27896 JNA are responsible, they are to remove all individuals and volunteer units that fail to join the JNA in the manner prescribed by this order, that is, those who are not subordinate to the chain of command and to discipline, so they are not to be used in any other way. And the next provision relates to the volunteers who fail to comply. There were certain volunteers who reported but then again did not respect discipline. And in paragraph 8, it says that "... persons found in uniforms and with the insignia of members of the Armed Forces of the SFRY but who have not joined the Armed Forces in the prescribed manner and regulated their position in compliance with this order will be subject to legal measures." So the highest organ, the collective Supreme Commander, which is the Presidency of the SFRY, ordered that order be introduced and that those who were not members of the armed forces and who were there on their own initiative be removed, and they say that the unit -- the commands of the units are duty-bound to remove all such people from their area of responsibility. Are you aware of this?
A. I was not connected to the JNA. I am aware of this, but I have not seen this order, this decree.
Q. It's an order. Would you have a look at it to see if it's authentic or not, because I wish to tender it into evidence.
A. We just can't see the signature, Mr. Branko Kostic here, who at that time was the president of the Presidency of the SFRY.
Q. You can't see that but you can see his name?
A. Yes, you can see his name.
Q. And in the Official Gazette, it isn't signatures that are printed 27897 but just the name of the person that has signed it, along with the date, et cetera.
A. Yes, I agree with you on that score. But I don't know how far this is under my competence, how far I can approve this or not approve it, in view of the fact that the date is the 12th of December and the government fell on the 12th of December.
Q. All right. So you're not competent to approve that. I accept that answer.
THE ACCUSED: [Interpretation] But I should like to insist, Mr. May that, this order be tendered into evidence, because it does indicate --
JUDGE MAY: Yes. Let's have it. Yes.
THE WITNESS: [Interpretation] If I can be of assistance, Your Honours. I do believe that this is a true and exact document. But I should like to emphasise once again that it doesn't come under my competency, giving a judgement on orders of this kind.
JUDGE MAY: Very well. We will -- we will give it the next number.
THE REGISTRAR: Defence Exhibit 204, Your Honour. Mr. MILOSEVIC: [Interpretation]
Q. I assume, Mrs. Gajic-Glisic, that when you wrote your book, you wrote it to the best of your understanding and knowledge of the events that were taking place and your participation in them.
A. I did my best. 27898
Q. So I assume that what you wrote then you stand by now and you think the same.
A. Yes.
Q. Now, I should like to remind you of several excepts from your book. And I can see you have the book beside you.
A. Yes.
Q. Could you turn to page 51, please. And General Simovic is responding there. He is answering some questions. They asked him, "What are the goals of the policies of Serbia, whether to reject the Croatian policy and to have Yugoslavia remain as a whole or to create a Greater Serbia, as some people are claiming?" Have you found that passage?
A. Yes, I have.
Q. Am I quoting from your text exactly?
A. Yes, you are.
Q. And now we come to Simovic's answer. Simovic says the following: "Serbia at times of crisis, as well as during the KPJ, Communist Party of Yugoslavia, comes out in favour of each and every nation having the right to declare itself and the right of national minorities to be citizens on a footing of equality in Serbia."
Mr. NICE: Has the Chamber found it?
JUDGE MAY: No. In English -- Mr. NICE: 35 at the top right-hand corner.
JUDGE MAY: Thank you. Mr. MILOSEVIC: [Interpretation]
Q. I should just like to ask us to follow this passage. Is that it? 27899 BLANK PAGE 27900
A. Yes.
Q. When the crisis blew up and the military aspects, Serbia opted for a peaceful settlement to the situation. Is that right?
A. Yes.
Q. Unfortunately, the armed forces -- armed force began to be used in Slovenia and then in Croatia. The Serbian government considered that the Ustasha paramilitary formations carried out massacres as a result of that which are unfortunately repeating themselves in history once again. Is that so?
A. Yes.
Q. Is that how it was?
A. Yes.
Q. In the interests of time, you go on to speak about the Second World War, et cetera, and then you continue: "In all this, the Yugoslav People's Army, pursuant to a decision by the Yugoslav state presidency, is given the task of setting up a buffer zone between the Ustasha formations of Croatia and settlements inhabited by Serbs from times gone by. It is not a question of creating a Greater Serbia but it is a question of protecting the Serb population which through force of circumstance is the most numerous in Yugoslavia and, therefore, populates the greatest territory." Is that right?
A. Yes.
Q. So was that an exact description given by General Simovic in response to the questions asked?
A. Yes. And I have here the authorised first version and this 27901 second version.
Q. You don't have to prove that to me. I'm just quoting from your book. And you stand by what you say there. And you consider it to be true and correct. Is that right?
A. Yes.
Q. Now, turn to page 54, please. And it is in the middle of that page, in the middle of that paragraph --
Mr. NICE: Your Honour, while the --
THE INTERPRETER: Microphone, please, Mr. Nice. Mr. NICE: While the Court is looking for the page, it may be assisted by noticing that at the beginning of the tab 9 there is an index that approximates B/C/S to the English. This should be, if it's 54, it should be something in the order of page 37, I would have thought.
JUDGE MAY: Yes, Mr. Milosevic. Mr. MILOSEVIC: [Interpretation]
Q. I am quoting once again and asking you for your confirmation whether that was so. And I'm quoting you. Simovic says, "From the very beginning of the secession, the Serbs were said to be guilty for the war for the sole purpose of asking that Serbs be treated as equal citizens with the citizens of Croatia." Is that right?
A. Yes.
Q. Is that how it was, Mrs. Gajic-Glisic?
A. Yes.
Q. Then it goes on to say, "I think that the Serbs in Yugoslavia -- that Serbia and Yugoslavia is one and the same," and Simovic's response is 27902 this, "So I'm asking you now why don't you stand up to this?" And he said, "I'm sorry that you didn't notice that the JNA is making efforts to protect the Serbs from genocide and not to cause an armed struggle but to work towards creating conditions for a political settlement to the crisis, which means peacefully, by peaceful means." Is that right, Mrs. Gajic-Glisic? Is that what it says in your book?
A. Yes.
Q. Is this an exact description of the situation which prevailed at the time?
A. Which was waged by Serbia at the time.
Q. And then I should just like to ask you a few more things. We have Minister Simovic's reactions. It is on page 76. And the heading there is "The Reactions of the Defence Minister Lieutenant General Tomislav Simovic to the Serbian Renewal Movement." And he says --
JUDGE KWON: It's page 53. Mr. MILOSEVIC: [Interpretation]
Q. -- that as the Serbian Revival Movement, which was very strong in creating the situation, Simovic says, "The prevention of the slaughter of the Serbian inhabitants in Serb lands and freeing our sons, members of the JNA, who were made -- held as prisoners in the barracks. Isn't that clear to everybody by now?" Was that how it was?
A. Yes. And I will confirm that thousands and thousands of soldiers, children from the age of 18, were shut up in the barracks in Croatia, that they had no electricity, they had no water, they had no food. And the women in black would send out their love to them and sing 27903 for them around them but that they were in a very poor situation, these children there.
And I also wish to say - and it is very difficult for me to remain calm in saying so - that for days and nights I did my best to -- through our connections and links, set up links with Croatia, and that I asked them to tell us what was going on with those children there, the soldiers there, those children of 18, 18 years old, are they still alive, how are they? I wanted to get any kind of information that I could, but connection would always break down and all we could hear was the term "nazocni" being used, the duty officer. Now, that is the worst period in my life and I can't rid myself of those images to the present day.
Q. Yes, I do believe you there when you say that. Now, would you please take a look at page 144, the penultimate paragraph. This is Simovic's explanation once again, and he says this: "Different armies clashed. The one wanted to liberate Osijek; the others wanted to take over Western Slavonia although that was not the object." Is that what Simovic says, this was never a goal, this takeover? And he continues and says, "Because we were fighting for places where the Serb population was in the majority but each one pursued his policy and tasks. And when they would encounter a trap, they said that the army was disloyal and would not help them in the fighting."
A. Yes.
Q. So these people who were outside anybody's control called the army a traitor army; whereas, the army tried to play, as Simovic had said - and I quote him from your book - the role of a buffer zone between the 27904 attacks and attackers and to protect the settlements which were supposed to be protected and defended from these individual, mutual clashes.
A. Yes, Comrade President, that is correct.
Q. Then in the next sentence he goes on to say, "The army did not wage a war of conquest. They were fighting for places in which the Serbs lived as the majority population and the fighters from those parts wanted to liberate their own thresholds." He goes on to explain that. "But not in places where they were in the minority and the fighters from those places wanted to defend their own thresholds." And that's where the confusion sets in that he talks about, and which the State endeavoured at the time to calm down and not to allow this chaos to break out, the chaos that was developing and the situation to which Simovic reacted. Isn't that so, Mrs. Gajic-Glisic?
A. Yes. Mr. NICE: Mr. Whiting thinks page 105. You're probably there ahead of us.
JUDGE KWON: It's in -- in page 104, in the penultimate paragraph.
Mr. NICE: Thank you very much. I've got to withdraw for just a couple of minutes. Mr. Whiting will remain, representing us.
Mr. MILOSEVIC: [Interpretation]
Q. And take a look at page 169 now, please, the end of that penultimate paragraph. Otherwise, the chapter is headed "Secret Bad Sides and Open Good Sides." "The army has no pretension with respect to any 27905 BLANK PAGE 27906 Yugoslav republic, but it cannot sit with its hands crossed while some of its garrisons were still found under siege," said Simovic. Was that so or not?
THE INTERPRETER: Microphone, please.
A. The barracks were under siege and Croatian wives were standing around. A large number of barracks throughout the territory of Croatia had been held under siege. The soldiers were left without electricity, food, without anything, in fact, and that is why we organised the column of buses taking mothers to visit their sons. The title of that chapter was, "Secret Faults, Open Virtues."
Q. I should like to draw attention to page 152, the middle passage. Simovic says, "There were 14 truces thus far and all of them broken by Croatia. During those truces, according to the data which I have, your country" - because he's being asked by a Hungarian journalist, it seems - "Hungary is flying planes into our air space and weapons are being imported through your country." Is that how it was?
A. Yes. And I should like to remind you, Comrade President, that there were municipalities with a majority Hungarian population and that the danger existed of new conflicts breaking out all the time, because the Hungarians wanted to join up with Hungary, the state of Hungary. And I think that it was in agreement with you that the foreign minister of the day, Vladislav Jovanovic sent a letter of protest to the embassy of Hungary, if you remember.
Q. Yes. There was quite a lot of that going on. And probably it is as you say it is. 27907
JUDGE MAY: Just one moment. We need to find this latest quotation. Can the Prosecution assist?
Mr. WHITING: I haven't found it yet. I'm looking.
THE ACCUSED: [Interpretation] Page 222 of the book. It is the middle paragraph.
JUDGE MAY: 222? You said 122. Let's find -- let's find 222 then.
THE WITNESS: [Interpretation] 250.
JUDGE MAY: Which --
THE ACCUSED: [Interpretation] 232.
JUDGE MAY: 232.
THE ACCUSED: [Interpretation] Yes, page 232.
JUDGE MAY: All right. We will find it. Just one moment while we find it.
Mr. MILOSEVIC: [Interpretation]
Q. "So far there have been 14 truces or cease-fires." It is how the middle paragraph begins.
JUDGE MAY: Yes, Mr. Whiting. Mr. WHITING: It's the middle of the page, 167.
JUDGE MAY: Thank you. Yes.
THE ACCUSED: [Interpretation] I hope you've found it?
JUDGE MAY: Yes. Mr. MILOSEVIC: [Interpretation]
Q. It says, "14 truces, each violated by Croatia," and then goes on to speak about the infiltration of weapons, et cetera. 27908 And then one more sentence - that comes at the end, the epilogue - on page 313, you say, "The minister of defence, without an army, the president of the republic, without the capacity of having the Supreme Command." I'm just quoting that for the moment. Mrs. Gajic-Glisic, you know that it was always our option to favour Yugoslavia.
A. Yes.
Q. You know that in the constitution of Serbia, which was written in such a way, that Serbia has all -- enjoys all the competencies when the crisis was in its throes, when the constitution was written, in fact. But in one article of the constitution it says that the competencies and authority enjoyed by the federal state, pertaining to the federal constitution, are executed in the federal state and in conformity with the federal constitution. Therefore, is it quite clear that the Republic of Serbia, with respect to the Yugoslav People's Army, did not have any competencies?
A. Yes. You were not the Supreme Commander of the Yugoslav People's Army. And as far as I - if Their Honours will believe me when I say this - as far as I was able to note, the army -- or rather, the person who had the weapons wielded the power.
Q. Well, yes, that is quite usual and customary, especially in war situations. But according to what you said, and because Mr. Nice did not let you finish what you were saying, you said that there are laws which show that the apparent authority was in the hands of the president of the republic, as if I had taken over this competence from Simovic's hands. 27909 Neither Simovic nor myself had any competence and authority over the Yugoslav People's Army, nor could we have had it. Is that right?
