1 Wednesday, 15 May 2002

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 9.03 a.m.

6 JUDGE SCHOMBURG: Please be seated. Good morning, everybody.

7 Good morning for Dr. Cehajic. We may continue immediately. Please take

8 the floor.

9 Sometimes it's better to know in which case we are, so it should

10 be called. Thank you.

11 THE REGISTRAR: Case Number IT-97-24-T, the Prosecutor versus

12 Milomir Stakic.

13 JUDGE SCHOMBURG: And the appearances.

14 MR. KOUMJIAN: Nicholas Koumjian with Ann Sutherland, assisted by

15 Ruth Karper, case manager, for the Prosecution.

16 MR. LUKIC: Good morning, Your Honours. Branko Lukic, John

17 Ostojic and Mr. Danilo Cirkovic for the Defence.

18 JUDGE SCHOMBURG: Thank you. Now we can really start.

19 WITNESS: MINKA CEHAJIC [Resumed]

20 [Witness answered through interpreter]

21 MS. SUTHERLAND: Thank you, Your Honour. Could the usher please

22 move the ELMO machine a little to the left, please.

23 Examined by Ms. Sutherland: [Continued]

24 Q. Doctor, before we broke yesterday, we were talking about staff at

25 the hospital. Can you tell me how many staff were there, approximately?

1 A. Before these events, I believe that there were between 550 and 580

2 employees.

3 Q. Of that number, approximately what percentage were of Bosniak

4 ethnicity?

5 A. At this moment, I don't think I'm able to tell you what the exact

6 percentage was. My best estimate would be 40 per cent, 30 to 40 per

7 cent. I do not know the exact data.

8 Q. And approximately how many per cent would have been of Croat

9 ethnicity?

10 A. A small percentage, because there were not more than 16 per cent

11 of Croats living in Prijedor. So the percentage of Croats employed at the

12 hospital was not as significant.

13 Q. Is it safe to say that the remaining percentage were persons of

14 Serb ethnicity?

15 A. Yes, and others who declare themselves as members of some other

16 ethnic community.

17 Q. Of the number of persons that you have said worked at the Prijedor

18 hospital, do you know approximately how many persons of Bosniak ethnicity

19 were doctors or professional staff?

20 A. I don't know that either, I'm afraid, this other percentage, but

21 in view of the overall composition, in any case, it would be a smaller

22 number than the Serb ethnicity.

23 MS. SUTHERLAND: Could the witness please be shown Prosecution

24 Exhibit -- it was numbered 465 in the Rule 65 ter exhibit list.

25 Q. Doctor, could you please read the title of the document.

1 A. "General Hospital, Prijedor. List of employees whose employment

2 has been terminated." Do you want me to continue?

3 Q. How many names appear on that list?

4 A. 114.

5 Q. Can you please tell me the signature block at the bottom of the

6 document?

7 A. "Director of the hospital, Dr. Radojka Elenkov, specialist of

8 internal medicine."

9 Q. Next to each name, a date appears. Is that correct?

10 A. Yes.

11 Q. Can you please peruse that list and tell me from your knowledge

12 those persons that you believe are of Croat ethnicity.

13 A. Topic, Jelena, listed under number 11. Karacic, Dr. Mario, listed

14 under number 20. 22, Grozdanic, Josipa, I think. I'm not sure.

15 Q. I'm sorry, before you go on, can you just tell me, Jelena Topic at

16 number 11, do you know what her occupation was?

17 A. She was a nurse, a head nurse in the psychiatry department.

18 Q. And number 20, Dr. Mario Karacic?

19 A. He was a doctor, a surgeon.

20 Q. And number 22, Josipa Grozdanic?

21 A. I'm not sure about her. I don't know what her occupation was.

22 Q. Can you continue?

23 A. Dr. Sikora, Zeljko, a Croat, number 47.

24 Q. Was that the doctor that you mentioned yesterday as an internist?

25 A. No, no. He was an intern undergoing specialisation at the

1 gynecology department. I may have mentioned him having been at the police

2 station together with my husband. I think I said that my husband told me

3 that he was there as well.

4 Juric, Ana.

5 Q. Is she listed at 103?

6 A. Yes, number 103.

7 Q. And where did she work?

8 A. She was an administrative assistant. She worked in an office.

9 Zec Dubravka, 111.

10 Q. And her occupation?

11 A. She was a biochemist. She worked at the laboratory. This is so

12 far as this list is concerned. There may be other persons whose ethnic

13 background I am not aware of.

14 Q. On that list, can you give me the number of any person of Serb

15 ethnicity?

16 A. Number 19, for instance, Dr. Risto Stojanovski. He's a

17 Macedonian, probably an orthodox by religion.

18 Q. What department did he work in?

19 A. I think at the time he was away on specialisation, but I'm not

20 sure. I know that he was not at the hospital at that time. He was

21 undergoing some sort of training outside our institution.

22 Q. Do any Serb -- persons of Serb ethnicity appear on the list that

23 you know of?

24 A. 38, Nukic Slavica. I know her, but she is married to a Muslim.

25 She is a Serb but married to a Muslim.

1 Q. What department did she work in?

2 A. She worked at the laboratory. She was a lab worker.

3 Listed under number 50, there's Vukotic Dzusanka. She could be

4 Serb, but I don't know her. Judging by her name, she may be a Serb.

5 Q. Do you know the person listed at number 98?

6 A. Yes. Dr. Zoran Vikalo.

7 Q. What is his ethnicity?

8 A. I think he's a Serb.

9 Q. What department did he work in?

10 A. He was also away undergoing specialisation.

11 Q. The person listed at number 85, do you know that person's

12 ethnicity?

13 A. 85, I didn't notice Emilija Jordan, but I think she is a Ukrainian

14 of Catholic religion. She worked in the kitchen.

15 Q. The other names that appear on the list, are they persons of

16 Bosniak ethnicity?

17 A. I am certain with respect to the majority of these people, but in

18 respect of some of them, I'm not quite sure. There was another individual

19 whom I saw on the list, but I don't know what his ethnic background is, so

20 I wouldn't discuss him.

21 Q. From that list, how many persons are there that you know of that

22 are deceased or missing, and can you please list their name and number and

23 their occupation?

24 A. Kadiric Ratib, under number 1, he was an ambulance driver. He

25 drove the hospital ambulance. I'm sure that he is missing. I know this

1 from his family. And I also know that he's listed in the book of missing

2 persons.

3 Q. Did you speak with members of his family?

4 A. Yes, with some of them. Not with his wife, but with his relatives

5 who know that he is missing, that he disappeared.

6 Q. If you can go to the next name but state the number first, and

7 then the name, please.

8 A. 11 -- I'm sorry, no, 12: Turkanovic, Fikret, under number 12.

9 Q. What was his occupation?

10 A. He was an engineer, and he was with the technical department. He

11 was actually the head of the technical department of the hospital.

12 Q. How have you come to know whether he's deceased or missing?

13 A. From his relatives, and also from the book of missing persons.

14 Q. I'm sorry, just in relation to numbers 1 and 12 that you've

15 mentioned, were you told when they died or when they went missing?

16 A. I didn't specifically gather this type of information. I just

17 learned whether they are alive or not, but what actually happened, when

18 they died or when they went missing, I don't know.

19 Q. Can you continue, please.

20 A. Number 43, Hamulic, Razim. He was a medical technician working at

21 the surgery department. He's no longer amongst the living. His wife is

22 working at the same institution where I am currently working. She is an

23 assistant, dentist assistant, and she was the one who told me her husband

24 disappeared.

25 Q. Please continue.

1 A. 46, Dr. Esad Sadikovic. He was an ear, nose, throat doctor; he

2 was the head of the department. And I saw in the book of the missing

3 persons that he is missing. I have never met any of his relatives, so I

4 was unable to hear anything from his family.

5 Q. Please continue.

6 A. Number 47, Dr. Zeljko Sikora. As I already said, he was

7 undergoing specialisation at the gynecology department. His name can also

8 be found in the book of missing persons, and at the time I was living --

9 while I was in Zagreb, 1994, I saw his mother on several occasions. She

10 was hoping that he was alive, but he hasn't turned up since.

11 Q. Please continue.

12 A. 55, Adnan Ekinovic. He was an x-ray machine technician, senior

13 technician, with the diagnostics department. He has been found, that is,

14 his body has been found in the Hrastova Glavica mass grave near Sanski

15 Most.

16 Q. Please continue.

17 A. 56, Islam Bahonjic, also an x-ray machine technician with the

18 diagnostics department. When I went to the identification procedure, I

19 saw his documents also at Hrastova Glavica.

20 Q. Please continue.

21 A. I don't know about others. In respect of some of them, I'm sure

22 that they are alive, but in respect of others, I'm not sure. I couldn't

23 tell you anything else about this.

24 Q. Do you know the names of other people not on that list that you

25 know are either deceased or missing? And can you please tell me their

1 names, what their occupation was, and how you know that they are either

2 deceased or missing?

3 A. I know about my colleagues, because I inquired with other doctors,

4 so I know who is missing. I have already mentioned Dr. Esad Sadikovic,

5 Dr. Sikora, Dr. Osman Mahmuljin, an internal medicine specialist. And

6 Doctor -- and a psychiatrist, Dr. Rasim Music, and a surgeon, Dr. Begic.

7 Q. I'm sorry, if I can just interrupt you. How do you know that

8 Dr. Osman Mahmuljin, the internal medicine specialist, how do you know he

9 is either deceased or missing?

10 A. His name can be found in the book of the missing persons.

11 Q. And Dr. Rasim Music?

12 A. As for Dr. Rasim Music, I have had contact with his family. He

13 has two brothers who are alive, so they told me about him. And his name

14 can also be found in this book. As for Dr. Begic, I only saw his name in

15 the book of missing persons. I didn't have an opportunity to inquire

16 about him with his family. Dr. Jusuf Pasic, also in the book of missing

17 persons. Dr. Suljanovic also in the book of missing persons.

18 Q. Excuse me. Sorry, also in relation to Dr. Jusuf Pasic, where did

19 he work?

20 A. He worked in Kozarac. I don't remember exactly how old he was.

21 He was probably born in 1935 or thereabouts. When he started working in

22 Kozarac, I was still not a physician. I have known him personally for a

23 very long time as a physician who worked in Kozarac. He never left

24 Kozarac. I believe that he spent his entire career in Kozarac.

25 Q. Did you speak with anyone in relation to him?

1 A. No, I did not. He has a wife and two children, but they no longer

2 live in the same area as I do. I didn't have an opportunity to speak

3 about him with his family.

4 Q. Where did Dr. Suljanovic work, what department?

5 A. He worked in various surgeries in Prijedor. I do not know, but I

6 think in the town of Prijedor. I do not know exactly in which one.

7 Q. Please continue of other names of persons that were colleagues of

8 yours from the hospital or Mladen Stojanovic Medical Centre that you know

9 are deceased or missing?

10 A. I think that I have mentioned those that I knew, and I think that

11 I have mentioned them all.

12 Q. Do you know a Dr. Kemal Ceric?

13 A. Yes, I forgot to say Kemal, Dr. Kemal Ceric. I forget to mention

14 him when I was talking about the doctors, and Seric Nedzad, who was the

15 president of the court in Prijedor, Nedzad Seric.

16 Q. In what department did Kemal Ceric work?

17 A. He was a microbiologist, and he worked in the lab of microbiology.

18 Q. How do you know that he is deceased or missing?

19 A. I spoke with his wife. I met her after the war, and she told me

20 that he was missing.

21 Q. You also mentioned Nedzad Seric, the president of the court in

22 Prijedor. How did you come to know of his fate?

23 A. I also heard, and also from that book, it was listed there as a

24 missing person. And I think in 1990 or 1993, I met his wife in Zagreb,

25 and she was alone there and she told me that her husband was missing.

1 Q. Do you know the names of any other persons that are either

2 deceased or missing from Prijedor town that you know of from speaking to

3 family members?

4 A. My neighbour. He has been my neighbour, Mehmedagic, who was a

5 lawyer, and he was a public defence lawyer, and a very dear person to me.

6 And I think that he was very nice and generous person, and that he did his

7 work in a very correct way in Prijedor, and people liked him a lot. And

8 this is how I know from the book of the missing persons and what I heard

9 from his wife who worked in the same hospital where I worked. She was a

10 head nurse in the surgery department. Mehmedagic, Fatima is her name.

11 Q. Do you know of any others?

12 A. There have been many, but maybe I should mention the husband of my

13 sister, Kapetanovic, Mehmedalija. He was a professor. He had an MA in

14 the biological sciences. Before the war, he had been a director what in

15 Prijedor was called the "old hotel." It was the catering company. He was

16 the director there before all the war events.

17 Q. We will move on to another topic. In 1992, was any of your

18 property taken?

19 A. Yes. They -- first they took my car. Some soldiers came to the

20 house and they told me that I had to give the car to be used by the army.

21 This was already in the first days, maybe in June, the beginning of June.

22 At the very beginning, they took my car away.

23 Q. Did they give you a receipt?

24 A. No, they didn't. They didn't give me any receipt, and I had

25 problems afterwards because of that, because I thought that that was the

1 way to maltreat me later on. Because they would come and ask for the car.

2 Because they had come several times to ask for the car, and when I said

3 that I didn't have the car, that I had given it away, then asked for the

4 receipt. And when I told them I didn't have any receipt because I hadn't

5 been given one, they were sending me to the military barracks to ask for

6 the receipt, in order to be able to show it to them. And of course, I

7 couldn't go there because I wasn't sure if I went -- had gone there, if I

8 would ever return home. And that's why I waited for them to come without

9 the receipt. I waited for those people who came for the car.

10 Q. Was your home ever searched?

11 A. Yes, they did search it once, an official search, so to say.

12 There were quite a few people. They were all dressed in military

13 uniforms. They were policemen. There were several of them, and they

14 searched the whole house. And they did not take anything from the house

15 of my personal things at that moment, but they took all the documents that

16 were there of my husband. He didn't even take -- he hadn't taken his ID

17 with him. He didn't remember it. So all his documents were taken by

18 these people, and all the photographs, my family photographs, so that all

19 the pictures were taken from me. I asked them to leave the pictures of my

20 children, that these were something for me to remember. But they didn't

21 want to listen to me. They took everything. It was a sack of -- a bag of

22 photographs. I had to give them the pictures, the photographs when my

23 daughter graduated. So maybe it is not a big thing, not a very important

24 thing in life, but for me, a part of my life has been erased because I

25 don't have a photograph of my child when he was small. So this whole -- a

1 whole part of my life was erased. This was a very difficult situation for

2 me. I want to apologise because I'm crying, because you cannot compare

3 this with what has happened, but this is also something that is important

4 to many people, as it is important to me also.

