1 Wednesday, 30 November 2005

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

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

6 JUDGE PARKER: Good morning.

7 THE WITNESS: Good morning.

8 JUDGE PARKER: Would you please read aloud the affirmation on the

9 card that is given to you.

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

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

12 JUDGE PARKER: Please sit down.

13 Mr. Moore.

14 MR. MOORE: Thank you very much.

15 WITNESS: ZVEZDANA POLOVINA

16 [Witness answered through interpreter]

17 Examined by Mr. Moore:

18 Q. Good morning. Could we have your full name, please.

19 A. Zvezdana Polovina.

20 Q. Madam, I'm going to ask you some questions, but I want to deal

21 with certain preliminaries at the start. I think it's right to say that

22 you were born in the town of Vukovar. Is that right?

23 A. Yes.

24 Q. You were born in 1965?

25 A. That's right.

1 Q. You attended school there which you finished, I think, in 1984?

2 A. Secondary school, yes, 1984.

3 Q. And then I think it's correct to say you went to the university at

4 Osijek to study mathematics and physics but you left in 1989 but you did

5 not graduate. Is that correct?

6 A. That's correct.

7 Q. In 1990 is it right that you started a temporary job at Radio

8 Vukovar where the editor, Mirko Stankovic, approached you to work there

9 because he had heard your singing voice. Is that correct?

10 A. Correct.

11 Q. However, I think your job was in broadcasting as opposed to

12 singing?

13 A. Correct.

14 Q. And I don't wish to touch on a sensitive subject. You met your

15 husband there who had worked as a technician for some 20 years. Is that

16 right?

17 A. That's right.

18 Q. Thank you very much. Now, prior to the war - if I may use that

19 phrase - in 1991, is it right that you continued living in Vukovar?

20 A. Yes.

21 Q. May we deal, then, please, with what I will call mid-1991. Are

22 you aware of an incident that involved 12 policemen at Borovo Selo?

23 A. Yes.

24 Q. And do you know the date of that incident?

25 A. Yes. The 2nd of May.

1 Q. And did matters change in the Vukovar area after that incident

2 itself?

3 A. Yes.

4 Q. In very brief terms, can you tell the Court what way things

5 changed.

6 A. People no longer trusted each other. Here first and foremost I

7 mean along the ethnic lines. They went back to their houses and tended

8 not to leave their houses much. After the killing of those 12 Croatian

9 police officers in Borovo Selo, nothing was ever the same again. For me

10 the war began when the first victims fell.

11 Q. Thank you. And now I wish to deal with the radio station itself.

12 Is it right that the station was situated I think in the centre of Vukovar

13 in Marsal Tito Street?

14 A. Yes.

15 Q. And following that incident would it be correct to say that in

16 your view the HDZ took over control of the radio station?

17 A. Yes.

18 Q. And it changed its name from Radio Vukovar to Croatian Radio

19 Vukovar. Is that right?

20 A. Correct.

21 Q. You told us that you had been employed temporarily July 1990; I

22 think it concluded in the end of the year 1990. Were you re-employed in

23 1991?

24 A. Yes, sometime in June 1991. That was when I was re-employed.

25 Q. Can I deal with Mirko Stankovic, who had been the general editor.

1 In June 1991 or, shall I say, the middle of 1991, that period, did he

2 remain as the general editor?

3 A. No.

4 Q. And why was that? Were you able to -- did you know why he was

5 replaced?

6 A. Mirko Stankovic was a pro-Serb editor or general editor. After

7 the HDZ took over control of the radio station, there was no place there

8 for Mirko Stankovic.

9 Q. Can we deal then, please, with who replaced him. Do you know who

10 that was? Josip Esterajher was the one who followed Mirko Stankovic.

11 Q. Did you know a reporter called Vlasejvic?

12 A. Glavasevic, no.

13 Q. It's my pronunciation. It's Glavasevic?

14 A. Sinisa Glavasevic, yes, indeed. He was also an editor and a

15 journalist with Radio Vukovar.

16 Q. And how would you describe your relationship with that particular

17 person?

18 A. In addition to being my work-mate, he was also a very good friend

19 and he was my best man, too.

20 Q. And what was his role within the radio station?

21 A. He was a journalist and an editor of Radio Vukovar.

22 Q. How many members of staff existed at the Croatian Radio Vukovar in

23 June 1991, approximately?

24 A. About 15.

25 Q. And what was the format for the material that was transmitted by

1 Croatian Radio Vukovar at that time?

2 A. We transmitted live. I'm not sure what you mean. Are you talking

3 about the various media, CDs, tapes, that sort of thing? We transmitted

4 live, and we played certain songs from the CDs that we had.

5 Q. How would you describe its political balance with regard to the

6 transmissions?

7 A. Prior to the 2nd of May, we tried to allay tensions throughout the

8 area. We tried to meet everyone's tastes, the tastes of all the different

9 ethnic groups living in the area.

10 Q. And afterwards?

11 A. Afterwards, when it all became clear, when the war intensified, we

12 were in permanent contact with the defence staff and we went out to the

13 field for as long as we felt that our lives were still not in danger. I'm

14 talking about late August and early September, after which time you were

15 no longer exactly able to go out to the field or go anywhere, indeed. At

16 any rate, we gathered our information from the hospital, from the staff,

17 and by talking to those people who were out in the field.

18 Q. I'd like to deal, if I may, please, with what I would describe as

19 the shelling of Vukovar. Can you remember the first significant shelling

20 of Vukovar? Or the Vukovar area, is perhaps a more precise question.

21 A. Yes. The first significant shelling occurred on the 4th of July,

22 1991. Vukovar -- or rather, Borovo Naselje was targeted from the

23 direction of Borovo Selo.

24 Q. And how did you know about the shelling of Borovo Naselje?

25 A. My parents lived there at the time. I, too, hailed from that

1 town. I got married to a man from Vukovar, but previously I had lived in

2 Borovo Naselje. I talked to them on the phone that day, and they told me

3 that they spent the best part of the day in the cellar.

4 Q. Were you ever in Borovo Naselje when an attack occurred?

5 A. Yes. On the 24th of August when a plane attacked Borovo Naselje.

6 Q. And are you able to tell the Court what damage, if any, was done

7 as a result of the plane attack?

8 A. Bombs were dropped on the elementary school. I'm not sure how

9 many casualties there were, wounded and dead. I don't have the

10 information. I can't remember.

11 Q. Finally this in relation to this topic. Between the 4th of July

12 and the 24th of August, are you able to assist the Court in telling them

13 how often Borovo Naselje was struck with shells or bombs?

14 A. It's very difficult to remember specifically, but I was in touch

15 with my parents daily and they were complaining all the time that there

16 was shooting. I'm not really very good with weapons, but I know that

17 rifles were being used as well as pistols in addition to powerful

18 explosions and shelling. I'm not sure how frequently, but I know that

19 between the 4th of July and the 24th of August they spent most of that

20 time hidden in the cellar.

21 Q. Thank you very much. Now, your parents, as you have told us, were

22 at Borovo Naselje. Did they remain there?

23 A. No. I proposed that they come to our home at Mitnica in Vukovar,

24 thinking that that would be a safer place for them to be. By this time,

25 Vukovar had not yet been subjected to any severe attacks. They eventually

1 moved to Vukovar to our shelter. However, the very next day, the 25th of

2 August, Vukovar was also subjected to a plane attack.

3 Q. And again, can you very briefly tell us the nature of the damage

4 or where the damage occurred as a result of that air attack?

5 A. I can't remember the exact location in Vukovar where the bomb was

6 dropped. I can't remember.

7 Q. All right. Let us move on then, please, to the radio station

8 itself. Did the bombing on the 25th of August have an effect on the

9 individuals who worked in the radio station?

10 A. Yes. Our offices, the editorial office of Radio Vukovar was on

11 the first floor at Marsal Tito Street, 16. After this heavy bombing we

12 realised this was no longer a safe place to be. So we went down from the

13 first floor to the ground floor. There was no proper shelter in that

14 building, so we sat down on the steps and laid down our equipment there

15 underneath the staircase. I believe this was sometime in early September

16 when we moved down from the first floor to the ground floor.

17 Q. The broadcasting centre or the aerial, if I may call it that way,

18 where was the main broadcasting mast or centre located?

19 A. The aerial was about 10 kilometres outside town, along the

20 Vukovar-Ilok road, and then just at the turn-off to Ovcara.

21 Q. And were you always able to use that aerial for your broadcasts?

22 A. No. At one point in time it was no longer used. However, we had

23 a spare mobile transmitter that we had received from Zagreb that we later

24 used, and we continued with our programme, despite the fact that our

25 original transmitter had been destroyed or occupied. It only took us a

1 very short time to resume our normal activities by using the other spare

2 transmitter.

3 Q. You have told us that the original aerial was in the direction of

4 Ovcara. Do you know when it was that that -- it ceased to operate?

5 A. It was in the first half of September. I can certainly say that

6 much, but I can't be specific about the date. I think about the 5th of

7 September. There was a vicious attack around that time, but I can't be

8 certain about the date. That was when we had to move and vacate the first

9 floor, and that was roughly the same time that the transmitter could no

10 longer be used.

11 Q. Do you know why it wasn't able to be used?

12 A. It just didn't function anymore. It's that simple.

13 Q. Were you the only broadcasters at that time?

14 A. At that time -- or rather, several days after the fierce attacks

15 and after we had moved to that small shelter -- you can't really call it a

16 shelter. It was just a small space underneath the staircase. The part of

17 town known as Sajmiste had been taken. At night it was often the case and

18 Sajmiste lies on hilly terrain that flares were being fired. There were

19 clusters of these flares - I'm not sure if that's what they're really

20 called - being fired illuminating the best part of town. At the same time

21 as the town was being lit up like that, they would play Serbian songs,

22 probably in order to intimidate us. They illuminated the entire town, and

23 the music boomed throughout the town because they were using very powerful

24 speakers or Tannoy.

25 Q. And can you tell us what sort of material was being broadcast on

1 the loud-speakers?

2 A. You mean which specific songs?

3 Q. Well, if you can tell us the general flavour of the songs. Did it

4 have an ethnic emphasis?

5 A. Yes. I don't know what they're called exactly. But it says

6 something like: "Silver lining Serb cloth. Who's out there telling lies

7 saying Serbia is small?" That sort of thing. I can no longer remember

8 now.

9 Q. Thank you very much. Now, the location of the radio station, was

10 it hit at any time?

11 A. Yes, it was. The building was hit. The building in which we were

12 was hit. The building was hit, but the new transmitter was operational,

13 the building located in Marsal Tito, number 16.

14 Q. And where did you then move to?

15 A. We moved into another basement, which was closer to the Vukovar

16 Hospital. It was a wine cellar belonging to the company called Vupik.

17 And it was called --

18 THE INTERPRETER: The interpreter didn't catch the name.

19 MR. MOORE:

20 Q. Madam, unfortunately the interpreters didn't hear the name. Could

21 you repeat it again, please.

22 A. In Vukovar internally, or locally, it was known as Vucedolska

23 Kapljica. That was the name that locals used for it.

24 Q. Again, I just want to deal with October, and I realise it's an

25 artificial division, but just to give the Court an idea. What was the

1 intensity of the attack at Vukovar at that time?

2 A. There were several thousand shells. Naturally we couldn't count

3 them all, but I had a feeling that every second from early morning until

4 late in the evening, various parts of the town were hit. Detonations

5 produced various sounds. It was immense, thousands and thousands. And

6 they came from various directions, were fired from various types of

7 weapons, multiple rocket launchers, guns, air raids, planes dropping

8 bombs, snipers.

9 Q. Thank you. I want to deal, if I may, please, with the

10 transmissions. Was there any time when you ceased transmitting prior to

11 the 18th of November?

12 A. Yes. Around the 15th of October, as we had come into new

13 premises, we had to organise our work. And we had local broadcasts for

14 local areas three times a day, at 8.00, 12.00 -- or rather, 2.00 and

15 8.00 p.m. And broadcasts intended for a wider audience, Zagreb and

16 elsewhere, was transmitted several times a day. At one point in time we

17 decided to discontinue broadcasts to Zagreb, meaning that we continued

18 with local broadcasts but no longer transmitted to Zagreb.

19 Q. Why didn't you broadcast to Zagreb? Can you tell us very shortly

20 why that was.

21 A. Because our reports underwent censorship in Zagreb; that happened

22 on several occasions. And we thought that if we discontinued our

23 broadcasts to Zagreb, then that would cause some anxiety there because

24 they were no longer receiving any information from us. Up until that time

25 we were the only ones sending reports, and we thought that if we

1 discontinued our reports they would do something in order to transmit our

2 reports in their original state, as we had sent them.

3 Q. I want to move on now to the period before the 18th of November,

4 so a period that's shortly prior to. Is it right to say that there were,

5 as far as you were aware, discussions about an evacuation?

