030611ED

Page 22067

1 A. Srdjan Knezevic was a local Serb from Pale. Before the war, he

2 had a coffee bar in Pale. Out of all these men I saw in these areas while

3 I was in Herzegovina and in Sarajevo, Srdjan Knezevic is the only one for

4 whom I can say that he was an honest man up to a degree. I mean, there is

5 no doubt about that, but he was a man who had a unit where there was some

6 kind of discipline.

7 Q. The unit, was it -- was it integrated in the VRS structure? And

8 if so, in which corps? To which corps did it belong?

9 A. Yes. It belonged to the Army of Republika Srpska. Officially it

10 belonged to the Sarajevo Romanija Corps. However, General Milosevic did

11 not have any influence whatsoever over Srdjan Knezevic directly.

12 Q. Who had the influence over Knezevic?

13 A. Ratko Mladic.

14 Q. And how do you know that?

15 A. Well, I know that on the basis of a million examples. For

16 example, many times Han Pijesak was contacted when Srdjan needed

17 something, and every action that Srdjan undertook was based on contacts

18 with Mladic before that.

19 Q. You mentioned Han Pijesak. Was that where Mladic was usually?

20 A. Yes.

21 Q. Did you ever hear or see Knezevic refuse to fulfil an order from

22 General Milosevic?

23 A. Yes, many times.

24 Q. And in such a case, what would happen?

25 A. Nothing would happen. Absolutely nothing. It would be the way

Page 22068

1 Srdjan said.

2 Q. The soldiers in the White Wolf unit, what kind of soldiers were

3 they? Where did they come from?

4 A. There were all kinds of people there. There were local Serbs from

5 Pale. There were Russians. There were Bulgarians. Seven languages were

6 spoken in the dorm. Most of these people had come from elsewhere.

7 Q. And what uniform did they wear? And did they have a particular

8 patch?

9 A. The uniforms were camouflage uniforms of the Army of Republika

10 Srpska. There were no patches whatsoever on the uniforms because these

11 were Srdjan's explicit orders that nobody should have any kind of patch or

12 insignia on them. The White Wolves never had any kind of patch or

13 insignia on except for the head of a white wolf on their vehicles.

14 Q. You have already mentioned that you were stationed in a building,

15 a wood building, at Jahorina. And you have actually prepared a sketch

16 with the help of the investigators. And it's tab 7. It is -- and I have

17 a few questions in relation to the buildings that you have indicated in

18 this sketch.

19 First of all, you have a building with the name "Mladic" in it.

20 What kind of a building was it and why is "Mladic" marked here?

21 A. It says "Mladic" here because that's what everybody called it in

22 the vernacular. This was a hotel where Mladic had most of his meetings.

23 I don't know how many times we saw his vehicles and his high-ranking

24 officers who had meetings with him.

25 Q. And you have also indicated this White Wolves's headquarters. And

Page 22069

1 did you actually -- the White Wolves, did you actually sleep in that

2 building when you were in Jahorina?

3 A. This is the headquarters of the White Wolves, and this is the

4 dormitory for the White Wolves, for people who came from elsewhere. But I

5 don't know whether I was there 20 times in total in this house, and

6 everybody else for that matter. Because we spent most of our time in

7 Trnovo and Treskavica.

8 Q. For what reasons did you go to this headquarters in Jahorina?

9 A. That would happen only when we would have time off. However, that

10 happened so seldom that I can count it on the fingers of one hand.

11 Q. And you have indicated also a place, Kosuta, and you put there the

12 name Goran Saric. What kind of a place was Kosuta and who was that

13 person?

14 A. Kosuta had been a hotel before the war. And when I came there, it

15 was the base of the special police brigade that was commanded by

16 Goran Saric. Its commander was Goran Saric.

17 Q. And you say "special police brigade," of the Republika Srpska? Is

18 that ...?

19 A. Yes.

20 Q. And you have also here the Hotel Bistrica. Who would use that

21 hotel?

22 A. Hotel Bistrica is also at Jahorina. It was used by the government

23 of Republika Srpska.

24 Q. Did you see government members there?

25 A. Yes, very often.

Page 22070

1 Q. What would they do there?

2 A. Some of them had rooms where they slept. Most of them came there

3 to gorge on food and drink.