5 Q. Were you given any reasons as to why they were searching your

6 apartment?

7 A. No, they didn't give me any reasons. They didn't tell me why they

8 were searching the house. I didn't know what they were looking for. They

9 did not find anything, actually. And neither had they taken anything at

10 that moment from my house.

11 Q. Approximately how many persons were there present conducting the

12 search of your house?

13 A. There were several, but I know that in each room, there was one

14 person, and that was about six or seven rooms which they had searched.

15 And in each of these rooms there were some walking around in the hall,

16 some were outdoors. So there was quite a number of people who were there.

17 Q. You mentioned policemen and soldiers. How were the policemen

18 dressed?

19 A. In the police uniform which was actually -- it was a blue uniform,

20 and on their arms, they had the signs of policemen. And the soldiers had

21 uniforms, not camouflage uniforms, just the regular ones. I don't

22 remember having seen any special signs. Maybe I didn't notice them.

23 Q. Did you recognise any of these people?

24 A. Some of those who I thought was a supervisor, he was a policeman.

25 I don't know his name, but I knew him. He had been a policeman before,

1 and then he was retired. And on that occasion, he had a police uniform

2 on.

3 Q. Were you mistreated during the search?

4 A. Not much. Some insults, that person -- that particular person

5 told me, "What did you need that for, doctor, because you were the first

6 lady of Prijedor? Why did you do that?" And I asked myself: What had

7 I done? What was I accused of? And he was quiet for a while, and he

8 said: "In the hospital, you cursed a Serb mother to the nurses." And I

9 said: "No, I had never cursed because I was brought up in the family

10 where there was no cursing, and I have never cursed, let alone somebody's

11 Serbian mother. I wouldn't do that." He didn't comment any longer. And

12 there were some other details. They asked me some questions, but they

13 were not the things that should be mentioned. I think they were

14 irrelevant -- they are irrelevant.

15 Q. Was your home searched on other occasions?

16 A. Yes, they did come several times, but they didn't search the house

17 but my garage, which the first time they had come, they saw what I had.

18 So they looked for the following: They looked for the boat, motor boat.

19 But I think they had an intention to treat me in a bad way rather than to

20 take some things. And every time they came to the house, there were three

21 or four of them. On one occasion, even five. And then I would take the

22 key and I would go to the garage, because it was far away from the house

23 because you have to pass two buildings in order to get to the garage. And

24 I thought that they enjoyed the fact that I was ahead of him and that

25 people were watching because some people were watching from the windows

1 how I went in front of them to the -- to my garage. And then they would

2 take what they wanted to or they didn't take what they didn't find, and

3 this was some kind of a parade through that part of the city, of the town.

4 Q. Were these people soldiers?

5 A. Yes, they were. They were -- every time, they were in military

6 uniforms.

7 Q. Did they take anything from the garage?

8 A. Yes. On the second occasion, they took the boat and the engine of

9 the boat, maybe some smaller things. I never checked. Because they asked

10 for the engine, a motorbike of my son, but it was not there because I had

11 given it to a neighbour. Immediately after they had come for the first

12 time, I gave it to my neighbour, so they didn't find the motorbike but

13 they were asking for it.

14 Q. What was the ethnicity of your neighbour that you gave the

15 motorbike to?

16 A. He was a Serb.

17 Q. I want to move to another topic now. Did you attempt to speak to

18 anyone in authority about your husband being detained in a camp?

19 A. Yes, I did try, but I couldn't get to anyone. I tried to reach

20 Dr. Kovacevic, and I thought that I was close to him. But at that moment,

21 it didn't mean much. But I did have a feeling that I could find some

22 understanding in him, but I wasn't able to get to him.

23 I tried to reach him by telephone twice. Once, I went there. I

24 went to the municipal building, but I could not reach them. So this

25 attempt to reach this person or someone else was not successful.

1 Q. Can you just pause there, please.

2 [Prosecution counsel confer]

3 MS. SUTHERLAND:

4 Q. Do you recall between what time period this was?

5 A. It could have been at the beginning of June when I tried and when

6 I still thought something could be done. Later on, I was not even trying

7 any more.

8 Q. When you said that you tried to reach "them," and you mentioned

9 Dr. Kovacevic, who else were you trying to contact?

10 A. I thought that I would contact Kovacevic and Dr. Stakic, because I

11 thought that they were his co-workers at some point, and if I came, that I

12 could reach Dr. Stakic also and ask him where my husband was. This, I

13 thought, would be the most normal thing if I could come and ask whether I

14 could do something. But of course, I was not able to do that, and I

15 didn't do it.

16 Q. When you said that you attempted to reach them by telephone twice,

17 do you recall what was -- who did you speak to when you telephoned?

18 A. The first time when I called, a secretary responded, and she said

19 that they were not there. And since I hadn't expected, of course, they

20 are not there, I thought neither of the two of them was there. So that

21 telephone conversation ended in this way.

22 Q. Excuse me.

23 A. On the second occasion when I --

24 Q. Excuse me. On that first occasion when you spoke to the

25 secretary, did she tell you where they were?

1 A. I asked her where they were, where I could find them, and she said

2 that they were in the Crisis Staff and that I couldn't reach them.

3 Q. On the second occasion, can you please tell the Court --

4 A. She also told me that they were not there, and she -- that's what

5 she told me, that she didn't know whether they would be there, something

6 in that direction. So I didn't even try to call by telephone again

7 because I knew that she would always tell me that they weren't there if

8 they didn't want to let me come.

9 Q. I think you also said that you went to the municipal building on

10 one occasion. Is that correct?

11 A. Yes, it is correct. They said that they received the pay at the

12 municipality, and my husband had this decision that he was on the annual

13 leave and that that was the pay for that time. So I went to the municipal

14 building to ask for the pay, not that I needed it, but in order for it to

15 be a way to enter the municipal building if anybody asked me why I

16 was -- why I had come. So I did enter the building, and in the hall, I

17 came across Marija Mutic. She was an economist working in the

18 municipality. I had known her for a long time. She was the best person

19 of my sister at the wedding, and she greeted me. I told her why I was

20 there. She said: "Don't go there. I shall go to the cashier." And when

21 she came back, it was very difficult for her to tell me, but she said I

22 wasn't able to get my husband's salary because whoever was in a camp was

23 not allowed to receive his salary. This is what they had said. And then

24 I asked if -- when I asked for Stakic and Kovacevic, she said they were

25 not there, so I returned without having succeeded in anything.

1 Q. Your husband was the president of the Municipal Assembly, which

2 was the highest organ in the municipality, was it not?

3 A. Yes, he was.

4 Q. After your husband lost his job, do you know who took over as the

5 highest authority in the Prijedor municipality?

6 A. Dr. Milomir Stakic.

7 Q. I now want to move to another topic. Were you in 1992 taken for

8 questioning?

9 A. Yes, they did take me for questioning. On the 11th of June, they

10 came to my house to pick me up. There were three men, and they told me

11 that I had to go for the questioning.

12 Q. How were they dressed?

13 A. One of them, I didn't recognise him. I asked him on the way back

14 what his name was. He said that he was a Montenegrin, Tajson. He had a

15 T-shirt and trousers. The driver who drove us and the other person had

16 some military uniforms on. I don't think they were marked with any

17 special signs. The third person, I did not know, and who was left in my

18 house when I had been taken. And the person who drove, the driver, I did

19 know him. He was a boy from Prijedor. He was of the same age as my

20 daughter, so I did know him, although he didn't say anything to me at

21 all.

22 Q. What was his name?

23 A. His name was Pekija Drasko. He was the son of Pekija Petar, who

24 used to work in the x-ray laboratory and who had been retired. When I

25 started working as a young doctor, he already worked there as an x-ray

1 technician.

2 Q. Were these men armed?

3 A. The didn't have rifles. They had guns, but they didn't have any

4 rifles.

5 Q. Where were you taken?

6 A. My sister and I, because she was at my house, they took us both,

7 and they drove us from Prijedor to -- this is Urije, is a part -- or a

8 part of Prijedor, to the military barracks, which was in that part of the

9 town. And I left the car with this person whose name was Tajson and took

10 me throughout the barracks, both floors, which were both full of soldiers.

11 They looked at me, but I was so scared that I couldn't even look. But

12 they were watching us, and they didn't do anything. They just took me

13 around, and we came back. He put me again into the car and drove me to

14 the place where I was supposed to arrive, in some premises on the road to

15 Banja Luka.

16 Q. How long did you stay at the army barracks --

17 A. I'm sorry, in Keraterm.

18 It was around 15 minutes. He took me on both sides, and he was,

19 like, looking for something. But he didn't say anything to anyone. And I

20 concluded that he was not supposed to bring me there at all, but he only

21 wanted to show me to those soldiers how he took the wife of the president

22 of the municipality, or a doctor, how he was taking me around. Maybe it

23 meant something to him. I don't know.

24 Q. You said that you were taken to some premises on the road to Banja

25 Luka.

1 A. Yes. Those premises...

2 Q. Continue.

3 A. Those premises were -- was some administrative building of

4 Keraterm which was on the right side of the road on the way to Banja

5 Luka. And on the other side of that building, there was the Keraterm

6 buildings and premises where the detainees were. I was not on that side.

7 I was on the other side.

8 Q. On the right-hand side of the road as you leave Prijedor, heading

9 towards Kozarac, Banja Luka?

10 A. Yes, that's correct.

11 Q. Where were you taken when you arrived at this building?

12 A. To the first floor of that building. It was a long corridor and

13 there were some people there, not many, but there were some people there.

14 Q. Did you recognise anybody?

15 A. Maybe there were other people which were familiar, but when I

16 turned around, I recognised a man who -- maybe I wouldn't have recognised

17 him, but he had some wounds on his face and on his nose, and there was

18 some band-aid on his nose. But I still recognised him. It was Medunjanin

19 Becir. He was a military administrator in Prijedor before those events,

20 and I was afraid that maybe they had brought me because of him. I was

21 afraid because of him, although I didn't know him very well. I maybe had

22 seen him two or three times. I knew that -- I knew of him. I knew that

23 he existed, but I didn't have any connection with him whatsoever. But I

24 was afraid because this was just an accident that we were both there.

25 Q. You mentioned that he had a bandage on his face. What was -- in

1 your opinion, what was his condition?

2 A. Yes, he did have some bandage, and you can tell that everything

3 was blue and swollen, the bandage and some cotton on his nose.

4 Q. Did you or your sister recognise anybody else?

5 A. No, I didn't. I didn't recognise anyone else.

6 Q. Did your sister?

7 A. No, she didn't tell me about having met anyone whom she knew.

8 Q. Where were you taken?

9 A. There were several rooms in this corridor and I could see people

10 waiting in these rooms. I figured that those were interrogation rooms.

11 And the one that I entered was a very simple room, with a desk and a chair

12 in it. That was the room where I was interrogated.

13 Q. Did you know who was interrogating you?

14 A. No, I did not. I saw two persons, two interrogators whom I knew,

15 in the corridor. But the one who interrogated me, no, I didn't know him.

16 Q. How long did the interrogation last?

17 A. It lasted from sometime just before noon until the evening hours,

18 just before the curfew.

19 Q. What were you questioned about?

20 A. My feeling was that the interrogator himself didn't know what he

21 was accusing me of, and it all boiled down to my having to say where the

22 wife of Dr. Mujadzic was, Dr. Mirza Mujadzic's wife, who was the president

23 of the SDA, and his wife was no longer in Prijedor. Among other things,

24 he also me whether I knew anything about what my husband did, where he

25 held meetings, what he had been preparing, and things like that. But the

1 interrogation itself wasn't very insistent, neither concerning myself nor

2 my husband. He just kept asking general questions as to who I was, but I

3 could tell that he knew quite a lot. He also inquired about whether I had

4 been a member of the communist league, whether I was still -- whether I

5 was a member of any political party at the time. I said I was not. And I

6 told him about my reasons why I was not a member of any political party,

7 why I had been a member of the communist party, and so on and so forth.

8 But he was not unpleasant and I think that, altogether, he treated me in a

9 humane way. He asked me a number of questions. He didn't -- he was not

10 accusing me of anything. Generally speaking, he was not unpleasant. I

11 wish I knew his name. I wish I knew a name of the person who, despite his

12 capacity, was not inhuman in his treatment of me.

13 Q. Were you made to sign a statement?

14 A. Yes, I was. What he kept telling me was that if I didn't say

15 anything about my husband, that I would remain there until I did so. And

16 then I told him then it means that I will remain here forever because I

17 have nothing to say about him. At one point in time, he cut the

18 conversation short, and he said: "You better sign this document." And I

19 said I didn't know where Mirza Mujadzic's wife was. I didn't know

20 anything about her. I never socialised with her, nor was she ever my

21 friend. So I signed it.

22 [Prosecution counsel confer]

23 MS. SUTHERLAND:

24 Q. You mentioned earlier Becir Medunjanin, and you said that he was a

25 military administrator. Do you know what his exact position was prior to

1 the war?

2 A. Yes. He had some sort of a function. I believe the title was

3 called an officer in charge of military affairs with the Department of the

4 Interior of the town of Prijedor, the Department of the Ministry of the

5 Interior of the town of Prijedor. He may have been some sort of a chief.

6 He was the number one in this department.

7 Q. Was this to do with the Territorial Defence of the municipality of

8 Prijedor?

9 A. Yes, yes.

10 Q. What happened after your interrogation?

11 A. My sister was afraid for me, and she told me that a group of

12 soldiers had passed and climbed up the stairs. They appeared to have some

13 knuckle dusters on their hands. She said they were metal and pointed.

14 They ran into the room where Medunjanin was, whereas the interrogator who

15 was there had left the office in the meantime to have some rest because my

16 interrogator also would leave the office from time to time, and I would

17 remain there alone. So she was very afraid when they entered the office,

18 but they eventually came out of this office. The interrogator appeared

19 after a while and he said that he could no longer conduct the

20 interrogation because the man was unconscious.

21 All of the people who were in the corridor were then taken

22 downstairs, including my sister, but this is something that I was not

23 aware of because I was inside. So I didn't experience this kind of fear.

24 My sister told me that she was afraid that the group of soldiers would

25 enter the office where I was, but nothing of the sort happened, and we

1

2

3

4

5

6

7

8

9

10

11

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

13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

1 returned home.

