Tribunal Criminal Tribunal for the Former Yugoslavia

Page 22682

1 Wednesday, 26 November 2003

2 [Open session]

3 --- Upon commencing at 9.06 a.m.

4 [The accused entered court]

5 JUDGE AGIUS: Yes, Madam Registrar, could you call the case,

6 please.

7 THE REGISTRAR: Yes, Your Honour. Good morning, Your Honours.

8 Case Number IT-99-36-T, The Prosecutor versus Radoslav Brdjanin.

9 JUDGE AGIUS: I thank you, ma'am.

10 Mr. Brdjanin, your microphone. Can you hear me in a language that

11 you can understand?

12 THE ACCUSED: [Interpretation] Good morning, Your Honours. Yes, I

13 can.

14 JUDGE AGIUS: I thank you and good morning to you.

15 Appearances, Prosecution.

16 MS. KORNER: Joanna Korner, Ann Sutherland, the lesser of the two

17 nations in this Court, together with Denise Gustin, case manager.

18 JUDGE AGIUS: I thank you, Ms. Korner, and good morning to you.

19 Appearances for Radoslav Brdjanin.

20 MR. CUNNINGHAM: Good morning, Your Honours. David Cunningham

21 with Aleksandar Vujic.

22 JUDGE AGIUS: I thank you, and good morning to you, too.

23 Number one, written version of Rule 98 bis decision, we are giving

24 it a final reading today in the afternoon, and hopefully if everything is

25 plain sailing as it should be, then we will follow with the filing.

Page 22683

1 My understanding, Mr. Cunningham, you've got some information to

2 exchange with the Trial Chamber.

3 MR. CUNNINGHAM: I do, Your Honour. First of all with respect to

4 our trial schedule --

5 JUDGE AGIUS: One moment.

6 Chuqing, could I have these books, these folders put somewhere

7 because they are obstructing. I mean, I don't need to see Mr. Bilo

8 [phoen], for example. He is leaving soon anyway. Thank you, usher.

9 Yes, Mr. Cunningham.

10 MR. CUNNINGHAM: Judge, there's three things I want to bring up,

11 two in open session and one in private session. The first one is with

12 respect to schedule. It is our belief that the Defence case will end no

13 later than the first week of March, my guess is it'll probably end

14 towards the end of the February, which I think is well within the

15 guidelines that the Court has provided us with. Secondly, Ms. Korner

16 asked me today about reports from experts. Obviously we're well aware of

17 our disclosure obligations, and we will endeavour to do our best to get

18 them all the reports before the Christmas holidays, because I know there's

19 nothing better than reading a report on Christmas day.

20 The third thing I'd like to talk about with the Chamber, I'd like

21 to go into private session.

22 JUDGE AGIUS: Yes, let's go into private session, please.

23 [Private session]

24 (redacted)

25 (redacted)

Page 22684












12 Pages 22684 to 22691 redacted, private session














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Page 22693

1 (redacted)

2 (redacted)

3 (redacted)

4 [Open session]

5 JUDGE AGIUS: Tomorrow, we were scheduled to sit in the afternoon,

6 the sitting was shifted to the afternoon in order to accommodate the

7 Blagojevic Trial Chamber. But I'm informed this morning by my secretary

8 that Blagojevic is not sitting tomorrow. The sitting has been cancelled.

9 So if you agree, we could try and shift it to the morning.

10 MS. KORNER: Your Honour, we were very surprised to hear we were

11 in the afternoon. We thought we were in the mornings all week.

12 JUDGE AGIUS: It was actually Blagojevic had a witness that they

13 were trying to -- they had problems with a witness apparently, and they

14 asked me to have today and tomorrow shifted to the afternoon. And so it

15 was a compromise. Today we sit in the morning, and tomorrow we sit in the

16 afternoon. But that has also been shifted now.

17 MS. KORNER: Your Honour, we're perfectly happy with the morning.

18 JUDGE AGIUS: Okay, thank you.

19 MS. KORNER: Your Honour, whilst I remember, can we take then that

20 next week the witnesses are as on the list, in that order.

21 MR. CUNNINGHAM: There is one scheduling problem. I'll get back

22 to you on it this afternoon. I know the first witness is still scheduled

23 to be the same, but one of them is -- the next witness after that is one

24 of the ones who has had some concerns.

25 JUDGE AGIUS: And Madam Chuqing, do we have the schedule for

Page 22694

1 January as yet? Do we have the schedule for January, for January? No.

2 Okay. Try to have the sitting of the 14th of January in the afternoon.

3 Okay.

4 So this next witness today is -- any further business before?

5 Okay. So usher, could you bring the witness in, please. Thank you.

6 There are no protective measures here, no?

7 MR. CUNNINGHAM: No protective measures.

8 JUDGE AGIUS: Is there a need for a caution? I don't think so.

9 MS. KORNER: I would have thought not, Your Honour.

10 [The witness entered court]

11 JUDGE AGIUS: Good morning to you, Madam.

12 THE WITNESS: [Interpretation] Good morning.

13 JUDGE AGIUS: And welcome to this Tribunal.

14 THE WITNESS: [Interpretation] Thank you very much.

15 JUDGE AGIUS: You are about to start giving evidence. And our

16 Rules require that before you do so, you enter -- you make a solemn

17 declaration equivalent to an oath, that in the course of your testimony,

18 you will be speaking the truth, the whole truth, and nothing but the

19 truth. The text of the solemn declaration is being handed to you. Please

20 read it out aloud, and that will be your solemn undertaking with this

21 Tribunal.

22 THE WITNESS: [Interpretation] I solemnly declare that I will speak

23 the truth, the whole truth, and nothing but the truth.

24 JUDGE AGIUS: I thank you. Please sit down.

25 THE WITNESS: [Interpretation] Thank you.

Page 22695

1 JUDGE AGIUS: I'll explain to you very briefly what's going to

2 happen. I want you to feel at ease. You are going -- you have been

3 summoned to give evidence here by Mr. Brdjanin, who is the accused in this

4 trial, as you know. And as a consequence, you're going to be first asked

5 a series of questions by Mr. Cunningham who is representing Mr. Brdjanin

6 here.

7 Mr. Cunningham is the gentleman here in the front row in the

8 middle. He will then be followed by Ms. Korner leading the team for the

9 Prosecution in this case. Ms. Korner will cross-examine you. She'll put

10 to you a set of questions. Now your obligation and your responsibility,

11 according to the Rules and also according to the solemn declaration that

12 you have made a minute ago, is to answer all questions fully and

13 truthfully as possible, irrespective of who is putting the question to

14 you. In other words, you have no right to say "I give preference to the

15 questions being asked by the Defence or by the Prosecution." Your duty is

16 to treat all questions the same and answer them truthfully irrespective of

17 where they are coming from. Did I make myself clear?

18 THE WITNESS: [Interpretation] Yes.

19 JUDGE AGIUS: We hope to finish with you today. I'm sure that

20 there shouldn't be any problems which would make it possible to you to

21 return back to Banja Luka --

22 THE WITNESS: [Interpretation] I certainly hope so.

23 JUDGE AGIUS: -- with your family again.

24 Mr. Cunningham.


Page 22696

1 [Witness answered through interpreter]

2 Examined by Mr. Cunningham:

3 Q. Your name is Drenkja Beric?

4 A. Beric, Drenkja.

5 Q. What municipality were you born in?

6 A. Banja Luka.

7 Q. What municipality do you currently live in?

8 A. Also Banja Luka.

9 Q. Do you work?

10 A. Yes, I do.

11 Q. Who do you work for?

12 A. I'm with the health ministry at the moment.

13 Q. And what sort of work do you do for the health ministry?

14 A. I'm an administrator for protocol and files.

15 Q. Okay. How long have you worked for the Ministry of Health?

16 A. Since the 1st of February 1994.

17 Q. Did you ever work for the Autonomous Region of Krajina?

18 A. Yes.

19 Q. And when was that?

20 A. This was from the 13th of July 1992 until the 13th of September

21 1992.

22 Q. And who did you work for? Who was your boss?

23 A. I was Mr. Brdjanin's secretary.

24 Q. Back in July of 1992, had you been -- who were you working for

25 specifically before July 13th, 1992? Were you working for the

Page 22697

1 municipality of Banja Luka? Tell us.

2 A. I was employed there until the beginning of April 1992. I was

3 with a secretariat as a typist.

4 Q. And how long had you been working for the -- let's put it this

5 way: When did you first start working for the Municipality of Banja Luka?

6 What year?

7 A. 1986, I believe.

8 Q. Did you work continuously for the municipality from 1986 through

9 1992, or were there periods of time when you were not working for them?

10 A. Yes, there were a number of such interruptions.

11 Q. Let's go to July 13th, 1992, when you started working for

12 Mr. Brdjanin. What was your job title?

13 A. Technical secretary.

14 Q. And what did your duties include?

15 A. To answer the phone, to call people whenever Mr. Brdjanin tells me

16 to do so, to type up letters whenever that was necessary. That was about

17 it.

