Tribunal Criminal Tribunal for the Former Yugoslavia

Page 3002

 1                           Monday, 31 May 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 2.15 p.m.

 5             JUDGE KWON:  Good afternoon.  We'll be sitting this week pursuant

 6     to Rule 15 bis with Judge Lattanzi being away on official business of the

 7     Tribunal.

 8             I was told that Mr. Tieger, you have something to raise.

 9             MR. TIEGER:  Thank you, Your Honour.  It's a scheduling matter,

10     very brief.  Pursuant to the Court's suggestion on Friday, we have been

11     attempting to readjust the witness schedule.  In the course of that

12     effort, there is a matter that arises that I wanted to alert the Court to

13     as early as possible, because I think some action at this point could

14     remedy that situation.

15             In the week of the 21st of June there will be a witness

16     commencing who must leave on the 24th.  If the Court could add one extra

17     hour per day that week on the 21st, 22nd, and 23rd, that would allow the

18     witness to complete his testimony within the time allocated or requested

19     as matters currently stand by the cross-examination schedule.

20             Now, obviously that could be done with the normal four hours one

21     day, six hours another day, five hours another day, but basically that

22     would remedy the difficulty of the witness' schedule for that week.  So

23     if I could ask whether it was possible for the Court to check into that

24     possibility and alert us as quickly as possible.  That would be of

25     enormous assistance.

Page 3003

 1             JUDGE KWON:  Thank you.  We will look into the matter.

 2             Then we'll bring in the witness.

 3             MR. TIEGER:  And the only thing I'd add, Your Honours, the

 4     witness is coming from very far away, so going back and forth is not a

 5     genuine possibility.  So ...

 6             JUDGE KWON:  The witness who is supposed to come on 21st June?

 7             MR. TIEGER:  Correct.

 8                           [The witness takes the stand]

 9                           WITNESS:  AERNOUT VAN LYNDEN [Resumed]

10             JUDGE KWON:  Welcome back, Mr. van Lynden.

11             THE WITNESS:  Thank you, Your Honour.

12             JUDGE KWON:  I appreciate you're coming back to conclude your

13     testimony.  Now, you'll bear in mind that your declaration will still

14     apply today.

15             THE WITNESS:  Yes.

16             JUDGE KWON:  Thank you.  If you're ready, we'll start.

17             Mr. Karadzic.

18                           Cross-examination by Mr. Karadzic: [Continued]

19        Q.   [Interpretation] Thank you.  Good afternoon to everybody.

20             Thank you, Mr. Lynden, for coming back.  May I ask you whether we

21     are richer, and have you brought one of your diaries with you?  Have we

22     been enriched with an extra diary?

23        A.   As I told the Court when I was last here, the diaries -- or my

24     notebooks, rather, I don't have diaries, my notebooks are not in my

25     possession.  All our property is currently held in storage, and I --

Page 3004

 1     that's held in the Netherlands, and I have not been in the Netherlands,

 2     and, no, I have not been into the storage.

 3        Q.   Thank you.  Would you agree with me, Mr. van Lynden, that the

 4     media have a decisive influence on public opinion?

 5        A.   Yes and no.  In certain cases they can.  In other cases, they

 6     don't.  There is no simple answer to that question.  We could write books

 7     about that kind of thing, Mr. Karadzic, and I think people have done.

 8        Q.   And would you agree that your reports, especially your reports,

 9     as coming from a respected journalist and respected newspaper or news

10     agency, have a very important role in public opinion?

11        A.   Well, as I answered before, possibly some of the reports had an

12     impact.  I think a lot of the reports actually didn't have an impact.

13     It's very difficult for -- for me to judge the precise impact that any

14     single report that I sent while I was in a war zone, I can't judge how it

15     is viewed in the rest of the world.

16        Q.   Thank you.  Now, may we have two photographs put up on our

17     screens, please -- or, rather, on the overhead projector so that we can

18     have a look at them.  I'm not going to tender them into evidence today.

19             JUDGE KWON:  I don't think the ELMO has been activated.  Can you

20     proceed?

21             MR. KARADZIC:  [Interpretation]

22        Q.   This caricature that we see here, does that affect the formation

23     of public opinion, for instance?

24        A.   I've never seen this before.  I don't know where it was

25     published, so I can't really react to that.

Page 3005

 1        Q.   But it's not very nice for the Serbs and Croats to see this.  The

 2     one with the U on his cap is a Croat; right?  It's not very pleasant.

 3        A.   I imagine this depicts, but as I said, this is the first time

 4     I've ever seen it, a Croat on the left, a Serb in the middle, and a

 5     Muslim on the right, and I would not imagine that would be pleasant, but

 6     as I said before, I don't know who made this, where it was published, who

 7     would have seen it.  It's a caricature.

 8        Q.   Thank you.  Well, obviously a German creation?

 9             JUDGE KWON:  Mr. Nicholls.

10             MR. NICHOLLS:  I believe it's the first time I've seen or heard

11     of it -- seen it or heard of it as well, Your Honour.  I was wondering if

12     this has a 65 ter number or if it was listed as an exhibit.

13             JUDGE KWON:  I think it has been informed -- you didn't inform

14     the Prosecution that you're going to use this document during your

15     cross-examination?

16             THE ACCUSED: [Interpretation] I just received it, Your

17     Excellency, so I just wanted to share it with Mr. van Lynden and show him

18     what impact the media can have on public opinion, but I'm not going to

19     tender it into evidence at this point.

20             JUDGE KWON:  Whether or not you tender it, we have a rule you

21     have to abide by.  You have to inform the Prosecution in advance of the

22     documents you're going to use.

23             Let's move on.

24             THE ACCUSED: [Interpretation] Thank you.  Can I show another

25     caricature then?

Page 3006

 1             JUDGE KWON:  I wonder what point it would have, but let's

 2     proceed.  Whether Mr. van Lynden can make any comment.

 3             THE WITNESS:  Well, the only comment, Your Honour, that I can

 4     make is Mr. Karadzic just said, "And show him what impact media can have

 5     on public opinion."  I'm not sure that this character had any impact on

 6     public opinion.  I'm not sure where it was ever published.  Mr. Karadzic

 7     says it's German.  What that proves is beyond me.

 8             JUDGE KWON:  Thank you.  Let's move on to your next topic.  No,

 9     it's done.  Move on to your next topic.

10             THE ACCUSED: [Interpretation] Thank you.

11             MR. KARADZIC:  [Interpretation]

12        Q.   Mr. van Lynden, the film that you showed us with the night

13     bombing, you said that it was taken by a Sky News reporter, right, that

14     he filmed it?

15        A.   All the film in the reports at the beginning of June were indeed

16     filmed by a Sky News cameraman whom I was with continually while he was

17     filming.

18        Q.   And how was the footage edited?

19        A.   By a picture editor.  Also from Sky News.

20        Q.   How much -- or, rather, how long was the raw material, the raw

21     filming?

22        A.   That would vary from day to day, but as I recall during those

23     days, certainly minimally two tapes of 30 minutes a day, probably more.

24        Q.   And then the editor would condense it to fit into just a few

25     minutes; right?

Page 3007

 1        A.   Television news reports -- a news bulletin is usually less than

 2     half an hour long.  Therefore, most broadcasts would be -- a report would

 3     be about a minute to a minute and a half long.  In this case, these

 4     reports were longer, very long, by the standards of a news bulletin,

 5     usually about two and a half to three minutes, but, yes, of course it has

 6     to be edited.

 7        Q.   So at least an hour of film was reduced to two or three minutes;

 8     right?

 9        A.   That's the process.

10        Q.   Thank you.  Now, your viewers, the viewers who saw the footage,

11     were they able to gain an impression as to who was doing the shooting?

12        A.   They were, because we told them that most of the -- what they

13     were seeing was incoming into Sarajevo.

14        Q.   But, you know, that Sarajevo had Serbs and Serb districts and

15     neighbourhoods; right?

16        A.   Yes.  I said "most."

17        Q.   Do you remember the convent, and do you agree that that was a

18     Catholic church convent and throughout it was on Serb territory?

19        A.   Yes, I do, but I don't see the point in connection to the footage

20     that we shot as far as the shelling of Sarajevo was concerned.

21        Q.   Well, I wasn't on that footage, and the footage wasn't clear

22     either.  You couldn't actually see that it was the Catholic church and

23     the convent, which is located on Serb territory right up at the front

24     line or almost up at the front line.  What I want to say is that this

25     wasn't stressed sufficiently, that it was a Catholic church on Serb

Page 3008

 1     territory, safeguarded very well throughout the war?

 2        A.   You're really wrong here, Mr. Karadzic.  Firstly, you are dealing

 3     with two completely separate matters, the stories that I did at the

 4     beginning of June and a story that I did in September when I was working

 5     out of Pale.  And we made quite clear in that report that we were in the

 6     territory of Sarajevo that was controlled by your forces and that these

 7     nuns were there, close to the front lines, and giving food to elderly

 8     people living there still.  So the two are not connected.  The reports at

 9     the beginning of June and the report in September are two separate

10     reports at different times, and we did make clear that that convent was

11     within the territory held by your forces.

12        Q.   Thank you, but although they could have been Serb, too, but what

13     I wanted to say was this was an example where the monastery was not a

14     Serbian one and not Orthodox, yet it was located on Serb territory and

15     nothing happened to it.  It was very safe.  And I'm not talking about

16     just one of your reports but your reporting in general.  But anyway,

17     thank you.

18             Now, do you remember, Mr. van Lynden, one of your reports about

19     the relocation of weapons, and you were shown a very big guy, and you

20     said that his nickname was Zver or "Beast."

21        A.   I think I know what you're referring to.  This is after a deal

22     had been done with the UN agreeing to the withdrawal of your heavy

23     weaponry either completely or to UN collection points and simultaneously

24     the collection of heavy weaponry within Sarajevo to UN collection points.

25             We were taken the day after General Rose had announced that all

Page 3009

 1     the heavy weaponry had either been removed or was now under the care of

 2     the UN by representatives of your government on a trek north of Sarajevo,

 3     and one of the places we stopped, we stopped at several, we saw -- as I

 4     remember with this bit, I -- I may be wrong, but I think what he had were

 5     heavy mortars, 120-millimetre mortars.  I can't remember him being called

 6     the Beast, but that may well be -- may have been his nickname.  What he

 7     showed me was that all the -- he was there, and the heavy weaponry was

 8     there, had not been withdrawn, but there was nobody from the UN there,

 9     and I remember him quite clearly saying that he'd heard what General Rose

10     had told the world the previous night, that all the heavy weaponry had

11     been withdrawn or was under UN control, and he then said to me, Well, as

12     you can see, that's not the case.  He was very willing for the UN to

13     come, but the point was that the UN hadn't come and that was really also

14     the point to the report that we made that day.

15        Q.   But you said that that young man was referred to as Zver or Beast

16     in that footage.  Now, do you remember that his nickname was Medo or

17     teddy bear and that probably your translator -- your interpreter

18     translated it as beast?  Do you know the difference between beast or bear

19     or teddy bear?

20        A.   The information, and I don't precisely recall this incident, but

21     people did have nicknames, as far as I can recall, he spoke about this.

22     He was a jovial figure who welcomed us.  There was no problem.  We were

23     offered a drink.  It was very early in the morning, but -- and I had with

24     me, firstly, Jaksa Scekic from Belgrade, who was the producer at that

25     time with me working in Pale; and secondly, we had had someone who --

Page 3010

 1     from your administration who also spoke English.  They translated it to

 2     me.  I didn't make that up.

 3        Q.   Thank you.  Now, I'd like to ask the interpreters to put me right

 4     if I'm wrong in what I'm going to say, but Medo, teddy bear, cannot be

 5     translated as "beast" but as "teddy bear."  The teddy bear is a nice

 6     animal, but he was represented as a Serb beast in your report, whereas he

 7     was a good natured teddy bear?

 8             JUDGE KWON:  Mr. Karadzic, it's not for the witness to comment

 9     upon.

10             THE ACCUSED: [Interpretation] But Your Excellency, this good

11     natured teddy bear was portrayed as a Serb beast.  That's what this is

12     about.  In his words in the report.

13             JUDGE KWON:  You will have the opportunity to bring up the matter

14     later on in your submission.  This is the time for you to cross-examine

15     the witness.

16             THE ACCUSED: [Interpretation] Yes, thank you.  Now, may we have

17     called up on e-court, please, document 1D1211 next, please.

18             MR. KARADZIC:  [Interpretation]

19        Q.   And while we're waiting for that to come up, Mr. van Lynden, let

20     me ask you this:  Do you remember that on the 8th of April, 1993, a

21     military patrol at Ilidza, near the airport, in a convoy organised by a

22     respected humanitarian organisation, found weapon -- found ammunition

23     hidden in the humanitarian aid convoy?

24        A.   As far as I can recall right now, I was not in Bosnia on the 8th

25     of April, 1993, and, no, I do not remember that incident.

Page 3011

 1        Q.   But are you -- do you only limit your knowledge about the events

 2     in Bosnia to the period when you were there, or did your television

 3     station send out reports about everything?

 4        A.   No.  We had correspondence almost permanently in Bosnia, other

 5     correspondence, but you cannot expect me to recall every single incident

 6     that happened in Bosnia, and certainly not in the periods when I was

 7     there.  And even when I was there, I would be focusing on one particular

 8     area and not on everything.

 9        Q.   Thank you.  Now, do you see this document?  It's a text from the

10     "The Independent," an article from the "The Independent," dated the 22nd

11     of August, 1992.

12        A.   Yes, I do.

13        Q.   What do you have to say to that, Mr. van Lynden?

14        A.   I'm aware that certain people, also within the UN, I believe that

15     this is the case.  I've never seen -- was never shown convincing evidence

16     that that was the case.

17        Q.   And all the things that you reported about the Serbs, did you

18     have convincing evidence of that and reports from the Presidency and so

19     on?

20        A.   What we reported we believed to be the truth, yes.

21        Q.   Well, I assume you should believe the United Nations and their

22     doubts and their beliefs as to who was doing the shooting, the shooting

23     at civilians.

24        A.   Well, the UN is a large organisation.  There are also differences

25     of opinion within the United Nations.  We did check with the United

Page 3012

 1     Nations, as I've testified earlier within this trial, about precisely

 2     about what was happening, about the front lines, about the breaking of --

 3     of cease-fires, about the levels of -- of shelling on one district or

 4     another.  Were they always entirely correct?  Probably they weren't.  We

 5     did our best.

 6             I have never -- I have asked when I was in Sarajevo, specifically

 7     also when General Rose was there, because although General Rose wasn't

 8     saying it publicly, as far as I was aware then, there were indications

 9     that he felt that some of the fire was indeed directed, as this report

10     would say, but we asked for a report and we never got one.

11             Without conclusive evidence being shown to me, I was not going to

12     make a report of that nature.

13        Q.   Thank you.

14             THE ACCUSED: [Interpretation] May I tender this document into

15     evidence now, please.

16             JUDGE KWON:  Yes.

17             THE REGISTRAR:  Your Honour, that will be Exhibit D240.

18             THE ACCUSED: [Interpretation] Thank you.  May we have 1D01226

19     called up next, please.  Thank you.  That's the first page.  May we turn

20     to page 2, please.  And I hope we have a translation.  Yes, we seem to.

21     Yes.  Yes.  Page 2 in both the Serbian and English please.  Thank you.

22             MR. KARADZIC:  [Interpretation]

23        Q.   This is a bulletin from the military security of the Muslim army,

24     and in the highlighted portion it says that:

25             "The military security service has knowledge of the fact that the

Page 3013

 1     citizens of Sarajevo are leaving the city also with the help of fake

 2     press accreditation.