2 Q. Did you report to work after your holiday leave had expired?

3 A. Yes, I did. I tried to call to see what would happen with me. I

4 was very much afraid at the time. I didn't feel like going to work, but

5 if I had to, of course, I was ready to go to work. So I called them up

6 and told them that my leave was coming to an end, and I asked them what to

7 do. I called a person by the name of Radojka who at the time was the

8 manager of the hospital department, the administrative manager of the

9 hospital, and I told her what was happening. I told her that my leave was

10 coming to an end and she said: "Well, you're not on leave. You have --

11 you are on the waiting list." And I said: "Well, what am I supposed to

12 do? Shall I report later on?" And she said: "No, there's no need for

13 you to report. If we need you, I will give you a call." And that was

14 that. That was the end of our conversation. I never contacted her again,

15 nor did I ever heard of her later on -- hear of her later on.

16 Q. Doctor, this person that you spoke to by the name of Radojka, is

17 this Dr. Elenkov --

18 A. Yes, yes. Dr. Radojka Elenkov.

19 Q. [Previous translation continues]... at the bottom of the document

20 that you were shown?

21 A. Yes, yes.

22 MS. SUTHERLAND: Your Honour, that document hasn't been given an

23 exhibit number. It was P465 in the Rule 65 ter exhibit list.

24 JUDGE SCHOMBURG: Normally, we do it at the end. Don't you intend

25 to tender any other documents?

1 MS. SUTHERLAND: Yes, Your Honour.

2 JUDGE SCHOMBURG: So let's wait until the end. Thank you.

3 MS. SUTHERLAND:

4 Q. Doctor, in 1992, was your son living outside Bosnia?

5 A. Yes, he was. At the time, he was studying medicine in Zagreb and

6 was not living in Prijedor.

7 Q. Was your daughter ever taken for questioning?

8 A. My daughter was in Prijedor. She was working as a general

9 practitioner at the time at the local health centre. But she was also on

10 standby at home. She was no longer working at the time. She did not

11 receive any document whereby she would have been sacked, so it can be said

12 that she was on standby. Her departure was a more tragic experience for

13 me, although I don't remember its date. I remember the date of my

14 departure. It was the 11th of June. It was the Bajram. I'm sorry, not

15 departure, but the fact when they were taken.

16 She was picked up in my apartment, although everybody knew that

17 she was not living with me, that she was married and living outside my

18 house. However, they came to fetch her in my apartment. I told him that

19 she was not there. They asked me where she was. And I said that she was

20 living in the vicinity of my block of flats some hundred metres away as

21 the crow flies. But I didn't dare say that she was there because I was

22 afraid that they would go there to get her and then that they would take

23 my son-in-law.

24 That was the reason why I called her on the telephone and told her

25 that she should come to my place, that she was being asked for. She had a

1 small child, and I said that if she had someone to leave the child with,

2 to do so. If not, to come to my apartment without child. She eventually

3 came without the child and --

4 Q. Was she taken to the SUP for questioning? Was your daughter taken

5 to the SUP for questioning?

6 A. Yes, she was taken to SUP, to the police station.

7 Q. How long did her questioning last, if you know?

8 A. Not as long. It was -- it lasted for a couple of hours, not

9 longer than that. Of course, it seemed like eternity to her, but it was a

10 shorter interrogation than mine.

11 Q. Did you at some point arrange for your daughter and other

12 relatives to leave Bosnia?

13 A. Well, I realised that both of us were in danger, and I thought

14 that it would be good for her to be sent somewhere. But we didn't dare

15 leave together with other residents who were transported in buses or

16 trucks and then taken to the central Bosnia and Zenica. I was trying to

17 find some other way, secret way, for my daughter, her child, and two of my

18 nieces to leave the town. My sister had two daughters; one was underage.

19 And this is how I learned through the radio that there was a convoy

20 leaving from Bosanski Novi organised by the United Nations, and that only

21 those who already had tickets could join the convoy. There was another

22 convoy that was supposed to leave before that one but didn't, so we were

23 told that only those who had some kind of tickets were allowed to leave

24 with that convoy. I tried to call a man whom I knew in my official

25 capacity, he was the director of the pharmacy, and I thought that he might

1 be willing to help my daughter join the convoy despite the fact that she

2 didn't have the ticket.

3 So I obtained his telephone number. I called him up. He was very

4 forthcoming and friendly. And I said: "Do you remember me?" "Of course,

5 madam, I remember you." And I said that I was asking for a favour. I

6 said that it was about my child, not about myself. I asked for my

7 daughter to be enabled to leave this -- to leave Prijedor through Bosanski

8 Novi with this convoy, although she didn't have the ticket. He said that

9 he was not aware of what is being organised, but that he would give me a

10 call later. And maybe within one hour or so, he called me back. He

11 said: "Let her come. Everything will be organised for her." And he gave

12 me the name of a woman working in the municipality and whom I could

13 contact to this respect. And she said that if there are any problems,

14 that I should call him back, that he would do everything to enable her to

15 leave.

16 So my daughter, with her child, my sister with two daughters, left

17 in this convoy. They said that they had reservations. They sat on the

18 first seat of the bus of this convoy. But there were other people who had

19 tickets and who had reservations and who were complaining about the fact

20 that their seats had been taken. But this man said: "This is a doctor.

21 She is a doctor. If there are any problems, she will be able to help

22 you." And this is how they managed to cross the border on the 23rd of

23 June and reached Croatia, where they were eventually met by my brother.

24 Q. You said the 23rd of June. Is that the correct date?

25 A. July, I'm sorry.

1 Q. The other persons on this convoy, do you know what ethnicity they

2 were?

3 A. No, I don't. But I guess that most of them were Muslims and

4 Croats who wanted to leave Bosanski Novi, who had asked for this convoy to

5 be organised for them. I don't think that they were Serbs, although it is

6 possible that there may have been Serbs amongst them.

7 Q. I want to move to another topic now. Do you know a person by the

8 name of Simo Miskovic?

9 A. Yes, I know him. I knew him before, even before, at the time when

10 he worked at the police before these events. He was retired, not because

11 of his old age, but because of the nature of the service, it was possible

12 for him to retire early.

13 Q. How long did you known him prior to 1992?

14 A. Well, I don't remember exactly when we met. I think that I had

15 known him ever since I started working in Prijedor. He was married to a

16 nurse who worked at the hospital. So on account of that, I probably saw

17 him more often. But I'm sure that at least 10 or 15 years before the

18 events.

19 Q. What was his ethnicity, if you know?

20 A. Serb.

21 Q. Was he a member of any political party?

22 A. Yes, he was. He was a member of the SDS.

23 Q. Do you know if he held any position within the SDS party?

24 A. He did. At one point in time, he was the president of the SDS.

25 As I said, at one point in time -- I don't know exactly when this was, but

1 I know from the media that he was.

2 Q. Did you ever speak to Simo Miskovic about your husband's

3 whereabouts?

4 A. Yes, I did. I believe it took place in August. A lady

5 acquaintance of mine of Serb ethnicity came to fetch me at my house, and

6 she said: "Let's go have a walk." She used to be a student of my

7 husband. And as we went for this walk, we were not very far from my

8 buildings, some 100, 150 metres away. Simo Miskovic came by, and she

9 greeted him. And I greeted him. He greeted me as well. So we stood

10 there for a while. She tried to ask me what -- if he knew anything about

11 my husband. She said: "Simo, do you know what happened to

12 Professor Cehajic?" And he said: "Well, I don't know much. I know that

13 he had been handed over to the military, the JNA. But that's all I know."

14 Obviously, it was a very uncomfortable situation for him and he couldn't

15 bear to look me in the eye. And my impression was that he was afraid to

16 discuss the issue.

17 It is possible that he already knew what had happened.

18 Q. You said that he said that he had been -- your husband had been

19 handed over to the military, to the JNA. Did Miskovic say who handed him

20 over to the JNA?

21 A. No, he didn't. He didn't tell me that, nor did I ask him any

22 other questions.

23 Q. Did he say anything else?

24 A. No, he didn't. I don't remember that he said anything else.

25 Q. Where were the SDS offices in Prijedor?

1 A. They were located in the block of flats where I lived, on the

2 ground floor. The building itself had three entrances, and on the ground

3 floor of the first entrance, the SDS had their premises before the events.

4 I didn't see many people there, though I didn't really dare look around

5 much or leave my apartment. But as far as I could observe, during that

6 period of time, not many people gathered in these premises very often.

7 Q. When you spoke to Miskovic about your husband, how did you address

8 him, in what capacity?

9 A. I did not address him in any specific capacity. Well, he was just

10 a member of a political party. I was not aware of any particular function

11 that he had.

12 Q. You mentioned a moment ago that he was president of the SDS. Do

13 you know during which period this was?

14 A. No, I don't know during which period this was.

15 Q. Did you ever hear Dr. Milomir Stakic on the radio?

16 A. It is possible that I did, though I must say I didn't pay much

17 attention to that. But I remember that sometime in August, after the

18 Omarska camp had been closed down, I heard a conversation. You see, there

19 were many shortages, power shortages, at the time, so I didn't turn on the

20 radio very often. But when I did, this was very traumatic for me so I

21 avoided as much as possible listening to the radio. But on one occasion

22 that I did turn on the radio, I heard him speak over the radio and I heard

23 him say that the Omarska camp did not exist. Of course, I felt insulted

24 by what he said because everybody knew about the existence of the Omarska

25 camp, and I remember discussing this with someone. It was strange that he

1 should be denying the existence of the Omarska camp, whereas everybody

2 knew about its existence. But I realised that it meant more to me than

3 others. Had it not been for this Omarska, my husband would probably be

4 still alive, my nephew and many others who perished. At any rate, this

5 was my personal experience of this speech that I heard over the Prijedor

6 Radio.

7 Q. Why was it traumatic for you to listen to the radio?

8 A. The contents of radio programmes often involved Muslim extremists,

9 the threat that was coming from Ustashas. I'm now paraphrasing. It was

10 something that I simply couldn't adequately react to. I had to defend

11 myself somehow from these allegations. I wanted to save myself from this

12 kind of environment.

13 Q. Doctor, did you try to ascertain the whereabouts of your husband

14 after the Omarska camp closed?

15 A. I did. I tried to contact the people who had been in the Omarska

16 camp. I went to the Trnopolje camp after it had been visited by the Banja

17 Luka ICRC and after it was said that family members were allowed to visit

18 detainees there and take food to them.

19 Q. Excuse me, Doctor. I'm sorry for interrupting you, but I notice

20 the time and it was a new topic I was getting to, so perhaps we can deal

21 with it after the break.

22 JUDGE SCHOMBURG: The trial stands adjourned until 10.55.

23 --- Recess taken at 10.31 a.m.

24 --- On resuming at 11.00 a.m.

25 JUDGE SCHOMBURG: Please be seated.

1 MS. SUTHERLAND:

2 Q. Witness, before the break, I asked you whether your daughter had

3 been taken for questioning, and you said that she had been taken to the

4 police station. You were answering my question, and you said that your

5 daughter had come to your apartment without her child. And then I

6 interrupted you. Was there anything that you wanted to add in relation to

7 that? How was your daughter eventually taken to the SUP?

8 A. The policeman came to fetch her, and they took her by car, and she

9 came back on foot. So there was nothing special in the whole event. One

10 of those policemen I knew, who was embarrassed because we knew each other,

11 and he probably knew me much better than I did know him because, in

12 Prijedor, many more people could know me than I could know them. So there

13 is nothing else to add to this.

14 Q. Did your daughter tell you what she was questioned about?

15 A. Very briefly, I know some things. I know that they asked her --

16 once they asked her about her father and what she thought of her father

17 because of what he had done. And she said: "What had he done? I do not

18 know, but if you tell me, I may know. But I think that my father was an

19 honest man and a citizen of Prijedor. He was a professor, and that he

20 brought me up as a good and honest person, and I'm very grateful to him

21 for that." And after that, they did not comment on this, and this is what

22 she said, what she mentioned about what she had said to them, nothing

23 else.

24 Q. Doctor, if we can move back to the topic we were dealing with just

25 before we had the break. I asked you whether you had tried to ascertain

1 the whereabouts of your husband after the Omarska camp closed, and you

2 started to answer that you went to Trnopolje. Can you please continue

3 your answer?

4 A. I saw outside many people from Omarska who were transferred here

5 and then later they went home. I don't know in what way but they were

6 released from that camp. And this is where I saw some people who said, "I

7 saw your husband in Trnopolje," and that he had slept with him in a part

8 of a room. Some people told me that on a certain date, he was called.

9 And after that, he did not come back. Professor Zec Adolf, who was a

10 teacher of the physical education in Prijedor, who I used to know, he told

11 me: "Whatever they tell you, they do not know." But he at some point at

12 the end of July, on the 27th or 28th, was called in when the detainees

13 were called in a roll call, and there were buses in which they were taken,

14 nobody knew where to. But afterwards, he never came back.

15 Such stories I heard from Islamovic, Sakib. We were born close

16 by. He was an engineer. He's younger than I am. And he was the director

17 of one department in the Ljubija coal mine. He was also my neighbour

18 where we lived. And he came among the first from Manjaca, the first

19 detainees who went from Omarska to Manjaca. He was among the first to be

20 returned to Banja Luka. And he came to Prijedor through some family

21 relations he had through his wife, who was a Serb. And he came home. He

22 really looked terrible. He had 30 kilos less than he used to have. And

23 he told me: "I tried to register since when he had disappeared. And I

24 thought that it was about eight days prior to the closing up of the

25 Omarska camp. And it could have been the 27th or the 28th of July."

1 After that, wherever I saw someone or I could ask them, I did so,

2 and I mostly asked people who came back from the camps. When they came to

3 Croatia from Manjaca, whichever group arrived, I went in order to see

4 someone and in order to find out, because I did hope that he was alive

5 somewhere, and that if there wasn't this -- the crucial, the 27th or the

6 28th of July, when he disappeared without coming back.

7 In Zagreb, I met a journalist, Roy Gutman, who at that time still

8 went to Prijedor and to that part of Bosnia. And I asked him if he could,

9 when he went to Prijedor, to ask about my man, about his whereabouts. And

10 as soon as he came back, he told me that the officials in Prijedor told

11 him that he was not there when the takeover of the authority in Prijedor

12 took place, that he had left it prior to that. And I told him that that

13 was not true, that I had a document which, unfortunately, I do not have

14 here but at home in which it says -- and the document was dated the 18th

15 of August, in which it is written that my husband and some other men, some

16 other persons, had been turned to the military court, and that he was no

17 longer under the authority of that particular court. This document was

18 signed by Zivko Dragosavljevic. And I gave this photocopy to Mr. Roy

19 Gutman, and he went for the second time to Prijedor with this document,

20 and he said that he had attended a dinner where all the leaders were

21 present in Prijedor and that he asked about my husband. They told him

22 that on the 27th July, in Omarska, there was no electricity, and some

23 detainees ran away, escaped, and among them also Cehajic. And this is

24 just the most important facts that I know about my asking about my

25 husband. But throughout the war, whenever I saw someone, I asked

1 questions, thinking that my husband might be alive until the end of the

2 war. Then I realised that if he had been somewhere, that he would have

3 come, and this was the end of my trying to find him, to locate him.

