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www.tenc.net * [Emperor's Clothes]

Slobodan Milosevic Cross-Examines Rade Markovic, Part 2 of 2
Comments by Jared Israel
[Posted 14 September 2002]


I have divided the cross-examination in two parts for quicker downloading. In this second part, despite constraints imposed by the assistant prosecutor, Judge Richard May, Mr. Milosevic pulls off a brilliant stroke. He questions Mr. Markovic about the attempt to coerce and bribe him into lying in order to frame Mr. Milosevic. He asks Markovic if he was tortured, and Markovic says, "Yes." You may if you wish go directly to the section on torture, which is indicated by the sub-head, "* [Note From TENC: Section On Coercion & Torture Begins Here] *" It starts at page 8762 line 7.

For more on the abuse of Mr. Markovic see: "33 Days And Still No Answer: What Was Done To Rade Markovic?" at

-- Jared Israel

[END Comment from Emperor's Clothes]

Part Two Of Cross-Examination Of Rade Markovic

8 Q. Is it logical, when there is a crisis in a particular territory,

9 in the territory of a particular province, precisely because of the

10 concerns over everything that is happening there, to delegate the deputy

11 federal prime minister with some other high officials. The president of

12 the federal parliament was there for a while as well as some higher

13 officials to help the local authorities, and generally speaking, in all

14 these developments, as an expression of the concern of the state for the

15 events involved and also ways and means of resolving that?

16 A. I think that is logical.

17 Q. Didn't we try, from the very top, down to these authorities, to

18 stop this flow of refugees who were leaving, that we tried to explain to

19 them, to convince them, through good arguments, that the army and the

20 police would protect them, that they should stay where they were? You did

21 that, you from the state security, and also people from the public

22 security section. That was an overall political intention. Is that right

23 or is that not right?

24 A. Yes, that was the instruction, and those were the assignments.

25 Q. And do you know that the KLA carried out propaganda, that as many

Page 8749

[At this point there is the following note in the transcript: "Blank pages inserted to ensure pagination corresponds between the French and English transcripts. Pages 8749 to 8758."]

Page 8759

1 civilians as possible should leave Kosovo and thus stage an exodus that

2 was caused by some kind of violent behaviour of the authorities?

3 A. Yes, I'm aware of that.

4 Q. Did it happen to you too, that you intervened in that direction in

5 order to stop the flow of refugees, to make efforts to help them, on the

6 basis of information that you yourself received and insisted, therefore,

7 upon that, that they be helped, in accordance with the policy that we

8 pursued in this connection?

9 A. Yes, I intervened once in Kosovo, here, from Belgrade. When I

10 received this kind of daily information that a large number of refugees

11 appeared who were moving towards the borders with Macedonia and Albania, I

12 called the staff there, General Sreten Lukic, and I asked him for more

13 detailed information. Also I asked him what they would do in order to

14 stop these refugees. He referred me to Sainovic, the head of the staff

15 there, that I should talk to him about it as well. I called Sainovic and

16 I actually abused your name in that conversation. I think you remember

17 that. I said that it is President Milosevic's order that the refugees be

18 stopped.

19 Q. Oh, this abuse I can understand only in - how shall I put it? - in

20 a very relative sense. You knew that that was my position as well. You

21 knew that I wanted the refugees to be stopped. And as far as I can

22 remember that event, when I was asked about that event whether I had

23 issued such an order through you, I said: "Of course I did."

24 A. That's it's way it was.

25 Q. So in your assessment, and according to the experience you had,

Page 8760

1 according to the information you had, were the refugees the result of a

2 war, like any other war, and in all other wars, not some kind of action

3 taken by the army and the police against the civilian population?

4 A. Yes.

5 Q. In all these endeavours, in all these attempts, did we manage to

6 slow down the refugee flows?

7 A. Unfortunately, we did not manage to stop them fully, but we

8 certainly reduced them to a degree. We guaranteed them their safety, we

9 guaranteed them medical security, and we explained to them that they were

10 safest in their own homes.

11 Q. Precisely in connection with that: To the best of your knowledge,

12 is it correct that the members of the police were actually explaining to

13 the Kosovar Albanians that they should not leave their homes, that they

14 should go back, that they are being guarded by the army and the police

15 and, and that when they go there, across the border, that they would be

16 recruited by force, and that they would be subjected to the other types of

17 violence that the KLA had been carrying out against them?

18 A. Yes, that is just the way they talked to them.

19 Q. And do you know that this political body that you refer to had

20 contacts with Albanian representatives, for example, Sainovic, on several

21 occasions, with Rugova, and with other Albanian leaders, that likewise,

22 during cooperation with the Verification Mission, he was head of the

23 commission of the federal government for cooperation with the Verification

24 Mission, that he had an assistant, the retired General Loncar, who was in

25 Pristina all the time, also for the purpose of cooperating with the

Page 8761

1 Verification Mission, that this federal commission for cooperation with

2 the Verification Mission consisted of representatives of all the relevant

3 ministries that were necessary for this kind of cooperation, that is to

4 say, the army, the military, the police, the commissioner for refugees,

5 the ministry for social matters, et cetera? Are you aware of that?

6 A. Yes, I know that Sainovic did contact the representatives of the

7 Verification Mission and for missions in Kosovo, and also that he had

8 contacts with Rugova.

9 Q. I have a few concrete questions. Being the best-informed state

10 official in terms of state security, as head of state security, did you

11 ever hear of a plan called Kolubara?

12 A. I already answered that question to the gentleman of the

13 investigation, that is to say that I never heard of such a plan.

