1 Friday, 17 June 2011
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.02 a.m.
5 JUDGE KWON: Good morning, everyone.
6 Shall we go into private session briefly.
7 [Private session]
11 Pages 14814-14817 redacted. Private session.
18 [Open session]
19 JUDGE KWON: Yes, Mr. Robinson.
20 MR. ROBINSON: Yes. Thank you, Mr. President.
21 Just before the witness is brought back in, I would like to
22 mention something with respect to the 50th motion for disclosure
23 violation, which is presently being considered by the Trial Chamber.
24 You will recall that the Prosecution, in their response,
25 indicated that they were in the process of identifying an additional
1 potential Rule 68 material relating to witness interviews that had been
2 done by the Office of the Prosecutor that may not have been disclosed in
3 a timely fashion by the Trial Chamber's March 31st dead-line, and they
4 attached a transcript of one such interview. And I want to inform the
5 Trial Chamber that in the last few days, we have now received 56
6 additional items that appear to be violations of Rule 68, and they're of
7 great length. There are many witness interviews, some of which are not
8 transcribed and are hours and hours of tape-recorded interview. Others
9 are transcripts that run into the hundreds of pages. And so I wanted to
10 make you aware of that.
11 We have a pending motion to suspend the trial because of these
12 disclosure violations. And at the time this arose, in your absence, with
13 the revelation of an interview with Mr. Cizmovic, we thought that it may
14 have been the tip of the iceberg, and, indeed, we're seeing the rest of
15 the iceberg now.
16 So we are in a position where we have a huge number of items that
17 take a long time to review, that have just been disclosed to us, and we
18 would like you to take that into consideration when you're deliberating
19 on the suspension of the proceedings as well as the issue of appointing a
20 special master.
21 We intend to file a written motion for the 51st disclosure
22 violation motion, but it's probably going to take three to four weeks
23 before we have reviewed all the video material so that we could point out
24 what exculpatory nature of the material is and how we're prejudiced by
25 each individual violation. But in the meantime, I wanted you to be aware
1 that we have received all of this new material, and it has an impact on
2 our being able to continue.
3 Thank you.
4 JUDGE KWON: Very well. It's well noted. Thank you,
5 Mr. Robinson.
6 Let's bring in the witness.
7 [The witness takes the stand]
8 WITNESS: DOROTHEA HANSON [Resumed]
9 JUDGE KWON: Good morning, Ms. Hanson.
10 Very well, Mr. Karadzic.
11 THE ACCUSED: Thank you, Excellency.
12 [Interpretation] Good morning, Your Excellencies. Good morning
13 to everyone.
14 Cross-examination by Mr. Karadzic: [Continued]
15 MR. KARADZIC: [Interpretation]
16 Q. Good morning, Ms. Hanson.
17 A. Good morning.
18 Q. May I draw your attention to the paragraph 57 in your report,
19 where you say:
20 [In English] "Of all the various forces within the crisis staffs
21 dealt -- which the crisis staffs dealt, it is in military matters that we
22 see the greatest variety of patterns. One pattern does not describe the
23 whole range of relations between the crisis staffs and the military
25 [Interpretation] Is that right?
1 A. It's not paragraph 57.
2 Q. [In English] 67.
3 A. Yes, that's what I say.
4 Q. [Interpretation] Further down in paragraph 73, you say:
5 [In English] "Tensions could arise, however, in those places
6 where municipal SDS leaders felt that the JNA was not sufficiently
7 supporting their cause, and the JNA Command was suspicious of the
8 military pretensions of the crisis staffs."
9 [Interpretation] Right?
10 A. Yes, that's what it says there.
11 Q. 74:
12 [In English] "Some crisis staffs took a different tack: rather
13 than co-operate with the existing military structure, they were involved
14 in arming of local Serbs and the formation of Serb units ..."
15 [Interpretation] And so on.
16 Is that right?
17 A. Yes, that's what it says.
18 Q. Can you provide documents showing that crisis staffs formed any
19 units outside the VRS?
20 A. I wasn't referring to the VRS. I was referring to the time
21 before the VRS was formed.
22 Q. Do you mean the Territorial Defence and Civilian Protection;
24 A. I mean, it was formed outside of the JNA or the existing
25 Territorial Defence structures, some of these Serb units.
1 Q. Do you know that according to the law, Territorial Defence and
2 Civilian Protection belong to the municipality, regardless of the JNA?
3 Have you seen -- did you see on Thursday the Law on All People's Defence?
4 It is obviously within the jurisdiction of the municipality; correct?
5 A. Yes, on Wednesday we saw the Law on All People's Defence. It is
6 within the jurisdiction of the municipal authorities. But this sort of
7 thing, I do have several documents that show that the SDS was forming
8 units outside of the municipal TO or the JNA.
9 Q. We'll come back to that, but we should bear in mind the law that
10 you did not take into account.
11 Let us look at paragraph 79:
12 [In English] "Some cries staffs did, indeed, explicitly distance
13 themselves from direct military command."
14 [Interpretation] And you give some examples. And in
15 paragraph 81.
16 [In English] "Other crisis staffs were also prepared to interpret
17 the government and party instructions in a manner that gave them command
19 [Interpretation] And then in 90:
20 [In English] "As the Kotor Varos Crisis Staff put it, 'The Crisis
21 Staff reviewed the work of the SJB. The Crisis Staff concluded that it
22 does not have the right to interfere with the professional work of the
23 police and army.'"
24 And then --
25 JUDGE KWON: What paragraph was it?
1 THE ACCUSED: [Interpretation] 90.
2 MR. KARADZIC: [Interpretation]
3 Q. And 91:
4 [In English] "Other crisis staffs were much more assertive in
5 their authority over the Serb police forces."
6 [Interpretation] Is that right?
7 A. Yes.
8 Q. Thus, in some municipalities it is one way, and in other
9 municipalities it is another way, so things vary from municipality to
10 municipality; correct? Both with regard to the army, and with regard to
11 the police, and to the Territorial Defence and the JNA; correct?
12 A. I say that within discussion -- discussing the army, that is, the
13 JNA, TO, VRS, there's a spectrum with considerable variation upon it. I
14 say that with regards to the police, there's a more consistent pattern
15 because, for one thing, the commander of the police was always a part of
16 the Crisis Staff. So there are distinctions, as I see, between
17 Kotor Varos -- the statement from Kotor Varos and what we see in some
18 other places about the extent of their interference in the execution of
19 the police tasks, but I see the relationship as much closer and
20 consistent with the police than with the other armed forces.
21 Q. Thank you. How many municipalities have you reviewed?
22 A. I reviewed the documents that we have in our -- in evidence. For
23 some municipalities, we have a great deal of documentary evidence. For
24 others, we have only a very scanty collection. Some, we have none at
25 all. So I would have to count through. You can see in my footnotes I
1 bolded the name of each municipality for ease, and I -- just sort of
2 going through the footnotes, we could go through and count. But I really
3 couldn't say, off the top of my head, how many municipalities I had
4 actually documents from.
5 Q. May I then assist you, perhaps? Is that 10, 15 municipalities?
6 A. No, more than that.
7 Q. Is it 20? Let's begin with the west, Novi Grad. You took that
8 into consideration; right?
9 A. Do you mean the former Bosanski Novi or Sarajevo Novi Grad? I
10 did both.
11 Q. Bosanski Novi. Bosanski Novi, Prijedor - I'll
12 enumerate - Sanski Most, Kljuc, Banja Luka? Did you take Banja Luka into
14 A. There are a few documents of a Banja Luka municipal Crisis Staff.
15 I didn't have many of those. It was hard to distinguish between the ARK
16 Crisis Staff and the Banja Luka municipal authorities. But I do have
17 something from the Banja Luka War Presidency, so, yes.
18 Q. Thank you. Krupa, Petrovac -- Bosanska Krupa, Petrovac,
19 Sanski Most. In the middle municipalities, that's Bosanski Brod, Brcko,
20 Bijeljina --
21 A. Brcko and Bijeljina, I had documents. Bosanski Brod, I'm not
22 sure I did. Only one or two, if I found anything.
23 Q. Good. Do you know how many municipalities there were in
24 Republika Srpska?
25 A. In Republika Srpska, no, I don't. As I said, there were about
1 100 and -- between 100 and 110 municipalities in the Republic of
2 Bosnia-Herzegovina. I don't know how many -- presumably fewer in
3 Republika Srpska.
4 Q. Do you accept that with the newly-established municipalities --
5 entire municipalities that were not divided and the newly-established
6 municipalities, Republika Srpska had 61 or 62 municipalities, but there
7 were 55 major large municipalities; correct?
8 A. That seems quite possible, but I have no basis for -- I never
9 counted them in that way, so I have no basis for agreeing or disagreeing.
10 It seems likely.
11 Q. So you perhaps took into account one-third or perhaps one half of
12 all municipalities and studied them, and within that framework, you were
13 not able to establish a pattern. Why didn't you take into account the
14 other municipalities? If it is about state policy of persecuting a
15 minority population coming from the central level, from a powerful leader
16 or an authoritarian regime, as your predecessor called them, if it's
17 state policy, it is applied in the entire republic, whereas you did not
18 manage to find and determine a pattern even in this limited number of
19 municipalities. Why did you not review all the municipalities to tell us
20 what those central authorities did?
21 A. As I said, I am limited by the evidence in the possession of the
22 OTP. I reviewed the evidence available to me as thoroughly as possible.
23 There were many municipalities where evidence was never collected. I
24 have noted throughout my report that I'm limited to the evidence
25 available to me.
1 Q. Thank you. Are you trying to say the Prosecution did not take
2 into account the entire territory of Republika Srpska, that it did not
3 investigate what happened in Srbac, for instance? Have you heard of that
4 municipality, Srbac?
5 A. Yes, I've heard of Srbac.
6 Q. Do you know that in that municipality, some Muslims remained to
7 live together with us, they were in the army, they were well respected,
8 and there was not a single problem? Did you investigate -- did you
9 research why?
10 A. I am aware that some Muslims remained in Srbac. I am not -- I
11 have no basis to say how well respected they were or that there was not a
12 single problem. I did not -- I was unable to investigate Srbac because
13 there was no evidence available to me on Srbac. I didn't have access to
14 the Crisis Staff minutes, or decisions, or the Municipal Gazette of
16 Q. Thank you. Are you saying that they did not give evidence to
17 you, or was there no evidence? Did the OTP ever investigate things and
18 see -- in Srbac in order to find whether the Serbs there were guilty of
19 any sins? I'm asking you about Srbac, but I'm not limiting myself to
20 that. They made your selection for you, and you, in your turn, were even
21 more selective and you narrowed down your research to some documents
22 which do not portray a very clear picture, they do not reflect what you
23 purport to say in your report; right?
24 A. There are many questions that you've asked. Do you want me to
25 take them in order or just answer the last one?
1 JUDGE KWON: It's in your hands, Ms. Hanson.
2 THE WITNESS: All right.
3 "They" did not -- who are "they"? I have complete access to all
4 the evidence in the possession of the OTP. Their evidence is limited to
5 where they investigated and collected evidence or what evidence they have
6 received from other sources. Nobody limited my access to anything. I
7 had access to everything there is here. I did not go out into the field
8 and collect evidence of non-investigated -- uninvestigated
9 municipalities. I believe they did not investigate Srbac because they
10 did not hear of crimes committed there. The OTP's mandate is to
11 investigate crimes, not to investigate the entire history of every
12 municipality in the Republika Srpska.
13 That there were some places where crimes did not occur does not
14 alter the crimes that did occur.
15 Q. Ms. Hanson, you are trying to establish a link between the
16 central authorities and the chaotic events that happened during the civil
17 war. Why didn't you list any of the municipalities where crimes did not
18 happen, and why didn't you say, then, these people did not listen to what
19 Karadzic was saying or Karadzic did not instigate any crimes there?
20 You're talking about central authorities. The president of a republic is
21 on trial here, and the OTP is trying to prove that what was happening
22 during the case of a civil war was something that the central authorities
23 were behind. Why didn't you take into account so many municipalities
24 where nothing of the sort happened?
25 A. I do not say -- I do not say that Karadzic instigated crimes
1 here. I say that crisis staffs considered themselves part of the Bosnian
2 Serb state system and took orders and instructions from the central
3 organs from the republican level. And I do, indeed, cite in my footnotes
4 some municipalities where, as far as I know, crimes have never been
5 charged, simply because they provided evidence of the links, not of links
6 that had to do with crimes, but simply links. For example,
7 Bosanska Dubica, Bosanska Gradiska, I had their municipal gazettes. I
8 don't know how those came into the possession of the OTP, but they were
9 there, I looked at them and I saw that they received Djeric's
10 instructions, formed crisis staffs, recognised the republican authority.
11 I also see that those crisis staffs, in municipalities where there was a
12 large-scale moving out of population, that they did it with such a
13 similar pattern that it's hard to believe it was spontaneous that they
14 all formed these agencies, that they all met and said, Let's move out our
15 Muslims; not all of them, but the seven municipalities. But I see enough
16 co-ordination between municipalities on the issue of moving out and I see
17 instructions and communications on various topics from the republican
18 level to the municipality that I concluded that there was -- that the
19 crisis staffs operated as part of a state system and that there appears
20 to be, among the municipalities, a co-ordinated policy of moving out the
22 JUDGE KWON: Ms. Hanson, let me put it this way: You stated that
23 there was some places where crimes did not occur, does not alter the
24 crimes that did occur. Would it be, by any chance, possible that they
25 have an impact upon whether they are of a systematic and widespread
2 THE WITNESS: Well, certainly if the majority of municipalities
3 were peaceful and a minority were not, that would influence how
4 widespread and systematic.
5 JUDGE KWON: Thank you.
6 Mr. Karadzic, please continue.
7 MR. KARADZIC: [Interpretation] Thank you.
8 Q. Ms. Hanson, before the Judge's question, you tried to speculate
9 as to what may have influenced things and how. Why speculate, if you
10 have Prime Minister Djeric's instruction before you? In his instructions
11 on the work of the crisis staffs, did Prime Minister Djeric aid, abet, or
12 instigate or order crimes, or was the situation just the opposite?
13 A. In his instructions, Djeric does not aid, abet, or instigate or
14 order crimes.
15 Q. Did he provide instructions against crimes, against violations of
16 the humanitarian law and so on and so forth? You established that his
17 instructions were implemented -- or, rather, first received and then
18 implemented by the crisis staffs; right?
19 A. His instructions do provide instructions against crimes --
20 against violations of humanitarian law. I do establish that his
21 instructions were received and implemented in the municipalities. The
22 extent of implementation -- the extent of implementation of every single
23 article, no, I don't go through that, but I do show that they were
24 received as an indication of the role of the crisis staffs in the state
25 system, and I see crisis staffs operating according to these
2 Q. Thank you. In your paragraph 45, you say:
3 [In English] "The municipal crisis staffs co-ordinated the Serb
4 military, political and administrative forces involved in seizing and
5 maintaining control on the ground."
6 [Interpretation] Let's leave "seizing and maintaining control"
7 aside in the municipalities which were growing. Why didn't you stick to
8 your own statement that they co-ordinated the existing structures of
9 power? Why did you turn them into some sort of authorities beyond the
10 existing authorities?
11 A. I'm sorry, it's not in paragraph 45.
12 Q. [In English] 145.
13 A. 145, okay.
14 Q. 145:
15 "The municipal crisis staffs co-ordinated the Serb military ..."
16 [Interpretation] You adhere by your statement that the crisis
17 staffs co-ordinated Serbian military, political and administrative
19 A. Yes. I stand by that.
20 Q. Did you establish that not even in the limited number of
21 municipalities, you could not find the pattern? Some of the
22 municipalities that you studied did not even have a crisis staff, and
23 there are so many municipalities that you did not even take into account.