18 Q. Did you and Mr. Brdjanin have an office?

19 A. Yes. Two offices, as a matter of fact.

20 Q. All right. When was -- where were these offices located at?

21 Which building?

22 A. The building was called the solidarity centre, but the offices

23 actually belonged to the Chamber of Commerce.

24 Q. Now, you told us there were two offices. Describe if you can what

25 the offices looked like. First of all, was there a corridor, a hallway,

Page 22698

1 that led to the offices?

2 A. Yes, there was a corridor. And outside the corridor, there was a

3 small hall from which there was a door leading first to my room. And then

4 from my room into Mr. Brdjanin's room.

5 Q. Now, how far was your desk from Mr. Brdjanin's desk in terms of

6 feet or metres? How far away were you?

7 A. Not more than 5 metres apart.

8 Q. From your office, could you hear what was going on in

9 Mr. Brdjanin's office?

10 A. Yes, I could, especially when the temperatures were high,

11 Mr. Brdjanin would keep the door to his office open.

12 Q. Now, you told us that you worked from 13 July to 13 September.

13 Are those the hot months in Banja Luka?

14 A. Yes, they were back then.

15 Q. Were you -- the summer of 1992, July through September, were you

16 able to use any air-conditioning in your office?

17 A. No.

18 Q. And why was that?

19 A. No. There was no electricity.

20 Q. You told us that I did some typing for Mr. Brdjanin. What sort of

21 equipment did you have to type on?

22 A. A mechanical typewriter.

23 Q. Did your job include serving as a receptionist? Meaning if people

24 would come calling on Mr. Brdjanin, to deal with them?

25 A. Well, first people would enter my office, and they would speak to

Page 22699

1 me to see if they would be allowed to see Mr. Brdjanin, to see if he was

2 there to begin with.

3 Q. Typically, in this two-month period that you worked for

4 Mr. Brdjanin, what were your hours of work? What time did you go to work

5 in the morning? What time did you leave at the end of the day?

6 A. I started at 8.00 in the morning and stayed until 1500 hours in

7 the afternoon, but I used to come in early, which was considered normal.

8 And sometimes when I needed to stay late, I would just stay late for as

9 long as it took to finish my work. Sometimes I'd stay half an hour late,

10 but not longer.

11 Q. Okay. And what time would you normally get to the office and

12 start working? 8.00?

13 A. That's when my work began, at 8.00.

14 Q. What time did Mr. Brdjanin typically get to work?

15 A. He would be there at 8.00 punctually.

16 Q. When you would arrive there at 8.00, would there be anyone waiting

17 in the hallway outside the office?

18 A. Yes, yes. There were people there almost every morning who came

19 to see him.

20 Q. Okay. And typically, how many people would be there each morning

21 waiting to see Mr. Brdjanin?

22 A. At least 20 people. Sometimes more.

23 Q. Okay. And did you know as the people were lined up what their

24 ethnicity was? Did you ask them or look at IDs or anything like that?

25 A. No. I never knew who exactly was waiting in front of the door.

Page 22700

1 In terms of their ethnicity, we didn't keep any lists. We didn't ID

2 people, nor do we call those people over; they just came of their own

3 accord.

4 Q. Do you know whether there would -- on a typical day there would be

5 non-Serbs in line seeking help from Mr. Brdjanin in July and September of

6 1992?

7 A. As I said, there would be people waiting belonging to all

8 different ethnic groups, but there were no lists kept so we don't know

9 their names. It was only after they told us their names that I could

10 conclude whether they were a Croat or a Muslim.

11 Q. Based on what you just told me, could you conclude back in July to

12 September 1992 whether there were Muslims or Croats waiting to see

13 Mr. Brdjanin when he came to work in the morning?

14 A. Yes.

15 Q. And were there?

16 JUDGE AGIUS: That's how I took her answer.

17 MR. CUNNINGHAM: I took it as such, too, but I wanted to be

18 careful, Your Honour.

19 Q. Let's talk about typically what would happen with these line of

20 people waiting outside the door? What would Mr. Brdjanin do with these

21 people? Would he see them? Would he tell them to leave? What would

22 happen?

23 A. Mr. Brdjanin would see every single person. He would receive them

24 in his office. They would raise their problems, and then he would take

25 them back to my office to write up a brief report concerning their request

Page 22701

1 or whatever assistance it was that they had requested.

2 Q. Okay. Let's break that down step by step. Would the people go

3 into Mr. Brdjanin's office?

4 A. Yes.

5 Q. And what sorts of things -- were they asking him for help?

6 A. Yes.

7 Q. What sort of things were they asking for help about? What were

8 the subject matters?

9 A. Most people had similar problems regardless of whether they were

10 Muslims, Serbs, or Croats. Normally they would ask for help when they

11 were looking for a job. Housing matters were sometimes a problem. And

12 food also was one of the typical problems.

13 Q. And when the people went into the back office with Mr. Brdjanin

14 and talked with him about these subjects, what would he try to do to the

15 people -- with the people in his office?

16 A. First he'd listen to them. Then he would go to my office. I

17 would have help him type up a report or a letter. The header would

18 usually say: "The Executive Board of the Autonomous Region of Krajina"

19 followed by the name of the company that the letter was being sent to.

20 The title would be "request" and then followed by a very brief text, a

21 very brief letter saying: "would you please see such and such person for

22 an interview and give them if you can a job. We would very much

23 appreciate that." Then this letter would be signed and that was that.

24 Q. And then I take it it would be given to the people or person in

25 his office. Correct?

Page 22702

1 A. Yes, that's correct.

2 Q. And because you were his typist, his secretary, if you will, did

3 you see him sign his name on few or many occasions?

4 A. Yes, yes, he signed these in front of me.

5 Q. Okay. And because he signed those documents in front of you, are

6 you acquainted with his signature?

7 A. Indeed I was.

8 Q. And we'll get back to that in a minute, but I want to go back to

9 these requests that Mr. Brdjanin had you type out for him. Could you tell

10 by the name that you were typing on the request whether they were a Croat

11 or a Muslim?

12 A. We had to give a name. We had to tell the manager of the

13 prospective company who they were seeing.

14 Q. But could you tell by typing the name what ethnicity they were?

15 Whether they were Croat or a Bosniak, a Muslim?

16 A. Yes, by looking at the first and last names I would normally make

17 an assumption as to the ethnicity of the person.

18 Q. Okay. And listening to Mr. Brdjanin's conversations with the

19 people in his office, considering the documents that you typed on his

20 behalf, was there any difference in the way that Mr. Brdjanin treated

21 Serbs and non-Serbs in that two-month period in 1992?

22 A. Everybody got the same treatment. He wanted to help everyone in

23 some way, in whichever way he could.

24 Q. In the time that you worked with Mr. Brdjanin, did you notice

25 anything that was improper or incorrect about the way that he dealt first

Page 22703












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Page 22704

1 with the Croat population in Banja Luka who came to see him in his office?

2 A. No, no improprieties whatsoever, not as far as Mr. Brdjanin was

3 concerned, the way he treated the people coming to see him.

4 Q. In the time that you worked with Mr. Brdjanin did you notice

5 anything that was improper or incorrect in the way he dealt with the

6 Muslim population of Banja Luka who came to see him in his office?

7 A. No, never. He never treated anyone unfairly.

8 Q. In the conversations that you had with Mr. Brdjanin, in private

9 conversations, did he ever indicate to you any animosity towards the

10 non-Serb population?

11 A. No, never.

12 Q. Okay. You told us that Mr. Brdjanin helped the citizens who came

13 to his office deal with those issues. Did you -- the issues of housing,

14 food, and employment, during this time period, did you ever -- were you

15 having problems with your housing, your accommodation?

16 A. Yes.

17 Q. And very briefly, what sort of problems were you having with your

18 accommodations?

19 A. I had no accommodation. I don't have any accommodation even as we

20 speak.

21 Q. Did you ask your boss, Mr. Brdjanin, for any assistance in helping

22 you get accommodations in July, August, and September 1992?

23 A. Yes, I spoke to him twice, maybe more times. I'm not sure. I

24 asked him to help me.

25 Q. You told us how he would, with your assistance, type letters for

Page 22705

1 Serbs and non-Serbs alike requesting assistance. Did he do anything like

2 that for you?

3 A. No, not for me. He said he was sure that nothing would come of it

4 and that he would not be able to help me.

5 Q. Now, were there other members of the -- were there members of the

6 executive council that were in the same building as you, the ARK executive

7 council? Were they in the same building as you?

8 A. Yes. There were, I believe, three other officers there.

9 Q. Now, were the people -- and do you remember who were in those

10 three offices, which individuals?