14 Q. And did you ever hear of a plan called horseshoe, Potkovica,

15 because that has also been referred to here. Let me not go into all that

16 now. I don't want the question to be a leading question. Have you heard

17 of a plan called Horseshoe?

18 A. I have already said that I hadn't heard of that either.

* [BEGIN Note from Emperor's Clothes] *

During the illegal bombing of Yugoslavia, NATO officials released a story that the Milosevic government had a plan to use NATO bombing as an excuse to drive all Albanians from Kosovo. Because liars talk too much, NATO had to give their made-up plan a clever name. They said the evil Serbs called it Operation Horseshoe, or 'Potkova.' The idea was, the existence of this plan showed that even while they negotiated, the treacherous Serbs planned to live up to their NATO-supplied label, "The New Hitler." Here's a quote from an article in the new York Times, written, to his shame, by Craig R. Whitney:

[START Excerpt from Times]

Mr. Milosevic's plan to redraw the ethnic map of the province by driving out most of the people of Albanian ancestry who lived there was put in place in October, according to German Defense Ministry officials.

The operation -- code-named "horseshoe," or "potkova" in the Serbian language -- was being planned even as Mr. Milosevic was promising to withdraw the police and military forces that had already begun driving Albanians out of their homes, the German Defense Minister, Rudolf Scharping, said in Bonn this week.

"Our analysis of 'Operation Horseshoe' sadly confirms what we had inferred during the negotiations, which is that Milosevic wanted to win time to prepare a systematic deportation," Mr. Scharping said."

-- New York Times, 11 April 1999, "Crisis In The Balkans: The Overview; Allies Expecting 'Many More Weeks' Of Air Campaign"

[END Excerpt from Times]

Alas, the path of crime is treacherous; likewise, lying. Although the main language spoken in all parts of Yugoslavia is Serbo-Croatian, some words differ in different regions. In Croatia, the word for horseshoe is indeed 'Potkova.' But 'Potkova' would never be used in Serbia, where the correct word is 'Potkovica," pronounced Pot-ko-vitza. The dopes in NATO had probably relied on some Croatian Ustasha (fascist) to provide a title for their propaganda lie, and said Ustasha was likewise pretty dumb. Likewise, Mr. Whitney of the Times.

Birds of a feather flock together?

-- Jared Israel

* [END Note from Emperor's Clothes] *

19 Q. All right. Let me just take a look.

20 In a conversation -- actually, do you remember this conversation

21 that you had with two committees of the federal parliament while you were

22 in prison? During that conversation or interview did you say that the

23 state security was not mine or yours but that it belonged to the state?

24 Is that your position?

25 A. Yes, that is precisely the way I put it, and that is what I assert

Page 8762

1 now as well.

2 Q. So this was not any kind of control over the state security. The

3 state security worked according to their own regulations and according to

4 the law. It could not have been the private affair of you or me or any

5 other individual in the state; is that correct?

6 A. Precisely.

* [Note From TENC: Section On Coercion & Torture Begins Here] *

7 Q. Let me just take a look here at my notes.

8 First of all, I would like to continue along the following lines:

9 I mentioned your interview with two committees of the parliament of

10 Yugoslavia, the assembly of Yugoslavia. Is it correct that you were

11 arrested only so that by exerting pressure against you, they could accuse

12 me?

13 A. Yes. That's why they arrested me.

14 Q. Here, when you talked to two committees of the parliament of

15 Yugoslavia, you say: "They asked me to accuse Slobodan Milosevic and to

16 admit to criminal acts and to say that I was instructed by Slobodan

17 Milosevic thereof."

18 Is that correct?

19 A. That's correct. I was told that in that case I would not be the

20 one who would be held accountable but that I could choose a country where

21 I would live and that I could get a new identity and that it was

22 indispensable to accuse you so that you would be tried in the country.

23 Q. So that I could be tried in the country so that they would not

24 have to sustain the shame of extraditing me to The Hague; is that right?

25 A. I assume that that was the reason.

Page 8763

1 Q. All right. Since you're a career policeman in the details that

2 were referred to here, as soon as you finished your university studies,

3 you started working in the police force and you did so all the way up to

4 your arrest. Is it correct that a detainee in an investigating prison can

5 be only under the jurisdiction of a court and is not under the

6 jurisdiction of the police?

7 A. According to our law on criminal procedure, a detainee is

8 exclusively under the jurisdiction of the court. That is to say, that

9 while an individual is under investigation, he is under the authority of

10 an investigative judge and then after that, within the authority of the

11 president of the chamber of the court.

12 Q. Is it true that even prison guards are not members of the Ministry

13 of the Interior but members of the Ministry of Justice, that is to say, a

14 completely separate authority that is within the judiciary system?

15 A. Prison guards are organisationally linked to the Ministry of

16 Justice.

17 Q. Is it correct that without the approval of the court, you were

18 illegally taken out of members of the state security section so that they

19 would exert this kind of pressure that I've been referring to against

20 you?

21 A. Members of the state security sector did not have a document given

22 to them by the investigating judge to have me taken out. They only had

23 permission to talk to me within the prison.

24 Q. Is it correct that a month after you were brought into custody,

25 they took you out to interview you and that there was an interview that

Page 8764

1 was attended inter alia by the Minister of the Interior, Mihajlovic, and

2 others. As for the official record from the trial, I submitted that here

3 while Witness Karleusa was being questioned, and that is stated in that

4 record as well. Is that right?

