030214ED

Page 16086

1 Friday, 14 February 2003

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.15 a.m.

6 JUDGE MAY: Yes, Mr. Nice.

7 MR. NICE: Your Honour, before the accused resumes his

8 cross-examination, you can see I'm assisted this morning by Mr. Theunens.

9 I draw this to your attention. He's one of the members of the OTP who has

10 assisted in the preparation of this witness, but he is, in due course,

11 going to be, or expected to be an expert witness is coming from the

12 military analysis department of the Tribunal and for those reasons I

13 thought I'd better put it on the record that he's actually in court today.

14 JUDGE MAY: Yes, Mr. Milosevic.

15 WITNESS: ALEKSANDAR VASILJEVIC [Resumed]

16 [Witness answered through interpreter]

17 Cross-examined by Mr. Milosevic: [Continued]

18 Q. [Interpretation] So, General, let's round off what we were

19 discussing about the competence of the -- of Yugoslavia towards the armies

20 of Republika Srpska and Republika Srpska Krajina. Is it true and correct

21 that Yugoslavia did not have any competencies with respect to command of

22 those armies -- over those armies?

23 A. In which period?

24 Q. Throughout the whole period. The material time. The period

25 you're testifying about. If somebody else has something else to add I'll

Page 16087

1 ask them.

2 A. Well, I explained that the Territorial Defence in the territory of

3 Kninska Krajina was subordinated and under the command of the JNA.

4 Q. Until the JNA withdrew pursuant to the Vance Plan; is that right?

5 A. Yes. And that's what I said.

6 Q. All right. Fine. Now, once the JNA withdrew from the territory

7 of Bosnia-Herzegovina and the territory of the Republika Srpska Krajina

8 according to the Vance Plan, and once the armies of Republika Srpska and

9 Republika Srpska Krajina had been formed, or the Serbian army of Krajina,

10 did the JNA have any power and authority over the commands over those

11 armies?

12 A. Well, the JNA didn't exist then.

13 Q. Did the army of Yugoslavia then have any authority over those

14 armies?

15 A. At that time, I wasn't an active-duty officer to be able to answer

16 that question directly, but I can give you some information which I knew

17 about and some data that I learnt about from the officers and superior

18 officers who, from the army of Yugoslavia, went to join up with the army

19 of Republika Srpska or Republika Srpska Krajina then once again returned

20 to the army -- to the JNA. And I know about the presence of top figures

21 from what we call the Vojna Linija, or military line, which during the

22 Pauk operation, Operation Pauk, were at the command post from which they

23 were able to command.

24 JUDGE MAY: Let him finish. Do not interrupt him.

25 Yes, General. Continue his answer. He is answering your question

Page 16088

1 about the information we had.

2 Now, is there anything you want to add, General?

3 THE WITNESS: [Interpretation] Well, just to finish the sentence I

4 had started. So some of these top people were in the most forward command

5 post for the Operation Pauk.

6 MR. MILOSEVIC: [Interpretation]

7 Q. General, I was asking you something quite directly, and that was

8 did the army of Yugoslavia have any command responsibility over the army

9 of Republika Srpska and Republika Srpska Krajina? I didn't ask you

10 whether it was a good year for plums or whether anybody had come visiting.

11 JUDGE MAY: No. Mr. Milosevic, that's a totally unfair comment.

12 Now, he's answered the question.

13 THE WITNESS: [Interpretation] Had you asked me about plums, I

14 would have told you about the plum situation. But you asked me whether

15 Yugoslavia participated --

16 JUDGE MAY: General, don't. You'll only keep things going.

17 Yes, Mr. Milosevic. Ask some further questions.

18 MR. MILOSEVIC: [Interpretation]

19 Q. What I asked was did the army of Yugoslavia have any competencies

20 and command authority over the army of Republika Srpska, army of Republika

21 Srpska Krajina.

22 A. And my answer was that I do not know.

23 Q. You don't know?

24 A. No, I do not know. I know about the details that I told you of.

25 Q. And you don't know that they had their headquarters and staff and

Page 16089

1 supreme commands? You know nothing about that? You know nothing about

2 who appointed the various commanders in the army of Republika Srpska and

3 Republika Srpska Krajina? You know nothing of any of that?

4 A. Well, I do know about that, but I don't know or, rather, I do know

5 that the ranks that were given had to be verified later on in Yugoslavia.

6 And I also know, and let me repeat once again, and this is not linked to

7 the army of Yugoslavia, that some of the top people from MUP assumed

8 command positions in Operation Pauk.

9 Q. General, well, you seem to have focused your attention on that

10 MUP. Whatever the subject, your answer is MUP.

11 A. Well, that's what the situation was like.

12 Q. Yes, yes, yes. We'll come to that. We'll get to that, and we'll

13 have other questions too linked to that particular issue. But you said

14 here, and I made a note of it, I wrote down your words, you said that a

15 parallel army had been established from the MUP and that MUP, you used the

16 word, became an armada. That's the word you used. Is that right?

17 A. I didn't emphasise it the way you're doing now.

18 Q. All right. But you did use the word "armada," didn't you?

19 A. No, I did not use the word "armada." That is not a term that I

20 use.

21 Q. All right. Well, look at the LiveNote and you'll be able to see

22 for yourself, and people in Yugoslavia watched all this. But tell us, how

23 big did the MUP get? How massive did it become, and how was this parallel

24 army in fact formed, and how far was MUP at all, because you say -- you

25 claim that -- how many members did MUP have at all?