11 A. The president of the executive board, Mr. Erceg. His secretary.

12 Mr. Zlatko Kelecevic, I believe he was there, too.

13 Q. Mr. Erceg and Mr. Kelecevic, were they seeing people like

14 Mr. Brdjanin was?

15 A. No.

16 Q. Was there anyone that was trying to help the citizens like

17 Mr. Brdjanin was in the offices in the building that you were in?

18 A. The people that would come to see us would come to see us because

19 of their problems, the problems they had. And the only person they spoke

20 to was Mr. Brdjanin.

21 Q. How much of the day would be taken up by speaking to these people

22 that were waiting outside his door when he came up?

23 A. Almost the whole time he was there at work.

24 Q. Do you ever remember him turning anyone away because of their

25 ethnicity?

Page 22706

1 A. No. We wanted to give a hand to whoever we could, hoping that

2 there wouldn't be that many people the next day. But you had the same

3 situation every day.

4 Q. Would he ever have meetings after the typical work day with people

5 who were still in line or showed up late?

6 A. Yes. If we were still in the office and it was past our working

7 hours, we would just stay to hear them out.

8 Q. We've talked about your personal dealings, face-to-face dealings

9 with the people who came to see Mr. Brdjanin. In your job as secretary,

10 did you also answer the phone for him?

11 JUDGE AGIUS: I think she answered that question already.


13 Q. When you would answer the phone for Mr. Brdjanin, would you refer

14 phone calls to him?

15 A. Yes.

16 Q. And when you would refer phone calls to him, would you tell him

17 the caller's name?

18 A. Yes, I would. Well, whenever the caller actually said their name.

19 Q. Okay. And during the July, August, and September period that you

20 worked for him, did he get phone calls from people who you could tell were

21 non-Serbs based on their names?

22 A. Yes. Yes. They called.

23 Q. And how did he treat, for example, the people that you could

24 identify as Croats when they called? Did he -- first of all, did he take

25 their calls?

Page 22707

1 A. He did.

2 Q. And what was his -- generally speaking, how did he treat these

3 people that you've identified as Croats when they would call?

4 A. The same as whenever I told him that there was a Serb on the line

5 waiting to speak to him.

6 Q. What happens if you would get a phone call from a caller that by

7 name you could identify as a Bosniak, a Muslim? How would he treat that

8 caller?

9 A. The usual way.

10 Q. Was there any difference in the way that he treated phone callers

11 based on their ethnicity? Did he treat Serbs, Muslims, and Croats the

12 same?

13 A. Yes.

14 Q. In the time -- the three-month period that you worked for him, did

15 you ever get phone calls from non-Serbs who called to extend thank-yous or

16 gratitude to Mr. Brdjanin for helping them? Did that ever happen?

17 A. Yes, this did happen, but there weren't too many calls of that

18 nature.

19 Q. Okay. We've talked about the phone calls that came from citizens.

20 I want to talk about whether or not -- I'd like to have you talk about

21 whether or not he got phone calls from any other individuals that you

22 recognised as being involved in government. For example, did

23 Vojo Kupresanin call?

24 A. Several times.

25 Q. And what's your definition of "several times"? How many times

Page 22708

1 would that be over this three-month period?

2 A. Perhaps twice, perhaps three times.

3 Q. What about Predrag Radic? Would he call?

4 A. Never.

5 Q. Did your office ever call Mr. Radic's office?

6 A. Yes, perhaps about three times. The reason was to ask Mr. Radic

7 to tell some of his own people to see these people who were coming to us

8 to speak about their problems because we were no longer able to see

9 everyone who came.

10 Q. Okay.

11 JUDGE AGIUS: One moment, Mr. Cunningham. I think we better clear

12 this up now.

13 Did Mr. Brdjanin have one line, telephone line? And if that is

14 the case, did he have to pass through you each time he needed to make a

15 call? Or did he have a direct access to that line? That's question

16 number one.

17 Question number two, apart from the line that you were using, did

18 he also have a separate direct line, another additional line?

19 THE WITNESS: [Interpretation] I understand your question,

20 Your Honour. The first question was if we had only one line. That's

21 correct, we only had one phone that we used. I would usually answer this

22 phone, and then I would pass messages on to Mr. Brdjanin.

23 He did not have any other phone.

24 JUDGE AGIUS: Okay. Thank you.

25 MR. CUNNINGHAM: Thank you, Your Honour.

Page 22709

1 Q. What about Nikola -- Mr. Erceg? Would he call?

2 A. We were on the same floor, so there was no need for him to

3 telephone us.

4 Q. Would Mr. Brdjanin and Mr. Erceg meet? And if so, how often

5 during this three-month period?

6 A. We didn't have that much time. We didn't have enough time to see

7 or speak to anyone apart from the people who were coming to see us.

8 Q. Okay. During the time that you worked for Mr. Brdjanin, did

9 General Talic ever call your office?

10 A. No, never.

11 Q. Did he ever come visit in the office with Mr. Brdjanin?

12 A. Mr. Talic, no. Never. No military ever came to see us or called

13 us on the phone, for that matter.

14 Q. What about Stojan Zupljanin? Did he ever call, first of all?

15 A. No.

16 Q. Did he ever come by?

17 A. No.

18 Q. Would there ever be any reason for your office to call him or his

19 office?

20 A. I believe there was this one time we needed a car for Mr. Brdjanin

21 to use to travel to a session of the National Assembly.

22 Q. What did that phone call involve?

23 A. The only thing we talked about was about having a car secured for

24 Mr. Brdjanin to travel because we had no official car to use on such

25 occasions.

Page 22710

1 Q. When we met yesterday, I asked you if you remembered the name

2 Nenad Stevandic. First of all, do you remember --

3 A. No.

4 Q. Do you ever remember -- and obviously, I know the answer to this.

5 But do you recall Mr. Stevandic ever calling or coming by the office?

6 A. No, never.

7 Q. You told us earlier that in the three-month period that you worked

8 with Mr. Brdjanin that you had the opportunity to see his signature on

9 many occasions. What I'm going to do is with the usher's assistance --

10 A. Yes.

11 Q. -- I'm going to show you a number of documents.

12 MR. CUNNINGHAM: Your Honour, with your permission, I'm going to

13 adopt the procedure you recommended the last time. I'm going to give her

14 a group of documents and have her go through them. My records indicate

15 that I'm showing Prosecution Exhibits 46, 175, 176, 179, 183, 182, 185,

16 187, 184, 192, 191, and I don't believe I've showed her that document

17 previously, so Mr. Usher, if you could keep that one separate. 198, 194,

18 200, 199, 210, 232 and 238, 295, 239, 241, 242, 243, 254, 255, 260, 265,

19 273, and P1725.

20 Q. And ma'am, what I would like for you to do is look through those

21 documents. I want you to look at the signatures. I want you to take as

22 much time as you can because after you've looked at them and are satisfied

23 with the documents, I want to ask you some questions.

24 A. I apologise for having kept you waiting. I have gone through

25 these carefully. I can see a number of signatures, and it says they're

Page 22711

1 "for" which means that it wasn't Mr. Brdjanin who signed them. Then

2 there are two documents only bearing a stamp with no signature. And there

3 are some signatures here that I really cannot say who really signed them.

4 I cannot see Mr. Brdjanin's signature here because when I typed

5 Mr. Brdjanin's letters for him, I had to leave a lot of space for him to

6 sign because his signature was quite a long one.

7 Q. So you do not recognise his signature among any of those documents

8 that have been placed in front of you?

9 A. No. There are a number of signatures saying "for."

10 Q. I am done with those exhibits.

11 MR. CUNNINGHAM: Thank you, Mr. Usher.

12 MS. KORNER: Sorry, Your Honour, because I don't want to go

13 through the same exercise. It's not altogether clear: Is the witness

14 saying that the ones which are not signed "za" or "for" Mr. Brdjanin, but

15 appear to be signed by him, in other words, there a signature,"R.

16 Brdjanin," are not in fact signed by Mr. Brdjanin. Is that the evidence?

17 JUDGE AGIUS: It's an important question.

18 MS. KORNER: I don't want to have to give her back the whole lot.

19 That's the only reason I'm asking it.

20 MR. CUNNINGHAM: Let me go ahead and ask it this way.

21 Q. There are a number of signatures -- just hold on.

22 [Trial Chamber confers]

23 MS. KORNER: Your Honour, perhaps she can identify the numbers as

24 well.

25 JUDGE AGIUS: Yes, I'm trying to -- yes, can I ask you to look at

Page 22712

1 two documents in particular. For example, P255, P255, that document, for

2 example, does not purport to be one --

3 THE WITNESS: [Interpretation] This isn't Mr. Brdjanin's signature.

4 JUDGE AGIUS: And if you look at P46, it's the first one. It's

5 also not a "za" signature.

6 THE WITNESS: [Interpretation] It isn't.

7 JUDGE AGIUS: It isn't, okay. I don't have a question.

8 Obviously, this is a delicate issue, I'm not going to -- I just pointed

9 out two documents where at least on the face of the document it doesn't

10 say "Za."