5 A. The first time they talked to me after I spent a month in prison.

6 Then, during the following months, they spoke to me several times. I

7 literally handed over my position in the service in prison, because they

8 did not carry out this handover when it was supposed to be carried out. I

9 talked about the sector. I referred to things where I thought I could

10 help them, where I could lead them to the right path, so that we could

11 clarify where the state security was used and where it was instructed to

12 do certain things and when it was not. Because very often the state

13 security service was used and abused. It was mentioned in many places,

14 and it had no authority to act in such areas.

15 After having spent four months in detention, I was taken out, and

16 that's when I had this meeting with the head of state security, Goran

17 Petrovic, and Zoran Mijatovic, his deputy, and the Ministry of the

18 Interior of the Republic of Serbia, Mr. Mihajlovic. They did say that in

19 court, and you have a record of that. They accepted that we did talk

20 outside the prison premises. They claimed that that was at my request.

21 Q. Was it at your request?

22 A. Had it been at my request, then they certainly would have had a

23 proper order from the investigating judge and then they would not have

24 taken me out for dinner.

25 Q. Is it true that they offered on that occasion to you certain

Page 8765

1 protective measures? They told you you would be in prison for six months

2 and would be tried if you don't agree to charge me falsely, to level false

3 allegations against me? Is that true or not?

4 A. They spoke to me about the difficult position I was in. They

5 warned me against the possible consequences and offered me an option in

6 the form of accusing Milosevic, as the person who issued orders for those

7 criminal offences, which would relieve me of liability before a criminal

8 court.

9 Q. Is it true that they offered you a new identity, money, and

10 sustenance for you and your family only so that you would falsely accuse

11 me? Is that correct?

12 A. Yes, that's correct.

13 Q. Do you know that in 1998 -- sorry. 1988, the General Assembly of

14 the United Nations adopted by consensus a declaration against torture, and

15 that such treatment that you were subjected to is explicitly forbidden by

16 this declaration, as well as forcing --

17 MR. NICE: Your Honour -- [Previous translation continues]

18 MR. MILOSEVIC: [Interpretation]

19 Q. -- statements from detainees, extortion and such things?

20 JUDGE MAY: This doesn't appear to have any relevance to the

21 evidence the witness has given here, none at all. He's been agreeing with

22 you, he's been agreeing to the matters you've put to him, and we're not

23 certainly going to litigate here what happened in Yugoslavia when he was

24 arrested. What we're concerned with, as you know, is events in Kosovo.

25 THE ACCUSED: [Interpretation] Mr. May, the conduct of a puppet

Page 8766

1 regime in Belgrade is completely identical to the false indictment --

2 JUDGE MAY: Precisely the sort of point which we're not going to

3 consider. Now, have you got any more relevant questions for this witness?

4 Or we'll move on.

5 Mr. Tapuskovic, have you got any questions of this witness?

6 MR. TAPUSKOVIC: [Interpretation] Yes.

7 THE ACCUSED: [Interpretation] Of course I have more questions. I

8 have many more questions.

9 JUDGE MAY: How long do you think you'll need, Mr. Tapuskovic?

10 MR. TAPUSKOVIC: [Interpretation] Your Honours, I will try to do

11 what I have to do within 15 minutes.

12 JUDGE MAY: Thank you.

13 Yes, Mr. Milosevic. Move on to some other topic.

14 MR. MILOSEVIC: [Interpretation]

15 Q. All right. Is it true that inciting somebody to false testimony

16 and false accusations is a criminal act under our law?

17 JUDGE MAY: That is precisely the point that has been ruled

18 against. Now, you'll have to deal with his evidence. Do you challenge,

19 for instance, the meeting at which it was said you were at and there was

20 talking of the cleaning up of the terrain? If so, you should put that?

21 THE ACCUSED: [Interpretation] Mr. May, I am asking precisely that

22 question: Is it true that this statement that has been presented about

23 the mopping up of the terrain was drafted precisely by the same people and

24 under the sponsorship of those people who exerted pressure on you and who

25 have been torturing you for one year and a half now?

Page 8767

1 A. Yes, it's an interview with the same people.

2 MR. MILOSEVIC: [Interpretation]

3 Q. From --

4 JUDGE MAY: Exhibit 283.

5 MR. MILOSEVIC: [Interpretation]

6 Q. I have noted down your words related to this matter. You said it

7 was a liberal interpretation on their part, that you discussed the mopping

8 up in an informal conversation with Ilic, that what was said was mostly

9 gossip, and that nobody, Ilic or you included, ever talked about removing

10 corpses from Kosovo. So could it be said that this statement is a

11 fabrication by the same people who conducted these interviews?

12 A. Unfortunately, I did not read that statement before I signed it,

13 and it is not really in the format of the statement. It was a

14 conversation, an interview, in which we were looking for a way out of the

15 problems that were facing the Ministry of the Interior. After that, an

16 official, officer of the state security service drafted this paper, and

17 later, when it was presented to me by the Office of the Prosecutor of The

18 Hague Tribunal, I pointed out certain details which did not tally with the

19 truth. And after that, I gave my statement to the investigators of the

20 OTP, which I assert is true and correct.

21 Q. Okay. Let's get one thing clear: At this meeting about which

22 they made this statement, did I ever mention in any way removing traces of

23 crimes?

24 A. No. You approved the mopping up, the clean-up.

25 Q. Is it true that the mopping up or clean-up means a lawful

Page 8768

1 procedure consisting of those elements which you mentioned in chief, that

2 is, removal of mines and explosives, removal of chemicals, removal of dead

3 bodies, taking care of the wounded, repairing infrastructure, service

4 lines, et cetera, that is, creating -- restoring life back to normal after

5 combat operations? Is that correct?