A. Yes, that is right. But let me just remind you that when I was speaking about national defence and the law on national defence and the competencies and authorities there over the Defence Ministry, having said that General Simovic did not have any authority, not even to measure up with an accountant, as I put it, I said that pursuant to an article of the law, that is to say, Article 6 of the law, which stipulates that the president of the republic in the organisation and preparation for defence heads the armed forces in peace and war, including authority to solve organisational and personnel matters in the Territorial Defence. So I wasn't speaking about competence and authority in respect of the JNA. That doesn't come under my competence.
Q. Yes. And do you remember that since you were in the Ministry of Defence yourself that it was even the command of the republican staff of the Territorial Defence that was nominated and appointed by the SFRY and not the president of the republic in any of the republics until these other republics had seceded, but in Serbia, for instance, that was at that time the competence and authority of the Yugoslav state presidency? I'm sure you'll remember that.
A. Probably. But allow me to say that I can't know everything, and I don't claim that I do know everything.
Q. Of course. You needn't know everything. That's quite true. So you talked about an event here. You said that when there was some sort of crisis where in those conflicts in Slavonia, as far as I can 27910 remember, a large number of civilians was at risk and members of the Territorial Defence, and you said this was in October or November 1991, and I asked Simovic to entreat the people in the JNA to fly over in planes, not to drop bombs, but to fly over in order to help them.
A. Yes. I didn't say that you issued the order. I didn't say that he was able to issue an order to them. I said that both you and he entreated them to do that.
Q. So I am asking Simovic, because he was a general and before that he was the commander of a military district, the Skorpion military district, and he was a very high-ranking general, I was asking him to use his influence and to entreat them to fly over in order to help those people there.
A. Yes. Yes. What's in dispute here?
Q. Nothing. Nothing.
A. Thank you. I thought I said something wrong.
Q. No, no. Nothing was wrong.
JUDGE MAY: [Previous Translation Continues] ... just remember, Mr. Milosevic, this isn't a private conversation. It's got to be interpreted. So will you leave a pause, and would the witness be kind enough to leave a pause after he's spoken. Thank you. So remember the interpreters.
THE WITNESS: [Interpretation] I apologise to Your Honours. Mr. MILOSEVIC: [Interpretation]
Q. Mrs. Gajic-Glisic, this event that you described is something I wanted to clarify again for a simple reason, because you as an eyewitness 27911 BLANK PAGE 27912 are saying that I asked Simovic to ask his colleagues from the JNA to fly over for the simple reason, as I said, is that the claim is being made here that I commanded the JNA. And you as an eyewitness say that I had to entreat Simovic to entreat those people of his over whom he did not have any command either to fly over. Had I been commander, I would not have had to ask Simovic to ask them to do that; I could have ordered it. Is this clear or not?
A. Yes.
Q. Thank you very much. Let's go on. You described -- I made a note here during your
examination-in-chief -- you described a meeting between Simovic and Hadzic where Hadzic was to be introduced to the Serbian public because he was representing the Serbs from Eastern Slavonia, Baranja, and Western Srem at the conference in The Hague. Is this correct?
A. Well, you've confounded two time periods. But let me hear your question to the end.
Q. I just wanted you to explain what you said later without being asked, in connection with this, that I didn't even know who Hadzic was. I wrote down, "Milosevic asked Simovic, Who is Goran Hadzic?" You said that?
A. Yes.
Q. And he was already in The Hague.
A. He was already on his way to The Hague.
Q. He was already in The Hague as a representative of the citizens of Eastern Slavonia, Baranja, and Western Srem. I am not contesting the 27913 right of the citizens in Eastern Slavonia, Baranja, and Western Srem to elect Goran Hadzic and send him there as their representative. This is not in dispute and this is not what I'm asking. But is it in dispute that when he was already in The Hague as an elected representative I didn't even know who he was?
A. Unfortunately, Comrade President, when Goran Hadzic came to the Ministry of Defence, Goran Hadzic didn't even know what he was president of. Later on you asked, "Well, who in fact is this Goran Hadzic?" General Simovic called General Nenezic to ask where Goran Hadzic was coming from. General Nenezic said that Goran Hadzic was a relative of his, that he had been a warehouse-keeper in the area, that General Nenezic wanted to push him as a politician and that he was in fact the self-styled president of the area and that it was too late now to correct all this because Goran Hadzic was already in The Hague. I describe that in detail in my book.
Q. We don't have time to go through that. I just wanted to establish on the basis of your testimony as an eyewitness of these material facts that at the time that he was already at The Hague and I asked Simovic, Who is Goran Hadzic? I didn't even know who Goran Hadzic was.
A. Well, I assume you didn't have all the correct information, that General Nenezic and the others around you had misinformed you.
Q. Well, I don't even remember General Nenezic. What was he doing there?
A. He was organising the rebellion of the Serbs over there in those 27914 areas.
Q. Was General Nenezic already retired?
A. Yes, he and General Pekic were the ones who went to those areas. Often they went back to their youth and raised revolutions.
Q. But these were pensioners, old-age pensioners who were doing things on their own initiative.
A. Yes, that's correct.
Q. And then you mentioned something about a conversation of mine with Simovic - I just want us to clarify this - in connection with the Territorial Defence in Slavonia, Baranja, and Western Srem. You said that there was some confusion and that Hadzic appointed Stojicic as the commander of the Territorial Defence. Did you say that yesterday?
A. Yes, I did.
Q. Do you know that Stojicic was a volunteer, that he went there as a patriot to help?
A. I'm not aware that he went there as a volunteer. Nobody told me that, that he had gone there as a volunteer.
Q. And Goran Hadzic appointed him commander of the Territorial Defence?
A. Well, that was the source of the confusion, because he was a policeman from Belgrade who went with his special unit.
Q. He didn't go with a special unit, he went in another way, but he went there as a volunteer and patriot. And Goran Hadzic appointed him commander of the Territorial Defence. Is this in dispute?
A. No, it isn't. 27915
Q. And it's not in dispute either that I said to Simovic, "There's some confusion over there. Hadzic appointed Stojicic commander of the Territorial Defence."
A. Yes.
Q. Thank you very much. Tell me, please, before we move on, I understood that you wanted to say more but due to shortage of time Mr. Nice interrupted you, so I will use my time now to ask you what did you know about the sufferings of the Serbs in Croatia while you were in the ministry and before and after your work in the ministry? What did you find out about the sufferings of the Serbs in Croatia?
A. It was dreadful. It was dreadful. The Serbs were expelled from their homes. Serbs had to flee with only a plastic bag in their hands. Those rooms in the 13th of May that were used for training and to put up those who were being trained, the first Serbs who were expelled after the arrival of Franjo Tudjman in power, the first refugees were Serbs. These Serbs would come and they had nothing, nothing. Many of them lost their families. They didn't know where their families were. We received photographs of slaughtered Serbs. I think, Comrade President, that we prepared a bundle of those photographs for you as evidence for The Hague, but unfortunately I gave the photographs I had to my friends with approval of a colonel from the -- who approved that this be given for them to show their families in Switzerland. They were all burnt. I apologise to Their Honours, what I have to say when I remember those pictures, their limbs had been cut off and pushed into their mouths. There were very many 27916 refugees. For example, at that time in Serbia there were 150.000 refugees from Western Slavonia. And according to the lists and our knowledge, in Western Slavonia there were 60.000 people, 60.000 Serbs, and suddenly in Serbia 150.000 refugees turned up and most of them were in Novi Sad, in Sid.
Representatives of trade unions came to see us because they were unable to find firewood, heating fuel, there were no classrooms, there was not enough money to buy books for those children. They didn't have food. At the time it was awful. On the other side, we had Milan Babic, who kept coming to the cabinet and kept threatening to bring 300.000 Serbs more unless we mobilised Serbs from Serbia to go and defend the Serbs from Croatia. It was a terrible time. At that time, children were imprisoned in barracks in Croatia, mothers -- mothers wept, screamed. They burst into the government buildings. Nobody dared go and face them. I think you asked Simovic to send me to talk to those mothers, and I wept in front of them, and I begged them to go on our knees, to bring our sons back and to look for them, even if we were killed. There were -- it was terrible. In Serbia there was not enough fuel. There was not enough food. There was not enough firewood. The situation was terrible. Those who were mobilised came back from the war front. We had invalids who arrived without legs, without arms, and we were unable to provide them with their basic means. They would sit there with their crutches in front of the government building, and we had to jump over them. The situation was terrible.
Sometimes I didn't leave the cabinet for days, and we worked for 27917 BLANK PAGE 27918 days on end.
Q. Thank you. You could probably say a lot about the sufferings of the Serbs in Croatia --
A. Oh, yes.
Q. -- at the time, but due to time constraints, I can't ask you to do that.
You provided here an interview given by Lieutenant General Tomislav Simovic on the 19th of November, 1991. I took this from your tab. The ERN number is 02905739. When I say "yours," I don't mean -- I'm not talking about you.
A. Yes. I have the original text here.
JUDGE MAY: I think -- I think, Mr. Milosevic, before we go into the document, it is in fact time to adjourn. So we'll -- we'll return to it. We'll get the tab number from the Prosecution. I take it to be one of their documents that's being referred to.
We'll adjourn now, and we'll come back in 20 minutes.
--- Recess taken at 10.31 a.m.
--- On resuming at 10.56 a.m.
JUDGE MAY: Yes, Mr. Milosevic. Mr. MILOSEVIC: [Interpretation]
Q. I assume, Mrs. Gajic-Glisic, that you are aware of the fact that the General Staff of the JNA, in that period, that is, the period when you were working in the Ministry of Defence, when talks had already started with Mr. Cyrus Vance, the emissary of the UN, about the arrival of the UN forces -- so do you know that the General Staff kept insisting that the 27919 barracks be unblocked so that the army could withdraw from there without casualties and without conflicts?
A. Yes.
Q. Do you remember applying to Lord Carrington that there were agreements between the JNA and Croatia, that this should be made possible, but that this was not made possible?
A. Yes.
Q. I now draw your attention to this interview. And I have told you the ERN number. I will not read it all, of course. Mr. NICE: It's tab -- it's tab 1 of Exhibit 568. Mr. MILOSEVIC: [Interpretation]
Q. In the middle column of the interview, the question is put whether the JNA was mostly a Serbian army according to its composition, as was often heard. And his reply was, "It is just partly correct. According to its ethnic structure, the JNA has still got approximately 27 per cent members of other nations and nationalities, aside from the Serbs and Montenegrins. It means that realistically its permanent and variable peacetime structure mainly consists of members of the most numerous nation, the Serb one in this case, which was the case before as well but to a smaller extent. The fact that that ratio is now somewhat bigger is a consequence of the past political and military developments in the territories of Slovenia and Croatia and the behaviour of leaderships of certain nations and nationalities in Yugoslavia. I can say that the JNA was turned into a Serb army, referring to its structure, exactly by those leaderships who invited their peoples to abandon it and start fighting 27920 against it." Is this an indisputable fact and is what General Simovic says in accordance with the actual situation and the events in the period that you are testifying about?
A. Yes. General Simovic gave this interview to Mr. Ivica Dacic in my presence, in our cabinet. And it's an authorised interview. It's correct.
Q. In the first column, he speaks of the protection of the Serb people from the renewal of genocide. You have just spoken of the sufferings of the Serbs in Croatia, of the 150.000 refugees then in Serbia. Is it contested that the Serbs at that time had very serious reasons to be afraid, because they were exposed to physical extinction?
A. Yes.
Q. At the end of his first reply, in the first paragraph, he says, "Objectively the Yugoslav People's Army did not have any other option facing the situation when the Ustasha units were adamant in their intentions to destroy the Serb populace." Was this the reality everyone was facing?
A. Yes. We were all very afraid of this. At any moment Serbia was threatened with attack, and you know that it was attacked in Sid. Sid was attacked. You were in The Hague at the time, and we were all communicating at that time.
Q. It was shelled from Croatian territory?
A. Yes.
Q. On the territory of Serbia. You go on to say -- just let me find it here -- that there was a 27921 meeting between General Jovic, who was already retired, is this correct, at the time?
A. Yes.
Q. And he was at one time in the peacekeeping forces of the UN?
A. Yes.
Q. One of the peacekeeping missions that Yugoslavia took part in.
A. Yes.
Q. And he knew Marek Goulding who was the assistant of the secretary-general for peace operations.
A. Yes.
Q. And he met him in private?
A. Yes.
Q. And this conversation that you describe in fact took place because everyone was interested as it was at the height of Cyrus Vance's activity and negotiations all over Yugoslavia with representatives of the authorities of the Krajinas, with us in the Presidency of the SFRY, in the Presidency of Croatia, and so on, about bringing in peacekeeping forces.
A. As far as I can remember, Marek Goulding was the first person to propose bringing in peace forces, and you accepted that the moment it was mentioned.
