Tribunal Criminal Tribunal for the Former Yugoslavia

Page 1502

 1                           Tuesday, 20 November 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.00 a.m.

 5             JUDGE DELVOIE:  Good morning to everyone in and around the

 6     courtroom.

 7             Mr. Registrar, could you call the case.

 8             THE REGISTRAR:  Good morning, Your Honours.  This is case number

 9     IT-04-75-T, the Prosecutor versus Goran Hadzic.

10             JUDGE DELVOIE:  Thank you.  May we have the appearances, please,

11     starting with the Prosecution.

12             MR. STRINGER:  Good morning, Mr. President and Your Honours.

13     Douglas Stringer, Alex Demirdjian, Uros Zigic, and Case Manager

14     Thomas Laugel for the Prosecution.

15             JUDGE DELVOIE:  Thank you.

16             For the Defence, Mr. Zivanovic.

17             MR. ZIVANOVIC:  Good morning, Your Honours.  Zoran Zivanovic and

18     Christopher Gosnell for the Defence of Goran Hadzic.

19             JUDGE DELVOIE:  Thank you very much.

20             Can we bring the witness in, please.

21                           [The witness entered court]

22             JUDGE DELVOIE:  Good morning, ma'am.

23             THE WITNESS: [Interpretation] Good day.

24             JUDGE DELVOIE: [Microphone not activated] Thank you for coming

25     today to assist us with your testimony.  First of all, do you hear me in

Page 1503

 1     a language you understand?

 2             THE WITNESS: [No interpretation]

 3             THE INTERPRETER:  Could Judge Delvoie's microphone please be

 4     switched on.

 5             JUDGE DELVOIE:  I'm very sorry.

 6             THE WITNESS: [Interpretation] Rakic, Gorana.

 7             JUDGE DELVOIE:  Thank you.  And your date of birth, please.

 8             THE WITNESS: [Interpretation] 12th of November, 1956.

 9             JUDGE DELVOIE:  And what is your ethnicity?

10             THE WITNESS: [Interpretation] I am a Serb.

11             JUDGE DELVOIE:  Thank you.  You are about to read the solemn

12     declaration by which witnesses commit themselves to tell the truth.  I

13     have to point out that that solemn declaration that you are about to make

14     does expose you to the penalty of perjury should you give untruthful or

15     misleading information to this Tribunal.  Could you now please read the

16     solemn declaration.

17                           WITNESS:  GORANA RAKIC

18                           [Witness answered through interpretation]

19             THE WITNESS: [Interpretation] I solemnly declare that I will

20     speak the truth, the whole truth, and nothing but the truth.

21             JUDGE DELVOIE:  Thank you, Ms. Rakic.  You may be seated.

22             THE WITNESS: [Interpretation] Thank you.

23             JUDGE DELVOIE:  Your witness, Mr. Demirdjian.

24             MR. DEMIRDJIAN:  Thank you, Your Honours.

25                           Examination by Mr. Demirdjian:


Page 1504

 1        Q.   Good morning, Ms. Rakic.

 2        A.   Good morning.

 3        Q.   I will be asking you first a few questions about your statement,

 4     and if you require any clarifications, don't hesitate to do so.

 5             MR. DEMIRDJIAN:  Could we display on the screen 65 ter 2379,

 6     please.

 7        Q.   Now, Ms. Rakic, it is correct to say that you gave a statement to

 8     the Office of the Prosecutor in May of 1999?

 9        A.   That's correct.

10        Q.   And that this statement was written in the English language and

11     was read back to you in the Serbian language before you signed?

12        A.   That's right.

13        Q.   Do you see this statement before you now?

14        A.   Yes, I do.

15        Q.   And at the bottom of the English version do you see your

16     signature?

17        A.   Yes, I do.

18        Q.   And it is correct to say that you signed every page of this

19     statement?

20        A.   That's right.

21        Q.   When you arrived in The Hague a few days ago, you were given a

22     copy of this statement translated in your language; is that right?

23        A.   Yes.

24        Q.   When you reviewed your statement I believe you had a correction

25     to one of the sentences; is that right?

Page 1505

 1        A.   Yes.

 2        Q.   Could we go there now.

 3             MR. DEMIRDJIAN:  It's at page 3 of both English and B/C/S

 4     versions.  And could we zoom into the top part, the very first paragraph.

 5        Q.   And I would like to take your attention to the last sentence of

 6     that very first paragraph which I believe begins with, "I am sure that my

 7     husband would get a weapon ..."

 8             Could you tell the Court what is the clarification you would like

 9     to make to this part of your statement?

10        A.   Well, as far as the statement is concerned, the one that was

11     drafted -- or, rather, translated, "I am sure that my husband would get a

12     weapon if there were weapon distributions in the village," my correction

13     is that my husband certainly would not have taken a weapon and brought it

14     home with him because we both disliked weapons and didn't want to have

15     any weapons in our house, either earlier on or subsequently.

16        Q.   Very well.  Putting aside this sentence that you have now

17     clarified for the Trial Chamber, is the rest of your statement accurate?