 3             "Actually, journalists who have already been accredited in

 4     Sarajevo have received accreditations from their networks for individuals

 5     who are supposedly engaged by news teams and are thereby allowing them to

 6     leave the city," and in brackets it says "probably in return for monetary

 7     gain."

 8             Did you know about that?

 9        A.   No.  We never handed out our accreditations ourselves to anybody.

10     Locally, we brought people in only.  We certainly never ever took anybody

11     out of Sarajevo.  We did not transport other people.  We were there, sent

12     by news organisation in Britain, and we didn't deal with that kind of

13     thing.

14             What we did do was take a lot of mail out, for instance, from

15     Sarajevo, and we were once stopped at one of your check-points and we

16     were told that we were not allowed to -- to do that kind of thing, that

17     it was an illegal activity, until they saw that many of the letters were

18     actually addressed to people in Serbia, and then we were allowed to

19     continue with that mail.  But as far as smuggling people out on false

20     accreditations, certainly not.  We absolutely did not deal with that.

21        Q.   What do you think, Mr. van Lynden, about the regime or any regime

22     in any city that one cannot get out of unless one has some documents,

23     permits, whatever?

24        A.   I don't understand the nature of your question.

25        Q.   Did you report to your company that you could not leave the city

Page 3014

 1     of Sarajevo if you do not have a foreign accreditation, or, rather, the

 2     citizens of Sarajevo cannot travel, cannot leave town unless they have

 3     some accreditation?  Were you aware of that?  You were aware of that,

 4     weren't you?  You knew that people could not leave town.  Did you report

 5     about that?  Did you say that there was an inside blockade within

 6     Sarajevo and that they were not allowing people to leave town?

 7        A.   We certainly reported that the people of Sarajevo could not get

 8     out.  We also reported -- I mean, they couldn't get out normally as we

 9     could as accredited foreign media with UN accreditation, although often

10     that was difficult for us as well.

11             We also reported that people did try to get out.  For instance, a

12     lot of people from Sarajevo tried or sometimes managed, sometimes not, to

13     cross the airport and get out from Sarajevo into Budimir, and although I

14     never saw it, I believe that a tunnel was later dug to facilitate people

15     coming in and out of the town that was besieged by your forces.

16             Where -- I mean, you've asked me a whole number of questions.

17     One of them is that you're saying that these people were not allowed out

18     because their people didn't let them out.  That would be true up to a

19     point, but the basic point about Sarajevo is that it was besieged by your

20     forces who would have shot these people or taken them prisoner if they

21     had tried to get out.  They couldn't walk out or drive out like we did.

22     That was an impossibility.

23        Q.   Are you trying to say that the Serb side fired at people who were

24     crossing over to the Serb side?  Give us one single example of that.

25        A.   Mr. Karadzic, where were you?  That's what happened in the war.

Page 3015

 1     People couldn't leave Sarajevo.  They would have been fired upon.  In

 2     fact, even buses which were organised to get small children out of

 3     Sarajevo were fired upon.

 4             Now, can I say categorically that that was only done by your

 5     forces?  No, I can't.  Was I in the bus?  No, I wasn't.  But the basic

 6     truth of the siege of Sarajevo was that the people were besieged in that

 7     town, and that even if they had got their side to say, yes, you may

 8     leave, there had to then -- usually, the only people who could then take

 9     them out would be the UN.  That did happen on occasion, but not

10     otherwise.

11        Q.   Mr. van Lynden, who would they show this permit to when they

12     wanted to cross over to Serb territory?  Would they show it to the Serb

13     authorities or their own authorities in Sarajevo?

14        A.   Well, if you cross a front line like we had to, you would have to

15     first show your papers on one side and then drive through the no man's

16     land that always existed and then show it on the other side.  So you

17     would have to show it to both.

18             There were organised procedures at certain occasions when people

19     were allowed to leave.  We indeed filmed an old woman crossing from

20     Grbavica across the Miljacka into Bosnian territory when we were with

21     your forces in September, and we showed that.  That had been an

22     organised -- between the two sides that this old lady should be allowed

23     to cross.  I don't know the particulars of that old lady because we were

24     not told about it, but we were able to film her and we put her in that

25     report.

Page 3016

 1             So there were organised instances of people crossing from one

 2     side to the other, but for the normal population to just say, "Well, I'm

 3     now leaving town because I don't like it here anymore because I'm being

 4     shot at, and I'd like to go to another part of the country," that was

 5     impossible for them.  They would have known that they risked certainly

 6     arrest, probably imprisonment, and possibly death on arriving on the

 7     other side.

 8        Q.   They risked arrests and death from the Serb side you mean?  Is

 9     that what you're trying to say?

10        A.   From either side.  If someone had just tried to walk out of

11     Grbavica unannounced, it would have been the same thing.  This is what

12     happens when you have a front line in a war zone.  You can't just cross a

13     front line in a war zone, Mr. Karadzic, not when people have guns there

14     unannounced and say, "Oh, I just want to cross the other side."  It

15     doesn't work like that.  It's an extremely dangerous thing to do.  It's

16     the basic rule for war correspondents.  You don't cross sides.  We did,

17     and every time we did we got shot at.  For the normal population to do

18     this in such circumstances is unthinkable without it having been properly

19     organised beforehand, usually with the intervention of the UN.

20        Q.   Do you know, Mr. van Lynden, that we asked for the Brotherhood

21     and Unity Bridge to be opened for several hours a day for free passage to

22     one side and the other and that that is the way it was, sometimes?

23        A.   When such things would had been properly organised, then it would

24     have been possible.  I was never there when that happened, and I never

25     filmed it.  I've been at the Brotherhood and Unity Bridge.  I was there

Page 3017

 1     with General Rose in March 1994.  But I have never seen, "Okay, we'll

 2     just open the bridge and people can come backwards and forwards without

 3     any problem.  That absolutely did not happen, in my experience.

 4        Q.   Now, let us go back to this document.  A person has his own

 5     papers, documents, and he applies to leave but then he cannot leave.

 6     However, if he has the papers that a foreign journalist has, then he can

 7     leave.  That's what time talking about, Mr. van Lynden.  It's a question

 8     of papers, documents.  That is to say that citizens of Sarajevo were not

 9     allowed to leave of their own accord and on the basis of their own

10     documents, but they needed foreign documents in order to be able to

11     leave.  Isn't that right?  This is a Muslim document.

12        A.   I have never seen the document before.

13             JUDGE KWON:  Yes, Mr. Nicholls.

14             MR. NICHOLLS:  I believe that's been asked and answered

15     completely.

16             JUDGE KWON:  When first asked, Mr. van Lynden said that he didn't

17     understand the nature of the question, so now I think he put the question

18     and he said he didn't know.

19             THE WITNESS:  I mean, I can answer the question as far as --

20     firstly, I don't -- I haven't seen this document ever before.

21             The second thing is that what you needed as a foreign journalist

22     to get in and out were not papers from your own news organisation, but

23     you needed to get a UN pass.  For that you needed foreign documents.

24     Only with a UN pass could you cross backwards and forwards.  It's that UN

25     pass that your forces on the one hand and the Bosnian forces on the other

Page 3018

 1     hand would want to see.  With that we could, at our own risk, and it was

 2     risky every time we did it, we could go in and out of the city.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Thank you.  Do you know, Mr. van Lynden, that in London and

 5     during the Carrington Conference and later on in Geneva we -- well,

 6     rather under the mediation of Mrs. Sadako Ogata, the three parties signed

 7     an agreement on the right of civilians to move about freely provided that

 8     their trip is announced.  Then they would get an escort, et cetera.  Do

 9     you know that that was signed in accordance with the Geneva conventions

10     and that that was supposed to be observed?

11        A.   I'm aware of all sorts of things being signed, but they weren't

12     always carried out in reality.  I am aware that, for instance, in 1992

13     for the Barcelona Olympics a delegation from the Bosnian side, including

14     two athletes, if I remember a woman runner and a male judo fighter, were

15     allowed to leave under UN escort to the airport and then on a UN plane

16     to, I imagine, first to Zagreb and then on to Barcelona.  Therefore, it

17     could be arranged, and, yes, via the United Nations with announcement and

18     with agreement from both sides.

19             Thinking back on and in relation to the document that you are

20     showing to the Court at the moment, while I always brought producers with

21     me, other organisations employed whilst in Sarajevo, interpreters, or

22     producers who were locals, I am not aware of them taking those people

23     ever outside of Sarajevo.  They would have been given accreditation, but

24     it would have been considered too dangerous to take someone like that

25     outside of Sarajevo from one side of the front lines to the other side,

Page 3019

 1     because they would have been seen as either being a spy or whatever by

 2     the other side, and therefore, I'm not aware of -- it may have happened,

 3     but I'm not aware of any Western news organisation giving accreditation

 4     to a Bosnian and then getting them out of Sarajevo once that person had

 5     been given UN accreditation.

 6        Q.   And that's the way it was on both sides; is that right?

 7        A.   Well, we had a producer, for instance, Jaksa Scekic, in Belgrade,

 8     and he came out to Pale, but he never into Sarajevo.  No, that was his

 9     personal wish.  He thought that he might then be accused by the Bosnians

10     of being a spy or whatever.  So we did not do so.

11             The two field producers that I generally used in Bosnia, one was

12     Zoran Kusovac whose father is from Montenegro, his mother is from

13     Dalmatia, and who was born in Bosnia, and therefore he is a Yugoslav who

14     no longer has a nation, and he was considered as someone that I could

15     take to all sides.  And the other was a Hungarian Yugoslav from Novi Sad,

16     Apat Nehmet [phoen].  He was also considered that I could take him to all

17     sides, and we did.

18             As I said, other organisations employed Bosnian Serbs or Bosnian

19     Muslims in -- in Sarajevo or in Pale to help them with their work, and it

20     was generally not considered safe to bring those people to the other side

21     of the front lines.

22        Q.   Thank you.  As for the document, well, I don't expect that you

23     have seen the document.  I am actually referring to a phenomenon here

24     that you are aware of.  Did you know that criminals made tons of money by

25     transferring people, by getting them out of town?

Page 3020

 1        A.   I'm aware of the rumours.  I never saw proof while I was there,

 2     nor would I have been likely to.  If this was a criminal endeavour, they

 3     would not have shown it to the world's cameras.  I am aware that people

 4     were smuggled out of the city and whether the criminals were on one side

 5     or the other side or both sides making money out of smuggling people, I

 6     don't know.  I think it's probably likely that they were making money on

 7     both sides on the front lines.

 8        Q.   Thank you.

 9             THE ACCUSED: [Interpretation] Can this document be admitted into

10     evidence, this report of the service of the Muslim army?

11             JUDGE KWON:  Yes, Mr. --

12             MR. NICHOLLS:  I object to this one, Your Honour.  The witness,

13     when asked about it, when it was first read out to him, he was asked you

14     know about that and he said no, and there is no nexus in -- that hasn't

15     had any impeachment value.

16             JUDGE KWON:  Thank you, Mr. Nicholls.  We agree.  This will not

17     be admitted.

18             THE ACCUSED: [Interpretation] Well, may I just say that

19     Mr. van Lynden confirmed the existence of the phenomenon.  He confirmed

20     that he had heard had of such things, that people could not leave town.

21             JUDGE KWON:  He didn't say anything about this document.  Let's

22     move on.

23             THE ACCUSED: [Interpretation] Well, he won't be able to say

24     anything about any document, because I'm not asking him about documents.

25     I'm asking him about phenomena, occurrences, events.  He could not have

Page 3021

 1     seen these documents.  These were documents of the Muslim Secret Service,

 2     the military secret service at that.  Anyway, let's move on.  1D01228.

 3             MR. KARADZIC:  [Interpretation].

 4        Q.   While we're waiting for this -- ah, it's here.  Mr. van Lynden,

 5     do you know that citizens could orient themselves on the basis of whether

 6     TV crews were there or not?  They would expect something to happen,

 7     something bad to happen, when they'd see foreign journalists.

 8        A.   Foreign journalists tend to come to places when something bad is

 9     happening.

10        Q.   Unless they know in advance that something is going to happen;

11     right?

12        A.   We don't.  Practically never, Mr. Karadzic.

13        Q.   Well, this is a document again of the Muslim army.  Yet again

14     it's the security administration.  Can we have page three now.

15              "Reliable sources," that's -- ah, yes, right.  Here it is.  I'm

16     going to read it out in Serbian.

17             "A reliable source of the military security service of the

18     1st Corps who is close to the CNN news team observed that lately there

19     has been a greater presence of foreign media representatives in Sarajevo.

20     It was especially noticed that news teams are primarily composed of more

21     experienced war zone reporters who also reported on the Gulf War and who

22     would not have come to Sarajevo unless they expected that 'something

23     important was about to happen.'"  That was under quotation marks.  "The

24     source also relayed the information provided by one member of the CNN

25     team that 'some' rushed preparations are being observed in the NATO bases

Page 3022

 1     in Germany as well," the "some" was under quotation marks, "which can be

 2     seen from the higher transportation of soldiers and equipment as well as

 3     flights."

 4             What do you say to that?

 5        A.   Once again, I have not seen this document before, and I should

 6     also states that in my opinion if I had been shown these documents before

 7     I could maybe give -- would have been able to give you a more

 8     thought-through answer, but my instant reaction to this is that this is

 9     probably a bit of Bosnian wishful thinking.  We encountered it throughout

10     the war, that certain Bosnians would say to us, ah, this and this is

11     happening, which probably wasn't, or that -- I don't know where they'd

12     heard it from, in the hope of military intervention by NATO.  And as far

13     as I'm aware in August nothing was undertaken by NATO.  The only thing

14     that happened was a conference in London that did not help end the war in

15     Bosnia.

16        Q.   Do you know who it was that refused to take part in that

17     conference bona fide?  Let me be more precise.  Did you know that

18     Izetbegovic said that Silajdzic would go there but not to negotiate,

19     rather, to express his dissatisfaction?

20        A.   As I recall, Mr. Izetbegovic went to the conference himself.  I

21     recall meeting him there.

22        Q.   1993?

23        A.   No, August 1992.

24        Q.   This has to do with 1993.  All right.

25             THE ACCUSED: [Interpretation] Can this document be admitted?

Page 3023

 1             JUDGE KWON:  No, in the same manner.  The witness didn't say

 2     anything about this document.

 3             THE ACCUSED: [Interpretation] Well, I don't think he can say

 4     anything about secret documents.  It says here, "Military secret,"

 5     high --

 6             JUDGE KWON:  Mr. Karadzic, we gave our ruling.  Let's move on.

 7             THE ACCUSED: [Interpretation] I'm interested in the future.  What

 8     will I do with documents that witnesses had not seen before, but I would

 9     like the witnesses to state their views on particular phenomena rather

10     than actual documents.  Can I ask them about phenomena, occurrences?

11             JUDGE KWON:  You asked the question, and you got his answer.

12     Let's move on.

13             THE ACCUSED: [Interpretation] All right.

14             MR. KARADZIC:  [Interpretation]

15        Q.   Did you have occasion to see General Rose's book?

16        A.   I've seen it in a bookstore, yes.

17        Q.   May I ask you something from that book if you just saw it in a

18     bookstore, if you hadn't read it actually?

19        A.   No, I have not read the book.

20        Q.   But you did have meetings with General Rose, and you received

21     information from him.  So --

22        A.   I never received any information from General Rose.  I did have a

23     couple of meetings with him and one interview with -- in front of the

24     television camera, but I never got any information from General Rose, no.

25        Q.   But you did receive information from persons who were under his

Page 3024

 1     command, right, his people?

 2        A.   I did get information during 1994 when General Rose was in Bosnia

 3     from various elements of the -- of UNPROFOR, yes.