Q. Well, you don't know that.
A. Of course.
Q. Because this was in the context of negotiations held by Cyrus Vance. Marek Goulding came along with him, and he was the assistant for peacekeeping operations. You drew up this note, which is tab number 7. I 27922 won't quote it in its entirety, but it boils down to, as I see, a telephone conversation between Jovic and President Milosevic from your cabinet, the cabinet of the minister of defence, where he is giving information to you and by telephone to me about his conversation with Marek Goulding.
A. Yes.
Q. And you drew up these minutes in order to have information recorded on what was essential in that conversation; is this correct?
A. I made an effort to take down everything to the best of my ability. And immediately afterwards I typed out these minutes and brought them to your cabinet personally.
Q. Yes. And now I wish to draw your attention to page 2 of these minutes. In the paragraph before last, he's describing how Goulding came to Yugoslavia to see about the possibility of bringing UN peacekeeping forces to Yugoslavia. And he says that they talked about the Yugoslavia of 1918 to 1941 through 1945, and he understood the role of Germany in all this, accepted the thesis about the Fourth Reich and the revision of the Second World War. "He knows what Milosevic has done for Serbia. I familiarised him with what Gorbachev did. I told him the US will be sorry for breaking up Russia," and so on.
And then you say -- not you, but you drew up the minutes -- he asked who Babic and Hadzic were and whether they could provide guarantees. Everybody then wanted guarantees that nobody would attack the UN peacekeeping forces. Is this correct?
A. Yes. 27923 BLANK PAGE 27924
Q. That they would accept the peacekeeping forces of the UN. That was our stance from the very beginning, to accept the UN peacekeeping forces, to put an end to all conflict, and to seek for a peaceful resolution of the crisis.
A. Yes. This was your sentence, which I was not allowed to take down. I could only take down what was said inside our cabinet.
Q. And he was asking about the volunteers and so on. He said he knew who the black-shirts were and asked for a guarantee from Paraga. You know who Paraga is; is that correct?
A. The leader of the paramilitary organisations in Croatia.
Q. At the time, did these paramilitary forces commit atrocities against the Serbs?
A. Yes, as far as we were able to ascertain. And General Vracarevic spoke of this, and this is in a part of my book entitled "The Dogs of War."
Q. Very well. And at the end of this paragraph, he says, "The principle of the UN boils down to understanding the technicalities of separating the sides at contact point." And he was confused about the behaviour of the Croats and the request that peacekeeping forces be deployed along the administrative borders. He's not clear about the volunteers. Then we come to the demand that a Serbian army be established. And as this idea was not accepted by Serbian policy, the advocates of a Serbian army were recorded as volunteers, registered as volunteers. And then there is mention of the "Guard" and that a company does not go over 1.000, and so on. 27925 Is it in dispute that he says that "The creation of a Serb army was not well received in Serbian political circles"? We were in favour of Yugoslavia, Yugoslav institutions and the JNA.
A. But at that time we simultaneously worked on the draft bill on the armed forces of Serbia. You know this. But the idea, after it was published in the press on the 5th November, was ferociously attacked by the JNA.
Q. We did not want to make the position of the JNA more difficult, or of any Yugoslav institution in any way. Is this correct?
A. Yes, this is correct. And in my book, I speak of the reorganisation of the JNA in the existing borders, the new borders, whether it would be a rump Yugoslavia or a Yugoslavia consisting only of Serbia and Montenegro, or whether it would be just Serbia alone. And this draft bill on the armed forces of Serbia had three versions, three variants.
Q. But you remember that in April the Federal Republic of Yugoslavia was promulgated and that according to the constitution the army of Yugoslavia was established?
A. In 1992.
Q. Yes, in 1992. This was several months later, after those others were recognised, when the FRY was established and the same joint session of the parliaments of Serbia and Montenegro on the part of the Yugoslav parliament that stayed behind, a declaration was issued that the FRY did not have territorial pretensions towards any Yugoslav state. Do you remember that? 27926
A. Yes. But that was after I was driven out of my job in the ministry. So this does not belong to what we are talking about here.
Q. Your testimony. Yes, I accept that, and I will not ask you about this further.
In your book, as I see in the summary, you mention me quite a lot. In your book, I came across a passage where you -- and please correct me if I'm wrong, because I had to skim through the book -- but you mention me in five places. For example, on page 60, the chapter is entitled "Genocide Before the World." And you say the following in that first sentence there: "During those days, there was a meeting, a tete-a-tete, between Simovic and Milosevic." And then he started to say -- this is at the bottom of the page -- what had to be done urgently, and then goes on to explain what the urgent tasks were. He says that all photographs and tapes, which we have and which relate to relations with respect to the genocide of the populace in Serbian Krajina, should give to the -- be given to the Ministry of Information for a book to be published and for documents to be compiled for The Hague. Is that right?
A. Yes.
Q. So this talks about efforts to hold political talks and to present the truth as clearly as possible about the actual state of affairs in which the Serb population in Croatia found itself and the dangers which were ultimately the reason for which the UN peacekeepers arrived and proclaimed zones under their protection, UN-protected areas. Is that right?
A. Yes. 27927
Q. So when The Hague is mentioned here, it is mentioned in the context of the peace conference and not in the context of this institution.
A. Yes. I think that that was on the 18th of October, The Hague Conference. Put me right if I'm wrong.
Q. Yes, in 1991. I don't know the exact date, but it's not important. The important thing is that that first meeting that you describe here in your book has no -- nothing to do with any armed operations, but what it is about is the gathering of information geared towards political negotiations through the mediation of the international community. Is that right?
A. Yes, that's right. And as far as I remember, you were in The Hague on the 18th of October and later on, on the 5th of November, if I'm not mistaken.
Q. Yes. There were several occasions.
A. Well, I apologise, a lot of time has gone by since then.
Q. Yes. There were a lot of meetings, but the point of what this is about is that the talks related to the preparation of information with a view to political negotiations and talks and not any kind of military operations.
A. Does it say "military operations" here?
Q. No, no, it doesn't. I just wanted to clear that point up.
A. Thank you for that. Yes, that is correct. And I believe I described it correctly.
Q. Now take a look at page 112, where you mention me once again. 27928 And you say the following - and this is in the paragraph that is in the middle of the page - "Our position at this meeting, and it is the Assembly meeting, expressly demands the formation of a Serb army. It was clearly requested that the president of the republic, Slobodan Milosevic, take on the role of the Supreme Command of the army of Serbia. And that is something that was not supposed to be uttered then and I don't suppose today either." Now, this explanation, that we were quite clear in our stance in favour of Yugoslavia and for preserving Yugoslavia and that we considered it indispensable to support the Yugoslav People's Army as a Yugoslav institution; is that right?
A. Yes, that is right. But I don't contest the fact either that at the same time we were working on the law for armament of the Republic of Serbia.
Q. Yes. That's another matter. Professional work to prepare a bill.
A. Mr. Nice referred to a secret law or bill of some kind. There was no secret bill or law. You worked to prepare the law as every ministry does within the field of its responsibility, and once it is prepared it goes to the assembly boards and goes to regular assembly procedure. It is never secret.
A. Well, I didn't understand Mr. Nice to say that it was a secret law. What I understood him to say, that everything that was done in the ministry was to a certain degree of secrecy and confidentiality. And what was being done there couldn't be presented to the public just like that.
Q. Well, yes, of course. And that is natural for ministries such as 27929 BLANK PAGE 27930 the Defence Ministry, the Ministry of Internal Affairs.
A. Yes, Comrade President. And this was a precedent, in fact, that somebody should put forward and state what was going on in a series of articles in the Nin magazine, and that led to a whole affair that was equated to the Watergate affair.
Q. Yes. But there were no consequences? Mr. NICE: The issue of secrecy was, I think, initially raised in a neutral way and I think it was the witness's first answer that spoke of the way in which matters were dealt with and I will have to check the transcript to find whether she used the term "secret" or not. I'm not sure that I used the word "secret" after that. But the evidence emerged from the witness's mouth, not from mine on this topic.
JUDGE KWON: And for the sake of the record, the passage of page 79 of the English translation.
Mr. MILOSEVIC: [Interpretation]
Q. Very well. Now, the third place in your book, where you mention Milosevic again, in the context this time of your description of what Simovic talked about to Babic, that is page 159. Have you found page 159?
A. Yes.
Q. And then Babic replies - and that's how the page begins - and in paragraph 1 he says, "The President is accusing us -" the President, meaning me -- "is accusing --"
A. Could you repeat the page number, please.
Q. It's 139. I apologise for reading it out wrong. Have you found that? 27931
A. Yes.
Q. Babic's answer was -- and you recorded this, because you attended the meeting between Babic and Simovic. He says, "The President is accusing us, and first of all I was surprised because I asked you to leave the TO as an armed force and not to withdraw the JNA." And Simovic says, "This has nothing to do with the withdrawal of the JNA, nor was that what was being asked." And then you go on to say --
JUDGE MAY: [Previous translation continues] ... Mr. MILOSEVIC: [Interpretation]
Q. Then you go on to say that Simovic was already quite irate and said what Babic was asked to do was neither a request made by Milosevic or Simovic. And he adds, "What am I here? Just a balance between the two of us? I want you to know that that is so because that is the sole condition for the arrival -- the only precondition for the deployment of the United Nations forces. Babic would not accept it," and so on and so forth.
THE INTERPRETER: Microphone, please.
JUDGE MAY: The record should show, as Judge Kwon said earlier but it wasn't taken down, that this appears at page 100. It's important that we have for the record not only the B/C/S version but also the English version so those who come after us can follow what's being said. Yes, Mr. Milosevic.
Mr. MILOSEVIC: [Interpretation]
Q. Therefore, he is emphasising, and I repeat the last sentence of that quote, the one that I selected where my name is mentioned: Simovic says, "I would like you to know that that is -- I want you to realise that 27932 this is so because that was the only precondition for the deployment of the UN forces." So this is prevailing upon Babic to accept the arrival of the UN forces; is that right?
A. Yes, as far as I remember, you had a great deal of problems with Babic at that time, who did everything off his own bat.
Q. All right. So this third excerpt from your book, where you mention me, that too is geared towards a political settlement and the arrival here in actual fact of the UN forces for which we are advocating, which Serbia is advocating and which the president of the SFRY advocated and which I was in favour of personally.
A. Yes. We were all in favour of the arrival of the UN forces. We all advocated that. And we were even prepared to make all the concessions necessary.
Q. And the reason for that?
A. Was peace.
Q. Exclusively?
A. Peace.
Q. Yes, that's right. Then you go on to mention me for a fourth time in your book, once again. It says, "Put off until eternity." This is page 202 of your book, I don't know what the page is in English, where you say that "the proposal came from this ministry," which means your ministry was proposing that General Veljko Kadijevic - General Veljko Kadijevic at that time was the Federal Secretary for National Defence, the number-one man in the JNA - and the president of Serbia, Slobodan Milosevic, should have a meeting and 27933 decide what to do next. "Simovic insisted that this should come about as soon as possible."
JUDGE MAY: Yes. And the English, please? Mr. NICE: 146.
Mr. MILOSEVIC: [Interpretation]
Q. Then on the next page, it goes on to say that "Since the problems that exist --" or rather, "The JNA has great problems because of all these events." And we've already mentioned that. And you go on to say in paragraph 2 on page 203 that "The clear question should be asked which the key problems are in taking over the territorial organs and territory, how far we have come in that regard, and what it is that the Republic of Serbia has still not done in order to make the mobilisation successful." So we are talking about that part of the competency, that was the sole competency that the Defence Ministry had, that is to say, with respect to mobilisation, keeping military records, and so on and so forth. It was that portion which belonged to the republican ministry, that came under the republican ministry, with respect to administrative matters having to do with military recruits from its territory.
A. Let me just remind you that the Defence Ministry of Serbia did not have any competence and authority over the mobilisation of military conscripts unless the reconnaissance and notification service -- unless you mean that.
Q. Yes. Thank you for adding that. So it only had these very limited duties.
A. Yes. 27934
Q. And that is why it is stated here that it should be clearly seen what Serbia has failed to do, because the question keeps cropping up about why the problems with respect to mobilisation, what we hadn't done and which was under our competency.
A. Yes. The mobilisation process had been taken over by the military departments, which had now come under the Yugoslav People's Army and its departments.
Q. And finally, on page 204 -- it is the last sentence of this chapter, on page 204, it says, "The Milosevic-Simovic-Kadejivic meeting never came about. Nor did a Serb army ever come about."