4 Q. Did the White Wolves also use that -- the kitchen of the hotel to

5 eat and spend time there?

6 A. Yes. Every time they would have time off, or rather, when we

7 would have time off, Srdjan's orders were that they had to give us food

8 there.

9 Q. Was Srdjan Knezevic ever asked to join the police forces with this

10 unit?

11 A. Yes.

12 Q. And what was his reaction to this?

13 A. Well, when these two monkeys from the MUP came, they came with a

14 briefcase full of money, and they made this offer to Srdjan. They said

15 that there was no need for him to go into action, no need to do anything.

16 He was just supposed to provide security for Karadzic. At the end of this

17 story, there were four or five of us there, and we tried to save these two

18 men.

19 JUDGE MAY: I'm sorry to interrupt, but we can't use expressions

20 like "monkeys." It doesn't assist. Who are we talking about.

21 MS. UERTZ-RETZLAFF:

22 Q. You heard that. About whom are we talking?

23 A. These are men from the MUP, from the Ministry of the Interior of

24 the Republika Srpska.

25 Q. And did you know their names or not?

Page 22071

1 A. No. Srdjan knew them personally. They were some local men from

2 Pale. I had never seen them in my life.

3 Q. And why did Srdjan -- how did he react to the offer?

4 A. As I've already said, we tried to save those two from being killed

5 by him.

6 Q. So he rejected it?

7 A. Yes.

8 Q. You have already mentioned that you usually were in -- on other

9 location, and you mentioned Treskavica and Trnovo.

10 MS. UERTZ-RETZLAFF: Your Honours, it is indicated on the map

11 again, the region. It's an entire region. And indicated is here with

12 letter "B." It's indicated here with the letter "B." And Trnovo is

13 actually right above -- let's say 2 centimetres above the letter "B."

14 Q. Witness, when you were in Trnovo, where would the White Wolf unit

15 stay?

16 A. In the school building.

17 Q. Which other units did you see in Trnovo?

18 A. There were members of the police there, of the police of Republika

19 Srpska, mostly from Kula. Also, there was a police station from Trnovo.

20 There were members of the Army of Republika Srpska from the

21 Sarajevo-Romanija Corps. Their commander was Cedo Sladoje.

22 Q. Were any Seselj Chetniks there?

23 A. During the major offensive of the Muslim forces, there was Slavko

24 Aleksic from Grbavica.

25 Q. And when was that major offensive?

Page 22072

1 A. In 1995.

2 Q. You have mentioned just this person, Aleksic, Slavko Aleksic

3 from -- no, I'll come to him a little bit later.

4 In the school in Trnovo, were there only Serb soldiers housed or

5 also Muslims?

6 A. A platoon, a work platoon, from Doboj was accommodated there as

7 well.

8 Q. Where did they -- did they directly come from Doboj, or were they

9 from some other place, transferred from a different place?

10 A. What I know I know from what they said, that is, that they were

11 from Doboj. However, as far as I know, they were first transferred to the

12 prison at Kula in Sarajevo and from there they were transferred to Trnovo.

13 Q. Does that mean they were detainees?

14 A. Yes. Yes.

15 Q. And why were -- what were they used for in Trnovo? Why were they

16 there?

17 A. As I have already said, they called them a labour platoon and they

18 were used to dig trenches and dugouts along the frontlines at Treskavica.

19 Q. Did the White Wolves order them to do such things, or who?

20 A. I don't know who was their superior. They just slept there in the

21 same building. The White Wolves and Srdjan Knezevic couldn't give them

22 any orders because the White Wolves never held the lines, the frontlines.

23 Q. In early May 1995, did the White Wolves participate in a combat

24 operation in Debelo Brdo, above the cemetery -- the Jewish cemetery in

25 Sarajevo?

Page 22073

1 A. Yes, they did.

2 Q. What was the task given to the White Wolves and who gave them this

3 task?