24 You say, in your paragraph 67, that there was no pattern?
25 A. In paragraph 67, I'm referring explicitly to the question of
1 relations with the military, and I say that the minimum that we see
2 everywhere is co-ordination with the military, support of the military
3 effort. That is the common denominator. That is not in contradiction
4 with paragraph 145, which says they co-ordinated the military, political
5 and administrative forces. I think that's not -- I think that those are
7 Obviously, if I was tasked to look at Bosnian Serb municipal
8 crisis staffs, I looked at the crisis staffs. I didn't look at the
9 municipalities where there were not crisis staffs formed, because that
10 was not my tasking. I do note that there are some municipalities that
11 did not form crisis staffs before March, when, in the Assembly, you
12 called for Serb municipalities to form crisis staffs. I note that most
13 of the crisis staffs formed in December are in the Serb minority
14 municipalities. Again, all I can say is I'm limited to the evidence
15 available and to my tasking.
16 Q. Ms. Hanson, I have to ask you once again. Do you make a
17 distinction between the crisis staffs of the party which were suggested
18 in December and the crisis staffs of the municipalities which I referred
19 to on the 27th of March, 1992?
20 A. No, I do not, because I saw that you did not in your speeches in
21 1994 and 1995 that you did not. You refer explicitly back to A and B as
22 the basis of the municipal authorities. I see in Kljuc and Sanski Most
23 an emphasis on the continuity. I see in many documents of these crisis
24 staffs, their use of the SDS, even as interchangeable with the Serbian
25 municipality, the use of the stamps interchangeably. I see continuity
1 between the A and B crisis staffs and December crisis staffs and those
2 operating as municipal authorities in the spring.
3 JUDGE KWON: Ms. Hanson, did you note the transcript?
4 THE WITNESS: Yes. My apologies to the interpreters.
5 THE ACCUSED: [Interpretation] Could the Court please produce P12;
6 English 2, Serbian 1.
7 MR. KARADZIC: [Interpretation].
8 Q. Let us see what, on the 14th February, the day after the
9 beginning of the Conference on Bosnia, I said about the same things that
10 you are talking about.
11 The document number is P12. We need number 2 in English.
12 I'm going to read for you from the second paragraph in the
13 Serbian language:
14 "We hope that the deputies are stepping up their activity in the
15 municipalities, because as we concluded the last time, representatives is
16 authority for a party and parties are a service to elected people, to the
17 people and to people, elected by the people to carry out -- to carry out
18 the political will of the people."
19 JUDGE KWON: Slow down. Slow down.
20 THE INTERPRETER: [Previous translation continues]... passages in
21 English. Thank you.
22 MR. KARADZIC: [Interpretation] "To carry out the political will
23 of the people."
25 Party officials are not authority to us. Authority for us are,
1 first of all, the representatives, then representatives in municipal
2 assemblies and others.
3 Q. Why did you neglect the fact that a party is not power, but only
4 a service to the people who elected them?
5 A. I do not think I neglected that. In my report, I note that in
6 the period January to March, while the SDS deputies were creating the
7 organs and institutions of the Bosnian Serb state, the emphasis was on
8 the role of the Assembly deputies as the link back to the municipalities.
9 As we know, they were to be on the crisis staffs. And you said that they
10 must go and sit next to the president of the municipal assemblies because
11 the president -- the municipal president is the one who actually takes
12 action on the ground, but the Assembly deputies are to make sure that
13 their actions are in line with SDS policy.
14 I do emphasise the authority of the deputies there. The deputies
15 are part of the crisis staffs. So are the municipal officials part of
16 the crisis staffs. So I don't think that I neglected that.
17 THE ACCUSED: [Microphone not activated]
18 JUDGE KWON: Mr. Karadzic, microphone.
19 THE ACCUSED: [Interpretation] I apologise.
20 Let's look at D034, and let's see what I referred to on the 27th
21 of March, when I asked the municipalities to form their crisis staffs.
22 MR. KARADZIC: [Interpretation]
23 Q. In the previous document, you see that power consists of
24 representatives, deputies, and other elected people, whereas the party
25 and the crisis staffs only helped them, they act as their service. The
1 deputies and representatives who were elected by the people constitute
2 the real power. Am I right in saying that?
3 A. The deputies made up the Bosnian Serb republican-level assembly
4 which, as I said, set up the organs of the Bosnian Serb state. But to
5 say that they are the only power, that ignores the entire municipal
6 structure, also ignores the Government of the Republic of
7 Bosnia-Herzegovina. So, no, I can't agree that only SDS deputies to the
8 Bosnian Serb Assembly are the only power.
9 Q. Well, I have mentioned everybody; deputies in the municipalities
10 and others, secretaries, and so on and so forth. What I was trying to
11 emphasise is that a party people were not the power, but just a service.
12 But it's very difficult for you to understand that, Ms. Hanson, I
14 We have not got the right document. It has to be 65 ter 1000.
15 Maybe it will be easier to get the right document in this way. D304,
17 There's something wrong with my articulation, obviously.
18 Serbian, 33; English, 20, please.
19 MR. KARADZIC: [Interpretation]
20 Q. I will be reading for you:
21 [In English] "When you returned ..."
22 [Interpretation] In English, it's in the middle of the page. I'm
23 going to read now:
24 "When you returned to your municipalities, especially the
25 newly-formed municipalities, I ask you to do what you are required and
1 entitled to do under the law. The moment you arrive in your
2 municipalities, you must urgently establish crisis staffs. You must try
3 to organise the people so that they can defend themselves."
4 And so on and so forth.
5 Do you note here that I am referring to the law here? Why didn't
6 you check what law was I referring to in here?
7 A. I see that you are referring to the law. As I said, I have
8 checked the laws and did not find any reference to crisis staffs.
9 Q. However, Madam, did you find a law pursuant to which a
10 municipality is entitled to carry out measures in emergencies? Why
11 didn't you ask yourself, What law did Karadzic have in mind here?
12 A. As I indicate in my section on the legislative origins, I thought
13 the law you were referring to was regarding municipal presidencies or all
14 people's defence committees. The question, though, is how much --
15 whether the law allowed for, for example, the formation of Serbian
16 municipalities, and how much the law -- the letter of the law was your
17 main motivation here.
18 I see you appealed to the law. I didn't inquire into the
19 legality, under the existing legal system, of each step, because I do not
20 say that the formation of crisis staffs, themselves, was a crime. I take
21 no stand on that. I describe the process of how they were formed, but
22 whether they were legal or not I see as not as important as what they
24 JUDGE BAIRD: Ms. Hanson, I don't quite follow that. I don't.
25 Please help me.
1 THE WITNESS: It may be that crisis staffs were, indeed, provided
2 for under the legislation of the Republic of Bosnia-Herzegovina, but it
3 doesn't follow that if they -- which I haven't seen, as I emphasised, I
4 haven't seen that. But the relationship between the laws of the Republic
5 of Bosnia-Herzegovina and the actions of the crisis staffs set up in
6 self-declared Serbian municipalities, even if there is a legal basis for
7 them - we certainly see there's a legal basis for municipal
8 presidency - that doesn't change whether the actions they took that
9 contributed to the crimes occurring -- it doesn't mean that their actions
10 were legal, even if they had a legal basis. You can have a
11 legally-elected president who commits -- and I'm not -- that was just an
12 example, I'm not referring to Dr. Karadzic in this case, but of any
13 country -- who commits crimes, but even if he's legally elected, he can
14 still commit a crime.
15 JUDGE BAIRD: Thank you.
16 THE ACCUSED: [Interpretation] Thank you.
17 Well, let's look at how all that looked like in Bosanski Novi,
18 which is a municipality that you mentioned.
19 Could the Court please produce --
20 THE INTERPRETER: Could the accused please repeat the number.
21 JUDGE KWON: Could you repeat the number, Mr. Karadzic?
22 THE ACCUSED: [Interpretation] 65 ter 6733.
23 MR. KARADZIC: [Interpretation]
24 Q. Please pay attention to this document. This is a report on the
25 work of the Crisis Staff of the Municipality of Bosanski Novi. Look at
1 the second paragraph, where it says:
2 "The other significant issues and questions which were not easy
3 to answer at the time was, for example --"
4 It has to be the following page in English.
5 And where it says:
6 "On the 20th of April, a part of Novska Battalion," still the
7 JNA, "that was stationed in Jasenovac, under the command of
8 Veljko Risojevic, came to Bosanski Novi and raised Serbian flag at
9 certain spots in the town, forcibly and under the threat of arms."
10 And now I'm just giving you my interpretation. You can see that
11 the Crisis Staff opposed that.
12 And then it says:
13 "On the 4th of May, concrete talks started with the
14 representatives of the SDA with regard to the current political
16 The war had been going on for a month already, and they were
17 still talking to the SDA; right?
18 A. Yes, it says they're talking to the SDA.
19 THE ACCUSED: [Interpretation] We need the second page in Serbian,
20 the third in English. I believe that you have already moved on to that.
21 MR. KARADZIC: [Interpretation]
22 Q. And then it says:
23 "A curfew was introduced between 10.00 in the evening and 5.00 in
24 the morning, and all the unlawfully-armed individuals and paramilitaries
25 were invited to immediately, and not later than 11 May 1992, surrender
1 their weapons either to the Municipal TO Staff or to the SJB. After that
2 dead-line, searches," it says here --
3 People were not being disarmed along the ethnic --
4 JUDGE KWON: I don't think the interpreters are following at this
6 THE INTERPRETER: It's very difficult to find the passage,
7 Your Honour.
8 JUDGE KWON: Of course.
9 Could you check the transcript and start again from the part they
11 MR. KARADZIC: [Interpretation]
12 Q. "The curfew between 22 and 05 hours was introduced, and all the
13 unlawfully-armed individuals and paramilitaries were invited to
14 immediately, and no later than 11 May 1992, surrender their weapons
15 either to the Municipal TO Staff or to the SJB. After this dead-line has
16 passed, the searches will be carried out, with the application of force."
17 Ms. Hanson, are they issuing this appeal to just one ethnic
18 community? What was the basis for the surrender of weapons? Was it the
19 ethnic background of those who held them or was it the fact that they had
20 been unlawfully obtained?
21 A. In this text, they do not mention any ethnic criteria. In
22 practice, I believe, in many municipalities, that was not the case in
23 practice, but the terminology used in this public report does not give
24 any ethnic criteria, simply the question of how the arms were -- whether
25 they were illegally armed or not.
1 Q. Well, let us stick to the subject, Ms. Hanson. Now we're not
2 talking about other municipalities. We're talking about these
3 municipalities. And you have seen that the Crisis Staff opposed the Serb
4 from the JNA who hoisted a Serbian flag over the municipality, and you
5 see that it's not only the Muslims who are invited to surrender the
6 weapons, but all of those who possess them illegally. Have we agreed
7 about that?
8 A. Yes, that's what it says here.
9 THE ACCUSED: [Interpretation] Thank you.
10 Can we see page 4 in English about negotiations. I'm retelling
11 it. Every time when representatives of the SDA -- it's midway through
12 the paragraph:
13 "In the implementation of the government's decision on disarming,
14 every time the SDA representatives demonstrated their readiness to make
15 it a success. However, it turned out that they either had little
16 influence on the Muslim people or they were working on a double track,
17 saying one thing at the negotiations, then saying something completely
18 different to their supporters and members."
19 Can we see page 5 in English.
20 You will see in this paragraph: "On the 11th of May ..."
21 That's how it begins. No, it's the same page. Oh, sorry. The
22 beginning is on page 4.
23 There was some shoot-out by the military police, and the
24 Crisis Staff criticises that:
25 "Pursuant to an order by the Crisis Staff issued around 1800
1 hours on the 11th of May, a cease-fire was ordered."
2 Next page in English.
3 And it says:
4 "On the 12th of May, the commander of the TO Municipal Staff
5 presented the current situation and said that TO Staff did not issue any
6 order to open fire at Bosanski Novi, except for Blagaj, where warning
7 shots were fired when the military police was attacked."
8 It was his assessment that he is unable to control the entire
9 territory of the municipalities because certain groups are distancing
10 themselves from the chain of command and not obeying orders, and are
11 acting on their own initiative.
12 "Such large numbers of armed people should be placed under
14 JUDGE KWON: Just a second.
15 Yes, Ms. Sutherland.
16 MS. SUTHERLAND: Does Mr. Karadzic have a question for
17 Ms. Hanson? He's just reading text into the record.
18 JUDGE KWON: I take it he's going to ask a question very soon.
20 THE ACCUSED: [Interpretation] Yes, yes, let me just finish this
21 paragraph, and then I'll come up with a question:
22 "Simultaneously, other armed groups are appearing that hold
23 themselves out to be regular units, army or police. But in reality, they
24 are under nobody's control and they are looting.
25 "After this analysis of the situation, the Crisis Staff distanced
1 itself from the activities by all such illegal groups and paramilitary
3 That was the conclusion dated 13 May 1992.
4 MR. KARADZIC: [Interpretation]
5 Q. Did you observe, Ms. Hanson, and did you put it in your report
6 that there had been groups under nobody's control, and that the
7 Crisis Staff disowned and said that they need to be placed under control?
8 A. No, I did not put that in my report.
9 Q. Thank you. Do you know that the war in Croatia had only just
10 finished, if at all, and that all over that territory there were many
11 people milling around, carrying their weapons from that war, because
12 Bosanski Novi is just on the border with Croatia? Perhaps the
13 Trial Chamber doesn't know that.
14 A. I know that many troops were withdrawn from Croatia into Bosnia
15 at this time. Many units withdrew and were relocated in Bosnia. But
16 people milling around, carrying weapons, I find that difficult to address
17 directly. But, yes, we see that in several municipalities, that the
18 return of troops, largely Serb, from Croatia raised tensions in many
20 Q. Was the local Muslim population armed, and did the Muslims also
21 have their own uncontrolled elements or were they under somebody's
23 A. This document indicates that the Muslims did have arms. It
24 doesn't give an indication of what kind or how many, nor does it give an
25 indication of whether they were under somebody's control. As I said, the
1 troops that were returning were largely Serb and had been armed by the
2 JNA, came back as JNA units. Most Muslims did not respond to the call-up
3 for the war in Croatia, so they were not getting arms from the JNA. I
4 have no basis to answer whether they were uncontrolled or under
5 somebody's control.
6 THE ACCUSED: [Interpretation] Thank you.
7 Can we see English page 6 and Serbian 4.
8 MR. KARADZIC: [Interpretation]
9 Q. It says nicely here all these organs were ordered, and that's at
10 the beginning of page 4 in Serbian, and the beginning of the paragraph is
11 after the analysis of that situation. These organs were ordered and
12 authorised to disable the work of such illegal persons and remove them
13 from the territory of the municipality.
14 Further below, it says:
15 "With the involvement of the military police and the
16 Banja Luka Corps, to assess the situation and search the terrain,
17 including incidents in Urije town."
18 And then it enumerates other places along the Japra River Valley
19 where order needs to be restored. And then it says:
20 "The assignments given by the Crisis Staff have not been
21 implemented. Field reports say that TO armed forces are not under the
22 control and subordination of the TO Municipal Staff Command."
23 End of that paragraph:
24 "TO forces must be placed under strict control of the superior
25 command, and all instances ..."
1 That's actually page 7 in English.
2 "... and all instances of violation of discipline and misconduct
3 shall be severely punished."
4 And below that:
5 "The Government of the Serbian Republic of Bosnia and Herzegovina
6 belatedly sent instructions to all municipalities."
7 In our municipality, it was received on the 20th of May. It was
8 sent on the 26th of April, but arrived on the 20th of May; correct?