A. Yes. And that was the last conversation that you and General Tomislav Simovic ever had.
Q. Well, you have enumerated four such talks, four such instances.
JUDGE KWON: It's the last paragraph of page 146. Mr. MILOSEVIC: [Interpretation]
Q. You enumerated four such conversations. And you also mention me on one more page, 212. You say, "They can't decide about that." And then you go on to say, "A meeting has been scheduled for tomorrow with President Milosevic, which is compulsory, and General Panic with his associates, Jokic and Sokolovic, Jokic, Commander of the Territorial Defence, Minister Simovic, to be present. Minister Simovic should come a little earlier. However, this meeting was called off at Milosevic's request as there would be no meeting and a solution would follow." I mention this because no meeting ever took place. So judging by what you write here in your book, I had three 27935 BLANK PAGE 27936 meetings in actual fact with Simovic, the one where I mentioned -- and one of the ones I quoted was a meeting with Babic, where he says that they were not the demands made by either Milosevic or Simovic but it was a precondition for bringing in the UN forces. So -- and now this fifth instance where I mention the meeting wasn't ever held; it was called off. Is that right, Mrs. Gajic-Glisic?
A. Comrade President, how many meetings you actually had with General Simovic I did not count them all. There was another meeting where I arrived with General Simovic, and then I wasn't able to enter your office. So that was one more meeting. And General Simovic told me that he was going to have a meeting with you, he was going to you for a meeting. When I wrote this book, I did not write it for the Tribunal. I did not write it for check ups of this kind. So I can't say exactly how many meetings you did have in actual fact. All I can do is to speak about the telephone conversations which I attended, the ones you had. And so I speak here about what you call - I don't know - firsthand, secondhand, or third-hand knowledge. I just told you what General Simovic told me.
JUDGE MAY: Wait a moment. The reference in the last passage is 154 in the English.
Yes. Mr. MILOSEVIC: [Interpretation]
Q. Mrs. Gajic-Glisic, I'm not questioning your goodwill to testify to the best of your knowledge and to answer questions frankly and sincerely. All I'm doing is and I assume you will allow for the possibility of the fact that you couldn't have known certain things, when 27937 you're talking about Marek Goulding, for example, as making the proposals and that it was Cyrus Vance's idea and that it is indeed called the Vance Plan. But that doesn't matter. I'm just quoting that by way of an example. But you allow for the possibility that perhaps you didn't know everything fully, perhaps you didn't hear properly about certain things in a situation of tension. You might have even interpreted things differently.
A. Well, no, but all of us are prone to make mistakes.
Q. All right. Well, let's take another example here, something that I would say is fairly - how shall I put this - radical. Take a look, please, at your statement in which you say the following: "That it was precisely because of that law, the one that was being drafted, that General Zivota Panic --" What was General Zivota Panic at the time?
A. Commander of the 1st Army District.
Q. Yes, commander of the 1st Army
A. And I think he was the commander for combat in Vukovar.
Q. He stormed into my cabinet wearing full military gear, combat gear. And I'll read paragraph 103 of your statement, which states as follows: "General Zivota Panic entered Milosevic's cabinet with his escorts. He allegedly accused Milosevic of creating a Serb army. General Panic forced Milosevic to order the Prime Minister of the Serbian government, Dragutin Zelenovic to tender his resignation so that the government of Serbia could not adopt a law on the armed forces of Serbia." Don't you think this to be highly improbable?
A. Comrade President, the secretary, Mrs. Mira, called me up on the 27938 phone and said, "Dobrila, don't give out any information to the information media because General Panic, in full army combat with all his entourage, stormed into Mr. Milosevic's office and solutions will follow, settlements with follow." So that was the conversation between myself and your secretary. I didn't even take this too seriously -- or rather, I didn't understand the seriousness of the situation. A little before that, in our cabinet, we had the presence of Mr. Dragutin Zelenovic. He was there talking to Simovic. And we leafed through the documents that had already been typed out, the documents compiled in Batajnica on the 13th of May. The president of the commission was Buda Kosutic. We were discussing having this discussed at a closed government meeting. So I attended that particular conversation when General Simovic went to attend a government meeting. He came back some 20 minutes later and said, "The government has fallen and Zelenovic has tendered his resignation." And then I told him what Mira, your secretary, had told me prior to that. And he said, "Well, a putsch has taken place." I said, "What putsch?" He said, "A coup d'etat."
Q. Mrs. Gajic-Glisic, from what you're saying, General Simovic informed you all of his conversations with everybody else. I can see that that would emerge from the way you put things. Now, I'm not entering into his methods of work. However, as far as I'm concerned, I never informed my secretary about the contents of my conversations with anybody. Nor did I have this kind of relationship with her that I felt it necessary to inform her of my conversations.
JUDGE MAY: Wait a moment. The witness can't answer for that. 27939 She can't know what you told your secretary. All she can say is what the secretary told her, and that's her account. Now, if you have some information that that account is wrong, of course you can put it. But you can't -- she can't answer for your relations with your secretary.
THE ACCUSED: [Interpretation] Mr. May, the witness, in point 103, says that General Panic forced me. I don't know how he could force me. But she says he entered armed to the teeth. That is a complete untruth. Panic never entered with an entourage of any kind into my office. He did come to see me, but he wasn't armed to the teeth, of course, and not to threaten me and to frighten me and to make it impossible for me or for Serbia to pass a law of any kind. So I hope you will allow for the possibility of the fact that you, Witness, understood this wrongly, because my secretary could never say something --
JUDGE MAY: Let the witness answer.
THE WITNESS: [Interpretation] I am here under oath, and I remember very well to the present day the sound of her words, and I stand by what I said, that that is what Mira told me on that occasion. Now, what happened --
Mr. MILOSEVIC: [Interpretation]
Q. Mrs. Gajic-Glisic, I really don't want to enter into what secretaries talk about amongst themselves, but can you conceive of a situation in which any general could storm into my office, whether Panic or anybody else, armed to the teeth and force me to do anything and that I would be frightened by that and to say, "All right, that was a joke. We're not going to pass a law and Zelenovic can tender his resignation"? 27940
A. It's a fact that on the next day Zelenovic resigned.
Q. Well, of course you didn't attend the cabinet session at which he resigned.
A. No, I didn't.
Q. Do you know what Zelenovic gave as the reasons for his resignation? It had nothing do with the enactment of the law on the armed forces. It had not even been prepared for the parliament.
A. He didn't give any explanation, apart from the letter I handed and which you have amongst these documents.
Q. Zelenovic's letter?
A. Yes.
Q. What does the letter say? Tell me, please - since you handed it in, I don't have it with me now - but what does Zelenovic say in that letter? Every Prime Minister has the right to resign.
A. It's very brief, just two sentences. Should I --
Q. Yes, please read Zelenovic's letter of resignation.
A. Can you help me? Can you give me the document number? What's the tab? Since --
Q. Unfortunately, I cannot. I have too much paper here. I can't help you.
JUDGE MAY: One moment. We'll -- we'll see if the Prosecution can help.
Mr. NICE: We're identifying it from rather a large number of documents, but we'll get there.
JUDGE MAY: Mr. Milosevic, why don't you go on to some other 27941 BLANK PAGE 27942 topic and they can look and we can return to it. It's a matter for you. If you want to wait, of course you can.
THE ACCUSED: [Interpretation] Very well. Of course I don't want to wait, because time is precious, Mr. May, but this claim is so unbelievable for anyone who knows.
JUDGE MAY: That's a matter of comment.
THE ACCUSED: [Interpretation] No, it's not a matter of comment. This is the first time I've heard that someone committed a coup d'etat in Serbia and the government fell for this reason.
THE WITNESS: [Interpretation] This was General Simovic's explanation, and I wrote it down for my book and not for the Tribunal. I stand by the conversation we had in the cabinet. That's how I noted it down. And it's not for me to think about what really happened in your cabinet and what you talked about with General Panic. Mr. MILOSEVIC: [Interpretation]
Q. General Panic, madam, General Panic had no competence. He was the commander of one strategic -- he had no competence to deal with any political issues.
JUDGE MAY: Look, that's not for the witness to answer. That's what she says she was told happened. Now, we will have to decide in -- in due course what weight to put on the -- the evidence. I suggest we find some other topic.
THE WITNESS: [Interpretation] I've just found the letter.
JUDGE MAY: Very well. The letter has been found. Perhaps you could read it for us. 27943 Mr. MILOSEVIC: [Interpretation]
Q. Yes. Read it.
A. "Dear Comrade President, In accordance with Article 93 of the constitution of the Republic of Serbia and Article 45 of the rules of proceeding of the parliament of Serbia, I hereby resign as the Prime Minister of Serbia. I take this opportunity, Comrade President, to thank the deputies for their understanding for the work of the government and for keeping their integrity and my integrity and for their cooperation with this office. I wish you all much success in your further work. Yours sincerely, Dragutin Zelenovic." It's his signature.
Q. Very well. So this is resignation of the Prime Minister. What has it got to do with the law on the army and what has it got to do with military matters at all?
A. Before writing this letter, he was sitting in the cabinet and talking to General Simovic about the draft bill on the armed forces.
Q. Well, he could have sat in anyone's cabinet and talked about various bills that were being prepared, but he did not resign because of a particular bill. The Prime Minister would resign in connection with a bill when it was rejected by the parliament, not when the cabinet hadn't even considered it.
JUDGE MAY: That's all a matter of comment. You've heard what the witness -- what the witness has said. Now, do you want that letter exhibited?
THE ACCUSED: [Interpretation] I have heard what the witness said. Yes, you can exhibit it or not, but these are incredible things, really. 27944 Please.
Mr. NICE: It's available in both languages.
JUDGE MAY: Yes. Thank you. We'll get the next D number, please.
THE REGISTRAR: Defence Exhibit --
THE ACCUSED: [Interpretation] Well, she read it, I suppose.
JUDGE MAY: Don't interrupt. Let us have the number.
THE REGISTRAR: Your Honour, Defence Exhibit 205. For the record, Defence Exhibit 204 is also exhibited as Prosecution Exhibit 387, tab 12.
Mr. MILOSEVIC: [Interpretation]
Q. Very well. Mrs. Gajic-Glisic, you say that Simovic was then replaced. You keep using the expression "the replacement of Simovic."
A. Yes.
Q. Very well, Mrs. Gajic-Glisic, are you aware that when the Prime Minister resigns, then the president of the republic gives a mandate to somebody else to form a cabinet? Are you aware of this?
A. Yes.
Q. Well, then, the resignation of the Prime Minister means that somebody else is given the mandate of forming a cabinet and this other person then proposes the composition of the cabinet to the parliament. Is this correct?
A. Yes, but previously consulting you.
Q. Whether they consult me or not. Well, there are some matters 27945 they consult me on and others they don't, depending on their importance. But what I'm asking you is this is not about the replacement of Simovic. It's simply that the term of office of the then-Prime Minister had been terminated and the new person who had been given the mandate to form a government selected his own ministers, and this is nothing unusual, because everyone who forms a government does so according to their own views and their own plans. So the Prime Minister resigned and the new Prime Minister is forming his cabinet. That's quite normal, is it not?
A. All this would be true, Mr. President, had not terrible repression followed on this. Marko Negovanovic, a general, came and said, "You wanted a Serbian army. I'll give you a Serbian army." And then he said, "You, you brought all kind of riffraff here. You brought Mosa [phoen] to my cabinet. What Serbian army? What law? Nothing will come of this."
Q. He was doing his job and he was dealing with the law on the army, which was part of his competence. Other ministers who arrived did their work. But you were not the only ministry there. There were 20 ministries in the government.
A. Well, not all ministers were replaced.
Q. Well, the new Prime Minister kept some and changed others. What's so strange about that? A new cabinet was established. He took some ministers from the previous government because he felt he had to keep them. What's so strange about this?
A. Yes, quite, Mr. President, but after that I was punished, and then I was banished from the ministry, and then I was banished to 27946 Batajnica, and then General Kuzmanovic and General Negovanovic allegedly ordered that I be liquidated urgently, and then Colonel Slobodan Jovanovic took me out barefoot, to run out on the 13th of May to save my life, and then even you intervened, according to what Mr. Milo Kligojevic [phoen] told me, and he said my life was not to be imperilled, and then General Aca Vasiljevic, who worked on part of the draft law on the armed forces of Serbia was taken to prison, and many other things happened.
Q. What did Serbia have to do with Vasiljevic? Vasiljevic was then in the General Staff. It has nothing to do with Serbia.
A. He attended meetings every Sunday -- or rather, every week, and he consulted General Simovic about this.
Q. I won't go into that, but here is another absurdity for you. I don't want to suggest by my means that you have told a lie. No, I simply want to draw your attention to the fact that you must allow that things may not have been the way you thought they were, especially as it was quite impossible for certain things to happen in the way you say, for Panic to burst into my office with weapons, for all of this to have something to do with the law on defence, and we were advocating Yugoslavia.
JUDGE MAY: You've already -- you've already covered all that. We've been over it. Let's go on to something else. Mr. MILOSEVIC: [Interpretation]
Q. Please, then, be so kind as to look at this, which is also absurd. Just let me find it. From what I see here - I'll read this out to you, although in paragraph 111 there are many things - but I'll start 27947 BLANK PAGE 27948 with what it says near the end of paragraph 111: "On the 14th of February, 1992, Tomislav Simovic arrived unannounced, which was unusual. He usually called before coming and announced his visit. This time he was devastated. He showed me the decision on his retirement. He told me that he had been called back from annual leave to the General Staff of the JNA and that there was no one in his office when he arrived. In the meantime, he had been promoted to colonel general and he worked in the General Staff of the JNA."