6 A. Yes, that is what the clean-up means, what it implies.

7 Q. Did anyone at that meeting mention that clean-up also involves

8 removal of traces of crimes or any sort of cover-up? Did anyone say that

9 crimes needed to be covered up?

10 A. No, nobody talked about crimes or covering them up.

11 Q. And even later, in the Ministry of the Interior, did anyone speak

12 about the need to transfer some bodies from Kosovo to Serbia proper?

13 A. Not that I heard.

14 Q. Is it well known that the actual situation, the reality, was quite

15 the opposite, as far as covering up is concerned? The position of all of

16 us, starting with me, the minister, Milutinovic, and other politicians,

17 yourself and others, namely, that crimes had to be answered for and that

18 any perpetrator of a crime had to be brought to justice?

19 A. That was also written in the orders that we received.

20 Q. So can we derive the conclusion that if anyone wanted to cover up

21 anything, it was concealment from the local authorities and not The Hague

22 Tribunal, because at that time, in March 1999, nobody gave a thought to

23 The Hague Tribunal?

24 A. Yes, it could be interpreted that way.

25 Q. Very well. During your testimony here, some sort of record of

Page 8769

1 interrogation was presented here, your interrogation before an

2 investigating judge, and Mr. Nice quoted, "Jovica Stanisic showed you a

3 paper which was actually an authorisation from then president of Slobodan

4 Milosevic, according to which the head of the SDB was directly answerable

5 to Slobodan Milosevic I don't know exactly was written in it, but it

6 transpired -- the essence was that the minister was bypassed, the Minister

7 of the Interior, Vlajko Stojilkovic, was bypassed, and instead, Jovica

8 Stanisic was directly accountable to Slobodan Milosevic."

9 That is basically the statement that Mr. Nice quoted here

10 yesterday. And then this decision was also presented to you, and you

11 confirmed it was the decision that indeed had been shown to you. Since

12 this decision contains only one sentence, I will read it out:

13 "In the period of preparations for enacting the federal law on

14 conducting law enforcement in the SFRY, the security sector shall work

15 according to the guidelines of the president and the government of the

16 Republic of Serbia from the day of entry into force of this decision until

17 the day of entry into force of the federal law which will govern security

18 affairs from then on."

19 So I've read this decision entirely. It says at the bottom

20 "Slobodan Milosevic, president of the Republic," and my signature. Can

21 this decision be interpreted or understood as bypassing the law or, as

22 they said here, bypassing the Minister of the Interior, Vlajko

23 Stojilkovic? Can that be the interpretation of this decision?

24 JUDGE MAY: Before you answer, the record should reflect that the

25 accused is referring to Exhibit 277.

Page 8770

1 Yes, Mr. Markovic.

2 A. It is a fact that Jovica Stanisic did not submit reports to the

3 Minister of the Interior, Vlajko Stojilkovic, nor did he or any

4 representative of the state security branch during his tenure attend the

5 senior staff meetings of the ministry while Vlajko Stojilkovic was the

6 minister.

7 MR. MILOSEVIC: [Interpretation]

8 Q. Okay. Let's clear this up. This decision was adopted on the 21st

9 of April, 1997. That's what it says here. But before I ask my second

10 question: Was that the case during all the time while Jovica Stanisic was

11 head of the DB until late autumn 1998, what you just said, that he did not

12 attend?

13 A. No. That was the case only during the time when Vlajko

14 Stojilkovic was appointed Minister of the Interior. Until then, he was a

15 regular attendant of meetings in the office of the minister, Zoran

16 Sokolovic.

17 Q. All right. But beginning with the 21st of April, or around that

18 time, Stojilkovic was appointed before that, was it the case that during

19 all that time he didn't attend these meetings while Vlajko Stojilkovic was

20 the minister?

21 A. I believe he started to attend, and at some point later, when he

22 was enabled in this way to report directly to the government of Serbia, he

23 stopped attending.

24 Q. So that was the case until the end of his term of office?

25 A. Yes, until the end.

Page 8771

1 Q. All right. This was adopted on the 21st of April, 1997. And I

2 ceased to be president of the Republic of Serbia by assuming the functions

3 of the president of the SFRY in the same year, on the 23rd of July. I

4 suppose that these facts are not disputed or disputable. Therefore, in

5 light of this decision - and I assert that it cannot be understood in this

6 way - he was able to report to me from the end of April until the 23rd of

7 July, but not after that date, because this refers to guidelines of the

8 president and the government of the Republic of Serbia, not me personally.

9 The reference is made here to institutions, not an individual?

10 JUDGE MAY: You're making your point.

11 Mr. Markovic, help us with this: Can you see any point in this

12 document? What would you understand the purpose of it to be?

13 THE ACCUSED: [Interpretation] Mr. May, we'll come to the purpose

14 of this document. Let me continue my examination.

15 JUDGE MAY: You've been making speeches. Let the witness answer.

16 THE WITNESS: [Interpretation] I understood that the head of the

17 state security sector at that time, Jovica Stanisic, did not wish to

18 communicate with the Minister of the Interior. The reason was probably

19 that his past experience until then was much richer than the experience of

20 the Minister of the Interior. It was at his personal request - and that's

21 what he told me himself - that he received this document, enabling him to

22 communicate directly with the head of the Republic of Serbia, the

23 president of the Republic, and the government of Serbia.