9 A. Yes, that's what this report says.
10 THE ACCUSED: [Interpretation] Thank you.
11 Can we see Serbian page 5 --
12 THE INTERPRETER: Thank you for indicating where the passage is
13 in English.
14 MR. KARADZIC: [Interpretation]
15 Q. ... all these are officials, members of the municipal government,
16 deputy president, commander of the Territorial Defence.
17 And then number 9:
18 "Milan Radulovic, in charge of war crimes and damage."
19 Do you know the Crisis Staff appointed a special officer for war
21 A. I see that here. I note that municipalities were charged to
22 investigate war crimes against Serbs. There's no indication here of the
23 ethnic -- of any ethnic criteria for the war crimes, perpetrators or
25 Q. And where did you find it, that investigations were made only
1 into crimes against Serbs? Are you perhaps confusing the Documentation
2 and Investigation Centre in the Federal Bosnia and Herzegovina with the
3 regular police work in investigating all crimes?
4 A. No, I'm thinking of the instructions from the member of the
5 Presidency, Biljana Plavsic, to investigate and document war crimes
6 against Serbs.
7 Q. We'll find that very soon. Ms. Hanson, do you accept that the
8 Serbian police was not able to investigate crimes in territories
9 controlled by the Muslim army?
10 A. Yes.
11 Q. Do you know that a documentation centre was established for that
12 purpose, headed by a literary man, not a lawyer, Miroslav Toholj, to
13 document and investigate what the police was unable to?
14 A. I've heard of the Documentation Centre, I've heard of
15 Miroslav Toholj. What that centre was charged with and whether it was
16 what the police were unable to do, I have no basis to answer that
17 question. I don't know about that.
18 THE ACCUSED: [Interpretation] Could we see 1D3585 briefly.
19 MR. KARADZIC: [Interpretation]
20 Q. Ms. Hanson, we are expected, and you are expected, and everyone
21 who is dealing with this legal case is expected to precisely determine
22 this: The Documentation Centre for investigating crimes in other
23 territories is not the same as investigating on your own territory;
25 A. I'm sorry, I don't know enough about the Documentation Centre to
1 answer that question.
2 Q. Well, the centre, headed by Toholj, was a documentation centre,
3 not an investigation centre; correct?
4 A. I'm sorry, I don't know enough about the centre to answer
5 questions about it.
6 Q. Thank you. Look at paragraph 2 here. Do you agree that these
7 are instructions from the Ministry of the Interior, the Serbian Republic
8 of Bosnia and Herzegovina, sent to centres in Banja Luka, Bijeljina,
9 Doboj, Sarajevo, Trebinje? Paragraph 2 reads:
10 "A questionnaire will be completed at security services centres
11 for all persons, regardless of ethnicity (Muslims, Croats, Serb,
12 et cetera) against whom criminal reports are filed because of reasonable
13 suspicion that they are responsible for crimes."
14 This is an instruction on the documentation and investigation of
15 war crimes, as we can see in paragraph 1. And in paragraph 2, it says:
16 "Without discrimination." Have you read this? Why do you keep
17 maintaining the Serbs investigated only crimes against Serbs?
18 A. This is not in my report because it's not about crisis staffs. I
19 do not state in my report, as far as I can recall, that -- I don't enter
20 into the question of police investigations into war crimes or crimes.
21 That wasn't in -- I didn't find that in the scope of my report.
22 Q. But, Madam, you invoke wrongly Biljana Plavsic, who asked that
23 this be documented, and here the police is required to investigate,
24 regardless of faith and nationality. You are misstating facts in an
25 attempt to support the theory about Serbian culpability.
1 A. I have no theory about Serbian culpability. There are
2 individuals charged. The nation is not charged. I talk about the
3 Bosnian Serb leadership, and I don't like being accused of just -- of
4 blaming all Serbs.
5 Yes, I agree, this document says "to investigate all the crimes,
6 regardless of nationality." I do believe that there is a document from
7 Biljana Plavsic. I didn't include it in my report because it wasn't
8 addressed specifically to crisis staffs. Perhaps it will come up
9 somewhere -- some other time in the course of the trial. I wasn't
10 talking about this document when I mentioned the one from Plavsic.
11 THE ACCUSED: [Interpretation] Thank you.
12 Can this document be admitted?
13 I don't have time to ask you whether this minister was part of
14 the Bosnian Serb leadership.
15 MR. KARADZIC: [Interpretation]
16 Q. Was this minister part of the Bosnian Serb leadership,
17 Mr. Mico Stanisic?
18 A. Yes.
19 THE ACCUSED: [Interpretation] Thank you.
20 Can this be admitted?
21 JUDGE KWON: I take it the previous Bosanski Novi document has
22 been already admitted.
23 THE ACCUSED: [Interpretation] We'll come back to it.
24 JUDGE KWON: It was P2632, if I'm correct.
25 And we'll admit this as a Defence exhibit.
1 THE REGISTRAR: It will be D1360, Your Honours.
2 MR. KARADZIC: [Interpretation]
3 Q. If this document has been admitted, let me ask you, Madam: Are
4 you aware of this document, and do you agree that in here the
5 Crisis Staff - Serbian page 6, English 9 - says that its orders have not
6 been honoured and that complete chaos occurred? It straddles pages 8 and
7 9 in English and pages 5 and 6 in Serbian.
8 Can we get back that previous document, 65 ter --
9 THE INTERPRETER: The interpreter didn't get the number.
10 JUDGE KWON: 6733.
11 THE ACCUSED: [Interpretation] P2632, the previous one about
12 Bosanski Novi; Serbian page 5, English 8. Serbian 5, English 8.
13 MR. KARADZIC: [Interpretation]
14 Q. This deals with the problems in the Japra River Valley, the
15 sectoral TO Staff for Agic, Rujinka and Krsalj, Muslim-populated places,
16 turned a deaf ear to the endeavours of the official policies and organs
17 of the authorities and started to deal with things on their own.
18 Then a conflict started and expulsion of Muslim civilians from
19 one village to another village. And:
20 "The Crisis Staff reacted vigorously and issued an order to the
21 Municipal TO Staff that they should immediately place all their members
22 and units under their control ..."
23 So it says here the order was not followed. And on pages 6,
24 English 9, it says:
25 "Complete chaos has begun to reign."
1 Ms. Hanson, in your footnote 162, you characterise these events
2 in Bosanski Novi as ethnic cleansing, led by the Crisis Staff, whereas
3 you have evidence that the Crisis Staff is warning against chaos and
4 issuing orders completely contrary to what you describe. It's
5 paragraph 99, I believe, and footnote 169 in your report. That's what
6 you say:
7 [In English] "Examples of crisis staffs actually setting forced
8 deportation as a policy include:"
9 [Interpretation] And you say "Bosanski Novi" among them, Blagaj,
10 the Japra River Valley.
11 So you ascribe this chaos, you blame it on a deliberate process
12 controlled by the Crisis Staff?
13 A. The letter from the president of the Crisis Staff, Radomir Pasic,
14 to the population of the Japra Valley says, If you don't move out, we
15 can't guarantee your safety, which caused a lot of people to move out,
16 thinking that the authority -- the municipal authorities refused to
17 guarantee their safety, or were unable to guarantee their safety,
18 perhaps. But I think if you consider the people being held in the
19 stadium at this time, the discussions with UNPROFOR and others to help
20 the Muslims of Novi, that you have to understand a report like this,
21 which was written to be adopted by the Municipal Assembly when the
22 Crisis Staff finished its work, involves a lot of passing the blame on.
23 A lot of these reports sort of say, Crimes happened, but it wasn't us,
24 things were out of our control. They may be true, they may not. It's
25 part -- it's part of the whole context and setting here. Yes, Pasic
1 says, It was out of our control. He says that here. He threatened the
2 Muslims that if they didn't leave, he couldn't guarantee their safety.
3 Whether this was forced or voluntary depends on your view of the context,
4 and I do not entirely trust the language of reports like this when they
5 are endeavouring to cast blame elsewhere. I see this kind of language in
6 a lot of the -- when I rely on documents written by the crisis staffs,
7 themselves, I focus on what they say they did. The whys can be less
9 Q. With all due respect, Ms. Hanson, your task was to present all
10 the facts to the Trial Chamber, and then the Trial Chamber can decide
11 whether they are credible or not. Is that right?
12 A. All facts? No. The Trial Chamber will be hearing, I believe --
13 I don't know -- I don't even remember what's charged in Bosanski Novi
14 because I'm not familiar with the current state of the indictment, but I
15 imagine the Trial Chamber will also be hearing from other people about
16 events in Bosanski Novi. My job was to present documents, not the whole
17 story that is unavailable in the documents of the crisis staffs or
18 contemporary records at the time. I am not supposed to be presenting
19 material outside of the documents.
20 Q. Madam, we are going around and around. Despite what you say,
21 that you are supposed to present documents, you have not presented
22 documents. You did not take into account the chaos of war and the
23 efforts of the Crisis Staff in Bosanski Novi to restore order and peace.
24 You characterised it in a certain way. You made a judgement that the
25 Crisis Staff in Bosanski Novi controlled the situation and led the
1 expulsions of Bosnian Muslims. And with a selective way, you treat
2 documents. What you are doing is you are being very selective and you
3 are deciding for yourself which ones to believe and which not.
4 A. Part of my job, as an analyst, is not to believe every document
5 on its face value. I do cite this document. I read it. But noting that
6 the Crisis Staff did have the forces and the ability to secure a convoy
7 of people to leave the municipality, but they didn't seem to have the
8 ability to protect those people within the municipality, I did not
9 believe all of the justifications they cite in this report.
10 Previously, in my first report, all the documents on which I
11 relied were also given to the Court, and I'm very glad to have as many
12 documents as possible made available to the Court. The process changed
13 because there were a lot of documents. The more documents the Court can
14 see, the better they can draw their own conclusions. But I also note
15 that this report starts out, right at the beginning, discussing how the
16 Crisis Staff was formed on the instructions of the Main Board of the SDS.
17 So I rely more on what they say they did than their motivations for it.
18 When I rely only on documents written by crisis staffs, there's a
19 lot of, let's say, blaming others, protecting themselves. These are
20 documents issued for the whole municipality to be discussed at the
21 Municipal Assembly. I don't think crisis staffs usually say, We did all
22 this. They don't list everything they do, and they're not always honest
23 about what they -- why they did it.
24 I hope the Court will hear more evidence of events in
25 Bosanski Novi in which they'll be able to put this document in context.
1 Q. Are you trying to say that crisis staffs are misinforming their
2 own leadership?
3 A. When they're submitting their reports to the municipal
4 assemblies, I think they -- or in their own minutes, I think they choose
5 words to make themselves look as good as possible.
6 THE ACCUSED: [Interpretation] Excellencies, I note the time. Can
7 I be given at least another half an hour, because there is a clear gap
8 between my needs and with what I have been able to achieve. And if you
9 given me another half an hour, I may be able to just fill in some of that
10 gap. If I'm able to finish before that half an hour expires, I'll try to
11 do that.
12 [Trial Chamber confers]
13 JUDGE KWON: Given that you haven't wasted time today, and that
14 as long as you remain on relevant issues, we'll grant that.
15 We'll have a break for half an hour.
16 --- Recess taken at 10.31 a.m.
17 --- On resuming at 11.00 a.m.
18 JUDGE KWON: Yes, Mr. Karadzic.
19 THE ACCUSED: [Interpretation] Thank you.
20 65 ter 5915 is the next document I would like to call up. It
21 should have a translation. This is a Prosecutor's number.
22 MR. KARADZIC: [Interpretation]
23 Q. However, you speak Serbian, and Croatian as well. Do you agree
24 that the president of the Republic of Croatia, President Tudjman, issued
25 a decision on crisis staffs on the 27th of August, 1991? And in here, in
1 Article 1, he says --
2 THE INTERPRETER: The interpreters note that the accused is
3 reading too fast and we don't have a translation on the screen.
4 JUDGE KWON: You are simply reading too fast, without any
5 translated material. Could you slow down and repeat.
6 THE ACCUSED: [Interpretation] "Decision on Crisis Staffs," which
7 was issued on the 27th of August, 1991:
8 "The Government of the Republic of Croatia, in keeping with its
9 constitutional obligations and authorities, is duty-bound to ensure a
10 co-ordinated action of executive and administrative bodies of the state
11 authorities in the republic, as well as economic and social activities,
12 in conditions when the independence of the republic is threatened or in
13 the state of war, as well as the logistics support and all the other
14 assistance to the commands and units of the armed forces. For that
15 purpose, the Government of the Republic of Croatia forms the Crisis Staff
16 of the Republic of Croatia, as well as the crisis staffs as co-ordinating
18 MR. KARADZIC: [Interpretation]
19 Q. Do you agree that this is what it says in this article?
20 A. Yes.
21 Q. Let me not read the rest of it. Do you agree that the second
22 paragraph of Article 2 says that in terms of their position -- or,
23 rather, by virtue of their position, government members and ministers are
24 also members of the Crisis Staff?
25 And the last sentence says:
1 "The Government of the Republic of Croatia can appoint up to
2 three other members of the Crisis Staff who are not its members already
3 by virtue of their position."
5 A. Yes, that's what it says.
6 Q. Thank you. Does it say in Article 3:
7 "In the municipalities in which the local bodies of authorities
8 regularly perform their duties and are loyal to the Republic of Croatia,
9 the president of the Municipal Crisis Staff is also the president of the
10 Executive Council of the municipality, and its members are the heads of
11 municipal administrative bodies."
12 And so on and so forth.
13 Do you agree that he cannot form crisis staffs in the
14 municipalities which are not loyal to the republic, but only in the
15 republics which are obedient, which are loyal to the republican
16 authorities? Right?
17 A. Correct, I agree.
18 Q. Article 4 says:
19 "In order to co-ordinate the work and activities of the municipal
20 crisis staffs, the Government of the Republic of Croatia can form a
21 crisis staff that will cover a territory of several municipalities or it
22 can appoint its own commissioner that will be in charge of several
24 Do you agree that they also have an institution -- or, rather,
25 that they have the institution of a commissioner who helps municipalities
1 in an attempt to co-ordinate their activities?
2 A. Yes.
3 Q. Municipalities, themselves, can also appoint commissioners for
4 local communes or settlements, and so on and so forth; right? Do you
5 agree that a crisis staff is just a form through which the existing
6 authorities function, rather than an entirely new body?
7 A. I'm not familiar enough with the Croatian legislation to really
8 draw that. I see here it refers to that the Executive Committee of the
9 Assembly can form a crisis staff or name a -- oh, the commissioner is
10 just to the local levels. That is so different from the model that I've
11 seen in the Bosnian Serb municipalities that I'm really reluctant to draw
12 any conclusions without having studied the Croatian legislation better.
13 Q. Please read Article 5, where it says:
14 "When this decision comes into force, the decision on the setting
15 up and activities of the Crisis Staff in the Republic of Croatia,
16 number 822/91 of 29 July 1999, will become null and void, as well as all
17 the decisions --"
18 THE INTERPRETER: The text has just disappeared from the screen,
19 and the accused was reading too fast.
20 JUDGE KWON: Mr. Karadzic, we can all read this document later
21 on, when it's translated. What is your question on this document?
22 MR. KARADZIC: [Interpretation]
23 Q. My question is this: Ms. Hanson, when we look at your footnote,
24 and when we see that you say that the crisis staffs existed elsewhere,
25 can we now finally underline the fact that those crisis staffs, indeed,
1 existed and that they existed much before the Serbian crisis staffs were
2 ever set up?