Page 16090

1 A. Well, I'm keeping that piece of information as confidential, as

2 secret, an official secret, and I assume that you can give us a better

3 answer to that. But from the information and data and indices presented

4 here during the presentation of evidence, we saw that intervention

5 brigades did exist, that detachments did exist, that they had helicopters,

6 that they had APCs, armoured vehicles, and that is something that they did

7 not previously have. And you saw on the basis of the request that was

8 made, and you and I observed that it was a megalomaniac request, asking

9 for the Banja Luka SUP to provide technical resources and materiel which

10 was the materiel of a military brigade.

11 Q. Did the MUP of Serbia ask for that, request that?

12 A. I'm not talking about the MUP of Serbia, but you know full well

13 that the MUP of Serbia received from the army --

14 Q. Just a moment, General. Just a moment. Let's make things clear.

15 Would you please answer my questions.

16 A. But you keep interrupting me and I'm not able to provide an

17 answer.

18 Q. Well, I can't ask you one thing and have you answer something

19 quite different. What I'm asking you is how big this MUP was, because you

20 keep focusing on MUP and calling it an armada and things of that kind. So

21 how big was it in fact?

22 A. Well, I don't have any official data of information, but --

23 Q. Well, give us an example.

24 A. Well, it was publicised that there were about 90.000 men.

25 Q. General.

Page 16091

1 A. Well, all right. That's what I'm telling you.

2 Q. Isn't it unfortunate that a general, head of the intelligence

3 service, has to use data and information that he has heard bandied about

4 and rumoured in the streets, round the back corners of the streets and in

5 cafes? Is this serious testimony for you to quote a figure of 90.000 men?

6 A. Well, don't hold me to my word. I'm sure you will have facts and

7 figures which will show you what the state of affairs was.

8 Q. Yes, I do have them.

9 A. Well, then provide them.

10 Q. That's why I say it's shameful for you to claim something like

11 that.

12 A. Well, I'm not working in the MUP intelligence for me to be able to

13 have the kind of data that you have as president of the republic.

14 Q. Well, I see that you had -- did your intelligence work vis-a-vis

15 along the lines of just one member of MUP, and then you say you didn't

16 deal with intelligence work for the whole of MUP.

17 A. No, we didn't. These are facts and figures and information that

18 would come to us periodically from people who were sent away by people

19 like that, and I assume you knew that.

20 Q. You say harassed. Who harassed these people and sent them away?

21 A. Well, are we in open session?

22 JUDGE MAY: We are.

23 THE WITNESS: [Interpretation] I know about the officers.

24 JUDGE MAY: Do you want to go into closed session?

25 THE WITNESS: [Interpretation] Yes. That would be a good idea.

Page 16101

1 figures.

2 General, is there anything you want to say on what's been put to

3 you so far?

4 THE WITNESS: [Interpretation] This probably -- these figures apply

5 to the permanent police force and not including the reserve force. That

6 is the first point.

7 The second is perhaps it would be interesting to give the figures

8 for 1999.

9 MR. MILOSEVIC: [Interpretation]

10 Q. Yes, I do have the figures for 1999. They are spectacularly

11 different. They really are. A total of 36.000; 6.000 in administration,

12 3.500 firemen - so they went up by 500 - 3.000 crime police members, 3.500

13 frontier policemen - they were increased by 500 too - 4.000 traffic

14 policemen, and 16.000 policemen of general competence, including special

15 police units that you are referring to. And do you know that, General,

16 that they consisted of policemen working at their work posts, and then

17 when a special unit is formed --

18 JUDGE MAY: [Previous translation continues]... you're now going

19 on to a separate point.

20 General, you should be able to deal with the figures which have

21 been put. Is there anything you want to say about them before we come to

22 the special units?

23 THE WITNESS: [Interpretation] I did not have occasion to have such

24 data or to have access to them to be able to enumerate the numbers

25 regarding policemen and firefighters and all the rest. But I don't know

Page 16102

1 the unit that I mentioned, to whom it belonged, the Skorpions. I have no

2 idea.

3 MR. MILOSEVIC: [Interpretation]

4 Q. They reported to you on the 17th of May. What did you -- I report

5 about?

6 A. Well, what I referred to at the private session.

7 Q. I see. You were reporting that there was a volunteer unit

8 somewhere.

9 A. Not volunteer. Members of SAJ.

10 Q. So it was called a special anti-terrorist unit and not Scorpios.

11 So I'm asking you about the Scorpios in that unit.

12 A. I don't know about that. Someone may call himself what they will,

13 but a special anti-terrorist unit has its own formation and it is well

14 known what its name is, just like Arkan's unit which had its own name too.

15 Q. Do you know that Arkan was never in Kosovo during the war of 1999?

16 A. I don't know where Arkan was, but I was speaking about men from

17 his unit.

18 Q. But as far as I understand it, the men who were with him as

19 members of volunteer units applied as volunteers, and according to

20 information I received then that you are now testifying about - I don't

21 remember it but you have said it and let's accept it - that only 30 of

22 them were admitted as volunteers and the rest were turned back precisely

23 because of certain problems that the competent organs thought there might

24 be with them. Is that what you said?