4 A. First of all, a letter came from the command of the

5 Sarajevo-Romanija Corps, signed by General Milosevic, to the effect that

6 Ratko Mladic had given orders to Srdjan Knezevic to make a breakthrough at

7 Debelo Brdo.

8 Q. And -- yes. Can you continue?

9 A. Yes, I can. Srdjan in those days could not get in touch with

10 Mladic because Mladic was already somewhere around Bihac, I think; anyway,

11 at the other end of Republika Srpska. And there was a major dispute

12 between Srdjan and his deputy, Cvjetko Gacanin, because Srdjan wasn't

13 willing to undertake this operation on Debelo Brdo because it was very

14 heavily fortified. However, as he didn't wish to go against Mladic's

15 order, the decision was taken to carry out that operation after all.

16 Q. Who -- which other unit was involved in that operation?

17 A. Slavko Aleksic's Chetniks, acting from the direction of the Jewish

18 cemetery.

19 Q. Did you meet this person, this Chetnik, and what can you tell us

20 about his activities in the war?

21 A. I did see Slavko Aleksic, because often with Srdjan or some other

22 persons - I can't remember where - we went together to Grbavica. As for

23 any other units, I never heard that anyone hadn't committed any crimes in

24 Sarajevo or anything like that. I only heard this about Slavko Aleksic

25 and his men from Grbavica.

Page 22074

1 Q. Was he constantly in the region of Grbavica, and what was his task

2 there, his general task?

3 A. As far as I know, Slavko Aleksic was in Grbavica from the

4 beginning of the war and he held the line at the Jewish cemetery.

5 Q. We have now displayed on the -- on the Sanction system a picture.

6 Was that picture shown to you in -- it's tab 10 in the binder, but it's

7 actually an exhibit already used, Your Honours. It's Exhibit 451, tab 24.

8 Was this photo shown to you, and did you recognise the person,

9 despite the quality -- the bad quality of the photo?

10 JUDGE KWON: I think it's from the Exhibit 458.

11 MS. UERTZ-RETZLAFF: Oh, thank you, Your Honour.

12 Q. Who is that?

13 A. It's Slavko Aleksic.

14 Q. During the operation at Debelo Brdo, did the White Wolves have

15 heavy losses?

16 A. Yes, they did.

17 Q. Was the -- was Knezevic himself wounded?

18 A. Yes, he was.

19 Q. Were you present when -- did General Mladic appear at some point

20 in time at Debelo Brdo?

21 A. Yes, he did.

22 Q. Can you describe what you saw.

23 A. First of all, I have to refer to the beginning of the story,

24 because as I was saying, Srdjan couldn't contact Mladic, and this

25 operation was under preparation for some seven days, a little more or

Page 22075

1 less. I can't remember exactly. However, when it started, we suffered

2 very great losses within a span of five minutes, and upon

3 withdrawing - now, I can't remember whether we first went to the hospital

4 with Srdjan and came back and then met Mladic or whether this was

5 immediately after we had pulled out - but Mladic appeared suddenly,

6 unexpectedly, and I just happened to be there by chance because I was

7 helping Srdjan because he couldn't walk. And when Mladic appeared,

8 Milosevic was there all the time, coming and going. The first sentence

9 uttered by Mladic was, "Who told you to go to the president without my

10 permission?" And I found this very strange, because up until then I

11 hadn't heard that anyone went to the president, nor that he needed

12 permission.

13 Then he slapped him a couple of times, tore off his rank insignia,

14 and that is all I saw, because Srdjan just made a sign to me, indicating

15 that I should move away, I should get lost.

16 THE REGISTRAR: Can I just make a clarification for the record,

17 please. It's Prosecution's Exhibit 458, tab 24.

18 MS. UERTZ-RETZLAFF: Thank you.

19 Q. To clarify who slapped whom.

20 A. Mladic slapped Milosevic.

21 Q. Did you subsequently find out whether Mladic actually had ordered

22 this attack on Debelo Brdo or not?

23 A. Yes, we all found that out later on from Srdjan. Mladic hadn't

24 ordered that attack, and that was the reason why he slapped Milosevic,

25 because this had been done arbitrarily, or rather, in agreement with

Page 22076

1 Karadzic. Milosevic had used the White Wolves to capture Debelo Brdo,

2 thinking that the operation would succeed, so that Karadzic to say to

3 Mladic that he'd been around Sarajevo for three years and Milosevic had

4 managed to capture Debelo Brdo. So this was an attempt to remove Mladic

5 from the leadership of the Army of Republika Srpska.