3 A. The date of this was August. Yes, had I realised in my writing
4 how much other crisis staffs -- non-Serb crisis staffs would matter to
5 the readers of my report on Bosnian Serb crisis staffs, I would have
6 expanded that section to make it clear that we hear of crisis staffs in
7 Croatia in 1991. We see crisis staffs on the Bosnian Croat and
8 Bosnian Government side as well. I readily can see I did not pay
9 attention to it -- much attention to that in my report on Bosnian Serb
10 municipal crisis staffs.
11 Q. Thank you. With all due respect, Ms. Hanson, the crisis staffs
12 that were formed by the Muslim side in January 1991, only a month after
13 our elections, were not the staffs of the Bosnian government. They were,
14 rather, the staffs of the Muslim community. The Crisis Staff of the
15 Bosnian Presidency was formed in mid-September 1991. In any case, all of
16 them had crisis staffs much before the first Serbian crisis staffs were
17 set up; is that correct?
18 A. No. I've listened to an intercept from, I believe, June 1991, in
19 which you say there is an SDS crisis staff already. It's not in my
20 report because it wasn't a municipal one, but I have heard mention of a
21 Serbian SDS crisis staff from the summer of 1991.
22 Q. In that conversation, I'm trying to calm down somebody who was
23 putting pressure on me to form a crisis staff. Did a crisis staff exist
24 at the time I indicated in my question?
25 A. In your question, what -- I'm sorry, what time do you -- do you
1 refer to, what time-period?
2 Q. Throughout 1991. Did it exist in the summer of 1991? Did the
3 Crisis Staff exist at the time that I indicated?
4 A. As I say, I've only your word for it in that intercept. That's
5 the only indication I have of a republic-level SDS crisis staff in the
6 summer of 1991. I have no other documents regarding that one.
7 Q. Well, very well. Do you know that people on the ground in
8 municipalities formed crisis staffs whenever they felt that there was a
9 crisis coming, even before the instructions were issued in 1991?
10 A. As I say in my report, I have seen or heard references to ad-hoc
11 crisis staffs formed even before -- well, before the war, I've seen
12 references, I know, to a crisis staff for the reception of refugees in
13 Bosanski Petrovac, I believe, in the summer of 1991, refugees coming from
14 Croatia. So I have heard the term used, but not as a municipal
15 government organ; simply a co-ordinating body to deal with a specific
16 issue or local crisis.
17 JUDGE KWON: Ms. Sutherland, do we have a 65 ter or the exhibit
18 number of the intercept she has referred to?
19 MS. SUTHERLAND: I was just trying to work out which one it was
20 myself, Your Honour.
21 JUDGE KWON: Thank you.
22 MS. SUTHERLAND: If Ms. Hanson can tell me the speakers, if she's
24 THE WITNESS: The other speaker's name is Zoran -- I'm afraid
25 that's all it is, Zoran. I believe it's June 1991.
1 If I may explain, Your Honours, I listened to intercepts in which
2 the word "crisis staff" appeared, so I don't know if they're on the
3 exhibit list or not. I was doing my own researches.
4 JUDGE KWON: Thank you.
5 Yes, Mr. Karadzic.
6 THE ACCUSED: [Interpretation] Can the previous document be
8 JUDGE KWON: Yes. It will be marked for identification, pending
10 THE REGISTRAR: As MFI D1361, Your Honours.
11 THE ACCUSED: [Interpretation] Could the Court produce 65 ter 594,
12 only in English, because the Serbian version is a handwritten document.
13 Page 11, please.
14 As for the previous question, the instructions were issued in
15 December 1992; page 43, line 23. The instructions were issued in
16 December 1991. The month was not recorded the first time 'round.
17 MR. KARADZIC: [Interpretation]
18 Q. Let's look at bullet point 3, where it says:
19 [In English] "From the second session of the Municipal Board of
20 SDS Bratunac, held on the 25th of October, 1991."
21 [Interpretation] Can we go to the following page.
22 Bullet point 3:
23 [In English] "Appointment of the Crisis Staff of Bratunac
24 municipality for implementation of measures for protection of the Serbian
1 [Interpretation] Do you agree with me that those people of
2 Bratunac acted of their own will and that they formed a crisis staff
3 independently, even before the instructions were issued in December 1991?
4 A. This is obviously before the 19 December instructions. But if we
5 can look at item 1, it follows information from the Main Board of the
7 If we can go back to the previous page.
8 "Information on the standpoints of the Main Board of the SDS BiH
9 and the standpoints and conclusions of the newly-elected Serbian Assembly
10 of the BiH."
11 In my report, I tie this Crisis Staff to the declaration of a
12 state of emergency in the party which Mr. Karadzic gave on the 18th, I
13 believe, October. And if this is the same one -- could I just go to the
14 top of this document? What's the date of it? It's the -- yeah, because
15 I also -- I cite a document from the 19th of October in which Deronjic
16 informs the leaders of the SDS Municipal Board of Bratunac of the
17 policies and instructions from the expanded session of the SDS Main Board
18 held the night before in Sarajevo:
19 "The membership of the municipal crisis staff was proposed
20 immediately." And the Bratunac crisis staff then met on the 26th of
21 October. So, actually, the day after this party emergency was declared,
22 Deronjic comes back to Bratunac and says, We got instructions from the
23 SDS leadership, and therefore a crisis staff should be formed. I tie
24 that to the state of party emergency.
25 I agree it is formed before the 19 December instructions, but I
1 would not say that it's completely on their own initiative. The explicit
2 references to instructions and information from the party centre make me
3 think it was not completely an initiative. They may have jumped the gun,
4 perhaps, already hearing of this term "crisis staff," forming a crisis
5 staff, given that the party is declared to be in a state of emergency,
6 but I think that they were -- that they were seeing themselves as
7 following the party line at that time.
8 I also see, in Bosanski Petrovac at this same time in late
9 October, the SDS Municipal Board proposes forming a crisis staff, which
10 the Municipal Assembly, being still a multi-ethnic body, rejects. So
11 I think there may have been talk of a crisis staff or the declaration on
12 the state of emergency may have led people to use this term "crisis
13 staff." I see no written instructions at this time from the party centre
14 about a crisis staff.
15 THE ACCUSED: [Interpretation] Thank you.
16 This document has been admitted.
17 Could the Court please produce 1D3594.
18 MR. KARADZIC: [Interpretation]
19 Q. I would ask you to help me go quickly through the following few
20 documents. There is not much left for us to look at.
21 JUDGE KWON: Yes, the previous document was Exhibit P2597.
22 MR. KARADZIC: [Interpretation] Thank you.
23 Q. Do you agree with me that this was issued on the 16th of January,
24 1992, and that these are decisions of the Presidency of the HDZ of
25 Bosnia and Herzegovina?
1 And we can go immediately to the second page, both in English and
2 in Croatian. I don't want to say "Serbian."
3 I would like to draw your attention and everybody's attention to
4 bullet point 7 and 8, where it says:
5 "Crisis staffs of the HDZ of BH at all levels ..."
6 And so on and so forth.
7 Were you familiar with this document? This was signed by the
8 president of the HDZ of Bosnia and Herzegovina, Stjepan Kljuic, a member
9 of the Joint Presidency of Bosnia and Herzegovina; right?
10 A. Right, it was signed by Kljuic, who was a member of the
11 Joint Presidency. I was not familiar with this document at the time I
12 wrote my report. It was brought to my attention since then, but I don't
13 feel it changes my conclusions on Bosnian Serb municipal crisis staffs.
14 Q. Did you come across a document which indicates that
15 Plavsic/Koljevic did the same, that they managed the area as members of
16 the Joint Presidency?
17 A. I'm sorry, I don't know what you mean by "managed the area," but
18 I have not seen an equivalent document like this from Plavsic or
20 THE ACCUSED: [Interpretation] Thank you.
21 Can this be admitted? This is precisely what I meant. You
22 understood me well. It was a good equivalent of what I had in mind.
23 JUDGE KWON: Yes, that will be admitted.
24 THE REGISTRAR: As Exhibit D1362, Your Honours.
25 JUDGE KWON: You have five minutes, Mr. Karadzic.
1 We dealt with Croatian crisis staff yesterday, which was noted in
2 her footnote 5. Please proceed.
3 MR. KARADZIC: [Interpretation] Thank you.
4 Q. Then I have to skip over so many things, and I have to ask you
5 this: You are appearing today as an expert witness, or, rather, you have
6 testified here as an expert witness; right?
7 A. Yes.
8 Q. Are you still affiliated with the OTP, are you still a staff
9 member there?
10 A. Yes.
11 Q. Thank you. What is your capacity as a staff member in the OTP?
12 You are a researcher, you're not an investigator; right? You are a
13 research officer; that's what you told us?
14 A. Yes, the name of my post is "research officer."
15 Q. When your testimony is finished today, you are going back to your
16 work to be a research officer; right?
17 A. Well, I hope I get a short break, but, yes, on Monday I'll start.
18 Q. Thank you. And you're going to try to help the OTP to reinforce
19 their case against me; right?
20 A. I'm going to try to help the OTP to better their case, which
21 includes a better understanding, if necessary, of all sides of the
22 issues. But, yes, I will go back to working to help the OTP.
23 Q. You have also stated that you did the same in the Krajisnik case.
24 Before you provided evidence, you were a research officer, and you had
25 collected documents that supported the Prosecution case. And then you
1 were transformed into an independent expert witness, and you remained
2 that for the duration of your testimony. And after that, you were again
3 transformed or you went back to being a research officer and an associate
4 of the OTP. Right? You said that on page 14721, from line 1 onwards.
5 I can look for that.
6 A. If you feel the need. But I agree with that statement, so I'm
7 not challenging you to find it in the transcript.
8 Q. Thank you. Ms. Hanson, do you find it difficult to turn from a
9 research officer, and an associate of the OTP, into an impartial expert
10 witness? How difficult is it to go back and forth between these roles?
11 A. It requires some intellectual rigour to separate -- to separate
12 the roles, but I -- my report -- my work is based on the documents, and I
13 have faith that the documents show what I'm saying. And I do try and
14 keep out other sources when I testify, when I write my report.
15 Q. If I put it to you, Ms. Hanson, that Mr. Krajisnik was found
16 guilty of only one charge in the indictment, and that is persecution of
17 the Muslim population, and that the decision was based mainly on your
18 findings, on the results of your research, and at the same time if I tell
19 you that he is a totally innocent person, how will that make you feel?
20 JUDGE KWON: No, an improper comment.
21 I take it you concluded your cross-examination, Mr. Karadzic.
22 THE ACCUSED: [Interpretation] That was not a comment. I asked
23 Ms. Hanson whether she feels responsible for the fact that an innocent
24 man was convicted based on such a selective approach to work.
25 Okay, I'll withdraw the question.
1 JUDGE MORRISON: Dr. Karadzic, it's a blatant comment, thinly
2 disguised as a question. We both know it's improper.
3 JUDGE KWON: And not helpful at all.
4 Yes, Ms. Sutherland.
5 MS. SUTHERLAND: Thank you, Your Honour.
6 Your Honour, a moment ago you asked for the 65 ter number for the
7 intercept that Ms. Hanson was referring to. If I could call up
8 65 ter 30073, please.
9 Re-examination by Ms. Sutherland:
10 Q. Ms. Hanson, this is an intercept between Mr. Karadzic and a man
11 called Zoran on the 29th of June, 1991. Is this the intercept that you
12 were referring to?
13 A. Yes, it is. On the second page, Karadzic says:
14 "We have a crisis staff."
15 MS. SUTHERLAND: I tender that document, Your Honour, to mark it
16 for identification.
17 JUDGE KWON: Yes.
18 THE WITNESS: He also connects it to a secret. He says, We have
19 a crisis staff, but we can't tell them about secrets over the phone.
20 THE REGISTRAR: It will be MFI P2713.
21 MS. SUTHERLAND: While we're on the subject of intercepts, I have
22 another one from June 1991.
23 If I could have Exhibit 65 ter 30035, please.
24 Q. Ms. Hanson, this is an intercept of a conversation between
25 Dobrica Cosic and Radovan Karadzic on the 8th of June, 1991. Have you
1 reviewed this intercept?
2 A. I believe so, but it's not -- I'm not recognising it right now.
3 It's still just -- the first pages are just the usual chitchat.
4 MS. SUTHERLAND: If we could go to page 12 of the English and
5 page 8 of the B/C/S. I'm sorry, page 8 of the English. In the bottom
6 right-hand corner, it says "8th of --" thank you.
7 Q. Just at the top of the page, do you recall reviewing this
8 intercept, now that you see that text?
9 A. Yes.
10 Q. And what's the significance of that in June of 1991?
11 A. That Krupa and Sanski Most are already planning to establish a
12 Serbian municipality.
13 MS. SUTHERLAND: Your Honour, I tender that and ask that it be
14 marked for identification.
15 JUDGE KWON: Yes.
16 THE REGISTRAR: As MFI P2714, Your Honours.
17 MS. SUTHERLAND:
18 Q. Ms. Hanson, at page 33/34 of today's transcript, Mr. Karadzic
19 took you to Exhibit D1360, which was the Mico Stanisic document. Do you
20 remember that?
21 A. Yes.
22 Q. And you said that you had seen documents which referred to only
23 investigating crimes against the Serbian population?
24 A. Yes, I remember that.
25 MS. SUTHERLAND: If I could have 65 ter 09342 on the screen,
2 Q. This is a strictly-confidential dispatch from the minister,
3 Mico Stanisic, to the CSBs Banja Luka, Bijeljina, Doboj, Sarajevo and
4 Trebinje. Is this a document that you may have reviewed?
5 A. I think I've seen this one, yes.
6 Q. And it states in the first paragraph -- and it's dated, sorry,
7 the 16th of May, 1992:
8 "In view of the tasks resulting from the order by the minister of
9 the interior, Strictly Confidential number," and gives the number, "and
10 for the purpose of monitoring combat operations and regular activities of
11 the organs of the interior, and in order to collect documentation on the
12 crimes against the Serbian population (for prosecution and to accurately
13 inform the local and international public), fax reports must be submitted
14 daily to the Ministry of the Interior of the Serbian Republic of Bosnia
15 and Herzegovina."
16 Did you -- do you recall seeing other similar documents to this?
17 A. Yes. I believe I've seen something from Plavsic with similar
18 instructions to collect documentation on crimes against the Serbian
20 MS. SUTHERLAND: Your Honour, I tender this document.
21 JUDGE KWON: I take it we have a full translation of this one.
22 MS. SUTHERLAND: Yes, Your Honour.
23 JUDGE KWON: Very well. We'll admit it.
24 THE REGISTRAR: As Exhibit P2715.
25 MS. SUTHERLAND:
1 Q. Ms. Hanson, Mr. Karadzic took you to -- on Wednesday, at the end
2 of the session, to Exhibit D01356, which is a report by the
3 SDS Municipal Board in Prijedor. Do you recall seeing that document? It
4 was the report written in December 1992.
5 A. Yes, of the SDS Municipal Board. Yes, I remember that.
6 Q. And during -- looking at that report, he was making the point
7 that there was no communication between the Prijedor SDS and the
8 republic-level SDS. And then he, at transcript page 14788, said:
9 "Well, we looked a moment ago at a diary that we looked at."
10 I'm sorry, the diary was D01356, the Prijedor Municipal Board
11 report was D01357.
12 In any event, he said:
13 "Well, the diary we looked at a little while ago, if we had time,
14 we would point your attention to where it says that they had not had
15 contact for 45 days with the representatives from Prijedor."
16 THE COURT REPORTER: Slow down, please.
17 MS. SUTHERLAND: I apologise.
18 Q. Do you remember that?
19 A. Yes, I remember him referring to a 45-day break in
20 communications, with no reference to -- without bringing up a document.
21 MS. SUTHERLAND: Your Honour --
22 JUDGE KWON: Could you check whether the transcript reflects all
23 of what you asked to the witness?