24 MR. MILOSEVIC: [Interpretation]

25 Q. Let us now go to the essence of this document and the essence of

Page 8772

1 what you testified yesterday, I believe it was during the

2 examination-in-chief. It might have been even the day before yesterday,

3 because there were constant interruptions. The subject was the

4 preparations for enacting the federal law governing security affairs on

5 the territory of Yugoslavia. Is it true that the procedure for enacting a

6 federal law starts with a certain expert body preparing a draft law, or a

7 bill, after which the competent ministry proposes that bill to the

8 government; if it is a federal law, then to the federal government; the

9 federal government first approves the draft, then reviews it, and only

10 then it is reviewed at a session of the federal government, whereupon a

11 proposal is made to refer it to the federal parliament for enactment.

12 Does this describe roughly the procedure for enacting a federal law?

13 A. Yes, that is the procedure for adopting a law.

14 Q. Could you then assume -- let me break this question down again.

15 Do you think that Jovica Stanisic was -- perhaps I should put it this

16 way -- to a great extent, the person who was the greatest expert in

17 national security affairs that we had at that time? Is that right or is

18 that not right?

19 A. Yes, that's right.

20 Q. So do you assume that he headed the team that worked on the

21 professional preparation of that law?

22 A. Yes. That was his idea originally, to adopt this law.

23 Q. Do you know that it was considered, in many developed countries,

24 that these state security affairs should not be carried out within the

25 Ministry of the Interior, but that there are agencies that the state

Page 8773

1 establishes for carrying out such work?

2 A. According to that model, that proposal was made, and I see that

3 such a law has been adopted now.

4 Q. Do you know that at that time, when work was being done on

5 regulating the state affairs in the area of state security, there was a

6 state security service of Serbia, a state security service of Montenegro,

7 there was an administration for intelligence and the General Staff, then

8 also an administration in the General Staff that also dealt with security,

9 and then also in the Ministry of Foreign Affairs, a special service that

10 also dealt in such matters? Are you aware of all of that?

11 A. Yes.

12 Q. So the objective was to create a community of security services,

13 to regulate it by federal law, and in this way to make it possible to do

14 away with mutual rivalries, mistrust, jealousies, et cetera, that usually

15 exist between such communities and they jealously guard the information

16 they have, rarely give it to other agencies, et cetera? Is that correct?

17 A. Yes, that was the objective.

18 Q. And then is it quite clear that Stanisic wished - how should I put

19 this? - to protect himself from lateral influences with regard to the

20 professional preparation of that law, and once he drafts it with his team,

21 it could not have a different fate by what we established a few minutes

22 ago, that it be presented to the government then, that then it be

23 presented as a bill to the federal parliament, and so on? So there was no

24 other question involved.

25 A. I can only assume that that was his wish.

Page 8774

1 Q. All right. But isn't it logical that someone who believes and --

2 MR. NICE: [Previous translation continues] ... amount of --

3 THE INTERPRETER: Microphone for Mr. Nice, please.

4 MR. NICE: There must be a limit to the amount of self-serving

5 benefit that can be got by assumptions and so on through this witness, but

6 it is a matter for the Court.

7 JUDGE MAY: It's a matter for the Trial Chamber to decide what

8 value this evidence has, given largely by the accused.

9 JUDGE MAY: Yes, Mr. Milosevic. There's not much point. This is

10 the point that's being made: Going on to the witness about matters which

11 he really doesn't know about and asking him what his assumptions are.

12 Now, if you want to call or give evidence about these matters from

13 somebody who knows about them, you can, but it's of little benefit to the

14 Trial Chamber. As you know, your time is limited, so you'll want to use

15 it as usefully as you can.

16 THE ACCUSED: [Interpretation] Well, I am using it, Mr. May, but

17 precisely from this paper that was submitted by Mr. Nice, this paper shows

18 what I have been claiming. It shows that the most expert team possible

19 that was preparing a draft law was headed by the greatest expert of all,

20 and it was logical to make it possible for that man that until he prepares

21 this bill for consideration for the government, that he should not be

22 subjected to pressure from any other sides until he actually prepares

23 this. So then it was not up to me or anyone else; it was up to the

24 government and parliament what kind of bill would be presented and what

25 the parliament would ultimately adopt.

Page 8775

1 JUDGE MAY: We hear your argument. It is a matter of argument.

2 The witness can only give evidence about what he knows himself or saw or

3 heard. Now, unless there's anything else you want to ask about this which

4 is relevant, I suggest we move on and don't waste further time on it.

5 THE ACCUSED: [Interpretation] Mr. May, you did not caution the

6 other side that they were wasting time when they were putting questions

7 about licence plates on a truck for ten minutes, and you are cautioning me

8 when you speak about a decision that is quite legitimate and that pertains

9 to the internal regulation of a sovereign state. And you cannot even --

10 JUDGE MAY: Your points are totally false. There was no question

11 of ten minutes on that matter. Anyway, it's irrelevant. If you want to

12 ask, if you've got questions that this witness can deal with, of course

13 this is an important document. If you've got some questions that the

14 witness can deal with in relation to it, why, then, ask him, but asking

15 him about a series of assumptions is not going to assist anybody.

16 THE ACCUSED: [Interpretation] The assumption is -- or rather, the

17 construction that somebody planted to this witness on purpose is that

18 through this document, the Minister of the Interior was bypassed. That's

19 not what it says in this document. And that the law was bypassed. And

20 that's not what this document says either.