18        A.   It is.

19        Q.   And with regards to the answers that are recorded in your

20     statement, would you give the same answers in the court should you be

21     asked the same questions?

22        A.   Probably, yes.

23        Q.   Thank you.

24             MR. DEMIRDJIAN:  Your Honours, may I ask to admit -- tender this

25     statement, please.

Page 1506

 1             JUDGE DELVOIE:  Admitted and marked.

 2             THE REGISTRAR:  Your Honours, it shall be assigned Exhibit P272.

 3     Thank you.

 4             MR. DEMIRDJIAN:

 5        Q.   Ms. Rakic, I will now ask you additional questions relating to

 6     topics that are contained in your statement.  First of all, in your

 7     statement you indicate that you worked for banks in Osijek.  Could you

 8     explain to the Trial Chamber what was your educational background?

 9        A.   I completed secondary school, secondary school for economics.  I

10     worked in a bank in Osijek for 13 years.  I started as a trainee, and by

11     1990, I was in charge of the shift -- of a shift.  I supervised

12     20 employees.  So I was, in fact, a supervisor.

13        Q.   Very well.  Now in your statement - and I will skip in time a

14     little bit - you explained the situation in the summer of 1991 and at the

15     top of page 3 you explain that you left Erdut on the 20th of July, 1991,

16     and that you stayed with your aunt in Serbia.  Could you tell the Court

17     when you returned from Serbia?

18        A.   I returned on the 19th of August, 1991, from Serbia.

19        Q.   And upon your return, did you -- did you resume working?

20        A.   You mean in Osijek?  No, of course not.  I returned to the

21     village, and since the JNA was already in the village at the time we had

22     an obligation - I don't know how else to put it - to perform work duties

23     in the village.  Everyone had to perform certain duties on the basis of

24     what one had previously done in accordance with one's previous

25     profession.

Page 1507

 1        Q.   And what work obligation were you assigned to?

 2        A.   I was assigned work in the TO staff, the Territorial Defence

 3     Staff, and I had to work as an accountant in that staff.  It involved the

 4     work that was performed in the canteen.

 5        Q.   And before doing this work as an accountant, is it correct to say

 6     that you were also involved in the cleaning or the organising of the TO

 7     centre?

 8        A.   I personally wasn't involved in that.  I was expecting the work

 9     of an accountant, but other people who were there, other women who were

10     there did perform such work.

11        Q.   Thank you.  Could you explain to the Trial Chamber what was your

12     role or your function as an accountant?  What did you have to do on a

13     daily basis?

14        A.   I had to do the following.  As I have already said, it -- it was

15     a certain position that had to do with -- with the economy.  I had to

16     make a list of the various goods, various items needed for the canteen,

17     cooking items for the employees there.  Items for people who were

18     cleaning the centre, items for the employees who worked in the vineyards

19     and picked grapes.  So I had to make a list of all the various goods that

20     were needed and procured by that centre.

21        Q.   Very well.  You explain in your statement that your superior or

22     your boss was a man by the name of Dragomir Lastavica from Dalj; is that

23     right?

24        A.   Yes.

25        Q.   Okay.  I would like to show you now an image of this area, and if

Page 1508

 1     you could estimate to us the various locations of your offices,

 2     et cetera.

 3             MR. DEMIRDJIAN:  Could we explain 65 ter 6254.  That's at tab 21.

 4             Is that not on e-court?

 5        Q.   Ms. Rakic, we will return to this in a moment.  It appears that

 6     we are having some technical problems with the image.  I will skip to my

 7     next set of questions.

 8             Now you explain in your statement that Arkan arrived in

 9     September 1991 and that he came to your office and introduced himself.

10     Could you tell the Court how did he introduce himself exactly?

11        A.   He entered the office.  He very calmly introduced himself.  He

12     said he was the leader of the Serbian Volunteer Guards.  That's all.

13        Q.   Very well.  And when he arrived at the training centre -- well,

14     when you saw him on that day, where was he stationed following this

15     introduction?

16        A.   At the time he was stationed in that centre, in the

17     Territorial Defence centre.

18        Q.   And was -- you explain in your statement that he arrived with

19     around 30 men.  Was there a guard at the entrance of the training centre?

20        A.   I think there were men from the JNA reserve forces there prior to

21     his arrival.

22        Q.   And were they still there after his arrival?

23        A.   No.  The army withdrew to the premises of the primary school.

24        Q.   You also mentioned a man by the name of Radovan Stojicic in your

25     statement and that you saw him in Erdut.  I'd like to ask you if you saw

Page 1509

 1     him at the training centre.

 2        A.   I think I saw him on a number of occasions.  On a couple of

 3     occasions he came to attempt to reach certain agreements, something of

 4     that sort.  But in any event he did go to the centre.

 5        Q.   And when he came to the centre, did you know who he came to meet

 6     with?

 7        A.   I don't know.

 8        Q.   In your statement you say that he was stationed at the

 9     Saponija facility.  Can you tell us what the distance is between this

10     facility and the training centre?

11        A.   It's very close as the crow flies.  I think it would be between

12     800 metres and 1 kilometre.  In fact, 800 metres between the Saponija

13     facility and the Territorial Defence centre.