4 Q. Did you ever go to Banja Luka to find out about your husband's

5 whereabouts?

6 A. Yes, I did. It was about the 15th of August.

7 Q. How did you travel to Banja Luka?

8 A. I heard some information - I do not know whether on the radio or

9 from people - that no passes were necessary to travel. And I decided to

10 take a bus, and I also tried to develop some tactics because people who

11 were going around, who knew, told me what to do. I took a bus from

12 Bosanski Novi to Banja Luka. They told me that that bus was controlled

13 until Prijedor, and then from Prijedor, that it was not controlled. And

14 the one that left Prijedor was controlled from Kozarac onwards. So I took

15 the bus going from Bosanski Novi, and I arrived -- I went to -- I arrived

16 in Banja Luka. And everything was fine, but on our way out, some control

17 came and this man saw my ID, and by the name, he could tell. My name

18 didn't tell him much, but at least my ethnicity. So he asked for my pass

19 for travelling, and I told him that I didn't need -- I thought that I

20 didn't need it. So he let me go.

21 So I arrived in Banja Luka and went to the ICRC. I had with me

22 some business, a business card of the head of the office in Banja Luka who

23 was officially -- who visited me officially in Prijedor, and he gave me

24 his business card. So I thought that this man was still there, so I would

25 show him his business card and mine as well and he would receive me.

1 However, there was no understanding there from the people who were

2 translating for me, and they told me that he was busy and that he

3 couldn't. I was very persistent, so I waited until the afternoon and then

4 I tried through some other people, because there were many translators,

5 interpreters, there. So I told them to give him the business card, and if

6 he couldn't receive me, I would come the following day.

7 Finally, this business card was gone, and this gentleman asked me

8 to come in. And when I entered the room, I saw that this was not the man

9 whose name was written on the business card. And then I apologized and

10 said that I didn't do it on purpose, that I didn't want to cheat him, that

11 this person really had given me the business card. So he said, "That's

12 nothing, okay, I had time. I was free to receive you." He listened to

13 what I had to say, and I asked him, because I thought the IRC was powerful

14 and that they could look for the people who were missing. And I also

15 asked him to take all the data. He did so. And I told him that my

16 husband had been in Omarska, that he wasn't there any more, that he was

17 probably in Manjaca or in some other camp. And that -- I asked him to try

18 to help people. I also said that I had come to ask all the people, not

19 only my husband, but to all the people who needed help in order for them

20 to be treated in a humane way. And at that time, I was really

21 traumatized, and I cried a lot. It was summer. I had a summer dress, and

22 it was all wet of my tears. And that man really was sad, and he tried to

23 comfort me as much as he could at that time. And he took all the personal

24 data and he told me to go, and whatever was in their power, they would do

25 in order to help all the people, and of course my husband as well.

1 Q. Did the Red Cross later come to Prijedor and telephone you on two

2 occasions?

3 A. Yes. Twice they telephoned, and they told me -- those at the IRC

4 asked for me. And of course, I interpreted that as some kind of care for

5 me because if they came to Prijedor and asked about me, that I was more

6 secure and that nothing should happen to me in the house.

7 Q. When you travelled to Banja Luka from Prijedor, did you go along

8 the main Prijedor/Banja Luka Road past Kozarac?

9 A. Yes, I did.

10 Q. As you travelled from Prijedor, were you able to see the non-Serb

11 villages along the way?

12 A. Yes. Kozarac is a village, a small place, which before the war

13 had around 20.000 inhabitants, and the highest percentage were Muslims and

14 a small percentage of other ethnicities. I did saw Kozarac. There are

15 several hamlets actually which belonged to Kozarac, and I saw that

16 everything was destroyed and damaged.

17 Q. Did you see your -- the villages of Kozarusa and Kamicani?

18 A. Yes. This is all along the way from Banja Luka along the road, so

19 you could see all those villages that you wanted to see.

20 Q. What ethnicity of people lived in the villages or lived in the

21 villages of Kozarusa and Kamicani in 1992?

22 A. Mostly Bosniaks, at least this was how they declared themselves.

23 Q. What were the condition of the houses in Kozarusa and Kamicani?

24 A. The houses were completely destroyed. It was really terrible to

25 look at them. There might have been one or two that was not completely

1 destroyed, but it was a horrifying sight, as if there was no life at all,

2 only destroyed houses, torn-down houses. This is what you could see.

3 Q. Can you tell me the date that you left Prijedor?

4 A. The 5th of September, 1992. And on the 6th of September, I

5 arrived to Karlovac, in Karlovac.

6 Q. Prior to leaving Prijedor, were you ever assaulted? And if so, by

7 whom?

8 A. Yes. Prior to my departure, because that man, a Serb from

9 Bosanski Novi, told me that he would come to pick me up and that he would

10 take me across the Croatian and Bosnian border. And we made the

11 arrangement. We agreed on the price, 3.000 deutschmarks, to take my

12 sister and me. And he said that I shouldn't take any things with me if I

13 wanted to remain alive because, the less I have, the more securities I

14 would pass. And, of course, I did not take anything. I thought what can

15 I take in a bag if I'm leaving everything else? So I didn't take

16 anything. I had only some money -- I had some money in the bank on my

17 book of my salary, and I went to the bank in order to take that money out,

18 which I meant to leave to my relatives, because my sister's son stayed in

19 Prijedor still, and he did not have any money on him, so he didn't have

20 anything to live on. So that's what I wanted to do, to leave it to this

21 relative of mine in Bosanski Novi, where I would stay overnight in order

22 to wait for my transfer to Croatia.

23 I went to the bank, and there were some guardsmen on the entrance,

24 and they controlled -- they looked at everybody's ID. And this is how my

25 sister and I came. It was our turn, because we were together. And he let

1 her go, but to me, he said: "You are Cehajic's wife, and you are with

2 Dedo Crnalic, a man who was in catering business. You had lamb with your

3 husband at his place." I looked at him, and I said: "Yes, I did go with

4 my husband to many places but I didn't visit Dedo Crnalic's place at all."

5 He looked at me and said: Yes, okay. Okay, go in." And Thank God, if he

6 would have kept me there, I would have passed and stayed on the side. So

7 I entered the bank like many other people. I went to the counter, and I

8 queued, and one of the men came to me and said: "Come out of the queue.

9 Leave the queue," and took me in the back of the bank where there were

10 some offices. I knew of those because I had come many times to the bank.

11 He put me -- took me into an office, and they took my handbag, and

12 they put on the table everything that was in my bag. And they started

13 cursing me, 'the Turkish' -- one of them, 'my Turkish mother,' and such

14 things. At that moment, I do not know whether I was scared, but I could

15 not pull myself together, what was happening in front of all the people

16 who were there. He took me to this room and he closed the door. After

17 him, some other men came. There were altogether five of them, and one

18 young man - he was not very tall - he started cursing my husband. He

19 started mentioning his name. And at some point, he wanted to hit me with

20 his hand. And this taller man who was standing next to me, he put his

21 hand in order to prevent this other man to blow me. So actually, he

22 managed to hit both me and him.

23 So this tall man said -- asked him what he was doing, maybe

24 because he was also hit, and I was hit as well. So I do not know why, but

25 his intention was to protect me, because he put his hand -- he quickly

1 took my handbag, put all the things into it, and also some books that were

2 on the desk, he put in my handbag. He gave the handbag to me and took me

3 out -- quickly out of that room. And I went home after that because I

4 lived close by. I did not know anything. At the moment of that blow, I

5 simply thought at some point that I left my consciousness -- conscience,

6 but I didn't fall down. But I knew for a moment that I did not know

7 anything any more. My head was swollen but nothing hurt, and I actually

8 managed to get to my house. I don't even know how I managed to cross the

9 street, the road. I looked in the -- at myself in the mirror when I came

10 home, and I saw on my face there was a trace of the blow. It was black

11 and blue under my eye. And of course, that was a problem. The following

12 day, when I had to go to Bosanski Novi in order to go to Croatia, it was

13 necessary to do something about this bruise because if someone saw the

14 trace of a blow, then of course they could think that I was someone who

15 needed to be caught again, arrested again, captured again.

16 So when I came home, my sister arrived also. She took the money,

17 and the man in the bank said that he would give her my money without me,

18 and this is how I managed to draw out that money that I needed.

19 Q. Doctor, these people that were in the office in the bank, how were

20 they dressed?

21 A. They were dressed in various kind of suits. There were several

22 police officers there. Some of them were wearing regular police uniforms.

23 Q. From the 23rd of May until the 5th of September, 1992, did you see

24 any sections of Prijedor city damaged or destroyed?

25 A. I didn't move around the town of Prijedor very much because after

1 the interview that had taken place in Keraterm, I was told that I should

2 not leave my apartment, that I was under some kind of house arrest. But I

3 also thought that it was not a very good idea for me to leave my apartment

4 because there were very few people who were taken for interrogation and

5 not ended up in a camp. I know this about my daughter, for example, but a

6 number of people were eventually taken to a camp and never returned. So

7 if I had some errands to do, I would leave my apartment but I would remain

8 in the vicinity of the apartment. There is a mosque there -- there used

9 to be a mosque there, and I could see that it was destroyed. There were

10 only remains of the mosque standing. I saw that a part of the Catholic

11 church was also demolished, and at the time I saw it, at the time I passed

12 by, part of the structure was still standing. And after a while, that

13 part was also gone.

14 Q. You mentioned how you were able to leave Prijedor on the 5th of

15 September, 1992. Did you seek official permission to leave Prijedor?

16 A. I sought official permission for my daughter, and I obtained it, a

17 permission for her to leave Prijedor together with my two nieces. Then in

18 August I tried to obtain a permission for myself and wait for the next

19 opportunity to leave. But on that occasion, I was told that I could no

20 longer obtain such a permit, that they were no longer issued. But at any

21 rate, it wasn't so important for me because, even with a permit, I didn't

22 know how I would go about leaving Prijedor. So I no longer went. I no

23 longer tried to obtain this permit. I was trying to find a secret way to

24 leave Prijedor. I didn't want anyone to know that I had left.

25 Q. Why did you decide to leave Prijedor?

1 A. As days went by, the situation was setting worse. I felt that I

2 should no longer stay there, that I could no longer stay there. Then I

3 started receiving visits of the people who wanted my apartment. My sister

4 had similar visits before me. These people told her that she had to

5 leave, she had to move out of her apartment. She had the same apartment

6 as I had, a four-room apartment, and she had to move out so that they

7 could move in. A soldier eventually came to her apartment.

8 After they had finished with her, they started visiting me in my

9 apartment and telling me I should leave. And two or three days prior to

10 that, a soldier came. They said that they were members of the military

11 police; they were wearing the typical white belts. He said that he heard

12 that I was about to leave my apartment and he expressed his interest in

13 moving in, justifying that with some merits that he had had in the war. I

14 said: "You're a young man. You have enough time. I'm sure you will

15 receive an award for your merits. But this is my apartment. I have spent

16 entire my life and my career living in Prijedor, and this is what I got as

17 a result of that." But that was very usual at the time. People would --

18 people would choose an apartment for themselves and then exert pressure on

19 those people who lived there.

20 So as I said, two or three days prior to my departure, I had this

21 visit, the visit of this soldier. And I knew that eventually he would

22 force me out of my apartment and I would no longer have a place to live.

23 And this is indeed what happened. So I asked my next-door neighbour to

24 close the window which I had previously opened. I wanted people to think

25 that I was still there. And I switched on the lights, and I asked her to

1 leave the lights on so that I could leave and cross the border because I

2 knew that they would come on the same day. And this is indeed what

3 happened. The same soldier arrived two or three days after my departure,

4 and he moved into my apartment.

5 Q. Do you know the ethnicity of this soldier?

6 A. Yes, I know. He was a Serb. His name was Gavranovic. His family

7 name was Gavranovic. His name now escapes me, but he was a resident of

8 Prijedor. He lived in a Prijedor neighbourhood.

9 Q. You said that you sought official permission for your daughter to

10 leave when she left Prijedor in July. Who gave this permission?

11 A. We were given these permissions in the SUP, the police station.

12 Q. Were there any conditions attached to leaving Prijedor?

13 A. Yes, there were. I had to give up my property. This was a rule

14 which applied to everyone. That was the condition for us to leave the

15 town.

16 Q. Did your daughter have to sign any documents?

17 A. Yes, she did. Everybody did. She had to sign personally this

18 document for herself. One of my nieces was above 18, so she signed the

19 document for herself. And this underaged niece, it was her mother who

20 signed on her behalf.

21 Q. Did your daughter ever tell you what was written on the document

22 that she had to sign?

23 A. Yes. I saw it, too. It was some kind of certificate whereby

24 so-and-so was giving up his or her property for the benefit of the

25 Republic of Serbian Krajina.

1 Q. What property belonged to you and your family in 1992?

2 A. We owned this apartment, a car, a garage, an apartment which was

3 still at the time in construction but which officially belonged to my

4 daughter. I had a family house in Ljubija, some land, some woods. My

5 husband had a family house in Sanski Most which he inherited from his

6 family. And we also had a partly constructed house in Sanski Most. It

7 was not yet finished. It just had a roof on, that's all.

8 Q. In 1992, was the house in Sanski Most that your husband inherited

9 -- what happened to that house, do you know?

10 A. That house was burned down. Even the debris was removed. Only

11 foundations have remained and a portion of a wall. Everything else is

12 gone.

13 Q. The family house in Ljubija in the Prijedor municipality, do you

14 know what happened to that in 1992?

15 A. That family house remained. It was not destroyed, but it was

16 vandalised. It no longer has any door or window frames. It's not

17 suitable for living. It was a very special type of architecture. It was

18 built in 1921, and it was one of the nicest houses in Ljubija. It was

19 built in a typical Austro-Hungarian style, with a carved fence on the

20 terrace and a carved entrance door. It was renovated at one point in time

21 and we tried to renovate it in the traditional style in which it was

22 built. But nobody lived in the house at the time, and it was vandalised.

23 Q. The partly-constructed house in Sanski Most, do you know what

24 happened to that in 1992?

25 A. It is still there. It was not a house that one could live in.

1

2

3

4

5

6

7

8

9

10

11

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

13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

1 It's never been finished, and it remained in the same condition as it was

2 in 1992.