 4        Q.   What about 1992?  You didn't receive any information from

 5     UNPROFOR?

 6        A.   Yes, I did, but not from General Rose because he wasn't there.

 7        Q.   Thank you.

 8             THE ACCUSED: [Interpretation] 1D1037.  Could I have that, please.

 9             MR. KARADZIC:  [Interpretation]

10        Q.   While we're we are waiting for that, I'm not talking about

11     General Rose in personal terms.  I'm talking about UNPROFOR, the united

12     nations, the military wing of the United Nations, that you received

13     information from.

14             THE ACCUSED: [Interpretation] 1D1037.  And then could we have --

15     yes.  It is page 243 and 244.  Page 243 and then page 244 of the book,

16     this book, that is.  That's the number of the book.

17             MR. KARADZIC:  [Interpretation]

18        Q.   Towards the bottom of the page, "My own theory."  Do you see that

19     bit, "My own theory of this misrepresentation."

20             "[In English] My own theory at this misrepresentation of the

21     truth did little to stem the tide of propaganda.  The perception of many

22     US east coast commentators is that during the fighting in Gorazde in the

23     UN -- the UN deliberately misled the world about what happened,

24     underestimated the scale of the disaster, and was economical with the

25     truth.  I explained that most of the damages -- damaged houses in Gorazde

Page 3025

 1     revealed by US air reconnaissance had not been destroyed in the fighting

 2     and took -- that took place in this -- in the town in April 1994.  They

 3     had been destroyed in 1992 when the Muslims drove the Serbs from the town

 4     and surrounding area.  These former Serb homes had no roofs, window

 5     frames, or doors, and had been stripped of all furniture and fitting --

 6     fittings.  Many of them had been tortured -- torched.  They were

 7     demonstrably not buildings recently subjected to shelling.  Today, the UN

 8     still stands condemned for having underplayed the damage done by the

 9     Serbs in Gorazde."

10             [Interpretation] As you reported about Gorazde, did you know how

11     the Serbs had fared in Gorazde in 1992?

12        A.   I was first in Gorazde at the beginning of 1993, in February,

13     beginning of March.  We met Serbs living there, including and going to

14     one small village which was entirely populated by Serbs.  So precisely

15     what occurred in the spring of 1992 in Gorazde, I don't know and I didn't

16     see with my own eyes.  There was clearly fighting there as there was in

17     the whole of Eastern Bosnia, and clearly many people from other areas of

18     Eastern Bosnia who had been forced by your forces to flee their homes and

19     their villages and their towns had moved into Gorazde, and there had been

20     fighting there as well.  But to the precise nature of what happened to

21     the buildings that General Rose is referring to, I don't know.  I don't

22     think that General Rose was in Gorazde in 1992, either, so I don't think

23     he knows.

24             What I do know in relation to Gorazde of 1994, which he refers

25     to, is when we met General Rose in March 1994 in Sarajevo after having

Page 3026

 1     been in Pale, we informed him that we had had information while in Pale

 2     that Gorazde would be attacked by the forces under General Mladic in

 3     April 1994.  General Rose's reaction at that time was that how could we

 4     know such a thing and that we were wrong, and we said we did not know for

 5     certain but that we had spoken to certain people while we were in Pale to

 6     had warned us that this was going to happen.

 7             As far as I can judge, General Rose didn't bear that warning from

 8     us, and pretty unfortunate circumstances arose in April 1994, including

 9     the loss of life of one of General Rose's personal soldiers.

10        Q.   What you mean to say is that the military secret of Mladic's army

11     was something that you could hear around the streets of Pale, these

12     military secrets going round?

13        A.   We were wary with the information.  One always is.  You get to

14     hear a lot of rumours if you're a journalist in a war zone, and much of

15     the rumour is incorrect.  We had heard, not on the streets but from,

16     let's say, more informed contacts that specifically Jaksa Scekic had

17     built up there that an attack on Gorazde by General Mladic was likely in

18     April, and we simply passed that on to General Rose and were slightly

19     surprised by his reaction at the time, because he dismissed it out of

20     hand, which of course it's his right to do, but as it turned out, we were

21     right and the information was correct.

22        Q.   And can you tell me when the Serb army attacks Gorazde with an

23     offensive that it wasn't a counter-offensive?  When did the Serb -- when

24     was it that the Serb army attacked Gorazde without any provocation from

25     Gorazde?  Quote me a single example if you can.

Page 3027

 1        A.   It's clear, Mr. Karadzic, that for you everything is only ever a

 2     counter-offensive.  No one ever shot at the Bosnians until the Bosnians

 3     shot at the Serbs.

 4             I'm sure that there were instances where the Bosnians did shoot

 5     first, leading to a counter-attack.  Was I in Gorazde at that time?  No,

 6     I wasn't.  Is the information that I've just given to this Court correct

 7     that we were told in Pale in March 1994 that an attack was likely in

 8     April on Gorazde, yes, that information is correct, and did such an

 9     attack occur?  Yes, it did.  Can I say absolutely that it's the whole

10     truth and nothing but the truth that this was not to a degree a

11     counter-offensive?  No, I can't.

12        Q.   Very well.  Now, were you in Eastern Bosnia and did you see with

13     your very own eyes how my forces -- did you see my forces expelling

14     Muslims from their houses and sending them away from Gorazde, expelling

15     them?  Did you ever see that with your very own eyes?

16        A.   From Gorazde, no, because Gorazde remained an enclave that held

17     out.  We went through various other places where houses had been torched,

18     villages that were empty.  We met people who had been forced to flee from

19     villages and towns right across Eastern Bosnia.  When we were in Gorazde,

20     we met a lot of these people who were living in schools or wherever else

21     they could who were refugees from other areas.  Did I actually see it

22     myself?  No, I wasn't in Bosnia in March, April, May 1992, but this is

23     what we always heard and others did witness.  For instance, in Bijeljina,

24     Ron Aviv [phoen] saw it happening.

25        Q.   But you said a moment ago that in Gorazde there were people who

Page 3028

 1     were expelled by my forces as if you'd seen it yourself.

 2        A.   Well, I did meet the people, yes, and that's what they said.

 3        Q.   I see.  Well, they said that, but you don't know that for a fact.

 4     You have no other proof and evidence apart from what they told you;

 5     right?

 6        A.   Well, I have proof and evidence that they were living as refugees

 7     in Gorazde, where the population had certainly tripled from what it was

 8     before the war.  And it was confirmed by everyone there, including by the

 9     Serbs who were living inside the enclave.

10        Q.   And were there Serbs living within the enclave in Gorazde?

11        A.   I've already testified there were.  There was at least one

12     village where we were taken, including a man who actually had a firm in

13     Rotterdam and with whom I was able to speak in Dutch.

14        Q.   But you saw him in Serb Gorazde, that is say the Serbian part of

15     Gorazde, not the Muslim part; right?

16        A.   No.  I met him within the enclave controlled by the Bosnian Army.

17        Q.   All right.  Now, at the beginning of 1993, were you in

18     Srebrenica?

19        A.   No.

20        Q.   All right.  We'll come back to that and deal with that later on,

21     but may we have 1D982 next, please.

22             This excerpt from General Rose's book, can I tender it into

23     evidence, where he writes about how foreign journalists report on the

24     situation showing Serb houses to be Muslim houses and so on?

25             JUDGE KWON:  Mr. Nicholls.

Page 3029

 1             MR. NICHOLLS:  I don't have it in front of me.  I don't see

 2     that -- I can't see that reference, but I don't object to this page we've

 3     just been looking at.

 4             JUDGE KWON:  Page 174 was previously admitted, but the Bench will

 5     confer.

 6                           [Trial Chamber confers]

 7             JUDGE KWON:  The witness said nothing about the book, so we'll

 8     not admit that part of the book.

 9             THE ACCUSED: [Interpretation] Thank you.

10             MR. KARADZIC:  [Interpretation]

11        Q.   Now, do you know what happened in Gorazde in 1994?

12        A.   Well, during the entire year?

13        Q.   At the time you were -- at the time you asked about Gorazde.

14        A.   I was in Gorazde in -- for a couple of weeks in March 1993, and I

15     have never returned to Gorazde after that.

16        Q.   And what period did you alert Rose to?  1994; right?

17        A.   Yes, but then I left Bosnia, and I was actually in Belgrade when

18     the offensives, whomever may have launched them initially, took place at

19     Gorazde, and it was at that period that I received a letter from the

20     Yugoslav authorities telling me that I was persona non grata and that I

21     had to leave the country, and so I 48 hours to leave Belgrade and return

22     to London.

23        Q.   Well, this is the first time I hear of anything like that,

24     Mr. van Lynden.  All the Serb presidents received you for interviews and

25     dinners after interviews, and suddenly in 1994 you say you became persona

Page 3030

 1     non grata.  How do you explain that?  [Overlapping speakers]

 2        A.   For life, Mr. Karadzic.  I think I can go back to Serbia now.  I

 3     don't think Mr. Milosevic can.

 4        Q.   Yes, but you had that kind of approach and access, whereas we

 5     received bias reports from you.  So we couldn't have won the media war,

 6     because you had access wherever you wanted to.  President Milosevic,

 7     President Karadzic, you could go there officially and privately, but we

 8     achieved nothing with you.  So that is why 1994 you deserved being

 9     considered that you were detrimental to their state interests in Serbia.

10        A.   That is --

11        Q.   Do you agree with that?

12        A.   That is your opinion.  No.  I just absolutely disagree with that.

13     I think it was important that international correspondents were given

14     access, and throwing journalists out is not the right response and only

15     damages those who do the throwing out.  I don't think this is the place

16     to have a debate as to Serbian policy with the foreign media.  I

17     personally believe it to be very mistaken from the beginning.  And what

18     you stated earlier of me being -- having private access to Mr. Milosevic

19     is utter nonsense.  I met him once.  I did an interview.  He invited me

20     for one drink afterwards and that was it.

21             I never had dinner with you, as far as I can recall.  I was

22     invited for drinks on several occasions.  I was once invited by

23     General Mladic for lunch.  That is the sum total.

24             In other parts of the world I've had more access, far more

25     access, with the leaders of the countries.

Page 3031

 1        Q.   Very well.  Now things are much clearer.  Now, let's turn to page

 2     6 of this report, please, by General Janvier.  Can we go down to

 3     "Similar."  "Similar to what happened."

 4             "[In English] Similar to what happened in Gorazde (spring 94) the

 5     BiH can attempt to draw UNPROFOR (including the rapid reaction forces) of

 6     NATO into the conflict on the BiH side.  Sudden abandoning of positions

 7     along the confrontation line, the simulation of a collapse of the

 8     enclave, or alarming reports from Bosnian side on the situation in the

 9     enclaves, will be indicators for this.  A stronger involvement of the

10     international community would be interpreted by the Bosnian Serb Army as

11     an incentive to step up operations and try to eliminate the enclave, as

12     well as retaliate against the UN forces.

13              "Based on the tank firings that occurred at Zepa yesterday,

14     similar BSA efforts at Zepa could occur in the next few days."

15             [Interpretation] Therefore, Mr. van Lynden, you see that

16     General Janvier is reporting here about the trickery, the tricks, that

17     took place in Gorazde, with the stage collapse of the lines, the

18     infiltration of the United Nations into the conflict, throwing out UN

19     soldiers, and then once they withdraw, they remain in an encirclement of

20     ours.

21             Now, do you see what was going on in Gorazde when you were there?

22     And it's the event that you draw Rose's attention to; right?  Warned him

23     about it.

24        A.   I was not there.  When I was there in March 1993, there was

25     actually almost no fighting going on whatsoever.  There was a lot of

Page 3032

 1     snow.  What we had warned General Rose about in March 1994 was that what

 2     we had been told while we were in Pale.  We know that fighting took place

 3     at April 1994 around the Gorazde enclave.  That we can agree.  Do I know

 4     the precise nature of that fighting?  No, I wasn't there at the time.

 5             My only -- I cannot react to what -- Janvier is saying this for

 6     reasons best known to General Janvier.  The one enclave I was in in 1994

 7     was the Bihac enclave which, and I spent several weeks there, and I saw

 8     with my own eyes that that enclave was attacked not only from within

 9     Bosnia but also by Serb forces in Croatia across the line that the UN was

10     meant to stop them from doing so and the UN did nothing.  That I know

11     because there I was and I saw it.  I wasn't there in Gorazde in the

12     spring of 1994.  The only thing I testified to this Court was that in

13     March I told General Rose what we had been told in Pale.  Given the fact

14     that there was fighting in the Gorazde enclave in April 1994, I don't

15     think that information was completely wrong, although I don't know the

16     precise nature of the beginning of that fighting, which is what you're

17     alluding to.

18        Q.   But General Janvier is reporting about the same thing, and he

19     says that there were tricks to involve the UN forces or NATO in Gorazde.

20     So you say that you heard about this from someone in Pale, although I

21     doubt that anybody knew Mladic's plans at the time or that he had any

22     plans to attack Gorazde for that matter.  Now, what about Bihac?  Is that

23     the full truth, or is the truth of it that from Bihac they took about 300

24     square kilometres and almost reached Bosanski Brod which was purely Serb

25     territory, and then in a counter-offensive General Milovanovic managed to

Page 3033

 1     return it to the enclave?  Do you know that before that that they -- the

 2     Muslims had arrived at almost Bosanski Petrovac, that line from the

 3     protected area?

 4        A.   In a war both sides launch offensives, Mr. Karadzic.

 5        Q.   But, you have represented it as the Serbs attacking Bihac.  The

 6     Serbs, first of all, had to liberate 300 square kilometres or even more

 7     territory, to liberate it and then to reach the outskirts of Bihac

 8     through a counter-offensive.  That's what it's about.  And we see what

 9     General Janvier says about that.

10             Now, are you challenging the observations made by General Janvier

11     here?

12        A.   I can absolutely not confirm them.

13        Q.   Well, do you challenge them then?  Do you believe what he says or

14     not, or do you disbelieve it?  Can -- is General Janvier somebody who can

15     be believed or not?

16        A.   When I was with the Bosnian forces in Bihac, and you're right

17     that there was a counter-offensive by the Serb, but there was also a

18     counter-offensive from Croatia which was meant to be a UN protected area,

19     and that was not meant to happen.

20             I have not witnessed the Bosnian forces behaving in the manner

21     described by General Janvier.

22        Q.   Thank you.  And do we agree that the Serb forces from Croatia

23     were in Abdic's campaign and not campaigning of their own accord?  And

24     was Abdic at war with the Bihac 5th Corps at the time?

25        A.   Abdic was up in Velika Kladusa, but there were attacks also from

Page 3034

 1     other areas in which the Croatian Serb forces became involved.  Two

 2     different things.

 3        Q.   Mr. van Lynden, the forces of the Croatian Serbs were in an

 4     alliance with Abdic.  So they didn't go to Bihac for themselves, but

 5     Abdic laid down the right to have Bihac and that whole enclave; right?

 6        A.   The Croatian Serbs were part of a UN protected zone and were

 7     coming across an international border and should not have been allowed to

 8     do so.

 9             THE ACCUSED: [Interpretation] This document is already an

10     exhibit, so I'm not going to tender it now, Your Excellencies.

11             JUDGE KWON:  Could we be informed of the exhibit number of this

12     document.

13             THE REGISTRAR:  Yes, Your Honour.  This was admitted as

14     Exhibit D137.

15             JUDGE KWON:  Thank you.

16             THE ACCUSED: [Interpretation] Do we have some more time before

17     the break?

18             JUDGE KWON:  We will have a break, after which you will have

19     three-quarters of an hour, Mr. Karadzic.

20             Twenty-five minutes.

21                           --- Recess taken at 3.36 p.m.

22                           --- On resuming at 4.02 p.m.