14        Q.   Very well.  In relation to the logistic aspects of the TO

15     centre's operation, I want you to look at a document that's going to

16     appear on the screen now.

17             MR. DEMIRDJIAN:  Its 65 ter 00445.  That's at tab 5.

18        Q.   Ms. Rakic, this is a military document that's in front of your

19     screen.  It is correct to say that you have never seen this document

20     before, right?

21        A.   Yes, that's right.

22        Q.   I'd like you to help us with some of the information included in

23     this report.  In the very first paragraph it indicates that 30 members of

24     the Serb national guard under the command of Arkan are based in the

25     training centre.  Now does that match with the information that you had

Page 1510

 1     at the time?

 2        A.   Well, I don't know whether there were 20, the 25, 30, or 35 of

 3     them exactly, but roughly speaking, yes, that's how many of them there

 4     were.

 5        Q.   In the next paragraph it is indicated that the centre had a

 6     capacity of 270 beds.  Now, I'm pretty sure you never had to count those

 7     beds but where would those be located?

 8        A.   Well, I assume beds and what we used to call a hotel -- well,

 9     they were dormitories before the 1990s there for JNA reservists.

10        Q.   And when you say "dormitories," do I understand this was part of

11     the centre itself in the compound?

12        A.   Yes.

13        Q.   In the next paragraph we see that in keeping with Arkan's order,

14     19 women from the village of Erdut were currently employed in the centre.

15     Can you tell us if this matches with the information you had at the time?

16        A.   I don't know whether there were 19 of them.  I think there were

17     fewer of them.

18        Q.   What was the information you had at the time in terms of numbers?

19     We don't have to be precise, but roughly, if you know.

20        A.   Well, perhaps there were up to ten of them.

21        Q.   The next sentence indicates that Arkan ordered a local TO to

22     provide transportation to work and back for these women.  Was this

23     something that you were aware about?

24        A.   No, I wasn't aware of that.

25        Q.   Very well.  The next paragraph indicates some of the equipment

Page 1511

 1     available at the centre, large quantities of infantry weapons, and there

 2     is a discussion about a huge warehouse.  Did you personally see a huge

 3     warehouse with weapons?

 4        A.   No, I didn't see that warehouse.

 5        Q.   Did you see Arkan and his men training at the training centre?

 6        A.   I didn't see them in the centre itself, but they would wander

 7     around, walk around the streets with their weapons and with --

 8             THE INTERPRETER:  What the witness calls "phantoms on their

 9     heads."

10             MR. DEMIRDJIAN:

11        Q.   Can you explain what the word "phantoms" means?

12        A.   They were caps, woollen caps, with slits for their eyes and for

13     their mouth.  Probably balaclavas.  Ski masks.

14        Q.   And just to be clear, you said earlier that they would walk

15     around the streets.  I assume you mean of the town of Erdut?

16        A.   Yes, that's what I said.  I would see them in the streets of

17     Erdut.

18        Q.   And how frequently would you see them in the streets of Erdut?

19        A.   Sometimes in the morning and in the afternoon.  In the course of

20     one day, I don't know how often.  In fact, quite a lot of time has passed

21     since then.  But at least once a day.

22             MR. DEMIRDJIAN:  And could we go to the next page, please.  This

23     is the last page of this two-page document.  And if we could zoom into

24     the bottom part.

25        Q.   In the paragraph before the last one, there is a description of

Page 1512

 1     the reaction of the inhabitants of the village of Erdut.  And the last

 2     sentence describes that the presence of Arkan in the centre and his

 3     conduct causes great discontent.  Is this something that you witnessed at

 4     the time, the reaction of the inhabitants of Erdut?

 5        A.   Well, I assume that their reactions were the same as mine,

 6     because when you see that a group of 20 men are walking around with

 7     ski masks on their heads and with weapons, well, that does not leave you

 8     indifferent.  You get out of their way.

 9             MR. DEMIRDJIAN:  Your Honours, may I tender this document.

10             JUDGE DELVOIE:  Admitted and marked.

11             THE REGISTRAR:  Shall be assigned Exhibit P273.  Thank you.

12             MR. DEMIRDJIAN:  I am informed that the aerial image is now

13     available.  Can we go back to 65 ter 6254, please, tab 21.

14        Q.   Ms. Rakic, we are going to have the aerial image on the screen

15     now.  And with the assistance of the usher I would like you to mark

16     certain areas.  Yes.

17             Do you recognise this image, Ms. Rakic?

18        A.   Yes.  Yes.

19        Q.   Can you tell the Trial Chamber what we are looking at?

20        A.   This photograph is an aerial photograph of the

21     Territorial Defence centre.  There is the new winery which is part of the

22     IPK, and there is the old part of the chateau which is also part of the

23     IPK, the industrial and agricultural enterprise.

24        Q.   Very well.

25             MR. DEMIRDJIAN:  Can the usher please help the witness.

Page 1513

 1        Q.   Ms. Rakic, could you, first of all, with the pen that will be

 2     provided to you in a moment, indicate where was the gate or the entrance

 3     of the training centre and these grounds that we see here?  You can mark

 4     it with a number 1.