3 Q. In 1992, did you consider yourself well off?

4 A. Yes, I did. I considered myself well off. We belonged to this

5 group of people who were relatively -- who were doing fine. As a

6 physician, I had a decent salary. But I had to pay tax, of course.

7 Officially, my salary was higher than the -- most of the salaries of

8 people who lived in Prijedor. My husband's salary was not that high. He

9 was a professor at the local high school, and teachers are usually paid

10 less than doctors. But he was a very modest, reasonable man. We had a

11 good life. We had some property from before, and I think that we had a

12 good life, yes.

13 Q. I want to move to another topic now. In relation to the fate of

14 your husband, do you know a person by the name of Ermin Strikovic?

15 A. No.

16 Q. Do you know a person by the name of Azra Blazevic?

17 A. Yes, I know her. I remember Strikovic. I know him only by his

18 nickname, "Lola." I just remembered. The man is the husband of Azra

19 Blazevic.

20 Q. Did you ever speak to him about the fate of your husband?

21 A. Yes, I did, with Lola. I didn't remember that his name was Erman

22 Strikovic. I know him by his nickname. He was the one who told me about

23 him. He used to be my husband's student, and so did Azra. He told me

24 that my husband was with the group of people who were first taken to

25 Omarska from Keraterm.

1 Q. Was Erman Strikovic detained in Omarska?

2 A. Yes, he was. He told me he had gone together with my husband,

3 that he had been taken together with my husband in this group. He was

4 also at Manjaca, but he survived Manjaca and is currently residing in

5 Germany.

6 JUDGE SCHOMBURG: Is it necessary to redact?

7 MS. SUTHERLAND: No, Your Honour.

8 Q. Did you ever speak to a person called Mustafa about your husband?

9 A. This man is a relative of my husband and lives in Banja Luka.

10 When my husband was in prison in Banja Luka, he was the one who paid him a

11 visit. He took him some essentials that he needed at the time, and he

12 informed me that my husband was in prison. Apparently, it was possible to

13 call from there, and it was possible for the detainees to receive

14 packages. After he left this prison, he called me to say that he was no

15 longer in Banja Luka.

16 Q. Do you know a person called Emir Ibrahimbegovic?

17 A. Yes, I do. He told me in Zagreb, because I met with him in

18 Zagreb, that in this prison he been some kind of warden in this prison.

19 I'm not familiar with their ranks. I don't exactly know what he was. And

20 my husband came to Banja Luka to this prison, and when he saw my husband

21 writing a letter addressed to Minka Cehajic, he remembered me. An he said

22 that he had gone to see him. He said that his name was Emir. He didn't

23 want to discuss anything in particular with me. He had to read this

24 letter which had been written by my husband because it was his duty. And

25 he said that more such letters had been written and sent out of the

1 prison. However, those letters never reached me. He said that two or

2 three days passed, and some people came to the prison and said that Croats

3 and Muslims could longer work in prison. So Emir had to leave the prison,

4 so he didn't know exactly when my husband had left prison, this prison.

5 However, a friend of his, a Serb, who was supposed to bring him some

6 documents, told him this friend of yours had left. Emir had probably told

7 him before that he was someone whom he knew from childhood, and that's

8 probably why he said, "this friend of yours."

9 Q. At some point, did you receive a letter that was written by your

10 husband?

11 A. I received one letter dated the 9th of June. It was not through

12 the prison authorities that my husband sent this letter. I assume that he

13 had written it in Banja Luka but that he brought it with him in Omarska,

14 that he had this letter in Omarska. And I think that it was there that he

15 met a young man from Prijedor who had approached him and told him that he

16 had seen me in Prijedor going to visit her, that is, my brother. And he

17 said that I was fine. So after a while, perhaps later on that day or some

18 other day, my husband gave him the letter that I still have. And he

19 said: "Please, I know that you will leave this place one day. Please,

20 give this letter to my wife, because I don't think I will ever leave this

21 place."

22 The letter bore my telephone number and the address, and this

23 young man unknown to me, who was also probably frightened because he had

24 been detained in the camp and did not want to be seen in the vicinity of

25 my apartment, he came to see me one day. He knocked on my door, and he

1 simply said: "Here is a letter for you. It was given to me." And this

2 is all he said, and he disappeared. I never saw him again.

3 Q. You said that you assume that your husband had written it in Banja

4 Luka but that he brought it with him in Omarska, that he had this letter

5 in Omarska. You're referring to the Omarska camp?

6 A. Yes, yes, I am.

7 MS. SUTHERLAND: Could Dr. Cehajic please be given the letter

8 dated the 9th of June? This will become a new exhibit.

9 Q. Is that the letter that you have just referred to?

10 A. Yes, it is. This is my husband's handwriting. It was a very

11 special handwriting. You can compare the handwriting in this letter with

12 the handwriting which can be found in the school books and school

13 registers. It's difficult for me from time to time to recognise my own

14 handwriting, but I can definitely always recognise his. He spent so many

15 years as a teacher.

16 Q. Do you have the original of this letter?

17 A. My son has it. He took the letter, and he wanted me to give it to

18 him. He said that it was the only memory that he had of his father.

19 Although the letter was addressed to me, the original is with my son

20 because, as I said, this is the only memory that he has of his father.

21 Q. Can you just turn to the second page of the two-page handwritten

22 document. And at the bottom of the page --

23 A. Yes.

24 Q. -- there is some text that is missing. Is that also missing on

25 the original?

1 A. I think that the original contains this text that is missing here.

2 I think that the word "Muhamed" is there. I haven't recently looked at

3 the letter since I gave it to my son, but I think that it should be there

4 on the original.

5 Q. Dr. Cehajic, I'm going to ask you to read this letter.

6 MS. SUTHERLAND: Your Honours, there is an English translation

7 which appears in Roy Gutman's book. We will be seeking an official

8 translation. But if Your Honours wanted to follow it, you can use this

9 document until we have an official translation.

10 JUDGE SCHOMBURG: I think in case it's not too problematic, and I

11 would understand this, it would be the best solution for all of us, also,

12 when it comes to problems of handwriting, if you could be so kind and read

13 out this letter, though we know it's difficult for you.

14 THE WITNESS: [Interpretation] The title says: "Minka Cehajic."

15 The street is Dzemal Bijedica 16, or the Prijedor hospital, and the

16 telephone is 21771, or 23722, which is my sister's telephone, so he

17 probably thought one or the other. "Banja Luka, the 9th of June, 1992."

18 This is a copy which is not easily legible, but I'll try and do my

19 best. "My dear Minka: I am writing you this letter, though I'm not all

20 certain that you will get it, but I still feel the irresistible need to

21 talk with you in this way."

22 JUDGE SCHOMBURG: Sorry. May I interrupt you. We are really

23 interested to hear it word by word, and for the interpreters, if you could

24 slow down a little bit. Thank you.

25 THE WITNESS: [Interpretation] Okay.

1 "Since my departure, since that 23rd of May when they came to our

2 house to get me, I have been living in another world. It seems to me that

3 everything that is happening to me is just an ugly dream, just a

4 nightmare. And I simply cannot understand how something like this is

5 possible. My dear Minka, Amira, and my son: You know how much I love

6 you. You know how much I love you all. And because of this love, I have

7 never done anything, nor would I ever do anything, that would cause you

8 any pain. I know that you know that what they are trying to put on me has

9 nothing to do with me whatsoever. I just keep wondering whom and how much

10 I have offended so that I have to go through all this. But I still

11 believe in justice, and I believe in truth, and I believe that this will

12 all be cleared up. Otherwise, I keep thinking of you constantly, and your

13 faces are always before my eyes. But I have to admit that it is Amir's

14 image that emerges most often before my eyes, and then an occasional tear

15 flows. I know how hard this will be for him, because I know how much he

16 loves me.

17 "I especially ask you, Minka, if you talk to him, please, try to

18 comfort him. Time is passing with dismal slowness, and I can hardly wait

19 for the day when I will be with you again. And you will be sufficient for

20 me for the whole of another world. I would be happiest of all if we could

21 go together far away, where there's no one else. Dear Minka, I'm terribly

22 worried about Sejdo, about Nasa, Biha, and others. I have heard some

23 terrible things, so please, if -- I say so please let me know, if you can,

24 what's happened to them. Safet Mustafa brought me cigarettes, some

25 underwear, and the essentials, and I thank him for that forever. If it

1 hadn't been for that, I would have thought I was completely alone in this

2 world.

3 "I keep wondering, where have all the good friends gone? But so

4 be it. And how's my Benjo doing? Does he ever ask about his grandfather?

5 I missed him so much. Today's the 18th day since I was deprived of my

6 freedom. But to me, it seems like a whole eternity. I don't even know

7 how many times I have been interrogated, and now the investigation is

8 conducted by a judge, Zivko Dragosavljevic. I also asked the lawyer

9 Bereta to attend the interrogations. And I beg you also to engage Sefik

10 Trozic or Emil Kulenovic, whoever wants to. I don't know how much longer

11 they're going to keep me here. If you can, please try and get me some

12 cigarettes somewhere, some soap, toothpaste, two or three pairs of

13 underpants, and an undershirt, a track suit, a shaving set, and some

14 shaving cream.

15 "Don't bother to send me any food, because I cannot eat anyway.

16 But if you can, please send me some ground coffee. As for Amir, tell him

17 to stay with Orhan. And if, God providing, all this settles down one day,

18 then you should go to him. Tell him to just keep studying. And for the

19 hundredth time, tell him that daddy loves him much, much more than he

20 loves himself. I don't even think about myself any more. But he must be

21 an honest and an honourable man. It is inconceivable for me all this that

22 is happening to us. Is it to be that life is so unpredictable and so

23 brutal?

24 "I remember how this time last year we were rejoicing so much over

25 building a house, and now see where we are. I feel so empty. I feel as

1 if I had never been alive. I'm trying to fight it. I'm trying to resist

2 it by remembering everything that was beautiful with you and the children

3 and all those that I love. That's all for this time because I don't have

4 any strength any more. Give my love to all who ask about me. And to you

5 and the children, I love you very, very much."

6 JUDGE SCHOMBURG: The trial stands adjourned until 12.20.

7 --- Recess taken at 12.00 p.m.

8 --- On resuming at 12.25 p.m.

9 JUDGE SCHOMBURG: Please be seated.

10 The Prosecutor may proceed, please.

11 MS. SUTHERLAND: Thank you, Your Honour.

12 Q. Dr. Cehajic, when did you receive the letter that was written by

13 your husband?

14 A. It could have been August. Most probably after the closing up of

15 the camp. When that young man came out, he didn't -- well, probably in

16 August, in the second half of August, some time before my departure. I

17 just remembered that I did not know about this letter at the moment I had

18 left to Banja Luka, so it must have been towards the end of August.

19 Q. You said earlier that Sakib Islamovic, a detainee in Omarska camp,

20 told you that he saw your husband in Omarska up until the end of July

21 1992.

22 A. Yes. That's Sakib Islamovic, yes.

23 Q. You also said earlier that you asked questions throughout the war,

24 trying to find out about your husband, and at the end of the war, you

25 stopped trying to find him because, had he been alive, he would have come

1 to you.

2 A. That's correct.

3 Q. Have you attended any of the exhumations that have been conducted

4 in Bosnia?

5 A. Yes, I did. I was present at some. In Sanski Most, they exhumed,

6 and they were brought to Sanski Most and exposed in the halls there. And

7 I went every time, hoping that I might recognise and find my husband

8 there. And this is what I did. I went to see those people that were

9 brought there. Every time I went there, I knew that there was nothing to

10 recognise him, that that was impossible. But still I had a need to go

11 every time for this identification. And every time, I went through a

12 terrible thing. It was very difficult for me, but I had to do it for my

13 husband. I had to go and see. But it wasn't possible to recognise him,

14 and I only hope -- the DNA, we did give that for the analysis, the DNA, so

15 if that might make it possible to find him.

16 Q. Dr. Cehajic, I have no further questions for you. If you could

17 just wait there for one moment.

18 MS. SUTHERLAND: Your Honour, do you want me to tender the

19 exhibits now?

20 JUDGE SCHOMBURG: Yes, please.

21 MS. SUTHERLAND: The first document which was referred to

22 yesterday, which was Prosecution -- which was marked P650 in the Rule 65

23 ter exhibit list, dated the 10th of June, 1992.

24 JUDGE SCHOMBURG: This was already admitted as S49.

25 MS. SUTHERLAND: Is admitted as S49.

1 JUDGE SCHOMBURG: Right.

2 MS. SUTHERLAND: The next document today was -- Your Honour,

3 Ms. Karper, the case manager, has it as S48.

4 JUDGE SCHOMBURG: Right. I'm already one step further. 465, I

5 think this will be the next now, the former 465.

6 MS. SUTHERLAND: Yes, that will be S49.

7 JUDGE SCHOMBURG: Yes. I had already marked this provisionally

8 S49.

9 MS. SUTHERLAND: And the letter --

10 JUDGE SCHOMBURG: S49B, because we have it only in B/C/S. But I

11 don't think a translation is necessary. We have it on the transcript.

12 Objections from the Defence?

13 MR. OSTOJIC: Yes, Your Honour, same as before, on the same

14 grounds, for the record, Your Honour.

15 MS. SUTHERLAND: Your Honour --

16 JUDGE SCHOMBURG: I take it, just for the record, and so this is

17 admitted as S49B.

18 MS. SUTHERLAND: Your Honour, there is a draft summary translation

19 just of the heading and of the signature block.

20 JUDGE SCHOMBURG: Yes. We already have the most important points

21 brought into -- tendered into evidence by the transcript and by the

22 annotations and the remarks by Dr. Cehajic. And I think this forms at the

23 end of the day one unit.

24 MS. SUTHERLAND: And Your Honour --

25 JUDGE SCHOMBURG: But I appreciate if you later on give this as

1 S49A as a translation in part to the registry.

2 MS. SUTHERLAND: The registry and the parties have been provided

3 with copies already.

4 JUDGE SCHOMBURG: Fine. Then it's S49A, this translation in part.

5 MS. SUTHERLAND: Your Honour, if the letter dated the 9th of June,

6 1992, could be marked S50, letter written by Muhamed Cehajic to Minka

7 Cehajic.

8 JUDGE SCHOMBURG: S50. Could we here agree -- I'm hesitant to use

9 that, what we have here as a part of a book, as a formal translation.

10 MS. SUTHERLAND: The Prosecution will be requesting an official

11 translation.

12 JUDGE SCHOMBURG: In both languages, please, in English and

13 French, please. Then this document, the letter, objections?

14 MR. OSTOJIC: No objections, Your Honour.

15 JUDGE SCHOMBURG: It is then admitted into evidence as S50B.

16 I wonder, because I don't know whether the Defence will come back

17 to this, this would be, of course, a surprise, but before the Judges come

18 back to other documents offered in this context, what about the former 65

19 ter Document 625?