6 Q. Did you get this information from Knezevic, or how do you know

7 that?

8 A. Directly from Knezevic.

9 Q. After the activity in Debelo Brdo, did you take part in this major

10 operation in Treskavica, when the Muslim offensive took place?

11 A. Yes, I did.

12 Q. Which Serb troops were involved?

13 A. At the beginning, when the Muslim forces launched the offensive,

14 the only people remaining in Trnovo were the White Wolves. All the others

15 had scattered. And then the Wolves from Drina, Marko Pavlovic, Legenda's

16 [phoen] Wolves arrived to help. And during this first attack, the Wolves

17 suffered considerable losses. And after that, upon Mladic's orders, we

18 were dispatched to Jahorina.

19 Q. When you were in Jahorina, did you see any troops arriving from

20 outside the area? And if so, which troops did you see?

21 A. Yes, I did. I first saw in Kasindol Ljubo Mauzer's Panthers and

22 when we arrived at Jahorina and went to the Bistrica Hotel, on the way to

23 the Hotel Bistrica, in front of the Kosuta Hotel, we first saw vehicles

24 with license plates of the Republic of Srpska Krajina. And after that,

25 people in black uniforms with markings of Arkan's Tigers and others with

Page 22077

1 Skorpije markings and people from the MUP of Srpska Krajina. Some of them

2 were in black uniforms and others in the standard police uniforms.

3 Q. Who was in charge of these troops coming from the Krajina and the

4 Tigers? Could you say?

5 A. Vaso Mijovic.

6 Q. Did you see him at Jahorina?

7 A. Yes, I did. I saw him.

8 Q. And had you seen him before in the Buna camp or in Jezero camp?

9 A. Yes. I saw Vaso Mijovic on one occasion at the camp at Boracka

10 Jezero. But what I was surprised by, because when I saw him at that time

11 he was a driver, and the young man that I spoke to at the Bistrica Hotel

12 on Jahorina, he said that Vaso Mijovic was a colonel.

13 Q. You mentioned the person Mauzer. Do you know what his correct

14 name was and where did he come from?

15 A. As far as I know, his name is Ljubisa Savic. His nickname is

16 Mauzer, and he's from Bijeljina.

17 Q. Did you see any soldiers with scorpion patches as well?

18 A. Yes, I did.

19 Q. Who were they?

20 A. At that point in time, I had no idea, because that was the first

21 time for me to see people with such insignia, and it was the first time I

22 had heard of the name Scorpions. But later on, staying in Vukovar, I

23 learnt that it was a unit from that area whose commander was a certain

24 Boco.

25 Q. I would like to show you now just a few patches. And this -- this

Page 22078

1 is here Exhibit 349, tab 5. What -- what patch is that? Which -- what is

2 written on the patch and which unit wore it?

3 A. It is the special guards, the Panthers. They were Ljubo Mauzer's

4 panthers from Bijeljina.

5 Q. And then Exhibit 349, tab 4. What kind of a patch is that?

6 A. Arkan's Tigers.

7 Q. And now I would like to put to you tab 8 of the witness Exhibit

8 460. It is a note dated the 24th of July, 1995 from the commander of the

9 IKM [phoen] Staff Savo Cvjetinovic. And it refers to the situation at the

10 Trnovo battlefront. First of all, do you know this person Savo

11 Cvjetinovic and what position he had?

12 A. No, I don't know that man. I've never even heard of him in my

13 whole life.

14 Q. At that time you see here 24th of July, 1995. Were you still at

15 the frontline in Treskavica and Trnovo, or had you already left?

16 A. No, I wasn't there.

17 Q. And reference in this document is made to the Scorpions unit of

18 the Serbian MUP. Do you -- were you aware that the Scorpions were a

19 police unit related to the Serbian MUP, or is that not known to you?