 5        A.   [Marks]

 6        Q.   It's not very easy.  You could try again.

 7             MR. DEMIRDJIAN:  Can we erase it, Mr. Usher?

 8        Q.   The usher will now erase it so you can try again.  If you could

 9     put a number 1 and put a circle around it, if that makes it easier.

10        A.   [Marks]

11        Q.   Thank you.  Now to -- can you indicate to us where your office

12     was when you started to work in August of 1991 as an accountant?

13        A.   Do you want me to mark it and put number 2 next to it?

14        Q.   Yes, please.

15        A.   [Marks]

16        Q.   And what is this building that we see now.  We see that you

17     marked as number 2 this very long building.  What else was there in this

18     building?

19        A.   The kitchen of the centre for Territorial Defence training and

20     the mess, the dining room.

21        Q.   Okay.  Could you mark that area with a number 3.

22        A.   [Marks]

23        Q.   Earlier we discussed this hotel or dormitories.  Where would

24     those be located?

25        A.   [Marks]

Page 1514

 1        Q.   Okay.  And next to the building that you marked with a number 4

 2     there seems to be another building.  What was that used for?

 3        A.   I really don't know.

 4        Q.   Okay.  Now did your office -- was your office always located at

 5     the same place throughout the time that you worked at the training

 6     centre?

 7        A.   No, no.  I believe that in the month of September, sometime in

 8     mid-September, I moved to an office which was part of the IPK compound.

 9        Q.   Okay.  Is that visible on this image?

10        A.   Yes.  Yes, I can see it.

11        Q.   Let's mark that with a number 5, please.

12        A.   [Marks]

13        Q.   And what caused you to move from one office to the other?

14        A.   Arkan had taken over the entire centre.  He had his - I don't

15     know what to call her - a woman who performed all sorts of duties for

16     him, his correspondence and everything else.  So she took my old office

17     and I moved together with Mr. Lastavica.  We both moved to the old

18     chateau, the old manor, which at that time housed the administrative

19     offices of the IPK.

20        Q.   You told us earlier that Arkan was stationed here.  Which area

21     did he move into with his men?

22        A.   What do you mean when you ask me where he moved to?

23        Q.   You told us earlier that when Arkan introduced himself to you,

24     following that he was stationed at the TO training centre.  On this image

25     which area of -- which area was it that he occupied with his men?

Page 1515

 1        A.   I marked it and put number 4 next to it.  He used those as his

 2     dormitory and he used number 3 as his dining room.

 3        Q.   Very well.  And could you tell us where were the offices of the

 4     government at the time?

 5        A.   Shall I also mark it with a number?

 6        Q.   Yes, please.  Yeah, with number 6.

 7        A.   I believe that they were here.

 8        Q.   And the building that you marked with a number 5, we see this

 9     long yellowish building, was it referred to in some way?  Did it have a

10     name, this building?

11        A.   It's the old manor.  It used to belong to Count Damovic in the

12     past.

13        Q.   Very well.  And when we talk about the winery generally, which

14     area of this compound was referred to as the winery in 1991?

15        A.   I'll put number 7 next to the new winery which was built before

16     the 1990s.  It is still operational.  Next to that new building they also

17     used -- and I will mark that with number 8.  In the old part of the IPK,

18     which was also one part of the Damovic manor, and that's where the old

19     cellars were and there was also a collection of wines there.

20        Q.   And when you say -- oh, yes, I understand.

21             MR. DEMIRDJIAN:  Now, Your Honours, can we freeze this image and

22     I would like to tender it.

23             JUDGE DELVOIE:  Admitted and marked.

24             THE REGISTRAR:  65 ter document 6254, marked by the witness in

25     court, shall be assigned Exhibit P274.  Thank you.

Page 1516

 1             JUDGE DELVOIE:  Thank you.

 2             MR. DEMIRDJIAN:  Thank you.

 3        Q.   Now at page -- I'm moving now to a different topic, Ms. Rakic.

 4     At page 4 of your statement you were mentioning about Hungarians who had

 5     been brought to the training centre in October of 1991.  You mentioned

 6     the name of Nikola Kalozi and his father.  Before the conflict did you

 7     know this family?

 8        A.   Yes.

 9        Q.   And can you tell us how you knew them?

10        A.   Before the 1990s, they had a restaurant in Erdut mountain, which

11     was a part of the village of Erdut.  We often went and dined there.

12        Q.   And can you tell the Court how you heard that Nikola Kalozi and

13     his father were brought to the training centre?

14        A.   At that time the only way we could learn that was from other

15     people's stories, as we were walking to work or as we were walking to the

16     shops or the bakery.  That's how I heard that they had been brought to

17     the centre.  I did not see them myself, obviously.

18        Q.   Okay.  Now you also mention in that same page the Albert family.

19     Could you tell us what was your relationship, if any, to this family?

20        A.   Yes.

21        Q.   I don't know if my question was translated well.  Could you tell

22     us what was your relationship with this family?