20 MS. SUTHERLAND: I don't seek to tender that document, Your

21 Honour.

22 JUDGE SCHOMBURG: So you want to leave it for the Judges?

23 MS. SUTHERLAND: Yes, Your Honour.

24 JUDGE SCHOMBURG: And then we have, in addition, another document

25 offered until now but not yet tendered. It is 65 ter Document Number 476.

1 MS. SUTHERLAND: Your Honour, I don't seek to tender that document

2 at this stage.

3 JUDGE SCHOMBURG: So it will be -- the Defence may be prepared

4 that both documents will be tendered by the Judges. So I understand this

5 was the end of the examination.

6 MS. SUTHERLAND: Yes, Your Honour. Yes, Your Honour.

7 JUDGE SCHOMBURG: Thank you. Then we may start with the

8 cross-examination, please.

9 MR. OSTOJIC: Thank you, Your Honour.

10 Cross-examined by Mr. Ostojic:

11 Q. Dr. Cehajic, my name is John Ostojic, and I'll be asking you

12 questions here this afternoon. Okay?

13 Doctor, initially, I'd like to ask you some general questions with

14 respect to the testimony that you gave, and if you can be so kind enough

15 to help clarify some issues that I continue to have questions on. Can you

16 help us with that, please?

17 A. If I can.

18 Q. Thank you. Did you ever attend a meeting of the SDS?

19 A. No, I didn't.

20 Q. Did you ever attend a meeting of the SDA?

21 A. I didn't.

22 Q. And I understand that you gave a statement to the OTP in 1997 in

23 connection with that which you've experienced tragically in Prijedor. Is

24 that correct?

25 A. Yes, it is correct.

1 Q. Is it fair to say that during the period of 1990 through 1992,

2 April of 1992, that you personally, Doctor, did not notice any animosity

3 between the politicians in the Prijedor municipality?

4 A. No, I didn't notice. I thought that they were in a coalition and

5 that they were dividing the power, so I did not notice any animosities.

6 My husband did not talk about this, and I wanted to exclude myself, to be

7 out of it, because in the past, I had been an active member as a

8 politician, an amateur, and at that time I didn't want to get involved at

9 all. And to go in depth and to analyse, I turned to myself. I wanted to

10 see who I am and what -- from what I am and how I could think then. It

11 was really stressful for me also because I had been brought up at

12 different times. And when this multiparty system came, it was a change

13 for me, and I wanted to really gather whatever was good in myself and then

14 start thinking about the new society that I had to live in.

15 Q. If I may ask you, Doctor, prior to April of 1992, were you

16 familiar with whether or not there was an inter-party agreement between

17 the SDS and SDA?

18 A. At the beginning, yes, because they have divided the powers. There

19 was this agreement, as much as I know about it. But I do not know of any

20 other agreements. I only know that in February 1992, the Municipal

21 Assembly of Prijedor was formed, the Serbian Municipal Assembly. But I

22 was not interested in that. And my husband did not talk about it. He did

23 not talk about it as something that could bring some changes or some bad

24 things. And I, myself, was -- wanted to exclude myself from this kind of

25 thinking.

1 Q. Would it fair, from February 1992 through approximately April

2 30th, 1992, to say that your husband, the late Mr. Cehajic, that he

3 continued to negotiate and discuss and meet with members of the Municipal

4 Assembly?

5 A. I cannot either confirm or say no, because I do not know. Of

6 course, he went to work. He worked, and I do not know any details about

7 it.

8 Q. Let me, if I may, direct your attention to another topic that

9 we've discussed here at the trial, without your presence at times. That's

10 the issue of mobilisation. Doctor, do you know in Prijedor or in Bosnia

11 in 1991 how many mobilisation call-ups were there?

12 A. I could not give you an answer as far as the numbers are concerned

13 because I cannot talk about what I do not know. Because if I do not know,

14 then that's not the truth.

15 Q. I appreciate that very much, as does everyone else in this room.

16 So is it fair to say that you don't know whether there was one, two, or

17 more than two mobilisation call-ups in the area in 1991? Would that be

18 correct?

19 A. I was simply not interested in that, and I did not register

20 something like that in my head at all.

21 Q. Thank you. Directing your attention, if we may, to approximately

22 April 30th, 1992, which is I believe the time-line that the parties may

23 ultimately agree as the day of the takeover of Prijedor by the Serbs.

24 With respect to that date, you testified that you were awakened in your

25 home by a friend who called you and that then you woke up your husband and

1 shared the news with him. Correct? Do you remember that?

2 THE INTERPRETER: The witness is nodding.

3 MR. OSTOJIC: I'll direct her.

4 Q. Doctor, if I may --

5 A. Yes, that's correct.

6 Q. Subsequent to that discussion -- the telephone call with your

7 friend and discussion with your husband, can you tell us whether or not

8 your husband proceeded to go to the radio station and give an announcement

9 at all?

10 A. No, he didn't go to the radio station, but he stayed at home. As

11 I said, he was given a decision that he was on an annual leave, that he

12 was actually taken from his position. And during that day, I was told -

13 and because I was working I didn't listen to the radio because in the

14 hospital I couldn't do that - I heard that he was invited to come to the

15 radio station and that he said something there. But I cannot even

16 paraphrase the content of what he said because I didn't think it was

17 anything important at that time.

18 Q. All right. And thank you for the correction. Is it fair to say

19 that it's your understanding that on April 30th, your husband, Mr.

20 Cehajic, was invited to come to the radio station, and that he, in fact,

21 did come to the radio station and was asked questions or gave a statement

22 on the radio?

23 A. It could be, but I cannot state that because I do not know. At

24 that time, I did not check it with him because if he was, he was there,

25 but this is not my truth.

1 Q. Did you, Doctor, at any time check that with your husband

2 subsequent to April 30th, 1992?

3 A. No, I didn't, because from the 30th of April to the 23rd of May,

4 he was at home. And I used to go to work. I would come back, and then we

5 would discuss our things. But we tried to avoid the reality, so we did

6 not talk much about it. And I had a feeling, and now I have a feeling,

7 that he wanted to comfort me, that nothing was terrible, or at least he

8 thought it wasn't. So even there was a fear, but we did not talk about

9 it. He did not tell me anything about it.

10 Q. And I understand that, Doctor. Thank you for those comments. Is

11 it fair to say to this day that you don't know what it is, if anything,

12 that your husband may have said on that radio programme on or about April

13 30th, 1992?

14 A. I don't know what he said. I did hear something, that they had

15 invited him, and that they at the beginning were disturbing father-in-law

16 and that he probably left the flat at some point. I do know that, and

17 that was something that hurt me because why to look for him at my

18 daughter's house or at her father-in-law's house? But the content, what

19 he had to talk about, I do not know.

20 Q. Fair enough. If I may turn also to that date, you mentioned that

21 you heard an announcement on the radio. And when asked, on page 67 of

22 yesterday's transcript, line 22, I believe, you stated upon questioning by

23 the Office of the Prosecutor that at this point you cannot recall the

24 contents of that announcement in detail. Correct?

25 A. Yes. But roughly speaking, I could say something.

1 Q. Okay. We'll give you that opportunity. What I'd like to know,

2 though, is that if you remember whether or not the speaker who gave the

3 announcement, whether or not it was a male or female speaker?

4 A. I think it was a woman, because in all that fear, I do not know

5 and I do not want to talk about this announcement because I did not

6 register its content. But I know that the power was -- the authority was

7 taken over without any shooting. I thought it was a female voice in that

8 announcement.

9 Q. And to this day, do you know who that voice belongs to, who the

10 person is that made that announcement? Do you know?

11 A. I have to be honest. I know what then it was but I don't

12 remember. It is something that I have heard from others. I know Ganic

13 Alija has read the announcement, that Dr. Stakic had said something

14 beforehand, but I didn't hear it. This is what I want to say. What I'm

15 talking about today is a different thing. I cannot testify because this

16 is not what I had heard then.

17 Q. And Doctor, that's exactly -- we're asking only for the testimony

18 and only the recollections that you personally have. And as you have in

19 your statement and as you have in the questioning by the Office of the

20 Prosecutor, if you would be kind enough to indicate for us when it is

21 something that would be considered hearsay or something that you heard

22 from others. I'm particularly only interested in that which you've heard

23 and that which you've experienced.

24 A. I personally heard, as far as I remember now, that that was a

25 speaker, someone of the speakers. And what else there is, I didn't even

1 talk about it.

2 Q. And is it fair to say that it was that same voice that you heard

3 repeatedly, although you resisted from listening to the radio for a number

4 of reasons, your personal convictions and disappointment in the situation,

5 as well as the fact that there was a lack of electricity and power in

6 Prijedor subsequent to April 30th, 1992?

7 A. Yes, that's how it is. And I had said that before.

8 Q. You also testified, I believe yesterday, that the document that

9 your husband, Mr. Cehajic, received on April 30th, 1992 regarding his

10 discharge, for lack of a better term, you did not review it or you did not

11 see that document. Correct?

12 A. Yes.

13 Q. But to this day, is it fair to say that you don't know who signed

14 it? Correct?

15 A. Yes. Well, since I didn't see the document, I didn't see the

16 signature either. I never said anything to that effect.

17 Q. No, and I'm not suggesting, Doctor, that you did. I was just

18 merely trying to inquire as to whether you learned from others who may

19 have signed it and in what capacity they signed it. So if I may, and I

20 know they may seem trivial questions for you, and I apologise; I'm trying

21 to speed it up as much as possible. Is it fair to say that you don't know

22 who signed that document that we're referencing, the letter that your

23 husband received on or about April 30th, 1992?

24 A. He got it while I was at work on the 30th of April, and he told

25 me: "This is what I got. I have been replaced. I'm on leave now." I

1 didn't check anything. I didn't pay much attention to it so I didn't see

2 who signed the document. I didn't know it would turn out to be this

3 important. After a while, when these people came to the house to get

4 these things, they took this document as well. If it had stayed in the

5 house longer, I would have probably looked at it again, but I didn't. So

6 all I know is what actually my husband had told me at this moment. He had

7 no reason to lie to me or to tell me anything that would not be true. He

8 did not say who signed the document. He just said that Dr. Stakic was

9 appointed to such and such position, but we didn't discuss the signature.

10 Q. No one's making that suggestion at all, Doctor.

11 With respect to the period of April 30th, 1992 through May 23rd,

12 1992, can you tell us generally, other than going to work, what were some

13 of the activities that you and your husband engaged in? Other than you

14 going to work, what did your husband do during that time period?

15 A. He was at home. He was reading. I know that he told me that he

16 had gone out a couple of times for a walk in the vicinity of our house

17 before I arrived. When I came home, we spent the time together. Whenever

18 we had free time, we always enjoyed spending it together. The two of us

19 were enough to one another. We did not discuss politics or what was going

20 on, because both of us could clearly see what the situation was and were

21 waiting to see what would happen.

22 Q. Do you know if your husband engaged in any or participated in any

23 meetings with members of the SDS at that time, again, April 30th through

24 May 23rd, 1992?

25 A. I don't think he did, but again, this is just my opinion, and

1 probably the best answer would be that I don't know.

2 Q. That's fair. Do you know if during that time period April 30th

3 through May 23rd, 1992, your husband had or held any meetings with members

4 of the Municipal Assembly or the Executive Board?

5 A. I don't know that either.

6 Q. Do you know if at that time, April 30th through May 23rd, 1992,

7 your husband held or attended any meetings with the SDA?

8 A. I don't know.

9 Q. Do you know if during that time period your husband had any

10 meetings with Mirza Mujadzic, who is the president or identified

11 previously, I believe, by yourself - and correct me if I am wrong - as the

12 president of the SDA in Prijedor?

13 A. While I was at home, no. But during those eight hours that I

14 would spend at work or when I was on duty, and therefore, 24 hours absent

15 from my home, I don't know. But when I was present at home, no.

16 Q. That's all we're trying to find out, is what you knew and what you

17 observed. Thank you, Doctor.

18 Is it -- strike that. Do you know if during the period of April

19 30th through May 23rd, 1992, your husband was ever arrested or detained?

20 A. No, he was not. Until the 23rd of May.

21 Q. Right. And I appreciate that. So it's fair to say from April

22 30th up until May 22nd, 1992, your husband was never detained or

23 arrested. Correct?

24 A. [No interpretation]

25 Q. And we know, as you shared with us, on May 23rd, your husband was

1 arrested for the first time. Is that correct?

2 A. Yes.

3 MR. OSTOJIC: If I may direct a comment or a question, I should

4 say, I apologise, to the Court. On line 24, there seems to be no answer,

5 Your Honour, to the question that commenced on line 21. So I'm not sure

6 if I should restate the question, just so that we have a record.

7 JUDGE SCHOMBURG: If I remember correctly, the witness nodded to

8 your question.

9 MR. OSTOJIC: I'm sorry. I didn't see that. I was looking at my

10 notes. If I may ask that question again, Your Honour, to get a verbal

11 response. May I, Your Honour? Thank you.

12 Q. Doctor, I'm going to ask you a question that you've already

13 probably answered, but just for our clarification, is it fair to say, from

14 April 30th up until May 22nd, 1992, your husband was never detained or

15 arrested? Correct?

16 A. No, not to my knowledge.

17 Q. If I may just return to an issue that we briefly discussed. We

18 talked about mobilisation, if you remember, earlier this afternoon or

19 several minutes ago. And I recognise that you don't know how many

20 mobilisations there may have been in 1991. Do you know, Doctor, what the

21 position was of your husband in 1991 during the mobilisation with respect

22 to whether or not Bosnian Muslims should participate in the call-up for

23 mobilisation during the war against Croatia?

24 A. I know that.

25 Q. Can you share that with us, please.

1

2

3

4

5

6

7

8

9

10

11

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

13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

1 A. His position was that one should not go to fight war in Croatia

2 because our state was Bosnia and Herzegovina, and Croatia was a different

3 state. And he thought that we should not go -- we or anybody else, for

4 that matter, should not go to Croatia to fight a war there. I know that

5 this was his position.

6 Q. Was that his position as a member of the SDA or as the president

7 of the Municipal Assembly of the municipality of Prijedor in 1991?

8 A. I don't know what his position was as a member of the SDA. I

9 never attended their meetings. But his personal conviction was that we

10 should not go to Croatia to fight a war there.

11 Q. Can you tell us if during the war in Croatia your husband

12 expressed his view that the Muslims and Croatians only should not join the

13 war in Croatia, and he expressed this view continuously?