23             THE ACCUSED: [Interpretation] Thank you.  May I have 1D1037.

24     It's Rose's book.  We were looking at it earlier on.

25             MR. KARADZIC:  [Interpretation]

Page 3035

 1        Q.   And while we're waiting for that to come up, Mr. van Lynden, let

 2     me tell you why this is important for me.  We had a witness here who

 3     said -- well, he made some assertions, and when -- yes.  Can I have page

 4     54 of this book.  But when I asked him, the witness, how he knew about

 5     that he said, "Well, it's common knowledge, generally accepted."  So

 6     public opinion crops up as proof and evidence as a document.

 7             Now let's see how General Rose views this, and let's turn to page

 8     54 for that.

 9             THE INTERPRETER:  Microphone, please.

10             MR. KARADZIC:  [Interpretation]

11        Q.   "I was beginning," that paragraph.

12             "[In English] I was beginning to be able to distinguish between

13     those journalists who unquestionably used material provided by the

14     Bosnian government propaganda machine and those who were interested in

15     presenting a more objective view of the war.  Much seemed to depend on

16     individual personalities and what sort of relationship the reporters had

17     developed with the female interpreters attached to all foreign news teams

18     by the Bosnian government.  Not all the journalists in Sarajevo were

19     biased, and I worked with many courageous reporters who often put their

20     own lives at risk in order to discover the truth.  Kurt Schork, an

21     American who had been at Oxford with President Clinton and worked for

22     Reuters, and Remy Ourdan, a Breton who reported for "Le Monde," were two

23     such people.  A television news clip once showed Kurt running out from

24     under cover and heavy mortar fire to pull a wounded woman to safety."

25             [Interpretation] And so on.  Therefore -- therefore,

Page 3036

 1     Mr. van Lynden, wouldn't it be nice if on this list we were to find the

 2     Sky News team?

 3             JUDGE MORRISON:  Dr. Karadzic, that's an observation, not a

 4     question.  A rhetorical question.  I'm sure the witness would be jolly

 5     pleased to see the Sky News team on a list depending on what the list

 6     said.  But this is obviously simply the individual subjective view of the

 7     author of the book, is it not?

 8             THE ACCUSED: [Interpretation] But, Your Excellency, he was the

 9     commander, the United Nations commander, and he has this ongoing

10     criticism saying reporting from the area was being done erroneously to

11     the detriment of the Serbs, and then he quotes these two courageous

12     people and unbiased people, but the Prosecution did not call those two

13     people into court here.  And on the other hand, I think that Sky News

14     would have liked to find itself on this list of unbiased people and

15     courageous people, but my question is as follows:

16             MR. KARADZIC:  [Interpretation].'

17        Q.   Mr. van Lynden, do you accept that large number of

18     journalists - let's leave Sky News aside for a moment - that they were

19     furnished with news by the Presidency, information from the Presidency?

20     Now, you didn't have a female interpreter that the Presidency provided

21     you with, but others did.  So do you agree that the use of information

22     predominantly from the Presidency was biased and one-sided?

23        A.   Mr. Karadzic, in my opinion, and I have not read this book as I

24     have already testified, the line that General Rose uses, "what sort of

25     relationship the reporters had developed with the female interpreters

Page 3037

 1     attached to all foreign news teams by the Bosnian government," that line

 2     should have warned you not to use such things.  It's a -- firstly, it's

 3     absolutely not true, and General Rose might have known that.

 4             The assertion in the line that basically all the foreign

 5     correspondents were being charmed by Bosnian young ladies at the

 6     instigation of the Bosnian government, that's within this line, is a

 7     terrible one and again is not true, and you should -- you should have

 8     been warned by that.

 9             Secondly, your assertion that Kurt Schork, who was killed ten

10     years ago, should be a witness at this Tribunal I find fairly shocking.

11     You should also note, Your Honours, that a street in Sarajevo is named

12     after Kurt Schork, who was very critical of the Bosnian Serbs and was

13     also critical of the UN and who was a great personal friend of mine.  We

14     often worked together.

15             I think that's really all I want to say about this piece from

16     Mr. Rose's book.

17        Q.   General Rose says that he could distinguish between two types of

18     journalists.  So there were both sorts.

19             Now may we look at page 69 and 70, please.

20        A.   I would just say to that there were many more than just two

21     sorts.  The world is more complicated than that.

22             JUDGE MORRISON:  Mr. van Lynden, if I remember rightly and you'll

23     correct me if I'm wrong, wasn't Kurt Schork later killed reporting in

24     Sierra Leone?

25             THE WITNESS:  You're absolutely right.

Page 3038

 1             THE INTERPRETER:  Microphone, please.

 2             MR. KARADZIC:  [Interpretation]

 3        Q.   [In English] Many journalists [Interpretation] Let's look for the

 4     paragraph beginning with "Many journalists."  On page 69, towards the

 5     bottom, I believe.

 6             "[In English] Many journalists -- many journalists in Sarajevo

 7     also supported the war option, either because they believed that it was

 8     morally right to engage in some form of holy war against the Serbs or

 9     else because images of war -- images of war sell better than those of

10     peace.  A journalist working for a leading London newspaper summed up

11     this view when he told Simon Shadbolt that he did not care about the

12     facts or the UN arguments in favour of peace, his object was to get the

13     West involved in a war in Bosnia."

14             [Interpretation] Do you believe that there were such cases?

15        A.   I absolutely do not believe that any journalist that I ever

16     encountered in Bosnia believed in any kind of holy war against the Serbs.

17     That's something in the Serb figment of the imagination.  That's utter

18     nonsense.

19             And an unnamed journalist working for a leading London newspaper,

20     I'm surprised General Rose could write such things.  I really cannot

21     comment further on that.  I'm pretty outraged to read something like

22     that.

23        Q.   Well, I would be surprised if he had written that nothing like

24     that existed.  It obviously existed and so General Rose took that

25     position and view; right?

Page 3039

 1             MR. NICHOLLS:  Objection to the comment.

 2             THE ACCUSED: [Interpretation]  It's not a comment.  It's a

 3     question.

 4             JUDGE KWON:  What is your question?

 5             MR. KARADZIC:  [Interpretation]

 6        Q.   Isn't it right that Rose wouldn't have written that had that not

 7     existed?  Why would Rose have written this paragraph if that's not how

 8     things were?

 9             JUDGE KWON:  It's not for the witness to comment upon the mind of

10     Mr. Rose.  Let's not move on to another topic of yours.

11             THE ACCUSED: [Interpretation] Can these pages be admitted?

12             JUDGE KWON:  No.

13             MR. ROBINSON:  Excuse me, Mr. President.  I wonder if you might

14     consider that a little bit longer.  I think that this was -- it's

15     particularly the first passage.  There was something that was within the

16     knowledge of Mr. van Lynden concerning the foreign journalists and how

17     they were treated by the Bosnian government.  He spoke to that.  It was

18     not consistent with General Rose, but nevertheless he spoke to that, and

19     I think under your most resent guidelines this is at least a closer

20     question and in my view should be admissible.  I would note also that

21     General Rose is coming as a witness in this case for the Prosecution,

22     which would make it more useful for the Chamber to have this material

23     before it.  Thank you.

24             JUDGE MORRISON:  Well, Mr. Robinson, that's going to be the

25     occasion for whatever General Rose testifies about.  If he wishes to

Page 3040

 1     align that to material contained in his book, he'll be free to adduce

 2     that as being something inconsistent with the testimony he's going to

 3     give.  But what in fact Mr. van Lynden did was to state his own views and

 4     not adopt the views that were contained in the book.  So it seems to me

 5     that under whatever policy one uses for the admission of documents, this

 6     is still not a document which has been adopted by the witness.  In fact,

 7     Mr. van Lynden went out of his way to disassociate himself with the

 8     document in general and parts of it in particular.

 9             JUDGE KWON:  There was a unanimous decision of the Chamber.

10     Let's move on.

11             THE ACCUSED: [Interpretation] Thank you, 1D1294.

12             MR. KARADZIC:  [Interpretation]

13        Q.   While we're waiting for this document, Mr. van Lynden, I would

14     like to inform you why it is that I want to put these things before you.

15     You said that the Green Berets are a figment of the Serbs' imagination.

16     You also said that other things had to do with imagination as far as the

17     Serbs were concerned, namely that the Muslims were inflicting harm on

18     themselves.  You did admit that the Serbs were misportrayed a bit in the

19     media.  But anyway, let's see what the conditions were.  Under which

20     conditions were we waging war and under which conditions are these --

21     these proceedings taking place, and to what extent was I satanised?

22             JUDGE KWON:  Yes, Mr. Nicholls.

23             MR. NICHOLLS:  Well, one, it's a large compound question, but for

24     this question I would request that the guidelines be followed and I be

25     given cites to the testimony.  I'd like to know which portions of the

Page 3041

 1     direct or earlier cross Mr. Karadzic is referring to if he knows.  If he

 2     has no cites whatsoever, then I'll allow this to keep moving on, but if

 3     he is knows what parts he's talking about, I'd like to know which pages.

 4             JUDGE KWON:  Mr. Karadzic, you said that the witness admitted

 5     Serbs were misportrayed a bit in the media.  Could you direct our

 6     attention to what portion you are referring to?

 7             MR. NICHOLLS:  And, Your Honours, that the -- the Muslims were

 8     harming themselves was a figment of imagination.

 9             THE ACCUSED: [Interpretation] I'm waiting for the interpretation,

10     Excellency.

11             Now, this is the way it is:  During his interview with me and

12     while he testified here Mr. van Lynden said that he had not seen the

13     Green Berets and that the Green Berets were a figment of the Serbs'

14     imagination.  Whereas in the interview he said to me, and he confirmed

15     that here, that the weakest point of our defence is the claim that the

16     Muslims fired at their own people.  We have all of that on the record.

17     We heard all of that in this courtroom.

18             JUDGE KWON:  What is your question in relation to this document?

19             THE ACCUSED: [Interpretation] Could I have page 7519.  1D007519.

20     Page 6 if you count them.  7514 is the first one, so we need 7519.

21             JUDGE KWON:  Could you tell us what book this is about?  Who

22     authored this?  Who compiled this?

23             THE ACCUSED: [Interpretation] This is a book that was compiled by

24     Zoran Petrovic, Piro Canac [phoen], Vesna Hadzivuckovic [phoen], and

25     Tomislav Kresovic.  It was published in 1994; that is to say, it was up

Page 3042

 1     until 1994 that the attitude of the foreign media was analysed.  I mean,

 2     vis-a-vis the war in Bosnia-Herzegovina.

 3             Can we lower this?  Can we scroll down so that we see the picture

 4     that was in the "Chicago Tribune."

 5             MR. KARADZIC:  [Interpretation]

 6        Q.   Take a look at this, Mr. van Lynden.  Serbs are these pigs and

 7     the Russians are those other pigs, although it says "Commies" in all

 8     fairness.  How would this affect the public opinion in America?

 9        A.   Probably not very much, because it didn't seem to change American

10     policy as far as I could judge.  I see it's the 1st of January, 1993.  As

11     far as I'm aware, the American military intervention, when it did take

12     place, was in August 1995.  And I can't really comment on the effect

13     of -- on a whole nation by one cartoon in one newspaper in the

14     United States, Mr. Karadzic.

15        Q.   Is this fair reporting, Mr. van Lynden?

16        A.   It's not reporting, Mr. Karadzic.  It's a cartoon.  If you look

17     at the cartoons, there was a famous cartoonist working for Vreme.  Is

18     that anti-Serb as well?  I believe he was a Serb.  I believe he was

19     pretty effective with his cartoons, certainly for the Serb population as

20     to what he was doing.  I mean, you could put his cartoons there and you

21     could ask the same questions.

22        Q.   Thank you.

23             THE ACCUSED: [Interpretation] Can we have page 7538.  Thank you.

24             MR. KARADZIC:  [Interpretation]

25        Q.   Up here we see it says "Muslims slaughter their own people."

Page 3043

 1     However -- actually, we are not going to deal with that now.  We saw it

 2     elsewhere.  Let's look at the photograph down here.  Could we have the

 3     lower part of the page, the photograph.  This is what we discussed:

 4             "[In English] I saw a TV camera crew and an ambulance standing

 5     nearby, half an hour before.  Everything was stage managed."

 6             [Interpretation] This is Vasa Miskin street or, rather, the bread

 7     line.  What I have put to you already, Mr. van Lynden, this is a lady

 8     obviously from Sarajevo.  There is this belief in Sarajevo:  When you see

 9     foreign journalist, run.  Do you believe that now when you see this

10     statement made by this Muslim lady as to what it was that had happened

11     there, namely that the media had been informed in advance as to what

12     would happen?

13        A.   I have never been informed in advance as to what will happen.  We

14     were never taken to a position and told something's going to happen here

15     for you to film.  I have never been told by any of my colleagues of that.

16     So, no.  I mean, neither side or any of the three sides, no one ever took

17     me anywhere beforehand and said something is going to happen for you to

18     film.  No.  I am totally unaware of that.  I am completely unaware of any

19     crew being taken anywhere either.

20        Q.   Thank you.  7564 now, please.  Mr. van Lynden, did you ever

21     mention rape in your reports, the Serb campaign of raping Muslim women as

22     a war strategy -- or, rather, a means employed in war?

23        A.   We did towards the end of 1992 report and interview various women

24     to this who told us what had happened to them, that they had been held,

25     some for weeks, some for even longer, and been raped.

Page 3044

 1             Did we mention that this was a strategy of war?  No, we did not

 2     until the full size of this operation was revealed in UN and EU studies.

 3     As a lone correspondent working in a war zone, you -- you -- lone -

 4     that's in single for the translation, "l-o-n-e," not "alone" -  you don't

 5     have the resources to go around interviewing everyone, but when the

 6     reports come out by the EU and the UN saying that tens of thousands of

 7     women had been raped and that in the opinion of those who put the reports

 8     together this had been a strategy of war, yes, quoting those documents we

 9     did report that.  But that's later in the war.

10        Q.   Have a look at this, what it says here.

11             "[In English] There is no evidence such camps exist or ever

12     existed.  Philippe Misery, official of the International Red Cross.

13             [Interpretation] That's what he said in relation to these camps.

14     Once the story about the death camps would not hold water, then it was

15     rape camps that were launched, and the figure that was used was even up

16     to 60.000; right?  60.000 was referred to most often, but the figure

17     actually went up to 80.000; isn't that right?

18        A.   I have heard people go up to 80.000, yes, but as far as I can

19     recall, that is not the figure that was used in the EU and UN reports.

20     Did we actually report on rape camps?  No, we did not.  Was I ever taken

21     to one?  No, I was not.  The figures as I remember them from the UN and

22     EU reports talked of figures of over 20.000.

23        Q.   Do you know ultimately how many raped women there were?  Muslim

24     women that were raped.  I'm not referring to Serb women now.  Muslim

25     women that were raped.  How many they ultimately found.  How many cases

Page 3045

 1     were actually confirmed?

 2        A.   No.

 3        Q.   Do you believe that it's a two-digit figure?

 4        A.   I have only in later reports basing myself on the reports of the

 5     EU and the UN reported that this had happened to somewhere around 20.000

 6     women, possibly more, because that's what those reports put together by

 7     large teams of people claimed.

 8        Q.   Do you know that these reports did not actually stand for long?

 9        A.   No.  That's not my understanding.

10        Q.   Thank you.  7579.  Could we have that now, please.  Sorry, first

11     7583.  7583 first.  Of this book that is.

12             While we're waiting, Mr. van Lynden, did you know how many

13     prisons there were for Serbs in Sarajevo, and did you know about the

14     Serbs, the thousands of Serbs, who were detained at the Kosevo stadium?

15        A.   No.  We asked for figures, and we asked to be taken to prisons in

16     Sarajevo.  I never was.  I was taken to a prison in Gorazde, and I was

17     taken to a prison in Bihac where we were able to speak to the prisoners,

18     but I was never given the opportunity to speak to the prisoners held

19     within Sarajevo, nor was I ever given a figure of how many people were

20     held there.