25 A. I know what I said. Not quite the way you put it. Among other

Page 16103

1 things, it was said that the previous day they had killed people. That is

2 the first point.

3 Secondly, Mr. Sainovic did not know that Arkan's units were in

4 Kosovo Polje.

5 Q. Will you please answer my question. You keep mentioning Sainovic.

6 As you know, Sainovic was the vice-premier, the vice-president of

7 the federal government. And by the federal government, being the

8 vice-president of that government, he was assigned responsibility for

9 Kosovo and Metohija. During the OSCE presence, he was president of the

10 Yugoslav Commission for Cooperation with them. He negotiated with Rugova

11 and other politicians over there. He held a series of political meetings.

12 JUDGE MAY: What you must do is ask a question.

13 MR. MILOSEVIC: [Interpretation]

14 Q. Yes. I'm asking a question. If he said he was not aware of that

15 unit, why wouldn't you believe him? Do you believe that he was not

16 telling the truth?

17 A. No. I'm just saying that it was strange that he didn't know.

18 Q. Now, if he didn't know, how could I know?

19 A. You should have known from Rade Markovic, who told you about it.

20 Q. According to what you say, he passed on this information at a

21 meeting that Sainovic was present at, and Sainovic said that he didn't

22 know about it. Did that happen then?

23 A. I don't understand what you're saying.

24 Q. You described a meeting, but we'll come back to that meeting.

25 That was in public session, and you'll be able to answer questions about

Page 16104

1 it.

2 You described the meeting, and you said Rade Markovic said that

3 there were 30 men, volunteers, which they had accepted, and that the

4 others had been turned back, and that Sainovic said - when I asked what

5 about this - that Sainovic said that he was not aware of it, so how could

6 I have known if he didn't know about it? And he learnt about it, if what

7 you're saying is correct --

8 JUDGE MAY: It's not for the witness to answer what you knew or

9 didn't know, what you could have known and what you couldn't have known.

10 He's described what happened.

11 Now, you were asking questions earlier. I think we had got onto

12 Sainovic.

13 THE ACCUSED: [Interpretation] We'll come to that meeting, as the

14 witness diluted it rather, so we'll review it in its integrity.

15 MR. MILOSEVIC: [Interpretation]

16 Q. But let us focus for a moment on the police. As you see, quite

17 incorrect figures have been given by you regarding the police.

18 JUDGE MAY: He's given his answer to that. He's given his answer.

19 Now, let's move on.

20 MR. MILOSEVIC: [Interpretation]

21 Q. Do you know that the relative ratio of policemen in Serbia in

22 1995, for instance, not in 1991, the ratio of policemen to the population

23 was 1 to 434 citizens? This is counting all those employed in the police.

24 I don't know whether in other countries they count the firefighters and

25 the administrative officers and everything. In France, it is 1 to 266.

Page 16105

1 In Italy, 1 to 338. In Holland, in Britain. Only Japan has a lower

2 ratio.

3 JUDGE MAY: What is the point? What is the point?

4 THE ACCUSED: [Interpretation] The point is that there is a rumour

5 being spread here of a very strong police force in Serbia, whereas in fact

6 the police force in Serbia was smaller than in virtually all other

7 European countries in relation to the population. And Serbia was in a

8 wartime environment.

9 JUDGE MAY: We're not -- we're not in fact using the time very

10 usefully. You can call your evidence about that, but you know what the

11 witness says. He says that that doesn't include the reservists, the

12 reserve forces who, the evidence is, were in action. Now, whether they

13 were or not is something which we may have to decide, but there's no good

14 arguing with the witness whether there were a lot or not a lot of

15 policemen. We've gone as far as we can on that.

16 MR. MILOSEVIC: [Interpretation]

17 Q. The reserve force could only exist in wartime, and the witness is

18 talking about 1991 and 1992, and you too are referring to that period.

19 Therefore, gentlemen, these are things that cannot be compared.

20 A. May I comment briefly? From the figures that you have given, in

21 1991 there were about 10.000 people employed in the police.

22 Q. I said in 1991, there were 22.000 total, not counting the state

23 security which was always constant at the level of 3.500, whereas the

24 general competence police numbered 10.000, traffic 2.000, frontier 2,

25 crime 3, firefighters 2.000 --

Page 16106

1 JUDGE MAY: Let the witness -- we've heard these figures. Let the

2 witness finish.

3 THE WITNESS: [Interpretation] Let's say 20.000. Again, it was

4 doubled. But that is not the point I'm making in this discussion.

5 In 1992, that is in the month of March, the standing force of the

6 JNA in those days had a total of 36.000. So compare the number of

7 employed in MUP to those in the army, and I'm saying that they were more

8 or less equal.

9 MR. MILOSEVIC: [Interpretation]

10 Q. How can you say such things as a general? A policeman is

11 employed, and a soldier is not an employee. The police doesn't have

12 soldiers who are unemployed and serving as part of their national service.

13 You're talking about the employees in the army who are officers and

14 non-commissioned officers, professional soldiers who receive a salary. In

15 the police -- in the police, all policemen are professionals. There are

16 no conscripts in the police, doing their military service. Therefore, the

17 army mostly consists of conscripts doing their national service, and the

18 minority are officers. Unless you're saying that there are more officers

19 than soldiers.

20 I'm giving you the total number of the employed in the Ministry of

21 the Interior, including the administration, including the technicians, the

22 firefighters, and everyone else. You said 90.000.