11 MR. CUNNINGHAM: I apologise for interrupting, Your Honour. Let

12 me go ahead and go through the rest of them, just to make them clear.

13 JUDGE AGIUS: It's up to you, Mr. Cunningham. I'm not going to

14 involve myself in this.


16 Q. Ms. Beric, what I'd like you to do is to get all those documents

17 that have someone's signature and that say "za," and put those in one

18 stack.

19 Okay, you've got a stack with all the zas in it. Then make a

20 stack with all those documents that have a signature but it doesn't say

21 "za." Okay? Keep that stack separate. And that should leave some

22 documents that don't have any signature. Am I right?

23 Let's do this. Go ahead and put the documents that do not have

24 any signature --

25 JUDGE AGIUS: Usher, I think we need your help here to identify,

Page 22713

1 make sure that we are identifying the documents. Can we put them one by

2 one on the ELMO so that even for the record we will have the exhibit

3 number?

4 MS. KORNER: Your Honour, yes, I think it would be helpful if

5 Mr. -- once they're on the ELMO, Mr. Cunningham can read out the numbers.


7 MS. KORNER: And what are we starting with?

8 MR. CUNNINGHAM: We are starting with documents that don't have

9 any signatures because that's the shortest stack. And I can't --

10 JUDGE AGIUS: Exhibit P199.

11 MR. CUNNINGHAM: Mr. Usher, could you put the next one up, please.

12 Exhibit P194.

13 JUDGE AGIUS: Let's take them one by one, Mr. Cunningham. If

14 you're going to ask a direct question relative to each and every one of

15 these exhibits, then we take them one by one. If you're going to ask one

16 collective question, then you can pool them together. We just see them on

17 the ELMO for the record. It's up to you.

18 MR. CUNNINGHAM: Your Honour, what I'd hoped to do to speed this

19 process along is obviously the ones that do not bear any signature, just

20 to read those exhibit numbers into the record.

21 JUDGE AGIUS: Right. Okay. The next one.


23 Q. Is that the last exhibit without, the last document --



Page 22714












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

13 English transcripts.













Page 22715

1 Q. Let's go ahead and start with the documents that have someone's

2 signature on them. Then what I'd like for you to do with the helper of

3 the usher is put them on the ELMO one by one.

4 MS. KORNER:, I'm sorry, this is not the "za" ones, this is a

5 signature without "za," Mr. Cunningham. Is that right?

6 MR. CUNNINGHAM: That's right. I'm saving the "za" for last.

7 Okay, I don't see an exhibit number on this.

8 JUDGE AGIUS: It's P232.


10 Q. On P232, Ms. Beric, there's no signature?

11 JUDGE AGIUS: No, there is a stamp, but no signature.

12 MR. CUNNINGHAM: Okay, the next exhibit, please, Mr. Usher. And

13 I'll identify the document as soon as I see the English copy. That

14 appears P1 --

15 JUDGE AGIUS: 194.1.


17 Q. Is that Mr. Brdjanin's signature on that document, Ms. Beric?

18 A. No.

19 Q. Let's have the next document, please, Mr. Usher. This is Exhibit

20 P191.

21 JUDGE AGIUS: Turn the page, please.


23 Q. And do you recognise that signature as being Mr. Brdjanin's?

24 A. It isn't Mr. Brdjanin's signature.

25 Q. Okay. Next exhibit, please.

Page 22716

1 JUDGE AGIUS: We haven't identified this document as yet.


3 Q. And I'll identify it in just a minute. Is that Mr. Brdjanin's

4 signature?

5 A. No.

6 MR. CUNNINGHAM: Can I see the exhibit number again, Mr. Usher.

7 JUDGE AGIUS: It's at the bottom of the page presumably. No?

8 MR. CUNNINGHAM: I need the English version just so we can get it

9 identified for the record.

10 JUDGE AGIUS: This is P198.


12 JUDGE AGIUS: Let's move. It's P198.

13 MR. CUNNINGHAM: Okay. The next exhibit, please, sir. That's

14 P254.

15 Q. And do you recognise that signature at the bottom of the page?

16 A. No.

17 Q. Next exhibit, please. P255. And I'll ask you the same question.

18 Do you recognise the signature?

19 A. No.

20 Q. Thank you.

21 JUDGE AGIUS: Do you recognise the signature is one thing.

22 Assuring us that it isn't Mr. Brdjanin's is another.

23 MR. CUNNINGHAM: You're absolutely correct.

24 Q. Did you recognise that signature, not this one but the one you

25 looked at before as Mr. Brdjanin's signature?

Page 22717

1 A. It is not Mr. Brdjanin's signature.

2 Q. The next exhibit we're looking at, I haven't seen the English

3 exhibit number. It appears to be 255. Do you recognise the signature as

4 being Mr. Brdjanin's?

5 A. No.

6 Q. Next exhibit, please. This is Exhibit 46. And do you recognise

7 that signature as being Mr. Brdjanin's?

8 A. No.

9 Q. Next exhibit, please.

10 A. These are documents with a "za," for.

11 Q. Let's go through the "za" documents one by one. And here's what

12 I'm looking for, Ms. Beric: Even though it says the word "za," I want you

13 to look closely at the signature to make sure you can tell us whether or

14 not it is Mr. Brdjanin's signature. The first exhibit is P176, these are

15 the "za" documents. Is that Mr. Brdjanin's signature?

16 MS. KORNER: Your Honour, if it says "za," I doubt very much, and

17 I don't think it matters when it says on behalf of.

18 MR. CUNNINGHAM: I just wanted to make sure.

19 JUDGE AGIUS: I will allow the question because it can be

20 relevant.

21 Is this your signature?

22 THE WITNESS: [Interpretation] No.


24 Q. And you've already told us --

25 A. I was not authorised to sign anything. I didn't have the

Page 22718

1 authorisation for it.

2 Q. Okay. Next exhibit, please, Mr. Usher. Sorry, I don't see an

3 exhibit number.

4 Do you recognise that document, do you recognise the signature as

5 being Mr. Brdjanin's?

6 A. This is not Mr. Brdjanin's signature.

7 Q. I would like to identify it for the record. I just don't have an

8 English copy available.

9 JUDGE AGIUS: It's 490, Mr. Cunningham.

10 MR. CUNNINGHAM: As usual, Your Honour, I appreciate your

11 assistance.

12 Q. If we can look at the next exhibit.

13 JUDGE AGIUS: One moment, because I have 490, but I also have

14 apparently 490 is also 158. If you could check that. Or it could

15 be -- no, 7.158. So it's document Exhibit P490. But okay, 7.158 is

16 another reference number.


18 Q. The next exhibit in front of you going to be P175. And I'm going

19 to ask you whether you can identify that signature as Mr. Brdjanin's. Is

20 that his?

21 A. No.

22 Q. Thank you.

23 MR. CUNNINGHAM: Next document, please.

24 Q. This is Exhibit P182. Same question, do you recognise that

25 signature on that document as being Mr. Brdjanin's?

Page 22719

1 A. No.

2 Q. Okay. This looks like a document dated 9 May 1992. This is a

3 document dealing with the war staff, the press centre. I apologise. And

4 I believe this is Exhibit P183. Do you recognise that signature as being

5 Mr. Brdjanin's?

6 A. This isn't Mr. Brdjanin's signature.

7 Q. Thank you. Next exhibit, please. Do you recognise the signature

8 on the back of that document as being Mr. Brdjanin's? Or at the bottom of

9 that document I should say.

10 A. It isn't Mr. Brdjanin's signature.

11 MR. CUNNINGHAM: Judge, I'm unclear as to the exhibit number on

12 this. I know it's 11 May.

13 JUDGE AGIUS: I'm not quite sure that I can help you there.

14 Because the list that you made use of today does not correspond completely

15 or totally with the list that was handed to us. So there are several

16 exhibits that you referred the witness to which I don't have.

17 P184, it says.

18 MR. CUNNINGHAM: Okay. P184. Go to the next exhibit. And thank

19 you, Mr. Usher, for your assistance.

20 JUDGE AGIUS: This was amongst the documents in any case.


22 Q. Do you recognise that signature? And we'll identify the document

23 once the English version comes up. Is that Mr. Brdjanin's signature on

24 that document?

25 A. No.

Page 22720

1 JUDGE AGIUS: Again, I think we need to identify this document

2 now.

3 MR. CUNNINGHAM: I do, Your Honour.



6 Q. Do you recognise that signature on that document as being

7 Mr. Brdjanin's?

8 A. No.

9 JUDGE AGIUS: This is for the record P185.

10 MR. CUNNINGHAM: Thank you, Your Honour.

11 Q. The next exhibit is going to be P187, same question. Do you

12 recognise that document -- recognise the signature at the bottom of that

13 document as being that of Mr. Brdjanin?

14 A. No.

15 Q. Next document is P260. And I'll ask you the same question. Do

16 you recognise the signature there at the bottom of that document as being

17 that of Mr. Brdjanin's?