21        Q.   Are you disputing the fact that there were 127 prisons in

22     Sarajevo, many of which were private prisons where Serbs were held as

23     slaves?

24        A.   I am not in a position either to confirm or to dispute those.

25     I'm simply saying I did not know.  We asked, and I wasn't told, and I

Page 3046

 1     wasn't brought to any of those prisons.

 2        Q.   Tell me, if that were to be proven to be true, would you think

 3     that the Muslim government had deceived you and put you in a position not

 4     to know about 127 prisons and not to know about thousands of Serbs being

 5     detained in Kosevo stadium?  Do you think that this was a very serious

 6     matter that you did not report on?

 7        A.   In all war zones one tries as best one can to see as many

 8     prisoners and to film as many prisoners as possible.  Also to a degree to

 9     do them a personal service.  If you film someone still alive, it makes it

10     much harder for whatever side in a war zone to kill them.

11             We tried to do that in Sarajevo.  I personally did not succeed,

12     and that is all I can say about this.

13        Q.   Thank you.  Could you please have a look at this page.  This is

14     how "The Independent" saw us on the 29th of May, 1992, how we were

15     portrayed.  What you see here, does that correspond to your experience

16     with the Serbs?

17        A.   No.

18        Q.   Thank you.  Can we now have 7 -- 7579, rather.

19             Mr. van Lynden, you reported about the humanitarian situation

20     there and the like; right?  Could you please cast a glance at this.

21              "[In English] Humanitarian aid delivered by road through a

22     corridor across Serbian territories from April the 1st to 23rd of August,

23     1993."

24             [Interpretation] Do you see that?  Muslims got nine times more

25     flour than the Serbs did.  Biscuits, 100 per cent more.  Sugar, 26 times

Page 3047

 1     more.  Then cooking oil, 74 tonnes.  The Serbs didn't get any.  And so on

 2     and so forth.  So what does this look like to you?

 3        A.   I don't see anything about what the Serbs got or -- oh, I see now

 4     what you're referring to.

 5             I imagine this is a reference to UNHCR aid, and if it's an UNHCR

 6     document, I do not dispute it.  I don't know if it's right or wrong.

 7     What I would say is that on the one hand a besieged enclave was being fed

 8     because it was its only source of sustenance was largely food brought

 9     from the outside, and then on the other side of the front line it's a

10     different situation.  There were farms and openings for the Bosnian Serbs

11     to get food through the normal manners.  And I suspect that you would

12     have to get someone from the UNHCR who is an expert on this kind of thing

13     to answer your question properly.

14        Q.   Could we scroll down a bit.  Mr. van Lynden, you know, that

15     Serbia was under sanctions and we could only trade with Serbia.  After

16     that, Republika Srpska was under sanctions as well, even sanctions

17     imposed by Yugoslavia; right?

18        A.   I do not believe that the Republika Srpska was under sanctions

19     imposed by Yugoslavia.  Indeed, we filmed -- after Mr. Milosevic had

20     announced those sanctions we filmed those sanctions being broken,

21     specifically as far as petrol and oil was concerned.  Yes, there were

22     sanctions for Serbia imposed by the UN, but these were regularly broken.

23     All sides, from Macedonia, from Romania, from Bulgaria, something that we

24     also filmed.

25        Q.   Thank you.  In relation to this -- actually, we have to go into

Page 3048

 1     closed session.  Can we have 1D02182.  We are going to be in closed

 2     session very briefly.  1282, actually.

 3                           [Private session]

 4   (redacted)

 5   (redacted)

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 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

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21   (redacted)

22   (redacted)

23   (redacted)

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25   (redacted)

Page 3049











11  Pages 3049-3052 redacted. Private session.















Page 3053

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10   (redacted)

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16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21                           [Open session]

22             JUDGE KWON:  I think you showed four or five pictures or

23     clippings from that book, but I'm not satisfied with the relevance of the

24     first one, and then the -- as to the remaining one, we were not provided

25     with the foundation evidence, and the witness was not able to confirm

Page 3054

 1     anything about it, and in relation to the bread queue, we already

 2     admitted "The Independent" clipping, but as to the picture, we're not

 3     satisfied with this foundation.  For those reasons, we are not minded to

 4     admit them at all.  You will have another opportunity to introduce those

 5     documents if we are satisfied with its relevance.

 6             Final questions?

 7             MR. KARADZIC:  [Interpretation]

 8        Q.   My final question is this:  Mr. van Lynden, we heard from you

 9     that you consider that we are responsible for not informing the world

10     sufficiently about our situation, put our case to the world.  Now, do you

11     consider that the media nonetheless did inflict a great deal of damage to

12     the Serbs regardless of whether we were to blame or whether the media

13     were to blame?  Do you -- do you think that it was unjustified and that

14     the picture that went out into the world about our image was far blacker

15     than it need have been and should have been?

16        A.   You're asking for my impression, Mr. Karadzic, and you had said

17     when I was here first that you didn't want my impressions.

18             I believe that the Serbs indeed are responsible for the image

19     that they received during the war in Bosnia, in the Western media.

20        Q.   And that that image did not reflect the actual state of affairs;

21     right?

22        A.   That's not what I said.  I said that I believe that the Serbs are

23     responsible for the image that they received during the war in Bosnia.

24             JUDGE KWON:  Mr. Nicholls.

25             MR. NICHOLLS:  Thank you, Your Honours.

Page 3055

 1                           Re-examination by Mr. Nicholls:

 2        Q.   Just a few questions, Mr. van Lynden.  A very small point but I

 3     want to clear it up.  Mr. Karadzic today at page 28, lines 1 to 10,

 4     implied that this was the first time today that you had ever said, spoken

 5     about how in April 1994 you were told to leave Belgrade for life.

 6             Do you recall speaking about that during your cross-examination

 7     in the Slobodan Milosevic case, 16 September 2003, at transcript page

 8     26764?  There you stated in April 1994, continuing:  "It was my last days

 9     in Serbia because then I was then ordered to leave the country after your

10     government decided to call me persona non grata for life."

11             Do you recall that you spoke about that indent back in 2003 under

12     oath?

13        A.   Yes, I do.

14        Q.   Okay.  Is it correct that you also discussed that in the Martic

15     case and in the Perisic cases?

16        A.   Probably.

17        Q.   I want to go now to some questioning by Mr. Karadzic about front

18     lines.  You were cross-examined about video P936.  That's the video from

19     5th December 1992 of the apartment building burning where the incendiary

20     bullet bounces nearby you and your cameraman, and you were questioned

21     about a statement in that report that the building was a civilian target,

22     and you were asked this question on the 21st of May, this is at 2628,

23     line 18.  Mr. Karadzic said:

24             "Thank you.  In another video-clip you said that the defenders

25     had turned apartments and offices into places" --

Page 3056

 1             THE INTERPRETER:  Would you mind slowing down.  Thank you.

 2             MR. NICHOLLS:

 3        Q.   -- "from where there was shooting and that explains what just --

 4     what you said just now and I'll accept it."

 5             And your answer was:

 6             "No, no, no.  No, no.  Wait a second.  On the front lines, as

 7     also on your side of the front lines, apartments and office blocks were

 8     turned into military installations.  This was not a front line apartment

 9     building.  This was a civilian apartment building that was targeted.

10     Quite different to the other positions on the -- right on the front

11     lines."

12             What I'd like to do is play just part of the clip that

13     Mr. Karadzic cited in support of his question to you.  That's 40264B is

14     the 65 ter number.

15                           [Video-clip played]

16             "Van Lynden:  Stark evidence of another night of fierce shelling

17     in a city that's gradually being destroyed.  Close by lie the front lines

18     of an urban war, offices and homes turned into machine-gun emplacements

19     by the defenders of Sarajevo.  Their Serb foes are close, very close.

20     This burnt out tank just 80 yards away.  Hidden around the city's Jewish

21     cemetery are other Serb positions, a district of town where the guns are

22     rarely quiet."

23             MR. NICHOLLS:

24        Q.   Let's stop there at 04:47:6.  Now, the front line positions, the

25     offices and buildings turned into machine-gun nests that you talked about

Page 3057

 1     in this story that Mr. Karadzic quoted, where were they located?

 2        A.   They were located on the Bosnian side of the front line by the

 3     Miljacka River just opposite the Jewish cemetery.

 4        Q.   Okay.  The burning apartment building we saw in the story from

 5     December 5th, 1992, where was that building located approximately?

 6        A.   That's -- we're in the western part of the town, fairly close to

 7     the television station.  It's a completely different part of town.

 8        Q.   Okay.  Did that building have anything to do, the one that we saw

 9     burning in the December 5th, 1992, film, did that have anything to do

10     with the clip Mr. Karadzic referred to about the front lines?

11        A.   No.  They were completely separate.

12        Q.   Thank you.  You were also asked also on the 21st of May, this is

13     at 2595, line 14, by Mr. Karadzic, continuing on to 2597, about damage to

14     the former military hospital or city hospital when you entered it, and

15     Mr. Karadzic characterised it as being pocked marked and there was some

16     questioning about the nature of the damage.  I'd like to play continuing

17     from this same 65 ter number, another portion starting at 6:15

18     approximately.  If you could watch this, please.  And I should say this

19     is from June 3rd, this news story.

20                           [Video-clip played]

21              "Sarajevo city hospital provides graphic proof, an incongruous

22     target that's been hit every single day."

23             MR. NICHOLLS:  Stop, please.

24        Q.   All right.  We're at 06:29:3.  Could you just tell us which

25     building is this that we've stopped on?

Page 3058

 1        A.   This is the former military hospital.  The building that we've

 2     stayed in --

 3        Q.   Thank you.

 4        A.   [Overlapping speakers] -- spent a lot of time in Sarajevo.

 5             MR. NICHOLLS:  Play it, please.

 6                           [Video-clip played]

 7             "Unscathed by shrapnel or bullet.  For the brooms of the

 8     cleaners, an almost hopeless task.  It was once a military hospital, but

 9     the lieutenant-colonel who left in such a hurry that his uniform still

10     hang on their pegs would hardly recognise it now.  Across the corridor

11     the office of a colleague has simply disappeared.  Yet the hospital still

12     functions.  Its intensive care unit fully operational."

13             MR. NICHOLLS:  We can stop.  Thank you.  Stopped at 06:59:5.

14        Q.   Very simply, that video that was broadcast on June 3rd, does it

15     fairly and accurately reflect the condition of the hospital when you

16     stayed there in early June 1992?

17        A.   Yes, it shows only a small part of the damage that it had

18     sustained.  I mean, it was -- the damage was really huge already.

19        Q.   Thank you.

20             MR. NICHOLLS:  Your Honours, I'd ask to admit that story.

21             JUDGE KWON:  What was the 65 ter number again please?

22             MR. NICHOLLS:  It was 40264B.

23             THE ACCUSED: [Interpretation] May I ask something?  Parts of the

24     interior, the shots of the interior, are they of the military hospital as

25     well, or was that filmed somewhere else?

Page 3059

 1             JUDGE KWON:  Mr. Karadzic, you're not allowed to ask questions

 2     during the redirect.

 3             THE ACCUSED: [Interpretation] Well, whether I'm going to object

 4     to it's -- being admitted or not depends on the answer I'm given.

 5                           [Trial Chamber confers]

 6             JUDGE MORRISON:  Mr. van Lynden, can you assist on the matter.

 7             THE WITNESS:  All of that was filmed at the military hospital.

 8             JUDGE KWON:  With that explanation, we'll admit the part of the

 9     film.

10             THE REGISTRAR:  Exhibit P954, Your Honours.

11             MR. NICHOLLS:  Thank you, Your Honours.

12        Q.   Now I want to ask you some questions arising from the

13     cross-examination where you were continually accused on your earlier

14     cross-examination and again today of bias, both yourself and the media in

15     general.

16             Principally you've been accused of reporting on Serb -- not

17     reporting on Serb losses and the existence of fire from Muslim positions

18     at Serb positions amongst other things.  Specifically, 20th of May at

19     2522 Mr. Karadzic said that all of your reports and the reports of many

20     of your colleagues do not leave any doubt in anybody's mind as to the

21     Serbs being the ones to attack, and it's always their fault.  At 2451,

22     line 1, on 19th of May, Mr. Karadzic put it to you that your reports

23     showed that nobody was actually shooting at the Serbs and that the city

24     was unarmed without any artillery, without any soldiers, without any

25     actions going on.  And the Serbs without having suffered any losses.

Page 3060

 1             MR. NICHOLLS:  I'd like to now play P806, please, in response to

 2     those questions, and I'll have a couple questions.  Your Honours, this is

 3     referenced in paragraphs 101 and 104 of the amalgamated statements.

 4                           [Video-clip played]

 5             "Van Lynden:  The Serb position is a commanding one.  They have

 6     the whole of Sarajevo in their sights, with tree tops shorn to provide

 7     better fields of fire.  The slopes are practically insurmountable to

 8     direct attack and the lines of sturdy log cabins, some already being

 9     prepared for winter, have an air of permanence.  For the moment, the Serb

10     guardians of these hilltop strongholds appear relaxed, yet they're

11     adamant that anything won in battle cannot be surrendered in negotiation.

12              "Soldier:  Giving any territory away would be a great treason

13     against their people and the Serb capitulation.

14             "Van Lynden:  In Grbavica, the only district of central Sarajevo

15     the Serbs control, that opinion was shared by all the soldiers, even if

16     many of these elderly civilians congregating to collect their pensions

17     are Muslims.  The war having halted earlier payments, now they received

18     their allotted share for April and May.  It's meager, between 3 and 8

19     pounds per person, which cannot buy a lot in an adjacent shop plentiful

20     by Sarajevo standards.  Then the calm of the morning is shattered by a

21     sniper's bullet.  A woman is hit, and the 20-millimetre gun of an APC

22     fires a concerted repast.

23             "The threat of the sniper forces any approach to the front lines

24     to be made crouched and at speed.  Here the guns are seldom silent.

25             "Neither the London Conference, with all it's stated promises and

Page 3061

 1     principles, nor the continuing talks in Geneva, would appear to have made

 2     one jot of difference here.  The shooting and siege continue, just as

 3     they have done for the past five months.  Much of the front line that

 4     divides Grbavica from the rest of Sarajevo is a natural one.  The river

 5     Miljacka, its bridges watched continually from apartment block

 6     machine-gun nests.  One gun, manned by an obese decoy.  Here, as on the

 7     hillside, the mood is an uncompromising one.

 8             "Soldier:  We are against it, we are against any concessions.

 9             "Soldier:  It could have been resolved politically before, but

10     not anymore.  Now only militarily, until victory.

11             "Van Lynden:  Yet at rare times, even here there is compassion, a

12     solitary Muslim woman allowed to cross the river in safety, freeing her

13     from Serb control, but leaving her in a city besieged by them.

14             "Aernout van Lynden, Sky News, Sarajevo.  Aernout Van Lynden, Fox

15     News, Sarajevo."

16             MR. NICHOLLS:  We stopped at the end -- we stopped at the end of

17     the clip, the story.

18        Q.   Just to be clear, when did you film and report on this story from

19     the Serb side in Grbavica?

20        A.   This was in September 1992.

21        Q.   Is this after the interview with General Mladic where you asked

22     for permission to visit different positions?

23        A.   Yes, I think it was.

24        Q.   And again, just to be very clear for the record, when you're

25     reporting there on sniping coming into Grbavica and a woman being hit,

Page 3062

 1     although we didn't see that on the film, which side is that, the Muslim

 2     or the Serb side that you were reporting on, sniper fire coming into and

 3     hitting women?

 4        A.   On the Bosnian Serb side.

 5        Q.   Thank you.  And very quickly to conclude.  You were also asked on

 6     20th of May, at 2557, line 10:

 7                 "Q.  If I tell you that foreign correspondents had no

 8     interest at all in the Serb side of the story, what do you say to that?"