23 JUDGE MAY: Let us deal with it in this way: Mr. Milosevic, as

24 usual, you argue with the witness. That's not what you're here to do.

25 Now, General, is there anything you want to add to what you've

Page 16107

1 said?

2 THE WITNESS: [Interpretation] I said that the number of

3 permanently employed in the MUP and the number of permanently employed in

4 the whole of the Yugoslav People's Army was such that there were more in

5 the MUP than in the JNA.

6 MR. MILOSEVIC: [Interpretation]

7 Q. Well, give us the figures, please. What was the total number of

8 staff in the JNA?

9 A. Thirty-six thousand.

10 Q. I see, 36.000. What year?

11 A. On the 27th of March, 1992.

12 Q. The whole of the JNA. Fine. I'll take that figure as your claim,

13 as I have to save time. I just wish, before passing on to some concrete

14 questions which you should be well-informed about, to ask you the

15 following: Was it the top military leadership in 1991, Veljko Kadijevic

16 -- I'm now talking about the ethnic composition. He was a Yugoslav.

17 Blagoje Adzic, chief of the Main Staff, a Serb from Bosnia-Herzegovina.

18 So cadres from Bosnia-Herzegovina. Josip Gregoric, deputy and

19 under-secretary from Croatia, a Croat. Stane Brovet, a deputy federal

20 secretary, a Slovene. Mile Ruzinovski, Chief of Staff of the first

21 administration - this is the operations administration and the most one -

22 a Macedonian. The commander of the north-western theatre of operations,

23 Konrad Kolsek, a command post in Zagreb, a Slovene.

24 JUDGE MAY: I'm going to stop you reading this. You're supposed

25 to be asking questions.

Page 16108

1 General, if at any stage you disagree with anything that's being

2 said, just interrupt, because it's the only way we can deal with it. Do

3 you agree so far with what the accused has read out?

4 THE WITNESS: [Interpretation] The -- what he has read out is

5 correct, and it applies to the first half of 1992 and not to the

6 subsequent period. In more concrete terms, General Gregoric was pensioned

7 off, and he was replaced by General Sljivic. General Kolsek was also

8 replaced as commander of the 5th Military District, and General Avramovic

9 came to take his place, Zivota Avramovic. Then General Ruzinovski was

10 replaced when he was sent as commander of the 2nd Operative Group to

11 Eastern Herzegovina, and only a few days after that, because of his

12 alleged reaction to the fact that Montenegrins over there and other people

13 who were there would not allow a Macedonian to be their commander. And

14 let me not go on enumerating, but these are the facts.

15 On the 4th of December in 1991, 41 per cent of the total staff in

16 the air force, and I'm only talking about the air force, were not Serbs

17 and Montenegrins; they were people of all ethnicities. There were 2 per

18 cent Hungarians, 1 per cent Albanian. And regarding the actual flyers,

19 the pilots, 52 per cent were Serbs and Montenegrins, and 48 per cent were

20 people of other ethnicities. However, that picture in the subsequent

21 period, that is during the second half of 1992 and 1993, changed

22 significantly so that, on various grounds, people were replaced because

23 they didn't have citizenship and they now belong to other states. Some

24 stayed on.

25 MR. MILOSEVIC: [Interpretation]

Page 16109

1 Q. But let me -- please answer my question first and then we'll move

2 on and you can make any additional remarks if you have any.

3 This list that I've read out to you so far, is it correct? I'm

4 asking you, is it correct for 1991? Is it correct or not? Don't explain

5 what happened later. We'll come to the reasons for the changes.

6 A. But I'm giving you a different picture for the end of 1991. That

7 is also 1991.

8 Q. What do you care about the picture? I'm asking you whether this

9 is correct.

10 A. It's not correct in the way you're interpreting it.

11 Q. So Aleksandar Spirkovski, a Macedonian, was not the commander of

12 the central theatre of war.

13 A. When, when, when?

14 Q. In 1991.

15 A. He was not until the end of 1991.

16 JUDGE MAY: I'm going to stop this. I'm going to stop this for a

17 moment. Read out what you say the position was for 1991 and we'll hear

18 that and then we'll go on to deal with later.

19 MR. MILOSEVIC: [Interpretation]

20 Q. Well, let him challenge any name. I'm going to read this out to

21 you. I'm going to read out 16 names. 1, Veljko Kadijevic, Federal

22 Secretary. 2, Blagoje Adzic, Chief of General Staff. Josip Gregoric,

23 deputy federal secretary and under-secretary. Stane Brovet, deputy,

24 federal secretary, under-secretary. Mile Ruzinovski, head of the first

25 administration of the General Staff. That is the cooperative -- that is

Page 16110

1 the operative administration. Konrad Kolsek -- I'll slow down. Konrad

2 Kolsek, commander of the north-west battlefield.

3 The commanders in Zagreb: Spirkovski, commander of the central

4 theatre, headquarters in Belgrade. Andrija Silic, also a Croat, Chief of

5 Staff of the central theatre. Zivota Avramovic, head of the south-east

6 theatre, headquarters in Skopje. Bozidar Grubisic, head of the navy.

7 Anton Tus, head of the air force. Zvonko Jurjevic, deputy chief of the

8 air force.