6 A. Yes. I knew that negotiations on evacuation were conducted. In

7 our basement, in this wine cellar, young men from the post office came, as

8 did Dr. Bosanac and Marin Vidic, Bili. The post office man managed to

9 establish telephone contact with Zagreb, and some negotiations were

10 conducted from our basement.

11 Q. From memory 15 years on, can you remember how often Dr. Bosanac

12 came to speak on the telephone?

13 A. We didn't have a telephone line. On the 17th or on the 18th, I

14 believe, we knew that the town would fall, any minute, any hour; and it

15 was then that the men from the post office moved into our basement and

16 established the phone contact. I saw Dr. Bosanac then. Only on that day,

17 in that basement, did we have a telephone connection with Zagreb.

18 Q. Do you know what Dr. Bosanac was talking about over the phone?

19 A. Dr. Bosanac spoke about evacuation of population with -- who

20 remained in Vukovar.

21 Q. And do you know whom she was talking to?

22 A. Yes. She spoke with Raseta, who was a JNA representative.

23 Q. And did you hear what Raseta was saying?

24 A. I remember one sentence very well. He said there would be no

25 problems. Just leave the town for us and everything would be fine. All

1 of you would be able to leave town.

2 Q. And how was it you were able to hear a telephone conversation?

3 A. It was very quiet in the basement. I'm not sure how many people

4 there were there, perhaps 20 or so of us. I'm not sure. It was very

5 quiet. The lads from the post office, once they got the phone line up and

6 running, they either had a loud-speaker or an amplifier, something of that

7 nature, which enabled us to hear what Raseta said. Dr. Bosanac addressed

8 him with "Mr. Raseta." And the voice on the other side seemed to belong

9 to him because I had occasion to hear his voice previously while working

10 on the radio.

11 Q. Can we deal just then with the 18th of November. Is it right that

12 you then left your location and moved to the hospital?

13 A. Yes, that's correct.

14 Q. And why was it you went to the hospital on the 18th?

15 A. The town fell on the 18th. The command left the town and went in

16 to break through, and we believed that we would be safer at the hospital.

17 Q. And when you say "we felt" that you would be safer, who are you

18 referring to?

19 A. Radio Vukovar team, workers of Radio Vukovar, Sinisa Glavasevic,

20 my husband, Vesna Vukovic, and myself. Three of our colleagues went in to

21 break through, Alenka Mirkovic, Zdravko Seremet and Josip Esterajher.

22 Q. When you got to the hospital itself, are you able to say if

23 negotiations were still continuing for the evacuation or not?

24 A. I heard that they did.

25 Q. Were you eventually evacuated yourself?

1 A. I was.

2 Q. Can you remember the date when you were evacuated?

3 A. Yes, I remember. The 20th of November, 1991. It took me two days

4 to reach Zagreb, meaning that I arrived in Zagreb on the 22nd of November,

5 in the morning.

6 Q. Before we go further on, I want to deal with the morning of the

7 20th of November. Can you remember, approximately, what time you awoke?

8 A. We woke up in the morning at around 7.00.

9 Q. When you say "we woke up," who was that, please?

10 A. In a room which was assigned to us in the hospital. There were

11 several mattresses, and in addition to the four of us from the radio

12 station there were three doctors there as well. So there were a total of

13 seven of us there. I don't know who woke up when, but it was at

14 around 7.00 in the morning when all of us realised we were awake and we

15 started talking.

16 Q. Did anybody leave your room that morning?

17 A. Yes. We talked for a while, and then at one point Sinisa

18 Glavasevic said he would go out to see what was going on and when we would

19 set out. That was the last time I saw him.

20 Q. Have you seen him since?

21 A. No, never again.

22 Q. You say that was the last time that you saw him. Can you, in

23 general terms, tell us the time that you left that room that morning,

24 please?

25 A. It was around 8.00. Vesna, my husband, Branko, and I left the

1 room. We passed through a corridor to reach the back entrance.

2 Q. And when you went out of the back entrance, did you see anyone who

3 spoke to you about your evacuation?

4 A. Yes. When we left the building, the hospital building, on the

5 left side there was a man in a uniform standing there. He said, Men to

6 the left. Women and children to the right.

7 Q. And can you describe to the Court, please, this man that you saw.

8 A. Yes, I can. He was tall, slim, on the slim side. He had

9 moustache and dark, black hair.

10 Q. What height was your husband at that -- that day?

11 A. 1 metre 80, approximately.

12 Q. And the man that you saw was tall, slim, and with a moustache.

13 Was he that tall than that or smaller?

14 A. As compared to my husband, he was taller.

15 Q. Did you know his name at the time you went out and first saw him?

16 A. At the time, when I saw him for the first time, I didn't know his

17 name. In the next 15 minutes or so, while talking, whispering to the

18 women standing around me, I learned that this was Veselin Sljivancanin.

19 Q. You have told us that Major Sljivancanin, as we know him, told the

20 group that men were to the left, women and children should go to the

21 right. Did any of the women approach him or speak to him?

22 A. Yes. Several women talked to him.

23 Q. And what did they ask of him?

24 A. They asked him why he had separated men from women, why he had put

25 them aside.

1 Q. And did he give an answer?

2 A. Yes.

3 Q. And what was the answer he gave, please?

4 A. He said, Don't you worry. They are going for a brief questioning

5 to the barracks and they, the men, will follow you soon thereafter.

6 Q. At that time, are you able to say if you saw other soldiers in the

7 area?

8 A. Yes. There were several soldiers there, too. I couldn't tell you

9 how many.

10 Q. Were you able to distinguish whether they were, what I will call,

11 regular JNA soldiers as opposed to paramilitary soldiers?

12 A. They were members of the JNA regular forces.

13 Q. Did you yourself see any paramilitary or irregular soldiers at

14 that time?

15 A. No, not at the time, no.

16 Q. Are you able to assess how many men were separated from the women

17 in that group?

18 A. I think there were about 30 of them, at least as far as I could

19 see.

20 Q. And are you able to describe whether they were injured or not

21 injured?

22 A. Yes. There were wounded, some heavily wounded, completely

23 bandaged up. Yes, there were wounded, yes.

24 Q. And can you recollect how long you remained there?

25 A. I think for quite a long time, perhaps even two hours. We, women,

1 stood on one side, the men on the other side. We watched each other but

2 did not communicate. But we stood there for a long time.

3 Q. And did you see the men then taken away?

4 A. Yes, I saw that. At one point in time they turned behind the

5 corner of the street and disappeared from our sight.

6 Q. We know, of course, that there were negotiations underway and

7 monitors became involved. Prior to those men being taken away, did you

8 see any monitors or peace organisations?

9 A. While the men stood in front of the hospital, there were no

10 observers there.

11 Q. And after the men were taken away, did you see any?

12 A. After they had been taken away, yes. On the other side of the

13 hospital, people started coming in, the monitors of the European

14 community, journalists.

15 Q. You have told us that you had had whispered conversations with

16 some of the ladies that the gentleman with the moustache was Major

17 Sljivancanin. Later on that day, did you have any other conversation

18 about that man's identity?

19 A. I did. First of all we boarded the buses, and then we set out

20 from the city, and during that day and on the following day before we

21 reached Zagreb and many times after that time, I heard the name of Veselin

22 Sljivancanin many times, and naturally, during that day while I was

23 talking to the women on the bus, yes.

24 Q. Can I deal with time intervals, and I know it's extremely

25 difficult. From the time that the men were taken away, are you able to

1 estimate the time interval before the journalist and monitors arrived?

2 A. It was before the noon. It was late morning. That's how I would

3 put it. If we left the hospital at 8.00 and then spent some time just

4 standing there watching the men and then they were taken away, I'm not

5 sure precisely what time it was, perhaps it was around 11.00.

6 Q. Well, I don't want you to guess. I'm just asking about the time

7 interval between the time the men were taken away --

8 A. All right. On the 20th of November in the morning.

9 Q. Can I deal then, please, with one final matter. You were with

10 your husband that morning. Was he taken away with the men?

11 A. Yes.

12 Q. And did you ever see him again?

13 A. I saw his remains.

14 MR. MOORE: I have no further questions. Thank you very much.

15 JUDGE PARKER: Mr. Vasic.

16 MR. VASIC: [Interpretation] Thank you, Your Honour. Good morning

17 to everybody.

18 Cross-examined by Mr. Vasic:

19 Q. First of all, Ms. Polovina, let me introduce myself. I'm a

20 lawyer. My name is Vasic. I'm one of the Defence counsel of Mr. Mrksic.

21 Since both of us speak the same language, I would kindly ask you to make a

22 pause before answering my questions so that the interpreters can

23 interpret, and we will do the same after you give me your answers. Thank

24 you.

25 First of all, I'd like to clarify a technical issue with you. You

1 spoke to the investigators of the Tribunal and gave a statement to them on

2 the 16th of June, 1995?

3 A. I don't think it was on the 16th.

4 Q. Yes. I apologise. I made a mistake. It was on the 23rd.

5 A. Yes, that's correct.

6 Q. This statement was composed in English and was later read out to

7 you in Croatian, and then you signed it. Is that right?

8 A. Yes.

9 Q. When giving statement, you were warned that you should give the

10 answers to the best of your ability to any questions put to you and that

11 you should clearly distinguish between what you heard from others and what

12 you saw yourself.

13 A. Yes.

14 Q. And you complied with this warning throughout that process?

15 A. Yes.

16 Q. You told us that you were born in Vukovar, that you lived there,

17 that you completed our schooling there. You must have been quite familiar

18 with the situation in this town and with the relations in that mixed

19 ethnic community. Isn't that right?

20 A. Yes. I knew my closest friends and family members. I was a

21 student in Osijek, which means that I travelled daily to Osijek between

22 1984 and 1989. So I communicated with the people who were close to me,

23 and I knew them very well.

24 Q. The people you were close with, you socialised with, were they of

25 diverse ethnic backgrounds?

1 A. Yes.

2 Q. You told us that in 1990 you started working at the Radio Vukovar.

3 It was a temporary job until the end of that year. Tell us, please, while

4 you worked there at the radio, did you come across information arriving

5 both from the Vukovar area, from Croatia in general, and even the entire

6 SFRY?

7 A. Yes, I did come across such information.

8 Q. At one point in time you said that your temporary contract

9 expired, and I would like to ask you whether you continued coming to the

10 premise of Radio Vukovar after that.

11 A. Yes, occasionally.

12 Q. And that's how it was until you were re-employed there in June of

13 1991?

14 A. Yes.

15 Q. I would like to clarify something else you said in your statement.

16 You said that the radio station was located in Marsala Tito Street.

17 A. The office of the radio station was in Marsala Tito 16, whereas

18 the studio from which we made our broadcasts was in another location. In

19 the main office we had a very small studio where we recorded news

20 programmes.

21 Q. All right. Now it's clear to me. Where is Marsala Tito Street in

22 Vukovar?

23 A. In the centre.

24 Q. What about this other location, the workers' hall, where the main

25 studio was located, where is that?

1 A. The office of the radio is in Marsala Tito 16 across from Zladna

2 Delina [phoen], whereas the studio from which at the time we broadcast our

3 programme in June of 1991 is located in the workers' hall, which is 300

4 metres away from the office.

5 Q. Thank you. You say that Vukovar was a mixed community with

6 several different ethnic groups. Were you familiar with the political

7 situation back in 1990 during and after the first multi-party elections

8 throughout the former SFRY, including the Republic of Croatia?

9 A. Yes, I was superficially familiar with the situation.

10 Q. You must know then that the HDZ won the Croatian elections?

11 A. Yes.

12 Q. Unlike the results at the republican level, do you know who won

13 the elections in the town of Vukovar?

14 A. I don't remember.

15 Q. If I tell you that it was the party of democratic change that

16 carried the day in Vukovar led my Ivica Racin, would that ring a bell

17 perhaps?

18 A. I know that we had the party in our town, but I'm not sure if they

19 won or not.

20 Q. Thank you. Do you know that Vukovar Serbs voted for this party

21 for the simple reason that they had no national party of their own to back

22 at those elections, such as the Croats had in the HDZ?

23 A. I don't know about that.

24 Q. Thank you. Do you know who the president of the Municipal

25 Assembly for Vukovar was following the 1990 elections?

1 A. I'm not 100 per cent certain. I really can't say.

2 Q. You were already with Radio Vukovar at this time. Do you remember

3 about December 1990 and the amendments that were made to the constitution

4 of the Republic of Croatia?

5 A. I have no recollection of that.

6 Q. Fair enough. In your interview to the Slobodna Dalmacija magazine

7 on the 10th anniversary of the fall of Vukovar, you said that the

8 atmosphere in town had changed as early as the beginning of 1991. Would

9 that be a fair assessment of what you said?

10 A. I don't remember specifically what I said, but I remember the

11 interview, the 10th anniversary interview. I just can't remember exactly

12 what I stated.

13 Q. I do accept that, but can you tell us if it is true that the

14 atmosphere in town was unsettled as early as the beginning of 1991?

