1 Tuesday, 4 June 2013
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.02 a.m.
5 JUDGE DELVOIE: Good morning to everyone in the courtroom.
6 Mr. Registrar, could you call the case, please.
7 THE REGISTRAR: Good morning, Your Honours. This is case number
8 IT-04-75-T, the Prosecutor versus Goran Hadzic. Thank you.
9 JUDGE DELVOIE: Thank you very much. Could we have appearances,
10 please, starting with the Prosecution.
11 MS. CLANTON: [Microphone not activated]
12 JUDGE DELVOIE: Microphone, please.
13 MS. CLANTON: Good morning, Your Honour, Sarah Clanton and
14 Matthew Olmsted for the Prosecution, with our intern Maria Bukovac.
15 JUDGE DELVOIE: Thank you. Mr. Zivanovic, for the Defence.
16 MR. ZIVANOVIC: Good morning, Your Honours. For the Defence of
17 Goran Hadzic, Zoran Zivanovic and Christopher Gosnell. Thank you.
18 JUDGE DELVOIE: Thank you. The witness may be brought in.
19 [The witness entered court]
20 JUDGE DELVOIE: Good morning, Mr. Witness. Do you hear me in a
21 language you understand.
22 THE WITNESS: Good morning. [Interpretation] Yes, I can hear you
23 well in the Croatian language.
24 JUDGE DELVOIE: Thank you for coming to The Hague to assist the
25 Tribunal. Could you please state your full name and date of birth,
2 THE WITNESS: [Interpretation] My name is Stipan Kraljevic,
3 8th of January, 19 --
4 THE INTERPRETER: Could the witness please repeat the year.
5 JUDGE DELVOIE: Thank you very much.
6 THE INTERPRETER: Interpreter's correction, 1937.
7 JUDGE DELVOIE: Mr. Kraljevic, you are about to make the solemn
8 declaration by which witnesses commit themselves to tell the truth. I
9 have to point out to you that by doing so you expose yourself to the
10 penalties of perjury should you give false or untruthful information to
11 the Tribunal. Can I ask you now to read the solemn declaration the court
12 usher will give to you.
13 THE WITNESS: [Interpretation] Thank you, Your Honours. I
14 solemnly declare that I will speak the truth, the whole truth and nothing
15 but the truth.
16 JUDGE DELVOIE: Thank you very much. You may be seated.
17 THE WITNESS: [Interpretation] You're welcome.
18 JUDGE DELVOIE: Ms. Clanton, your witness.
19 MS. CLANTON: Thank you, Your Honour.
20 WITNESS: STIPAN KRALJEVIC
21 [Witness answered through interpreter]
22 Examination by Ms. Clanton:
23 Q. Good morning, Mr. Kraljevic.
24 A. Good morning.
25 MS. CLANTON: With the permission of the Court, I'd like to lead
1 the witness through his background information.
2 JUDGE DELVOIE: Please do.
3 MS. CLANTON:
4 Q. Mr. Kraljevic, is it correct that you were born in Bosnia and
5 moved to Croatia in the early 1940s?
6 A. Yes.
7 Q. And is it correct that you completed your gymnasium studies in
8 Backa Palanka?
9 A. Yes.
10 Q. And that you did your compulsory service with the JNA in
11 Montenegro from 1961 to 1962?
12 A. Yes.
13 Q. Mr. Kraljevic, is it correct that you then studied agriculture at
14 the university in Zagreb?
15 A. I studied and graduated before I went to do my compulsory
16 military service.
17 Q. Thank you for that. The place where you studied, was that in
19 A. Yes.
20 Q. And is it correct that you obtained further certification to be a
22 A. Since I worked in school, a number of teaching subjects had to be
23 passed and that is what I did. I did those exams.
24 Q. And is it correct that in 1990 you were working as a lecturer in
25 the topic of agriculture?
1 A. Yes.
2 Q. Mr. Kraljevic, can you confirm that you served as mayor of Ilok
3 starting in 1993?
4 A. Yes, between 1993 and 2001.
5 Q. And is it correct that the -- in 1990, the town of Ilok was part
6 of the municipality of Vukovar?
7 A. Yes.
8 Q. And is it correct that the towns of Sarengrad, Bapska, and Mohovo
9 are part of the local community of Ilok?
10 A. As a matter of fact, those were all local communes of the
11 municipality of Vukovar. That was one single municipality, yes. Yes.
12 Q. And, Mr. Kraljevic, how far is Ilok from Vukovar, the city of
14 A. 35 kilometres.
15 Q. And can you tell us, please, the population in Ilok in
16 March of 1991 in terms of the number of people who were living there?
17 A. In Ilok itself, there were 6.774 inhabitants according to the
18 1991 census. Now, in the villages surrounding Ilok, Bapska, there was
19 about 1600; Sarengrad, 1100; and Orahovo, 340.
20 Q. Mr. Kraljevic, what was the majority ethnic group in Ilok?
21 A. In ethnical term, Ilok was a mixed settlement. However, the
22 population of the Ilok, the majority of it, were Croats, who accounted
23 for about 64 per cent. There were 7 per cent Serbs, 17 per cent of
24 Slovaks, which was the largest ethnic minority in the town of Ilok and we
25 can easily say in all of the Croatia as well. As for other ethnic
1 minorities, their numbers were really small.
2 Q. Mr. Kraljevic, the villages that you've described as being part
3 of the Ilok area, Sarengrad, Bapska, Mohovo, what was the majority
4 ethnicity in those villages?
5 A. Over 30 [as interpreted] per cent in Sarengrad and Bapska were
6 Croats, 4 per cent were Serbs, 64 per cent Croats in Mohovo and
7 3 per cent Serbs.
8 Q. And, Mr. Kraljevic, just to follow up on that, can you tell us
9 again what was the percentage of Croats in Sarengrad, please?
10 A. Over 90 per cent.
11 Q. And in Bapska?
12 A. Over 90 per cent.
13 Q. Thank you. Now, earlier you confirmed that you completed your
14 studies at the gymnasium level in Backa Palanka. I'd like to ask you if
15 it was common for residents of Ilok and Backa Palanka to have business
16 and studies on both sides of the Danube River?
17 A. I attended to the secondary school in Backa Palanka between '56
18 and '61. At the time there was an agricultural school in Ilok. There
19 was a secondary grammar school in Backa Palanka. Children normally
20 attended both schools according to their preferences. The people from
21 Ilok attended the grammar school and the others came to Backa Palanka to
22 attend the agricultural school.