9 So when Tus was pensioned off, as you said, again, he was replaced

10 by a Croat, Jurjevic.

11 Ivan Radanovic, head of the centre for higher military schools in

12 Belgrade. Ibrahim Alibegovic, head of the war college. Tomislav Bjondic,

13 commander of the Command Staff Academy.

14 JUDGE MAY: What nationality or ethnicity are you saying they had?

15 THE ACCUSED: [Interpretation] This is the way it was: Kadijevic,

16 Yugoslav; Adzic, Serb from Bosnia; Josip Gregoric, Croat; Stane Brovet,

17 Slovenian; Mile Ruzinovski, Macedonian; Konrad Kolsek, Slovenian;

18 Aleksandar Spirkovski, Macedonian; Andrija Silic, Croat; Zivota Avramovic,

19 Serb; Bozidar Grubisic, Croat; Anton Tus, Croat; Zvonko Jurjevic, Croat;

20 Ivan Radanovic, Croat; Ibrahim Alibegovic, Muslim; Tomislav Bjondic,

21 Croat; Mate Petar, a Croat.

22 The ethnic pattern as regards these 16 top generals in the top

23 military echelon of the JNA: One Yugoslav, two Serbs -- that is to say

24 from Bosnia and Serbia proper, a total of two Croats, eight Slovenians,

25 two Macedonians too, and Muslims one.

Page 16111

1 Did I have any influence over this top military echelon? You tell

2 me that.

3 JUDGE MAY: You're going on to a totally different point. First

4 of all, let's deal with the list as it's been read out, since the general

5 is giving evidence and not you.

6 Is the list which the accused has read out correct for 1991 or

7 not?

8 THE WITNESS: [Interpretation] Just for one period in 1991, the

9 first half of 1991, as regards some persons. As regards some other

10 persons, it is relevant to the period up to September 1991.

11 Bozidar Grubisic was not, in 1991, commander of the navy. He was

12 Assistant Federal Secretary for National Defence.

13 MR. MILOSEVIC: [Interpretation]

14 Q. For what?

15 A. For personnel. Political affairs, et cetera.

16 Q. Oh, it's not correct that Grubisic was commander of the navy in

17 1991?

18 A. No. No. Another admiral who was a Serb. I can't remember his

19 last name right now, but it's not that it really matters. And his Chief

20 of Staff was a Croat. Bozo Erceg. Out of those who have been mentioned,

21 the following have been replaced: As I said, General Ruzinovski,

22 immediately a few days after being appointed commander of the 2nd

23 Operative Group, at the request of Montenegro, as far as I know, that he

24 is not accepted as this kind of an appointment because he's Macedonian.

25 Then General Spirkovski was replaced by Zivota Panic who was

Page 16112

12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.

Page 16113

1 appointed.

2 Andrija Silic was replaced and later on, he was detained and

3 investigations were carried out against him in 1993.

4 Then General Kolsek was replaced and Zivota Avramovic took his

5 place.

6 And I could go on referring to these replacements and other

7 appointments, however, I cannot give a clear-cut answer. If one says

8 1991, this situation was partially true. But as I said, either up to June

9 1991 or by September, at the latest, when all these changes were made and

10 when retirements took place. But General Zvonko Jurjevic did not come to

11 become Deputy Chief of Staff for the air force. He was commander of the

12 air force.

13 Q. I'm not saying that. He was deputy head of the air force. He was

14 Tus's deputy. And then when Tus left, he came to his position. Is that

15 right or is that not right?

16 A. No, that's not right. In the army this is called the Chief of

17 Staff.

18 Q. Oh, all right. He was the number 2 person in the air force; is

19 that right? Tus was commander, Jurjevic was Chief of Staff. Both of them

20 Croats. When Tus retired, the then Chief of Staff Jurjevic became

21 commander. Is that right?

22 A. Yes.

23 Q. So a Croat was there before him, he retired, and then again a

24 Croat came to the position of commander of the air force.

25 A. Yes. Yes. And on the 25th of September, 1991, an effort was made

Page 16114

1 to carry out a coup in the air force. Bozidar Stefanovic was behind it,

2 and they tried to get rid of Zvonko Jurjevic in this way.

3 Q. Oh, please. What did you challenge out of this entire list that I

4 read out to you? Only that Grubisic was not commander of the navy but,

5 rather, Assistant Federal Secretary for National Defence. Is that right?

6 A. No. I gave my answer. If you didn't understand it, I'm not going

7 to repeat it.

8 Q. Is there something else that is incorrect in this list? You claim

9 that Grubisic was not at this position?

10 A. What period are you talking about?

11 Q. 1991, General.

12 A. Which month? The year has 12 months.

13 Q. I'm asking you about 1991.

14 A. That is an imprecise question.

15 Q. Well, I don't know what hour, minute, and day people -- until what

16 minute, hour, and day people held their appointments. I have this list

17 and I'm asking you whether it's correct.

18 A. I said for which period this list was correct and in what respect.

19 Q. Oh, so towards the end of 1991 Kadijevic was no longer Federal

20 Secretary for National Defence, Blagoje Adzic was no longer Chief of

21 Staff, and let's go on.

22 A. You're not right.

23 Q. Were they or were they not?

24 A. Until the 8th of January, Kadijevic was Secretary for National

25 Defence.

Page 16115

1 Q. Was Adzic throughout 1991?

2 A. I didn't challenge any of that.

3 Q. So what are you challenging?

4 A. Well, go on. Go on. Move on to Spirkovski.

5 Q. All right. I read you this list for 1991.

6 A. Well, that's fine. But you're asking me about Blagoje Adzic. Why

7 don't you ask me about Spirkovski?