18 A. No.

19 Q. That document that was just in front of you was P265. Do you

20 recognise that signature as being Mr. Brdjanin's?

21 A. No.

22 Q. Next is Exhibit P200. Same question, is that Mr. Brdjanin's

23 signature at the bottom?

24 A. No.

25 Q. This is Exhibit P238. Same question: Do you recognise the

Page 22721

1 signature there as being Mr. Brdjanin's?

2 A. No.

3 Q. I don't know if you can see the signature on the document in front

4 of you. Is that Mr. Brdjanin's?

5 A. No, it isn't.

6 Q. That looks like it's dated -- that's Exhibit P241.

7 Now, Exhibit P239. Do you recognise the signature there as being

8 Mr. Brdjanin's?

9 A. No.

10 Q. This is a document dated June 12th. Do you recognise that

11 signature as being Mr. Brdjanin's?

12 A. No.

13 MR. CUNNINGHAM: If we can get the exhibit number. It's either

14 going to be 242 or 243.

15 JUDGE AGIUS: It's 242.




19 Q. This is Exhibit 243. The question is: Is that Mr. Brdjanin's

20 signature?

21 A. No.

22 Q. This looks like a document 17 June 1992. It should be -- do you

23 recognise that signature as Mr. Brdjanin's?

24 A. It isn't Mr. Brdjanin's signature.

25 Q. And this should be, I believe, Exhibit P1725.

Page 22722

1 JUDGE AGIUS: Yes, it is, Mr. Ackerman.

2 MR. CUNNINGHAM: He's a lot older.

3 JUDGE AGIUS: Mr. Cunningham, yeah. It is P1725.

4 MR. CUNNINGHAM: Is that it? Thank you, Mr. Usher. I appreciate

5 all your help.

6 I've got one more area, Judge, but it looks like --

7 JUDGE AGIUS: We have to break now, then.

8 We are going to have a short break of 25 minutes. That would give

9 you enough time to have a rest and a coffee. We will resume in 25 minutes

10 from now. Thank you.

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

12 --- On resuming at 10.59 a.m.

13 JUDGE AGIUS: Yes, Mr. Brdjanin is here. The witness is ready.

14 Mr. Cunningham, you may proceed.

15 MR. CUNNINGHAM: Thank you, Your Honour.

16 Q. In the two months that you worked for Mr. Brdjanin, did you know

17 his title?

18 A. You mean his duties at work, or do you mean his education?

19 Q. No, no, his duties at work. Did you work for him as president of

20 the ARK Crisis Staff or in another capacity?

21 A. No, I worked for him while he was the vice-president of the

22 Executive Board.

23 Q. Did he have any job obligations with respect to traffic,

24 construction, things like that?

25 A. At that time, he was the vice-president, or rather the deputy

Page 22723

1 prime minister for the economy.

2 JUDGE AGIUS: In 1992, July to September 1992? I mean, are we

3 sure?


5 Q. Let me ask you this: Are you sure about that, or was he the

6 secretariat for traffic and transport at this time?

7 A. No, that was later. He was a minister later. But at that time,

8 he was the vice-president.

9 Q. Who was his direct supervisor? Do you know? Direct superior, I

10 should say.

11 A. The president of the executive council was Mr. Nikola Erceg.

12 Q. Would that be his direct superior?

13 A. Yes.

14 Q. And now you only worked there from 13 July through 13 September

15 1992. Were you paid for your work?

16 A. I worked throughout that period of time. As for salaries, we

17 hardly received any salaries. It's a strange thing to say, but the

18 salaries we received could hardly be used to buy a box of matches.

19 Q. And why is that? Is that because of the inflation?

20 A. Precisely, there was a galloping inflation, and sometimes you

21 could use a certain amount of money to buy something in the morning, but

22 in the afternoon, it would have no longer been sufficient.

23 Q. And why did you leave -- when you did in September?

24 A. Because the Autonomous Region of Krajina was cancelled at the

25 session of the Assembly. I think it was in Bijeljina.

Page 22724

1 Q. Now, in 1991 and 1992, did you live that entire period in the

2 Municipality of Banja Luka?

3 A. Yes.

4 Q. I want to talk to you first about the war in Croatia. Did that

5 have any impact on the economy in Banja Luka?

6 A. Yes.

7 Q. And how did the war affect the economy in Banja Luka from your

8 perspective as someone who lived there for two years?

9 A. Early on, in that period of time, there wasn't enough electricity

10 in Banja Luka. There was no fuel to be had. Petrol stations. There

11 weren't too many supplies to be had in the shops and everyone in Banja

12 Luka was facing difficulty.

13 Q. Did -- were you aware of mobilisation orders going out to all

14 ethnicities?

15 A. Yes.

16 Q. And what would happen to people who did not respond to

17 mobilisation?

18 A. They would stop working regardless of their ethnicity. Whoever

19 failed to respond to the call-up for mobilisation would be fired.

20 Q. Did that apply to Serbs who failed to respond to mobilisation?

21 A. Applied to everyone.

22 Q. Would the failure to respond to mobilisation, could that affect a

23 person's accommodations, their housing situation?

24 A. I'm not aware of that.

25 Q. Okay. Let's move into 1992. What was the job situation like in

Page 22725












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

13 English transcripts.













Page 22726

1 Banja Luka?

2 A. The situation was difficult. The companies had ceased to operate,

3 and Banja Luka was blocked, cut off. There were less jobs to be had in

4 the companies.

5 Q. Were you able to find a job in -- after you left your job in

6 September of 1992?

7 A. I found another job in 1994 when I started working with the health

8 ministry.

9 Q. Between September 1992 when you left your job and 1994 when you

10 started working with the health ministry, were you out looking for a job?

11 A. No, not really.

12 Q. Now, living in Banja Luka, did you have any non-Serb friends?

13 A. Yes.

14 Q. Were any of your non-Serb friends Muslims?

15 A. Yes.

16 Q. When did the vast majority of the Muslim population leave

17 Banja Luka? What year?

18 A. 1995.

19 MR. CUNNINGHAM: That's all the questions I have. Thank you,

20 Ms. Beric.

21 JUDGE AGIUS: I thank you, Mr. Cunningham.

22 THE WITNESS: You're welcome.

23 JUDGE AGIUS: Ms. Korner as I explained to you earlier on is going

24 to cross-examine you. Ms. Korner, please proceed.

25 MS. KORNER: Thank you.

Page 22727

1 Cross-examined by Ms. Korner:

2 Q. Ms. Beric, do I take it you're a Serb by nationality?

3 A. That's correct.

4 Q. At any stage were you the technical secretary to the Assembly of

5 the Autonomous Region of Krajina?

6 A. No, not of the Assembly, of the executive council.

7 Q. No, sorry. Were you -- I'm sorry, you were the technical

8 secretary to the executive council for the Autonomous Region of Krajina

9 Assembly. Is that right?

10 A. No, the assembly was one thing, and the executive council was a

11 different kettle of fish, and those were two different buildings. The

12 offices were in two different buildings.

13 Q. I understand that. But we're talking now about not the executive

14 council to the municipality where the head was Mr. Kasagic, but the

15 executive council headed by Mr. Erceg.

16 A. Yes, yes, that's where I worked, where Mr. Erceg was head.

17 Q. Right. Did you know Mr. Blagojevic, the secretary to the

18 assembly?

19 A. I'd heard of him, but I didn't know him personally.

20 Q. All right. Did you work at the executive council of the

21 autonomous region from the moment that it came into being in September

22 1991?

23 A. I worked from the 13th of July to the end of September. In 1992,

24 I think it had probably been founded earlier on, but they didn't have a

25 separate office as executive council so they were looking for one.

Page 22728

1 Q. No. Were you aware that the Autonomous Region of Krajina Assembly

2 came into existence in September of 1991?

3 A. I believe so, but I'm not sure.

4 Q. So in September 1991, where were you working? For whom?

5 A. I was with the Banja Luka Municipality.

6 Q. Yes. But in which office?

7 A. I think it was the secretariat for property-related issues. I

8 worked for a number of different secretariats, part-time, though.

9 Q. Right. How did you come to move to work for the executive council

10 of the autonomous region?

11 A. I assumed they would need people to work for them because they

12 were looking for offices to occupy, and I asked around to see whether all

13 the vacancies had been occupied.

14 Q. When was that?

15 A. That was towards the end of June 1992. That's when I started

16 asking around to see whether I could have a job with the executive

17 council.

18 Q. So the executive council, is that what you're saying, up until

19 June 1992 had no offices?

20 A. Not that I was aware of. I'm not sure they had any before, but I

21 know that when I started working they had offices inside the Chamber of

22 Commerce.

23 Q. All right. And you went to work not as Mr. Brdjanin's personal

24 secretary, but as a secretary to the executive committee. Is that right?