A. On the 21st of December, he was promoted to the rank of colonel general.
Q. Yes.
A. And he was moved to the General Staff, transferred there.
Q. He was no longer a minister but he was a general and he was given an assignment.
A. Yes.
Q. Now, please pay attention to this part of your statement. You say - I've just read this - "There was no one in his office when he arrived." I don't know why there should be someone in his office when he arrived. Probably as colonel general he had an office of his own, he didn't share it with anyone. And it says, "After some time, General Tumanov arrived." Tumanov was in the security service; is that correct?
A. Yes.
Q. I think that at the time he was a colonel and not a general.
A. After this, he was promoted to general very soon.
Q. Well, this doesn't matter really. I heard that he worked in the 27949 security service and that he did a good job.
A. Yes, evidently.
Q. General Tumanov arrived after a time and put a request to -- a retirement request on the desk.
A. Yes. He put this request on Simovic's desk.
Q. And Simovic was supposed to sign it.
A. Yes.
Q. So this request was already drawn up, and Simovic just had to sign it and he would be pensioned off.
A. Yes.
Q. So he put this request on his desk, pointed a pistol at his right temple, and ordered him to sign. He put the request on his desk, ordered him to sign it, and put a pistol to his temple. General Tumanov ordered him to sign this; otherwise, it would look like suicide. Did you write this?
A. Yes, I did write this. General Simovic stated this when he came to see me.
Q. He stated this?
A. He told me about this. And that night he told Zoran Bogavac about this and many other things, and Zoran Bogavac promised never to make this public. General Simovic immediately afterwards, faced with enormous threats and pressures, changed his story and said, "Oh, yes, I wanted to retire. I didn't get where I wanted. I didn't manage to set up a Serbian army. The Serbian variant has fallen through, I want to retire." And very soon he changed the story that he told me when he came to see me, and 27950 this same story he told Zoran Bogavac in his house that night.
Q. Very well, Mrs. Gajic-Glisic, I don't want to put you into a difficult situation, I really don't, and I don't know any of the -- the character of the dramatic relationships between General Simovic. But I have here a photocopy of the request by General Simovic. I have a photocopy here. And it has been registered in the Federal Secretariat for National Defence. The number is -- and it is authorised, the authenticity has been certified, et cetera. So here you have the request for General Simovic's pensioning off, that you say Tumanov put a gun to his temple, but this entire request was written out in hand, written by General Simovic himself in his own hand, so he couldn't have placed this on the table with a pistol to his head. And it says "Request for cessation of AVC," which is active military service. And then the title, sent to the chief of the General Staff of the armed forces of the SFRY in person. All this has been written out in his own handwriting, and it says, "In view of the fact that I have over 40 years of service, I hereby request that the AVS --" that is to say the active military service -- "that my active military service cease forthwith." And the next sentence is, "Please forward my request to the PSU" or, rather, the personnel department. The 15th of January, 1991 is the date. Colonel General Tomislav Simovic, followed by his signature. So this completely refutes what you claim, Mrs. Gajic-Glisic, and it is very improbable. This is the first time that I've heard anything like this, that somebody placed a pistol to --
JUDGE MAY: Now, we've -- we've heard enough now. You're supposed to be asking a question. I've allowed you to read the letter. 27951 But you must now show it to the witness and allow her to comment on it. Mr. NICE: It's tab 10 of the exhibits.
THE WITNESS: [Interpretation] This seems to me to be General Simovic's handwriting. This is General Simovic's signature. General Simovic could not have had 40 years of service at that point in time. As far as I recall, General Simovic was born in 1933, and we're talking about 1991 here. So it says here that this document was registered on the 15th of January. I'm talking about the 14th of January. According to my notes, it was the 14th of January. I have nothing to say in this regard, pursuant to this document. I stand by what I said previously and what I wrote previously, that that was how it was and that the general told me that story on that day. And General Simovic, under different pressure, would very often change his statements. I should just like to ask you to take a look at page -- a page in my book. It is page 293, where it -- "We're all posthumous." And even when he authorised my manuscript in its first version prevented me and prohibited me from having it printed. And then he changed his mind and authorised the portion he had banned, banned being printed, and allowed me to publish it.
JUDGE MAY: Just one matter that I want clarified. The year was given as 19 -- January 1991. Is that the right year?
THE WITNESS: [Interpretation] The month of January, 1992.
JUDGE MAY: Yes. That's how it is. Yes, thank you.
THE ACCUSED: [Interpretation] It says that on the document, Mr. May. 27952
JUDGE MAY: Yes. But it was translated or came out as 1991. That is why I was questioning it.
Yes. Do you want this exhibited?
THE ACCUSED: [Interpretation] Of course, Mr. May. This is a notorious fact.
JUDGE MAY: Very well. Hand it -- hand it in, and we'll give it the next number.
THE REGISTRAR: Defence Exhibit 206, Your Honour.
JUDGE MAY: Yes.
THE ACCUSED: [Interpretation] I understood it, Mr. May, that yesterday Mr. Nice had said that General Simovic would be testifying. He mentioned that.
Mr. NICE: I --
THE ACCUSED: [Interpretation] So -- Mr. NICE: I said no such thing at any stage.
And while I'm on my feet, by the way, just to correct something else. The references to "secret" were both made by the witness in answer to neutral questions by me, the one about a level of publicity and the other to like effect.
JUDGE MAY: Yes.
THE ACCUSED: [Interpretation] I've just been given a copy of Dragutin Zelenovic's resignation. I don't want to read it out again, because I'm quite sure that the witness read it out very correctly. I simply wish to draw your attention to the fact that this resignation was addressed, as it says, "Comrade President." That is not me. I don't want 27953 that to be misunderstood, because you have different expressions for that. But this resignation was addressed to the person it was intended to, the President of the National Assembly of the Republic of Serbia, because the National Assembly nominates the government, appoints the government. And that's what it says in this translation here. So I just wanted to draw your attention to that. And he did this pursuant to the rules and regulations for this kind of thing. The president of the republic proposes the mandate. The National Assembly appoints the government pursuant to proposals of the mandate. And it is only the Assembly that can dismiss or appoint anybody. And the oath is taken before the Assembly.
I don't know. But I understood it that an announcement was made yesterday to the effect that General Simovic would come in to testify. But if I have understood incorrectly, then I'm sorry. Mr. MILOSEVIC: [Interpretation]
Q. Do you remember anybody mentioning that?
A. No, I didn't understand it that way.
Q. Very well.
A. Well, Comrade President, perhaps --
JUDGE MAY: Let's make it plain. There was no such announcement yesterday by the Prosecution.
JUDGE KWON: I just note that Mr. Nice said yesterday while he mentioned about the book, "We are -- we will be hearing in due course Mr. Simovic." Yes. It's on page 27793, line 20.
Mr. NICE: That simply must be a transcript error. I have never 27954 had that in any mind and I certainly have no recollection of saying that. I'll look it up and see what it must be a mistranslation or a misrecording of.
JUDGE KWON: No. I remember I heard that.
JUDGE MAY: Yes.
THE ACCUSED: [Interpretation] I also remember that well, having heard something to that effect. That's why I brought it up. And I wouldn't have any reason for bringing it up except for having heard it with my own ears. And as you can see, His Honour heard that too.
JUDGE MAY: Very well.
THE ACCUSED: [Interpretation] Otherwise, the transcript as we know --
JUDGE MAY: Let us -- let us have the matter clarified. But the answer is no.
Now, let's move on. Mr. MILOSEVIC: [Interpretation]
Q. Mrs. Gajic-Glisic, is it contested or not that you in your statement in many places, or to be more specific -- well, yes, in many places don't only write about things you heard directly and saw directly but you're talking about things you heard from others as well and also the conclusions you made about what you heard and which was grounds for the observations you make?
A. I used my diaries, my own notebook, my book, my knowledge in order to write out my statement in detail.
Q. Yes, I understand that. But without a doubt, in many places you 27955 write about what you had heard from others, mostly from General Simovic; isn't that right?
A. Yes.
Q. All right. Are you sure that it was from your observations and from the things you heard that the right conclusions always emerged, that you made the right conclusions about what you say and specifically, in concrete terms, the matters I asked you about?
A. Had I not been sure, I would not have put them there.
Q. Very well. Tell me this now, please: I noticed -- Mr. NICE: Your Honour, while that's being dealt with -- I'm so sorry. Forgive my interrupting.
JUDGE MAY: Yes. Mr. NICE: Ms. Dicklich has found the passage that His Honour Judge Kwon has referred to, and I can pretty well recollect what was said and -- certainly what I intended to say and indeed what I think I did say. I think you'll find this is an early passage of the examination-in-chief, and I was putting a question of one of those passages which didn't require evidence in full from the witness. And I was saying that this was checked for the content of its accuracy by a man called Simovic, of whom we will be hearing in due course. Certainly what was intended to be said -- because at that stage you -- well, you may have known, but from the evidence we got to that far, you wouldn't have known exactly who we were talking about. That's all.
JUDGE KWON: That's quite right.
THE ACCUSED: [Interpretation] Very well. 27956 Mr. MILOSEVIC: [Interpretation]
Q. Now, you in your CV mention many things that do not have a direct bearing on your testimony or the time during which I performed some political function. But could you please clear this point up. You say that upon return from America, you wrote a report, 360 pages, but that work of yours was banned. Is that right?
A. Yes.
Q. As far as I can see, that was in 1983. Is that right?
A. Yes.
Q. How do you mean banned, when it wasn't published in the first place?
A. Well, this manuscript of mine was taken away from me by the state security.
Q. In 1983?
A. Yes. Because the manuscript -- as the manuscript probably is still in existence in the archives of the state security somewhere, and since I believe that you might dig it up, and so that I should prevent you from saying that I was telling lies or not telling the truth, in agreement with the OTP I put that sentence in, to the effect that all of us in our lives have some things that happened to us and which should be mentioned for me to be completely pure and clean here. Of course, that has nothing to do with you. I didn't know that you existed at all at that time. But of course, some information and knowledge that I got there, heard about, wrote down. I was young. I didn't believe in some of those things. I was told that I wasn't to speak about those things or write about them, 27957 nor could I publish them anywhere.
Q. All right. Regardless of the fact that this was all happening in 1983 - and I really don't know anyway, nor can I have any idea about it all and what you say - but what was the name of the member of the state security who advised you not to publish that work of yours? What was it that you wrote in that work that was so dramatic?
A. Well, quite obviously you know about it very well.
Q. I don't know whether that is obvious or not. I know nothing about it.
A. I can see that on your face clearly, and quite obviously you know all about it.
Q. Well, regardless of what you assume, can you tell us what it was that you wrote at the time?
A. At the time, I listened -- and this seemed to me to be a joke by Kundara [phoen] or Orwell's 1984 to the effect that communism would topple in the whole Eastern Bloc according to the domino system. It would fall down like dominos and that the Soviet Union would disintegrate and that the Serbs would be disbursed and resettled and up rooted from its territories. And that in Yugoslavia there would be blood up to the knees and that Kosovo would be joined up with Albania, part of Macedonia, and Greece and that a greater Albania would be formed, and so the siptars could breed over there and that part of Macedonia would be attached and conjoined to Bulgaria and that part of Vojvodina would be joined to Hungary, that there would be great divisions in Europe generally, and that that was a long-term plan that was being prepared. 27958 Now, at that time, my country was the greatest and most beautiful country in the world, and I found this all to be a science fiction, highly improbable. And I wrote all this down from one day to the next, and I wrote a diary, in manuscript form, 360 pages long, and I thought I'd publish it and that this would then be a big book. However, when I handed it over to the director of the Obecija Novina [phoen] publishing house, they called me to come to their premises. They introduced me to a man whose name was Liki --
Q. Let's not go further into all this. All I wanted to hear from you was what you wrote. And that what you wrote seems to be coming true, what you heard over there when you were in America.
A. Unfortunately, Comrade President, I told all this to General Simovic in our first conversation and I told him that all this was -- had been realised, right according to the domino system and in the periods of time that they told me about over there then.
Q. Who told you that there? Who told you about this plan? Who put it forward to you?
A. I was very young then. I was a correspondent for the paper Komunist. I was a journalist but also an engineer in the Sloboda [phoen] company and dealt with innovatory work there. I was an enthusiast, very enthusiastic about the work I was doing, and I published my first book "Mother, Give Birth to me Again." It was published by the Obecija Novina publishing house in Gornji Milanovac. A businessman turned up from America and he spoke Serbian very well.
Q. I apologise for interrupting but my time is very short. I just 27959 wanted to hear about this all. I'm sure the history of it all is very interesting, but we don't have time. But who did you learn about these facts from, that is to say, how the Serbs would be disbursed and how Yugoslavia would be destroyed and how a Greater Albania was to be created and all the other things that you've just mentioned?