24 MS. SUTHERLAND: Yes, I would just repeat what I was saying.
25 That Mr. Karadzic said, at page 14788:
1 "Well, in the diary that we just looked at a little while ago, if
2 we had time, we would point your attention to where it says that they had
3 not had contact for 45 days with the representatives from Prijedor."
4 Your Honour, if --
5 JUDGE KWON: Yes, let's proceed.
6 MS. SUTHERLAND: If I could have 65 ter 23157.
7 Your Honour, this is the conversation that Mr. Karadzic was
8 referring to -- not a conversation, a notation in the diary, and he had
9 previously said that it was his handwriting. And this is at page 14783.
10 When the handwritten document came up on the screen, he said:
11 "This is a session of the Cabinet on the 14th of September, 1992,
12 in Bijeljina."
13 We can see that on page 1.
14 Can we see the next page in Serbian:
15 "This is obviously my handwriting and my diary."
16 And there was only a limited number of the diary -- pages of the
17 diary in evidence, and I seek to use the remaining -- the entire diary
18 now as Exhibit 65 ter 23157.
19 And if we could please go to the ERN, which is R066-3937.
20 And this is a note of -- a notation on the 19th of October, 1992,
21 and I think it says there -- and I'm sorry, Your Honour, we don't have a
22 translation at the moment. It's been put in for urgent translation.
23 Q. There's a meeting of the Presidency and the Main Staff of the RS;
24 is that right?
25 A. Of the VRS. Yes, the Main Staff of VRS and the Presidency.
1 Q. And then it says there's a report from Geneva?
2 A. Yes.
3 Q. And then on the next page, does it say "Presidency with Prijedor"
5 A. Yes.
6 Q. And then:
7 "The first 45 days of the war, there was no connection with us"?
8 A. Mm-hmm, yes, that's what it says.
9 Q. "Problems of the functioning of government and the relations
10 between party and government"?
11 A. Yes, that's what it says.
12 Q. "Assembly session to be held"?
13 A. Mm-hmm.
14 Q. "Political goals in the army can be interpreted only by SDS
16 A. Yes, that's what it says.
17 Q. And according to Mr. Karadzic, it's -- he understands the war to
18 be beginning at the beginning of April; is that right?
19 A. Yes. From the way he's been counting the months of the war,
20 that's my conclusion.
21 MS. SUTHERLAND: Thank you.
22 I seek to tender this document, Your Honour, MFI, marked for
23 identification, and to have a translation.
24 JUDGE KWON: Yes, Mr. Karadzic.
25 THE ACCUSED: [Interpretation] First of all, let us be precise.
1 The war in Prijedor began in end May, not in April. And, second,
2 am I writing here what I am saying or what I'm being told? How can
3 anyone ascribe to me words which other people tell me?
4 JUDGE KWON: If necessary, the Chamber can give you another go,
5 but it's not for you to intervene with the examination of the
7 MS. SUTHERLAND: Your Honour, if I can just make a point.
8 Mr. Karadzic can't have his cake and eat it too. He either has
9 been putting to this witness throughout her testimony that the war
10 started -- for example, if we have a document at the end of -- end of
11 June, he'll be saying, Well, this is three months into the war, and this
12 is what's happening in Kotor Varos, when, in fact, everyone knows that
13 the war broke out in Kotor Varos on the 11th of June. So he can't, for
14 one minute, be saying three months into the war, in relation to
15 Kotor Varos, and then, in relation to Prijedor, well, it's at the end of
16 May, so now we've got to count 45 days from the end of May.
17 JUDGE KWON: It may depend.
18 In any event, what's the number under which we admitted part of
19 this diary?
20 MS. SUTHERLAND: That was Exhibit D01356, and that was the
21 decision of the Cabinet on the 14th of September, 1992, Your Honour.
22 But this document -- this handwritten diary is a lot longer and
23 covers a lot more period in 1992, and so I thought it was better that we
24 had a new exhibit number.
25 JUDGE KWON: Yes, we'll mark for this --
1 THE ACCUSED: [Interpretation] And may I ask Madam Sutherland to
2 show to the Trial Chamber the entire page, everything that is written on
4 JUDGE KWON: We mark this for identification, pending
6 THE REGISTRAR: As MFI P2716, Your Honours.
7 JUDGE KWON: Yes. Please proceed, Ms. Sutherland.
8 MS. SUTHERLAND:
9 Q. Ms. Hanson, I want to just quickly, very quickly take you back to
10 the excerpts on the 26th of April, 1992.
11 In your evidence-in-chief, I called up Exhibit D407 because that
12 was the document that we had exhibited in the case, and that was at
13 transcript page 14529. However, in -- during your cross-examination,
14 Mr. Karadzic also brought up Exhibit D407, and that was at transcript
15 page 14774 to 14775. And at that point, you said this is a Latin script
16 and you were using the Cyrillic version; is that right? Do you recall
18 A. Yes, I recall that.
19 MS. SUTHERLAND: If I could have, first of all, quickly on the
20 screen Exhibit D407.
21 Q. And that was the document that you were taken to by both myself
22 and Mr. Karadzic?
23 A. Yes, it is.
24 MS. SUTHERLAND: And if I can now have on the screen Exhibit --
25 sorry, 65 ter 00783.
1 Q. And this is actually the document -- or is this the document that
2 you were referring to --
3 A. Yes.
4 Q. -- and cited in your report?
5 A. Yes, I believe I used this version in my report, and certainly
6 the one to which I'm more familiar. But I have seen the Latin script,
7 but this is the one I usually use.
8 MS. SUTHERLAND: Your Honour, I would seek to tender this
9 document, 65 ter 00783.
10 JUDGE KWON: Yes.
11 THE REGISTRAR: Exhibit P2717, Your Honours.
12 MS. SUTHERLAND: And if we can just go to the second page of the
13 B/C/S and English.
14 Q. And we can see there that it's got a signature block and a date
15 of the 26th of April?
16 A. Yes.
17 Q. Ms. Hanson, you were also asked in cross-examination about the
18 Agency for Resettlement, and that's at transcript page 14640 to 14642.
19 Mr. Karadzic took you to Exhibit D01308, which is the ARK Crisis Staff
20 decision, signed by Brdjanin, of the 26th of May, 1992, where he said, at
21 item 6:
22 "An agency shall be established immediately that will work on the
23 problem of population resettlement."
24 Mr. Karadzic said:
25 "Is that what you meant? Were you referring to agencies of this
1 kind when you said that we oversaw -- or, rather, that the crisis staffs
2 oversaw the removal of non-Serbs?"
3 And you answered:
4 "What I see in a great many municipalities is an institution
5 named variously Property Exchange Agency or Agency for Movement of
6 Population, and so on."
7 And then you go on a little. And then Mr. Karadzic said:
8 "This is what you're reading into this, but this was not done,
9 this was not implemented. You don't know that, but this was not
11 Do you recall that?
12 A. Yes, I do.
13 MS. SUTHERLAND: Could I have 65 ter 05485 on the screen, please.
14 Q. This is a decision dated the 12th of June, 1992, of the
15 ARK Crisis Staff to found an agency for population movement and exchange
16 of material wealth for the Autonomous Region of Krajina. Is that the
17 document that you were referring to?
18 A. Well, I was referring to such agencies at the municipal level as
19 well as this one at the regional level, but, yes, I knew that the -- the
20 item in the ARK conclusions had been implemented, and this is the
21 evidence that I was thinking of, of its implementation.
22 MS. SUTHERLAND: I seek to tender this document.
23 JUDGE KWON: Yes.
24 THE REGISTRAR: Exhibit P2718, Your Honours.
25 MS. SUTHERLAND: If I could have 65 ter 05484 on the screen,
2 Q. Again, this is a decision of the ARK Crisis Staff, dated the 12th
3 of June, 1992, a decision to appoint Professor Milos Bojinovic from
4 Glamoc as chief of the Agency for Population Movement and Exchange for
5 Material Wealth for the ARK. Were you aware of this decision?
6 A. I knew that someone had been appointed. I didn't remember the
7 name. I don't know if I've seen this exact appointment, but I do know
8 that the agency was set up and personnel were named to it, yes.
9 MS. SUTHERLAND: I'd seek to tender this document, Your Honour.
10 JUDGE KWON: Yes.
11 THE REGISTRAR: Exhibit P2719, Your Honours.
12 MS. SUTHERLAND:
13 Q. Ms. Hanson, I'm now going to show you a number of documents
14 related to this agency.
15 If I could have one moment, Your Honour. Sorry, Your Honour,
16 I've got a lot of paper on my table.
17 While we're waiting for the list to print: Ms. Hanson, on
18 another matter, Mr. Karadzic asked you this morning how many
19 municipalities you had looked at in relation to the documentation for
20 your report, and he named off maybe a dozen municipalities and then asked
21 you, How many municipalities were there, 55 or 60 rather large
22 municipalities, and then said that you probably only included a third or
23 something of that region in your report. Do you recall that?
24 THE ACCUSED: [Interpretation] Can we have the reference for that,
1 JUDGE KWON: It's today's transcript.
2 MS. SUTHERLAND: Page --
3 JUDGE KWON: 13.
4 MS. SUTHERLAND: -- 13. Thank you, Your Honour. I had it on
5 page 12 and 13, but --
6 THE WITNESS: I do recall the exchange.
7 MS. SUTHERLAND:
8 Q. Would you agree with me that it was -- it's probably more in the
9 vicinity of 60 municipalities that are listed in your report?
10 A. I am quite prepared to believe that. I haven't, as I said, made
11 a list of that, but I know it was a lot more than 20.
12 MS. SUTHERLAND: Thank you.
13 Now I have my piece of paper back in relation to the
14 Autonomous Region Agency for Population Movement.
15 If I could have 65 ter 23145, please.
16 THE ACCUSED: [Interpretation] Did I receive a wrong
17 interpretation or translation? Madam Sutherland said "the displacement
18 of population," and in our language, when this is translated the way it
19 was translated to me, it has a totally different connotation.
20 MS. SUTHERLAND: I said the Agency for Population Movement.
21 Q. Ms. Hanson, you can see on the screen here a payroll for
22 July 1992, and listing a number of persons. One is Milos Bojinovic, who
23 we've just seen from the previous two documents was a director of the --
24 appointed director of the agency or as the chief?
25 A. Yes.
1 Q. What does this document signify to you?
2 A. It signifies to me that Milos Bojinovic was actively working in
3 July 1992.
4 Q. And do we see -- can you make out the stamp at all?
5 A. If it could be enlarged. I'm afraid I can't see it that well.
6 JUDGE KWON: We can enlarge further. We can collapse the English
8 THE WITNESS: I see the words "for resettlement" or "movement,"
9 and the "Autonomous Region of Krajina, Banja Luka." I can't -- yes, "The
10 Serbian Republic of BiH, Autonomous Region of Krajina," something,
11 "movement," or "resettlement."
12 MS. SUTHERLAND: There's a better stamp on the next document.
13 Your Honour, I tender that document.
14 JUDGE KWON: It will be admitted.
15 THE REGISTRAR: Exhibit P2720.
16 MS. SUTHERLAND: If I can have 65 ter 23146 on the screen.
17 My apologies, I will slow down. 65 ter 23146.
18 Q. The English on the screen is a payroll for December 1992, and it
19 is signed by the director, and it has a stamp.
20 And if we could just quickly blow that stamp up.
21 A. Yes, it's the Agency for Movement of ARK in Banja Luka, so this
22 would suggest to me that the agency was active and its members were
23 working in December 1992.
24 MS. SUTHERLAND: I tender that document, Your Honour.
25 JUDGE KWON: Yes.
1 THE REGISTRAR: Exhibit P2721, Your Honours.
2 MS. SUTHERLAND: If I could have 65 ter 23147 on the screen,
4 Q. This is an authorisation dated the 10th of August, 1992, signed
5 by Director Milos Bojinovic, and it's entitled "An Agency for Helping in
6 moving of Population and Exchange of Material Property." And it's
7 authorising Ms. Perka Bandic, Mr. Milan Segrt, Mr. Slobodan Bandic, and
8 they're authorised by the government of the ARK and the management of the
9 agency that they can carry out negotiations with the representatives from
10 the Republic of Croatia regarding the matters concerning moving of
11 population and exchange of material property.
12 What does this document signify to you?
13 A. It signifies to me that the agency was established, was
14 operating, was actively involved in the movement of -- organising the
15 movement of population out of Bosnia altogether, since they're dealing
16 with representatives from Croatia.
17 MS. SUTHERLAND: I tender that document, Your Honour.
18 JUDGE KWON: Yes.
19 THE REGISTRAR: Exhibit P2722, Your Honours.
20 MS. SUTHERLAND: If I could have 65 ter 23148.
21 Q. And, again, this is a certificate signed by the director,
22 Milos Bojinovic, in relation to an exchange of apartments in Zagreb with
23 one in Banja Luka?
24 A. Yes, that's what it appears.
25 Q. And it's dated the 26th of October, 1992. So did this signify
1 that this agency is working at that point?
2 A. Yes.
3 MS. SUTHERLAND: I tender that document, Your Honour.
4 JUDGE KWON: Yes.
5 THE REGISTRAR: Exhibit P2723, Your Honours.
6 MS. SUTHERLAND: If I could have 65 ter 23150.
7 Q. This a document dated the 29th of August, 1992, from the Agency
8 for Aiding relocation of Inhabitants and Exchange of Material Assets, and
9 it's a contract on co-operation. It's signed by Perka Bandic and a
10 company in Zagreb. And we saw a moment ago Perka Bandic having
11 authorisation to deal with Zagreb.
12 What does this document signify?
13 A. That it's organising a convoy of -- from Zagreb -- from
14 Banja Luka to Zagreb, four buses, each taking about sixty people. So it
15 indicates the agency is actively involved in organising the relocation of
17 MS. SUTHERLAND: Your Honour, I have another five documents
18 relating to the agency. I don't want to waste a lot of time -- not
19 "waste a lot of time," but valuable time going through these documents,
20 and I wonder whether we could simply call them up, and then I could
21 tender them either as a bundle or individually.
22 JUDGE KWON: Mr. Robinson.
23 MR. ROBINSON: Well, Mr. President, we didn't have enough time
24 for our own examination, even with a lot of extensions, particularly a
25 lot of documents. Our own documents we had for this region we chose not
1 to use because of lack of time. So I think if they want to admit a
2 document, it ought to be presented to the witness, and there might to be
3 some thought for allowing Dr. Karadzic some time for re-examination also.
4 MS. SUTHERLAND: If I could have 65 ter 23 -- sorry.
5 [Trial Chamber confers]
6 JUDGE KWON: We think that Mr. Robinson's comment is fair enough,
7 so let's deal with them.
8 MS. SUTHERLAND: 65 ter 23149.
9 Q. This is a notice in relation to a convoy to Travnik on the 6th of
10 October, 1992. What does this document tell you?
11 A. That it's arranging a convoy to Travnik, which was then
12 Bosnian-held territory, and that each passenger must pay 14.000 dinars to
13 cover the costs of their ticket. So it tells me the agency is actively
14 involved in relocating people.
15 MS. SUTHERLAND: If I could have -- I tender that document.
16 JUDGE KWON: Exhibit P2724.
17 MS. SUTHERLAND: If I could have --
18 THE REGISTRAR: Exhibit P2725, Your Honour.
19 JUDGE KWON: Yes, thank you.
20 MS. SUTHERLAND: If I could have 65 ter 23154. I'm sorry -- yes,
22 Q. And this is from the same agency, dated the 1st of October, 1992,
23 signed by the director, Milos Bojinovic, to the CSB Banja Luka. What
24 does this document signify?
25 A. They're requesting the police to escort a convoy going from
1 Banja Luka to Vlasic. So the agency is actively involved in organising
2 the movement of population.