20 A. No, that was not known to me.

21 Q. And reference is made here -- there is a sentence saying: "During

22 the day, we will organise part of the company from Trebinje to go to

23 Nevesinje and attend Commander Zirgjevic's funeral, Dragan Zirojevic was

24 deputy commander to the late Nebojisa Sukic." Do you know this person

25 Zirojevic? Who was he?

Page 22079

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

13 English transcripts.

Page 22080

1 A. Yes, I do know Dragan Zirojevic. He's from Nevesinje. He was

2 also one of the first 57 Red Berets. Dragan Zirojevic came together with

3 all of the Red Berets to Mostar. And after the Red Berets, that is, those

4 from Serbia had gone to Serbia, he became the commander or chief of the

5 police station in Nevesinje.

6 Q. And were you aware that he got killed?

7 A. Yes, I heard about it.

8 Q. Do you know whether he was killed in -- on Treskavica or any other

9 combat action?

10 A. Dragan Zirojevic was killed at Treskavica.

11 Q. That should be enough for this.

12 While you were still in the region of Sarajevo and Treskavica, did

13 international forces start bombing Pale?

14 A. Yes, they did.

15 Q. Do you recall the time of the year?

16 A. All I can say is that it was immediately after the operation on

17 Debelo Brdo, because we attended the funeral of White Wolves members when

18 the bombing started.

19 Q. Did you get information in relation to activities of a certain

20 Nikola Ribic?

21 A. Yes. Nikola Ribic, also known as Kanada, was a member of the

22 White Wolves.

23 Q. What did he do in relation to the bombing?

24 A. Nikola Ribic, on his own initiative, without receiving orders from

25 anyone, captured two members of UNPROFOR or observers, whatever they were,

Page 22081

1 took their jeep, and tied them to a mast at Pale -- to a bridge at Pale.

2 Q. Were you present when Knezevic got a -- a call on the Motorola

3 related to that issue?

4 A. Yes, I did.

5 Q. What -- can you explain what you heard and what the circumstances

6 were?

7 A. After Kanada had done what he did, I think that we were at the

8 Sandro coffee bar and he came there. And shortly after him Knezevic

9 arrived. Kanada told him what he had done. And quickly after that a call

10 came over the Motorola and the White Wolf was being looked -- asked for by

11 Vihor. I can't remember whether it was Vihor I or II, but it was Vihor.

12 I am 100 per cent sure of that. And Srdjan was given permission for the

13 operation to continue, that he had done well and that he should continue

14 with it.

15 Q. What were the exact words? Do you recall the words that you heard

16 this Vihor I or II say?

17 A. I can't remember exactly what the words were, but what I can

18 remember is that it was in connection with what Kanada had done, that it

19 was a good thing, and that the operation should be continued.

20 Q. And Vihor I or II, did you know who used that caller ID?

21 A. Yes, I do know. Vihor I or II - I'm not sure which - is the code

22 name for Momcilo Krajisnik, or rather, his office.

23 Q. How do you know that?

24 A. During the preparations for the operation against Debelo Brdo,

25 just by chance - because code names are changed frequently - Srdjan for

Page 22082

1 the crew of recoilless gun used the code name Vihor, upon which a man from

2 the security unit of Radovan Karadzic came to Srdjan to tell him

3 personally that that code name could not be used because it was Momcilo

4 Krajisnik's code name. And we also received information of the same

5 contents from the communications centre at Jahorina, of which the code

6 name is Labud III.

7 Q. And after this conversation on the Motorola that you heard, were

8 more hostages taken and were the White Wolves involved in that?

9 A. I was personally present, close to the hotel - I think its name

10 was Panorama - and a house was there in which the observers or UNPROFOR

11 were put up. And Srdjan was also there. And it was explicitly ordered

12 that all the military equipment should be collected and that personal

13 belongings could not be taken.

14 Q. And I forgot to ask you: You mentioned that you were in a place

15 like Sandro cafe or bar. Where is that? Where is it located?

16 A. The Sandro coffee bar is at Pale, and its owner was a man who

17 worked in a unit of Srdjan Knezevic. He was in the logistics.

18 Q. Did you know how this whole hostage-taking affair ended? Did you

19 get information to that effect?

20 A. As I was saying, I was present when that house was being searched

21 and when the hostages were taken from there, the operation acquired broad

22 proportions, so that at Grbavica Slavko Aleksic's Chetniks had a conflict

23 with the French Foreign Legion, also the military barracks at Lukavica.