14 A. No, he didn't think that. He was of the opinion that no one

15 should go to war. As far as I know, this is not -- this was not his view.

16 Q. Also tell us if this was his view or not: Did your husband tell

17 the non-Serbs not to fight against the Croats? Was that ever the view of

18 your husband?

19 A. I don't know. I cannot confirm that. I know that it was his

20 position that no one should go to war in Croatia, be it a Croat, a Serb,

21 or a Muslim. I don't know about the rest.

22 Q. At that time, you mentioned that -- or at that time in 1991, was

23 Bosnia-Herzegovina still a part of what's known as the former Yugoslavia?

24 Were they still part of that federation?

25 A. No. As a result of a referendum which was held in March - I don't

1 remember the exact date, it could have been the 27th of March - it became

2 an independent state; that is, the majority of the citizens of

3 Bosnia-Herzegovina had expressed already their wish to become independent,

4 as was the case with other republics of the former Yugoslavia. As for the

5 recognition, well, we know when it happened, the recognition by the United

6 Nations.

7 Q. My question, Doctor, if I may, and I apologise if I was convoluted

8 in the questions or unclear, the issue that you're talking about, the

9 independence of Bosnia, occurred in 1992, did it not? If you know.

10 A. Yes, in 1992. You asked me about 1991.

11 Q. Right. And it was my fault, and I apologise for that. With

12 respect to 1991 and the mobilisation issue in particular, I think in one

13 of your answers you shared with us the sentiments of your husband, but in

14 part of your answer, I thought - and I may have been mistaken, and you can

15 help clarify that - you are saying that Bosnia is a separate state and

16 they shouldn't go for that reason. Regardless of that, at that time, in

17 1991, do you agree with me that Bosnia was still part of the federation

18 known as former Yugoslavia, or currently known as former Yugoslavia?

19 Correct?

20 A. The former Yugoslavia, yes, but it was a federal state. The

21 former Yugoslavia was made of several federal states: There was a state

22 of Bosnia and Herzegovina, and then a federal state, the former

23 Yugoslavia. If that is what you had in mind, then, yes.

24 Q. And the former Yugoslavia still continued to have a military; do

25 you know? Or if you don't, you can share with us that you don't.

1 A. Yes, I know that it did, even after 1992. After the referendum,

2 and after all these events, the Yugoslav People's Army was still in

3 Bosnia. I know that.

4 Q. In 1991, would it be fair to identify respectfully the politicians

5 in the Prijedor municipality as local politicians as opposed to federal

6 politicians or republic politicians or national politicians?

7 A. I wouldn't describe it that way.

8 Q. How would you describe the local politicians who were

9 representatives and members of the Municipal Assembly of Prijedor in 1991

10 and 1992?

11 A. I don't see what you mean, what kind of definition you have in

12 mind. I don't understand your question, I'm afraid. I didn't have any

13 specific definition for them, I must say.

14 Q. That's fair. I'm not looking necessarily for a definition, but

15 really a description from your perspective as being the wife of the former

16 president of the Municipal Assembly of Prijedor. And respectfully, I

17 don't want to minimise what your husband has done or the other politicians

18 in Prijedor, but I must ask you this question: Was the position of

19 president of the Municipal Assembly of Prijedor a local political

20 position?

21 A. I don't think I know the answer to that question. It was probably

22 a local one, but I don't know. I don't have an answer. I don't know.

23 Q. Do you know if there were any political offices that fell below

24 the office of the representatives of the Municipal Assembly of Prijedor in

25 1991 and 1992?

1 A. There must have been, I'm sure. I'm sure that there was a

2 hierarchy, as it is customary within a municipality.

3 Q. And do you know what the hierarchy was going up instead of going

4 down from the Municipal Assembly of Prijedor in 1991 and 1992?

5 A. I believe that the hierarchy went from Prijedor through Banja Luka

6 all the way up to Sarajevo.

7 Q. And if you know, where did that hierarchy proceed after Sarajevo

8 in 1991?

9 A. I don't know for sure. I know what the former system was. Well,

10 if we're talking about the former state, the former Yugoslavia, then the

11 end of this hierarchy would be in Belgrade.

12 Q. With respect to the organs that were in the Prijedor municipality,

13 were there some republic or federal institutions in Prijedor in 1991 and

14 1992?

15 A. Where, in Prijedor? I'm sorry, I missed the beginning. Are you

16 referring to Prijedor?

17 Q. Yes, the Prijedor municipality.

18 A. I don't know the answer to this question.

19 Q. Do you know if there were any federal governmental institutions

20 that were in the Prijedor municipality in 1991/1992?

21 A. I don't know. I think I already answered this in response to your

22 previous question. I don't know.

23 Q. Thank you. I apologise if you had.

24 Let me change the subject, if I may, a little bit. You worked at

25 the hospital, or as you call it, the balisi [phoen] in Prijedor for many

1 years. Can you tell me the structure of that hospital? Was it

2 affiliated or connected to other institutions within and outside the

3 municipality of Prijedor?

4 A. Yes, I know about that. The hospital was part of a larger medical

5 institution, Dr. Mladen Stojanovic Clinic, which consisted of several

6 departments and my hospital was one such department. There was a

7 pharmacy, and then a local health centre in Prijedor, the institute for

8 occupational medicine in Prijedor, the health centre in Sanski Most and

9 the health centre in Bosanski Novi. And also, a unit, administrative

10 unit, in Prijedor, which all made up a whole which was called Dr. Mladen

11 Stojanovic medical institution which was, in turn, part of an even larger

12 organisation, SOUR, as we called it at that time, which was an umbrella

13 organisation comprising all medical institutions in Prijedor. And our

14 hospital was part of that larger organisation.

15 Q. The municipalities of Bosanski Novi and Sanski Most, are they

16 separate and distinct from the municipality of Prijedor?

17 A. Politically speaking, yes, they were separate, but the medical

18 institutions were connected.

19 Q. If you know, and I know that you were the -- one of the directors

20 at the hospital for a period of time but I don't know for sure if you

21 would know the answer to this question: Do you know if during that time

22 period what, if any, influence the politicians or the people from the

23 municipality of Sanski Most and Bosanski Novi had on the institution of

24 the hospital or the clinics at which you served?

25 A. At that time, it did not have any significant influence. We

1 constituted a medical organisation which did not -- which was not exposed

2 to any such influence, no.

3 Q. Do you know, Doctor, if there were any other areas which also had

4 these associations between various municipalities?

5 A. No, I don't know. I know about our work organisation, and I told

6 you about that.

7 Q. And can you tell us, if I can call it an "association," can you

8 tell us how long these associations between the various municipalities

9 were in existence prior to 1992?

10 A. In the area of health, I don't know what year it was - I don't

11 remember - but I know that roughly 350.000 residents were under the

12 jurisdiction of this medical institution which had its seat in Prijedor.

13 Q. Do you know a gentleman by the name of Risto Banovic?

14 A. Yes, I do. He was one of the managers. He was actually the

15 manager of this work organisation, this association, at the time I was

16 manager at my hospital.

17 Q. So was he the manager or the director, or can we use the terms

18 interchangeably?

19 A. He was a director. "Manager" is a more general term. He was the

20 director of this work organisation.

21 Q. And do you know whether or not Mr. Banovic in 1992 was discharged

22 and relieved from his duties as director?

23 A. Yes. Yes, he was. He told me on -- over the telephone, when I

24 asked him whether anyone else can receive my salary on my behalf, he said

25 that he no longer had this function and that he was no longer in a

1 position to approve this.

2 Q. Can you share with us, if you recall, the date of that telephone

3 conversation or the approximate month and year that it may have occurred?

4 A. Maybe in the month of June. In the course of June.

5 Q. You are talking about June of 1992. Correct?

6 A. Yes, yes, 1992.

7 Q. Where was Mr. Banovic located in approximately June of 1992?

8 Where was his office, home, position?

9 A. I don't know. I dialed the number of this working

10 organisation -- work organisation, so he was probably still at his duty

11 station where he worked before, just that he was no longer the director.

12 Q. And where was that, ma'am? Was that in the municipality of

13 Prijedor or a different municipality?

14 A. In the municipality of Prijedor in the Urije neighbourhood, near

15 the new hospital where there was an administration building.

16 Q. Can you tell me, if you know, what the ethnic background is of Mr.

17 Risto Banovic, the person we are discussing here?

18 A. He was a Serb.

19 Q. Did you at any time inquire of Mr. Banovic why he got discharged?

20 A. No, I did not. But he could probably -- the case was probably

21 that he could no longer be trusted. He could go on working, but he could

22 no longer be a director. Unlike myself, who was not able either to work

23 or be a director. He was a Serb. He was allowed to continue working, but

24 he could no longer be a director. In any society, including the communist

25 system, people who were trusted or considered to be suitable were on

1 managing positions.

2 Q. If I may now switch to a separate issue, and that was the

3 interrogation that you had to regrettably undergo on or about June 11th,

4 1992, according to my notes. May I ask some questions about that

5 interrogation, please?

6 A. Yes. Yes, it was on the 11th. The 11th of June.

7 Q. Right. Thank you. I have that.

8 Just briefly, and I don't want to recollect all of that, because I

9 know obviously it has left an impact, tragic, on you, so if you can just

10 patronise me for a moment and let me just ask a couple questions on this

11 issue. You mentioned that the interrogator himself seemed to be

12 unorganised and didn't really know what he was asking you or what

13 information he wanted to obtain from you. Would that be fair?

14 A. Yes, more or less, because he didn't ask any specific questions.

15 And I spent quite some time there with him. But he never asked any

16 significant question as to the reasons of my being there.

17 Q. So would it be fair to conclude, and you help us with this, if you

18 can, that the questions were not in any way, shape, or form scripted?

19 A. I don't know whether they had been prepared in advance, but he

20 didn't ask any concrete, specific questions. I am simply unable to convey

21 to you what it was that he wanted from me, and I don't know to this very

22 date. But obviously, he knew everything about me, so one can perhaps

23 argue that he had been prepared. He knew that I had been a member of the

24 League of Communists, that I had been a member of the local committee of

25 the party. He knew about my family, about my brother, what kind of

1 function he had. He knew all about that.

2 There's six of us in my family, and out of six of us, five have

3 university degrees. My brothers, they all held high, managing positions.

4 My brother was an economist, a financial director of the mines throughout

5 that period of time. I have another brother who is an engineer. My

6 sister is also highly educated. And he knew all about that. He even knew

7 about my father, what he had done during the Second World War, that he

8 supported Partisans. So he was well aware of all this, and he intimated

9 this knowledge to me. And in a way, I felt that he wanted to facilitate

10 things for me at that moment.

11 Q. In any event, despite the fact that he may have known a lot about

12 it, is it fair to say that the questions that he asked, according to what

13 you felt, were not concrete, were not precise, and seemed to have no

14 bearing whatsoever on the purpose for which they detained you and brought

15 you for interrogation?

16 A. Well, my feeling was that there was no specific reason that I had

17 been brought there. They obviously didn't have anything to ask and didn't

18 have anything against me, anything on the basis of which they could have

19 accused me of anything.

20 Q. Thank you. If I may just turn briefly to another issue, and that

21 is you state that in August of 1992, you met Simo Miskovic with a friend

22 of yours who was at one time, according to your testimony, the president

23 of the SDS. Do you remember that testimony?

24 A. Yes.

25 Q. Thank you. Did Mr. Miskovic, during that one conversation that

1 you inquired about your husband with your friend, did he or did he not

2 tell you at that time that, "We do not have any control over this any

3 more"?

4 A. Yes, that is what he said. When he said "we," I understood him to

5 mean the SDS, because he had some kind of function at the SDS. Whether I

6 accepted his answer and trusted him is another matter, but those were his

7 words. That's the way he put it.

8 Q. I'd like to, if I may, turn to another issue, and that is, you

9 mentioned that in August of 1992, you used your telephone to call the IRC.

10 Correct?

11 A. I didn't call them; I was in Banja Luka. I visited Banja Luka in

12 1992.

13 Q. Okay. Let me ask you this: In May and June of 1992, is it fair

14 to say that you used your telephone and that it was operating?

15 A. Yes. It caused me a lot of problems because of various forms of

16 harassment. So at one point in time, I had to disconnect it in order not

17 to be disturbed.

18 Q. And in July, did your phone also work? Because I think you shared

19 with us at one point that your daughter may have called in connection with

20 your grandchild. Is it fair to say that your phone was operating in July

21 of 1992?

22 A. Yes, yes. My phone was operating all the time. It is true that

23 from time to time, the lines would be down with Banja Luka, for instance.

24 But when the line was functioning, my telephone was operating as well. I

25 talked to a friend of mine who was in Belgrade, who had gone to school

1 with me in Zagreb. Sonja Badham [phoen] is her name. She was a

2 journalist at the time. And I wanted her to get in touch with my son and

3 tell him that I was alive.

4 Now, I remember that sometime before that, we had celebrated the

5 anniversary of the high school prom, the 30th anniversary of the high

6 school prom, and I had this business card of hers, and I contacted her and

7 my son was able to learn that I was alive. I'm telling you this because I

8 was not cut off. I had my telephone operating at house.

9 Q. Thank you. And perhaps I shall just ask the more direct question,

10 and that's what I was getting to: My point was that in fact your

11 telephone was operating during the entire period of time, specifically,

12 the period from April 30th, 1992, up to and including September 5th, 1992,

13 when you departed Prijedor. Correct?

14 A. Yes, except from occasional disruptions, and when I, myself,

15 disconnected the phone when they harassed me. Yes, from time to time, the

16 line was disrupted, but I don't think that they had done it on purpose,

17 though it's a possibility.

18 Q. Sure, and anything is possible. I'll agree with you there. To

19 the best that you can recall, were these interruptions intermittent and

20 inconsistent and lasted for only short periods of time?

21 A. From time to time, we would have the connection with Banja Luka

22 but not with Sanski Most. But I was in the same situation as anyone else.

23 The line would be disrupted maybe for one day or two days.

24 Q. How about the electricity? Did you have access and was the

25 electricity operating for the entire period of time, from April 30th,

1 1992, through September 5th, 1992?

2 A. We were very often without electricity. There was a period of

3 time when I was not able to make myself a cup of tea or coffee, and I

4 didn't dare leave the apartment. There was a longer period of time

5 without electricity, and I tried to make some fire on the balcony to boil

6 the water for tea. But in view of everything else, it was a marginal

7 thing.

8 Q. Do you know, Doctor, the reason as to why there was lack of

9 electricity or lack of power in the Prijedor municipality during that time

10 period, April 30th, 1992 through September 5th, 1992?