23 Q. And how are these two towns connected geographically?
24 A. Both towns are located on both banks of the Danube River and they
25 were connected by a ferry. Then in 1974, a bridge between Backa Palanka
1 and Ilok was built. This bridge was very important especially for
2 Vojvodina because that was the shortest way with the western part.
3 Q. What was the name of this bridge?
4 A. Its name was the 21st of May in order to mark the birthday of
5 President Tito.
6 Q. And, Mr. Kraljevic, you've told us about the fact that you
7 attended school in Backa Palanka yourself and that it was common for
8 people to cross to go about their daily functions. I want to ask you,
9 can you describe the relations in 1990 with your neighbours in Serbia?
10 A. The movement of people went normally. I did not observe any
11 problems in that respect.
12 Q. Were you a member of any political party in 1990 or shortly
14 A. Up until 1990, 1991, I hadn't been a member of any party. I was
15 only a member of the Croatian Christian Democratic Party. However, this
16 party did not survive for too long and it was disbanded in 1993.
17 Q. Thank you, Mr. Kraljevic. I would now like to change topics and
18 ask you about what you observed happening in 1991, specifically changes
19 in your community in 1991.
20 I want to ask you if there came a time that you noticed any
21 changes in behaviour between the ethnic groups in your area?
22 A. Well, it did not actually start only in 1990, it had been lasting
23 for quite some time because this atmosphere was felt in the central
24 committees of certain republics who were in disagreement. This was
25 followed by self-rule elections both on the republican and local levels.
1 Q. And, Mr. Kraljevic, our time is limited so I'd like to focus you
2 on what you observed in 1991, please. Did you see any changes in your
3 area in 1991?
4 A. The local government was changed following the elections, which
5 means there were many new members. In 1991, during the preparations for
6 multi-party elections, an incident took place in Ilok at the Orthodox
7 cemetery where a number of graves were desecrated or demolished, and I'm
8 talking about the Orthodox cemetery in Ilok.
9 Q. Mr. Kraljevic, can you tell us what you learned about how these
10 acts had been committed?
11 A. We didn't hear anything about it because the police, who were
12 200 metres away, did not respond in any way; however, the journalists
13 from the Novi Sad television were there on the spot on the very same
14 morning and they broadcast this news. That is how this incident was
15 recorded. We can only speculate about who was behind it.
16 Q. How did the fact that television from Novi Sad reported on this
17 incident prior to the police, how did that make you understand what had
18 happened there?
19 A. The residents, including myself, perceived this as a provocation
20 and a means of a feeling of sort of mistrust towards certain ethnic
21 groups, but as I said, we might just speculate about who the perpetrators
23 Q. And, Mr. Kraljevic, were you aware of an event in May 1991 in
24 Borovo Selo?
25 A. Yes. We knew because it was on the news, a serious crime was
1 committed in which 12 policemen lost their lives and, of course, this
2 caused high tensions among the populous.
3 Q. And what happened in the immediate area of Ilok after this
4 incident at Borovo Selo which you've told us caused high tension among
5 the population?
6 A. Rumours were being spread, all sorts of rumours. Of course there
7 were various stories going around, but the killing of such a large number
8 of police officers naturally caused tensions. But in addition to that,
9 there were rumours being spread that the same thing might be repeated in
10 Ilok as well. As a result, certain individuals, but in working together
11 with the police, started guarding the entry point to Ilok and Bapska from
12 all sides as well as in other settlements. In that way, a duty post was
13 established at the bridge which was manned by members of the civilian
14 protection and that was all.
15 Q. Mr. Kraljevic, after the people in Ilok heard about this incident
16 and the civilian protection was put on the bridge, can you describe the
17 response from the other side of the bridge?
18 A. Well, you know, since this duty post was established at the
19 bridge, it provided control of the movement in a way which meant that
20 people passing by were identified, their documents were checked, but this
21 did not hinder any free movement. However, on the 10th of May, on the
22 access to the bridge from Backa, tanks arrived and were positioned at the
23 very entry point to Ilok near the bridge and thereby established their
24 own checkpoint. The explanation was that they wanted to control the
25 traffic in order to prevent any disturbances in that respect.
1 Q. Mr. Kraljevic, these tanks you've described, which army did they
2 belong to?
3 A. The Yugoslav People's Army.
4 Q. And you've told us that this occurred on the 10th of May; is that
6 A. I believe that it was on the 7th, but I cannot be certain.
7 Q. Thank you. And this is in May. After the declaration of
8 independence in June of 1991, what changes did you observe among the
9 Serbs in Ilok?
10 A. Well, I cannot say that there occurred any changes worth
11 mentioning. People were communicating normally. I believe that the
12 relations between neighbours were good; however, there were a few
13 occurrences when certain members of the Serb ethnic group went to
14 Backa Palanka to spend the night there and would then return in the
15 morning under the pretext of doing it for safety reasons, but we didn't
16 notice any need for anyone doing that.
17 Q. Thank you, Mr. Kraljevic. Can you tell the Court, please, what
18 changes happened within the police after the declaration in June of 1991?
19 A. Well, the composition of the police force compared to the
20 national composition in Croatia was disadvantageous for Croats. About
21 50 per cent of the population of Croatia in certain parts were Croats and
22 there were parts where Serbs constituted more than 30 per cent and the
23 rest declare themselves of Yugoslavs, although I don't know what that
24 meant. And by that, I mean that there was no Yugoslav nation as such.
25 May I continue?
1 Q. Yes, Mr. Kraljevic, if I could just focus your answer. What I'd
2 like to know is the changes that you could tell us about the police in
3 June of 1991.
4 A. Well, this is precisely what I told you. The number of Croatian
5 policemen increased within the police force. However, after the Republic
6 of Croatia was declared independent, which was followed by the changes to
7 the constitution and multi-party elections, Croatia had new national
8 symbols and these symbols were prescribed as something to be worn on the
9 caps by policemen, and I'm talking about the Croatian coat of arms.
10 However, some policemen refused to wear such caps. As far as I know,
11 they went to Backa Palanka. I think there were five police officers who
12 took that course.
13 Q. Thank you. Earlier you've told us that Vukovar is located
14 approximately 35 kilometres from Ilok. I want to ask you if in the
15 summer of 1991 you became aware of an attack in Vukovar.
16 A. I worked at the secondary school centre in Ilok. It catered to
17 the whole municipality of Vukovar, and we had meetings. During the
18 summer, I went to Vukovar for that reason and I also heard news about the
19 situation in Vukovar itself.