21 JUDGE MAY: It will be a matter for the Trial Chamber to decide

22 what construction to give to the document. Now, let's move on.

23 MR. MILOSEVIC: [Interpretation]

24 Q. Please, were there any changes at all in the method of your work

25 and in the work of the state security -- I'm comparing the time when I was

Page 8776

1 president and the time after I stopped being president, that is to say,

2 after the coup of the 5th of October. Did you work the same way before

3 that and after that?

4 A. The public security functioned the same way. I cannot speak about

5 state security because I do not know how it functioned at that time.

6 Q. All right. But I'm referring to the following. For a while you

7 did head state security after the 5th of October too, for a few months. I

8 cannot say exactly how many months. Did you change anything in the method

9 of your work? Did you work differently while I was president and after I

10 stopped being president?

11 A. No. Nothing was changed in the method of work. That is to say

12 that the sector worked for the state, and the state had its duties that

13 are precisely regulated by law and other regulations.

14 Q. Now let us digress in relation to this mystification of

15 resubordination of the forces of the Ministry of the Interior to the army.

16 Actually, in a situation of war, precisely because of the existence of the

17 principle of one command, the police is subordinated to the army. Is that

18 correct or is that not correct?

19 A. That's correct.

20 Q. Is it correct that by proclaiming a state of war, the General

21 Staff of the army of Yugoslavia becomes the staff of the Supreme Command?

22 Is that correct?

23 A. Yes.

24 Q. Is it correct, therefore, that the staff of the Supreme Command

25 and the Supreme Command, in a state of war, includes all armed forces, not

Page 8777

1 only the army? That is to say, the army and the police and everybody else

2 who carries a weapon.

3 A. That's right.

4 Q. I am not going to give you now this instruction of the staff of

5 the Supreme Command, Mr. May, because I need it for other reasons, more

6 important ones, but I should just like to recall that it bears the

7 signature of the head of the staff of the Supreme Command.

8 Lest there be any misunderstanding, the fact that it was signed by

9 the chief of staff of the Supreme Command does not mean that I am not

10 considered to be the authority -- the order giving authority in this

11 respect as well.

12 MR. NICE: I'm not sure if the accused is saying that he's

13 cross-examining on a different document from any that we have and that

14 he's not prepared to disclose, but if that's what he's saying, he should

15 perhaps be corrected, because if he has a document, it ought to be

16 revealed to the Court.

17 JUDGE MAY: Let's see what the point is.

18 Yes, Mr. Milosevic.

19 THE ACCUSED: [Interpretation] This is what I'm trying to say: In

20 the order -- actually, yesterday Mr. Nice presented a document here that

21 refers to General Pavkovic's order in respect of resubordinating the

22 police to certain structures of the army in the field, but I'm just

23 mentioning that General Pavkovic's order is based on the order issued by

24 the staff of the Supreme Command, and in it the command of the 3rd Army,

25 headed by General Pavkovic, are told that forces of the civil defence are

Page 8778

1 being put under the command of the 3rd Army and are being used exclusively

2 on the basis of your decision. So we clarified this a short while ago,

3 that this is a legal --

4 JUDGE MAY: What is the date of this document?

5 THE ACCUSED: [Interpretation] The date of this document is the 9th

6 of April, 1999.

7 JUDGE MAY: You're going to produce it in due course; is that

8 right.

9 THE ACCUSED: [Interpretation] Of course I will. But I need it for

10 cross-examining another witness. According to the list provided by the

11 OTP, or rather, those who aspire to be the Office of the Prosecutor, I

12 will needed this for another witness that I will be cross-examining, and

13 after all, I have that right, not to disclose it now. After all, I have

14 the right not to disclose anything I don't want to disclose, so there.

15 JUDGE MAY: But in order that there's some order in this, you must

16 disclose that before we break from the Kosovo part of the case. Or you

17 can give a copy to the Prosecution. Either way will do.

18 THE ACCUSED: [Interpretation] I am going to tender it before we

19 finish the Kosovo segment of the case, Mr. May. Don't you worry. But

20 before that, I want to discuss certain allegations made by a witness who

21 is supposed to appear here. I hope so, at least, unless the Prosecution

22 does not call him again.

23 MR. MILOSEVIC: [Interpretation]

24 Q. Furthermore, please, let's just look at the question of financing

25 for a moment. You were asked -- or rather, you personally have been asked

Page 8779

1 here by the representatives of this indictment -- this is the way I wrote

2 it down -- whether the state security was financed by the state, from

3 state sources, or in some other way. And then there was an explanation

4 given by you that the budget was approved, et cetera, et cetera, and that

5 the funds that were lacking for that were given from the funds that were

6 collected by way of the Federal Customs Administration. Is it contested

7 that resources that are collected by way of the Federal Customs

8 Administration are also state funds, not funds that are apart from the

9 state?

10 A. These are state funds.

11 Q. Is it contested that every time, for such funds, there was an

12 appropriate relationship between the customs and an appropriate service of

13 the Ministry of the Interior that then used these resources according to a

14 plan that had it explained and elaborated before that? Is that right or

15 is that not right?

16 A. That's what I said.

17 Q. Yes, but, for example, the Prosecution said that there was some

18 kind of mediation in terms of the purchase of helicopters and equipment

19 for helicopters, that there was some kind of mediation on the part of my

20 brother. Did he do this as my brother or because he was required to do so

21 by the service?

22 A. He did that within the context of his own service, and this was

23 required from him by the service.

24 Q. And do you know that already in the early 1970s my brother was

25 counsellor of the embassy in Moscow?