11 A. No, I don't know the reason. Nobody told me, nor did I inquire.

12 I know that Serbs living in my building would go to other places where it

13 was possible to either make fire or cook something, and they would bring

14 this food from there, which is something that for me was not possible to

15 do.

16 Q. Is it fair to say that the Serbs who were living in your building,

17 having had to go to other places to either make fire or cook something,

18 also meant that there was lack of electricity for them in their apartments

19 as well? Correct?

20 A. Yes, yes. It would be impossible to cut the electricity only for

21 my household. There were about ten apartments in this building. They

22 couldn't disconnect my apartment only.

23 Q. Do you recall, Doctor, whether or not there were any electrical

24 disruptions or interruptions prior to April of 1992 in the Prijedor

25 municipality?

1 A. No, no. We had very rare disruptions, an insignificant number of

2 them. I mean, it's not something that I observed as being a problem.

3 Q. I just have a few more questions. I'm hoping to be able to wrap

4 up. Do you know of an incident that has been coined, at least in my mind,

5 in this Chamber, of an incident called the Hambarine incident that took

6 place on or about May 22nd, 1992? Are you familiar with that incident?

7 A. Yes, I do know about it.

8 Q. Thank you. Is it fair to say, Doctor, and just so that I

9 establish my time line and our time line for the Defence here, that in

10 fact your husband was arrested after the incident occurred on Hambarine on

11 May 22nd, 1992? Correct?

12 A. The arrest of my husband took place when there was -- the

13 Hambarine was attacked on the 23rd at 12.00, when there was this

14 ultimatum. And then I said at half past 3.00, he was arrested.

15 Q. I don't want to split hairs with you, and thank you for your

16 patience here today. My point is a little different. There was an

17 incident that occurred at a checkpoint in Hambarine on or about May 22nd.

18 As a result of that incident, there was what has been also called an

19 attack on the area of Hambarine. So I respectfully understand and accept

20 your testimony wholeheartedly as to the timing of your husband's arrest

21 vis-a-vis the attack on Hambarine. My question, although slightly

22 different, is: Do you know whether or not your husband was arrested

23 before or after the incident that occurred in Hambarine on May 22nd, 1992?

24 MS. SUTHERLAND: Your Honour, the witness has already sustained

25 that.

1 JUDGE SCHOMBURG: Sustained.

2 MR. OSTOJIC: May I proceed, Your Honour?

3 JUDGE SCHOMBURG: Of course.

4 MR. OSTOJIC:

5 Q. Is it fair, Doctor to state --

6 THE WITNESS: [Interpretation] May I say something?

7 JUDGE SCHOMBURG: Of course you may, if you want.

8 THE WITNESS: [Interpretation] When he asked me about this

9 incident, I didn't even mention it in my statement, but I know

10 incidentally because it is connected with it. I was on duty on the 22nd

11 of May, and I was at the hospital, and I came to the surgery where I was

12 present at an event where some reporters, journalists from Radio Prijedor,

13 were shooting on a videocassette a conversation with people who were in

14 the vehicle that later took place as an incident at Hambarine. I thought

15 that, as a witness, something would happen to me. I was scared that night

16 because I heard when this young man had said -- actually, two young men

17 were in the surgery who were slightly hurt, and the third was also hurt

18 much more. I didn't see him. They said he had gone to Banja Luka. These

19 two young men said that -- I did hear that, and I can witness if there was

20 this videocassette that we could see. I heard when he said, "We went to

21 Hambarine, we passed the guards, and they told us to stop. The driver who

22 had -- who was hurt stopped. And at some point, he suddenly started, and

23 they started shooting at us." This is what I had heard, this statement.

24 And there was no reason that my husband would have been taken or that he

25 would have been arrested for that.

1 When I heard that, I was scared because I knew that I was a live

2 witness of that, and later on people were talking about that all these

3 three young men were hurt, and I saw two of them who were not hurt at all.

4 And I really felt this as a necessity to say something about it because

5 you had asked me. I didn't think it was necessary to testify on this, but

6 since you have asked me, this is what I can tell you.

7 JUDGE SCHOMBURG: Thank you for that clarification. The Defence

8 may proceed.

9 MR. OSTOJIC: Thank you, Your Honour.

10 Q. On line 8, page 7 -- on line 8, page 78 of your testimony here

11 just moments ago, you state: "I didn't even mention it in my statement."

12 Can you tell me which statement you're referring to in which you didn't

13 mention this what you just described to us?

14 A. There was a statement -- I don't know how many years ago, in what

15 year. Maybe it is present here. Maybe 1997. Somebody asked me

16 officially. This is what I meant.

17 Q. Do you know if in that statement of 1997, whether you mentioned

18 the incident at Hambarine at all?

19 A. I don't think I mentioned this.

20 Q. Okay. Do you know if in that statement of 1997, you mention

21 anyone by the name of Mr. Aliskovic?

22 A. Yes, maybe I did, if they had asked me about the 23rd of May.

23 Because on the radio, there was this ultimatum that a policeman named

24 Aliskovic ought to be handed over or Hambarine would be attacked. This is

25 how it was. And on that day, on the 23rd, at 12.00, because they probably

1 had not handed over this man, there was this attack on Hambarine.

2 Q. And finally, if I may ask you, with respect to Dr. Stakic, you

3 have had no personal contact with him. Would that be a fair

4 characterisation?

5 A. Yes. This could be said. He also knows that it was not either as

6 friends or as enemies. He was a colleague that I knew, and I did not know

7 much about him. I wasn't even interested because the situation was not

8 such as if I ought to know about him.

9 Q. Finally, is it also fair that you had no professional contact with

10 Dr. Stakic as well during any period of time, so no personal contact as

11 well as no professional contact. Correct?

12 A. Yes, it is possible because I worked -- I was very often on duty

13 at hospital, and maybe he sent a child who I actually received. I don't

14 remember. Maybe we were in some contact in such a way, because there

15 were -- he worked in Omarska. He checked on adults and on children. He

16 may have sent some child to the hospital. He might have referred a child.

17 This was what the professional connection was. We may have been at some

18 conferences together where we gave speeches, because this is what

19 physicians and doctors do. This is where we might have seen each other.

20 But this was not such an important thing to be mentioned.

21 Q. But Doctor, as far as you know, sitting here today, based on the

22 recollection you have today, you don't have any recollection of ever

23 interacting professionally with Dr. Stakic. Correct?

24 A. Yes. Maybe he remembers. I don't remember. But he -- if he

25 could remind me, maybe I would remember myself.

1 Q. With your approval, and the Court's, I do have a couple follow-up

2 questions if you don't mind, although I indicated it might be my last

3 question.

4 MR. OSTOJIC: If I may, Your Honour.

5 Q. Doctor, may I ask you just a couple more questions. Thank you.

6 Doctor, just going back briefly to your tenure in the hospital,

7 who provided the payments and how was the hospital financed in 1991 and

8 prior?

9 A. We had the fund of the health protection. Through the fund, we

10 all received our salaries. It was actually allocated to different basic

11 organisations. So for associated labour, the head office was in Banja

12 Luka, but this was a branch office in Prijedor, and this is how the

13 administration of the health organisation was managed in general.

14 Q. And who, if you know, contributed the funds for the operation of

15 the health system and your hospital in Prijedor?

16 A. It went from our personal salaries, and it was collected in the

17 fund and it was later allocated on the basis of some contracts which were

18 made annually. I was very often present when these agreements were made

19 in order to decide.

20 Q. But who gives you the money which you would decide to distribute

21 to the various parts and personnel at the hospitals? Where do you get the

22 money from?

23 A. I said from the fund, and then from the fund to the bank, and then

24 we allocated the money within our individual basic organisations of the

25 so-called associated labour. Maybe I did not understand your question

1 properly. But if you want to know anything else, I will tell you.

2 Q. It was probably a poor question, and let me just try one last

3 time. And if I don't understand it or if you don't, then I'll move on to

4 something else. The fund that holds the money, who puts the money in that

5 fund? Where does that money come from? Does it come from a municipal

6 assembly of any sort? Does it come from more than one municipal assembly?

7 Does it come from a republic? Does it come from a federal government, or

8 does it come from all portions of those four, if you know?

9 A. I will tell you. The main source were the personal salaries,

10 regardless of which institution, health system or everywhere. It was

11 taken from each person. It went to the fund, so these were the

12 contributions. It was named differently. At some point, it was a fund or

13 a health insurance. And according to that, the main part would come from

14 that source. There were also some individual parts. We would be given

15 money from different companies, from the coal mine, from the fabrika, and

16 the municipality was the one who actually took care of all that. But

17 these were not the permanent sources. It may have been just temporary

18 sources. Whether the municipality contributed, I don't know. Yes, they

19 probably did, because there was this compulsory insurance for the socially

20 deprived persons, but these were all very small amounts. And the largest

21 amount came from the fund of the health system or health insurance fund.

22 I hope I have answered correctly, sufficiently.

23 Q. You have. Thank you, Doctor. Where is the seat of this fund?

24 A. In Prijedor was a branch office, and we used to say that the main

25 office was in Banja Luka where all the money came to. And then everything

1 was later on distributed to different municipalities and individual health

2 organisations.

3 Q. Doctor, thank you very much. I have no further questions

4 MR. OSTOJIC: I have no further questions. Thank you, Your

5 Honours.

6 JUDGE SCHOMBURG: Are there any questions in re-examination?

7 MS. SUTHERLAND: Yes, Your Honour. I have two matters. I don't

8 know -- I think it will take longer than two minutes.

9 JUDGE SCHOMBURG: We would have I think for additional five

10 minutes. Would the interpreters, in the interest of the witness, be

11 prepared that we proceed 12 minutes sharp? I see nodding. Okay. Let's

12 try to be short.

13 Re-examined by Ms. Sutherland:

14 Q. Dr. Cehajic, in cross-examination, you were asked questions about

15 your husband's media statements. To your knowledge, did your husband ever

16 give any advice or did he have a position regarding resistance or armed

17 resistance to the SDS?

18 A. Not that I know. I think that he didn't, but I do not know. I do

19 not know of any such statements that he would have made.

20 Q. The other area you were questioned about, or another area, you

21 were asked about your phone being in operation between the time 30th of

22 April until you left Prijedor. You answered that the phone -- you

23 disconnected the phone a number of times because it caused you a lot of

24 problems because of various forms of harassment. Can you explain to the

25 Court --

1 A. Yes.

2 Q. -- what you meant by "various forms of harassment"?

3 A. I will tell you one thing that is probably the most crucial one,

4 but there were constant harassment. There was one thing that disturbed me

5 a lot. There was a telephone call from Prijedor. A telephone rang one

6 day. And a person said, "I'm Mira Kuruzovic." Mira Kuruzovic was, I

7 understood, the wife of Mr. Kuruzovic, who was the head of the camp at

8 Trnopolje. And she told me: "You need to give me deutschmark." And I

9 asked, "Why do I need to give you deutschmark?" She said, "Because you

10 owe me from many years ago when we travelled to Poland." And she said the

11 following: "You were the last. We sat in the first seats. You sat in

12 the first seats, and I sat on the last one. And I paid for the customs

13 duty and you didn't. And this is why you have to give me the money."

14 And I answered -- I did know Mira. She was from Prijedor. She

15 even used [as interpreted] in the health system. I said "Mira, I don't

16 have any deutschmark." And she said, "I want you to send me or leave it

17 in the cashiers in a shop of a man -- salesman called Huran [phoen].

18 There's a man who works there. You bring it there and leave it." And I

19 said I didn't have any money. But she kept calling me.

20 And then at once, I told her that I had some money in the bank,

21 and I wasn't even aware how much. And I said: "Mira, if you want, I

22 shall go to the bank and draw that money, but I don't have deutschmark."

23 She said she didn't want the local money, she wanted deutschmark. And she

24 also said that that was not enough. And of course, I had to disconnect my

25 telephone because of such harassment. And one day, I asked my neighbour

1 to help me because he had always been very kind to me. And at that time,

2 for me, it was enough that somebody just said "hello" to me because it was

3 a different time. And he told me: "Okay, I will try to help you." And I

4 really did see that he meant it.

5 And at some point, he remembered that she was the wife of

6 Slobodan Kuruzovic and that I was the wife of Muhamed Cehajic and that

7 something could be attributed to you because this will be by telephone.

8 But I shall see what can be done. He mentioned the Crisis Staff, and he

9 said he would see what he could do. So it was on the stairway when he was

10 just passing by me. And really, afterwards, this woman did not call any

11 more, and this is how all my troubles stopped and ceased to exist.

12 Q. Just a couple of questions on that. Did you, in fact, buy any

13 goods in Poland which required you to pay customs?

14 A. No, I didn't buy anything. We went because of an excursion, the

15 professors of the high school, and they took their wives with them and

16 some friends. I didn't buy anything, and neither did I have to pay the

17 customs duty. Whatever I had seen there, I had at home, so I didn't buy

18 anything and I didn't have to pay any customs duty. It was such an

19 unimportant moment that I did not consider would be the reason for someone

20 to ask me and harass me by asking money for that.

21 Q. Before your neighbour was able to contact the people he contacted

22 in order for these phone calls to be stopped, on approximately how many

23 occasions did Mira Kuruzovic, the wife of Slobodan Kuruzovic, telephone

24 you?

25 A. I think it happened several times, many times. I did not count,

1

2

3

4

5

6

7

8

9

10

11

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

13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

1 but I'm sure quite a number of times that she had -- that she called me

2 because she kept asking, "You still don't have the money. You still

3 haven't collected my money." Had I had the money at that point, I

4 probably would have given it to her. The money that I later paid for my

5 departure, it was not with me at the time. It was at my family house in

6 Ljubija. And only later I managed to get that money. Had I had it at

7 that point, I probably would have given it to her.

8 JUDGE SCHOMBURG: Sorry. I have to interrupt now. I thought

9 there would be only two questions by the OTP put forward, but now it

10 doesn't make any sense. We have to answer the questions from the Judges.

11 And would it be possible for you to come back tomorrow morning at 9.00,

12 because -- I know it's really difficult, but we have to consider the

13 interest not only of the interpreters but also there is another case

14 scheduled starting in 20 minutes from now. And therefore, I have to

15 apologise, but we really have to come back to the one or other question

16 still open, because your statement is really of utmost importance for all

17 of us, and we won't forget to ask you the remaining questions. You gave

18 numerous insights today, and I hope this will continue tomorrow. Thank

19 you.

20 The Court stands adjourned until tomorrow, 9.00.

21 --- Whereupon the hearing adjourned at

22 1.51 p.m., to be reconvened on

23 Thursday, the 16th day of May, 2002,

24 at 9.00 a.m.

25