20 The situation was complex because barricades had been put up all
21 around, and Vukovar was cut off from Vinkovci. It was cut off at Brsadin
22 and towards Osijek, at Trpinje in the direction of Dalj and Borovo Selo.
23 That would be briefly it. And of course the population couldn't move
24 about freely, which certainly resulted in some tension.
25 Q. And from Ilok, what could you hear from this area?
1 A. Radio and television were still operating. People were
2 travelling to Vukovar and back. There was coverage of any event that had
3 happened anywhere.
4 Q. And from Ilok, was the fighting audible?
5 A. Well, no, but when, on the 24th of August, an overall attack at
6 Vukovar began, we heard it from Ilok because airplanes flew over Ilok at
7 very low altitude. We could also hear bombing. However, we had heard
8 bombing at Ilok before. If I may, I would like to mention some events
9 that are characteristic of Ilok when some incidents happened.
10 Q. Mr. Kraljevic, just to clarify the point that you were just
11 making. Whose aircraft could you hear?
12 A. There was only one organised army and that was the Yugoslav
13 People's Army.
14 Q. Thank you. And I do want to ask you now about specific incidents
15 in Ilok between the JNA tanks that you've described for us that were on
16 the bridge and the forces, the civilian protection that was in Ilok. Can
17 you tell us what happened in July of 1991?
18 A. In July 1991, it was on the 8th of July to be precise, an
19 incident happened in the evening hours. As I have already said, by the
20 bridge there was a tank unit of the Yugoslav People's Army. Some
21 100 metres away, the police of the MUP of Croatia had its own checkpoint.
22 As I've said, the distance between the two was about 100 metres.
23 Suddenly, a tank-mounted machine-gun was used to destroy a vehicle
24 belonging to Ilok police station. There were four persons in that
25 vehicle, one of whom was killed immediately and the others were wounded.
1 They were taken to hospital in Slavonski Brod.
2 Q. Mr. Kraljevic, this person who was killed, can you tell the
3 Trial Chamber his age or where he was from?
4 A. The person was from Sarengrad. It was a young man who had only
5 recently joined the police station in Ilok. He may have been 20 or a bit
6 over 20 years old at the time.
7 Q. Mr. Kraljevic, what was the response from the police that had
8 been at the checkpoint to being fired on by this machine-gun that was on
9 a tank?
10 A. Nearby, how near exactly I don't know, there was probably a
11 person belonging to the ZNG and that man destroyed a tank with a
12 hand-held rocket launcher, a Zolja.
13 Q. And what was the response by the JNA when their tank was
14 destroyed by the hand-held rocket launcher?
15 A. Of course there was a protest by the JNA representative but on
16 the next day around noon, something happened at Principovac. There was a
17 group of ZNG members there who had come to Ilok before that and two
18 aircraft opened machine-gun fire on that group of ZNG members, who were
19 playing soccer at that time. One person was killed and I believe that
20 two were wounded.
21 Q. How far is Principovac from Ilok?
22 A. If I may, let me just mention that. In July -- it was in July
23 that this incident happened, but on the other side of our local community
24 in the direction of Sid, a group of JNA members with tanks arrived and
25 took up positions there so that Ilok, from that moment on, was completely
1 surrounded. That would be a short account of these events. However, let
2 me also add that the ZNG, who were accommodated at an agricultural
3 facility, moved to town for safety reasons because JNA contingents were
4 very close. But after that incident I have just mentioned, the ZNG left
5 the area.
6 Q. Thank you. If you could tell the Chamber, please, how far
7 Principovac is from Ilok?
8 A. Yes. First of all, Ilok is on the promontory next to the Danube
9 at an altitude of about 70 metres. There is another such promontory that
10 we call Principovac which is some 2 kilometres from the centre of Ilok,
11 and there was an excellent view from there. You could see the entire
12 area around Ilok.
13 Q. Thank you. As you've just told us, there was a JNA response
14 which was to use aircraft to attack this position in Principovac of --
15 and the agricultural building of the ZNG. I want to ask, were any other
16 buildings shelled in Ilok at this time?
17 A. Yes.
18 Q. Can you tell us which buildings, please?
19 A. It happened on the 20th of July, I think, by the bridge on the
20 Ilok side, of course. There was a private workshop -- that is actually a
21 workshop and a store. It was called Zec. Suddenly, that workshop was
22 attacked with artillery and it was damaged. At the same time, the spire
23 of the Catholic church in Ilok was targeted and damaged, so were some
24 private houses. Fortunately, nobody was killed. As far as I know, only
25 one person was wounded.
1 Q. Mr. Kraljevic, I now want to move to talk about events that were
2 happening in the other villages that are near Ilok in the Western Srem
3 region. This would be in the summer and fall of 1991. I'm going to ask
4 you, when did you first hear about the use of aircraft or other JNA
5 equipment in towns or villages in Western Srem?
6 A. I cannot hear the interpretation. Now I can hear it. I cannot
7 hear anything.
8 Q. I will ask my question again.
9 I want to ask you, when did you first hear about events in other
10 towns and villages in Western Srem involving the JNA?
11 A. Yes. Let me try to focus. There are many villages there. Let
12 me -- I'll try to get my bearings.
13 On the border towards Sid, there is Tovarnik, on the road from
14 Sid to Vinkovci. But even before that, there were incidents at Sotin.
15 Q. Mr. Kraljevic, perhaps I can focus my question a bit more. Prior
16 to the events in Sotin and Tovarnik, were you aware of any other town or
17 village in the area that had been involved in attack with the JNA. The
18 time period I'm interested in is the late summer of 1991.
19 A. Yes. In the late summer of 1991, and if I remember well, it was
20 on the 24th of August when the real attack of the JNA on Vukovar began.
21 On the 25th of August, there were air raids, and at that moment,
22 four persons were killed in a car. Two of them were from Ilok who
23 happened to be in Vukovar. Of course, that was very discomforting.
24 As of the 24th, there was daily combat activity in Vukovar, which
25 was very worrying. Sotin is the first village in the direction of Ilok
1 when you come from Vukovar. It was attacked by aircraft on the
2 28th of August, I think. It's very telling because at that very time,
3 there was a funeral at Sotin and that added to the dismay over the air
4 raid. From the 5th of September, there was no more communication between
5 Ilok and Vukovar.
6 Q. Mr. Kraljevic, a moment ago you mentioned Tovarnik. I want to
7 ask you what happened in Tovarnik and if you can give us an approximate
9 A. There was an ultimatum issued to Tovarnik that they should
10 surrender to the JNA, otherwise the army would enter by force. As far as
11 I know, Mr. Burik, the priest, went to Sid to negotiate but to no avail.
12 And there was an attack on the 24th of September. Many people from
13 Tovarnik came to Ilok through Lovas and some of them went in the other
14 direction, through Nijemci, and Tovarnik was left without the majority of
15 its inhabitants.