Page 8780

1 A. No. I met him as ambassador.

2 Q. And do you know that later in the 1970s he was minister counsellor

3 in the embassy in Moscow? Just say yes or no. It's not important.

4 A. No.

5 Q. And do you know that towards the end of the 1980s he was

6 ambassador of the former SFRY in Algeria and he also served a term?

7 A. No. I only know about the period when he was ambassador to

8 Russia.

9 Q. And before that period he lived in Moscow, and before that in

10 Paris, et cetera. Was it through me that the service communicated with

11 our ambassador to Moscow, or did the service officially address him? For

12 example, did you communicate with him through me when you had some contact

13 with him, or did you have contacts of your own with him?

14 A. No. The communication was direct, because it was inherited, so to

15 speak. That is the way it worked before me. And Borislav Milosevic was

16 engaged in other matters in addition to being ambassador, before that, and

17 he was a man who knew very well what the possibilities were of obtaining

18 what we needed.

19 Q. Actually, did he help the service to meet their needs in terms of

20 purchasing some equipment?

21 A. Yes, he did help the service.

22 Q. Because of what can be interpreted between the lines, did anyone

23 ever have any information to the effect that he had taken some money for

24 helping the service?

25 A. No. He only enabled contacts based on which the service of the

Page 8781

1 Ministry of the Interior, the relevant service, managed to conduct these

2 transactions.

3 Q. So he used his own reputation, connections, to enable members of

4 your ministry to get this done?

5 A. Yes.

6 Q. And do you have any information to the effect that he himself, or

7 any of his subordinates, collected any money for this service, so to

8 speak?

9 A. No. The state security sector did not conclude any contracts. It

10 was the job of the financial department of the Ministry of the Interior,

11 and I have no such information.

12 Q. You mentioned yesterday Borka Vucic. I don't want to object to

13 this or hold it against you, but the opposite side seems to represent this

14 person as some sort of shadowy figure through which such -- shady figure

15 through which such transactions were conducted. Do you know that she was

16 actually the director of one of the major financial institutions, major

17 banking institutions called Beogradska Bank?

18 A. I spoke of Mrs. Borka Vucic precisely as an expert in the area of

19 finance and banking, and that was the reason why we were directed to

20 conduct our affairs through that bank, because they were experts in that

21 field.

22 Q. Do you know that Mrs. Borka Vucic has been engaged for many

23 decades in this area and that she is well known to the top-notch bankers

24 in the world?

25 A. I have heard a lot about the expertise of Mrs. Borka Vucic. I'm

Page 8782

1 not competent to qualify her or to assess her qualifications, but I know

2 that she is a well-known banker internationally.

3 Q. But do you know that every transaction had to be legally effected

4 through a bank precisely because rules had to be abided by in every

5 respect, rules governing banking, financial affairs, et cetera?

6 A. Since it was the Ministry of the Interior, I'm certain that all

7 transactions had to be effected legally and lawfully.

8 MR. MILOSEVIC: [Interpretation] Let me just look through this.

9 JUDGE MAY: We're going to adjourn now. It's 12.15. It's time

10 for the break. Twenty minutes. Would you be back then, please,

11 Mr. Markovic.

12 MR. NICE: Your Honour, just before we leave, in setting the

13 timetable for the balance of the day, with a witness of this kind, he's

14 already been in cross-examination longer than in chief, there will be a

15 significant number of questions to ask in re-examination. It's not a case

16 where, of course, the cross-examination has been regarded as hostile by

17 the accused. The re-examination may be quite important.

18 JUDGE MAY: How long are you asking for?

19 MR. NICE: At least 15 minutes, but it could be longer.

20 JUDGE MAY: Very well.

21 --- Recess taken at 12.15 p.m.

22 --- Upon commencing at 12.39 p.m.

23 JUDGE MAY: Mr. Milosevic, you can have half an hour more, if you

24 require it.

25 THE ACCUSED: [Interpretation] I was just going to tell you,

Page 8783

1 Mr. May: Since I heard that the amici want to use up 15 minutes and that

2 Mr. Nice too wants 15 minutes, I was going to tell you that I will shorten

3 my cross-examination so that they can have this opportunity in full, and I

4 wanted to say that at the end of the previous session, when you told me I

5 may continue after the break.

6 MR. MILOSEVIC: [Interpretation]

7 Q. I have just a few more questions, mainly related to what the

8 opposite side put forth in this courtroom. Radomir, yesterday, or the day

9 before yesterday - I can't remember exactly - the opposite side quoted

10 some alleged statement of yours to the effect that my wife wanted to

11 influence have over the service, and that is associated with the

12 appointment of Uros Suvakovic on one of the positions in the service.

13 Just a few questions about that.

14 Is it true that Uros Suvakovic was not a member of the Yugoslav

15 left wing, but a member of the socialist party of Serbia?

16 A. Suvakovic was a member of the socialist party of Serbia, yes.

17 Q. Was he appointed by a decision of the Minister of the Interior to

18 his position?

19 A. He was appointed by a decision of the Minister of the Interior,

20 yes.

21 Q. Is it true that in that position to which he was appointed to,

22 Uros Suvakovic did not deal in either intelligence or counter-intelligence

23 affairs, but as a young scientist in the field of sociology, he dealt in

24 general issues of sociopolitical nature, of political and security nature,

25 rather?

Page 8784

1 A. His job had to do with analytical work in the state security

2 branch.