15 A. Yes, that's true.

16 Q. Can you please describe for us how you saw the beginning of that

17 year. You say the atmosphere was unsettled. How did that show?

18 A. People started discussing politics much more. I can't give you a

19 set date, a specific date, and say politics had never been discussed prior

20 to that date. But it was sometime in late 1990, the period that you have

21 referred to, and then certainly the beginning of 1991. One could feel a

22 change, and politics became the most topical thing to discuss for

23 everyone.

24 Q. Thank you. Was that only in the Vukovar area or did that also

25 apply to Croatia in its entirety?

1 A. I have no idea what was happening elsewhere in Croatia because I

2 lived in Vukovar.

3 Q. Thank you. Do you remember a time early in 1991 when the -- when

4 barricades were being set up?

5 A. Yes.

6 Q. Were Serbs, too, setting up barricades in Serb-dominated villages

7 as well as Croats, in their own villages where they were, the predominant

8 ethnic group? Do you remember that?

9 A. Villages in the surroundings of Vukovar, to my knowledge at least,

10 were predominantly Serb. I remember specifically. I had a friend, a lady

11 friend, who lived in Borovo Naselje. I know that I couldn't go and visit

12 her because barricades had been erected.

13 Q. Do you perhaps know if barricades were erected also near the Slon

14 cafe and the Zurich cafe in Borovo Naselje?

15 A. I can't say because I travelled that area with no difficulty. A

16 barricade for me means you can't get through, and I did travel that area

17 freely at the time.

18 Q. In my understanding, a barricade is where there needs to be

19 someone who will let you through, not a place where you can't get through.

20 All I'm asking is whether you remember any barricades there at the time.

21 A. No, I don't.

22 Q. Thank you. What, in your view, was the reason that these

23 barricades began to be erected? What was this about?

24 A. I spoke to that friend of mine who lived in Borovo Selo. She told

25 me about the fear that people felt there, that there were all sorts of

1 rumours in circulation. Some people were even saying that they had moved

2 their families, their women and children, by boat across the river into

3 Backa. There was fear in that village.

4 Q. Thank you. Was the propaganda in that village to the effect that

5 the Ustashas would come to the village and kill all the children, slit

6 their throats?

7 A. Yes, that was indeed what she told me, that propaganda was rife

8 and that everybody was afraid.

9 Q. When someone drops the term "Ustasha," that probably reminds

10 people of World War II and the horrible crimes committed by the Ustashas

11 in Croatia. I suppose that's what the propaganda was about; it was a

12 reference to that period in history.

13 A. I don't know. I don't know. I'm saying I don't know because I

14 was only born in 1965. I don't know about the Ustashas. I've never seen

15 one myself.

16 Q. Which is precisely the reason why I'm saying that this reference

17 to the Ustashas was a historical reference, a reference to a different

18 time long ago. I agree with you in as far as I'm not aware of any units,

19 military units, at the time that described themselves as Ustasha units.

20 You mentioned this fear or apprehension that took hold of the

21 Serbs of Borovo Naselje after all this propaganda work. They got so

22 scared, in fact, that some of them moved their children and women and

23 wives to a safe place across the river to Vojvodina?

24 A. Yes, that's what I friend told me.

25 Q. You said in your opinion the war started on the 2nd of May, 1991,

1 after the incident in Borovo Selo. You said this when prompted by my

2 learned friend. You said that for you the clashes began the day the first

3 victims fell?

4 A. Yes.

5 Q. We shall go back to the inter-ethnic atmosphere and the situation

6 in Vukovar and the Borovo Selo incident as well as its significance. But

7 what about the 1st of May, 1991, in Brsadin near Vukovar, what happened

8 there? Stevan Inic was killed by Djura Gelencir, an HDZ member. Do you

9 know anything about this incident?

10 A. No, I've never even heard those names.

11 Q. Thank you. Let's go back to Borovo Selo, the 2nd of May. Did you

12 know that on that day more than 50 members of MUP's special forces,

13 Croatian MUP special forces, entered Borovo Selo on that day and most of

14 them were ethnic Croats?

15 A. I don't have information that's nearly as specific. I know they

16 were Croatian police officers, and I know that 12 of them were killed.

17 When I say "killed," I mean dead. But there were some who were wounded as

18 well.

19 Q. So there were more than 12, because I think the answer you gave to

20 my friend --

21 A. Yes. The way I remember it 12 were killed and a number of them

22 were wounded.

23 Q. Do you know that the MUP forces entered Borovo Selo on the 2nd of

24 May after the municipal authorities of Vukovar, led by the then-president,

25 Stanko Dokmanovic, had reached an agreement with the locals to remove the

1 barricades in Borovo Selo. It was once the barricades had been removed

2 that the MUP forces entered Borovo Selo. Did you know about this?

3 A. I don't remember.

4 Q. Thank you. Did you perhaps hear that the JNA put an end to these

5 clashes by positioning themselves between the clashing parties?

6 A. I don't know. I don't know how the clashes happened exactly. I

7 only know about the number of casualties.

8 Q. Thank you. I had to wait up for the interpretation.

9 You said in your statement that after these events in Borovo Selo,

10 Vukovar and its surroundings were gripped by fear. People stopped going

11 on trips, traditional trips, that were a daily reality and a very popular

12 pastime in Vukovar?

13 A. I'm not sure what you mean by daily reality and popular. On the

14 1st of May, people went to Adica and Dzergaj, two popular destinations.

15 On the 2nd of May, the killing in Borovo Selo occurred. And then you say

16 after the 2nd of May people stopped going to these popular holiday

17 destinations. Well, yes, we can put it that way, but I don't remember

18 that particular 1st of May being a very merry occasion either. People

19 didn't go.

20 Q. My question had to do with the fact that under normal

21 circumstances, people from Vukovar would often go to these destinations to

22 be out of doors and to pursue some physical activities. My question is:

23 Did they still make these trips to the surroundings after the 2nd of May,

24 1991?

25 A. I don't know. I myself didn't go. I can't tell you about anybody

1 else.

2 Q. About after these events on the 2nd of May in Borovo Selo? Is it

3 not true that barricades were removed in most localities throughout the

4 Vukovar area?

5 A. I know that this was the case with some localities. I couldn't

6 say that it was most localities, and I don't think I would be able to

7 enumerate for you all the Serb towns and villages in the area.

8 Q. After Borovo Selo were there rumours again that a new group of MUP

9 forces would be arriving? Did that -- did this cause additional panic?

10 A. No, I have no idea what else people were saying in Borovo Selo.

11 My only friend there was the one that I spoke to on the 2nd of May. After

12 that I don't remember speaking to her again in 1991. We did hear from

13 each other again several years ago, but not in 1991. That was the last

14 time.

15 Q. Did you have an uncle and an aunt in Borovo Selo?

16 A. No. I suppose this is something you got from my statement. It's

17 not aunt and uncle. I believe this is a matter of translation. It's my

18 father's family. They had a cottage at Savulje. Savulje was a holiday

19 resort near Borovo Selo. Yes, they were there; that is true.

20 Q. Do you know if after the 2nd of May, 1991, all traffic connections

21 between Vukovar and the surrounding villages were cut?

22 A. I don't know about that, but I know that I was in Borovo Naselje

23 at the time and that I wasn't able to go to Vukovar for a period of maybe

24 three or four days. It was impossible to go. I couldn't drive -- I

25 couldn't take a bus there; that's what I mean.

1 Q. What about after the 2nd of May, did people from Borovo Selo still

2 go to Vukovar?

3 A. I don't know.

4 Q. For example, those whom you knew?

5 A. I only had one friend there, and she didn't go. I never saw her

6 there.

7 Q. Thank you very much.

8 MR. VASIC: [Interpretation] Your Honours, is this a convenient

9 time for a break?

10 JUDGE PARKER: We can make it one, Mr. Vasic.

11 We will adjourn now for the first break and resume at a quarter

12 to 11.00.

13 --- Recess taken at 10.19 a.m.

14 --- On resuming at 10.48 a.m.

15 JUDGE PARKER: Mr. Vasic.

16 MR. VASIC: [Interpretation] Thank you, Your Honour.

17 Q. Before the break we spoke about the Borovo Selo events. Do you

18 know whether after these events there were any attempts on the part of the

19 president of the Vukovar Municipal Assembly and then also on the part of

20 the prime minister of SFRY, Ante Markovic, and Admiral Brovet to reduce

21 tensions in the area and to try to smooth the situation?

22 A. I'm not sure you enumerated the exact posts held by these persons.

23 I think that Ante Markovic was the president of the federal executive

24 council, but you put it in different terms. I know that after the 2nd of

25 May, several days later, he came to Vukovar.

1 Q. In the interview that I've mentioned -- or rather, in the

2 statement, did you say that despite these attempts to reduce tension and

3 to find a solution, a compromise, these stories started circulating around

4 Vukovar and spreading panic?

5 A. Yes, that's correct.

6 Q. Can you please clarify for us what kinds of stories these were and

7 what reaction did they cause among population?

8 A. Everybody was afraid. I heard these stories from people in my

9 circle, neighbours, friends. Senior citizens, some of whom had war

10 experience, used to say there would be war. At any rate, everybody felt

11 fear. People of my age did not have -- did not feel fear to such an

12 extent. I personally couldn't fathom that something terrible, as terrible

13 as what unfolded later, would happen.

14 Q. Thank you. Let us go back to Radio Vukovar where you worked. You

15 have already told us that in May 1991 it was renamed into Croatian Radio

16 Vukovar, that editor-in-chief Mirko Stankovic was removed due to his

17 pro-Serbian orientation. Would you please tell us whether the director of

18 Radio Vukovar, who was a Croat, was also replaced?

19 A. Yes. After these events he didn't work on the radio any longer.

20 Q. Why was he replaced; do you know? Was he replaced due to his

21 pro-Yugoslav orientation?

22 A. I'm not sure whether he was replaced or left of his own. I don't

23 know whether he received any official document terminating his employment.

24 Somehow I think that he left on his own. I think that he couldn't put up

25 with the newly created situation and he simply left.

1 Q. The number of employees and their composition, did it also change

2 in relation to what it was before the -- May of 1991?

3 A. Yes, that's right.

4 Q. Is it true that previously there used to be 15 employees and after

5 May there were nine?

6 A. I'm not sure whether these figures are correct, 15 and nine. I

7 would have to go back and check it against the names that I remember, but

8 roughly, yes.

9 Q. Was there a number of Serb employees of Radio Vukovar who left

10 their work?

11 A. Yes.

12 Q. You received some reinforcements. From where did these people

13 arrive?

14 A. In June, once I was re-employed, an audition was organised. There

15 was several young people who were hired at that time, perhaps five or six

16 of us.

17 Q. In addition to five or six of you young journalists, was -- did

18 Croatian Radio Vukovar also receive reinforcement in the form of two

19 experienced journalists?

20 A. I don't understand your question. If you were to give me their

21 names, then I would be able to tell you whether they were experienced

22 journalists or not.

23 Q. Margareta Tot-Arvaj and Marija Sesler.

24 A. These two ladies were hired at the same time after that audition.

25 They had no experience whatsoever, and they were young girls of some 20 or

1 so years.

2 Q. Thank you. You told us something about how the work changed after

3 it became Croatian Radio Vukovar. Can you tell us something about the

4 programming. Was the content of the programming also changed?

5 A. Yes. Before the 2nd of May, the programme was aired from 13 or

6 1400 hours until 1800 hours. After the 2nd of May, it was expanded, the

7 air time was, and I don't know whether it was broadcast from morning until

8 evening or perhaps throughout the entire 24-hour period. I don't remember

9 that.

10 Q. In this new policy -- programming policy that was introduced, did

11 you become a reporter as well as a broadcaster?

12 A. After this audition I was re-hired as a broadcaster, announcer,

13 which is the same position I held in 1990. So I was an announcer in that

14 local small radio station, and that entailed also selection of music to be

15 played. As the war escalated, older employees were leaving the radio

16 station and younger people remained; and thus, I also became a radio

17 journalist.

18 Q. Since becoming a journalist, did you have to meet certain

19 requirements of the editorial policy in your work?

20 A. Yes.

21 Q. In the statement that you gave to the OTP investigators, you said

22 that in June of 1991, once you were re-hired as an announcer and a

23 reporter, you had to do everything that was required of the employees.

24 Could you now clarify to us exactly what was required of the employees.

25 A. I could give you some examples. I don't have a specific

1 recollection, but the requirements were typical of those that the

2 journalists had to meet. Why was the water supply cut off? When would it

3 be reinstated, and so on. So there were a lot of such anomalies, if I can

4 call it that.

5 Q. Were there any requirements that the HDZ set in relation to

6 political programming on your radio station?

7 A. No, there were no particular requirements.

8 Q. In the statement that you gave to the OTP, you said that the HDZ

9 believed that a programme could be organised where various participants

10 could exchange their views live, thus enabling the population of Vukovar

11 to hear live the views of their political leaders?