16 Q. And, Mr. Kraljevic, you've told us that there was this attack on
17 Tovarnik after there was an ultimatum that was received and there were
18 negotiations that didn't lead anywhere. Can you describe for the Chamber
19 what you know about how the attack was actually carried out, what the
20 steps were, and who was engaging in the attack?
21 A. Well, you know, I wasn't there and I can't give you a full
22 description. But infantry and tanks of the army entered the village and
23 so did paramilitaries. I know that there were many victims at Tovarnik
24 but I don't want to speculate about their numbers. I know that some
25 60 to 80 people were killed there in those few days.
1 Q. And what you've described happening in Tovarnik, did this happen
2 in other villages in Western Srem, similar events?
3 A. Of course the main target was Vukovar and the army proceeded --
4 or, rather, was moving there gradually. I could mention Ilaca, where
5 similar events happened over a course of a few days. And other villages
6 such as Lovas, which is near to Ilok, there was also an ultimatum issued.
7 There was always shelling from heavy weapons. At Tovarnik, for example,
8 many houses were badly damaged. The Catholic church was totally
9 destroyed, and the same thing started at Lovas and in other villages
10 closer to Vukovar.
11 Q. And, Mr. Kraljevic, the villages that you've named, Ilaca, Lovas,
12 can you tell us what was the majority ethnic group in those villages.
13 A. Yes, I can tell you. Based on the census, over 60 per cent of
14 the population of Tovarnik were Croats and some 30 per cent were Serbs.
15 At Lovas, over 90 per cent of the population was Croatian and there were
16 about 7 per cent Serbs.
17 MS. CLANTON: Now I would like the assistance of the Registrar,
18 please, to call up 65 ter 06329.1. This is Prosecution Exhibit 1723.
19 And for this to be on the monitor for the witness, please. It's a road
20 map of eastern Croatia and it's at tab 58.
21 THE REGISTRAR: Just for the record, this is Exhibit P1723.
22 Thank you.
23 MS. CLANTON:
24 Q. Mr. Kraljevic, do you see a map on the screen in front of you?
25 A. Yes.
1 MS. CLANTON: I would like to ask, please, for the usher's
2 assistance to provide Mr. Kraljevic with a pen that he can use to mark on
3 the map.
4 Q. Now, Mr. Kraljevic, I would like for you to draw a circle around
5 the villages that were attacked in the way that you've previously
7 MS. CLANTON: And sorry, perhaps we can zoom in a bit. Is it
8 possible? I'm interested in the area south and east of Vukovar, please.
9 A bit to the right. Would it be possible to go a bit further so that we
10 can see to the Croatian border? That's great. Thank you.
11 Q. Mr. Kraljevic, if you could circle the towns that you know
12 experienced events, experienced attacks like the ones you've just
14 A. Tovarnik, Ilaca, Lovas, and before that, we mentioned Sotin.
15 Q. Were there any other villages that were attacked in the fall of
17 A. It was further away from us so news didn't travel so easily, but
18 we know that there were incidents at Berak, and in these villages,
19 Cakovci, Tompojevci and Miklusevci. I don't think I need to go further
20 west. I know that in this triangle, Tompojevci, Miklusevci, Cakovci,
21 there is a rather strong ethnic minority of Ukrainians and Ruthenians.
22 Q. And, Mr. Kraljevic, you've told us about the villages that were
23 little a bit further away from Ilok, were there any villages going in the
24 direction of Ilok that you recall were also attacked?
25 A. We can mention Bapska and Sarengrad first. It was on the 4th --
1 just a minute. It was the 4th of October when, around noon, Sarengrad
2 was suddenly attacked with artillery and boats from the Danube and from
3 the other side of the Danube by forces of the JNA. That part of
4 Sarengrad is easily visible from the other bank of the Danube. Sarengrad
5 is on the river itself, and many houses were damaged and so was the
6 Orthodox church, which can be seen very well. There's also a Catholic
7 church there but it was not damaged because it wasn't so easily visible.
8 A civilian was killed and two members of the civil protection
9 were killed in a car. They happened to be there in that car and got
11 Q. I'm going to ask you to pause there. I see that you've circled
12 the town of Lovas. Can you tell me how many people were killed in Lovas
13 when it was attacked?
14 A. I'm sorry, may I first finish with Sarengrad because Bapska was
15 attacked on that very same day, the 4th. Representatives of the JNA were
16 deployed to the south of Sid. Many houses were damaged and a few people
17 were wounded, and with it, I would end.
18 Now, to come to Lovas, this happened practically a week later, if
19 this was on the 4th, and then again on the 10th, Lovas came under attack.
20 As a result, according to the information I received from the observers
21 some time later, 22 casualties were -- and all of them were civilians.
22 Q. And, Mr. Kraljevic, you've shown us where these villages are that
23 were attacked. Can you describe for us -- you don't need to mark
24 anything, just tell us in which direction the majority of the people fled
25 after their towns had been attacked?
1 A. Speaking of Lovas and Opatovac, which is on the very bank of the
2 Danube, this is Opatovac, this is Mohovo, the only possibility for the
3 population to withdraw and flee was towards Ilok. There was no other
4 option. Similarly, the population of Sarengrad and/or Bapska were also
5 withdrawing towards Ilok so that at that time, there was a large number
6 of civilians in Ilok, and there were fewer and fewer of facilities
7 providing conditions for normal life, which, of course, caused problems
8 for the residents of Ilok.
9 Q. I want to stop you there. Just so that we can be done with this
10 map, you now circled Opatovac and Mohovo. And for the record, I just
11 want to make clear, have you circled these towns because they were
12 attacked and the people fled?
13 A. No, they were not attacked.
14 Q. So that we can record the information that you've given to us, I
15 would like for you to please mark next to Opatovac and Mohovo the letter
16 N so we can record that they were not attacked, please.
17 A. [Marks]
18 Q. Could you -- I'm sorry, I know it's difficult to use the pen. I
19 think that will be a bit difficult to read. Could you please mark again
20 the letter N next to Opatovac and Mohovo for the record.