3 Q. Very well. Yesterday, the opposite side produced a document here

4 titled "Order by Lieutenant General Nebojsa Pavkovic," dated 8th May,

5 1999. It is an order concerning resubordination of the MUP to the army of

6 Yugoslavia, and it was adopted almost a month earlier, as I said before.

7 Is it true that the command of the 3rd Army of the VJ -- is it true that

8 this order relies completely on this previous order, since it is dated the

9 8th of May, 1999?

10 A. Yes. I said yesterday that I assume that this order of his is

11 based on the order of the staff of the Supreme Command.

12 Q. And it is implied - and I don't contest it in any way - that an

13 order of the chief of staff of the Supreme Command must have an approval

14 from me.

15 A. That's understood too.

16 Q. Are you aware of any -- I quoted here only a certain number of

17 orders, but are you aware of any order of the staff of the Supreme Command

18 which would be contrary to the laws and customs of war, the Geneva

19 Conventions, and all the legislation governing proper treatment of

20 civilians and proper conduct of the army or the armed forces in general?

21 A. No, I don't know of any such order. I am certain that none

22 existed.

23 Q. Some training centres for volunteers have been mentioned here. Is

24 it true that neither you nor your service could have had no information

25 about the role of the leadership of Serbia or my personal role in the

Page 8785

1 fostering or maintenance of such training centres? Is that true or not?

2 A. I had no such knowledge, and during my tenure as head of the state

3 security sector, there were no such camps.

4 Q. I omitted to ask you something about that notorious mopping up.

5 Is it true that there was an official instruction on mopping up that

6 included all those elements that you enumerated, plus some more elements

7 which were prescribed by the same instruction?

8 A. I don't know about the official instruction, but it was prescribed

9 by the army of Yugoslavia. They issued an order to that effect, and I

10 suppose it was signed by General Lazarevic.

11 Q. When was the first time that you heard about some transport of

12 corpses to Serbia proper?

13 A. I heard about it and I read about it in the papers while I was in

14 prison.

15 Q. So you didn't, and you couldn't have known anything about it while

16 you were heading the state security sector, and if anything of the sort

17 existed, I suppose, you would have had to know?

18 A. I knew absolutely nothing about it.

19 Q. Since you occupied high positions in the police, have you ever

20 heard of any plan designed by me or anyone else in the top echelons of

21 Serbia or Yugoslavia to create a Serbian army outside the territory of

22 Yugoslavia or a Serbian army within the boundaries of Yugoslavia? Have

23 you ever heard of such a plan?

24 A. No, I haven't.

25 Q. References are made here often on the importance of the Ministry

Page 8786

1 of the Defence of Serbia, especially in relation to Croatia. Since you

2 worked in the Ministry of the Interior and you had access to the most

3 confidential documents, did the Ministry of Defence of Serbia ever have a

4 role with regard to Croatia or the war in Croatia?

5 A. I know nothing about that.

6 Q. One more question: Did the KLA -- or rather, is the KLA just a

7 name for a terrorist organisation which assumed that name in order to make

8 the international community treat them as some sort of liberation movement

9 rather than a terrorist organisation?

10 A. Yes.

11 THE ACCUSED: [Interpretation] No further questions, Mr. May.

[Transcript is continued "Cross-Examination, Part 2," at

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* JUDGMENT Video Proves We Were Lied to about Yugoslavia *

In 1992 the world was shocked by pictures of a supposed Bosnian Serb death camp.

The photos were distributed to newspapers and TV by ITN, the British news station. The pictures were a fraud. They had been staged and they had been doctored. This is proved in the movie, 'JUDGMENT!'

The most famous picture showed an emaciated man, naked to the waist. It looked as if he were imprisoned behind a barbed wire fence. As it turns out, the fence was almost all chicken wire and the man was part of a group on the outside, talking to ITN reporters inside an enclosure.

On August 6th, 1992, literally twenty minutes after the doctored photos were shown on TV, George Bush, Sr., held a press conference. [Re: timing, see "The Straits Times
August 16, 1992, "Holocaust images of Bosnia prison camps make the West sit up," by Lee Siew Hua] The unheard-of speed with which Bush held this press conference makes it almost certain the fabrication and release of the doctored photos was an intelligence operation.

With the world horrified by the Holocaust images they believed they had seen, Bush demanded:

"tighten[ing] economic sanctions on Serbia so that all understand that there is a real price to be paid for the Serbian government's continued aggression."

On the same day that the British ITN news people filmed in Bosnia, a crew from Serbian Television (RTS) accompanied them. They filmed right beside the ITN crew, sometimes even mistakenly filming them. Using this almost identical footage, 'JUDGMENT!' shows, step by step, how a humanitarian refugee center (at Trnopolje) and a humanely run detention center (at Omarska) were made to look like cruel concentration camps.

The film includes interviews with Muslims and also with the Serb commander at Omarska, and with Muslim refugees at Trnopolje. The sentiments expressed in these interviews suggest that, absent outside interference, there never would have been a war in Bosnia. ITN never broadcast the interviews.

It is ironic that by slandering the Serbian people and their moderate Muslim allies, British ITN aided the Islamic Fundamentalists who ran the so-called Bosnian government. That "government" was an Islamic Fundamentalist junta. It worked closely with the Islamic Fundamentalist leaders in Iran and with terrorist thugs like Osama bin Laden. Hundreds of terrorists from the Middle East and Afghanistan were brought into Yugoslavia to train the Fundamentalist army which the Western media then lauded as a font of multiethnic tolerance. Amazing.

If after viewing 'JUDGMENT!' you feel we are not telling the truth, we will refund your payment.

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