12 A. Yes, that's correct. Political leaders of the town would

13 occasionally come to the radio station. Sometimes independently,

14 sometimes several of them would come simultaneously. And then they would

15 be given opportunity to state their views.

16 Q. You said that there came a time when before sensitive topics were

17 discussed on the air, you had to seek approval of the defence committee?

18 A. Yes.

19 Q. When was the first time when you heard of the Vukovar defence

20 committee?

21 A. I think that this was improperly translated. I don't think that

22 we used this term "defence committee." It was a Territorial Defence staff

23 or something to that effect. At any rate, those who organised the defence

24 and were headed by their commander. This is what it was.

25 Q. Was it called the main defence staff of the city?

1 A. We could call it that, yes. We could say so.

2 Q. Can you tell us who was on the staff?

3 A. At the time in June and July, it was Tomislav Mercep. I'm not

4 sure about the dates when he was a member, but it was at around that time,

5 June, July.

6 Q. He was the commander. And do you know who else was a member of

7 the Main Staff or did you perhaps have contacts only with him?

8 A. I can't remember the names of other people. I know who came after

9 he was no longer commander. I know who his successors were, but who was a

10 member of the staff along with Tomislav Mercep, I cannot remember that,

11 no.

12 Q. Please tell us now that we have touched upon this subject, who was

13 a member of this staff, the Crisis Staff, after Tomislav Mercep left and

14 until the 18th of November?

15 A. After Tomislav Mercep left it was Mile Dedakovic, Jastreb. And

16 after his departure, the command was taken over by Branko Borkovic. Mladi

17 Jastreb was the nickname.

18 Q. What kind of cooperation did you have with this defence committee

19 while it was headed by Tomislav Mercep?

20 A. As this was the very beginning of the war, all of us had to get

21 accustomed to the situation, both us at the radio station and they, the

22 defenders, so that initially we had some problems, but later on it became

23 more coordinated.

24 Q. Let us now turn to what you said to my learned friend, namely that

25 for a while your parents stayed in Borovo Naselje and that you went to

1 visit them there. Do you know that after these events in May of 1991 in

2 Borovo Selo, in June and July, members of Croatian community organised

3 themselves for defence against the local Serbs. And do you know whether

4 this was organised on a street-by-street basis in areas where Croats

5 constituted majority?

6 A. No. If you're referring to Borovo Naselje, I have no idea where

7 Serbs constituted a majority. I don't know that.

8 Q. Do you know that in July in Borovo Naselje, pursuant to the

9 instructions of Tomislav Mercep, a campaign was instituted to get rid of

10 Serb residents?

11 A. I'm not aware of that.

12 Q. Thank you. Can we agree that from the 2nd of May until the 4th of

13 July when Borovo Naselje was shelled from Borovo Selo, in the Vukovar area

14 there were no armed conflicts?

15 A. No, I wouldn't be able to agree with you on that. There was

16 occasional exchange of fire. There was no intense shelling, but yes,

17 there was firing. One could hear shots fired.

18 Q. Thank you. Did you hear that precisely during this period of

19 time, late June, early July, certain facilities, houses, and commercial

20 premises owned by Serbs were blown up as well as newsstands of the Borba

21 publishing agency from Belgrade?

22 A. I know that certain premises were blown up, but I do not know that

23 they were owned by Serbs.

24 Q. Did you hear about the Borba newsstand?

25 A. Yes, I did hear about it.

1 Q. Thank you. Do you know that certain residents of Vukovar went

2 missing during that period of time? Was this discussed in Vukovar?

3 A. Nobody disappeared in my vicinity. Some members of my family

4 fled, but as for people disappearing, no, I don't know about that. Nobody

5 reported it to me that any of their dear persons went missing.

6 Q. All right. Let us go back briefly to the 4th of July, 1991. In

7 the interview that you gave to Slobodna Dalmacija newspaper, did you state

8 that only upon reaching Zagreb did you learn that this attack on

9 Borovo Naselje had been provoked by a previous shelling of Borovo Selo

10 from Osijek?

11 A. I don't remember. Are you sure that this pertains to the 4th of

12 July and not to the 2nd of May?

13 Q. What's your recollection in relation to this? Because my

14 information seems to suggest we're talking about the 4th of July.

15 A. I don't know. When I reached Zagreb, all the Croatian papers were

16 writing about the 2nd of May. There was one or several articles

17 suggesting that there had been active provocation from Osijek. I can't

18 remember the specific newspaper that I read this in.

19 Q. I would now like to move on to the 24th of August, 1991, which is

20 another date that you mentioned. You said there was a plane attack

21 against Borovo Naselje and that the elementary school building was hit.

22 Did this elementary school building actually house the defence staff of

23 Borovo Naselje at the time, its headquarters?

24 A. That was what I heard, but I wasn't there myself. I know that the

25 local commune premises were inside the school building and so was probably

1 the defence headquarters.

2 Q. Thank you. Did you perhaps hear that a JNA air force plane flown

3 by Sasa Acimovic, a native of Borovo Naselje, was shot down over

4 Borovo Naselje on that day?

5 A. I know that Sasa Acimovic came from Borovo Naselje. He went to

6 the same primary school that was hit as did I. His house is across the

7 way from the school; the distance is perhaps about 100 metres. I'm not

8 sure if the plane is shot down or not, though. I can't remember.

9 Q. Did you hear anything about any JNA planes being shot down on that

10 day over Borovo Naselje?

11 A. I know that several planes were shot down. I'm not sure if on

12 this day, and I'm not sure if Sasa Acimovic was in one of those. This is

13 what I can't remember.

14 MR. VASIC: [Interpretation] For the transcript, the pilot's name

15 is Acimovic.

16 Q. Madam, have you ever heard the story saying that the 25th of

17 August attack on Vukovar had been preceded by a JNA plane being shot down?

18 Have you ever heard the suggestion that this was what triggered the

19 attack?

20 A. No.

21 Q. As a journalist, were you aware of the fact that in May four

22 brigades of the National Guards Corps were set up?

23 A. No, I wasn't aware of that. I know that defence was being

24 organised. I'm not sure what these units were called, if they were

25 brigades; and if so, how many of them.

1 Q. Did you know that pursuant to President Tudjman's decision, siege

2 was laid to all the barracks throughout Croatia, including the Vukovar

3 barracks?

4 A. I could agree with what you're saying to some extent. So my

5 answer is partially yes. I'm just not sure about all the barracks

6 throughout Croatia, including the one in Vukovar. I'm not sure about the

7 bit where you're suggesting that all were under siege.

8 Q. While you worked with Radio Vukovar, did you ever hear that there

9 was an order from the commissioner for the town of Vukovar to cut the

10 Vukovar barracks' electricity and water supplies and to cut their phone

11 lines?

12 A. I heard nothing about that. In our section of town and among the

13 people that we were in touch with at the time, it was a well-known fact

14 that there was no water and no electricity. I'm suppose the same would

15 have applied to the barracks. I must say I even find your question a bit

16 strange. Because on the 20th of November, on my way out of town, along

17 the stretch between Sajmiste and Negoslavci, that's where we were, and I

18 was quite astonished to hear people suggest that, yes, they did have

19 electricity because I thought there had been a general power cut or

20 absence of electricity throughout the area.

21 Q. You're talking about Negoslavci, aren't you?

22 A. Yes, that's true.

23 Q. Thank you. You told us that after the 25th of August you remained

24 with your husband on the premise of Radio Vukovar?

25 A. Yes.

1 Q. Throughout your time in Radio Vukovar you transmitted for Vukovar

2 and for the whole of Croatia. Was that the case?

3 A. No, our signal was only powerful enough, our transmitter was only

4 powerful enough to cover Vukovar municipality, and a phone line was being

5 used to forward reports to Zagreb. The signal was not strong enough to

6 cover the entire territory of Croatia.

7 Q. Thank you. When you broadcast reports in addition to the facts

8 you published, you said you also had to appeal to the public's emotions as

9 well as keep in mind the reactions of the political leaders. Is that

10 true?

11 A. Yes.

12 Q. At this period, you were receiving visits from foreign journalists

13 and media, were you not?

14 A. Some were coming --

15 Q. I mean September and October.

16 A. September, yes. October, no. But in September, yes, we did

17 receive a number of visits. But Vukovar was besieged and cut off by early

18 October. I'm not sure if anyone arrived from Bogdanovci or Osijek. I

19 can't remember specifically. In September, yes, there was a presence of

20 foreign journalists in Vukovar. But October, I'm much less sure about

21 that.

22 Q. What about the journalist from the Corriere Della Sera? Do you

23 remember when he came? When was that?

24 A. We were still at Marsal Tito Street. We remained there until the

25 15th of October, so that journalist must have visited sometime before the

1 15th of October, but I can't be specific.

2 Q. What about the after the 15th of October when you moved and went

3 to the Vupik cellar, as you said? Was there a rather considerable number

4 of people from Sajmiste who arrived in that same location?

5 A. Yes, but they didn't arrive the same time as we did. On the

6 15th of October we left our old offices. We were driving through town. I

7 remember the workers' hall. But the first place we went to was the

8 municipality building. They said it was okay for us to go to Vucedolska

9 Kapljica, the shelter that was there. It took us several days to get

10 organised, by which time those people arrived who had been Sajmiste up

11 until that point in time.

12 Q. So this is, roughly speaking, the time when Sajmiste fell?

13 A. Yes. Based on my information, that would seem to be true.

14 Q. Can you please tell me if certain soldiers, members of the ZNG and

15 MUP, came to your studio to inform themselves about the situation that

16 prevailed along certain sections of the front where they were not

17 physically present?

18 A. Sometimes some people would come, but they were more helpful to us

19 then we were to them because they provided information that we wanted and

20 they told us a lot about stuff that we wanted to know about.

21 Q. Did you ever see any members of the H-O-S, HOS, there?

22 A. I never saw them myself, but I heard that a group of HOS members

23 had visited.

24 Q. What about these HOS members? Were they not the ones who held the

25 most crucial portions of the Vukovar front line, as your colleague, Alenka

1 Mirkovic, seems to be suggesting?

2 A. I really don't know about the deployment of Vukovar's defenders.

3 Q. Thank you. You told my learned friend that once you were -- once

4 you had moved to the Vupik cellar, you started broadcasting news three

5 times a day.

6 There's something else I want to know about this. When was the

7 first time you called upon the political leaders and the government to

8 take responsibility for Vukovar's situation?

9 A. I think the first time I called them to account or we called them

10 to account was in early November.

11 Q. Was that when your reports first began to be censored, following

12 orders from the leaders in Zagreb?

13 A. That may be the point in time. I can't be very specific, but I

14 think, roughly speaking, the time-line would seem to make sense.

15 Q. At the time you could practically watch your own reports on TV,

16 realising at the same time that they in no way resembled the original ones

17 that you had dispatched, which only confirmed your point, did it not?

18 A. We did not have a TV set, and we were thus unable to watch our own

19 coverage, our own reports. There was a TV set, the only one, at the

20 headquarters. We would sometimes go there if one of our reports was being

21 aired, and then we would have a look. We realised that our reports were

22 being cut and curtailed severely by listening to the Croatian radio.

23 Q. Thank you very much. This is very elucidating. Being critical,

24 as you were, about the work of the government and the top leadership, you

25 enjoyed the backing of the town's commissioners of the defenders and of

1 the whole town?

2 A. You mean we as a radio station enjoyed the backing of --

3 Q. Yes, in terms of the reports that you were sending and what you

4 were saying in those reports.

5 A. Yes, indeed. We enjoyed the backing of all these people and

6 institutions that you have mentioned, and it was by joint decision that we

7 decided to proceed as we did.

8 Q. The question was raised at the time, was it not, that Vukovar may

9 have been sacrificed for a higher goal, which begs the question if it

10 still made any sense to transmit your radio programme.

11 A. I'm not sure this was the point in time when the question was

12 first raised, but anyway.

13 Q. When was the issue raised?

14 A. It was still -- we were still in Vukovar under siege when the

15 issue was raised. That much is certain.

16 Q. This issue was a logical result of the way the Croatian government

17 treated Vukovar, a needy place facing a serious situation?

18 A. Yes.

19 Q. At this time - and I'm talking about November 1991 - did you enter

20 into any polemic about the political objective that might have been

21 reached by allowing Vukovar to fall?

22 A. Yes.

23 Q. Did the conclusion not just impose itself as part of this

24 discussion that the fall of Vukovar or, rather, allowing Vukovar to fall

25 and leaving Vukovar to its own devices, as it were, was the price for the

1 recognition of Croatia, the price to pay for the recognition of Croatia?

2 A. You couldn't exactly call it a conclusion. We debated the matter;

3 that was all.

4 Q. Did you ever hear that President Tudjman had told Mr. Mercep that

5 for Croatia it would be far graver if 200 people from Zagreb got killed as

6 opposed to 2.000 people from Vukovar, who would have constituted less of a

7 casualty?