21 A. [Marks]. I have no experience with this kind of pen, therefore I
23 Q. It's okay.
24 MS. CLANTON: At this time the Prosecution would seek to tender
25 this map as marked by the witness, please.
1 JUDGE DELVOIE: Admitted and marked.
2 THE REGISTRAR: Exhibit P1723 marked by the witness in court
3 shall be assigned Exhibit Number P2017. Thank you.
4 MS. CLANTON: And we can take that down, please.
5 Q. Mr. Kraljevic, a moment ago you were describing the events in
6 Bapska, and previously you told us about ultimatums that were delivered
7 to the residents of these towns. I wanted to ask you if you ever had
8 occasion to see a copy of such an ultimatum?
9 A. Yes.
10 MS. CLANTON: I would like to ask for the Registrar to please
11 bring up 65 ter 00418, which is P316. This is tab 11.
12 THE WITNESS: [Interpretation] I can see it.
13 MS. CLANTON:
14 Q. Mr. Kraljevic, do you recognise this as a document that you
15 provided to the investigators of the OTP?
16 A. Yes, I do.
17 Q. Are you able to tell the Trial Chamber the name of the person who
18 authored this?
19 A. The author of this document is last name Barjaktarevic, first
20 name probably Slobodan, but I'm sure about his last name,
21 Major Barjaktarevic. He issued this document and sent it with
22 Boro Tomic, who was working at Mesnica in Sid. He was a resident of Sid,
23 but in the past he used to live in Bapska. And he was the one who handed
24 over the document to representatives of the local commune.
25 Q. Mr. Kraljevic, do you recall the names of the representatives of
1 the local commune who received this document?
2 A. Their names were Bozinovic and Rukavina. I believe that those
3 were the Rukavina brothers, Tomislav and -- I don't know exactly the
4 first name of the other one. Rukavina.
5 Q. And after this ultimatum was provided to these persons who were
6 the representatives of Bapska, what happened in Bapska?
7 A. Naturally, this document was exceptionally threatening in nature
8 and the population found it very hard to reach a decision. However, the
9 fulfillment of such conditions was not possible and a large number of the
10 inhabitants left for Ilok.
11 Q. And earlier you told us that there was an attack on Ilok. How
12 did you first hear about this document -- I'm sorry, an attack on Bapska,
13 excuse me.
14 A. Yes. I received this document from an office in Zagreb. It was
15 handed over to me by the representative of the Institute for History,
16 while they had received it from the TV station. Presumably it had been
17 given to the journalists by the local residents, and that is how the
18 document found its way to the Institute for History and eventually to
19 Ilok and me.
20 Q. What I want to ask you is at the time, so close to the time of
21 the date of this document and then the attack on Bapska, how did you
22 receive information that such a document had been provided? I don't mean
23 actually seeing the document but just that there was such a document that
24 had been provided?
25 A. They received information at the civilian protection HQ. I was
1 not a member of the civilian protection staff and I didn't know anything
2 about it at the time. I learned about this only a few days later, but
3 yes, the civilian protection staff. Because from Bapska, they
4 immediately went to the civilian protection staff to obtain information
5 because, of course, once the attack on Bapska started, members of the
6 civilian protection forces joined the defence of Bapska.
7 Q. Mr. Kraljevic, you've told us before that after these towns
8 including Bapska were attacked, the majority of the civilian population
9 fled to Ilok. I would like for you to explain briefly, describe the
10 conditions in Ilok with the refugees coming in.
11 A. There was a huge number of civilians who found shelter in Ilok.
12 The Red Cross of Ilok made arrangements for their accommodation in
13 private houses in socially-owned facilities, various halls, et cetera, so
14 that there was an enormous number of people in the town itself. Even in
15 my own house, there were six people from Lovas whom we put up. They were
16 mostly moving around the centre of town but would come over to spend the
17 night. It was a tense situation. It was difficult. We only had four
18 GPs. There were no medicines and the situation was very difficult.
19 I can tell you that in the course of all those days, life
20 nevertheless went normally, so to say. There was even a bus service for
21 as long as it was possible to maintain it, and I'm talking about the
22 service between Ilok and Backa Palanka. Cazmatrans, the company serviced
23 the route from Ilok, and there was another Serbian company driving from
24 Backa Palanka. However, on one day, while Cazmatrans bus was in
25 Backa Palanka, a number of individuals burst into the bus, identified
1 themselves as members of the Territorial Defence and they simply
2 requisitioned the bus and it had never been seen again.
3 Since we also had a terrible problem with food, and particularly
4 with medicines, in Ilok, the only person who was brave enough to go to
5 Sid was Ivica Matkovic. He managed to cross the border and he drove a
6 trailer lorry there, filled it with food and medicines, and on the way he
7 was stopped at Sid, sent him to prison, and they confiscated the whole
8 load of truck. That's how life was and how communications were.
9 I think as early as on the 6th of October, Ilok had been
10 receiving electricity from Backa Palanka because all the lines with the
11 Croatian electrical grid were severed. On that day, electricity supply
12 was simply cut off and all lines were practically severed. Fridges were
13 not working. Food was rotting in the fridge. There was no radio
14 transmission. There was no TV broadcast. A few people had transistor
15 radios, but since the relays were also demolished, we could not listen to
16 Radio Zagreb at all. The only radio station that we could listen to was
17 Radio Osijek. However, Belgrade-based radio stations were perfectly
19 Q. I'm going to stop you there, please, Mr. Kraljevic. I think
20 you've given --
21 A. Very well.
22 Q. -- a good idea of the conditions at that time in terms of the
23 refugees and supplies and the electricity.
24 A moment ago, you mentioned that there were persons from the
25 Red Cross who were involved in trying to deal with the situation in Ilok.
1 During this time period, I want to ask you, were there any other persons,
2 representatives from other organisations who were present in Ilok?
3 A. Before the 8th of October, there were no other individuals that
4 could have provided assistance in a humanitarian way. This was something
5 that the citizens themselves organised.
6 When I mentioned the Red Cross, I meant that the population of
7 Ilok held themselves as well, not only rely -- they didn't rely only on
8 the Red Cross. The situation was very serious although I must say that
9 there was a certain level of communication; however, at one point we
10 realised that Ilok was surrounded and that two monitors managed to come
11 to Ilok across the bridge. I am talking about Hugh Cunningham, a
12 Canadian, and Petr Kypr, a monitor from Prague, in Czechoslovakia.
13 Q. Mr. Kraljevic, to stop you for a moment, what organisations did
14 these monitors represent?