23        A.   I knew them.  My sister was married to one of the Albert family

24     members, and she still is, as a matter of fact.

25        Q.   Okay.  And you mention in your statement that a man by the name

Page 1517

 1     of Milorad Stricevic was supposed to help the Albert family leave Erdut

 2     and cross into Serbia.  Now, first of all, could you tell the Court who

 3     was Stricevic?

 4        A.   I didn't know Stricevic before 1990.  In the 1990s I may have

 5     seen him once or twice.  He was a friend of my brother-in-law -- or,

 6     rather, a friend of a friend of my brother-in-law.

 7        Q.   And did he -- what relations, if any, did he have with the Albert

 8     family?

 9        A.   There were no family relations at all.  They just knew each other

10     through a mutual friend, through a friend of the Albert family.

11        Q.   And after or following the month of August of 1991, did you know

12     where he lived?

13        A.   Stricevic lived in my sister's house and my brother-in-law's

14     house in Erdut.

15        Q.   Now in your statement you say that you realised that the Albert

16     family, that is Djuro, Helena, and Victoria, and Ana Terzic had gone

17     missing some two weeks later.  Could you tell the Court how you learned

18     that they went missing?

19        A.   How they disappeared, is that what you're asking me?

20        Q.   Yes.  How you learned that they disappeared.

21        A.   Before they left they came to say goodbye to my parents.  They

22     said to them that they would first go to Serbia, and from there that they

23     would go to Hungary and then perhaps somewhere else.  Perhaps ten days or

24     so later, we got in touch with my sister and my brother-in-law through

25     our friends in Odzak [as interpreted].  The telephone lines were down at

Page 1518

 1     that time.  Those people from Odzak called my sister and my

 2     brother-in-law, who were in Slovenia at the time, and they heard from

 3     them that they had never contacted them.  And based on that, some five or

 4     six days later, when they failed to get in touch, we concluded that they

 5     had gone missing, that they had left no traces.  They had simply gone

 6     missing.

 7        Q.   I'd like to clarify something you mentioned about friends.  And

 8     what's recorded in the transcript is the town of Odzak.  Is that the

 9     right name of the town?

10        A.   Odzaci.  Odzak is a place in Bosnia and Odzaci is in Serbia.

11        Q.   Thank you for that clarification.  Now in that same paragraph,

12     after you've talked about the Albert family and the case of Manda Maj,

13     you say that some other Croats were put on buses and expelled from Erdut

14     before UNPROFOR arrived.  What I would like to ask you is which

15     time-period would this be approximately?

16        A.   That expulsion I believe happened in spring.

17        Q.   Okay.  And how did you learn about this expulsion?

18        A.   We heard about all of those important things on the street.  I

19     heard about that from my cousin.  Arkan's men came and forced him at

20     gunpoint to drive the bus with those Croats, i.e., non-Serbs from the

21     village who were being expelled from the village.

22        Q.   And what happened to the homes of the Croats who had been

23     expelled?

24        A.   Those houses were then rented out to the Serbian refugees who had

25     arrived either from Osijek or from Western Slavonia.

Page 1519

 1        Q.   Were any Croats left after these expulsions in Erdut?

 2        A.   Very few and they were mostly elderly or they were in mixed

 3     marriages.

 4        Q.   Now you just told us that the Serb refugees who had been expelled

 5     from Osijek or Western Slavonia came to occupy some of the homes that

 6     were left behind by the Croats.

 7             MR. DEMIRDJIAN:  I would like to look at the following document,

 8     which is 65 ter 00982, and that is at tab 18.  I don't know why the

 9     English version is in green.

10             THE WITNESS: [Interpretation] There is also a version in my

11     language.

12             MR. DEMIRDJIAN:  Okay.

13        Q.   Now the document describes the -- deals with the home owned by

14     Drago Albert.  Did you know Drago Albert?

15        A.   Yes.  Drago Albert is my sister's husband.  He is my

16     brother-in-law.

17        Q.   Okay.  And what ethnicity is he?

18        A.   Drago Albert, he was of Catholic faith.

19        Q.   At the time, did you know that this house was given to the

20     Vujanic family as indicated on this document?

21        A.   Yes, we knew that.  I knew it.

22        Q.   Okay.  And did you know where the Vujanic family came from?

23        A.   I believe that they came from Podravska Slatina, but I'm not

24     sure.

25        Q.   And what was that you are ethnicity?

Page 1520

 1        A.   Vujanic was of Orthodox faith.

 2             MR. DEMIRDJIAN:  May I ask for this document to be admitted, Your

 3     Honours.

 4             JUDGE DELVOIE:  Admitted and marked.

 5             THE REGISTRAR:  Shall be assigned Exhibit P275.  Thank you.

 6             MR. DEMIRDJIAN:  And I'm sorry, can we scroll down to the bottom

 7     of this document.

 8        Q.   Do you recognise the signature on this document, Ms. Rakic?

 9        A.   Yes, I do.

10        Q.   Very well.  And who's signature is it?

11        A.   My husband's signature.

12        Q.   And you explained that at the time he was working for the Erdut

13     local commune; is that right?