8 A. No, I never heard of anything like that being said.

9 Q. Did you know that at some point in 1991 about 100 Serbs went

10 missing in the Gospic area in Croatia?

11 A. I was not aware of that at the time. I was in Vukovar myself.

12 Q. Did you perhaps hear at some point later on --

13 MR. MOORE: With the utmost respect, what relevance is that to the

14 issue?

15 JUDGE PARKER: Can you suggest any, Mr. Vasic?

16 MR. VASIC: [Interpretation] By all means, Your Honours.

17 We talked about Vukovar's sacrifice, a price to pay for Croatia's

18 recognition. This is the issue that I'm discussing right now. And my

19 line of questioning ends with the following submission. My next two

20 questions, the events around Gospic, and the fall of Vukovar, having to do

21 with this epilogue, as it were, that I mentioned a minute ago.

22 JUDGE PARKER: I don't immediately see any connection. Quite

23 content that it's part of your case that Vukovar may have been sacrificed,

24 but to bring in Gospic seems to be going too far. You could leave that.

25 MR. VASIC: [Interpretation] Thank you, Your Honours.

1 Q. Following your return to Zagreb, did you at any time learn that in

2 late 1991 the European community complained to Croatia and raised

3 objections about some things that happened in Croatian territory, saying

4 that this might prove an obstacle on the path to Croatia's political

5 recognition?

6 A. I don't remember that specifically. I arrived in Zagreb on the

7 22nd of November. All I did was search for my husband, who at the time

8 was still listed as a missing person.

9 Q. Thank you. Let's come back to Vukovar again. Can you please tell

10 me whether you were subjected to censorship of information by the Main

11 Staff of the Vukovar defence?

12 A. I don't know. I don't think so. Everything that we reported was,

13 in a way, in agreement with them. We knew what we could report on and

14 what we could not report on. We cooperated well.

15 Q. At one point during that cooperation, did you receive an order or

16 a recommendation from Mr. Borkovic - I don't know what to call it - to

17 stop broadcasting so that the problems of Vukovar could be taken seriously

18 in Zagreb?

19 A. The programme was broadcast continually for the local area, three

20 hours a day from 8, 14, and 2000 hours, and some reports were sent out in

21 agreement with Mr. Borkovic. And for a period, we did not send reports to

22 Zagreb in agreement with Mr. Borkovic.

23 Q. So based on what you talked about with Mr. Dedakovic and based on

24 the feedback you got from Zagreb, you understood that there will be no

25 help for Vukovar. Is that correct?

1 A. We hoped until the last day that help would, nevertheless, come.

2 Q. Did you receive information from Mr. Dedakovic that there would be

3 no technical support or no other type of assistance had set off from

4 Vinkovci?

5 A. I didn't receive any information from Mr. Dedakovic.

6 Q. Thank you. You told us that you learned that the command of the

7 Vukovar defence would leave Vukovar and that you thought about leaving

8 with them. Is that correct?

9 A. Are you thinking about these last days?

10 Q. Yes.

11 A. The 17th and onwards, yes, yes.

12 Q. And you used the term "breakthrough" for this departure. Was that

13 armed breakthrough or just leaving via the roads that could be used to get

14 out of Vukovar, which were perhaps not just the ordinary, regular, routes?

15 A. It was not an armed breakthrough of any kind. All the roads,

16 actually, were regular, normal roads, except for the fact that they were

17 occupied. The term "breakthrough" was used in the sense that it was not

18 possible to pass through. So that is why the term "breakthrough" was

19 used. It would be an attempt to break through. Some managed to do that

20 and some were killed.

21 Q. Throughout the events in Vukovar that we are talking about, the

22 population was multi-ethnic, was it not?

23 A. Yes.

24 Q. Could you please help me with the time frame of this conversation

25 and the departure of the Vukovar defence command. In your statement, did

1 you tell the Prosecutor that on the 17th of November you heard that the

2 command had decided to leave Vukovar and that Mr. Glavasevic on the 18th

3 of November, at around 1400 hours, went to the command to agree the -- on

4 the details with them, but he didn't find anyone there?

5 A. All of that was happening on the 17th and the 18th. We , and when

6 I say "we," I mean the people -- us who were working on the radio. So on

7 the night of the 17th and the 18th, we were talking about whether we would

8 also attempt this breakthrough with the command or whether we would stay

9 where we are.

10 Q. And Mr. Glavasevic go on the 18th of November at around 1400 hours

11 to the command to see?

12 A. I'm not quite sure about this 1400 hours. It's actually 2.00 in

13 the morning, it's 2.00 a.m. and not 2.00 p.m. I know that it was night

14 when we were discussing this.

15 Q. I'm going to check my copy of your statement. It's possible that

16 you said that it was 2.00 a.m. but it states in the statement 2.00 p.m.

17 A. Well, in any case it was night.

18 Q. Did you say in the same statement that on that day, the 18th, your

19 colleagues Alenka Mirkovic, Josip Esterajher, and Zdravko Seremet left?

20 A. Yes, they did leave.

21 Q. And that night you stayed in the basement where you were joined by

22 people from the post office, from the PTT?

23 A. Yes.

24 Q. Thank you. Were these people Mr. Bozidar Zugec and Emil

25 Aleksander; do you remember?

1 A. Well, it wasn't Emil Aleksander definitely because I think he was

2 killed by a heavy shell. The other person was in a cellar or basement

3 next to ours. The basement where we were was actually an extension of

4 another basement. You couldn't go from one basement to the other, but we

5 knew that a group of people was there and hey also knew that we were in

6 our part of the basement. I don't remember when, but it wasn't on the

7 17th of November, definitely, it was much earlier. When I say "much

8 earlier," I still mean November but it was probably early November when

9 Emil Aleksander was killed. I think that it was a cannon -- artillery

10 shell that fell. It was a heavy one. It killed his wife, small baby, his

11 parents. I think that this one shell actually killed some ten people. So

12 Emil Aleksander was not there on the 17th of November. Zugec, perhaps he

13 was there.

14 Q. Thank you very much. You told us that you heard a conversation or

15 conversations and negotiations relating to evacuation. Did you tell the

16 investigators of The Hague Tribunal that the negotiations lasted from the

17 18th until the 20th of November, 1991?

18 MR. MOORE: With the utmost respect, if there's going to be

19 questions - and I don't criticise the question in any way at all - but if

20 there's going to be questions about what was said to the investigator,

21 might I respectfully submit it's only fair that the witness have a copy of

22 the statement.

23 JUDGE PARKER: Mrs. Polovina, if you would like to look at the

24 statement to refresh your recollection for any of these questions, please

25 indicate that and you can look at the statement.

1 MR. VASIC: [Interpretation] Thank you, Your Honour.

2 Q. Madam, if you need to see it, I have a statement or perhaps you do

3 recall it.

4 A. Yes, I think I know what you're talking about. I think in one

5 sentence it does say that the negotiations lasted from the 18th until the

6 20th of November.

7 Q. Yes, precisely.

8 A. I don't know exactly when they began, but those last three days

9 when we were in the hospital, the 18th, the 19th, and then the 20th, early

10 in the morning, I heard that negotiations were being conducted. Before

11 that, before we went to the hospital while we were still in the basement,

12 there was also that part of the negotiations that I personally heard.

13 Q. Thank you, Madam. I'm interested in that part when you came to

14 the hospital. You said that you were in the basement and that at one

15 point on the 19th of November, if I concluded correctly, you saw a person

16 wearing the insignia of the milicija or the police of the Republic of

17 Serbian Krajina. Is that correct?

18 A. Yes, that is correct. I don't know exactly what it said, whether

19 it was the police of the Krajina or the police or milicija of the Republic

20 of Serbian Krajina, something like that. But in any case, at that point I

21 knew that that was not one of our soldiers but one of the soldiers from

22 the Serb side.

23 Q. Can you describe this uniform, the uniform of that soldier -- or

24 actually, the police officer, not the soldier, according to what you say?

25 A. I don't remember. I remember very well the insignia because I

1 thought that was one of our people, and then at the last moment when I saw

2 what was written there, the Krajina milicija, I realised that I had to be

3 careful how I spoke or how I addressed that person.

4 Q. And when you saw that, what was your association when you saw that

5 insignia on the 19th of November?

6 A. Well, it didn't make me think of anything in particular. The

7 person had this insignia on their sleeve, and to me that was an enemy

8 soldier, somebody that I could not trust.

9 Q. Did you see any other police officers like that on that day or was

10 that the only one that you saw?

11 A. I saw some other people in uniform, but I cannot tell you exactly

12 what kind of insignia they had. There were different formations, so I

13 don't know exactly which ones there were.

14 Q. If I were to tell you that this person could not have been a

15 police officer of the Republic of the Serbian Krajina because the Republic

16 of the Serbian Krajina was formed in 1992, would you accept my assertion?

17 A. I really don't know when the police force was formed, but that

18 person did have a uniform with the insignia of the Krajina police.

19 Q. The state of the Serbian Republic of Krajina was formed in 1992.

20 I was not talking about the police, but thank you. That is your comment.

21 I have one more question relating to how you left the hospital.

22 You said in your statement that you -- that there were four columns, a

23 column for Zagreb, one for Novi Sad, one going to Belgrade, and a column

24 of those people who wanted to stay in Vukovar. Is this correct about

25 these four columns? And you stood in the column that was meant to go to

1 Zagreb.

2 A. No, it wasn't like that. There were no columns. We were just

3 told to group, to make groups, of those who wanted to go to Zagreb, who

4 wanted to stay in Vukovar, and a group of those what wanted to go to

5 Serbia. I don't know if there was separate groups for those who wanted to

6 go to Belgrade or Novi Sad. But in any case, there were groups for

7 Zagreb, Serbia, and a group of those who wanted to stay in Vukovar, but

8 there was no columns of any kind formed.

9 Q. Thank you very much. And my last question - I have to ask you

10 this - was your husband of Serb ethnicity?

11 A. He never told me what he was, what his ethnicity was. We never

12 talked about it.

13 Q. Thank you very much, Madam, for your answers.

14 MR. VASIC: [Interpretation] Your Honours, I have no further

15 questions for this witness.

16 JUDGE PARKER: Thank you, Mr. Vasic.

17 Ms. Tapuskovic.

18 JUDGE PARKER: Mr. Moore, I'm sorry.

19 MR. MOORE: Your Honour, before we just proceed to the next

20 cross-examination, there was a question by my learned friend where he

21 indicated to the witness what the witness had said in the statement. It

22 is at page 45, 11.41.07. And what is said, I think, from memory was that

23 negotiations lasted from the 18th to the 20th of November. With the

24 utmost respect, that is not what the -- certainly the English statement

25 says, because the English statement said: "I heard that between the 18th

1 and 20th of November that negotiations were still continuing."

2 And there is, in my submission, a difference in relation to that.

3 I don't know now if that is in relation to the B/C/S translation, but in

4 the English translation that is certainly what I have.

5 The second thing, again to assist my learned friend and I hope the

6 Court, there was reference to a gentleman leaving at 2.00 p.m. In the

7 English translation we have got 2.00 a.m. So again, I don't know if that

8 assists all parties.

9 JUDGE PARKER: Mr. Moore, thank you for bringing that up at this

10 point.

11 Mr. Vasic, before we leave you, is there anything more you want to

12 follow-up on either of those matters?

13 MR. VASIC: [Interpretation] Thank you very much, Your Honours. I

14 would also like to thank my learned friend, but I think that I resolved

15 the time-line issues with the witness.

16 THE WITNESS: [Interpretation] I said it was night-time.

17 MR. VASIC: [Interpretation] As for the first issue raised, I

18 simply asked the witness whether the negotiations were ongoing during this

19 period of time. If my learned friend thinks that the use of continuous

20 tense implies that it went on after the 20th, then I regret that.

21 Thank you.

22 JUDGE PARKER: Thank you.

23 Ms. Tapuskovic.

24 MS. TAPUSKOVIC: [Interpretation] Good morning, Your Honour.

25 Cross-examined by Ms. Tapuskovic:

1 Q. Ms. Polovina, good morning. My name is Mira Tapuskovic. I'm one

2 of the Defence counsel of Mr. Miroslav Radic. I will try to speak slowly

3 so that we ensure smooth interpretation and so that we can be sure that

4 both my questions and your answers are accurately translated. I will also

5 try not to repeat the questions put to you by Mr. Vasic; however, if there

6 are such occasions when some questions are repeated, then that is due to

7 my seeking clarification because I probably did not quite understand

8 something from your previous answers.

9 When you spoke earlier of your work at the radio station, at

10 Vukovar Radio, which was later renamed Croatian Radio Vukovar, you

11 mentioned Mirko Stankovic, the former editor-in-chief. Please tell me:

12 Do you remember on what day his job was terminated?

13 A. No.

14 Q. Do you remember what month it was when he was terminated?

15 A. I don't know.

16 Q. If I were to assist you and tell you it was in July of 1991, were

17 you already employed then with the Croatian Radio Vukovar? You can't just

18 nod.