15 A. I believe that they were European Union monitors, but I don't
16 know exactly. Yes, European monitors. I don't know the exact name of
17 the organisation, really.
18 Q. And when these monitors arrived in Ilok, what did you tell them
19 about the situation in terms of the number of people and the difficulties
20 that you've described?
21 A. A few of us, I think there were three or four of us, informed
22 them about the entire situation; however, they were not satisfied with
23 that. They wanted to see for themselves. They went around Ilok. They
24 talked to people, and they could verify everything that we described for
25 them, which is the same as I did for you now. And in that way, they
1 managed to familiarise themselves with the situation in Ilok and the
2 surrounding area.
3 MS. CLANTON: I would like for the assistance of the Registrar,
4 please, to pull up 65 ter 00381. This is tab 3. It's a report of the
5 monitors, the European Commission, dated the 9th of October, 1991.
6 Could we have the B/C/S translation as well. And if we could
7 move the B/C/S a bit to the left so we can see the left margin, please.
8 Thank you.
9 Q. Mr. Kraljevic, I would like to you read in the B/C/S, which is on
10 the left-hand side of your screen, points 1 through 5, and then let me
11 know when you're done, please.
12 A. I have finished. May I read it now. Oh, yes, I'm sorry.
13 Number one, Ilok wasn't attacked.
14 Q. You can read it to yourself and let me know when you're done
15 reading 1 through 5.
16 A. I've read it.
17 Q. Okay. Mr. Kraljevic, we see in this report that the team of
18 monitors, I believe you said you met with a Mr. Cunningham and Mr. Kypr,
19 that they visited Ilok and this report says that -- the report describes
20 the situation in Ilok. And in point 5, do you see where it says that:
21 "Due to the factors which aren't listed above, the whole
22 community is under extreme stress."
23 A. Yes.
24 Q. Is this an accurate statement of the situation in Ilok when the
25 monitors arrived?
1 A. Yes, even more than that. In a nutshell, this was a description
2 of the prevailing situation.
3 MS. CLANTON: At this time, the Prosecution wishes to tender this
4 document into evidence, please.
5 JUDGE DELVOIE: Admitted and marked.
6 THE REGISTRAR: It shall be assigned Exhibit Number P2018. Thank
8 MS. CLANTON: And we could take that down now, please.
9 Q. Mr. Kraljevic, I want to change topics now and I want to ask you
10 about the negotiations -- may I proceed?
11 A. Please go ahead.
12 Q. I want to ask you about the negotiations that were held in
13 October of 1991 between the negotiating commission comprised of
14 representatives of Ilok and the JNA. My first question is: When did you
15 become involved in negotiations with the JNA?
16 A. I became personally involved on the 7th of October; however, the
17 negotiations with representatives of the Yugoslav Army lasted throughout
18 the whole summer because representatives of the local government, the
19 president and his deputies were maintaining contact, and due to the fact
20 that fields had to be worked and since the army was deployed in the area,
21 we always had to pass through these checkpoints, and that is why the
22 negotiations had been going for so long even before I joined them.
23 At first, a commission was set up made up of a number of people
24 representing all ethnic communities so that the negotiations could be
25 channeled properly and so that always the same persons would be involved.
1 This provided for continuous negotiations, primarily with
2 Colonel Grahovac whose units were stationed in Vojvodina, but also near
3 the bridge in the territory of the town of Ilok.
4 Q. Now, Mr. Kraljevic, can you tell me what position did you hold on
5 this commission?
6 A. At an extended meeting of the city council, a committee or a
7 commission was elected made up of several members. Among them was, for
8 example, Sulejman Salihovic, Josip Cermak, a Slovak by ethnicity.
9 Salihovic was a Muslim by affiliation. Then Lazar Kuljancic, a Serb;
10 Slobodan Savic, a Serb; Maja Samsalovic, who represented women. Then
11 there was Ivan Mrsic. He was the president of the Ilok Assembly. Then
12 villages were represented by Plazonic of Bapska, Rendulic of Lovas, and
13 from Sarengrad, yes, Dr. Holoker from Sarengrad. Well, that would be
14 more or less the composition of this commission.
15 After the commission was set up, we discussed issues at their
16 headquarters in Backa Palanka. It was a long meeting --
17 Q. Mr. Kraljevic, I'm going to ask you to pause for a moment,
19 The specific question that I would like for you to answer first
20 is: What was your position on this commission?
21 A. Actually, at that time I was elected chairman of that commission
22 as a senior person. I used to be a teacher in the secondary school, and
23 on the basis of that, they believed me to be a serious and composed
24 person capable of discussing and talking.
25 MS. CLANTON: Your Honour, I'm mindful of the time.
1 JUDGE DELVOIE: Thank you, Ms. Clanton.
2 Mr. Kraljevic, this is the time for our first break,
3 30-minute break. We'll come back at 11.00. And the court usher will
4 escort you out of the courtroom. Thank you very much.
5 THE WITNESS: Thank you.
6 [The witness stands down]
7 JUDGE DELVOIE: Court adjourned.
8 --- Recess taken at 10.31 a.m.
9 --- On resuming at 11.01 a.m.
10 MS. CLANTON: Your Honour, if I may, while the witness is being
11 brought in. During the break, I spoke to Mr. Zivanovic and he's
12 indicated that the Defence does not have an objection to the addition of
13 the two documents that were provided by Mr. Kraljevic yesterday. These
14 were disclosed and then sent through by separate e-mail, and so at this
15 time we would like to ask that they be added to the 65 ter list.
16 JUDGE DELVOIE: Are they already on your list of documents?
17 MS. CLANTON: They are. They are on the list that we sent
18 through last night.
19 JUDGE DELVOIE: Being tab numbers?
20 MS. CLANTON: 59. And there's actually a second 59 which should
21 have been a 60.
22 JUDGE DELVOIE: Two 59s. Okay.
23 MS. CLANTON: The 65 ter numbers are 06442 and 06443.
24 [The witness takes the stand]
25 JUDGE DELVOIE: You may add them to your 65 ter list, to the
1 65 ter list, Ms. Clanton.
2 MS. CLANTON: Thank you.
3 JUDGE DELVOIE: Please proceed, Ms. Clanton.
4 MS. CLANTON:
5 Q. Now, Mr. Kraljevic, before the break we were speaking about the
6 commission that was formed and your position on this commission as the
7 chairman. I would like to ask you, were you aware of negotiations taking
8 place -- I'm sorry, let me withdraw that.