14        A.   Yes, that's right.  He did work for them.

15        Q.   Now the last document I'd like to show you is at 65 ter 00850.

16             MR. DEMIRDJIAN:  That's at tab 17.  Now in the English version

17     could we go to page 2, and in the B/C/S version could we go to page 5.

18             Your Honours, this is a series of approximately 30 notifications

19     to inhabitants of the village of Erdut.  We will use a few examples here

20     and we've translated one or two of them, but the documents are always

21     similar, they are always the same.  It is simply the name of the

22     inhabitant which changes.

23        Q.   Now could you tell us, Ms. Rakic, what this document is about?

24     What's the subject here?

25        A.   This document is not very legible, I must say.  However, this is

Page 1521

 1     a notification to the Serbian refugees who arrived in Erdut in 1991 and

 2     occupied empty Croatian homes.  That decision was issued by the

 3     Ministry of Defence of the Republic of Serbian Krajina for all those who

 4     temporarily resided in the territory of Erdut and their original places

 5     of residence had been liberated, that they should go back to their

 6     original places of residence.

 7        Q.   This document here is addressed -- this decision is addressed to

 8     Zoran Stojilovic [phoen].  Is this somebody you were familiar with?

 9        A.   I knew him, well, just in passing.

10        Q.   And do you know where he went to?

11        A.   I think that he moved to Serbia.  Or to be more precise, he went

12     to Vojvodina.

13        Q.   Okay.  Is that also your husband's signature on this document?

14        A.   Yes, it is.

15             MR. DEMIRDJIAN:  Can we go to the next page.  I believe we may

16     have another version that is a bit clearer.  I mean the next page in the

17     B/C/S.  We can always leave the English version as is.  Perhaps the next

18     one in B/C/S.

19        Q.   Ms. Dragana -- well, on this one, Ms. Rakic, do you recognise the

20     person who is being notified?

21        A.   Yes, I do.  Sofija Alvadzic, yes.

22        Q.   And where was she from?

23        A.   She came from Vukovar.

24             MR. DEMIRDJIAN:  Well, in B/C/S can we go to the next page?

25        Q.   Do you recognise this name?

Page 1522

 1        A.   No, not this name here, no.

 2             MR. DEMIRDJIAN:  Again in B/C/S can we go to the next page.

 3        Q.   Yes, the name here appears to be Garosac.  Is this somebody you

 4     were familiar with?

 5        A.   I believe that she also moved away.  She went to Vojvodina, I

 6     think.

 7             MR. DEMIRDJIAN:  Let's move to the next page in the B/C/S

 8     version.  Let's move again to the next one in the B/C/S version.

 9        Q.   On all these documents we can see that it's the same format.  Is

10     that right, Ms. Rakic?

11        A.   Yes.  It is the same.

12        Q.   Okay.  Let's try one or two more and I'll wrap it up.

13             MR. DEMIRDJIAN:  Can we move to the next page in the B/C/S -- oh,

14     no, to another one, please.

15        Q.   Is this also someone you were familiar with, Ms. Rakic?

16        A.   No, I don't think so.  No, no.

17        Q.   Okay.

18             MR. DEMIRDJIAN:  Can we move perhaps to the page that ends with

19     772.  That's three pages later.

20        Q.   The name here is Nikola Grubisic.  Is this someone you were

21     familiar with?

22        A.   Yes, I knew him.

23        Q.   Okay.  And where did he go to?

24        A.   He's in Bogojevo.  As you cross the Danube from Erdut, that would

25     be the first place in Vojvodina.

Page 1523

 1        Q.   Okay.  And let's try one last one.

 2             MR. DEMIRDJIAN:  The very next page in B/C/S.

 3        Q.   It's the name Milan Panic.  Is that somebody you were familiar

 4     with?

 5        A.   Yes, I knew him.  Even before the 1990s.

 6             MR. DEMIRDJIAN:  Your Honours, I'm not going to show the rest.

 7     There is about 20 more.  Could I ask for this set of documents to be

 8     admitted and marked.

 9             JUDGE DELVOIE:  Admitted and marked.

10             THE REGISTRAR:  It shall be assigned Exhibit P276.  Thank you.

11             MR. DEMIRDJIAN:

12        Q.   Now, Ms. Rakic, all these documents which are signed here are

13     done in accordance with a decision of the Ministry of Defence of the

14     Republic of Serbian Krajina.  At the time were you aware as to who was

15     your husband's superior?

16        A.   No, I didn't know who his superior was.  We never discussed that.

17        Q.   Very well.

18             MR. DEMIRDJIAN:  Thank you, Your Honours.  That is all I ask.

19             JUDGE DELVOIE:  Thank you.

20             Cross-examination, Mr. Zivanovic?

21             MR. ZIVANOVIC:  Thank you, Mr. President.

22                           Cross-examination by Mr. Zivanovic:

23        Q.   [Interpretation] Good morning, Ms. Rakic.  My name is

24     Zoran Zivanovic.  I represent Goran Hadzic in this case.

25             Ms. Rakic, in your statement on page 2 you stated, inter alia, in


Page 1524

 1     paragraph 1 or 2, a paragraph that starts with the words, "On the

 2     20th of July, 1991 ..."  I apologise.  It will be page 3.  Not page 2.  I

 3     misspoke.  I believe that you can see that on the screen as well.  You

 4     stated that a majority of women with small children left Erdut on the

 5     20th of July, 1991.