A. From people very close to the then-President Reagan. Unfortunately --
Q. That was in 1983, was it?
A. Yes. And in my country, they ordered me not to speak about that to anybody. They forbid me to speak about it to anybody, to publish a single word of that, that I had to keep quiet about it and that it was something that wasn't to be spoken about.
Q. Well, I really don't want to enter into all that, because to the present day I couldn't understand the reasons for which you were not allowed to write all that down or, rather, to publish it, because everything else about Yugoslavia was published. I don't remember that there were any bans of any kind. But -- so this is -- these are things you learnt from people close to the American President, President Reagan, in 1983; is that right?
A. Yes.
Q. The Pope, in 1982, when --
JUDGE MAY: I think we are now getting a long way from the subject. You've asked the witness about something which you've been allowed to do. It may have affected or not the credibility. But it sounds as though we're getting a long way from the topic. 27960 Anyway, it's time to adjourn. Twenty minutes, please.
--- Recess taken at 12.16 p.m.
--- On resuming at 12.41 p.m.
JUDGE MAY: Yes, Mr. Milosevic.
THE ACCUSED: [Interpretation] Mr. May, I only ask you to tell me how much time I have left, as I have many questions to put to the witness.
JUDGE MAY: You've got 22 minutes -- 25 minutes.
THE ACCUSED: [Interpretation] You see, Mr. May, the statement of Mrs. Gajic-Glisic has 307 paragraphs, 307. And there's the book, plus the binder. If I were looking only at the paragraphs, it would mean 100 paragraphs an hour. That would add up to three hours. So I have to ask for more time. I cannot go through everything, but at least allow me to go through part of this statement.
JUDGE MAY: Mr. Tapuskovic, how long do you think you might be? Mr. TAPUSKOVIC: [Interpretation] Your Honours, I always took account of the time and try to make the best use of it. I think that 15 or 20 minutes would be sufficient for me.
JUDGE MAY: [Microphone not activated]
THE INTERPRETER: Microphone, please.
JUDGE MAY: You can have additional time to allow Mr. Tapuskovic 15 minutes.
Five minutes for re-examination? Mr. NICE: [Microphone not activated] There are eight questions at the moment.
THE ACCUSED: [Interpretation] Very well. I will continue and you 27961 will tell me when my time has run out. I assume you will use the usual procedure.
Mr. MILOSEVIC: [Interpretation]
Q. Mrs. Gajic-Glisic, in paragraphs 19 and 20 of your statement, you say that in 1986 national tensions started in the JNA. And you're mentioning the famous Keljmendi case.
A. Yes.
Q. What did that Keljmendi do? Do you remember?
A. He killed JNA soldiers while they were asleep.
Q. You also say that this is when the first tensions began between the republican Territorial Defences and the JNA, as well as the republican police forces and the JNA. Is this correct?
A. Yes. At that time, I was head of the reconnaissance and notification service of Cacak municipality, and information was available to me that was not available to the public.
Q. And as you say, it then became clear that the Territorial Defences are becoming separate armies.
A. Yes. General Simovic told me this in his interview in 1984, and he said quite correctly, "If war breaks out one day, it will not be because Yugoslavia has been attacked by a foreign aggressor. It will be an ethnic and religious war between the Territorial Defence and the JNA." Unfortunately, that interview was also banned.
Q. I won't go into who banned that interview. Do you consider that these tensions had at their root the nationalism and separatism of certain political structures at the time? 27962
A. Yes. Should I explain?
Q. We don't have time for that. So such activities were an introduction into what was to take place later on the territory of the former Yugoslavia.
A. Yes.
Q. And to a large extent, this was in accordance with what you wrote in your book which was never published.
A. You mean the interview?
Q. No. I mean that big work of yours where you wrote about Yugoslavia disintegrating, Greater Albania, the expulsions of Serbs, and so on.
A. Yes.
Q. When you received this information, as you say, from people close to the then-American President Reagan, that in 1992, in a meeting between Reagan and the Pope, there was talk of Yugoslavia being broken up --
JUDGE MAY: We're now -- we're now moving a long way from the witness's evidence, between any meetings of the Pope and President Reagan.
THE ACCUSED: [Interpretation] Very well, Mr. May. Mr. MILOSEVIC: [Interpretation]
Q. But in fact, the formal excuse for your dismissal from the ministry was that you had connections with the foreign intelligence service.
A. General Marko Negovanovic told me this, but they also told me that you defended me vehemently and that you pensioned off 40 generals for my sake because you wanted them to prove what they were saying and they 27963 didn't have a single piece of evidence to put before you. And now it's up to you to say whether that's how it happened.
Q. I was unable to dismiss generals, but whenever somebody put claims before me without evidence to support them, of course it was logical for me to ask for evidence to support certain arguments.
A. Well, this is an occasion for me to say thank you for being on my side at the time.
Q. In paragraph 40, you say that I asked Simovic whether he wanted the post of minister of defence and whether he wanted to work on the reorganisation of the JNA, and so on and so forth. Was it Simovic who told you this?
A. Yes, Simovic told me this in one of our conversations.
Q. Then I won't into this, because we would simply be putting one claim against another. I don't think he could have told you this, but that's up to him.
Very well, Mrs. Gajic-Glisic, as you say here that I told him that he was to work on the project of a Serbian army and so on, that for 11 years continuously I was the president, first of all of Serbia and then of Yugoslavia. Is this correct? And during those 11 years, did I establish a Serbian army?
A. There were a number of reorganisations of the JNA, as far as I was able to follow this, because after that I was concerned mainly with preserving my own life and not what you were doing. I interrupted my work on the 1st of June, 1992, when I lost my job definitely and instituted legal proceedings, which are still going on, which are still pending to 27964 this day, and it was never established whether I was to blame for anything or whether I should get my job back. After that, I was never able to get a job in any government organ or to get a job anywhere else.
Q. I won't go into this, because I really don't know anything about this. But in your statement, in paragraph 41, it says -- or rather, you mention some sort of a viso orders. You say that I was issuing orders of this kind. I have to tell you that this is the first time I've heard of such orders, and you say that a person under certain conditions who refused to carry out such an order could be eliminated. Did you write this, or was this a mistake?
A. This is not a mistake. A viso orders are ordinarily used in government organs when certain measures of readiness are in place or when there is an imminent threat of war or during war, and these orders are issued tete-a-tete, and issuing such an order meant it had to be carried out.
Q. This is the first time I'm hearing this from your statement. Tell me, do you have any experience, any personal experience, of me giving such an a viso order?
A. I never received one from you personally, but others said that when they came to see you and when you told them something, they were not allowed to respond with a single word. They simply had to carry out the order. When I asked General Simovic, "How can you mobilise someone when you don't have legal authority to mobilise anyone?" he said, "He's my president, and I cannot say I won't do it or I can't do it."
Q. Does this mean that I ordered Simovic to mobilise someone? 27965
A. According to what he dictated to me, he said that a certain number of volunteers were to be mobilised in one day, to bring up to manpower level Territorial Defence units.
Q. What you have just said is contradictory, because to mobilise excludes any kind of volunteering. Volunteers and mobilised soldiers are two quite different things.
A. Yes. But you know that's not how things were. People are often mobilised and then in their military booklets it was recorded that they had volunteered. There were many such examples. And I came across these. Many came to complain about this at the ministry.
Q. You mean if someone complained that they had been registered in error as a volunteer, did you then relieve them?
A. What do you mean "relieve them"?
Q. Did you then have to send them to the organs mobilising soldiers? You couldn't tolerate forged books or false books.
A. You know the case of the taxi drivers.
Q. What taxi drivers? I don't know anything about this incident.
A. When the army was mobilising their conscripts and sending them off to the war-affected areas, people got scared. They left behind their equipment, trucks, everything they had taken with them, they left it in the war-affected areas and fled, and this equipment and these APCs had to be brought back to Belgrade, so we recruited taxi drivers to organise themselves as volunteers and bring back this equipment, these vehicles. Later on, it transpired that nobody wanted to receive these taxi drivers, that nobody wanted to inscribe into their military booklets that they had 27966 been at the war front, that they had been mobilised. We even asked you to intervene. And then -- and then in the end --
Q. So they went and brought back this equipment?
A. Yes, they did. But they didn't get anything for it. It wasn't even put into their military booklets that they had done this. Mr. Uskokovic did this, the president of the taxi drivers' association.
Q. I don't know who Mr. Uskokovic is.
A. And do you know what happened later? Colonel Velimirov, who was in charge of all this, ascribed to himself, or somebody gave him, the rank of general as a reward because the soldiers had heroically carried out their obligation.
Q. I don't know anything about this. I won't ask you about this. I'm really not interested.
Look at paragraph 48 of your statement. You say, as far as I can understand, that on the 20th of September, 1991 you were, as you say, angry - and I assume you were also sincere - and you said the following to Simovic. I'm quoting you: "General, Yugoslavia no longer exists. This nation expects you to save their soldiers, their children, to create a Serbian army, to be their commander." Were these your words?
A. Yes. Yes. I argued with him then. I argued a lot. Because I had been brought back, through the court, to my post of chief of the reconnaissance and notification service, and they wouldn't give me the documents I had created, they wouldn't let me work, nobody wanted to protect me, and I said to General Simovic that I would sue him because he wasn't intervening in my case. Nobody proved -- 27967
Q. I'm not talking about your case. But you said, "The people expect you to save their children, to be the war commander, to command the soldiers."
A. When I say "children," I mean --
Q. The point is here to create a Serbian army. That's what you said.
A. Before that, we had talked about a Serbian army, when I was in the cabinet with him.
Q. Was this your idea that he should create a Serbian army?
A. I wasn't my idea. But before that, in the days preceding this - and it's in the paragraphs that you skipped over - it says that he talked to you about setting -- about creating a draft bill on the armed forces of Serbia.
Q. Well, drafting a bill is one thing and forming a Serbian army is quite another. A Serbian army was never established.
A. At the time, it was said that the volunteers were the backbone of the future Serbian army, which would be above party interests and would defend the interests of Serbia.
Q. There were a number of volunteer detachments which had nothing to do with either the state or any kind of conception. In paragraph 50, you say that Simovic spoke before the Serbian parliament when he took his oath as minister.
A. Yes.
Q. And you say that this speech was a page and a half long and that it fascinated all of Serbia. 27968
A. Yes.
Q. That's what you say. Do you have a copy of this speech?
A. No. I had a cassette, but the OTP would not accept it and we sent it back to Belgrade.
Q. That means that he read a speech that you wrote for him. I didn't suggest it to him.
A. I apologise. We wrote the speech together. I wrote it; he added things, corrected things. And then he brought the speech to you, and you agreed that he could read that speech out before the parliament. That's what he told me.
Q. That's what he told you. And you wrote the speech.
A. We wrote it together. I was typing it and drafting it, and he was adding parts of sentences.
Q. Very well. I won't burden you with this any longer. But judging by everything, even by your statement, the setting up of a Serbian army, which is both implicitly and explicitly ascribed to me, does not hold water.
In paragraph 68, you say that a meeting was held between me and Simovic. And you say that I then told Simovic to prepare lists of JNA generals to be pensioned off. Is that what you're saying?
A. General Simovic dictated this to me after coming back from your office. That's what he told me, that he'd come back from seeing you.
Q. From what we concluded together here, during this examination, is it clear or should it be clear that neither I, as president of Serbia, nor Simovic, as the minister of defence of Serbia, were able to dismiss or 27969 replace or pension off JNA officers?
A. Well, that's what I said to General Simovic, "What did you say to President Milosevic about this?" And he said, "I said I understand." I said, "How could you say that when you're not competent to do this?" And he replied, "But he's my president."
Q. Very well. How could Simovic have pensioned off any JNA general? How could anyone give someone a task for which he is not competent?
A. He wasn't competent and he didn't pension anyone off.
Q. Very well. Isn't there a clear criterion for people to be pensioned off; their age, their years of service, their rank?
A. I know this, Comrade President, but he kept telling me that you were asking him to pension off the incompetent generals.
Q. Mrs. Gajic-Glisic, I really cannot go into what somebody told you, but do you have any knowledge of the fact that the vast majority of generals or colonels or captains or whatever rank were pensioned off, that they were pensioned off exclusively according to the criteria for retirement, which has to do with years of service and their age and also their rank? The higher the rank, the higher the age. But this is all within a range of a few years, not more. And that this is how they retired.
A. Comrade President, I'm not saying that this is not correct, but I still abide by the statement --
Q. Very well. Let's proceed. Let's move on. Then you go on to say that I told Simovic to form lists of volunteers and to establish a battalion of volunteers. That was what you say. 27970
A. That's what he told me.
Q. He told you that?
A. Yes. And I have a notebook in which I wrote this down with the date.
Q. All right. But don't you know that the volunteers came under the competence of either the JNA or the Territorial Defence?
A. And Comrade President, you must know that those volunteers went to report to the centre for reconnaissance and notification.
Q. Yes. That was according to the decrees that we looked through. We can't go back to that. Everybody reports to the territorial body that then registers them, has them written down in their lists, and then it is the commanders of the military units of the ranks of brigade and higher ones to okay this. That's what it says in the rules.