9 You have told us that you were aware of negotiations taking place
10 prior to the time that the commission was formed in October of 1991, and
11 I want to ask you what you heard about who participated in the
12 negotiations prior to October 1991.
13 A. Petar Cobankovic took part in these negotiations. He was the
14 deputy of the president of the local commune of Ilok. Furthermore, there
15 was Ivan Mrsic, who was president of the Assembly of the local commune of
16 Ilok. Then there was Borislav Magovac, who worked at Backa Palanka and
17 knew many people there, including the mayor and others. Then there was
18 Ivan Uros, he was also a member of the Croatian parliament.
19 There were talks about various topics such as working the land
20 and other problems. The most serious problems were also discussed, such
21 as the eviction of population, and the army entering villages and towns.
22 Then the problem of displaced persons at Ilok and problems connected with
24 Q. Can I stop you there, please. You've told us the persons who
25 attended from Ilok. Can you describe for the Chamber who attended on the
1 other side for these earlier negotiations?
2 A. For the other side, there was always Petar Grahovac, colonel of
3 the Yugoslav army, and the representatives of Backa Palanka were the
4 president of the municipality, as far as I know. And when I was present
5 at the talks at Sid, there was also the deputy of the president of the
6 municipality of Sid.
7 There was also the deputy of the president of the Vukovar
8 Assembly, Mr. Kojic. I'm not sure about his exact position, though.
9 Q. Mr. Kraljevic, I'm going to stop you again, please. These
10 earlier negotiations that you've told us you heard about but did not take
11 part in, what was the thing that the JNA wanted from those negotiations?
12 A. The JNA had some main goals. First, for the civil protection to
13 surrender all their weapons. Secondly, they wanted the army to be let
14 into the populated places and search them. They also wanted to apply
15 sanctions to the people who had caused tensions or committed crimes in
16 those areas. They simply wanted to enter the town and impose military
18 Q. Mr. Kraljevic, what month were these negotiations held, these
19 negotiations that you were not part of?
20 A. The talks at Sid took place on the 30th of September. There were
21 other talks in early October, but there were other talks even before.
22 This would be it in a nutshell.
23 Q. Okay. Now I'd like to ask you about the talks that you
24 participated in. You've told us that there were talks in Backa Palanka
25 and that there was an officer of the Yugoslav army named Colonel Grahovac
1 who was involved in those talks. Can you tell us what Colonel Grahovac
2 said would happen if the wishes of the JNA were not respected?
3 A. The JNA demanded what I have just stated. Unless their demands
4 were met, that is the weapons, which were light weapons, rifles,
5 possession of the civil protection, they were to be surrendered by the
6 bridge at the Zec workshop and controlled by the army. They also wanted
7 to be allowed to take the city. Otherwise, they would use all their
8 firepower to make it happen.
9 Q. And what did Colonel Grahovac say about the events that could
10 take place in Ilok compared to what was taking place in Vukovar?
11 A. Yes. He said that their actions would be such that the combat
12 wouldn't go on for days, but given the imbalance of power, it would all
13 be over within hours. And that was a realistic expectation given the
14 imbalance of power.
15 Q. Now, other than Colonel Grahovac, who else did you meet with from
16 the JNA?
17 A. Colonel Tomic also attended the meetings regularly. Our
18 negotiating committee representing the town of Ilok said that we couldn't
19 yield to their demands because we didn't have the authority to take such
20 decisions. We were willing to disarm the civil protection but wanted to
21 store the weapons at the depot of the Ilok police. Furthermore, there
22 was no legal or constitutional provision allowing the army to enter Ilok
23 and keep law and order there. That was for the MUP, that is, the police,
24 to do.
25 Q. Mr. Kraljevic, I'm going to pause you again and ask you, you've
1 given us the names of Colonel Grahovac and Colonel Tomic. Were there any
2 other officers of the JNA who you remember meeting with?
3 A. Not up until the 11th of October. But General Dragoljub
4 Arandjelovic was Colonel Grahovac's superior, and the latter said that
5 that was the man to talk to about possible solutions to this crisis. And
6 he suggested that we go to Sid to speak to General Arandjelovic.
7 MS. CLANTON: At this time I would like the Registrar's
8 assistance. If we could please pull up 65 ter 05030.6. This is a
9 video-clip that comes from the video which has ERN V0004590, and in the
10 packet it's at tab 29. This is a news report, and I would like to play
11 it without the sound and I only want to play a part of it. And after we
12 play it once through, we'll go back and pause at a certain point, please.
13 If we could get it ready to play, please, from 34 minutes and
14 3 seconds to 34 minutes and 30 seconds.
15 [Video-clip played]
16 MS. CLANTON:
17 Q. Now, Mr. Kraljevic, were you able to see the image on the screen
18 in front of you?
19 A. Yes.
20 Q. Do you recognise either of the men who appear in this video-clip?
21 A. I see one man and that's General Arandjelovic.
22 MS. CLANTON: At this time we'd like to tender this still, which
23 has a separate 65 ter number. It's at 34 minutes and 30 seconds, and
24 that 65 ter is 05030.10.
25 JUDGE DELVOIE: Ms. Clanton, is that a clip or the photograph of
1 this man -- the image of this man?
2 MS. CLANTON: I would like to tender the image, please.
3 JUDGE DELVOIE: The image. Admitted and marked.
4 THE REGISTRAR: It shall be assigned Exhibit Number P2019. Thank
6 JUDGE DELVOIE: And I saw the witness change his glasses so he
7 probably did not see the beginning of the clip where the other man
8 appeared. I don't know if it is of any importance to you but just
9 telling you.
10 MS. CLANTON: I think since he's identified the person who is at
11 the still at the time code where the video was paused, I'm comfortable
12 with his identification.
13 JUDGE DELVOIE: Okay. Thank you.
14 MS. CLANTON:
15 Q. Mr. Kraljevic, a moment ago you told us about the demands of the
16 JNA, and you stated that the position of the commission was that they
17 would not be able to agree to those including the surrender of weapons.
18 I'd like to know if you ever provided an alternative peace proposal to
19 the JNA?
20 A. Yes, I was going to say that, that we put forward an alternative
21 proposal, namely for the civil protection to be disarmed and all their
22 weapons to be placed at the police station so that the police may do
23 their work. Because there were no conflicts, no clashes among the
24 population of the town or in the surrounding villages. There's never
25 been -- there had never been one incident justifying an intervention from
2 Q. Mr. Kraljevic, I want to ask you, please, were you able to give
3 your alternative proposal to General Arandjelovic?