24 And towards the end of the day, together with Knezevic and I think a

25 couple of others from the White Wolves, we went to the Lukavica

Page 22083

1 headquarters where Knezevic went to attend a meeting with General

2 Milosevic. Because you can't go inside, I went to the building of the

3 military police to see their commander Cvoro, who told me that Jovica

4 Stanisic and the Red Berets from Serbia were involved in this operation

5 regarding the hostages and their equipment.

6 Q. While you were in the wider Sarajevo region in the years 1994 and

7 1995, did you observe deliveries of weapons coming from Serbia?

8 A. Yes, many times, especially in front of the building of the

9 military police. There were civilian trucks with license plates from

10 Serbia. I personally never got into the truck to see what was inside, but

11 from people who were members of that unit I learnt that there were new

12 rifles or ammunition or whatever it was they were delivering.

13 Q. You say "in front of the building of the military police." Can

14 you be more specific? What kind of a building are you referring to?

15 A. It's the building in which the military police was housed of the

16 Sarajevo-Romanija Corps. Their commander was Captain Cvoro. And they

17 used the military police building and the trucks always entered at night,

18 because at the other gate there were UNPROFOR members or, rather, members

19 of the French Foreign Legion who controlled everything coming in and going

20 out from the barracks.

21 Q. Did you see these kind of trucks also in Pale?

22 A. Yes, many times in front of the police building at Pale, or in the

23 area where the warehouses are, where the timber mill is at Pale. On many

24 occasions, yes.

25 Q. While you were in combat actions, did you happen to notice where

Page 22091

1 THE REGISTRAR: We're in open session.

2 MR. MILOSEVIC: [Interpretation]

3 Q. Very well, Mr. C-017. You spoke here about the events in Mostar

4 and the surrounding parts at that material time, the time you testified

5 about. That's right, isn't it?

6 A. Yes.

7 Q. I assume that the events in Mostar from those times are well known

8 to you; right?

9 A. Generally speaking, yes.

10 Q. All right. Fine. Now, I'm going to ask you a few questions to

11 which you can give me brief answers. You can say whether you know about

12 it or don't know about it. Do you know that at the end of the summer of

13 1991, that is to say, the time you mentioned yourself, this period, in

14 Mostar the Patriotic League, a paramilitary Muslim formation, was formed?

15 Did you hear anything about that? Do you know about that?

16 A. What I can say on the subject is this: I knew that there was a

17 strong stronghold of the SDA. As far as the Patriotic League is

18 concerned, that was the only time -- the only time I saw it or heard about

19 it was on BH television, whether before the war or a little after the war

20 had started in Sarajevo. That's as far as I know about the Patriotic

21 League.

22 Q. All right. Fine. When you say there was a strong stronghold of

23 the SDA in Mostar, what do you mean by that?

24 A. I mean that at that particular time, most of the inhabitants of

25 Mostar were Muslim by ethnicity and that they had a very strong party

Page 22092

1 there.

2 Q. All right. And do you remember some other events? Because at

3 that particular time, as far as I understood it, you were there in the

4 area throughout. Is that right?

5 A. Yes, I was.

6 Q. Well, do you remember the attack launched by the Muslim forces on

7 Djuro Salaj on the Buna on the 1st of April, 1992?

8 A. I can't remember that, because at that particular time I was in

9 Mostar, which means during April. Whether it was the end of March or the

10 beginning of April, I can't quite remember, but I ended up being in prison

11 in Mostar.

12 Q. All right. And do you know that from the motel called the Buna

13 Motel, the Muslim extremists started shooting at a military vehicle? Do

14 you happen to remember that particular event and that the JNA members

15 arrested five reserve policemen? They released them the same day, by the

16 way. But there was shooting at the members of the Yugoslav army in those

17 days.

18 A. As far as I can recall, yes, there were incidents, sporadic

19 gunfire or whatever you like to call them, between the reserve or active

20 composition of the JNA, and these local police forces. Under whose

21 command they were, I really can't say. But as I've already said, I was in

22 a cell.

23 Q. All right. Fine. Now, do you know about the terrorist attack on

24 the JNA barracks called Severni Logor, Northern Camp, at the beginning of

25 April? Did you hear about that?

Page 22093

1 A. Yes, I did. If we're thinking of the same thing, if we're

2 thinking about the truck where some explosive devices were planted.