 9             And you said that you're talking utter nonsense.  We went to Pale

10     and continued.  And you went on to say:

11             "When we were there in September, we were taken to a front line

12     position outside Hadzici, a Serb-held position, and it came under fire.

13     We filmed it and reported on it."

14             And I want to show P808, if we may, Your Honour.  This is in

15     reference in paragraph 101 of the amalgamated statement.

16                           [Video-clip played]

17             "Some duck for cover, others scramble to respond.  For the Serb

18     fighters on the hills west of Sarajevo, skirmishes like this one are

19     sudden but daily fact of life.  The forests resound to gunfire as local

20     commanders with some urgency ask for more information.  Even if the dense

21     undergrowth limits their fields of fire, they take few risks, pouring

22     pre-emptive machine-gun bursts down the slopes.

23             "Soldier:  For the past 15 days there's been heavy fighting here.

24     Five of my men have died, 15 have been wounded.

25             "Van Lynden:  As ever, the Serbs hold the high ground, looking

Page 3063

 1     down on the Muslim villages in the valleys below.  The Serbs took these

 2     hills two months ago and know that the Bosnian government forces must

 3     retake them if the ever worsening siege of Sarajevo is to be broken.

 4             "It's in the constant offensives and counter-offensives on fronts

 5     like this one, the demilitarisation of Sarajevo and the region that

 6     surrounds it is likely to break down even if the rival Bosnian leaders

 7     put their signatures to an agreement.

 8             "Certainly in the hillside trenches and bunkers we found no

 9     expectations of an early peace.  Just a blind commitment to war.

10     Aernout van Lynden, Sky News, on the front lines west of Sarajevo."

11             MR. NICHOLLS:

12        Q.   Now, is that the story you were referring to in your answer - I'm

13     not sure - when you --

14        A.   This is outside Hadzici, yes.

15        Q.   Okay.  Thank you.  And in that story we saw that you reported

16     that the Serb soldiers there had suffered casualties, 15 wounded, five

17     dead according to --

18        A.   Okay.  That's the commander saying that.  I didn't see the dead

19     or the wounded, but that's what he told us, and we broadcast what he

20     said.

21        Q.   And you also broadcast there that the Serb position was

22     responding to fire and that there were constant offences and counter

23     offences at fronts like that one.  Why did you include that in the

24     report?

25        A.   Because it was the way it was.  While we were there, that

Page 3064

 1     position came under fire, and there was a response from those soldiers to

 2     the incoming fire.  That's what we filmed, and that's what we

 3     experienced, and that's what we reported.

 4        Q.   And I'll play just one last one.  If we could play P810, please.

 5     It's a short clip of the funeral in Vlasenica.  It is referenced on page

 6     113 of your statement.

 7                           [Video-clip played]

 8              "In the eastern Bosnian town of Vlasenica, the bells of the

 9     Orthodox church toll for the dead, twenty-eight of them.  They lie in

10     simple pine coffins surrounded by the leaders of the Serbs, by relatives,

11     and by almost the entire population of the town.  The men, all Serb

12     soldiers, were killed when their position was overrun last Saturday by

13     Muslim forces.  Only a date later were they found, their bodies

14     horrifically mutilated, two even having been roasted on a spit, and the

15     coffins could not hide the stench of defiled death from any bystander.

16             "In slow procession they wind their way to the cemetery where the

17     victims of Bosnia's last war lie.  A new mass grave has been dug amongst

18     the old, and here the latest victims of this new and barbarous war in

19     Bosnia are laid down side by side.  Colleagues fire a last salute and

20     then leave the grave to parents, wives, and children unwilling to let the

21     dead fall from their grasp.

22             "Aernout van Lynden, Sky News, Vlasenica."

23             MR. NICHOLLS:

24        Q.   All right.  That's one of your reports referenced in your

25     statement that you sent out, and I think it speaks for itself.  You state

Page 3065

 1     in your statement at paragraph 113 that 28 soldiers were buried in that

 2     mass funeral which you covered.  And you were also questioned a lot about

 3     government manipulation of the media and the way politicians manipulate

 4     the media, try to manipulate the media.  Do you recall meeting with

 5     Mr. Karadzic at around this time and what he told you that who the

 6     victims were of this attack?

 7        A.   Yes.  We met Mr. Karadzic, as I recall, before going there for

 8     the funeral and that he gave figures that several hundred people had been

 9     killed and that they were civilians.  At the -- in Vlasenica we asked who

10     these people were and they said to us that they were soldiers and there

11     were 28 coffins, because we counted them, and the day after that we

12     actually went to the position where these men had died and met their

13     company commander who confirmed that it was 28 men who had died there and

14     that no civilians had been killed in that particular attack.

15             MR. NICHOLLS:  Thank you.  That's all I have, Your Honours.

16             JUDGE KWON:  Thank you.

17                           [Trial Chamber confers]

18             JUDGE KWON:  Thank you, Mr. van Lynden.  That concludes your

19     evidence.  Thank you again.

20             THE WITNESS:  Your Honours, thank you.  I would, with your

21     allowance, like to make a short statement about the rights of witnesses

22     which I believe have been slightly forgotten.  I think a war crimes

23     Tribunal, and I'm specifically referring here to the permanent

24     International Criminal Court that has been set up in The Hague, needs to

25     bear in mind that a witness at a war crimes tribunal is not the same as a

Page 3066

 1     witness in a normal civil court.  I'm aware that two, at least two victim

 2     witnesses were flown twice to The Hague and then flown back again without

 3     having been able to give their testimony.  I believe that is doing those

 4     people a further injustice to the injustices that they've already faced

 5     during the wars that they are willing to testify on.

 6             Separately, this is the sixth time I have given evidence at this

 7     tribunal.  It is the first time that I have been asked to speak to the

 8     lawyers of the defendant or in this case the defendant himself

 9     beforehand.  I was willing to do so.

10             It was noticeable to me or it has been during these days that

11     none of the questions I was posed when I met Mr. Karadzic in prison were

12     ever asked in the court and that he could have shown me the decency and

13     the courtesy of showing me the documents that he was going to bring

14     before me in the court, but he did not do so.  This is strange to me,

15     because Prosecution and Defence have the right to see documents, and I do

16     not understand why a witness should not have that right as well.

17             And lastly, when one of Your Honours suggested that the documents

18     that Mr. Karadzic was going to be using in the days ahead should be given

19     to me for, I believe, my night-time reading was the quote that I was

20     given, I did read those documents and they were then not brought up in

21     court at all, leaving me to wonder why I had been given them to read.

22             That's all I would like to say to Your Honours.

23             JUDGE KWON:  Thank you for your observations.  Thank you again

24     for your coming yet again to the Tribunal to give it.  Now you're free to

25     go.

Page 3067

 1             THE WITNESS:  Thank you, Your Honours.

 2                           [The witness withdrew]

 3             JUDGE KWON:  We'll have a break now and -- for 25 minutes, and

 4     then we'll have another witness.

 5                           --- Recess taken at 5.18 p.m.

 6                           --- On resuming at 5.44 p.m.

 7                           [The witness entered court]

 8             JUDGE KWON:  Good afternoon, Doctor.  If you could take a solemn

 9     declaration, please.

10             THE WITNESS:  [Microphone not activated].  I solemnly declare

11     that I will speak the truth, the whole truth, and nothing but the truth.

12             JUDGE KWON:  Thank you.  Please make yourself comfortable.

13             Yes, Ms. Edgerton.

14             MS. EDGERTON:  Thank you, Your Honour.

15                            WITNESS:  ROBERT DONIA

16                           Examination by Ms. Edgerton:

17        Q.   Doctor, could you please introduce yourself to the Court and tell

18     us your occupation?

19        A.   I am Robert Donia.  Last name is D-o-n-i-a.  I am or have been

20     intermittently over the past several years and expect to be again in the

21     fall of this year a visiting professor of history at the University of

22     Michigan.

23        Q.   Now, as a professor of history do you have any particular area of

24     specialisation?

25        A.   Yes.  I have specialised in political and social history,

Page 3068

 1     principally of the 19th and 20th centuries, and principally in the area

 2     of south-eastern Europe, in particular Bosnia-Herzegovina and the former

 3     Yugoslavia.

 4        Q.   Now, in regard to your qualifications, could I ask that 65 ter

 5     21894, page 121, be displayed, please.

 6             MS. EDGERTON:  And that is an appendix to one of Dr. Donia's

 7     reports, which we'll be referring to more fully later.  21894, page 121.

 8        Q.   Dr. Donia, do you see Appendix A to your Sarajevo report on the

 9     screen on the monitor in front you?

10        A.   Yes, I do.

11        Q.   And is that, CV, Dr. Donia?

12        A.   Yes, it is.

13        Q.   Now, as I look at page 1 on your CV, I note that you've written

14     three books over the course of the last years:  "Islam Under the Double

15     Eagle," "Bosnia and Herzegovina:  A Tradition Betrayed," and "Sarajevo, a

16     Biography."  Is that correct?

17        A.   Yes.  I coauthored the second book, "Bosnia and Herzegovina:  A

18     Tradition Betrayed," with John Fine, a professor of history at the

19     University of Michigan also.

20        Q.   What are those books about, sir?

21        A.   The first book that you referenced, "Islam Under the Double

22     Eagle," is a social and political history of the Muslims of Bosnia and

23     Herzegovina during the Austro-Hungarian occupation from 1878 to 1914.

24     The second book is a more general introductory history of

25     Bosnia-Herzegovina from the Middle Ages up until about -- up until 1994

Page 3069

 1     when the book came out.  And Sarajevo, a biography, is a history of the

 2     city of Sarajevo from its Ottoman origins to the very early twenty-first

 3     century.

 4        Q.   Thank you.  Now, in relation to these books, perhaps I could ask

 5     you whether you could talk in a general way about the sources you

 6     exploited and relied on in your writings.

 7        A.   The sources that I've used in -- in these books and, for that

 8     matter, the various articles that I have done are very diverse.  I use a

 9     lot of archival sources, and in particular for the first and third books

10     that you've mentioned have worked in multiple archives both in the former

11     Yugoslavia and neighbouring countries and other countries of Europe

12     and -- and also in the US.

13             I also use heavily the periodical press and the secondary

14     literature by scholars both from the region and from outside the region

15     which pertain to the topic that I'm addressing.  And, of course, a lot of

16     published document collections and various collections of articles and

17     conference papers that deal with topics that I'm working with.

18        Q.   Do you have any command of the Bosnian Serbian Croatian language,

19     what we commonly refer to as B/C/S within the walls of this building?

20        A.   Yes, I do.  I'd say I speak it well.  I read it well.  I write it

21     with some difficulty, and probably have considerable difficulty reading

22     handwritten Cyrillic.

23        Q.   But you can read the language both in Cyrillic and Latin script

24     then?

25        A.   Yes.

Page 3070

 1        Q.   Next I'd like to refer to some of your reports, three of which

 2     bring you here today.  The first is entitled:  "The Origins of the

 3     Republika Srpska, 1990 to 1992."

 4             MS. EDGERTON:  And for the record and Your Honours, that's 65 ter

 5     number 11699.

 6        Q.   The second is entitled:  "Thematic Excerpts from the Assembly of

 7     the Republika Srpska, 1991 to 1996," 65 ter number 11700.  And the third,

 8     Bosnian Serb Leadership and the Siege of Sarajevo, 1990, to 1995," the

 9     number of which I've already mentioned, 65 ter 21894.

10             Now, Dr. Donia, could you explain briefly to the Trial Chamber

11     what these three various reports are?

12        A.   Yes.  You've identified them in the chronological order in which

13     they were prepared.  The first report, "Origins of Republika Srpska," I

14     prepared some years ago.  I guess I've lost track of exactly the years,

15     but nearly a decade ago, I believe, for the Krajisnik case, and prepared

16     the second report for the Stanisic/Simatovic case originally.  That

17     report is a selection of excerpts from the transcripts of the Assembly of

18     Republika Srpska or what I call the Bosnian Serb Assembly.  And the third

19     one, which is the history of the Sarajevo area and siege and war, I

20     prepared for -- for this case about two years ago.

21        Q.   Now, just to move on to your methodology, and you've alluded to

22     that in your Sarajevo report at pages 4 to 6, I think.  Perhaps you could

23     tell us what is it that you as a historian do.  What's your craft?

24        A.   I think fundamentally I prepare narratives, narratives which

25     follow a particular progression, typically divided into thematic

Page 3071

 1     sections, and each thematic section attempts to elucidate a sequence of

 2     events, the causes of those events, and the linkages between them to

 3     produce a coherent story of events and the topic concerned.  That's what

 4     essentially most professional historians do, although they may also do

 5     other things and address problems or issues that arise in the course of

 6     preparation of such narratives.

 7             The purpose of that narrative, then, is to acquaint a reader who

 8     is unfamiliar with the geography or chronology of the time and space

 9     concerned to gain some context and background about the area and the time

10     about which the narrative is prepared.

11        Q.   Is this narrative format that you've discussed the format you

12     adopted for your origins of the Republika Srpska report and your Sarajevo

13     report?

14        A.   Yes, it is, and that -- those two reports rely on a very wide

15     variety of source material and often call upon the words of the principal

16     actors in their -- in their own expressions but are primarily designed to

17     tell that story, to pull that narrative together.

18        Q.   Is the second report, "Thematic Excerpts from the Assembly of the

19     Republika Srpska," and I think I'll -- just so I don't have to say a

20     mouthful every time I refer to the report I might call that one the

21     excerpts report, is your excerpts report different in any regard?

22        A.   It is different in that it relies upon a single source, although

23     the information within that source has been richly cross-checked with

24     other sources for the period of times -- periods of time concerned, but

25     although it relies on a single source, it is in it's own way a narrative,

Page 3072

 1     because I've broken it down into eight topical areas presented, then, in

 2     chronological order, what I judge to be the most revealing and helpful

 3     excerpts from the Assembly minutes, which is a voluminous collection of

 4     many thousands of pages, I'm not sure how many, but it's long, with the

 5     intent of creating exactly that kind of a narrative so that a reader

 6     could follow the progression of people's thinking and their own

 7     understanding of events at the time, a contemporaneous understanding as

 8     opposed to a retrospective one and one which captured then in their own

 9     words their own explanations and perceptions.

10        Q.   On the subject of your sources, first of all, more generally

11     speaking, and you alluded to this in your Sarajevo report but perhaps you

12     could enlarge upon it, does anything guide or inform you in your

13     selection of sources?

14        A.   Yes, and I codified basically what I think most or every

15     historian uses as guideline for assessing sources, and number one is

16     relevance.  Is a particular document relevant to the question being

17     examined in the narrative?  Second, is its source, its origins, its

18     provenance, the preparer or creator of the document.  And third is its

19     cross-checkability, if I can use the word, its verifiability in terms of

20     other events related in other sources at the same time or in other

21     sources retrospectively.  And fourth is richness.  I think that the -- an

22     important and often unspoken criterion is does this document tell me

23     something significant?  Does it really enlighten and enrich mine and the

24     reader's understanding of events.

25        Q.   How do the Bosnian Serb Assembly sessions in your excerpts

Page 3073

 1     report -- now, how do the Bosnian Serb Assembly sessions then fit within

 2     these four criteria?

 3        A.   Well, certainly their provenance is very clear.  They were, as I

 4     understand it, delivered to the Tribunal by the secretary of the of the

 5     Assembly of Republika Srpska.  Large parts of them are, frankly, not

 6     relevant, that is of the Assembly sessions themselves, and significant

 7     parts are relevant.  So I've tried to focus on those parts that are

 8     relevant.