3 MS. SUTHERLAND: I tender that document.
4 JUDGE KWON: Yes.
5 THE REGISTRAR: P2726, Your Honours.
6 MS. SUTHERLAND: 65 ter 23152, please.
7 Q. This is a document dated the 13th of November, 1992, again from
8 Milos Bojinovic to the CSB. And is it also requesting an escort from the
9 CSB to assist the convoy?
10 A. Yes. It's very similar to the previous document. It shows that
11 it's a regular -- that this is what the agency is doing, creating
12 convoys, organising their security.
13 Q. And the route is Banja Luka --
14 A. -- Galica-Vlasic.
15 MS. SUTHERLAND: I tender that document, Your Honour.
16 JUDGE KWON: Yes, Exhibit P2727.
17 MS. SUTHERLAND: Could I have 65 ter 23156.
18 Q. This is a document dated the 12th of November, 1992. It's signed
19 by the director of the agency to the Secretariat for National Defence,
20 Banja Luka, requesting a war schedule for four individuals. What's the
21 significance of this document?
22 A. First of all, it describes the employees at the agency, which
23 tells us the agency is working, and that their work in the agency is to
24 be considered as war assignment, and, therefore, that they should not be
25 drafted, but that this assignment is helping the war effort is how I
1 understand that "ratni" [indiscernible].
2 MS. SUTHERLAND: And, finally, if I could have 65 ter number --
3 JUDGE KWON: We'll admit it as Exhibit P2728.
4 MS. SUTHERLAND: My apologies, Your Honour.
5 If I could have 65 ter 23155.
6 Q. And this is a document dated the 25th of November, from the
7 agency, in relation to services provided by it. And if you could just
8 briefly tell the Court what that -- what those services are.
9 A. They're organising bus travel, they're organising the moving of
10 furniture, they're organising convoys of private vehicles, and exchanging
11 apartments, making contracts, acting as a middleman between those who are
12 exchanging apartments and other assets.
13 MS. SUTHERLAND: I tender that document, Your Honour.
14 JUDGE KWON: Yes.
15 THE REGISTRAR: Exhibit P2729, Your Honours.
16 MS. SUTHERLAND:
17 Q. Ms. Hanson, also at footnote 172 of your report, relating to
18 paragraph 100, you cite five municipalities where committees for
19 immigration, travel agencies and exchange officers were established by
20 crisis staffs, and you list Bosanski Petrovac, Kljuc, Kotor Varos,
21 Sanski Most and Zvornik.
22 Your Honour, as these are footnoted in Ms. Hanson's report, I
23 would seek to tender the three that are not yet in evidence. The first
24 one, Petrovac, is Exhibit D01343, and the Kljuc one is Exhibit P02606,
25 but I would seek to tender the one from Kotor Varos, 65 ter 4203 and
1 00344, and from Sanski Most, the two documents, 65 ter 001 -- I'm sorry,
2 01097 and 05121, and from Zvornik, 65 ter 11256.
3 JUDGE KWON: Could you give the numbers of the first two about
4 the Bosanski Petrovac?
5 MS. SUTHERLAND: Petrovac was D01343.
6 JUDGE KWON: Is it different from that is noted in her footnote?
7 MS. SUTHERLAND: No, it's the same, 65 ter 01114. That's the
9 JUDGE KWON: And what is your tendering now?
10 MS. SUTHERLAND: I don't seek to tender that because it's already
11 Exhibit D01343.
12 JUDGE KWON: Yes.
13 MS. SUTHERLAND: And the next one from Kljuc, that's
14 65 ter 00853. That's already Exhibit P02606.
15 JUDGE KWON: Now I understand it.
16 Mr. Robinson.
17 MR. ROBINSON: Yes, Mr. President.
18 I'm sorry to ask that you take up the time, but I believe that
19 you've already indicated that these documents should not be the subject
20 of -- that you prefer to hear oral evidence. This is almost an oral
21 Bar Table motion, as I understand it, and I don't think it's appropriate.
22 [Trial Chamber confers]
23 JUDGE KWON: Fair enough.
24 Ms. Sutherland, as you noticed, it has been our practice, if the
25 Prosecution finds it necessary to tender the document through a witness,
1 you better put it to the witness. It's up to you, whether or not to put
2 them to the witness.
3 MS. SUTHERLAND: Thank you, Your Honour.
4 If I could have --
5 JUDGE KWON: Microphone.
6 MS. SUTHERLAND: Sorry. Thank you, Your Honour.
7 If, then, I could have 65 ter 04203.
8 Q. Ms. Hanson, this is an excerpt from the 14th session of the
9 War Presidency of Kotor Varos of the 14th of July, 1992. Could you
10 briefly tell the Court --
11 A. I --
12 Q. -- about this document?
13 A. Well, I cite the second bullet point under item 2:
14 "Activities relating to moving out the population failed to meet
15 expectations. This task must be dealt with in a much more organised
16 fashion. An agency has to be established to handle these matters."
17 I cite this as an example of an agency and, in general, of the
18 War Presidency involving itself in the organisation of the moving of
19 population -- the moving out of population.
20 MS. SUTHERLAND: I tender that document, Your Honour.
21 JUDGE KWON: Yes.
22 THE REGISTRAR: Exhibit P2730, Your Honours.
23 MS. SUTHERLAND: If I could have 65 ter 00344.
24 Q. These are the minutes of the 37th session of the War Presidency
25 of Kotor Varos, dated the 27th of July, 1992?
1 A. At the bottom of page 1 in English, the War Presidency has
2 received a report on population resettlement and wants a detailed work
3 plan of the Population Resettlement Service, so it suggests to me that an
4 agency has been established and it's reporting to the War Presidency.
5 MS. SUTHERLAND: I tender that document.
6 JUDGE KWON: Yes.
7 THE REGISTRAR: Exhibit P2731, Your Honours.
8 MS. SUTHERLAND: If I could have 65 ter 01097.
9 Q. This is from Sanski Most. It's the conclusions of the
10 Sanski Most Crisis Staff, dated the 23rd of June, 1992. Could you please
11 point out the relevant passage in this conclusion?
12 A. Well, it's citing, in fact, that ARK decision -- ARK conclusions
13 that we saw, discussing that, among other things, the army has to be in
14 the line with the SDS. But particularly item G, excuse me, at the bottom
15 of the page -- the English page, that they are faxing -- all
16 municipalities are to appoint a representative on the matters of
17 relocation and exchange of population and prisoners, and they should be
18 faxing these appointments to Vojo Kupresanin, member of the ARK and of
19 the SDS Main Board. And Sanski Most here appoints Vlado Vrkes to that
20 duty. As we recall from a previous document, Vrkes was the one appointed
21 to implement the policies and ideas of the SDS. They've also established
22 a camp at Sitnica. I think I've used this decision for several things
23 but the relevant here is appointing -- implementing the ARK conclusion on
24 agencies for resettlement.
25 MS. SUTHERLAND: I tender that document, Your Honour.
1 JUDGE KWON: Yes.
2 THE WITNESS: And also, I'm sorry, item 4, the bottom of the
3 second page of English, the commission, itself, is formed.
4 THE REGISTRAR: Exhibit P2732, Your Honours.
5 MS. SUTHERLAND: If I could have 65 ter 05121.
6 Q. And this is minutes of a meeting of the War Staff in Sanski Most
7 of the 21st of July, 1992?
8 A. Item 1 is a report of the commission for the movement of
9 population, or the Population Resettlement Commission here in the
11 MS. SUTHERLAND: I tender that document.
12 JUDGE KWON: Yes.
13 THE REGISTRAR: Exhibit P2733, Your Honours.
14 MS. SUTHERLAND: And 65 ter 011 -- oh, sorry, 11256.
15 Q. And this is a decision on the establishment of the Agency for
16 Exchange of Real Estate Property, dated the 11th of May, 1992?
17 A. In Zvornik, yes.
18 MS. SUTHERLAND: Yes.
19 I tender that document, Your Honour.
20 JUDGE KWON: Yes.
21 THE REGISTRAR: Exhibit P2734.
22 THE ACCUSED: [Interpretation] Is there a question arising from
23 this document?
24 MS. SUTHERLAND:
25 Q. Was an agency for exchange of real estate property set up in
2 A. Yes, it was.
3 JUDGE KWON: Yes, I take it to be the case.
4 Please proceed.
5 MS. SUTHERLAND: Thank you, Your Honour.
6 Q. Footnote 173 of your report cites to the Bosanski Petrovac
7 document re. the War Commission, and this document was put to you by
8 Mr. Karadzic at transcript page 14749 to 14750. It's dated the -- it's
9 65 ter -- it does have an exhibit number, but the 65 ter number is 1115.
10 THE REGISTRAR: Exhibit D1344.
11 MS. SUTHERLAND: Thank you, Mr. Registrar.
12 Q. And he was saying to you that:
13 "You were treating this document as if ethnic cleansing is the
14 intention of the Serbian authorities to cleanse Muslims from Petrovac;
16 And you said:
17 "I don't use the word 'ethnic cleansing' or even 'cleansing,' but
18 I say that their solution to -- that -- I say that their solution to
19 Muslims wanting safety was to move the Muslims out. And that was one of
20 the things that crisis staffs did, or war commissions in this case, was
21 organise the departure of Muslims, and this is an example of it."
22 And then Mr. Karadzic said:
23 "Why didn't they just drive them out immediately?"
24 And you said:
25 "As I said repeatedly, Petrovac was a Bosnian Serb majority, and
1 in general, the Serb authorities may have felt they could control the
2 power sufficiently."
3 And then you go on.
4 Were you aware of any convoys being organised for the non-Serb
5 population of Petrovac from mid-September 1992 onwards?
6 A. I do not right now recall seeing documents of such convoys. But
7 I've looked at a lot of documents, so I can't say one way or the other.
8 MS. SUTHERLAND: Your Honour, may we go into private session for
9 one moment?
10 JUDGE KWON: Yes.
11 [Private session]
11 Pages 14887-14889 redacted. Private session.
10 [Open session]
11 THE REGISTRAR: We're now in open session, Your Honours.
12 JUDGE KWON: We'll resume at 10 past 1.00.
13 --- Recess taken at 12.36 p.m.
14 --- On resuming at 1.11 p.m.
15 JUDGE KWON: Shall we go to private session briefly.
16 [Private session]
11 Pages 14891-14895 redacted. Private session.
12 [Open session]
13 MS. SUTHERLAND: Thank you, Your Honour.
14 JUDGE KWON: Yes, Ms. Sutherland.
15 MS. SUTHERLAND: Mr. Registrar, if I can have Exhibit -- sorry,
16 65 ter 00242 on the screen, and if you could go to page --
17 JUDGE KWON: And you suggested that you would put to the witness
18 a demographic map?
19 MS. SUTHERLAND: Yes, Your Honour.
20 JUDGE KWON: She's in the position to answer those questions?
21 MS. SUTHERLAND: Yes. The document speaks for itself --
22 JUDGE KWON: Well, very well. We'll see.
23 MS. SUTHERLAND: -- and I have some questions.
24 Page 312.
25 THE ACCUSED: [Interpretation] May I ask, is this a document
1 drafted in Croatia about the population of Bosnia-Herzegovina, and was
2 there a census made at the time? In which way is this document relevant
3 to us? This is April 1995. A different state is making assessments
4 about the ethnic --
5 JUDGE KWON: Just refrain from making comment at this moment.
6 And when she tenders the document, you have an opportunity to object to
7 the admission of the document. Let's hear from what the witness can say
8 about this document.
9 Yes, Ms. Sutherland.
10 MS. SUTHERLAND:
11 Q. So we have on the screen in front of us the ethnicity map for the
12 municipality of Petrovac, which is -- the source document is the 1991
13 census. And this document has been produced in Croatia in 1995, based on
14 the 1991 census data. And we can see, for the municipality of Petrovac,
15 that it has a total population of 15.621, of which 11.694 are Serb
16 ethnicity, 3.288 are Muslim.
17 Given the population of the Muslims, is it right that having seen
18 the previous document, that by the end of September 1992, basically, the
19 majority -- nearly all of the Muslim population had left the
21 MR. ROBINSON: Objection. Leading.
22 JUDGE KWON: So what is your question, Ms. Sutherland?
23 MS. SUTHERLAND:
24 Q. Given what we can see on the screen here, and given the previous
25 document, is it --
1 JUDGE KWON: The first question to be put is whether she agrees
2 with these statistics, if you are minded to ask that question, given the
3 population of the Muslims.
4 MS. SUTHERLAND:
5 Q. Ms. Hanson, you said earlier on in your testimony that the
6 Bosanski Petrovac municipality was -- I don't know whether you used the
7 word "Variant A municipality," but you said that it was a Serb majority.
8 Is that right?
9 A. Yes, I said it was one of the most Serb municipalities, in that
10 it was one of the municipalities with the highest percentage of Serbs.
11 And I'm familiar with this census of 1991. I'm familiar with this
12 publication as a reliable representation of the census. So, yes, I'm
13 familiar with -- these census figures appear correct to me.
14 Q. Thank you. And then, secondly, looking at the figures here, and
15 bearing in mind the last document, would it be right to say that the
16 majority of the population had left the municipality by the end of
18 A. The majority of the Muslim population --
19 Q. Yes, sorry.
20 A. -- had left the municipality, yes. If we could look at the map,
21 to just scroll down, I had said that, I believe, the Muslims of
22 Petrovac -- of the municipality were concentrated in the town, itself,
23 and the map shows only two other significant Muslim settlements. So this
24 corresponds with my understanding of the ethnic structure of the
1 MS. SUTHERLAND: Thank you.
2 Your Honour, I don't know whether you want just this one page.
3 I think it would be helpful for you to have the entire census data.
4 JUDGE KWON: We'll admit this page. Do you have an objection,
5 Mr. Karadzic?
6 THE ACCUSED: [Interpretation] I would not object to this page --
7 sorry, I'm waiting for the interpretation.
8 I would not object to this page if the figures are correct and if
9 the chart is correct. But I don't see where it shows that the population
10 was moved out and how Croatia established that.
11 JUDGE KWON: It may all go for -- go to the issue of weight which
12 is to be assessed later on.
13 We'll admit this page.
14 MS. SUTHERLAND: Yes, Your Honour.
15 The actual figures are on the ERN page 0048-1977 to 0048-1978.
16 It has the municipality total and then it has the breakdown of every
17 village in the municipality.
18 If we could quickly go to 0048-1977.
19 Your Honour, you can see it's got the figures for several
20 different years. And then over on the following page, if you follow
21 "Bosanski Petrovac" along, I think it's number 36, and then you pick up
22 number 36 on the next page, then you see, in 1991, the figures that I
23 just called out, 15.621, consisting of 3.288 Muslims and 11.694 Serbs.
24 So that's where the figures come from for the ethnic map at the back of
25 the book.
1 JUDGE KWON: Very well.
2 Shall we admit those two pages?
3 MS. SUTHERLAND: Yes, Your Honour.
4 JUDGE KWON: Or three pages?
5 MS. SUTHERLAND: Yes.
6 THE ACCUSED: [Interpretation] With my objection -- or, rather,
7 with the proviso that the 1991 census is not official, it was not
8 verified before the Assembly, because we had major objections concerning
9 falsifying, which doesn't mean, necessarily, that this is an inaccurate
11 JUDGE KWON: As I indicated, it's a matter that goes to the
13 We'll admit these three pages.
14 THE REGISTRAR: As Exhibit P2736, Your Honours.
15 JUDGE KWON: And I take it there are English pages corresponding
16 to these.