 6             First of all, tell me please on that occasion when a majority of

 7     women with small children left Erdut, as you stated, does that refer to

 8     the women of all ethnic groups or just one ethnic group?  What did you

 9     mean?

10        A.   Those were women of both ethnic groups.

11        Q.   In other words, both Serbs and non-Serbs, right?

12        A.   Yes, that's right.

13        Q.   At that time, on the 20th of July 1991, Erdut was under the

14     control of the Croatian authorities, right?

15        A.   Yes.

16        Q.   I can see that at that time you also left Erdut, on or about that

17     time, together with your small child.  Could you please tell us why you

18     left?  What prompted all the women and children to leave, women and

19     children of both ethnic groups?  What, for example, prompted you to leave

20     Erdut at the time?

21        A.   Well, at the time members of the ZNG were in Erdut, members of

22     the reserve Croatian police force.  Guards were mounted at night.  Croats

23     from Erdut stood guard.  Fire was opened at night.  The troops were

24     deployed in Bogojevo and they opened fire on each other.  So naturally we

25     were all afraid.  We were concerned about our children.  And therefore we

Page 1525

 1     decided to leave.

 2        Q.   And you say that when you returned on the 19th of August, the

 3     village was almost empty?

 4        A.   Yes.

 5        Q.   Similarly, you said that after the 1st of August a sort of work

 6     obligation was introduced in Erdut, and what I'm interested in is whether

 7     this obligation concerned all the inhabitants of Erdut or was it a

 8     particular kind of obligation that depended on one's ethnicity?

 9        A.   No, all those who remained in Erdut and were capable of doing

10     work had the will to carry out duties and they had that task too, and

11     that concerned everyone, the Serbs, the Hungarians, the Croats.

12        Q.   At the time was this a legally prescribed work obligation?  Were

13     the regulations such at the time?  Do you know anything about that?

14        A.   No, I don't know.  I don't think there were any legal regulations

15     that concerned that obligation at the time.  I think it was just a matter

16     of people volunteering.

17        Q.   Very well.  I won't put any further questions to you about the

18     legal situation, about the laws of Yugoslavia and whether they were valid

19     at the time.  With regard to your first meeting with Zeljko Raznjatovic,

20     Arkan, if I have understood you correctly you said that he entered your

21     office, he calmly introduced himself.  I am asking you about this because

22     on page 7, line 9, I think it was translated a little different.  You, in

23     fact, say that he stood as ease and then calmly introduced himself.  I

24     think it has happened again.  When you say "calmly," do you mean he was

25     calm or do you mean that he adopted the military position of being at

Page 1526

 1     ease?

 2        A.   Well, when I first met him I had never spoken to him but he did

 3     seem to be acting like a gentleman, which surprised me at the time.  When

 4     he adopted that position, it wasn't as if he was saluting me in a

 5     military fashion, but he stood there, he sort of bowed and said, This is

 6     my name.  He introduced himself.

 7        Q.   Very well.  We have resolved that issue now.  When you spoke

 8     about Milorad Stricevic and the Albert family, I just wanted you to

 9     clarify something for us.  You said that the Albert family at the

10     beginning of 1992 disappeared, in fact, and I would like to know whether

11     you know anything about Milorad Stricevic.  Did he subsequently appear

12     anywhere?  Do you know what happened to him?

13        A.   He was also found in the well, together with the Albert family.

14     He and the Albert family were killed.

15        Q.   When you spoke about refugees who had found accommodation in

16     certain houses in Erdut, you said that those houses had been let to those

17     refugees.  This is how it's been translated.  It's page 17, line 15.  But

18     did they have to pay rent or were they provided with necessary

19     accommodation?  Because these people were very poor.  They didn't have

20     any property.

21        A.   They didn't have to pay any rent.  Perhaps when the electricity

22     bills arrived they would have to pay for the bills, but at that time

23     there was no rent to pay.

24        Q.   And there is one other matter.  My friend from the Prosecution --

25     my learned friend from the Prosecution showed you a lot of documents that


Page 1527

 1     concerned information provided to the Serbian refugees in 1992 --

 2     18th of June, 1992.  It was information according to which they were to

 3     return to their places because the conditions were such that they could

 4     return.  They didn't have to remain in that territory.  So these houses

 5     that had been let to them had been let to them on a temporary basis; is

 6     that correct?

 7        A.   Yes.

 8        Q.   That's all I wanted to ask you about.  Thank you very much.

 9        A.   Thank you -- you're welcome.

10             JUDGE DELVOIE:  Anything in redirect?

11             MR. DEMIRDJIAN:  No, Your Honours.  No questions to ask.

12             JUDGE DELVOIE:  Thank you.

13                           Questioned by the Court:

14             JUDGE MINDUA: [Interpretation] Ms. Rakic, I have a brief question

15     for you.  When we had a look at Exhibit P275, P275, we saw a signature.