8 Q. I don't have time to. I read out all the names to you and I don't

9 have time to go from one name to another, I'm not going to go into all of

10 that, I'm just asking you about 1991 when these conflicts started.

11 JUDGE MAY: The witness has answered. Now what he should have, in

12 fairness to him, is the list in front of him so that he could begin to

13 answer it. If you want to ask any more questions about it, then you'll

14 have to put a copy of it in front of him, or the original.

15 THE ACCUSED: [Interpretation] I will deal with that. That's not a

16 problem for the witness either. He's just trying to be of such great

17 assistance to this Prosecution that even what is undeniable he is trying

18 to challenge.

19 JUDGE MAY: No, Mr. Milosevic. Comments do not assist. Just get

20 on with the questions. If you want him to have a copy of the list, he can

21 have it. Otherwise, we'll move on to another topic.

22 THE ACCUSED: [Interpretation] When we go back to that, I'll give

23 him the copy. Actually, somebody can take this and this copy -- this can

24 be copied.

25 THE WITNESS: [Interpretation] By your leave, I don't really need a

Page 16116

1 copy of this. I know all of this by heart.

2 JUDGE MAY: Well, it's probably just as well the Court has a copy.

3 MR. MILOSEVIC: [Interpretation]

4 Q. General, if possible, can you just give me brief answers to my

5 questions, because my time will be limited. I'm going to put an entire

6 series of questions to you that have to do with the period that you're

7 testifying about and concerning events that you should know something

8 about.

9 Is it correct that after the victory of the HDZ in the elections

10 in 1990 that over there various expert teams were immediately established

11 for military matters?

12 A. Yes.

13 Q. Is it correct that a project of the Croat armed forces was carried

14 out then, counting on 44.000 people for all the arms and services, that is

15 to say the army, navy, and ground forces?

16 A. Yes.

17 Q. Is it correct that on the basis of that project a plan of special

18 activity vis-a-vis JNA officers was worked out, especially those who were

19 ethnic Croats, with a view to breaking up the JNA?

20 A. Yes.

21 Q. Is it correct that Boljkovac then stated that Croatia is prepared

22 to sacrifice 25.000 people in order to attain these objectives?

23 A. Yes.

24 Q. Is it correct that in mid-1990 a meeting was held between the

25 delegation of the HDZ and the Slovenian Demos precisely in order to agree

Page 16117

1 on what their tactics vis-a-vis the JNA would be in order to have broken

2 up?

3 A. Yes, there was a meeting then, and there was another meeting in

4 January 1991 in Otocac Krka. That is correct.

5 Q. Is it correct that on the basis of the agreement reached then,

6 that you have confirmed, the leaderships of the HDZ and Demos, on the 9th

7 of July, 1990, Slovenia started preparations for establishing its own

8 army? And Jelko Kacin, the Deputy Minister of Defence of Slovenia, in the

9 centre for training the TO near Ljubljana, said that Slovenia already in

10 September would sent to the federal authorities an ultimatum that 60 per

11 cent of conscripts should serve their military service in Slovenia, 35 per

12 cent in Croatia, and only 5 per cent in the rest of the SFRY, and that

13 already in December of that year 90 per cent of the conscripts would

14 remain in Slovenia and 10 per cent would be in Croatia. Do you remember

15 these figures?

16 A. This is 1990?

17 Q. Yes.

18 A. Well, yes, that's right.

19 Q. Is it also correct that Kacin said at that meeting that if the

20 federal authorities do not meet this request, Slovenia would stop paying

21 into the federal budget and it will also tell all Slovenian officers to

22 leave the JNA in order for the Slovenian army to be established?

23 A. That is correct.

24 Q. Is it true that this was coordinated with the leadership of

25 Croatia?

Page 16118

1 A. Yes.

2 Q. Is it correct that at that time what was agreed upon was that all

3 powers of the federal states should be taken over in the domain of defence

4 and that all of this should be put under their own authority, that a

5 detailed cleansing of personnel and secretariats should be carried out,

6 Secretariats of National Defence, also in the Territorial Defence, in the

7 Ministry of Interior, and that at all offices in these ministries tested

8 personnel who are ethnic Croats and Slovenians respectively should be

9 appointed?

10 A. Yes, that's right.

11 Q. Is it true that in the -- in mid-1990 in Croatia, that is to say

12 in 1990, mid-1990, that what started was the massive establishment of

13 volunteer units in order to replace the Territorial Defence which was

14 multi-ethnic and that this, in mid 1990, preceded the National Guards

15 Corps?

16 A. I know about information from mid -- mid-July 1990 when volunteer

17 units were established that were then called the Croatian National Guard

18 Corps.

19 Q. So we are talking about mid-1990. Let's not split any hairs now,

20 15 days here or there. Is it correct that in mid-June 1990, mid-June 1990

21 in Croatia, a campaign was launched to replace the top personnel of the

22 TO? About 60 per cent of all personnel were replaced. And within that

23 campaign of replacing the top personnel of the TO, on the 25th of June,

24 1990, Spegelj sent a telegram to all in the TO related to the change of

25 personnel because there was resistance to such policy, and then he informs

Page 16119

1 them in this telegram and he makes it compulsory upon them to cleanse the

2 personnel of the TO, and in this sense they should closely coordinate with

3 the leaders of the municipalities. Do you know about that?