25 A. No. I was the secretary of Mr. Brdjanin.

Page 22729

1 Q. All right. Who offered you the job?

2 A. Mr. Brdjanin himself.

3 Q. And when did you first meet Mr. Brdjanin?

4 A. A month before I started working with him.

5 Q. And where was Mr. Brdjanin then?

6 A. Where he resided?

7 Q. No, where was he working? Where were his offices then?

8 A. I didn't know that.

9 Q. Where did you meet him?

10 A. I met him outside the Banja Luka Municipality building. I

11 approached him assuming that he was Mr. Brdjanin. I spoke to him and told

12 him that I needed a job. I asked for help.

13 Q. I'm sorry. So this wasn't a job that had been advertised; you

14 approached Mr. Brdjanin on the off chance that he could offer you a job?

15 A. I merely asked him whether there would be any vacancies, and he

16 said in case there were any vacancies, feel free to come over. It was

17 later on that I started working for him. Not back then.

18 Q. You'd never met Mr. Brdjanin before?

19 A. No, I had never met him. He IS originally from

20 Celinac Municipality, and I am myself from Banja Luka.

21 Q. Yes, but how did you know it was Mr. Brdjanin you were approaching

22 then?

23 A. I assumed so.

24 Q. I imagine there were many people who you might have assumed were

25 Mr. Brdjanin coming out of the municipality building. How did you know

Page 22730

1 that was Mr. Brdjanin?

2 A. Someone called him by his name, someone shouted out "Brdjo." I'm

3 sorry that I'm laughing, but that's really how it happened. And then I

4 approached him, and I asked him, "Mr. Brdjanin, you are Mr. Brdjanin,

5 aren't you?" And he said, "Yes. What is it you need?" And I told him

6 what I needed. What I needed was a job. I asked him whether he was able

7 to give me a hand. And he said, "Right now we don't have any premises to

8 occupy, but later on we will need people to work for us."

9 Q. Forgive me, Ms. Beric. Wasn't this a slightly unusual thing to

10 do?

11 A. Well, perhaps it wasn't even polite honestly.

12 Q. Were you aware -- had you seen Mr. Brdjanin on television?

13 A. No. I never watched TV. There was no electricity. Even when we

14 had electricity, I usually preferred to watch a video, a film, or

15 something.

16 Q. Did you read newspapers?

17 A. No. I want to point out that I was really not interested in

18 politics at all.

19 Q. You may not be interested in politics, but didn't you like to know

20 what was going on?

21 A. I just wasn't interested. The main thing for me is not to be

22 harassed by anyone, not to face any problems myself.

23 Q. Did you listen to the radio?

24 A. No, there was no electricity. You couldn't listen to radio.

25 Q. How did you know who Mr. Brdjanin was?

Page 22731

1 A. Well, I've just explained, haven't I? I was standing outside

2 the --

3 Q. I'm sorry, that's my fault. Bad question. I don't mean how you

4 knew who he was when you asked him for a job, but how did you know that he

5 was someone that you wanted to work for?

6 A. I needed a job. It didn't matter who with or what company.

7 Q. All right. What did you understand was Mr. Brdjanin's position

8 when you walked up to him and asked him if you could have a job?

9 A. Well, he was the vice-president of the executive council at that

10 time.

11 Q. What makes you think he was the vice-president of the executive

12 council?

13 A. Well, if I were to work with a vice-president of the

14 Republika Srpska government for the economy now --

15 Q. No, in 1992 when you approached him outside the municipal

16 building, what made you think that Mr. Brdjanin was the vice-president of

17 the executive council?

18 A. Well, he was. He was vice-president.

19 Q. I know, but why do you think -- I hear what you say, Ms. Beric.

20 Why do you think he was the vice-president of the executive council? Had

21 you seen it in a newspaper --

22 A. Well, simply because he was. No, no. I knew it for a fact that

23 he was the vice-president of the executive council.

24 Q. All right. I'm sorry, you say you knew it as a fact. How did you

25 know it as a fact? I mean, in other words were you told that or did you

Page 22732

1 see it in the newspapers?

2 A. I believe someone told me, but I really can't remember who. They

3 said it would probably be a good idea to talk to him to see about the job.

4 Q. Was it somebody in the municipality building where you worked?

5 A. I believe it was someone there, yes.

6 Q. And are you saying through the entire two months that you worked

7 with him, you were under the firm impression that he was the

8 vice-president of the executive council of the autonomous region?

9 A. Yes, I was. Whenever I typed up his official letters, what I

10 would put at the bottom of the letter was "vice-president."

11 Q. Of the executive council?

12 A. Yes.

13 Q. I just want to see whether -- were you aware that he was the

14 vice-president of the Autonomous Region of Krajina Assembly?

15 A. Whenever I typed up his official letters, at the bottom of the

16 page, every time I would type "vice-president of the executive council,

17 Radoslav Brdjanin, BA in civil engineering."

18 Q. Are there any of those letters available? Have you brought any of

19 those letters with you?

20 A. No.

21 Q. Well, where would those --

22 A. I don't have them.

23 Q. Where would those letters be?

24 A. They're certainly not in my files. I was not in charge of the

25 files.

Page 22733

1 Q. All right. You may not have been in charge of the files. Where

2 are the files?

3 A. I really don't know.

4 Q. Did you ever hear about a crisis staff in Banja Luka for the

5 region?

6 A. I'm not familiar with that. I don't know when it was founded or

7 when it ceased to operate. I was not involved in any way with the crisis

8 staff.

9 Q. Right. So did you ever tell an investigator for Mr. Brdjanin that

10 you could talk about Mr. Brdjanin's everyday activities as the president

11 of the crisis staff?

12 A. No.

13 Q. When did you first see -- well, who did you first see about

14 testifying in this case?

15 A. Two and a half years ago, perhaps more, attorney Peric, Milos

16 Peric was there, accompanied by Ms. Mirka Maglov.

17 Q. Did you ever tell either Mr. Peric or Ms. Maglov that you were the

18 technical secretary to the Autonomous Region of Krajina?

19 A. I told them that I had worked with Mr. Brdjanin in a period of

20 time that I mentioned.

21 Q. Did they take a statement from you when you first saw them two and

22 a half years ago?

23 A. They took a brief statement of some sort. Perhaps they wrote down

24 the date and those who were present.

25 Q. Well, were you asked to sign a document then?

Page 22734

1 A. No.

2 Q. And you were unaware, were you, that Mr. Brdjanin was the

3 president of the Autonomous Region of Krajina Crisis Staff?

4 A. I was unaware of that.

5 Q. All right. Do you have any idea about his contacts before July of

6 1992 with the municipal figures such as Mr. Radic or Mr. Kasagic or

7 Mr. Cvijic?

8 A. I was not aware of that. I was not aware of that really. What he

9 had done up to that point, I really can't say.

10 Q. And you couldn't say anything either about his contacts with the

11 army and the police and ordinary people before the 13th of July 1992?

12 A. I can't.

13 Q. And through the entire time that you worked for him, you

14 understood that he was the vice-president of the executive council, and

15 all the letters that you sent out on his behalf stated that was his

16 position?

17 A. Yes.

18 Q. And you got the job because how? He rang you up after the meeting

19 and said "come and work for me"?

20 A. No. I came back to see him when I heard that they had been given

21 offices to work in. And I asked him again whether there was a job for me,

22 and he said, "Yes, please come over and start working for me." And that's

23 how I began.

24 Q. Did he ask you for any references?

25 A. No. The only thing he asked is where I had worked before and what

Page 22735

1 sort of jobs I had.

2 Q. So the only time that you two had ever met was that brief meeting

3 outside the municipal building?

4 A. Yes.

5 Q. Then you went back when you heard he'd found offices and asked him

6 for a job. And the only thing he asked you then is who you had been

7 working for -- where you had worked before and what sort of jobs you had?

8 A. Yes.

9 Q. Did you have to do any kind of a test to see whether you could

10 actually type?

11 A. Yes. It was a very brief test using just a normal typewriter.

12 Q. Did you have to take shorthand?

13 A. No.

14 Q. So how would you type the letters? Would he dictate them to you

15 or would he write them out himself in hand?

16 A. He would dictate letters to me.

17 Q. So he would be sitting there at your desk dictating the letters?

18 A. Precisely.

19 Q. And according to you, there were a large number of letters because

20 he was forever trying to help people solve their problems?

21 A. That's true.

22 Q. Indeed, from what you say, the majority of his day was spent

23 dealing with these people who came to him for help?

24 A. We were compelled to do that because by the time we got to work,

25 people would already be queueing.

Page 22736












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13 English transcripts.













Page 22737

1 Q. I know what you say. But during working hours and afterwards,

2 that is between 8.00 in the morning and 3.00 in the afternoon,

3 Mr. Brdjanin did nothing but see these people who wanted help with jobs or

4 help with accommodation?

5 A. Yes. He talked to them. We typed up the letters, and we answered

6 the phone.

7 Q. Absolutely. So I mean, when did he have enough time to attend

8 meetings?