19 A. No, no, I was waiting for interpretation. I was employed in

20 July. And as for the day of termination of Mirko Stankovic, I don't know.

21 I never saw any official documents regarding that.

22 Q. Thank you. However, you know that another person was appointed to

23 his post as editor-in-chief.

24 A. That's right.

25 Q. You even told us here the exact last name of that person.

1 A. Yes, that's right.

2 Q. He was appointed by the new director, Mr. Serementa.

3 A. The man's name is Zdravko Seremet. He was the new director of

4 Croatian Radio Vukovar.

5 Q. I apologise for mispronouncing the name; however, you and I

6 understood each other. Would you please tell me now whether Mr. Seremet -

7 I hope my pronunciation is right now - replaced Mr. Stankovic.

8 A. Mr. Seremet was unable to replace Mirko Stankovic because Mirko

9 Stankovic served as editor-in-chief. I think that was his post, whereas

10 Zdravko Seremet was the radio's director.

11 Q. Thank you. Do you know that Mr. Seremet submitted a disciplinary

12 complaint against Mr. Stankovic, the former editor-in-chief?

13 A. No, I don't remember that.

14 Q. Mr. Seremet - let me just try to refresh your memory - filed a

15 disciplinary complaint to the disciplinary commission. There were a total

16 of 15 of you working there when you started working full time, and some of

17 you must have been members of this disciplinary commission. Am I wrong?

18 A. This is really the first time I hear of this. I really don't know

19 what you're asking me. At the time, I did work at the radio station, but

20 I have to correct you, it wasn't full time. However, I knew what was

21 going on, but I cannot remember that there was any such disciplinary

22 commission. I was certainly not a member of it.

23 Q. All right. We will not pursue this any longer since you, as you

24 say, no nothing about these events.

25 In the statement you gave to the investigators you said that

1 immediately after the events in Borovo Selo on the 2nd of May, if I am not

2 mistaken about the date, the HDZ took over control of the radio station.

3 Can you please explain briefly to us what this means, that they took over

4 control.

5 A. That means, both physically and legally, from that time on the

6 station was renamed into Croatian Radio Vukovar. I wasn't employed at the

7 radio then. However, I heard from Sinisa Glavasevic and Branko, my

8 husband, that the lock was changed.

9 Q. You said in your statement that between your two employments you

10 spent a lot of time on the premises of Radio Vukovar and that you were

11 quite familiar with what was going on in the entire area. Would you be

12 able to tell us whether this pertains only to the city of Vukovar or to

13 the entire Vukovar region, meaning Slavonija?

14 A. I would go to the premises of the radio station during the period

15 of time when I wasn't employed then, because at the time I was dating my

16 husband. The signal of Radio Vukovar was able to cover the territory of

17 the municipality of Vukovar, and its programming concerned local issues,

18 those of interest to the municipality of Vukovar.

19 Q. All right. I'm waiting for interpretation.

20 Let me go back once again to Mr. Stankovic. He's a person who

21 practically helped you get a job. Is that right?

22 A. Yes, that's right.

23 Q. In your statement you said that he demonstrated some signs of Serb

24 extremism. Today you said on page 4, line 6, that he was an editor with a

25 pro-Serbian orientation and therefore there was no room for him at the

1 radio station. Could you please tell us what this pro-Serbian programming

2 orientation of his entailed.

3 A. Mirko Stankovic at the time was editor-in-chief, but nevertheless

4 occasionally he would write a text either for the radio station or for the

5 newspaper in Vukovar. These texts of his occasionally would send a

6 message to the effect that Vukovar was a Serbian city and that the Serbian

7 population was at risk. This is what indicated that his orientation was

8 pro-Serbian.

9 In addition to that, there were some 16.000 records at the radio

10 station. Some of them were marked "airing prohibited." Those were the

11 songs of Vice Vukov, Vera Svoboda, which means that those were the songs

12 which were of Croatian content, something having to do with Croatia. When

13 I asked about this, because I was shocked by this, I was told that this

14 was a decision of Stankovic, decision not to air these songs.

15 Q. You were born in 1965?

16 A. Yes.

17 Q. Do you remember who Vice Vukov was?

18 A. Certainly.

19 Q. Do you remember that he was convicted for his - let's put under

20 quotation marks - his "nationalist outbursts." Do you remember that he

21 was convicted for this?

22 A. Back then in 1971 or 1972, no, I didn't know that. Later on, when

23 I was older, I learned about this.

24 Q. You said that the HDZ took over control and that all of a sudden

25 the lock was changed. How did you learn that the lock had been changed?

1 Who told you about this?

2 A. I think that I've already told you that Sinisa and Branko told me

3 about this. Sinisa Glavasevic and Branko Polovina.

4 Q. Did they say why the lock had been changed and by whom?

5 A. They didn't say the reason the lock was changed, but they

6 mentioned people who were close to Tomislav Mercep.

7 Q. Thank you. Does this mean that people who were close to Tomislav

8 Mercep also set the programming policy of the Croatian Radio Vukovar?

9 A. No, that's not true.

10 Q. However, if these people came and changed the lock?

11 A. Yes. But that doesn't mean that they also set the programming

12 policy.

13 Q. Thank you. Can you confirm that after the departure of Stankovic,

14 Josip Esterajher became editor-in-chief? I hope I pronounced the name

15 correctly.

16 A. In the meantime, I remembered another man who spent a very brief

17 amount of time there. I'm not quite sure, but I think his last name was

18 Schlafhauser, and first name perhaps Kreso. I knew him very little, but I

19 think that he spent a very short period of time serving as editor-in-chief

20 between these two men. However, during the war, Josip Esterajher was

21 editor-in-chief.

22 Q. All right. Thank you. Can you tell me does it seem strange to

23 you that in a brief space of time, practically from the time you were

24 re-employed at Croatian Radio Vukovar, four persons of Serb ethnicity

25 holding prominent offices in town were replaced or fired?

1 A. I don't know what persons you are talking about, and I also don't

2 know whether they are of Serb ethnicity.

3 Q. When asked by my friend Vasic, you said you didn't know who the

4 president of Vukovar municipality was. Is that right?

5 A. Yes, that's right. I wasn't sure about it.

6 Q. Thank you. If I tell you the name, Slavko Dokmanovic, would that

7 sound familiar to you?

8 A. Yes. I heard of Slavko Dokmanovic.

9 Q. Did you also hear that on the 25th of July Franjo Tudjman

10 disbanded the Municipal Assembly by a decree and also suspended Slavko

11 Dokmanovic?

12 A. I don't remember that.

13 Q. Thank you. Do you know that Marin Vidic, Bili, replaced the

14 director of the hospital, Rade Popovic, who was a Serb, on the 18th of

15 July, 1991?

16 A. I'm not aware of that. I know Marin Vidic, Bili, and the other

17 one is a doctor, Rade Popovic, isn't he? I also heard of him. Now, as to

18 whether he was replaced or not, I don't know that.

19 Q. What is important for us here is that he was the hospital

20 director.

21 A. I don't know whether he was the hospital director. I heard his

22 name from other people. I know he was a doctor. I believe he was a

23 psychiatrist.

24 Q. You as somebody employed at the radio station, somebody who is

25 supposed to provide unbiased reports to the population in your area, did

1 you know that a director of the large enterprise, Borovo, called Zdravko

2 Egic, also a Serb, was also removed from office during that period of

3 time?

4 A. I don't remember that.

5 MS. TAPUSKOVIC: [Interpretation] If I can have the usher's

6 assistance now, please, to display a map. This is Exhibit 59, or proposed

7 Exhibit 59.

8 Your Honours, we shall have to take a break at some point. Do you

9 think I should move on with my other questions now and leave the map for

10 later, for after the break? Namely, I would like to ask the witness to

11 mark the map and I would not wish to have to do that faster than

12 necessary. So can I be allowed to change the original order of my

13 questions?

14 JUDGE PARKER: Certainly. Could I indicate that it's not a matter

15 of finding the map, but the physical process of it being produced and able

16 to be displayed, produced electronically, takes a great deal longer with a

17 map than with a page of type face. But given the time, certainly move on

18 to other questions and perhaps arrange with the court staff to have the

19 map ready when we return after the break -- it is ready now, but I leave

20 it to you entirely whether you want to deal with the map now. We would be

21 breaking no later than quarter of an hour from now. If that isn't time

22 enough to deal with the map, go on and deal with something else.

23 MS. TAPUSKOVIC: [Interpretation] Thank you for your assistance,

24 Your Honour. I still remember your explanation about colour photographs

25 requiring a little more time to be displayed on the screen, which is why I

1 wanted to leave that for later. However, if we still have 15 minutes to

2 go, I think that I can deal with the map or at least I'm sure that I will

3 try to do my best.

4 Q. Ms. Polovina, do you have the map on your screen? You recognise

5 it to be a map of Vukovar, don't you?

6 A. Yes. All I can't see is the number that you referred to, 59.

7 Q. That's for internal use, so you needn't worry about that.

8 MS. TAPUSKOVIC: [Interpretation] Can the usher please zoom in a

9 little so that we may be better able to see the centre of Vukovar. A

10 little more, please. More, more. Fine. That's excellent. Thank you

11 very much. I want all the red dots to be displayed clearly on the screen

12 so that the witness can see them.

13 Q. Ms. Polovina, do you think you could give us a hand with this. I

14 would like you to indicate certain buildings for us on the map or at least

15 indicate their approximate location in Vukovar. The usher will help you

16 with this.

17 A. I will tell you everything that I know. I must say, though, that

18 I grew up in Borovo Naselje. I only came to Vukovar to live there in May

19 1991, and I'm not familiar with all the street names. I know some, but I

20 can't say that I have a complete mastery of the town's layout and streets.

21 Q. Ms. Polovina, you'll see it's actually much simpler than you'd

22 expect. Can you please use the pointer to indicate for us on the map the

23 location of what was first the main offices of Croatian Radio Vukovar and

24 mark that as number 1. Approximately. I'm looking for an approximate

25 location, not high precision. That's not what I'm expecting.

1 A. The orange lines are the streets, I assume?

2 Q. Yes, indeed. Those are the main roads in Vukovar.

3 A. If this is the Vuka, then the workers' hall was here. And then

4 about 300 metres further in this direction was our office. Here's a

5 street that you turn into. You said to use number 1. Right?

6 Q. Yes. The Arabic numeral 1.

7 MS. TAPUSKOVIC: [Interpretation] Could you please blow that up a

8 little. Thank you.

9 Q. Can you now please indicate the direction of your studio.

10 A. From this dot here in the direction of the Vuka, that's where the

11 workers' hall was. Which number do you want me to use?

12 Q. The next Arabic numeral, 2. Put a number 2 there, please.

13 A. It was hereabouts, roughly speaking, the studio. I'm talking

14 about the time when we were still able to transmit from there.

15 Q. Thank you. And thank you for saying so on the transcript.

16 Can you now put another dot marked with number 3 at the place or

17 the area of Vukovar in which you lived after you had got married.

18 A. That was a brief period, but -- is the water-tower somewhere on

19 this map? Because if I know that I would find it much easier to find the

20 exact location.

21 Q. I'm afraid I can't help you with this. You need to try and

22 remember yourself.

23 A. I think it's hereabouts. Number 3.

24 Q. Can you put a dot there, too, please.

25 A. [Marks].

1 Q. Thank you. Could you now please indicate what today you

2 accurately called the headquarters of Vukovar's defence.

3 A. [Marks].

4 Q. Please put number 4 there.

5 A. It should be around here.

6 Q. Thank you. Next could you please use a dot and mark with number 5

7 the new shelter, the Vupik cellar that you were later to move to.

8 A. Here it is.

9 Q. Thank you.

10 MS. TAPUSKOVIC: [Interpretation] Your Honours, I move that this

11 map be admitted into evidence as our next exhibit.

12 JUDGE PARKER: It will be received.

13 THE REGISTRAR: Your Honours, that will be Exhibit 127.

14 MS. TAPUSKOVIC: [Interpretation]

15 Q. Could you now please indicate -- or rather, we no longer need to

16 indicate anything on the map, but can we please keep it on the screen for

17 the time being. Now the map is gone. It's fine now. What I meant is --

18 well, regardless.

19 Madam, we have now seen where your studio was and the shelter,

20 too. Could you please tell us which route did you take to the hospital?

21 You did tell us, after all, didn't you, that you would go very often from

22 your radio office to the hospital?

23 A. When I say "we went to the hospital," I mean the Radio Vukovar

24 team. I myself did not go as frequently as others, but I can still share

25 that with you. The shelter you mentioned was the Vucedolska Kapljica

1 shelter, right?

2 Q. Yes.

3 A. Number 5 is here, this is the main road, and the largest dot you

4 can see in this area is the hospital.

