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Theunens said crimes were committed by the Serbian fighters in the Kninska Krajina region of Croatia, including the village of Skabrnja, and in the town of Vukovar and other places in the Eastern Slavonia region.

He quoted a report by Serb Territorial Defence forces’ intelligence bodies from autumn 1991, which said that “Arkan and his volunteers were committing genocide uncontrollably in Vukovar”, were spreading “terror”, and were out of control.

According to Yugoslav People’s Army reports which Theunens cited, the fighters associated with the Serbian SDB were also involved in the forcible transfer and deportation of the non-Serb population from Kninska Krajina and the Eastern Slavonia region.

He claimed that those crimes were committed for the sake of “taking control over the territories claimed by Serbs”, which, according to the indictment, was the goal of a joint criminal enterprise whose protagonists included Stanisic and Simatovic, along with Serbian President Slobodan Milosevic and Arkan.

Stanisic, the former chief of the Serbian State Security Service, and his deputy, Simatovic, are accused of participating in a joint criminal enterprise aimed at permanently and forcibly removing Croats and Bosniaks from large parts of Croatia and Bosnia and Herzegovina, which would then be incorporated into a unified Serb state.

According to Theunens, in 1991 the Serbian police and the SDB not only allowed but encouraged the deployment of paramilitary forces and volunteer fighters to battlefields in Croatia.

Via its agents, the Serbian SDB also established camps for the training of special forces troops, such as the one in Golubic, near Knin, where Dragan Vasiljkovic, also known as Captain Dragan, was an instructor.

Theunens quoted a report by Simatovic which said that on April 13, 1991, the SDB chief and Captain Dragan considered the possibility of Vasiljkovic’s engagement in Knin “according to a plan previously presented to him ”.

According to a document signed by the then Serbian Defence Minister Tomislav Simovic, which Theunens also cited, “Captain Dragan was invited to the country by the Serbian SDB” and cooperated with Stanisic and Radmilo Bogdanovic, who was the Serbian interior minister at the time.

Theunens claimed that Simatovic’s order to transfer weapons from the Knin fortress to Golubic in the summer of 1991 was proof that the SDB chief had the authority to exert command in the Kninska Krajina area of Croatia.

Captain Dragan was convicted by a Zagreb court last September of committing war crimes in Croatia, and sentenced to 15 years in prison.

Stanisic and Simatovic both pleaded not guilty in December 2015 after the appeals chamber of the International Criminal Tribunal for the Former Yugoslavia overturned their acquittal in their first trial.

The appeals chamber ruled that there were serious legal and factual errors when Stanisic and Simatovic were initially acquitted of war crimes in 2013, and ordered the case to be retried and all the evidence and witnesses reheard in full by new judges.

Theunens will be cross-examined on Thursday.

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