16     It was Drago Albert's signature.  I apologise, Ljubomir Rakic's

17     signature.  Ljubomir Rakic.  And when we had a look at the following

18     exhibit, P276, Ljubomir Rakic's signature appears on that exhibit again.

19             The person who signed the first document was president of the

20     Commission for the Protection of Refugees, and the person who signed the

21     second document was the secretary of the Executive Council of the Erdut

22     commune.  Are we dealing with the same person or not?

23        A.   It's the same person.  The secretary [Realtime transcript read in

24     error "secret"] of the local commune and the president of the commission

25     is the same person.

Page 1528

 1             JUDGE MINDUA:  [Interpretation] This Commission for the

 2     Protection of Refugees is an organisation that was under the auspices of

 3     the commune then?

 4        A.   No, I don't think so.  I wasn't really informed but I think that

 5     that commission was a particular commission.  It had a special status.

 6             JUDGE MINDUA:  [Interpretation] Very well.  Thank you very much.

 7             MR. DEMIRDJIAN: [Interpretation] There is a slight error in the

 8     transcript.  Judge Mindua, in response to your question, on page 26,

 9     line 14, and I see that the answer was:  "The secret of the local

10     commune ..."  I think the witness said:  "The secretary of the local

11     commune."

12             JUDGE MINDUA:  [Interpretation] Yes.  Quite right.  It is "the

13     secretary" in fact.

14             JUDGE DELVOIE:  Ms. Rakic, I have a follow-up question for you on

15     that matter.  So I understand that it was your husband who signed the

16     assignment of Drago Albert's house to a Serb refugee, right?

17        A.   Yes.

18             JUDGE DELVOIE:  Drago Albert being your brother-in-law?

19        A.   Yes.

20             JUDGE DELVOIE:  Was this something you, after it happened, you

21     discussed with your husband?  Was this something -- was this odd?  At

22     first sight, it looks odd that your own husband gives away your

23     brother-in-law's house.  Did you discuss that with your husband?  Were

24     there any -- I don't know.  Did you consider it as normal?  I mean, was

25     that a normal thing to do?  Was this normal in his line of work?

Page 1529

 1        A.   I'll explain.  My sister and brother-in-law, when the army

 2     arrived they left.  They went to Slovenia and they lived in Slovenia for

 3     a certain period of time.  Later they returned to Osijek.  Since all the

 4     abandoned houses were being let out to Serbian refugees who had arrived

 5     from Osijek or from other areas from which they had been expelled, well,

 6     all these houses were in fact let out to these Serbian refugees.  Since

 7     the house that belonged to my sister and brother-in-law was a new one and

 8     we wanted to preserve it as well as the furniture in that house, since we

 9     knew that it had to be let to some of the Serbs who had arrived in

10     Erdut, we tried to let it to someone we knew or who was known.

11     Mr. Vujanic, who came from Podravska Slatina, knew a relative of my

12     sister or the father of Drago Albert because Vujanic worked in the

13     agricultural enterprise in Podravska Slatina and Drago Albert's father

14     worked in the agricultural enterprise in Erdut.  So they had a business

15     relationship, they knew each other, and with his blessing, with the

16     blessing of Drago's father, the house was let to a person who was known.

17     And this was done in order to maintain the house, prevent it from being

18     damaged.

19             JUDGE DELVOIE:  So by doing this you were more or less taking

20     care of your brother-in-law's house?

21        A.   That's correct.  That's correct.  Because Drago Albert's father

22     and the husband of the late Victoria Albert was still in Erdut in 1992, I

23     think.  When this was done he was still in Erdut.

24             JUDGE DELVOIE:  Thank you very much.

25             So, Ms. Rakic, this brings your testimony to an end.  Thank you


Page 1530

 1     for coming to The Hague to assist the Tribunal with your testimony.

 2     You're now released as a witness.  The usher will escort you out of the

 3     courtroom and we wish you a safe journey back home.

 4             THE WITNESS: [Interpretation] Thank you.

 5                           [The witness withdrew]

 6             JUDGE DELVOIE:  Mr. Stringer.

 7             MR. STRINGER:  Mr. President, we have no additional witnesses to

 8     call today.  The next witness will be arriving this afternoon from the

 9     region.  We've got a bit of a gap.

10             JUDGE DELVOIE:  Obviously.

11             MR. STRINGER:  I regret that but sometimes it's inevitable.  I

12     think we weren't entirely sure how things would go with one of the

13     earlier witnesses this week.

14             So we have three witnesses who are now in the process of arriving

15     or who will begin arriving today, and on our own calendar we think that

16     we are down for calling and hopefully completing three witnesses during

17     Thursday and Friday.

18             JUDGE DELVOIE:  Okay.  Anything else to be discussed or

19     addressed?  Nothing.  Court adjourned.  We will resume, then, Thursday at

20     9.00.

21                           --- Whereupon the hearing adjourned at 10.17 a.m.,

22                           to be reconvened on Thursday, the 22nd day

23                           of November, 2012, at 9.00 a.m.