5 Q. You said you moved to the Vupik cellar; that was recorded today.

6 You said you had decided to do that so as to be as near the hospital as

7 possible. Why was that necessary for you to be as near the hospital as

8 possible?

9 A. Funny, I don't remember saying that, about being near the

10 hospital. We went to the municipal building to see Marin Vidic, Bili.

11 That was perhaps one of the few cellars or the only shelter that was safe

12 at the time in Vukovar, in as far as anything at all was safe in Vukovar

13 at the time.

14 But yes, we did wish to be as near the hospital as possible

15 because that lessened the risk of us being killed. The shorter the route,

16 the smaller the risk. One thing is to just run across a road and keep

17 running for 300 or 400 metres. If you had to drive or walk for several

18 kilometres, the chances of you surviving were very slim, indeed.

19 Q. On your way from home to work, did you use any means of transport

20 at all?

21 A. Which period are you referring to, because when the shelling was

22 at its heaviest I wasn't staying at my house?

23 Q. When I say "from home," then that must mean reference to the time

24 while you were still there.

25 A. For as long as I could, I either drove in a car or walked.

1 Q. Did you go together with your husband or alone?

2 A. Sometimes we went together and sometimes I went on my own.

3 Q. Between the first severe shelling of town, the day which you

4 defined as the beginning of fighting on the 25th of August -- or rather,

5 since the first severe shelling, how was the distribution of food

6 organised in Vukovar?

7 A. From the 25th of August to sometime around the beginning of

8 September, I was at the radio station and mostly we would cook our own

9 food. No one brought us food. We organised everything ourselves because

10 at this period every now and then you could still nip over and go to a

11 shop to get some food. After that period -- after that period, it was

12 very dangerous to walk around. It wasn't possible any longer, unless you

13 had a death wish. It was very, very difficult. On some days there was

14 nothing to eat. We had some old supplies, biscuits, canned food, pate.

15 It was extremely difficult. But people who organised food distribution in

16 Vukovar had not yet gotten into their stride, as it were. But this began

17 to work much better after a while, and we heard that food distribution was

18 organised in some of the shelters. You knew exactly who was doing the

19 cooking and who was bringing in the food supplies.

20 Q. Food was being prepared at Borovo Komerc?

21 A. Some, yes. I did hear that, that was one of the places. Borovo

22 Komerc did not organise food for the entire town, but yes, people were

23 cooking food there.

24 Q. This food was then distributed to certain areas in Vukovar, was it

25 not?

1 A. Yes, for a while.

2 Q. So it was on a daily basis that food from Borovo Komerc was being

3 delivered to other parts of Vukovar, was it not?

4 A. I don't know about other parts of Vukovar, but while we were at

5 Vucedolska Kapljica, for a while we were receiving food from Borovo

6 Komerc.

7 Q. My conclusion, Madam, would be that it was not that dangerous,

8 after all, to move around if you were able to organise food distribution

9 all over Vukovar on a daily basis. Would that not seem to be a fair

10 conclusion?

11 A. I myself don't need to have any conclusions at all because I know

12 the facts. I don't know their numbers, but people were getting killed on

13 a daily basis in the process. One day there would be someone who got

14 killed. The next day it was someone else, and then two or five people

15 were killed in the possess as they were delivering food across Vukovar.

16 Q. Did you know whether these people were killed by shells or also

17 mines?

18 A. I don't know about the various ways in which these people were

19 killed. Shells certainly killed some of them. I could also assume that

20 maybe some of the roads were booby-trapped and that there were mines,

21 unexploded mines, along those roads that killed some of the drivers.

22 Q. Thank you.

23 MS. TAPUSKOVIC: [Interpretation] Your Honours, I think this is a

24 good time to have a break, if you agree.

25 JUDGE PARKER: Thank you.

1 We will resume at five minutes to 1.00.

2 --- Recess taken at 12.30 p.m.

3 --- On resuming at 1.00 p.m.

4 JUDGE PARKER: Ms. Tapuskovic.

5 MS. TAPUSKOVIC: [Interpretation] Thank you, Your Honour.

6 Q. Ms. Polovina, I would like to put one more question to you at the

7 point where we stopped before the break regarding the functioning of the

8 town, in that period, as you say of the siege. My colleague Vasic

9 reminded you of your interview to Slobodna Dalmacija on the occasion of

10 the 10th anniversary of the fall of Vukovar. Is that correct?

11 A. Yes.

12 Q. Can you confirm for us here that already in September 1991 all the

13 food reserves in the Nama department store were removed, placed under

14 control, for the purpose of distribution in the shelters?

15 A. I cannot be 100 per cent certain whether this was in September,

16 but I think that it was.

17 Q. Thank you. Could you please tell us whether movement was

18 restricted in town in the morning and in the evening.

19 A. In which period?

20 Q. In the September and October period, the ninth and the tenth

21 month.

22 A. It was restricted because of the shelling. So I don't

23 understand. When you say the evening hours or daytime, I think it's the

24 same.

25 Q. I'm asking whether perhaps movement was restricted or not allowed

1 after nightfall, after 10.00 p.m.?

2 A. I don't remember.

3 Q. In your statement to the Prosecution you said that until the 15th

4 of September, is that correct, the ninth month?

5 A. Yes, that's correct.

6 Q. It was still possible to move around town, although movement was

7 restricted. Do you remember that?

8 A. Yes.

9 Q. So movement was restricted, as far as you're concerned, because of

10 the shelling?

11 A. Yes.

12 Q. You confirmed that you knew Marin Vidic, Bili, and that you kept

13 in touch with the Main Staff.

14 A. Yes, I do know Marin and he did work as a liaison -- oh, and the

15 radio station was in contact with the Main Staff.

16 Q. Well, can you confirm that the Main Staff adopted any kind of

17 decision relating to restriction of movement?

18 A. No, I cannot remember. The only thing I do remember is that I had

19 absolutely no desire to go out because there was shooting. I think that I

20 could have done that at any point, though, but I would have risked my

21 life.

22 Q. I think that it was obvious from my question that I was referring

23 to a formal restriction of movement. Do you know if there was any kind of

24 formal imposition on restricting movement past?

25 A. No, I do not remember that.

1 Q. Thank you.

2 MS. TAPUSKOVIC: [Interpretation] Your Honours, I would like the

3 usher to call up document number 0D04-0001. That's the number of the

4 B/C/S version. Could that be please placed on the ELMO and the screen in

5 front of the witness. The English version has the number 0D04-0003.

6 Could the witness be shown the B/C/S version, please.

7 Q. Madam, do you see the document?

8 A. Yes.

9 MS. TAPUSKOVIC: [Interpretation] Would it be possible to zoom in

10 on the document and could we look at the first -- the top half of the

11 page, please.

12 Q. Can you read the date from the top left corner of the document,

13 please.

14 A. I -- from what I can see, it says 8th of September, 1991. I don't

15 know if there are any other numbers in front of the 8th, but I don't think

16 so.

17 Q. Thank you. Can you please read to us the second paragraph.

18 MR. MOORE: With the utmost respect, shouldn't the witness be

19 asked if this is a document that she knows and has personal knowledge of?

20 If she does not have personal knowledge of the document, how can she give

21 any useful evidence in relation to its content?

22 MS. TAPUSKOVIC: [Interpretation] Your Honour, thank you very much.

23 I agree with my learned friend's suggestion.

24 Q. Madam Polovina, did you have the opportunity to familiarise

25 yourself with this document?

1 A. No. I've never seen this document.

2 MS. TAPUSKOVIC: [Interpretation] Could the usher please show us

3 page 2 of the document.

4 Could the witness please tell us whether she can read who signed

5 this document.

6 THE WITNESS: [Interpretation] I don't see anyone's signature, but

7 I can see the name "Marin Vidic, Bili" in the document.

8 MS. TAPUSKOVIC: [Interpretation]

9 Q. Thank you. There is no signature on the decision, but there is a

10 stamp. Can you read just one line. It's the last-but-one line on the

11 second page of this document?

12 MR. MOORE: I'm sorry. I repeat my objection. If the witness

13 doesn't know the document, has not seen the document, what is the

14 relevance pursuant to the question, and how can this witness then give any

15 useful evidence in relation to it? It's not her document, she doesn't

16 know the document.

17 MS. TAPUSKOVIC: [Interpretation] Your Honours, my previous

18 question to the witness had to do with the restriction of movement within

19 the town. The witness said that she didn't know about that, but she

20 confirmed that Radio Vukovar or that they had land-line with Marin Vidic,

21 Bili; they were in contact with him. This is a decision that relates to

22 the whole of Vukovar and also would include the conduct and the work of

23 the radio station. I believe that if the witness were to see the

24 document, perhaps she would remember -- if not having seen this document,

25 then perhaps having commented on the document perhaps with her colleagues.

1 JUDGE PARKER: Thank you.

2 Mr. Moore, the document, I believe, can be properly put to the

3 witness to see whether it prompts her recollection of the situation at the

4 time. If it doesn't, it can't be taken beyond that.

5 Please go ahead.

6 MS. TAPUSKOVIC: [Interpretation] Thank you.

7 Q. I assume that you've now read the document. Do you maybe remember

8 commenting the decision to restrict movement in Vukovar with your

9 colleagues?

10 A. I don't remember this document, and I don't remember commenting

11 with my colleagues about what is written in the document.

12 Q. Did you perhaps comment with your colleagues about some changes in

13 broadcasting policy in conditions of war?

14 A. Could you please repeat your question once again.

15 Q. Yes, yes. Did you perhaps comment with your colleagues any kind

16 of need to change the broadcasting of news programmes in conditions of

17 war?

18 A. No.

19 Q. Thank you.

20 MS. TAPUSKOVIC: [Interpretation] Your Honours, since the witness

21 has said that she is not familiar with this document, I'm not going to

22 seek to admit the document at this point. Thank you.

23 Q. You said that your first shelter which was under the staircase in

24 the studio radio -- studio building, that you left that shelter on the

25 15th of September. Is that correct?

1 A. No. Firstly, it wasn't a shelter. It was just a basement. And

2 it was the newsroom building, not the studio building, and we didn't leave

3 it on the 15th of September but it was on the 15th of October.

4 Q. After that, you went to a new shelter, to the basement of the

5 Vupik enterprise. Can you please tell us what the Vupik company was, what

6 was their business?

7 A. Vupik had several departments, farming, wine growing, crop

8 growing. Probably had its own shops. I don't know really that much about

9 this company, but these are the things that I know about it.

10 Q. When you entered the Vupik warehouse, what did you find there?

11 A. It was a warehouse that we used as a shelter. It was a large,

12 empty space. I remember that there was wine there. That's all I

13 remember. Wine, water, some kind of mineral water, Donat mineral water.

14 Q. Donat is a brand of mineral water?

15 A. Yes, that is correct.

16 Q. Can you please tell us who told you and who permitted you to move

17 to the Vupik warehouse and to use it as a shelter as well as a place of

18 work.

19 A. After the withdrawal on the 15th of October, first of all we came

20 to the municipal building where Marin Vidic, Bili, was. And my editors,

21 having agreed on that with him first, decided that the most appropriate

22 shelter for us would be this Vucedolska Kapljica, this space owned by

23 Vupik.

24 Q. So the defence staff of Vukovar directly admitted you to this

25 area?

1 A. No. Marin Vidic, Bili, at the time was the commissioner for the

2 municipality of Vukovar. So it was a kind of mayor's post; he was not a

3 military person.

4 Q. Could you please explain why you said "a military person."

5 A. Because you said. I'm sorry, I'm speeding up a little bit.

6 Q. Does that mean that a military person admitted you to Vupik's

7 cellar?

8 A. No. You suggested an answer like that to me.

9 Q. I did not mention any word that could associate with any kind of

10 military person or unit. Could you please tell me who from the

11 municipality, somebody charged by the commissioner, Marin Vidic, or

12 somebody from the Vukovar defence staff that admitted you to the Vupik

13 cellar. Who was it?

14 A. I don't remember who it was. I don't know if anybody was there in

15 that capacity at all.

16 Q. Well, somebody had to give you the key.

17 A. The cellar didn't have a key. You took some steps from the yard

18 down into the cellar. It was an open area.

19 Q. So are you saying that until the 15th of October, nobody of the

20 citizens from Vukovar actually was using that large cellar?

21 A. I don't know whether anybody used the basement until the 15th of

22 October, because I had never been to that basement prior to that. When we

23 arrived on the 15th of October, it was empty.

24 Q. Let us now sum up what you told us twice today. Following your

25 entry into the Vupik basement on the 15th of October, who else came to

1 that basement and when to share that space with you?

2 A. Several days after we entered the basement some people came who,

3 until that time, had been in a shelter in Sajmiste. When Sajmiste fell,

4 people started withdrawing into the centre of town, and thus arrived in

5 our basement.

6 Q. How many people were there; can you tell us?

7 A. Perhaps 80 to 100.

8 Q. So together with you from Croatian Radio Vukovar, how many people

9 were there all together, using that basement?