17 MS. SUTHERLAND: There's English pages for the heading --
18 THE ACCUSED: [Interpretation] Excuse me.
19 Can we see -- can we scroll down to see what it says about the
20 Croatian population originating from Bosnia-Herzegovina, just to see the
21 figure? Can we see the top of the page? Could we maybe zoom in?
22 MS. SUTHERLAND: Your Honour, if this is going to take time, I
23 would mark it for identification, and the accused can -- and look at this
24 volume at his leisure. And then we can come back to the document.
25 THE ACCUSED: [Interpretation] I would like to tell the
1 Trial Chamber that it says: "Population of Croatia originating from
2 Bosnia-Herzegovina, broken down by settlements." How is this relevant,
3 and what does this mean? "Croatian population originally from BH."
4 JUDGE KWON: We admitted this page to support the page we saw in
5 relation to the map.
6 We'll proceed.
7 MS. SUTHERLAND: And, Your Honour, we were also looking at the
8 figures on the left-hand side of the screen, not the right-hand side of
9 the screen, on that particular page, 0048-1978.
10 JUDGE KWON: Very well. Let us proceed.
11 MS. SUTHERLAND:
12 Q. So, Ms. Hanson, Mr. Karadzic took you yesterday to a document --
13 or Wednesday to a document dated the 28th of October, 1992, from the
14 War Presidency of Bosanski Petrovac, and that was at transcript
15 pages 14753 to 14754, which stated that all Muslims were afforded all
16 rights under the Constitution and for the Public Security Station to
17 increase the patrols.
18 Given the state of affairs by the end of September, this decision
19 by the War Presidency would be affecting a small handful of people, would
20 it not?
21 A. Yes.
22 THE ACCUSED: [Interpretation] This is, again, leading and
23 inaccurate. I mean, it's leading, and we'll prove that it is incorrect.
24 JUDGE KWON: You preempted Mr. Robinson's role.
25 Yes, that was leading, yes, but --
1 MS. SUTHERLAND:
2 Q. In footnote 174 of your report, you cite three examples of crisis
3 staffs setting the conditions for departure. And you cite documents from
4 Bosanski Novi, Kljuc and Sanski Most. I won't take you to those
5 documents now. But the accused also raised the issue of voluntariness
6 and suggested that the non-Serbs were leaving of their own volition, and
7 then spoke to you about convoys at transcript page 14689 to 14690, and
8 talking about, you know, resettling the population in the areas where
9 they felt safe and whatnot. And you replied that as for the obligation
10 to secure the convoys, you did see lots of documents of municipal
11 authorities securing the convoys you can but not an equal attention was
12 paid to the local population in-situ, the non-Serbian population, that
14 Do you recall now what documents that you had in mind when you
15 said that?
16 A. Well, I had in mind documents of the sort we've seen today,
17 arranging the police escort. The crisis staffs often note that they have
18 to get the city transport company -- to get the buses and the police to
19 provide the security, but I did not see them discussing, Can we use those
20 same municipal resources to persuade these people not to move, to make
21 them feel safe. That's what I was talking about, like when the
22 delegation of Muslims comes to the Petrovac War Commission, they ask, Can
23 you make us safe? And the answer is to move them out in an organised
24 fashion, the safety seems to be in -- while they're being moved, but not
25 while they're in place in the municipality, or being -- they're not --
1 neither are they offered another place in the municipality that might be
3 Q. Thank you. I now want to move to the municipality of
4 Bosanska Krupa, if I can.
5 And Mr. Karadzic took you to a document at transcript page 14769
6 to 14772, which was Exhibit D01353, and it was the document of the 1st of
7 May, 1992, from the Committee of Refugees, stating that it's a temporary
8 evacuation of residents and refugees from Arapusa and that the Command is
9 obliged to ensure the safe return of the residents to their homes. Do
10 you recall that?
11 A. Yes.
12 Q. If I could just take to you a couple of documents now, and I'll
13 ask you to comment.
14 If I could have 65 ter 19898, please. Oh, sorry, before that,
15 65 ter 06724, and this is the War Presidency order of the 28th of April,
16 1992, to evacuate the Muslim population from Podgrmec enclave, and using
17 the words "Evacuating them." And in the direction of Bunja [phoen]
18 Japra, Kamengrad and Fajtevci --
19 A. Fajtevci.
20 Q. Sorry for my pronunciation. And that's cited in footnote 170 of
21 your report; is that right?
22 A. Yes.
23 Q. And you cited this document for which reason?
24 A. Another example of organised evacuation. As I noted, the
25 president of the War Presidency, himself, said that the War Presidency
1 suggested two options to the Muslims; either to organise their own
2 evacuation from the area or to have that effected by military means. So
3 I cite this to support that, in fact, they did carry out these
4 evacuations, and that if the options are merely, Do it yourself or the
5 army will make you move, it can't be considered truly voluntary
6 evacuation. We also have the deputy from Krupa saying in the Assembly
7 that he hopes the Muslims will not come back.
8 MS. SUTHERLAND: Your Honour, I tender that document.
9 JUDGE KWON: Yes.
10 THE REGISTRAR: Exhibit P2737, Your Honours.
11 MS. SUTHERLAND: And could I please have 65 ter 19898.
12 Q. Ms. Hanson, this is a list entitled "List of inhabitants of
13 Arapusa deported to Sanski Most municipality," on the 1st of May, 1992,
14 at 1530 hours.
15 And if we could quickly scroll through the pages, Mr. Registrar.
16 Have you seen this document before?
17 A. I believe I have. All the names appear to be Muslim, just on a
18 quick glance. There are so many obviously family -- surnames, and the
19 first names all appear to be Muslim.
20 Q. It's a list of 390 names. Is this consistent with what you say
21 in your report in relation to the temporariness of the evacuation?
22 A. Yes, it is.
23 MS. SUTHERLAND: I tender that document, Your Honour.
24 THE ACCUSED: [Interpretation] Excuse me.
25 What is this document?
1 MS. SUTHERLAND: This is a list of 390 persons who were deported
2 from Arapusa municipality to Sanski Most Municipality on the
3 1st of May, 1992.
4 MR. ROBINSON: And what is the provenance of the document? Who
5 did it come from, who issued it?
6 MS. SUTHERLAND: It's been provided by a witness.
7 MR. ROBINSON: I think we need to know more than that,
8 Mr. President, before you can admit it.
9 MS. SUTHERLAND: Your Honour, we can provide that information to
10 the Defence. If we can mark it for identification at this stage.
11 THE ACCUSED: [Interpretation] I can't agree with that. Anyone
12 could have brought this. It has no authenticity at all.
13 [Trial Chamber confers]
14 JUDGE KWON: The Chamber is of the view that you have another
15 opportunity to tender this document through another witness, so we'll not
16 admit this through this witness at this time.
17 Before you proceed, I'm going to ask you, at the end of your
18 re-examination, to identify the items that you wish to tender among the
19 Appendix B list. So could you identify those --
20 [Overlapping speakers]
21 MS. SUTHERLAND: I've done that already.
22 JUDGE KWON: You already have. All right.
23 MS. SUTHERLAND: If we could have 65 ter 13197 on the screen,
25 Q. Ms. Hanson, do you recognise this document?
1 A. Yes, I do. I cite it in my report.
2 MS. SUTHERLAND: And unfortunately, Your Honour, we don't have a
4 Q. So could you please read the text of the document? Sorry, it's
5 dated the 13th of July, 1992, and it's a War Presidency order.
6 A. [No interpretation]
7 JUDGE KWON: Ms. Hanson --
8 MS. SUTHERLAND: We're not getting a translation/interpretation.
9 JUDGE KWON: Ms. Hanson, could you repeat? We don't have the
11 THE WITNESS: I've taken my headphones so I don't hear the
12 B/C/S --
13 "[Interpretation] The War Presidency of the Serbian Municipality
14 of Bosanska Krupa is issuing the following order:
15 "The Public Security Station of the Serbian Municipality
16 Bosanska Krupa is hereby instructed to invite, for security reasons, for
17 an interview all persons from mixed marriages and to offer to them, if
18 they so wish, to move out of the area of the Serbian Municipality
19 Bosanska Krupa individually or together.
20 "This order enters into force immediately."
21 MS. SUTHERLAND:
22 Q. And is this consistent with a temporary evacuation?
23 A. No. It suggests that people from mixed marriages are still in
24 Krupa in July and that they are going to be -- have it suggested by the
25 police that they might want to leave, which strikes me as a method of
1 intimidation. Perhaps they genuinely want to leave, but if the police
2 are saying that, Because you're in a mixed marriage, you might want to
3 leave, it suggests intimidation to me.
4 MS. SUTHERLAND: Your Honour, I tender that document.
5 JUDGE KWON: Yes.
6 THE REGISTRAR: MFI 2738, Your Honours.
7 MR. ROBINSON: Excuse me, Mr. President.
8 I'm just a little slow in my thinking about that, but I would
9 like to object to that last answer as beyond the qualifications of this
10 witness as an expert. I don't think that she's in a position to
11 determine, from a document like this, whether -- which, on its face,
12 talks about people being given the opportunity to leave, whether that's a
13 form of intimidation or not. She's just a researcher for the Office of
14 the Prosecutor. She doesn't have that kind of expertise. Although
15 things like this sometimes go to weight, I think in this case that
16 particular observation is outside of the expertise of the witness and
17 shouldn't be allowed.
18 JUDGE KWON: Thank you.
19 But as you indicated, it all goes to the weight and credibility,
20 but the witness must have heard it. Thank you for your intervention,
21 Mr. Robinson.
22 Let's proceed, Ms. Sutherland.
23 MS. SUTHERLAND:
24 Q. Ms. Hanson, yesterday you also -- Wednesday you were also
25 shown -- no, I showed that to you. I'm sorry.
1 Could I have 65 ter 01217.
2 And yesterday -- Wednesday, again, Mr. Karadzic was talking to
3 you about these temporary transfers. This is a report of the work on the
4 Municipal Assembly and the War Presidency from the 1st of January, 1992,
5 to the 20th of April, 1993, and this is something that you cite in your
6 report at footnote 9, 69, 115, 136 and 170.
7 In this report, do the Muslim -- I'm sorry, the municipal
8 authorities, the War Presidency, discuss the temporary or otherwise
9 evacuation of its population, the non-Serb population?
10 A. Yes. That's where I got the quotation from that I read earlier
11 about the -- being offered either to organise their own evacuation or
12 have it carried out by the army.
13 MS. SUTHERLAND: If we could scroll to -- and this is, I think,
14 at footnote 170 --
15 THE WITNESS: Yes.
16 MS. SUTHERLAND: -- which is on page 5 of the English.
17 THE WITNESS: Yes. It says that it would be a temporary
18 transfer, but certain areas were an exception and dealt with militarily.
19 However, as I mentioned before, the Assembly deputy, Miro Vjestica, did
20 say he hoped the Muslims would not return.
21 MS. SUTHERLAND: Your Honour, I tender this document.
22 THE ACCUSED: [Interpretation] May I ask Ms. Sutherland to present
23 the entire document to the Chamber, or, alternatively, ask to get more
24 time myself. Let's see, on the first page in Serbian, what happened in
25 Arapusa the day before and the reason for this decision about temporary
1 resettlement, because it's explicitly said that it's temporary. Equally,
2 if the document is admitted, it should be admitted in its entirety.
3 JUDGE KWON: Yes, we are admitting it in its entirety, of course.
4 MS. SUTHERLAND: Yes, Your Honour.
5 JUDGE KWON: That will be admitted.
6 THE REGISTRAR: Exhibit P2739, Your Honours.
7 MS. SUTHERLAND:
8 Q. You mentioned a moment ago that Vjestica formed his view on the
10 A. Yes.
11 Q. Do you recall his speech he made at the Assembly session?
12 A. Yes, that's what I was referring to.
13 Q. Which Assembly decision was that?
14 A. The 12th of May, I believe.
15 MS. SUTHERLAND: If we could have 65 ter 0026 -- no, it's a P
16 number. P01379. Sorry, P00956. And if we could go to English page 20
17 to 21, and in B/C/S, the page is 16 to 18, where we can see Vjestica
18 beginning to speak on page 20 of the English and page 16 of the B/C/S.
19 And then if I can perhaps direct you to page 21 in the English
20 and 18 of the B/C/S.
21 A. The quotation I was thinking of, it's at the very bottom of the
22 screen. Oops. Yeah, it's between the two pages. That there are no more
23 Muslims left in the Serbian Municipality of Krupa, and now that they have
24 heard the president has told us --
25 THE INTERPRETER: The interpreters kindly ask for the reference
1 in the B/C/S text. Thank you.
2 MS. SUTHERLAND: The quote is on page 18 -- page 17, sorry.
3 JUDGE KWON: So we go back to the previous page in English as
5 MS. SUTHERLAND: Yes, page 17.
6 THE WITNESS: It's -- for the interpreters, it's in the middle of
7 the large paragraph, so it's about one-third of the way down the page.
8 He lists various settlements, and then he says:
9 [Interpretation] "Will I have anywhere -- will they have anywhere
10 to go back to? I don't think so."
11 [In English] So at the very bottom of the English page, it says:
12 "Will they have a place to return to?"
13 And then the next page goes on:
14 "I think it is unlikely after our president has told us the happy
15 news that the right bank of the Una is the border."
16 That's a reference to one of the strategic objectives
17 establishing the Una as a border of the Republika Srpska. So he
18 explicitly ties the inability of the Muslims to return to their homes
19 as -- he explicitly ties that to the strategic objective of the border of
20 the state.
21 MS. SUTHERLAND: And while we have that Assembly session, if we
22 could go to page 17.
23 THE WITNESS: Could I also note something on that page? Well,
24 sorry, it's --
25 MS. SUTHERLAND: No, no.
1 THE WITNESS: You haven't asked me about it.
2 There's a reference to Bosanski Novi, that an ultimatum has been
3 issued for the Muslims to surrender their weapons, which is -- earlier,
4 Dr. Karadzic was taking me through the report of the Crisis Staff and
5 saying there was no ethnic criterion for their surrender, but, I think
6 the Muslims will soon be disarmed there too, Vitnica is saying. Or
7 that's in Sanski Most. So, Bosanski Novi, Sanski Most, it's the Muslims
8 being disarmed.
9 MS. SUTHERLAND: If we could quickly go to, while we have this
10 12th Assembly session on the screen, to Mr. Kalinic.
11 Q. Do you remember him making a speech at this Assembly?
12 Mr. Karadzic took you yesterday to a document which was signed by him in
13 English --
14 A. Yes, I recall the document.
15 Q. -- saying that people had to --
16 A. Co-operate with the International Red Cross and humanitarian
18 Q. And -- yes, yes.
19 If we could go to page 17 of the English and page 14 of the
21 Are you familiar with what he said at this Assembly session?
22 A. I know I've read it. I'm not quite sure what quotation -- or
23 what passage you're leading me to now, but I've certainly read his
25 Oh, I remember this, yes, where he says:
1 "The enemy cannot be trusted, and until they are physically
2 militarily destroyed and crushed, which, of course, implies eliminating
3 and liquidating their key people."
4 And he does not hesitate in selecting that option.
5 Q. And the document, I think, we saw from Mr. Karadzic was dated
6 around the end of April. So this is a fortnight later. This is what
7 Mr. Kalinic has to say about the matter?
8 A. Yes, this -- that seems to follow my recollection of the
10 MS. SUTHERLAND: Thank you.
11 If I could have 65 ter -- sorry, it's Exhibit P1379 on the
12 screen. This is the 34th Assembly session.
13 Q. Do you recall Mr. Vjestica speaking at this Assembly session?
14 A. I know I've reviewed his speeches. I can't recall right now what
15 he's saying, but --
16 MS. SUTHERLAND: If I could ask for page 20 of the English and
17 page 18 of the B/C/S, just so that we can see Mr. Vjestica's name at the
18 beginning of his speech.