 9             In terms of cross-checking with contemporary sources, these

10     transcripts are very well attested to by linking events with other

11     contemporary sources.  I'd give it high grades in that respect.  And

12     probably most illuminatingly they are extremely rich.  They really

13     provide -- they allow you to get into the mind of the people who were

14     speaking at the time, understand what their philosophy was, what drove

15     their decision-making, and what debates they had about various policies.

16        Q.   Thank you.  I think now I'll move on to another theme that comes

17     up in -- particularly in two of your reports, your Sarajevo report and

18     your excerpts report, and that's the subject of the strategic objectives,

19     and I'd like to call up a document, please, and while we wait for that

20     ask you a question if I may, Doctor.

21             MS. EDGERTON:  Could I have 65 ter 17509, please.

22        Q.   And while we wait for that, perhaps I could ask you to give us

23     some background on these strategic objectives.

24        A.   Well, I now see the B/C/S version of the strategic -- and the

25     English version of the strategic goals on the screen.  The document that

Page 3074

 1     we're looking at is an excerpt from the Official Gazette of the republic

 2     of the Serbian people in Bosnia and Herzegovina, published this

 3     particular -- this particular issue in November of 1993.  The document

 4     reflects the approval of the strategic goals at an Assembly session of

 5     the Bosnian Serb Assembly on 12 May 1992.  The Assembly at that time,

 6     after a lengthy exposition of the goals by various leaders of the

 7     Republika Srpska, approved the six goals that are -- that are before us.

 8             The fact that it was published in 1993 indicates that it still

 9     was -- reflected the time that -- or the assessment of the leaders that

10     these were important goals that should be publicly known and that they

11     had not changed.  They basically had been in place since 1992.  The -- in

12     fact, the ideals that undergird the strategic goals were expressed in

13     many speeches by various leaders in the Assembly and in other speeches

14     well prior to 12 May 1992 and are referenced repeatedly and consistently

15     as a foundation for decision-making within the Assembly from 1993,

16     November 1993, until the end of the war.

17             MS. EDGERTON:  Your Honours, if I may, I'd like to -- if I may,

18     perhaps I could ask that this first document, 17509, be admitted as the

19     next exhibit.  And while we wait for that, if I could ask for 65 ter

20     number 00026, page 9, to be brought up, please.

21             JUDGE KWON:  Yes, it will be admitted.

22             THE REGISTRAR:  Your Honours, as can be P955, Your Honour.

23             THE ACCUSED: [Interpretation] No objection.

24             MS. EDGERTON:

25        Q.   And now while we wait for 65 ter 00026, page 9, which, in fact,

Page 3075

 1     is an excerpt from the 12 May 1992 Assembly session, perhaps I could ask

 2     you, Dr. Donia, what was that Assembly session about?

 3        A.   Before I answer that question, can I just point out that the

 4     prior document that we looked at, the B/C/S was, in fact, a typed script

 5     of the original text of the proclamation which I have seen in its

 6     original and examined as a part of the Official Gazette.

 7             And your question was what was the 12th -- or the 16th Assembly

 8     session -- yes.  And I recognise this as -- as a page from the actual

 9     original transcript of the 16th Assembly session on May 12th, 1992.  That

10     Assembly session was the first Assembly session to meet after the war had

11     begun and after, in fact, much of the territorial gains had been secured

12     by the various military and police and party forces of the Bosnian Serb

13     nationalists.  So it's a -- I think of it as a -- almost as a celebratory

14     session in which delegates congratulate one another but also speak to

15     what the key essential objectives of the Bosnian Serbs -- of the Serb

16     people are in Bosnia, and therefore it's a kind of a founding Assembly

17     for wartime, the pursuit of wartime goals.

18        Q.   Are you aware whether there were military leaders, Bosnian Serb

19     military leaders, in attendance at this session?

20        A.   Yes.  General Mladic was certainly there.  He gave a lengthy

21     speech following Dr. Karadzic's talk to the Assembly, and there were a

22     number of other people there in uniform we know from references, and I

23     believe there were a few other general officers in attendance.

24        Q.   Did --

25             JUDGE KWON:  Doctor, the previous document was typed by whom?  Do

Page 3076

 1     you know?

 2             THE WITNESS:  I do not know.

 3             JUDGE KWON:  Thank you.

 4             MS. EDGERTON:

 5        Q.   Now, you indicated a few moments ago that you recognised the

 6     document on the screen in front of you, and for the record I'll say again

 7     this is an excerpt of the 12 May 1992 Assembly session, and I'd like to

 8     direct our attention to what I think is the first full paragraph on

 9     English page 9 which reads:

10             "The Serbian side in Bosnia and Herzegovina, the Presidency, the

11     Government, the Council for National Security, which we have set up, have

12     formulated the strategic priorities," and further.

13             And on the B/C/S page, I can't quite see the paragraph break to

14     the left-hand side of the page, but my notation is that the same quote

15     appears on page 8 of the B/C/S page, the first full paragraph on page 8.

16             Now, Dr. Donia, this is an excerpt by -- speech by Dr. Karadzic,

17     and you indicated you recognised it.  Could you then tell us more

18     precisely what it is?

19        A.   The -- the -- just looking at the B/C/S, this begins on the next

20     to bottom line in what I'm looking at anyway, and I see now it's been

21     scrolled up so it is there as a paragraph which appears to be the same as

22     the exert that you just read.

23             The statement in this paragraph is that Dr. Karadzic is

24     indicating that the key elements of the -- the key institutions of the

25     Bosnian Serb state have set forth these goals, have formulated them, on

Page 3077

 1     behalf of the Serbian people, and then states the first goal, which is,

 2     as he puts it, separation from the other two national communities,

 3     separation of states.

 4        Q.   Moving on to the next paragraph --

 5             JUDGE KWON:  Microphone.

 6             MS. EDGERTON:  Pardon me.  Your Honour.  Pardon me, Your Honour.

 7        Q.   Moving on to the next paragraph which begins, "The second

 8     strategic goal," do you have any comment on that paragraph?

 9        A.   Well, the second strategic goal is a key statement that the

10     Bosnian Serbs want a contiguous territory based on a corridor of land

11     between Semberija, which is to the -- in the very north-east of Bosnia,

12     and Krajina which is in the north-west of Bosnia, and that corridor of

13     land, as Dr. Karadzic expresses it here, not only links the two parts of

14     eastern and Western Bosnia, which the Serbs held at that time, but also

15     links the Serb-held territory in neighbouring Croatia to the west and the

16     republic -- republics of Serbia and Montenegro to the east.  Thus the

17     corridor is a key linkage between what I think of these as two lung-like

18     state territories to the east and west, but also a link between and among

19     neighbouring polities.

20        Q.   Neighbouring polities being who?

21        A.   Well, the Bosnian -- I'm sorry.  The neighbouring polities being

22     the Republic of Serbian Krajina, which was the Serb-held part of Croatia,

23     and the republics of Serbia and Montenegro to the east.

24        Q.   Thank you.  If we can go on to the next paragraph which reads,

25     "The third strategic goal is to establish a corridor in the Drina valley,

Page 3078

 1     that is, elimination of the Drina as a border between our two worlds."

 2     Do you have any comment?

 3        A.   Well, this third strategic goal speaks to the eastern border area

 4     of Bosnia and proposes that the Drina, which -- much of which had served

 5     as a boundary between the Republic of Serbia or originally the

 6     principality of Serbia and the Kingdom of Serbia and Bosnia, it served

 7     that capacity since the 1830s, be eliminated as a boundary which would

 8     mean that there would be then no boundary between the Serb-held area of

 9     eastern Bosnia and the Republic of Serbia.

10        Q.   I'd like to draw your attention to just one more of the strategic

11     objectives, and it requires us to move over to the next English page and

12     the next B/C/S page; that being the fifth strategic goal, division of the

13     city of Sarajevo into Serbian and Muslim parts.  Could you go over to the

14     next English page, please.

15             Now, Dr. Donia, do you see the top line that reads:

16             "Sarajevo is strategically in the fifth place, but the battle in

17     Sarajevo and for Sarajevo, seen strategically and tactically, is of

18     decisive importance because it does not allow the establishment of even

19     the illusion of a state.  Alija does not have a state while we have part

20     of Sarajevo."

21             Do you see that?

22        A.   Yes.

23        Q.   Do you have any comment on this passage?

24        A.   The strategic goal of separation as it pertained to Sarajevo, the

25     capital city and largest city in Bosnia, in fact, had in Dr. Karadzic's

Page 3079

 1     articulation some specific features; namely, in recognition of its status

 2     as the capital, he valued this separation of the city as a way of

 3     crippling or denying -- crippling the state or denying to the Republic of

 4     Bosnia-Herzegovina the attributes of a state, and Sarajevo in that sense

 5     sort of crystallises into a specific area the general goal that was

 6     expressed as the first strategic goal.

 7             MS. EDGERTON:  Your Honour, those are my questions with respect

 8     to this excerpt from the 16th Assembly session, and I would at this point

 9     like to ask Your Honours for admission of those pages, but I understand -

10     and I haven't been present in court for these rulings - but I understand

11     Your Honours' guidance as being for documents contemporaneous as this one

12     obviously is --

13             JUDGE KWON:  This minute it will be admitted in its entirety and

14     which in particular will be used in the later stage.  For the

15     convenience, it's much better to admit it in its entirety.

16             MS. EDGERTON:  Thank you, Your Honour.

17             JUDGE KWON:  So you're now tendering this one?

18             MS. EDGERTON:  Yes, please, Your Honour.

19             JUDGE KWON:  Twenty-six -- just a second.

20                           [Trial Chamber and registrar confer]

21             JUDGE KWON:  Just for the record, I note the original copy of

22     that Official Gazette which contains the strategic objectives was

23     admitted as Exhibit P781, but the current one we received is a typed

24     version.  So because the format is different we'll admit them both.  And

25     we'll admit this transcription or minute of this session as --

Page 3080

 1             THE REGISTRAR:  Exhibit P956, Your Honours.

 2             JUDGE KWON:  Thank you.

 3             MS. EDGERTON:  And, Your Honours --

 4             THE ACCUSED:  No objection.

 5             JUDGE KWON:  Thank you, Mr. Karadzic.

 6             MS. EDGERTON:  Your Honour, my apologies with respect to that

 7     last document.  I think it was a situation where we had different

 8     versions of the same document and I wasn't aware.  My apologies to the

 9     Court and Mr. Registrar.  But I must say, I've received the same

10     information at the same moment Your Honours did.  So my thanks to my

11     colleagues who are watching remotely.

12        Q.   Now, Dr. Donia, if I may, we've gone through each of these

13     objectives in a little bit of detail now, and I want to go back to the

14     first one and ask you, sir, how would you characterise this first

15     objective?

16        A.   It is expressed as a general principle, but it has many possible,

17     let's say specific, components to it.  It clearly embraces the separation

18     of the national communities but does not specify whether that separation

19     is to be territorial, physical, organisational, or institutional, or

20     human, or some combination of those.

21        Q.   Have you seen articulations in the course of your research as to

22     the nature of separation that was contemplated?

23        A.   Yes, I have.  I endeavoured to put some of those in those that

24     were -- a selection of those that were referenced in transcript of the

25     Bosnian Serb Assembly in the excerpts report, as we've called it, the

Page 3081

 1     excerpts from the Assembly of Republika Srpska.  They also occur in a

 2     number of speeches and declarations reported in the periodical press, and

 3     in both cases they occur before and after the principles actually adopted

 4     as the first strategic goal on the 12th of May.

 5        Q.   So then if you've seen some evidence, what type of separation was

 6     contemplated, territorial, physical, organisational, institutional, or

 7     human?

 8        A.   Well, I meant to say institutional as covering organisational,

 9     but I find indications that what was intended was all four, and in some

10     articulations there are two or three that are included or only one, but

11     in a few cases all four are indicated.

12        Q.   Articulations by the accused?

13        A.   By the accused and other leaders of the Bosnian Serb -- of the

14     SDS.

15        Q.   Who in particular?  Do you recall?

16        A.   Well, we find the principle endorsed by General Mladic.  We find

17     it embraced by Dr. Koljevic and Mr. Krajisnik, among others.

18             MS. EDGERTON:  If we could perhaps then have P956 brought up on

19     the screen again.  I'd like to take us to pages 4546 of the English

20     translation and 3839 of the B/C/S.

21        Q.   Ah, Dr. Donia, on the screen before us is a passage containing

22     comments by Mr. Krajisnik, who you've just referred to.  And if we could

23     scroll down to the bottom of the page in English, please.  The -- pardon

24     me for one moment -- seventh line up from the bottom we see

25     Mr. Krajisnik's statement to the effect that:

Page 3082

 1             "The first goal is the most important one, and in relation to all

 2     other goals, all other goals are sub-items of the first one."

 3             Do you have any comment on that?

 4        A.   Well, I think that's a self-evident comment on his part as the

 5     first strategic goal really is a general principle and governs in

 6     principle the other goals that were expressed in -- in two through six.

 7     The notion that the first strategic goal was, let's say, the founding

 8     one, the essential principle, I think is reflected in the number of times

 9     that it gets cited and recited in other Assembly sessions following

10     this one.

11        Q.   Well, referring to other Assembly sessions, perhaps I could turn

12     now to your excerpts report and ask to display a passage from that.

13             MS. EDGERTON:  That's 65 ter 11700, pages -- e-court pages 30 to

14     31, I think, paragraph 73.  And this should be an extract -- if we could

15     move further.  It's paragraph 73, please.  You're at paragraph 65 now.

16     And move forward in English I would guess two pages, please.

17        Q.   There.  At the bottom of the page we see, Dr. Donia, as cited in

18     your report, an extract from the 56th session of the Bosnian Serb

19     Assembly, dated 17 December 1995, which is a quote by Mr. Krajisnik.

20     Could you read that to us, please?

21        A.   Yes.  Let me first say that I think I have been defeated by the

22     system in that I tried to make the footnote numbers correspond to the

23     paragraph numbers so that the B/C/S would be readily apparent in the

24     original report and clearly I have failed in that endeavour, but to read

25     this particularly -- particular excerpt from the Assembly session held

Page 3083

 1     right at the time that the Dayton Peace Agreement was signed in Paris:

 2             "The task of this republic and the first strategic goal is that

 3     we separate from Muslims and Croats and no one has the right to base the

 4     strategy of Srpsko Sarajevo --"

 5             MS. EDGERTON:  Could you please move to the next page.

 6             THE WITNESS:  " -- on remaining in a joint country.  Therefore,

 7     any danger or wish for connection and solution of Sarajevo in which we

 8     will stay with Muslims and Croats is out of the question.  No one can

 9     make a new decision now, according to which we will stay together.

10     Neither do the people in Sarajevo want that, that is to say, the people

11     or the leadership of Sarajevo, but the flaw of our members of parliament

12     is that they see -- is that they see the danger if we stay in the

13     Muslim-Croat Federation, and Sarajevo would be the connection point

14     keeping the union together."

15             Let me just say that this was a statement in response to a speech

16     of another delegate or sequential to it in which a delegate had proposed

17     that in the -- in accord with the post-Dayton change of -- of borders, of

18     boundaries, that the -- instead of moving all the Serbs out of Sarajevo

19     that the Republika Srpska relocate some of its governing institutions

20     into the federation where Serbs were then living.  So he was proposing,

21     was this other delegate, a policy that deviated from the strategic goal.

22             MS. EDGERTON:

23        Q.   I note that Mr. Krajisnik made this statement some three years

24     into the war after he made a similar statement you just referred to on

25     May 12th, 1992.  Do you have any comment in that regard?

Page 3084

 1        A.   Well, he actually made this statement when the war was over and

 2     still insisted that the strategic goal was valid and, in fact, could not

 3     be violated in the post-war relocations that he foresaw.