4 A. I know about that telegram. I'm not sure about the actual date

5 and the month that you are referring to, but I do know about the personnel

6 purges in the Ministry of Defence of Croatia. When General Spegelj became

7 minister, he immediately dismissed 20 employees who were primarily ethnic

8 Serbs, and this fits into the context that you are referring to now, but I

9 don't know exactly which month this was.

10 Q. Is it correct that through HDZ committees and the Catholic church,

11 these volunteer units were enlisting their personnel?

12 A. Checks were made for the personnel for these volunteer units. It

13 is either the Catholic church or the local committees of the HDZ that were

14 checking them out and giving recommendations for them. I don't know

15 whether they were actually carrying out the recruitment, but the Catholic

16 church, inter alia, said who was eligible to enlist in these units.

17 Q. Is it correct that at that time, from Western Herzegovina, 220

18 members were received from there because Croatia already considered

19 Western Herzegovina to be their territory at that time?

20 A. So we -- we had that kind of information.

21 Q. So is that correct?

22 A. Yes, that's correct.

23 Q. Is it true that among the persons who were engaged were many

24 persons who were sentenced to many years in prison for having committed

25 grave crimes, as well as those who had not done their military service?

Page 16120

1 So in order to -- in Valdanos, Lucka, Zagreb, Rakic, all prisoners were

2 released, all of those who were serving prison sentences for grave crimes

3 like looting, murder, et cetera? Do you know about that?

4 A. That's not what I know.

5 Q. Well, say what it was.

6 A. It's not in Valdanos but in Valbadon, near Pula. And also the

7 other places that you mentioned, these were not prisons, these were camps

8 for training and for having these units that were established stationed.

9 So in Lucka, there was not a prison, this was a MUP base. So these were

10 not prisons. What is true is that there was one prison, Valbadon, near

11 Pula. Valdanos is on the southern coast.

12 Q. Okay. There may be a mistake as far as the name is concerned, but

13 is it correct that it is precisely these persons who were serving prison

14 sentences were engaged there? Is it true that criminals were recruited?

15 I'm talking about the actual phenomenon.

16 A. That's correct. Just like in some military units in Serbia there

17 were also criminals.

18 Q. Yes. I understand your need to explain straight away that there

19 was something of that kind in Serbia. I'm sure there is in France and

20 England, but I'm asking about Croatia specifically now.

21 Is it true that at that time or, rather, on the 27th of July, 1990

22 we're talking about, a competition was published to take in MUP personnel

23 on condition that the candidates were morally and politically reliable,

24 could be trusted, and so on and so forth? So that all those who were

25 recruited secretly were later on turned in to these orderlies of the ZNG,

Page 16121

1 Croatian National Guard Corps, and stationed in the training centre in

2 Zagreb?

3 A. Well, the situation was a little different. First of all, data

4 was published in the Belgrade press as to the formation of the Croatian

5 guards. And I think that this was on the 25th of July, 1990. And then

6 two reactions that came with the establishment of this organisation: The

7 MUP who had taken in these people earlier on, previously, into these

8 illegal volunteer units covered them by publishing a subsequent

9 competition on the 27th of July, whereas the competition was published as

10 it was in the Socialist Republic of Croatia, which implied moral and

11 political reliability, trustworthiness, and so on. So there was this job

12 vacancy that was publicised and that was the competition. And the

13 condition was that they had done their military service. So until this

14 job announcement came up, they tried to legalise -- with this competition

15 and job announcement, they tried to legalise the people who they had taken

16 in earlier.

17 So this centre, this educational training centre, was not the only

18 thing and existed in these facilities in Zagreb but in the other places

19 that you said were prisons and were not prisons.

20 Q. So you mean the institutions of higher learning.

21 A. Yes, that's right.

22 Q. Well, let's make one thing clear: The fact that was publicised

23 about these illegal formations was correct, was it not?

24 A. Yes, it was.

25 Q. And when they saw that everything had been made public and come

Page 16122

1 out into the open because the press had been writing about it, they

2 hurried up to legalise the illegal situation that had been created

3 previously; is that what you're saying? Is that correct?

4 A. Yes, that's right.

5 Q. And is it true that, in that period of time, those units had

6 already been armed with automatic weapons?

7 A. Which period are you talking about?

8 Q. In the period of time that we're talking about, that is to say

9 mid-1990 or, rather, July to be more exact. Let me put myself right and

10 say July 1990.

11 A. I know about the period from the end of September or the beginning

12 of October, I know that for certain, that they did have automatic weapons.

13 What weapons they had before that, I can't say. But as of the end of

14 September and beginning of October, from the contingent of weapons that

15 had been imported and brought in from Hungary, these formations were

16 armed, yes. What they had been using for weapons before that, I don't

17 know.

18 Q. Is it true that at that time the Territorial Defence in Croatia

19 was selected on an ethnic basis, already at that time, that its members

20 were selected on an ethnic basis in the middle of the year?