A. Yes. This is what it looked like. They would report to the notification centres, and they would give their particulars. Then through the notification centres all the data and information would go to the republican centre for notification, and then the republican centre for notification would go down the horizontal chain and vertical chain and inform others. And the centre for notification would every day receive reports from the notification centres as to how many volunteers had signed up in which place, in which locality. Then those volunteers were further sent on to the training centres, which came under the authority of the Territorial Defence.
Q. Well, everything that you say is what is contained in the instructions and provisions that we looked through a moment ago. 27971
A. Yes.
Q. So this was all done -- this procedure was all in conformity with those provisions. Is that right?
A. Yes.
Q. In paragraph 69, you go on to talk about the owner of Jugoskandik, who came to the ministry and said that he would help. Who sent him in the first place?
A. I invited him to come.
Q. I see, you invited him to come. Now, as far as I understood it, I asked you who that man was?
A. That was later, when he wanted to have a meeting with you. You said, "Who is the man?"
Q. So he asked for something through you. He asked me to receive him through you, and I asked who the man was.
A. Through General Simovic. You asked General Simovic who the man was.
Q. Very well. Then you go on to say that in October I told Simovic to ask Babic - and Babic, I assume, was the commander of the Territorial Defence in Montenegro or what? What is he, defence minister?
A. Defence minister in Montenegro.
Q. Right. So he asked his colleague why Dubrovnik was under siege?
A. That's what General Simovic asked Babic, yes. Our President Milosevic would like to know why they are moving towards a siege of Dubrovnik, for God's sake.
Q. And what did Babic answer? I wasn't able to establish that. 27972
A. Because the Montenegrins didn't want to go to other battlefronts and there were a lot of soldiers who were shut up in the barracks in Croatia. And the Croats did not want to release those young soldiers who were being captured there and held in the prisons, and that Prevlaka was the problem and that Montenegro had a large number of volunteers and that they had started out in the direction of Dubrovnik to instil fear in Croatia, to prevail upon them to free those soldiers.
Q. You mean Babic gave the explanation that pressure was being brought to bear on Croatia, to release the soldiers; is that right?
A. Yes. That's what I heard. That's what I noted down on that occasion.
Q. Yes, I understand. I just want to hear your explanation. That's what I wanted to hear, and thank you for giving it. Now, in paragraph 97, you say that Simovic on the occasion told Babic that the JNA in 1991, in addition to its proper relationship, even when it was proclaimed an occupation army in Croatia, that it was doing everything to prevent internationality conflict. Is that right?
A. Yes.
Q. And was that indeed the endeavours made by the JNA and was that General Simovic's conviction based on everything he knew, although he wasn't in the JNA structure any more but was the defence minister of Serbia?
A. Yes.
Q. And is that what he told Babic?
A. Yes. 27973
Q. Very well. Was there a joint meeting of any kind between them and that the general assessment was made that a further transformation of the JNA could not be done without the political agreement of all the republics who wished to remain within the composition of Yugoslavia, to remain within Yugoslavia?
A. Yes, that's what they discussed, and they also discussed how they could negotiate with Bosnia-Herzegovina, to have Bosnia-Herzegovina remain within Yugoslavia too. And then Colonel Kovacevic, I think he was, said, "Well, the defence minister in Bosnia-Herzegovina was a Croat. How are we going to negotiate with them?" And then Babic said, "But Montenegro quite certainly is going to remain with Serbia."
Q. Yes. And that's what happened; Serbia and Montenegro formed the Federal Republic of Yugoslavia in April 1992.
A. As far as I recall, Macedonia was to be a part of that. And as far as I recall, you went to negotiations there to see the possibility of Macedonia remaining within that entity.
Q. Yes. There was a meeting of all the presidents of the republics, and I did advocate the preservation of Yugoslavia. There's no doubt there.
Now, in your article published in Nin magazine, you say in paragraph 115 that "Milosevic didn't place the veto on the first article that appeared in Nin or any other articles in the series." Now, I'm asking you why would I place my veto on those articles?
A. Well, if the articles happened to be contrary to Serbia's policies and the policy you pursued. You had the right -- you had the 27974 discretionary right to use your power of veto to stop the article being published. You did not do that, and once again I would like to say thank you to you for that.
Q. Do you have any example where I banned any articles that were supposed to appear in any newspapers?
A. I didn't deal with that at all. I don't know.
Q. Now, I'd like to tie this up to what we started off with, because we made a clear delineation and distinction, and I think we can say black and white, we put it in black-and-white terms, and distinguished between the paramilitaries and the volunteers. You spoke about that yesterday and we cleared up that issue today. So you devote a significant portion of your statement to volunteers. And in paragraph 146, you state -- yes, paragraph 146, you state that, "All the chaos at the battlefield was caused by armed groups which were under the control of the parties." Is that right?
A. Yes, based on my knowledge.
Q. All right. And let me just check paragraph 146. I have the sentence here, the one I quoted. "I know that Vuk Draskovic set up the Serb guards. Seselj organised his Chetniks, and those paramilitaries were located in the territory of Croatia populated by a Serb majority. And these volunteers --" I apologise to the interpreters for going so fast. "Those volunteers, at the outset, were outside the command of the JNA. Later on I heard that the volunteers had seized vehicles, money, and property, houses from the Croats." And then we come to this critical sentence, which I would like to emphasise: "All this chaos was created by 27975 the armed groups, which were under the control of the parties. That is my personal opinion and what I know." Is that right?
A. Yes. And if you want me to -- Mr. NICE: For context, the next sentence ought to be read as well.
JUDGE MAY: Perhaps you would read it. Just a moment, let him finish.
MR. NICE: The next sentence reads: "It was obvious that it was not possible to set up armed units in a Communist or a post-Communist country with a strong army without the prior approval of the competent authority organs."
JUDGE MAY: Yes. Mr. Milosevic, you now have -- just a moment. You have ten minutes more, so that you know that. That will give Mr. Tapuskovic 15 minutes, the Prosecution 10 minutes. Now, we'll go back to the statement. Yes, the witness was going to say something.
THE WITNESS: [Interpretation] Yes. I learnt about all these things, not only while I was the chef de cabinet but also while I was a journalist, when I had no fixed job, before I became the chef de cabinet, about the party armies that went to the territories in order to protect the Serb population there. I also learnt about this and I describe that in detail in my book. According to what Milan Paroski told us, he said that he was taking his army to those areas, regions. And I also learnt from Pejicic, who was in our cabinet - and this is again described in my book - that they, too, transported some of their army outside the system. 27976 Mr. MILOSEVIC: [Interpretation]
Q. Do you mean the SPO, the Vuk Draskovic resistance movement?
A. Yes.
Q. Now, this intervention of Mr. Nice was a very good idea to have this read in context because it shows that armed units could not have been formed without the acquiescence and approval from the organs of authority, the ones that created this chaos in the first place. Now, can you explain to those who do not find this quite clear that, as far as I'm concerned at least, and the authorities that I would wield influence on, that is, the Serbian government and its organs, the organs of that institution, the organs of that government, armies of that kind could not gain support, Vuk Draskovic's army or Jovic's army or any of the others. And we have already noted that these armies were outside the system, that they were party armies, and that they were armies of oppositional political parties.
A. Well, Giska, Beli, Lainovic, all these were said to be members of the state security. That's what they said in my cabinet. Now, I haven't proof and evidence of that, but that is what I heard in the cabinet.
Q. That is quite unbelievable that the state security here, which as a whole, everything it does is being ascribed to me, that it should suddenly help armies that were working to overthrow me.
A. They assisted the protection of the Serb populace in the areas in which they were under threat.
Q. In paragraph 147, you mentioned Jovic's volunteers, the White Eagles, and also you say that the government opened up training centres to place the volunteers under their control or, rather, to make this kind of 27977 organisation of volunteers impossible.
A. Yes.
Q. Therefore, the government measures were to make these political party armies impossible and to prevent this kind of chaos. And I quote you when you said that all this chaos was created by the armed groups who were -- which were under party control. So the Serb government took measures to eliminate groups of this kind, and the volunteers who wished to defend their people, the people and the state, had to join up pursuant to the laws and regulations and come under the organisation of either the JNA or the Territorial Defence. That was the purpose of this Serbian government measure.
A. We're talking about the time up to this provision and after the provision. Up to the provision, the government and you were in favour of legalising all the volunteers, of having them registered, and having their status being made equal to the reservists of the Yugoslav People's Army.
Q. Yes, that's what it says.
A. But before the provision, there were party armies which went to the war-threatened territories without any consultations or any knowledge on the part of the competent authorities.
Q. All right. So that's quite clear. Without any consultations or knowledge of the competent authorities.
A. Yes. That's what I learnt there.
Q. Very well. Fine. Now, is it clear that the government of Serbia - and we have seen the provisions and decrees and all the endeavours made - that they did all this, in fact, in order to prevent these party armies 27978 from running wild, running amok in the regions engulfed by war?
A. Yes. And my first agreement with the Prosecution was, yes, I worked on the basis of legal provisions and regulations which I was acquainted with as soon as I arrived at the ministry.
Q. Tell me now, please, you devote 14 paragraphs of your statement, from 155 to 169 - and as you've just heard, I don't have the time to go through all this - but you devote those paragraphs to Vuk Draskovic's Serbian Guards, that is to say, the main oppositional party. And you say that he was responsible for disseminating, looting, hatred, and the looting and the victims of war in Croatia, the casualties of that war.
A. That's what was talked about in the ministry while I was there.
Q. You also claim that he called up the JNA reservists not to respond to the mobilisation call and to use their weapons and equipment and move -- and to join up with the Serb Guards.
A. Yes, that's true. And I publish all my letters and correspondence with Vuk Draskovic, my conversation with Pejicic, and on the basis of everything it says in the book you can learn a lot, a lot more than I am able to present before this court of law. I maintain that what is in the book is meritorious and, therefore, an answer to your question.
Q. You were asked by Mr. Nice, as you say you learnt about the volunteers from the different irregulars -- you've learnt about the irregularities, the looting, the crimes that were being committed, and whether he informed me of that, and your answer was - and I jotted it down - you hope that Simovic conveyed that information to me. That was your 27979 answer. But you don't know whether he actually did so, whether he informed me of everything he heard from the volunteers. You said you hoped he conveyed it to me.
A. Well, I couldn't hear what you were talking about tete-a-tete, so I couldn't say that I heard him tell you that. I said I hoped that he conveyed it all to you.
Q. Very well. Thank you. Now, as my time is almost up, is it true and correct that in the armed forces of Yugoslavia, that means -- this refers to the JNA, the Yugoslav People's Army, and the Territorial Defence, that there were strict rules and regulations with respect to the application of international war law in our -- with respect to the armed forces of the SFRY and that they also related to the Yugoslav People's Army and the Territorial Defence and that they insisted upon that; that is to say, that all higher military instances in Yugoslavia insisted upon having that prevail?
A. You expect me to say yes, but you know very well that this was not within my competence.
Q. It doesn't matter what I expect. I am simply putting questions, and you can respond according to your conscience.
A. According to my conscience, Colonel Djokovic would say that when the reservists went to the battlefield, even the most respectable of them came back with a car full of goods, even the most honest of them did that. He would wait for them with his unit to stop them and to take records of all this, but they would fire shots from their cars, so he couldn't do that. 27980
Q. Well, precisely this was part of the chaos that the leadership of Serbia was trying to prevent with these measures of discipline and with these attempts to introduce order into the situation with these units. Is that correct?
A. I hope so. Did they say anything to the contrary?
Q. No, you didn't.
JUDGE MAY: This must be your last question.
THE ACCUSED: [Interpretation] Very well. If it's the last question, I have one more question.
Mr. MILOSEVIC: [Interpretation]
Q. Yesterday you said Simovic, how long was he minister of defence, how many months?
A. Officially two and a half. Unofficially, three months.
Q. Very well. You say that during that time he published 200 interviews given to local journalists and about 100 more given to foreign journalists, 170.
A. Yes.
Q. So this is three interviews a day during his term of office.
A. Yes.
Q. Thank you, Mrs. Gajic.
A. I have these interviews. I can give them to you if you want.
Q. Well, how could he do anything else if he spent all his time giving interviews?
A. I was very expeditious there. Mr. TAPUSKOVIC: [Interpretation] Thank you, Your Honours. 27981 Questioned by Mr. Tapuskovic:
Q. [Interpretation] Mrs. Glisic, there are many topics that you deal with in your book, but there is only one thing I would like you to confirm or not confirm, as the case may be, and that is in the chapter entitled "Arkan's Sniper." In English, it's page 39. And in that passage, it's the paragraph before the last, "Shooting a rabbit with Arkan's sniper." There was a TV event broadcast via Studio B. And you said that Arkan, when asked, said, "We do not recognise anyone. We do everything on our own."