3 Q. Yes, I am thinking about that cistern truck that caused an

4 explosion and the explosion could be heard far wider than Mostar. That's

5 right, isn't it?

6 A. Yes, it is. That's right.

7 Q. That took place on the 3rd of April?

8 A. Didn't it?

9 A. Well, I really can't say. I'm not very good with dates. I can't

10 remember. It was in April, yes, it was. Now, what the exact day was, I

11 don't know. I can't say.

12 Q. Now, do you remember that 30 civilians were wounded and that one

13 soldier was killed following that incident and that four were seriously

14 wounded and three men less seriously wounded? Do you remember that? I

15 assume you do because it was an event that everybody knew about in Mostar.

16 Mostar isn't a big town.

17 A. As far as the fact that a certain number of people were injured

18 and that considerable material damage was caused to the JNA barracks, I do

19 know that, yes. Because yes, it was a well-known event in Mostar. But

20 once again, as to the figures of who was wounded and killed, I really

21 can't say.

22 Q. All right. Now, how did this event and occurrence impact on the

23 citizens of Mostar?

24 A. Well, there was fear. And what I can tell you, what I know and

25 can say, is that the Serbs began to leave Mostar in masses.

Page 22094

1 Q. Well, how many Serbs lived in Mostar before the war, to the best

2 of your knowledge?

3 A. Well, for me personally, it's a difficult question to answer,

4 because I consider myself to be a Yugoslav, from the Socialist Federal

5 Republic of Yugoslavia, the country I was born in. So I really never

6 asked anybody in my life whether they were a Serb, a Croat, or Muslim.

7 Q. All right. I just asked you. If you don't know, say so.

8 A. No, I don't know.

9 Q. Now, after that attack, the attack that everybody in Mostar knew

10 about, did you hear about attacks by the HOS and Green Berets on military

11 facilities, especially the military airport, airstrip, and these attacks

12 became frequent later on? On the 9th of April, for example, a soldier was

13 killed and several others were wounded and the armed attacks around the

14 JNA became more and more frequent and gained in intensity during those

15 days.

16 A. As I've already said, the events that took place round about,

17 there were rumours going round, but I personally was in prison.

18 Q. And do you happen to remember the event that took place when close

19 to Mostar ten soldiers were captured and three superior officers after the

20 truce that was agreed upon in Sarajevo and related to the entire territory

21 of Bosnia-Herzegovina?

22 A. Which truce are you talking about? Which cease-fire?

23 Q. The 13th of April. You don't know about that?

24 A. No.

25 Q. And do you remember another event, when some pilots were

Page 22095

1 kidnapped, Major Milan Micic and Captain First Class Dragan Arsovski from

2 the airport in Mostar? Do you remember them?

3 A. Partially. It rings a bell. I'm vaguely -- I vaguely remember

4 something like that happening, but I really can't remember the details

5 around the whole event.

6 Q. All right. Did you know what was going on, for example, on the

7 26th of April, what happened then, when these formations, the ones we're

8 discussing, attacked the barracks of the Mostar battalion? Do you know

9 where the Mostar Battalion barracks are located?

10 A. I know where the northern and southern camps are located, but I

11 don't know the names.

12 Q. All right, you don't know names. But do you remember the attack

13 on the barracks on the 26th of April?

14 A. No.

15 Q. All right. Fine. Now, do you remember this: That on the 27th of

16 April this time in Mostar, we saw the arrival of UNPROFOR forces?

17 A. No.

18 Q. And then there was some provocations, and there was artillery fire

19 coming from both sides, precisely when the UNPROFOR forces arrived. And

20 there are facts and figures about that, information about that.

21 A. No, I don't know anything about that.

22 Q. All right, then. Do you know who controlled at the time, apart

23 from the soldiers who were in the barracks there, the JNA soldiers, who

24 was in control of the Mostar region?

25 A. As I've already said, the situation was very murky, because I

Page 22096

1 [redacted]

2 [redacted]

3 [redacted]

4 [redacted]

5 [redacted]

6 Q. All right. Now, is it quite clear that it was for the most part

7 these paramilitary formations, that is to say, the HOS and the Green

8 Berets or, rather, the Muslim forces, and these paramilitary forces as

9 well, that they controlled the town itself - is that clear - and all the

10 main facilities in the town?