19 And then if we could go to page 22, the last paragraph on
20 page 22, going over to page 23 in the B/C/S. And in English, the last
21 paragraph on page 24, going over into page 25.
22 Q. And it starts around about the war in Krupa started on the 21st
23 of April -- on 21 April?
24 A. Yes.
25 Q. And then he's talking about Abdic --
1 A. Yes, Fikret Abdic.
2 Q. -- coming to Krupa?
3 A. He describes one village as a Turkish village, by which he means
4 Muslim. He's used the derogatory term "Turk" for Muslims here.
5 Q. And then he says:
6 "And, gentlemen, since it is written in this agreement that
7 everyone will be able to go back to their own territory, that means that
8 his people will be going back to Veliki Babic, and we will have to
9 compensate everything we destroyed and burnt and 17 mosques that we
11 Is that consistent with the proposal that you were shown in your
13 A. Yes, Klickovic's proposal from May 1992 to destroy settlements.
14 Q. That's the 25th of May, 1992, and it's Exhibit P02616?
15 A. Yes, and it indicates that although they have a written agreement
16 that everyone will be able to go back, they hadn't really planned on it,
17 and that's why they destroyed everything. And Dr. Karadzic right away
18 says he was always charmed by Vjestica, admires his fighting spirit, but
19 nothing is true of what he just said.
20 Q. Thank you. If we could leave that document now.
21 Mr. Karadzic took you, at transcript page 14729 to 14736, to an
22 Exhibit D01338, which was minutes of a meeting held in Bosanski Petrovac
23 on the 3rd of June, 1992. I don't want to go back to Petrovac, but he
24 suggested to you that the municipality was being put under pressure from
25 the masses, who were not getting paid to sack the non-Serb workers. And
1 you responded at transcript page 14736:
2 "I see that this is one member, he's saying that was the reason,
3 but I know the ARK was taking a similar position from above."
4 Do you recall that?
5 A. Yes, I do.
6 MS. SUTHERLAND: Could I have 65 ter 01095, please.
7 Q. This is a decision by Brdjanin, dated the 22nd of June, 1992,
9 "Only personnel of Serbian ethnicity may hold executive posts,
10 posts where the information flow is possible ..."
11 Is this the decision that you were referring to?
12 A. Well, this decision seems to come after the one in Petrovac, but
13 I was certainly -- if this is what I had in mind, I see it implemented in
14 municipalities, and it may be that there were earlier versions of these
15 instructions. But certainly at the time, at this time in June, they're
16 implementing these decisions, yes.
17 Q. And if we go to the next page, we can see the document for
18 immediate delivery to the president of the Municipal Crisis Staff. And
19 then the following page, page 3, where we have the president of the
20 Prijedor Crisis Staff, Milomir Stakic, on the 23rd of June --
21 A. Receiving and forwarding this decision of ARK.
22 Q. And is that consistent with what you have in your report?
23 A. Yes. If we could go back one page, too, I would note another
24 interesting item that they -- reference to the Serbs had to vote in the
25 plebiscite to prove their loyalty. That's something else that I note in
1 my report, the participation in the plebiscite as an indicator of
2 loyalty, and that they must regard the SDS as the sole representative of
3 the Serbian people.
4 MS. SUTHERLAND: I tender that document.
5 JUDGE KWON: Yes.
6 THE REGISTRAR: Exhibit P2740, Your Honours.
7 MS. SUTHERLAND: Now, if we can very quickly look at
8 Exhibit P0008, which is a communication dated the 25th of June, 1992,
9 from Petrovac.
10 Q. And that's implementing the steps and decisions set out in the
11 Crisis Staff decision that we just saw; is that right?
12 A. Yes. It says employees have already been sacked, and the
13 remaining ones have now been sacked, except for one, who, when he
14 finishes his tasks, will be fired.
15 MS. SUTHERLAND: I tender that document, Your Honour. Sorry,
16 it's already an exhibit.
17 I'd like to take you to another example of crisis staffs making
18 decisions in relation to the non-Serb population, and that's 65 ter
20 Q. And this is a decision of the Prijedor Crisis Staff on the
21 release of imprisoned persons, dated the 2nd of June, 1992. And can you
22 just very briefly tell the Chamber the significance of this document?
23 A. I cite it in my report as an example of how the crisis staffs
24 were deciding about who would be imprisoned or released. I find
25 Article 1 quite significant, that all Serbs who have been imprisoned by
1 mistake are to be released, implying that there was an ethnic criterion
2 for the imprisonment.
3 MS. SUTHERLAND: I tender this document.
4 JUDGE KWON: Yes.
5 THE REGISTRAR: Exhibit P2741, Your Honours.
6 THE ACCUSED: May I ask, could we work today a little bit longer?
7 JUDGE KWON: You could have asked that later on, but let's
9 MS. SUTHERLAND:
10 Q. Ms. Hanson, I now want to ask you a few questions about -- and
11 show you a few documents about the Kotor Varos municipality.
12 If I could have 65 ter 0338 on the screen, please.
13 Mr. Karadzic painted the Kotor Varos municipality as one of the
14 authorities having everything under control, so to speak, and I just want
15 to -- for you to see whether, in this document, that's really the case in
16 Kotor Varos at the end of June 1992.
17 MR. ROBINSON: Objection. Leading and comment.
18 MS. SUTHERLAND:
19 Q. Ms. Hanson, what's the significance of this document?
20 A. I believe that Dr. Karadzic brought it to my attention, showing
21 the -- that Serb houses were being burned in Kotor. I recall that he
22 described Kotor Varos as Serb territory, and described Muslim and Croat
23 enclaves as deep in the heart of Serb territory. I -- after I checked
24 what I had before on my -- in my information on Kotor Varos population, I
25 don't know if that's something I could mention or not, but to declare it
1 a Serb territory is a bit of a stretch. He's -- it shows -- if you could
2 direct me to which passage you want my attention. He describes the
3 police describing problems with the special unit.
4 Q. And that's Dr. Gajanin?
5 A. Yes, in general. But, yes, he was driven away from the
6 Health Centre by members of the special unit.
7 Q. And do you know whether there were any people killed at the
8 Health Centre?
9 A. I believe so, yes. I believe there was -- it was one of the
10 killing sites, yes.
11 Q. And was anything done by the authorities in Kotor Varos about the
12 special unit that came to Kotor Varos?
13 A. I believe that they requested that the ARK or CSB in Banja Luka
14 withdraw them.
15 Q. And did that happen?
16 A. I'm not familiar, I'm sorry, with the sequence of events
17 regarding the special unit.
18 Q. It says here that Djekanovic said last night that he had told
19 Dubocanin -- do you know what Dubocanin is being referred to there?
20 A. A member of the ARK crisis staff, I believe. I'm not sure.
21 Q. Is that Slobodan Dubocanin?
22 A. I believe so.
23 Q. About everything going on at the Health Centre and in the town,
24 he said that:
25 "All these questions had to cleared up and information provided
1 on the behaviour of the members of the special unit at the meeting with
2 S. Zupljanin, the chief of the CSB, scheduled for tomorrow?"
3 And you said that they had asked -- the crisis staff asked for
4 these special units to be removed?
5 A. I --
6 THE INTERPRETER: The speakers are kindly asked to slow down and
7 pause between question and answer.
8 THE WITNESS: My apologies.
9 Yes, that's as I recall. I've read a lot of minutes from a lot
10 of municipalities, and I can't sort out the sequence of events without
11 some reference to the documents.
12 MS. SUTHERLAND: Your Honour, I seek to tender that document.
13 JUDGE KWON: Yes.
14 MS. SUTHERLAND: Okay.
15 THE REGISTRAR: Exhibit P2742, Your Honours.
16 MS. SUTHERLAND:
17 Q. Finally, I just want to show you one document, and that --
18 Mr. Karadzic took you to quite a number of documents, Crisis Staff
19 minutes, for the period the 25th of October to the 2nd of November, and
20 then the 3rd of November, the 7th, the 10th to the 12th of November, and
21 this was all in relation to Vecici. Do you recall that?
22 A. Yes, I do.
23 Q. And you mentioned at page 14658 to 14659, he asked you about
24 Vecici, and you said your understanding of it was that it was surrounded
25 by Serbian forces and that, in the end, some killings followed in early
1 November, but you can't honestly remember whether they were the men of
2 this village or another place, in a school. Mr. Karadzic didn't take you
3 to the War Presidency minutes of the 6th of November, 1992.
4 And if I could have 65 ter 00292 on the screen, please.
5 What's Mr. Djekanovic up to on this day, what he's reporting?
6 A. He's going to Grabovica, monitoring the cleaning-up of the
7 terrain and the cleaning of the school. And my understanding is that
8 there was a massacre in the school, and there's the president of the
9 War Presidency making sure it's being cleaned up.
10 THE ACCUSED: [Interpretation] How do we know this? How do we
11 know this?
12 JUDGE KWON: That question was about to be asked by me.
13 How do you know that a massacre took place?
14 THE WITNESS: It's -- it's not in these pages, I know, but I just
15 know from the Krajisnik trial, the -- my -- the investigations into the
16 killings scheduled in Krajisnik of that. It's beyond the scope of my
17 report, but I don't know when I can bring in what has been established by
18 other trials or not.
19 MS. SUTHERLAND: Your Honour, if we could see 65 ter 00719 --
20 sorry, 00293.
21 Q. This is a one -- a report from the 1 KK, the 1st Krajina Corps,
22 to the Republika Srpska Army Main Staff, a regular combat report for the
23 4th of November, 1992. And they talk about their -- about 40
24 Green Berets, members were killed, and about 200 were captured. A brutal
25 massacre of the captured members of the Green Berets started because of a
1 wounding of four and a killing of one soldier.
2 Is this what you were referring to?
3 A. I believe so.
4 MS. SUTHERLAND: Your Honour, I would ask that document be marked
5 for identification.
6 THE ACCUSED: [Interpretation] What is the link with the school?
7 It says: "I'll undertake measures to prevent ...," but what does it have
8 to do with the school?
9 MS. SUTHERLAND: Your Honour --
10 JUDGE KWON: Why do you suggest it to be marked for
12 MS. SUTHERLAND: I can seek to tender it, Your Honour.
13 JUDGE BAIRD: But why did you seek it to be marked for
15 MS. SUTHERLAND: I'm sorry, because when I asked Ms. Hanson was
16 this what she was referring to, she said, I think so. At least that's
17 how I understood it.
18 But if I may take her to one more document, Your Honour,
19 65 ter 00722. This is another combat report from the following day,
20 where it states:
21 "The deaths of those captured from Vecici were simply the result
22 of combat activities in the clash against the VRS following the death of
23 one soldier and the wounding of several others, and it seems to be
24 downgraded now to more than 150 extremists died in combat."
1 "In the clash against the VRS, following the death of one soldier
2 and the wounding of several others, more than 150 extremists died in
4 No, Your Honour, we're still not getting the link to the Grbavica
5 school. We'll have to get that through the military expert.
6 JUDGE KWON: So you seek to tender those documents at a later
7 stage or now?
8 MS. SUTHERLAND: We can either mark them for identification now
9 or we can tender them now, and the military expert will speak to them.
10 JUDGE KWON: I'm not sure whether that link has been sufficiently
11 shown at this moment. I will consult my colleagues.
12 [Trial Chamber confers]
13 JUDGE KWON: Why don't you tender them at a later stage,
14 Ms. Sutherland, yes.
15 MS. SUTHERLAND: Thank you, Your Honour.
16 Your Honour, I have no further questions.
17 JUDGE KWON: I understand, Mr. Karadzic, you wanted to ask
18 further questions. But please explain to us what questions you are going
19 to ask and why it --
20 THE ACCUSED: [Interpretation] Thank you.
21 JUDGE KWON: And tell us why it was not -- it could not have been
22 raised before, and in what context it arose from the re-examination of
23 the Prosecution.
24 THE ACCUSED: [Interpretation] This is precisely what I am going
25 to explain.
1 My learned friend, Madam Sutherland, has just been given a new
2 direct examination. 14641 and 14642 are the pages where she did that.
3 Actually, it is the pages on which I said, and Madam Sutherland
5 [In English] Hanson:
6 "Crisis staffs and war presidencies as the institutions through
7 which the moving out of the population was to be organised, including the
8 signing over of property. So I don't mean simply the ARK and so on. I
9 also see them as many individual municipalities."
11 "We will get back to this issue of property being signed over.
12 This is what you are reading into this, but this was not done, this was
13 not implemented. You don't know that, but this was not implemented."
14 [Interpretation] There are two things at stake here. What is
15 being implied is that crisis staffs were formed up and were instrumental
16 in the forcible resettlement of the population, and that their assets and
17 property were taken away from them. And based on that, Madam Sutherland
18 had been given the chance to re-examine and introduce new elements,
19 including demographic elements that did not arise either from my
20 cross-examination, as a whole, or from these particular two pages and the
21 answers that the witness provided in cross-examination.
22 As for the agencies, they are services, and --
23 JUDGE KWON: Just a second.
24 Do you find the reference to the transcript pages of today,
25 Ms. Sutherland?
1 MS. SUTHERLAND: Sorry, Your Honour, I don't understand.
2 JUDGE KWON: Whether you can find the page numbers of the
3 transcript Mr. Karadzic just referred to.
4 MS. SUTHERLAND: Is that the Agency -- the Agency for
6 JUDGE KWON: Yes, referring to his comment that that was not
8 THE ACCUSED: [Interpretation] I never contested the existence of
9 the agencies. What I challenge is the implication that they implemented
10 the forcible resettlement of the population and confiscation of property.
11 And this is what was interpreted on those ten lines, and those ten lines
12 were the very base for the additional questions by the Prosecutor.
13 The document I showed after that, 1308, demonstrated that there
14 was a reason for me to ask those questions, and now we have opened an
15 entirely new page in the whole process.
16 MS. SUTHERLAND: Your Honour, the transcript pages was 14640 to
17 14642, so it would be --
18 JUDGE KWON: I meant in today's transcript. Very well.
19 MR. TIEGER: Your Honour, from today's transcript, that's at
20 page 59, if I --
21 JUDGE KWON: Thank you, yes.
22 [Trial Chamber confers]
23 JUDGE KWON: Yes, Ms. Sutherland. Microphone.
24 MS. SUTHERLAND: The way I read Wednesday's transcript,
25 Mr. Karadzic was disputing they were implementing -- or, in fact, that --
1 the very fact that the resettlement agencies were implemented in the ARK
2 or, in fact, anywhere in Bosnia, and that's why I took him -- Ms. Hanson
3 to all these documents --
4 JUDGE KWON: Thank you.
5 MS. SUTHERLAND: -- to show that there was a resettlement agency
6 and it was working.
7 JUDGE KWON: I'm not sure that we are going to give extra burden
8 to you, Ms. Hanson. We are minded whether we should have a more informed
9 decision on this issue. So probably you may be free of your obligation
10 to the office of the Prosecutor, but given that you are still here, could
11 you come by on Monday morning, and we'll issue a decision first thing on
13 Yes, Ms. Sutherland.
14 MS. SUTHERLAND: Your Honour, Mr. Reid advises me that --
15 JUDGE KWON: So we'll deal with it on Monday, then.
16 Yes, please. I thought you were raising the items, telling us --
17 MS. SUTHERLAND: No. It was just one English translation that's
18 been up-loaded, but that doesn't matter. It can wait until Monday.
19 JUDGE KWON: All right. Thank you very much.
20 We rise for the week, and we'll resume on Monday morning at 9.00.
21 [The witness stands down]
22 --- Whereupon the hearing adjourned at 2.30 p.m.,
23 to be reconvened on Monday, the 20th day of June,
24 2011, at 9.00 a.m.