21 A. The -- no. The Territorial Defence was not, especially the

22 republican staff and headquarters. Again General Ostovic was still there,

23 he was a Croat. However, the Secretariats for National Defence, which

24 were under the jurisdiction of the Ministry of Defence, something was done

25 there and the cadres were sifted through and vetted. Now, whether in some

Page 16123

1 Municipal Staff of the Territorial Defence some of this vetting took

2 place, I really can't say, but in the Secretariat for National Defence,

3 that was true; it did happen there.

4 Q. All right. And is it true that from June 1990, Croatia, to all

5 intents and purposes, intensively worked to establish its own army, to

6 form its own army, and that there was intensive training of these

7 formations and the aim was on marksmanship?

8 A. They started their training with marksmanship, as far as I know,

9 and they represented this as being as the members were the police. But as

10 I know, the police -- and guardsmen. But the police, first of all, learns

11 about rules and regulations and then how -- and then learns how to use

12 weapons. With them, it was the reverse.

13 Q. And is it true, General, that in August 1990, Vladimir Seks, Ivan

14 Vekic, Branimir Glavas -- do you know those names? I assume you do.

15 A. Yes I do.

16 Q. Were they all top functionaries of the HDZ? That's right, isn't

17 it?

18 A. Yes, they were.

19 Q. The new authorities in Croatia. That was what they were. And in

20 August 1990, they agreed to form the armed section or armed detachments,

21 in fact, armed detachments on the territory of the Sremska Baranja region,

22 and the formation of groups for silent liquidation.

23 A. What I know for certain is this: I know about Glavas. He was the

24 Secretary for National Defence in Osijek. And I know that Mercep,

25 Mercep's group, in fact, that he had distributed 100 rifles to Mercep's

Page 16124

1 group and about 300 kilogrammes of explosives. And I also know what the

2 whole of Yugoslavia knows and learnt from the programme that was televised

3 later on, that Glavas did have these groups -- or, rather, Mercep had

4 groups for silent liquidation, and that after the television programme,

5 the man was -- the man who said all this was killed, and his name was

6 Zvonko Ostovic.

7 Q. Yes, I did quote that example and said that after the television

8 programme, this man was killed. I said this before some witnesses who

9 denied it and I'm very happy to hear this from you. I said this was a

10 going to be a good, useful witness.

11 Now, were these groups for secret liquidations, were they

12 targeting the leading Serbs, communists, et cetera? Those were the

13 criteria more or less, that they were prominent Serbs, good communists, et

14 cetera?

15 A. Yes.

16 Q. Is it true that -- as you say you know Glavas, by the way, is it

17 true that he had a group of this kind that numbered 17 members and that

18 they were all identified, while Mercep also had his own group of men and

19 only four of those men were identified as being members of the group, and

20 Glavas for terrorist actions, according to my information, gave Mercep

21 1.000 rifles and 300 kilogrammes of explosives.

22 A. No, it wasn't a thousand rifles, it was 100 rifles. That was our

23 information.

24 Q. How much explosives?

25 A. That is correct, 300 kilogrammes of explosives.

Page 16125

1 Q. Yes. That's right.

2 A. You now have some details, I assume, there in front of you about

3 that. I think they are more or less true. I can't say if there was 17 --

4 if Glavas had 17 members and Mercep had another number, but I do seem to

5 recall figures of that kind, of that order.

6 Q. But at that time in the mid-1990 -- in mid-1990 when all the

7 terror began and the liquidations began, there was complete peace in

8 Yugoslavia. There were no clashes or conflicts at all at that time. Did

9 the Serbs pose a threat to anyone at that time? Did they jeopardise

10 anybody?

11 A. If you're talking about that particular period of time, that would

12 be up until mid-1990, no, I don't know that any excessive incidents or

13 behaviour existed at that time.

14 Q. Is it true that the terrorist group of the Croatian Uzdanica was

15 formed at that time?

16 A. Have you heard of the Croatian Uzdanica, made up of 80 men, and in

17 Osijek 40 were under the command of Damir Horvat; is that correct?

18 A. Yes, that is correct. That is Damir's statement to the security

19 organs.

20 Q. And is it true that already in the summer of 1990 when there was

21 complete peace, when peace reigned, that there were mass provocations that

22 were launched and open attacks and pressure against the JNA, its members

23 and family members, the family members of the officers?

24 A. This kind of pressure escalated as time went by, that's true, but

25 that was from August on, or perhaps September 1990. So we had records of

Page 16126

12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.

Page 16127

1 concrete acts of provocation and some JNA members were even taken into

2 custody. And I can remember some of this. I presented this data and

3 information when I was questioned. So I do remember this particular piece

4 of information. From 1988 until the end of 1991, for instance, we had

5 records for Yugoslavia as a whole. 459 attacks on members of the JNA,

6 members and JNA facilities. Of that number, 200 took place in 1991. And

7 106 of those 200 took place in Croatia. So those are the facts and

8 figures for 1991. Those are the details.

9 As to when they started, I think that the first cases were

10 recorded in August, August through September and later on.

11 Q. 1990, are you saying?

12 A. Yes, 1990.

13 Q. Fine.

14 JUDGE MAY: That would be a convenient moment to adjourn. Twenty

15 minutes.

16 --- Recess taken at 10.30 a.m.

17 --- On resuming at 10.55 a.m.

18 JUDGE MAY: Yes, Mr. Milosevic.

19 THE ACCUSED: [Interpretation] Mr. May, bef