A. Yes.
Q. Thank you. There is another topic I would like to go into before this Bench, and it concerns primarily the functioning of the Territorial Defence during decades, starting from 1984, and of course the establishment of armies after 1990. Please look at paragraph 129 of your statement. I have to read it to avoid misunderstanding. It isn't long. "The TO units did not leave their territory. They carried out their wartime assignments only on the territory of their village, town, municipality, or republic, while the JNA units were mobile all over the territory of the SFRY and their purpose was to protect the country from foreign aggressors. During times of peace, plans were drawn up relating to the movements of the reservists of the JNA."
My question is as follows: Does this mean that the Territorial Defence was envisaged as a defence system in case the borders were attacked or, rather, if there was an attack, the borders would be protected by the army and the people would defend the entire territory? 27982
A. Yes, the Territorial Defence was to protect the territory on which they were based.
Q. From a foreign aggressor?
A. Yes, from a foreign aggressor.
Q. Would you now look at paragraph 137 of your statement. "Should the country be attacked from outside, members of the TO units had their uniforms at home," and this was the same all over the territory of Yugoslavia; is this correct?
A. Yes, as far as I know. But that's how things were in Cacak where I saw this; I knew about it.
Q. But you know that that's what the law prescribed.
A. Yes.
Q. The weapons were stored in TO depots at the municipal level.
A. Correct.
Q. Now, look at paragraph 38. I have to draw your attention to these paragraphs because I would like to put this in a certain order for the Court to understand better. I'm not trying to confuse you. In paragraph 38, you say that you met General Simovic for the first time in 1984, when he was the commander of the Territorial Defence of Serbia, and that he then told you that if there was a war, this would be a war between the JNA and the TO, which was being established along ethnic lines. Is this correct?
A. Yes.
Q. Did he then explain something to you about the reorganisation of the JNA and the TO when the constitution was enacted and that this was 27983 based on the regulations of 1974, when the constitution was promulgated?
A. Yes. Do you want me to explain this to you in a broader context?
Q. No. Sorry, there's no time. But is this based on the constitution of 1974?
A. Yes. But let me explain to you who were the members of the TO and who were the members of the reserve forces of the JNA.
Q. No, no, believe me, there's no time. Let me move on, Witness.
A. Would the Judge give us time?
Q. Well, if His Honour will allow, I do not object.
MR. TAPUSKOVIC: [Interpretation] Your Honour, the witness is asking for time to explain this.
JUDGE MAY: We are very short, I'm afraid, because we've got to leave this courtroom to allow another case to come in. So I think if we'd keep it short, please.
Yes, Mr. Tapuskovic, please. Mr. TAPUSKOVIC: [Interpretation]
Q. Now, look at paragraph 20. Have you found it?
A. Yes.
Q. Here you say that as early as 1986 -- you say Simovic in 1984 and already in 1986 you're say that the territorial defences of the republics were growing stronger and becoming separate and independent armies more and more. Is this correct?
A. Yes.
Q. Now, look at paragraph 189. Mr. NICE: Your Honour, we haven't burdened you with this 27984 statement, of course. It's a very long statement and 50-odd pages would be available should you want it.
JUDGE MAY: Yes. Yes, Mr. Tapuskovic. We can follow.
Mr. TAPUSKOVIC: [Interpretation]
Q. Look -- now, what did I say? What paragraph? Sorry. 179, where you say that in 1991, when it seemed that conflicts could not be avoided, Slovenia and Croatia created their own republican armies out of the TO. Is this correct?
A. Yes.
Q. I apologise for having to take you back to paragraph 139 now. You say here in your last sentence, "In Croatia in 1991, most of the materiel was confiscated by the Croats and that's why the Serbs in Croatia were left without weapons." Is this correct?
A. Yes.
Q. And finally, paragraph 269: "The Croatian TO became a parallel army, parallel with the JNA. The JNA was soon isolated and its communications were cut off. The Serbian populace could not efficaciously oppose the ZNG." Is this correct?
A. Yes.
Q. And then soldiers were imprisoned in the barracks.
A. Yes.
Q. Did the Territorial Defence of Serbia ever gain the status of an army? Did it at any moment have the status?
A. No, never. 27985
Q. In Bosnia-Herzegovina?
A. It did.
Q. And now paragraph 49, if there's time.
THE INTERPRETER: 40. The interpreter apologises.
MR. TAPUSKOVIC: [Interpretation]
Q. You spoke about the creation of a Serbian army here and in the last sentence. I won't take you back to what you've already said, but in paragraph 121, you said, in the middle here, "This did not succeed because at that time Slobodan Milosevic could not confront the leadership of the JNA directly." Is this in fact what you said in your book, that the minister of defence had no authority over the JNA and also that the president of the republic had no authority over the JNA?
A. Yes. And what mistake did I make here?
Q. No, no, I'm just asking for your response. And to round off this topic, I did have a few other questions, but I've come to the end now. You started working in the Ministry of Defence of Serbia only in October.
A. On the 25th of September, 1991 I received my -- the decision, the official document on the 1st of October. But I was physically present there from the 25th of September, 1991.
Q. And up to then you were in Cacak?
A. I was -- and lived in Cacak up to the 25th of September.
Q. The first refugees that turned up came from Croatia?
A. Much earlier, before I arrived in the ministry.
Q. Yes, I know. I know. But these were the first refugees that 27986 started moving on the territory of the former Yugoslavia?
A. Yes.
Q. And my last question is: Did you ever hear of the existence of any plan, at that time, planning the persecution of anyone? For example, that plans were drawn up in your ministry to persecute non-Serbs?
A. No. On the contrary; I worked in the same office with a Croat in the 13th of May. Not a single Croat was persecuted or dismissed from his job. No one was persecuted. They all kept their jobs, even those who came from the territories of other republics got jobs in Serbia.
Q. Thank you. Thank you very much.
A. Did I contradict myself?
Q. It's up to Their Honours to judge that. Mr. NICE: Your Honours, I've only got one question, I think, on the book. But at some stage the Chamber may want to decide what it should do about the book.
JUDGE MAY: Well, I think we'll probably have to admit it. Mr. NICE: That would be our submission. It's a book as to the accuracy of which the witness has attested and the accused seems to have accepted that it's her accurate recollection, even if he challenges some of her underlying conclusions.
Re-examined by Mr. Nice:
Q. On page 41 in the English - and that will match page 60 in the original - there was a line that the accused put to the witness coming from Arkan saying, "We do not acknowledge any authority. We do everything on our own." And it may be that the Chamber would want to see the context 27987 for that. Because, Ms. Gajic-Glisic, isn't this the case that as your book reveals, Arkan's arrival -- I beg your pardon, "Arkan being spoken to by the moderator --"
THE ACCUSED: [Interpretation] Mr. May.
JUDGE MAY: Just let counsel finish, and then you can object. Yes.
Mr. NICE: "-- asked Arkan in public who was his commander-in-chief." Silence in the office as you were watching the broadcast, expecting him to say Simovic. He said, "Patriarch Pavle." "Everybody laughed. It was not serious. It was just his way." You then go on, then saying: "We do not acknowledge any authority. We do everything on our own." And follow that by saying, "A few days later Kum brought us a videotape shot by Studio B showing the volunteers sending their greetings to General Simovic, proclaiming him to be their commander-in-chief. Some of the officials resented that. Simovic was not one of them."
You told us --
JUDGE MAY: [Microphone not activated] Mr. NICE: Yes, certainly.
JUDGE MAY: Yes, Mr. Milosevic. Yes.
THE ACCUSED: [Interpretation] I just wanted to correct a minor point, his not acknowledging anyone. This was not a question put by me but by Mr. Tapuskovic.
JUDGE MAY: Yes. My recollection is page 41 was put by you, but I may be wrong. 27988 Yes.
Mr. NICE: [Microphone not activated]
THE INTERPRETER: Microphone, please. Mr. NICE: If it was put by Mr. Tapuskovic, I accept that correction.
JUDGE MAY: Very well. Mr. NICE:
Q. Please tell us this, please, Ms. Gajic-Glisic: You gave an account of who Arkan answered to right at the beginning. Namely, to who?
A. To whom Arkan answered at the beginning? Is that your question?
Q. You told us at the beginning of your evidence who he answered to, which body he answered to.
A. As Comrade Zoran Sokolovic told us, they answered to the SUP of Serbia.
Q. In that broadcast, given that he had his funny ways, was there anything to throw doubt on your understanding?
A. Well, we expected him to say, "Our commander-in-chief is General Simovic," because General Simovic had declared that the volunteers were the backbone of the future Serbian army, which would transcend political parties and would defend Serb national interests, and the Serb Volunteer Guard was part of that at the time.
Q. Very well. You spoke of a viso orders. You described how the accused made such orders, you spoke of them being appropriate at the time of an imminent threat of war. Was what the accused was doing consistent with what a man in his position should be doing with an imminent threat of 27989 war?
A. I said that a viso orders was something that was quite usual in the organs of state administration, and I said sometimes I gave a viso orders to my collaborators and this was quite usual for a viso orders to be given directly tete-a-tete for a superior to give his subordinate such an order. Of course, I was not present when Mr. Milosevic spoke to people. I was not present, I did not hear him directly give a viso orders to anyone. I just heard General Simovic say, "President Milosevic told me this, this, and this," and I would note it down. I have my diaries here which I can show you, Your Honours.
Q. I'm going to cut you short because of time. You did in your answer make a linkage of this type of order to the imminent threat of war. The question was whether what the accused was doing, on the basis of what Simovic told you, was consistent with there being such an imminent threat or his acting as if there was such an imminent threat. Can you answer that, please?
A. It seems to me that in some borderline municipalities an imminent threat of war was proclaimed. So one could say that he respected those regulations in that case. But as for a viso orders, you have had so many military people here who could tell you about this off the top of their heads. They could talk about this.
Q. Let's move on. You were asked about shelling from one country to another. Shelling from one country or one part of Yugoslavia to another. Do you know of your own knowledge where Vukovar and East Slavonia was shelled from? Was it always from within or was it ever from without its 27990 own borders?
A. I can't answer this question. I don't know.
Q. There was a question raised by the accused as to whether Badza was or was not a volunteer. And he asked you a question about it linked with another question that drew a single answer. It's on page 38, line 15.
Just for clarification, was Badza a volunteer or not?
A. As Comrade Zoran Sokolovic told us, he had been sent from the Ministry of Defence to help Arkan and to help the populace in those areas. Whether he volunteered to go, I don't know.
Q. You were asked questions by the accused about actions of the air force in Vukovar at the time when Arkan emerged from Vukovar. It was suggested by him, the accused, that there were a lot of civilians present. Was the air force put into action on account of civilians or on account of Arkan's predicament?
A. In Vukovar, there were quite a few civilians, both Serb and Croat civilians, of course, but the action there then was precisely because of the situation Arkan found himself in. That's why General Simovic asked the air force simply to fly over but not to fire any shots. And President Milosevic asked General Simovic to --
Q. My next question relates to that. I think the word "entreating" was used, the accused claiming that he was entreating Simovic, and Simovic then did what he did. Did you ever hear of or see Simovic denying the accused anything he asked of him?
A. I didn't understand your question. 27991
Q. In their relationship, that is the accused and Simovic, did Simovic ever deny the accused something that the accused asked of Simovic?
A. Did the accused deny? Did President Milosevic deny that Simovic denied? Who denied?
Q. No. Did -- when the accused asked Simovic to do something, did Simovic always do it or did he ever refuse to do it?
A. There were things he couldn't do. He didn't make lists of incompetent generals, he didn't mobilise anyone, but he didn't tell the president he wouldn't do it. Most often he did what President Milosevic told him to do.
Q. Two last questions. The question of paramilitaries being illegal, were you ever aware of any paramilitaries being pursued on the grounds that they were unlawful?
A. Some proceedings were initiated before courts, and I know that Vojislav Kostunica with his team put himself at the disposal of the accused as their Defence counsel. However, most often when we received information that war crimes had been committed by these illegal paramilitary formations, we didn't know when or where or who or their name, so we were unable to investigate to a large extent. And time was short. All this happened within the space of two and a half months.
Q. The volunteers supported by or through the Ministry of Defence, once they'd been trained, where did they go and serve? They were deployed in units of the Territorial Defence of the place -- or rather, of places that were at risk, where there was a threat of genocide over the Serbian population, and they had the same treatment as the population of that 27992 place, if I'm correct.
Q. And as you say in your summary, that's in Slavonia, Baranja, and Western Srem and in the Krajina.
JUDGE MAY: The witness for tomorrow?
MR. NICE: C-062.
JUDGE MAY: C-062. Very well. Mrs. Gajic-Glisic, that concludes your evidence. Thank you for coming to the International Tribunal to give it. You are free to go.
THE WITNESS: [Interpretation] Thank you.
JUDGE MAY: Could the legal officer come up, please.
[Trial Chamber and legal officer confer]
--- Whereupon the hearing adjourned at 1.50 p.m., to be reconvened on Thursday, the 23rd day of
October, 2003, at 9.00 a.m.