9 A. The meetings or sessions of the assembly would be scheduled ahead

10 of time, and we knew exactly when he would have to travel.

11 Q. But -- so the only thing -- the only meetings he attended were the

12 meetings of the assembly until it was abolished in September?

13 A. Yes.

14 Q. Otherwise, he was doing nothing but dealing with these people,

15 dictating letters to you, and signing these letters?

16 A. Yes.

17 Q. Did he have a secretary before you?

18 A. He probably did. But I can't say really.

19 Q. Well, did you find out whether or not he had a secretary? Did you

20 ask him who was his previous secretary?

21 A. No, I didn't. I didn't ask him about his previous job either.

22 Believe me.

23 Q. Why didn't all these people who needed all this help go and see

24 Mr. Erceg?

25 A. Well, probably they heard talking one to another that they could

Page 22738

1 reach Mr. Brdjanin in an easier way, and that is why probably they came to

2 see us at our office.

3 Q. Was Mr. Brdjanin, as far as you were aware, a man of influence?

4 A. Well, I will tell you how influential he was. I will tell you

5 when earlier the Defence asked me about my housing problem, well, he was

6 unable to solve my housing problem, and that indicates how influential he

7 was.

8 Q. I was going to come on and ask you about that. There were all

9 these Bosniaks, Croats, and Serbs coming to his office and asking for his

10 help. And he would give it willingly, from what you say.

11 A. Yes.

12 Q. Why wouldn't he help you out?

13 A. Well, he was unable to. As I said, he had told me that there

14 weren't any flats available and that we would have to wait for some time

15 before my housing problem to be solved.

16 Q. But for all these other people who came to see him regardless of

17 their ethnicity, nationality, he was prepared to write letters?

18 A. Yes.

19 Q. So didn't you say to him, well, why are you writing the letters

20 for all of these people and you won't do it for me?

21 A. Well, I thought that there would be enough time that we would

22 still be working together, and that I would ask him again later on because

23 these people at first would be queuing up there, and then later on simply

24 we didn't have a chance for that.

25 Q. I know. But he was writing letters from the moment you started

Page 22739

1 work on behalf of people who were total strangers to him. Didn't you

2 think of asking him, why are you doing it for total strangers and not for

3 your own secretary?

4 A. I never made any such objection to him because I always thought

5 that our first and foremost duty there was to help the people who were

6 coming.

7 Q. He told you that there was no prospect of you getting an

8 apartment, but was saying to other people, is that right, I will write

9 letters to see if you can get an apartment?

10 A. Will you please repeat the question.

11 Q. He said to you: "There's no point in me writing a letter because

12 there's no accommodation available"?

13 A. Well, perhaps because I had come from the Banja Luka Municipality,

14 and then started working for him. Perhaps that's why he thought, well, if

15 they were unable to solve that issue for me earlier, how was he then able

16 to solve it.

17 Q. But you told us a minute ago that one of the reasons he gave you

18 was that there was no accommodation available.

19 A. At that time, he thought that he was unable to secure for me as

20 his employee an apartment.

21 Q. But he never told any of the other people, the Bosniaks, for

22 example, that there was not the slightest chance that they could get an

23 apartment?

24 A. No, he supported them. He wanted to help them, and he did really

25 write those letters.

Page 22740

1 Q. From your own personal knowledge of living in Banja Luka during

2 this period, Ms. Beric, isn't it right that Bosniaks in particular were

3 being expelled from their homes, thrown out?

4 A. I am not aware of them being thrown out of their homes. I can

5 only tell you that the people who failed to respond to the call-up, they

6 got fired. And that applied to Serbs, Croats, and Muslims alike.

7 Q. I want to come back to that in a moment. You dealt with all the

8 signatures, and I just want to understand this. Not one single document

9 that bears a signature, either "za" or apparently on the face of it

10 Brdjanin's signature himself is signed by him. That's what you're saying,

11 is it?

12 A. Yes.

13 Q. Somebody else has forged his signature, in the case of the ones

14 where there is no "za"?

15 A. Someone did sign it, but it wasn't Mr. Brdjanin.

16 Q. But if someone signed on his behalf, it should have said, should

17 it not, "za," on his behalf?

18 A. On some of the documents, it does say on his behalf, "za".

19 Q. But the other documents which don't have that look as though they

20 have been signed by Brdjanin, don't they, to the outsider?

21 A. But it wasn't Mr. Brdjanin who signed any of them.

22 Q. So somebody forged, because you've seen these are all official

23 documents with a stamp, somebody forged his signature?

24 A. So it seems.

25 Q. And what effect would that have on the -- if you know, on the

Page 22741

1 legality of those documents?

2 A. It is not correct.

3 Q. One of the documents you were shown, and that is P255, can you

4 have that back, please, now, that one appeared, and you better have 254 as

5 well to go with it, appeared in Glas. Now, did you see that at the time,

6 the article in Glas with a copy of this decision?

7 A. I did not.

8 Q. If you had seen it, you would have been able to say straight away,

9 would you, "that is not Mr. Brdjanin's signature"?

10 A. I wouldn't be able to say so because this is the 22nd of June

11 1992. Therefore, the time when I did not work for Mr. Brdjanin and I did

12 not know his signature.

13 Q. You're quite right. But if you'd seen it subsequently after you

14 started work for him, you would have said straight away, well, that's

15 really odd, that's not Mr. Brdjanin's signature?

16 A. Precise.

17 Q. And anybody else who was familiar with his signature on the 22nd

18 of June would have been able to say the same thing.

19 MS. KORNER: Actually, that's a comment. I withdraw that

20 question.

21 THE WITNESS: [Interpretation] Yes.


23 Q. I want you to look at a couple of other documents which you

24 weren't shown. Would you look at P197 first of all. Perhaps we better

25 have it on the ELMO.

Page 22742

1 Put the last page with the signature on, please.

2 JUDGE AGIUS: Yes, we could have it on the ELMO at least

3 momentarily.


5 Q. Now, have a look at that. Is that Mr. Brdjanin's signature?

6 A. No.

7 Q. Okay. 198, please. Now, is that Mr. Brdjanin's signature?

8 A. No.

9 Q. Finally, please --

10 JUDGE AGIUS: Again, I would like it to be shown momentarily for

11 the record because I don't think it was.

12 MS. KORNER: The signature. It was on the ELMO, Your Honour.



15 Q. Finally, could you look at P64.

16 Ms. Beric, is that Mr. Brdjanin's signature? It's not a terribly

17 good copy.

18 A. No, it isn't.

19 Q. Forgive me, Ms. Beric, and I don't mean this insultingly, but are

20 you sure you worked for Mr. Brdjanin?

21 A. Yes.

22 JUDGE AGIUS: I had in mind, Ms. Korner, perhaps it's wise to

23 intervene, put the question now. I had marked for myself a question that

24 I meant to ask the witness at the end. But I am going to ask it now.

25 During the briefing while you were being -- when you met Mr. Cunningham or

Page 22743

1 whoever from the Defence team for Mr. Brdjanin, were you at any time shown

2 any document on which you recognised Mr. Brdjanin's signature?

3 THE WITNESS: [Interpretation] No.

4 MS. KORNER: Your Honour, could I just --

5 JUDGE AGIUS: Because I am sure that Mr. Cunningham would have

6 come forward and produced those documents. But obviously, it's not the

7 case.

8 MS. KORNER: If Your Honour would give me just one minute, I just

9 want to see if I can find something else.

10 JUDGE AGIUS: For example, if you look at this signature that you

11 have there in front of you on the screen now, does it resemble, at least,

12 Mr. Brdjanin's signature?

13 THE WITNESS: [Interpretation] No.


15 Q. I'm just going to put this one up.

16 MS. KORNER: Could you look at this, Your Honour. It's DB169B.

17 Q. Is that Mr. Brdjanin's signature?

18 A. No.

19 JUDGE AGIUS: Once, too, I went to my bank where they knew me

20 donkey's years to cash a cheque, and the lady at the counter told me "this

21 is not your signature."

22 MS. KORNER: Your Honour -- thank you very much, Ms. Beric. We'll

23 stop this exercise now.

24 Your Honour, this was given to us by the Defence as an example of

25 a letter written by Mr. Brdjanin and signed by him.

Page 22744

1 Q. Ms. Beric, I'm going to ask you again. Are you really sure you

2 worked for Brdjanin?

3 MR. CUNNINGHAM: Judge, I object to that, that's repetitive.

4 JUDGE AGIUS: Yes, objection sustained. Ms. Korner, let's

5 proceed, and switch on to something more...

6 MS. KORNER: I'm not sure there's too much more I need to ask,

7 Your Honour.

8 Q. Can I take it from what you say, Ms. Beric, that you are wholly

9 unaware of any press conferences given by Mr. Brdjanin in which he stated

10 that non-Serbs in charge of companies should be dismissed from their jobs?