11 A. As I've already said, it was a very murky situation, because the

12 northern camp facility, for example, is in the town itself. The southern

13 camp is towards the exit of the town. And the northern camp was across

14 the road from the Zalik settlement, which means in town, and the army was

15 there. As to the Konak barracks, for example, which before the war was

16 linked to the JNA command or something like that - I really can't say -

17 but you could see military personnel moving about there. That remained

18 under the command, for example, of the Serb forces, or rather, the JNA.

19 Now, between the Konak and the northern camp, that part of town, there was

20 a sort of reserve police force, so the formation that I saw and that took

21 me into custody was officially HOS.

22 Q. So you were arrested and taken into custody by the HOS. Do you

23 know what the HOS is?

24 A. Yes, Croatian Defence Forces.

25 Q. Do you know that it is a paramilitary formation?

Page 22097

1 A. I do know that, yes. I do know that it is a paramilitary

2 formation. At that time it was, anyway.

3 Q. I'm asking you this because the HOS was treated as a paramilitary

4 formation even by the Croatian authorities, both in Bosnia and in Croatia

5 too.

6 A. Yes, I do know that.

7 Q. Now, do you know that because it's Paraga [phoen] and his

8 extremists; right?

9 A. There was particular fear in Mostar from HOS because they knew

10 that Blaz Kraljevic was commander of the unit. So when I was in prison

11 myself, the way in which I was exchanged, for example, was precisely

12 because of this, because people learnt about it. So the people who helped

13 me, actually, were Croats. But they came to learn that they would be

14 transported to Dretelj. And anybody ended up in Dretelj never left it in

15 one piece. And if he did leave it in one piece, he was a bit deranged. So

16 the people were there from Blaz Kraljevic's unit, that is to say, people

17 from Western Herzegovina.

18 Q. And do you know that when it comes to HOS, the Croatian

19 authorities themselves ordered that HOS had to be subordinated to the

20 Croatian army or disbanded? If they refused to join the Croatian army and

21 become subordinated to it, in Bosnia-Herzegovina that they had to be

22 subservient to the HVO? So they, too, were absolutely astounded by the

23 atrocities that HOS carried out in the region. Do you remember that?

24 A. As far as all this is concerned, I stressed in my statement and my

25 testimony that I'm a sportsman myself, so I am apolitical, totally

Page 22098

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

13 English transcripts.

Page 22099

1 apolitical. And I was there not of my own free will. So all the events

2 around HOS and the military and paramilitary formations, I really can't

3 say anything about that. The only thing I can say is that yes, there was

4 a great deal of fear. Even Croats were afraid. And the young man -- the

5 guy who helped me had a lot of problems with the HOS after I was

6 transferred to Serb territory.

7 Q. Well, this man Blaz Kraljevic and his escorts precisely on the

8 Cule-Mostar road and Croatian territory, they themselves killed because

9 they couldn't come to terms with them.

10 A. Yes, I did hear about that story.

11 Q. Because of his self-will, lack of discipline, the atrocities he

12 carried out, and all the rest of it, because everybody suffered from this,

13 both the Serb, Croats, and the Muslims, everybody. It was to their

14 disadvantage.

15 JUDGE MAY: Let us deal with the witness's evidence, not your

16 comments on it. He can deal with what he knows himself. He can't give

17 evidence -- he can't deal with political matters or what the Croats did.

18 That's for them, and you can give evidence about it if you want.

19 MR. MILOSEVIC: [Interpretation]

20 Q. Do you remember, as this was the time when you could have known

21 about this - and I told you when UNPROFOR arrived in Mostar - do you

22 remember that on the 3rd of May, in a place between Mostar and Citluk, the

23 representative of the European mission was killed, he was a Belgian,

24 Bertrand Dore [phoen] was his name, and due to that the European mission

25 transferred its offices to Split temporarily because of the security

Page 22100

1 situation there?

2 A. I really don't know about that.

3 Q. You don't remember? All right. Fine.

4 Now, let's move on to the main subject of your testimony. You