 4        Q.   Thank you.  Perhaps we could move to another area now, still

 5     related to the strategic objectives.  And in talking about, in

 6     particular, the second objective, you referred the Judges to different

 7     areas of Bosnia and Herzegovina.  I wonder if it would assist if we

 8     called up a map, P727.  And while we wait for that map, perhaps I could

 9     ask you to enlarge on the question of the strategic objectives in the

10     following way:  Are they territorially defined?

11        A.   The second through the sixth goals do, in fact, define

12     territories, although the exact territory being defined is not very

13     specific.  The second goal, of course, defining a corridor, the two other

14     goals speaking about borders on rivers or no borders on rivers, and the

15     outlet to the sea very vague, but there was some agreement on -- on where

16     that corridor to the sea would ideally go.

17        Q.   Do you think, Dr. Donia, if my colleagues from the registry were

18     able to enlarge Bosnia and Herzegovina on this map in front of you, you

19     might be able to roughly illustrate for Their Honours - oh, well done.

20     Thank you very much - the territory generally encompassed by the

21     strategic objectives?

22        A.   Well, I could certainly identify the boundaries that were

23     specified.  Defining the exact territory is a little more difficult,

24     but --

25        Q.   Could I invite you to do that with the pen from the side of the

Page 3085

 1     monitor in front of you.

 2        A.   This is fancy.  This is good.  Let me start with the Drina River.

 3     The Drina River begins inside Bosnia.  I believe it's about -- excuse me.

 4     It's about here somewhere and then becomes the border, the eastern border

 5     of Bosnia.  I'm sorry, I went too far.  And therefore -- and for the,

 6     let's say all but its first couple dozen kilometres defines the boundary

 7     between Serbia, the Republic of Serbia, and the Republic of

 8     Bosnia-Herzegovina.

 9             MS. EDGERTON:  So Dr. Donia for the record has made a marking in

10     red line on the far right side of the map of Bosnia.  And -- well, I was

11     just about to ask Dr. Donia, as indicated, that he went a little bit too

12     far, and as I recall e-court, we may be able to remove that last line,

13     too far, that he tried to correct.

14             THE WITNESS:  All right.  It goes up about to here.  Yup.

15             MS. EDGERTON:

16        Q.   Now, you've delineated, I take it from what you've said, one

17     boundary?

18        A.   Yes.  That -- that was the boundary that was to be abolished in

19     the goal that referred to the Drina River.  The other rivers that were to

20     serve as boundaries were the Neretva, which starts here but actually kind

21     of gains some significance as it goes to Mostar and down to the sea.

22             MS. EDGERTON:  Dr. Donia's made an upside down U shape in the

23     middle of the map from the centre of the territory to the sea.

24             THE WITNESS:  And to the Sava River, which comes down from

25     Croatia and proceeds along the very -- constitutes the northern boundary

Page 3086

 1     of Bosnia.

 2             MS. EDGERTON:

 3        Q.   Referring at this last passage to the line across the top of the

 4     territory of the former republic?

 5        A.   Yes.

 6        Q.   Was there a boundary that lay to the west at all?

 7        A.   Yes, and you're going to have to give me the name of the river

 8     here to evoke my geography skills.

 9        Q.   The Una --

10        A.   Okay.

11        Q.   -- was one of the rivers mentioned in these objectives.

12        A.   Yes, and the Una --

13        Q.   Number four.

14        A.   -- runs along the western part of the republic and goes inland to

15     run through Bihac and up to the -- to merge with the Sava.

16        Q.   Thank you.  Now could I invite you, Dr. Donia, to put your

17     initials on one corner of the map with today's date, which is 31 May.

18        A.   [Marks]

19        Q.   Now, this territory that you've depicted as encompassing the --

20     encompass by the strategic objectives, was that territory meant to be

21     contiguous?

22        A.   Well, the second strategic goal really spelled out that this

23     territory, whatever else it would be, would, in fact, be contiguous, that

24     it would link, as I described it, the two saddle bags to the east and

25     west.  That corridor then running sort of to the -- along the northern

Page 3087

 1     part of Bosnia and, in particular, the area of Brcko was its narrowest

 2     point.

 3             MS. EDGERTON:  And Dr. Donia has made a double line now to the

 4     top right.  That would be the north-east corner of this map.

 5        Q.   So, then, territorially speaking, do -- if we look at this map do

 6     these goals represent potential links to areas outside the borders of

 7     Bosnia-Herzegovina?

 8        A.   I'm sorry, what was the question again?

 9        Q.   Territorially speaking, then, do these goals represent potential

10     links to outside the borders of Bosnia and Herzegovina?

11        A.   Yes, and the second goal and the Drina goal, which I think was

12     the fourth, in particular.

13             MS. EDGERTON:  Thank you.  If I could tender this map as the next

14     exhibit, please, Your Honour.

15             JUDGE KWON:  Yes.

16             THE REGISTRAR:  Your Honour, that will be Exhibit P957.

17             MS. EDGERTON:  Now, to go back to the fifth objective and the

18     city of Sarajevo, I'd like to ask for another map which has been entered

19     previously.  It has the number 815, P815.

20        Q.   And while we wait for P815, perhaps I could ask you, Dr. Donia,

21     to -- ah, and there's P815 in front of us.  Perhaps with the assistance

22     of P815 I wonder if I could invite you to provide a brief explanation of

23     the development of the city of Sarajevo.

24        A.   Okay.  I don't need another drawing disaster here.  The city of

25     Sarajevo developed from -- in this -- this east-west valley starting at

Page 3088

 1     the extreme eastern end, and I'll just put a circle, perhaps -- that was

 2     gorgeous.  Where the -- following along the river there to the area in

 3     orange, one sees a little crook in the river, and that really is the

 4     place where as an urban settlement in the Ottoman period, in the 1400s,

 5     Sarajevo first was founded, and from there the city grew to the west or

 6     the left of the map that we're looking at and reached about a kilometre

 7     and a half by the end of the Ottoman period, which was 1878, and filled

 8     in substantially then with the Austro-Hungarian period until 1918.  And

 9     then really the major development of the city to the west from that point

10     on took place in the Socialist period or the Communist period after 1945.

11     That development was actually very rapid and consistent over the period

12     from 1945 to 1990 and included some expansion into the hills on either

13     side of the city, that is to the north and to the south, and to the

14     peripheral areas of the city, some of which are shown here, some are not.

15        Q.   Now -- thank you, Doctor.  Just before you go further, before the

16     drawing disaster as you had described it, I should have asked you and

17     omitted:  Do you recognise what's depicted on the screen in front of you

18     here?

19        A.   It is a map essentially of the most developed area of Sarajevo

20     with an indication on it of the boundaries of the municipalities that

21     made up the city, or some of them, some of those municipalities as of

22     1990, in fact, the period from 1977 to 1990, and also an approximation of

23     the lines of the siege from about 1995.

24        Q.   Did the rapid development that you've just described have any

25     effect on the municipalities in the area of the city of Sarajevo?

Page 3089

 1        A.   Yes.  The relationship between municipalities, which is the

 2     fundamental administrative unit used in the Socialist period, and cities

 3     is very diverse in Yugoslavia in the Socialist period.  Sarajevo in the

 4     early years of socialism consisted of four municipalities.  Those were

 5     Stari Grad or Old Town to the extreme right of our map, Novo Sarajevo,

 6     and then to the lower left of the map Ilidza, and at the very top of the

 7     map Vogosca.  Ilidza and Vogosca were essentially standalone

 8     municipalities linked to the city, but they were economically largely

 9     self-sufficient, Ilidza being a kind of resort area, Vogosca being more

10     industrial.

11             In 1977, the city -- the map of the city changed with -- in

12     accord with the urban plan that was developed in -- in 1976.  The two

13     inner municipalities of Stari Grad and Novo Sarajevo had become very

14     densely populated, and in order to bring government closer to the

15     population and also to rationalise the growth of communications and

16     transport facilities and industrialisation, the -- the city fathers

17     divided Stari Grad into two municipalities, one which retained the name

18     Stari Grad or Old City, and the second one called Centar.  They then

19     further divided Novo Sarajevo into keeping the same name, Novo Sarajevo,

20     and a new area known as Novi Grad, or New City, to the upper left part of

21     the map.  In addition, the city acquired four existing municipalities

22     which were largely rural in character.  Those were Hadzici, Pale, Ilijas,

23     and -- help me with number four here.  Trnovo.  Trnovo.  So that rounded

24     out the ten municipalities that made up the city of Sarajevo in the

25     period from 1977 to 1990.

Page 3090

 1             Now, there was then a -- kind of an umbrella city of Sarajevo

 2     government which had its own Assembly and brought together the delegates

 3     from these ten different municipalities.  So in a sense the city had a

 4     two-tiered organisation, the municipalities that made up the city and the

 5     city itself.

 6        Q.   This concept --

 7             MS. EDGERTON:  If I could just have your indulgence for a moment,

 8     Your Honour.

 9        Q.   Now, you've talked about municipalities as regards Sarajevo.

10     This term "municipality," what did it mean in Bosnia-Herzegovina?

11        A.   The municipality, or "opstina" in B/C/S, is -- was the name

12     for -- given in the latter part of socialism to a fundamental unit,

13     administrative unit, that dates back to late Ottoman times, and that

14     administrative unit was a -- typically a small town or even a larger town

15     which was -- which bore the same name as the municipality and was

16     surrounded by agricultural land, undeveloped land, socially owned land,

17     and typically peasant villages.

18             The structure of the municipality, of course in the case of

19     Sarajevo, took on a somewhat different character, but still the idea was

20     that there was a seat of government located in some area that was the --

21     the centre or near the centre of the municipality, and the municipality

22     was conceived of as and built to be a unit that was rationally

23     geographic, economic, and administrative so that its rationale were

24     essentially those three criteria.

25        Q.   Was ethnicity a factor in this concept?

Page 3091

 1        A.   Generally speaking, it was not.  The purpose of the plan, for

 2     example, of 1976 was to try to develop the economy on a more rational

 3     basis so that many of the productive facilities, factories, were moved

 4     outside of the city, the central city, to peripheral municipalities with

 5     the thought of bringing -- with the intent of bringing the means of

 6     production closer to the workers.  There was no ethnic component or any

 7     discussion of ethnicity about that design at the time.  It was, in fact,

 8     an effort by the city fathers to make the city more attractive as a

 9     competitor for the 1984 Winter Olympics.  So ethnicity in the overall

10     picture of municipality boundaries played no role or very little role in

11     the actual design of where boundaries were placed.

12        Q.   Now, in this answer you've, I think, alluded to Sarajevo when you

13     refer to the Winter Olympics, and when you say ethnicity in the overall

14     picture of municipal boundaries played no role or little role in the

15     actual design of where boundaries were placed, is that also in reference

16     to Sarajevo or is that throughout the former republic?

17        A.   No.  I'd say it's throughout the Republic of Bosnia-Herzegovina.

18     Ethnicity really was not a consideration.  Sometimes people would talk

19     about cultural factors as a -- as a role in the design of the

20     municipality map with the intent of having cultural facilities convenient

21     to large blocks of population.  So that's what I meant by -- that might

22     have been an indirect consideration of ethnicity, but generally speaking,

23     it was an economic, geographic, and administrative concept throughout

24     Bosnia-Herzegovina.

25        Q.   Did Dr. Karadzic or other SDS leaders express opinions about this

Page 3092

 1     concept?

 2        A.   I think from the late 1980s, perhaps even earlier, the Serb

 3     nationalist thinkers, in Sarajevo in particular, developed a critique of

 4     Bosnia-Herzegovina in the Communist era that included the critique of the

 5     municipal structure, and their contention was, and I would point to a

 6     number of early speeches by Dr. Karadzic in which he expressed this view,

 7     their contention was that the municipalities had been drawn to the

 8     disadvantage of the Serb people.  Croats in Bosnia, some of them also

 9     voiced the view that municipalities were developed to the disadvantage of

10     the Croatian people.

11             The critique surfaced into, I think, public discourse in the

12     early days of the election campaign starting in about the summer -- or

13     starting in the summer of 1990 and thereafter became, I think, an

14     important part of the Serb nationalist programme for the SDS and

15     particularly the SDS leaders.

16        Q.   Perhaps at this point we could turn to another map, and that will

17     be final map for today, P783, on the subject of municipality structures.

18             Do you see the map on the screen in front of you, Dr. Donia?

19        A.   Yes, I do.

20        Q.   Are you familiar with this map?

21        A.   Yes.  I used it, referred to it a great deal.

22        Q.   Could you then tell us what it is, please, and what it

23     represents.

24        A.   This map shows the 109 municipalities that made up Bosnia and

25     Herzegovina in the year 1991 at the time of the census.  I liked the map

Page 3093

 1     because it's extremely difficult, in fact impossible, to capture the

 2     ethnic distribution of people's in Bosnia on a two-dimensional object in

 3     any map, but this one to me -- to my mind comes perhaps closer than --

 4     than most to capturing that, because it shows you not only -- it shows

 5     you for each municipality not only the group that has an absolute or a

 6     relative majority in that municipality, but also gives you on the bar

 7     charts the other groups, including those that are --

 8        Q.   Oh, could I just stop you for a moment.  I'm sorry to interrupt

 9     you, but we've just lost the picture of the map that was on the screen.

10     Please continue.  I'm sorry about the interruption, Dr. Donia.

11        A.   The bar graphs, the vertical bars, show the secondary, tertiary

12     and sometimes fourth group, given that there were a significant number of

13     people who in the 1981 and 1991 census declared themselves as others or

14     Yugoslavs.  So one gets a sense from this map not only of what the

15     largest group was in a municipality, that is held an absolute or relative

16     majority, but also what the composition of others -- other groups was in

17     that municipality.  Unfortunately, it doesn't go below the municipal

18     level to show that, but it does at the municipal level show what the

19     population distribution was.

20        Q.   Now, can you relate the population distribution as depicted on

21     this map to the boundaries of the strategic objectives that you depicted

22     earlier for us?  Does the territory encompassed by the strategic

23     objectives cover multi-ethnic areas?

24        A.   Yes, insofar as we can determine from the strategic objectives

25     what was intended in territorial terms.  For example, the east-west

Page 3094

 1     corridor, which was an inherent part of -- which was the essence of

 2     strategic goal number two, runs across the very north part of

 3     Bosnia-Herzegovina, and as one could see from this map, those numerous

 4     municipalities sort of in the upper right-hand part of the map, right

 5     where that corridor would have to run, were indeed very mixed in

 6     composition.

 7        Q.   Now, what about the city of Sarajevo, Dr. Donia?  I recall in

 8     your Sarajevo report you said that it embodied the human diversity of

 9     Bosnia and Herzegovina.

10        A.   Yes.  What I just said about a map not capturing the diversity of

11     identity and the complexity of identity for all of Bosnia-Herzegovina

12     goes doubly so for Sarajevo, and there is an effort here just on -- to

13     the lower right of the -- of the map, a separate representation of

14     Sarajevo, which frankly is not very good because it's not complete, but

15     even just a glance at that shows that there are few areas in the city of

16     Sarajevo that are ethnically homogenous, and, in fact, the complexity

17     ranges -- it gets particularly pronounced in the areas of the city that

18     were settled and built up after 1945, because those housing settlements

19     were largely high-rise apartment buildings, and so people were living on

20     various floors of apartment buildings without any ethnic differentiation

21     whatever.

22             Now, that is true of part of the city.  Other parts of the city

23     as it was created with the ten municipalities in 1977 were more rural but

24     were nevertheless very complex in their ethnic composition.

25             MS. EDGERTON:  Your Honour, I note the time.

Page 3095

 1             JUDGE KWON:  Yes.  Okay.  We'll adjourn for today, and we will

 2     continue tomorrow at 2.15 in the afternoon.  Have a nice evening.

 3                           --- Whereupon the hearing adjourned at 7.01 p.m.,

 4                           to be reconvened on Tuesday, the 1st day

 5                           of June, 2010, at 2.15 p.m.