11 A. I am not aware of any press conferences, and I am unaware of him

12 stating ever anything to the detriment of Serbs -- of Croats or Muslims.

13 I've never heard any such thing.

14 Q. And you never presumably either heard him describe Bosniaks as

15 "non-Christian scum"?

16 A. No, I never heard this.

17 Q. Or say that only a small percentage of non-Serbs should be allowed

18 to stay in Banja Luka?

19 A. No, he never used any derogative word or any improper word for the

20 people of other ethnicities, not in his office, and that is something I

21 can say for a fact.

22 Q. I'm not talking about his office for the moment. I'm talking

23 about outside his office. Were you ever aware of any public statements

24 made by him?

25 A. No.

Page 22745

1 Q. Were you ever aware of any of your Bosniak or Croat friends saying

2 that Mr. Brdjanin's speeches terrified the life out of them?

3 A. No. My friends of other ethnicities always greeted me, and they

4 never told me that they were really concerned about anything. They only

5 spoke of the purchasing power that was on the reduction level and that our

6 salaries were lower and lower, and that's sort of things that we spoke

7 about. I was not involved in politics, and I was not a member of any

8 political party, if that's what you're interested in.

9 Q. Were you ever aware of busloads of non-Serbs leaving Banja Luka

10 during the period 1992?

11 A. I've never seen that.

12 Q. Were you aware of a red combi driving around Banja Luka seizing

13 people and beating them up?

14 A. No. This is the first time I hear of it.

15 Q. Yes.

16 MS. KORNER: Thank you very much.

17 THE WITNESS: [Interpretation] You're welcome.

18 JUDGE AGIUS: I thank you, Ms. Korner.

19 Is there re-examination, Mr. Cunningham?

20 MR. CUNNINGHAM: No, Your Honour.

21 JUDGE AGIUS: Yes, we have some questions for you, Madam.

22 Judge Janu from the Czech Republic will go first.

23 Questioned by the Court:

24 JUDGE JANU: Ms. Beric, when you were describing for us that you

25 met Mr. Brdjanin and you asked him for the job and he told you to come

Page 22746

1 back, did he ever later on ask you about your education? What sort of

2 education did you complete, about your qualification?

3 A. Yes, he did. He asked me what my education was, the schools that

4 I finished, where I worked previously, and what my abilities were.

5 JUDGE JANU: And what is your completed education? Can you tell

6 us.

7 A. Administrative school.

8 JUDGE JANU: And my second question, you said you had friends from

9 the different -- other ethnicities. Are those -- were those friends close

10 friends or just somebody you went to school together and met them in the

11 street? Or how close you were to those people you are referring to as

12 friends?

13 A. These were my schoolmates, and people I worked with in the

14 municipality.

15 JUDGE JANU: And could you consider this friendship as a close

16 friendship?

17 A. Well, you know that a lot of time is spent at the workplace, so I

18 can say that we were really on friendly terms.

19 JUDGE JANU: And those people had to leave during the war, or they

20 stayed in Banja Luka?

21 A. They stayed in Banja Luka, those that I know.

22 JUDGE JANU: All of them?

23 A. Yes.

24 JUDGE JANU: So you don't have friends who left at that time?

25 A. No. As far as I know, these people did not leave Banja Luka.

Page 22747

1 JUDGE JANU: Thank you. That's all. Thank you.

2 JUDGE AGIUS: Judge Taya, do you have any questions?

3 JUDGE TAYA: From 13th July to 13th September 1992, as the

4 secretary of Mr. Brdjanin, you received almost nothing as salaries. Is

5 that right?

6 A. Well, as I said earlier, the salary was a minimal one due to the

7 inflation.

8 JUDGE TAYA: You didn't receive any favour for your accommodation

9 from Brdjanin during that period. Is that right?

10 A. No.

11 JUDGE TAYA: Then what was the incentive for you to work as a

12 secretary for Mr. Brdjanin?

13 A. To gain work experience. And I expected the salaries to be high

14 actually. I apologise.

15 JUDGE TAYA: Thank you.

16 JUDGE AGIUS: Yes, thank you, Judge Taya.

17 I have got very few questions. One refers to a question that you

18 were asked earlier on by Madam Korner, and I just want to make sure that

19 what you said -- what you meant to say is reflected in the answer.

20 Madam Korner asked at a certain stage: "Did you ever hear about a crisis

21 staff in Banja Luka for the region"? And your answer was: "I'm not

22 familiar with that. I don't know when it was founded or when it ceased to

23 operate about that. I was not involved it any way with the crisis staff."

24 Forget that you were not involved in any way with the crisis staff, forget

25 that you don't know when it was founded or when it ceased to operate, but

Page 22748

1 do you know -- are you aware that it existed at some point in time, the

2 crisis staff of the ARK, of the Autonomous Region of Krajina?

3 A. No. I am not aware of it having been established or dissolved. I

4 do not know anything really about the crisis staff.

5 JUDGE AGIUS: And the last thing, you at one point in time said

6 you were not authorised to sign for Mr. Brdjanin. Do you know who was

7 authorised --

8 A. No.

9 JUDGE AGIUS: -- who was authorised to sign for Mr. Brdjanin? You

10 don't know.

11 A. I don't think anybody had the authorisation to sign anything on

12 his behalf while he was vice-president of the executive council. I am not

13 aware of anyone having been authorised to that effect.

14 JUDGE AGIUS: All right. I thank you.

15 And that brings us to the end of your testimony.

16 THE WITNESS: [Interpretation] You're welcome.

17 JUDGE AGIUS: I thank you once more on behalf of everyone for

18 having come here to The Hague to give testimony, and I wish you a safe

19 journey back home.

20 THE WITNESS: [Interpretation] Thank you very much.

21 [The witness withdrew]

22 JUDGE AGIUS: So that leaves us where, Mr. Cunningham.

23 MR. CUNNINGHAM: Next witness is being proofed this afternoon.

24 We're right on schedule and - this is intended for the OTP - I think I can

25 finish with him by 12.30 tomorrow.

Page 22749

1 JUDGE AGIUS: This was indicated to us on your list as a soft one,

2 meaning that he could be replaced.

3 MR. CUNNINGHAM: And I apologise --

4 JUDGE AGIUS: He is here?

5 MR. CUNNINGHAM: He is here.

6 JUDGE AGIUS: So we're talking of witness number 17 in other

7 words?

8 MR. CUNNINGHAM: Yes, Your Honour.

9 JUDGE AGIUS: Right. And it was indicated also that this would

10 last two days, so it's going to last --

11 MR. CUNNINGHAM: It will take us through Friday.

12 JUDGE AGIUS: Through Friday.

13 MS. KORNER: Your Honour, can I just make a point, though, about

14 this. This is the second time where what was clearly going to be a short

15 witness has finished, and there's nobody to come. The difficulty is this:

16 We, then, when there's an important witness are restricted on our

17 cross-examination because we're told, "We're bringing them now, they have

18 to go back Friday." Your Honour, my suggestion is that because I'm going

19 to submit to Your Honours that these arbitrary time limits shouldn't be

20 put on what are clearly going to be important witnesses, that more

21 witnesses -- we're wasting more time and more money by having these gaps

22 than if witnesses virtually witnesses go over. Your Honour, my suggestion

23 is that the witnesses should be brought up and there should be witness two

24 witnesses ready to testify at any one time when there are shortish

25 witnesses.

Page 22750

1 JUDGE AGIUS: I agree with you, Ms. Korner, because it's all

2 right -- I mean, we can use the time for the business that we have to

3 conclude today. So for us three and our staff, in a way, it's a blessing.

4 But I also realise that what you are saying is very much --

5 MS. KORNER: Well, Your Honour, I'm still, may I say, smarting

6 somewhat from being forced to take an important witness, Mr. Kalabic, in

7 effectively half a day and therefore not being properly able to put many

8 of the documents that I wished to put. That's the reason I'm raising --

9 JUDGE AGIUS: Yes, you're right.

10 MS. KORNER: -- we will be objecting to having arbitrary time

11 limits put on these "important witnesses".

12 JUDGE AGIUS: Yes, Mr. Cunningham.

13 MR. CUNNINGHAM: Judge, her point is well taken. I couldn't

14 anticipate Mr. Ackerman being ill and in the future, in light of this, if

15 we have a brief witness, I will try to direct traffic a little bit better

16 so that we can use all the time.

17 JUDGE AGIUS: I appreciate that, Mr. Cunningham. I take

18 Ms. Korner's point as a very valid one, and very constructive one. And

19 also fair.

20 So we'll reconvene tomorrow at -- Madam Chuqing, can I have a

21 confirmation from you that we're sitting in the morning?

22 All right, so we'll sit in the morning starting at 9.00 in this

23 same courtroom, and we'll hear witness number 17. Thank you.

24 --- Whereupon the hearing adjourned at 11.59 a.m.

25 to be reconvened on Thursday, the 27th day of

Page 22751

1 November, 2003, at 9.00 a.m.