10 A. As I've told you there were 80 to 100 of them, whereas there

11 were - just a minute - six people working at the radio. That means that

12 it was between 86 and 106 people. Sinisa, Branko, Alenka, myself, and so

13 on. There were six or seven of us.

14 Q. In your statement you said that soldiers also came to you. Can

15 you tell us who were these soldiers who came to visit you.

16 A. I don't remember all of the names. There were some soldiers. I

17 remember some of them who had come to Vukovar from various parts of

18 Croatia to defend the town. I remember one young man who was from the

19 vicinity of Sinj.

20 Q. Members of the 204th Vukovar Battalion also came. Is that right?

21 A. At the time I'm not sure that that unit was in existence.

22 Q. In October?

23 A. I'm not sure.

24 Q. Did they come from Vinkovci and Osijek?

25 A. Nobody came in October. But now that we're discussing the

1 soldiers who occasionally came to the basement, then I'm referring to the

2 young men who would come to Vukovar back in August or September.

3 Q. Since your task was to provide information to the residents, you

4 told us yourself that you acquired information in various ways, by going

5 out to various places.

6 A. Yes. Well, that was still not too dangerous.

7 Q. Then you acquired information via telephone?

8 A. Yes.

9 Q. Then you must have had information of -- about all of the people

10 who came from various places to assist in the defence of Vukovar. What

11 units were there?

12 A. I really don't know what units came to assist in the defence of

13 Vukovar. But I know that they were from various parts of Croatia. I

14 remember that there were people from Dalmacia, from Zagorije, from

15 Dubrovnik. One could tell that based on their pronunciation. However, I

16 don't know their names or the units they belonged to.

17 Q. All right. You mentioned Sinj. How far is Sinj from Vukovar?

18 A. As the crow flies or using highways?

19 Q. Nobody could have flown to Vukovar at that time, so let's say

20 travelling on highways. What was the distance?

21 A. I think that Vukovar-Zagreb is 275 kilometres, and then

22 Zagreb-Sien, perhaps 300. I'm not sure. But around -- more than 500

23 kilometres.

24 Q. So practically people had come from all over Croatia to join the

25 defence of Vukovar?

1 A. Yes. There were people there from various parts of Croatia.

2 Q. You must have had information on the approximate number of such

3 people.

4 A. No, I did not have such information.

5 Q. Thank you. When you told the investigators about Croatian Radio

6 Vukovar and the relations with the staff, you said that you did not have

7 the best of rapport with them. Can you please tell us what were the

8 differences in opinion between you and the defence staff.

9 A. We had very good relations with the commander, Dedakovic, and

10 Branko Borkovic. Initially when the defence was being organised after the

11 events in Borovo Selo, the person in charge was Tomislav Mercep then. And

12 in that initial stage of war, if I can call it that, it took us some time

13 to get accustomed to the situation because none of us from the radio had

14 experienced war and neither did any of these defenders. Perhaps some of

15 the older people had some war experience, but nobody else. So we didn't

16 know how to operate under the circumstances. The war began and we

17 couldn't really find our footing right away.

18 Q. All right. But you didn't tell me what was exactly the difference

19 in the position, that of your radio station and the defence staff.

20 MS. TAPUSKOVIC: [Interpretation] Your Honours, I could give the

21 statement to the witness.

22 THE WITNESS: [Interpretation] I don't need the statement. There

23 was no difference of opinion or position. Simply put, we wanted to

24 acquire information on how the defence was being organised. Naturally the

25 commander refused to give us that information for security of the people

1 in town.

2 MS. TAPUSKOVIC: [Interpretation]

3 Q. You said that you went to get your information in the staff and

4 also at the hospital. Would you please tell me, Mrs. Polovina -- when I

5 say "you," I don't necessarily mean you yourself but employees of Radio

6 Vukovar. Would you please tell me what type of information you received

7 at the hospital.

8 A. The number of the wounded, dead, lack of medication, blood

9 supplies, there were also times when the hospital had been shelled. So

10 that type of information we acquired at the hospital.

11 Q. And then you transmitted this information daily to Zagreb. Is

12 that right?

13 A. Yes.

14 Q. Where did you send it to? To the medical staff? Ministry --

15 Ministry of Health?

16 A. No. We had contacts with -- or rather, we sent our reports solely

17 to the media.

18 Q. Your reports -- then somebody in Zagreb refused to publicly

19 publish or announce your reports. Is that right?

20 A. Some of the reports, yes.

21 Q. When you mentioned the arrival of Vesna Bosanac and Bili to the

22 Vupik basement, you also said that several employees of the post office

23 brought in some equipment. Is that right?

24 A. Yes.

25 Q. You said that there was an amplifier there or some other type of

1 equipment, a loud-speaker or an amplifier. That's what you said. That's

2 what's recorded in the transcript. Would you please tell us with greater

3 degree of accuracy what equipment was brought in from the post office.

4 A. I don't know. I don't remember, and I'm not really very

5 knowledgeable when it comes to equipment.

6 Q. You said at the beginning of your testimony that you would

7 frequently come to Croatian Radio Vukovar to help your husband, who was a

8 technician.

9 A. Yes. You mean while I wasn't employed there? Yes, I used to come

10 then.

11 Q. All right. So after being a journalist and a reporter for so many

12 years, you still don't know what an amplifier or a loud-speaker is?

13 A. I know what those things are, but I don't know whether lads from

14 the post office had that type of equipment. All I know is they got the

15 telephone connection up and running. I don't know how they did it.

16 Q. All right. Thank you. Can you tell us why was the link with

17 Zagreb established from the Vupik basement and not from the building of

18 the post office? Was it because the defence staff had been relocated to

19 the Vupik basement?

20 A. At that time there was nobody from the defence staff there. They

21 had left the city. Our basement, the Vupik basement, was very near the

22 staff premises. And I think that this was the closest spot or the most

23 logical location for establishing the telephone connection.

24 Q. Are you telling us that the entire staff had left the city,

25 attempting to break through?

1 A. I don't know what you mean when you say "the entire staff." The

2 people who were there in that location, commander and people around him.

3 They were the people who had left the premises of the staff.

4 Q. All right. Thank you. Can you know for a fact that it was

5 impossible to establish telephone link with Zagreb from the post office

6 building?

7 A. I'm not hundred per cent sure.

8 Q. It's right, isn't it, that there was just one telephone in Vukovar

9 during the last days or the the last two weeks before the fall of town?

10 A. Yes. Based on the information I had at the time, yes. I was told

11 that there was just one telephone in town.

12 Q. Do you know that Marin Vidic, Bili, stated that pursuant to his

13 order on the 1st of November, all telephone lines in Vukovar were

14 disconnected, leaving just one telephone operational?

15 A. I don't remember that.

16 Q. Tell us then: Where was this single telephone located in Vukovar?

17 A. At that moment, while we were in the basement when the young men

18 from the post office came, that was the telephone that was operational.

19 Q. Thank you. Could you please describe to us the dimensions of the

20 Vupik basement. How big were the barrels?

21 A. I don't remember there being any barrels. I remember wine

22 bottles.

23 Q. Can you define in any way the space of that basement?

24 A. I think it was a bit smaller than this room, if we're talking

25 about square metres; however, it wasn't the same shape.

1 Q. You are now referring to this courtroom, Courtroom III?

2 A. Yes.

3 Q. Tell me, please, do you know how many times you or any of your

4 colleagues met with Dr. Bosanac?

5 A. I met her very rarely. I seldom went to the hospital or, for that

6 matter, left the basement to go anywhere, whereas my colleagues were in

7 contact with her more frequently.

8 Q. Was your colleague Vesna Vukovic among them?

9 A. Yes.

10 Q. Do you know on what occasion or for what reasons she met Vesna

11 Bosanac? Did she tell you what she had talked about with her?

12 A. She went there as a journalist to acquire information about the

13 situation at the hospital.

14 Q. Thank you. You said that Sajmiste at one point in time during the

15 siege fell?

16 A. Yes.

17 Q. Can you say how many residents lived in that part of Vukovar?

18 A. No, I can't. Maybe I could tell you what my assessment is.

19 Q. What would you say about 2.000 residents under siege? If you

20 know, that's fine.

21 A. That sounds reasonable. It certainly wasn't 100.000. It could

22 have been 2.000, easily.

23 Q. The people who reached the Vupik shelter from Sajmiste, did those

24 people tell you why they were now moving to your shelter?

25 A. Yes. They said that the defence lines at Sajmiste had been

1 pierced, that the Serbs were entering houses and people just fled back

2 towards the centre where they felt they might be safer.

3 Q. Your job was to keep the citizens informed, wasn't it? You knew

4 at any point in time who controlled which area of Vukovar, did you not?

5 A. This was by no means always the case. Sometimes we ourselves

6 didn't have the right information.

7 Q. What about the MUP and ZNG forces in Vukovar, did they control the

8 area known as Petrova Gora also?

9 A. I don't know. I don't know.

10 MS. TAPUSKOVIC: [Interpretation] Your Honours, I have two or three

11 questions left before I close and complete my cross-examination.

12 Q. Madam, you know about the daily paper, Glas Slavonije?

13 A. Yes.

14 Q. Do you know who the owner is of that particular publication?

15 A. No.

16 Q. Two or three days before your testimony, I surfed their web site.

17 On the 26th of November on their web site, they published a list of all

18 hospital employees during the siege, including all the help workers,

19 including the people who helped with the logistics. When it comes to

20 liaison and coordination, the names given are you, your husband, the late

21 Sinisa Glavasevic, and Vesna Vukovic. Vesna Bosanac expresses her

22 gratitude to you all for the assistance that you extended.

23 Would I be wrong in concluding that both you and your Croatian

24 Radio Vukovar [as interpreted] were placed directly at the disposal of the

25 hospital in order to disguise the presence of ZNG members and all the

1 paramilitaries who were there in the hospital in Vukovar just before the

2 fall?

3 A. I find your sentence a trifle too lengthy, perhaps. If you could

4 please repeat your question.

5 You said: Would I be wrong -- well, you are suggesting that my

6 colleagues and myself from Radio Vukovar were placed at the disposal of

7 the -- the sentence was a bit long, but if I can sum it up. Yes, you are

8 wrong.

9 Q. What about your -- the work and services in terms of providing

10 information. Did you offer your services to the hospital, which on the

11 eve of Vukovar's fall had been hiding ZNG members and paramilitaries,

12 soldiers, such as members of the 2004th [as interpreted] Vukovar Battalion

13 and ZNG units?

14 A. We did enjoy the hospital's support ourselves. Likewise, we

15 returned this support to the hospital by sending messages out to Zagreb

16 and to the world at large about everything that was going on in the

17 Vukovar Hospital. As for the latter part of your sentence, well, I

18 wouldn't know about that.

19 Q. But Zagreb refused to receive your information.

20 A. That was indeed the case at one point in time.

21 Q. My last question is in relation to the moment at which you were

22 leaving the shelter. There was still lots of civilians remaining in

23 Vukovar, weren't there, on the 18th?

24 A. Yes.

25 Q. Why then did the entire Radio Vukovar team decided to try to

1 escape? Was there a reason for you to attempt to escape?

2 A. We knew that the town had fallen on the 18th of November. We were

3 scared of what might befall us. There weren't too many options open to

4 us, but one of them was to try and escape. So this was an option that was

5 discussed.

6 Q. So much like the staff members several days before, the entire

7 team of Radio Vukovar decided to break through the siege and escape

8 Vukovar. Wasn't that the case?

9 A. Those from the staff had gone on before us, the day before, and we

10 decided to give it a thought, too.

11 MS. TAPUSKOVIC: [Interpretation] Your Honours, this concludes my

12 cross-examination. I have no further questions for this witness.

13 JUDGE PARKER: Thank you very much.

14 Obviously that now is the time when we need to adjourn for the

15 day.

16 Mr. Moore.

17 MR. MOORE: I'm terribly sorry. Your Honour, there is an

18 important administrative matter that we have to deal with tomorrow

19 morning. We have not made any application before for a delay in the

20 trial. I wonder if it would be possible if we could start or commence

21 tomorrow morning at 10.00, as opposed to 9.00.

22 JUDGE PARKER: It happens, Mr. Moore, that that would also suit

23 the convenience of the Chamber. So you needn't argue too long.

24 MR. MOORE: Thank you very much.

25 JUDGE PARKER: In fact, it would be even more convenient

1 at 10.15.

2 MR. MOORE: Thank you very much.

3 JUDGE PARKER: So you've relieved me of a problem about tomorrow

4 morning as well.

5 MR. MOORE: Thank you.

6 JUDGE PARKER: Thank you.

7 In view of that, we will resume tomorrow morning at 10.15 rather

8 than 9.00.

9 Thank you. We will now adjourn.

10 --- Whereupon the hearing adjourned at 1.49 p.m.,

11 to be reconvened on Thursday, the 1st day of

12 December, 2005, at 10.15 a.m.

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