4 A. Yes, we were. We gave them our proposal but they never even
5 looked at it. General Arandjelovic made his own proposal which was
6 actually an ultimatum for the surrender of the weapons. It had a number
7 of articles and he demanded that we sign it immediately. We replied that
8 we couldn't do that because it was for the citizens to decide about that
9 in a referendum. Our committee didn't have the authority to make such a
11 Q. Mr. Kraljevic, the ultimatum that was given to you, to your
12 committee by General Arandjelovic, what did it say about the surrender of
14 A. In that article or that provision of the agreement, which was an
15 ultimatum, stated that all the weapons had to be surrendered by
16 12.00 noon on the following day. The place where that should be done was
17 the workshop of Ivan Zec controlled by the JNA. If that wasn't done, the
18 army would enter the town and fulfill their task.
19 MS. CLANTON: I would like the Registrar to please pull up
20 65 ter 00403, which is Prosecution Exhibit 318. This is at tab 6.
21 Q. Mr. Kraljevic, do you recognise this as a document that you
22 provided to investigators of the OTP?
23 A. On the right side, no. On one side, there is the agreement
24 issued by the Yugoslav army, and on the other side there's something in
25 English. Oh, must be the English translation. This is the agreement as
1 proposed by Arandjelovic on the 12th of October.
2 Q. I would like to ask you to look at clause 1, please. It says
3 that all weapons should be surrendered to the JNA, in particular to the
4 members of the 1st Military District.
5 A. Regardless of how they were obtained, to the military police of
6 the 1st Military District, safe access to Ilok, and a search of all
7 private, social and state facilities --
8 Q. Sir, if I could ask you to pause, please. I didn't intend for
9 you to read it.
10 If you could now look at clause 7, please. Here it says that if
11 weapons are used or if the security of the JNA is threatened, retaliatory
12 measures are authorised. I want to ask you what kind of retaliatory
13 measures did you think could happen?
14 A. First of all, there was never any threat to the security of JNA
15 members, nor was that possible in practice. But retaliatory measures is
16 a phrase that we understood implying everything that had already been
17 happening in all those villages, that houses would be entered, that
18 people would be killed, that there would be no law and order, which would
19 allow individuals to commit crimes, atrocities, beatings. So that was
20 what we could expect. It had happened at Bapska, Tovarnik, Lovas before,
21 basically everywhere where the units had entered.
22 Q. Mr. Kraljevic, you told us that when this ultimatum was put to
23 you, the members of the negotiating commission could not agree to it and
24 that they had to go back and speak to the people. Now, before the
25 meeting ended with General Arandjelovic, do you remember if the members
1 of the commission asked any questions to General Arandjelovic?
2 A. It was a long conversation because there was a number of people
3 there, the entire committee, practically, and I mentioned the names
4 already. For example, Mr. Mato Brletic, the Ilok police commander, told
5 the General that there were over 10.000 people at Ilok and asked him if
6 he wasn't sorry because there would have to be casualties. Arandjelovic
7 replied: "I'm a soldier and I will do what I'm told, that is take the
9 On the 10th, the previous day, at Lovas, over 20 people, actually
10 22 to be precise, which figure I learned later from the European
11 monitors, had been killed. Mr. Rendulic asked why so many people had
12 been killed at Lovas. The General replied it had been done in
13 retaliation for the death of a soldier whose body was found in a
14 cornfield. But there was no body found in a cornfield. Nobody ever
15 proved that. This was a clear indication of what we could expect if the
16 units were to enter town.
17 Q. Now, I want to ask you about what was happening amongst the
18 community leaders of Ilok at this time, so after you finished your
19 meeting with General Arandjelovic when he delivered this ultimatum, I
20 want to know if you recall that there were discussions among the
21 community representatives about what had happened during those
23 A. Representatives of Sarengrad -- excuse me, Bapska, given the fact
24 that the majority of Bapska residents were in Ilok, asked Arandjelovic to
25 go to Bapska in order to collect some of their belongings, at least the
1 basic ones --
2 Q. If I could ask you to pause for a moment. The question that I've
3 asked you actually pertains to what was happening in Ilok at the time, if
4 there were any meetings among people in Ilok about what had happened
5 during the negotiations.
6 A. All I wanted to say was to describe what was still happening in
7 the meeting of the 11th, when General Arandjelovic issued a few passes to
8 citizens allowing them to go to Bapska and gather their things. I'm
9 sorry, I'll finish very soon.
10 Q. Can I just ask you to pause there because we will come to these
11 topics, but for right now, I want to ask you about when you went back to
13 Were there meetings of any community group to discuss what had
14 happened in the negotiations?
15 A. Well, I believe that our commission conveyed all the information
16 to the citizens. It typically happened in the culture hall where a huge
17 crowd of citizens were present, not only representatives of the
18 authorities from Bapska, Lovas and other places. Everybody was
19 interested to know what was going on. We informed them about the
20 negotiations because the majority of residents wanted to protect their
21 own lives. We also discussed the issue of evacuation of the population
22 so as to see how to deal with things for at least a certain period of
23 time until the issues have been resolved. You are probably aware that at
24 the time, there were intense intergovernmental talks at the highest level
25 between Mr. Tudjman and Mr. Milosevic, and at the time, we expected a
1 certain agreement to be reached which would calm the situation. Now,
2 there were constant agreements being signed about cease-fire but
3 cease-fire never happened. So there were negotiations going on a daily
4 basis, but the point was that nobody was willing to leave their place of
5 residence and that was the main point.
6 When we talked to the citizens, we told them --
7 Q. Mr. Kraljevic, what I want focus on is what you just said, that
8 you were part of the group that talked to the citizens and that these
9 questions about solutions at a national level and also about what would
10 happen in Ilok were being raised and addressed in your community, which
11 you've just told us.
12 MS. CLANTON: I would like to ask for the Registrar to please
13 bring up 65 ter 00214, which is Prosecution Exhibit 321. This is at
14 tab 23, and these are the minutes of the Ilok urban community Assembly
15 from this time period in 1991.
16 Q. Now, Mr. Kraljevic, since you arrived here in The Hague, have you
17 had an opportunity to read the minutes of the Ilok community Assembly
18 which are in front of you on the left-hand side of your screen?
19 A. Yes.
20 MS. CLANTON: If we could please scroll down to the last page, I
21 think it's page 5.
22 Q. Now, Mr. Kraljevic, do you recognise the signature at the bottom
23 right of this page?
24 A. Yes.
25 Q. Whose signature is it?
1 A. It's my signature.
2 Q. And do you recognise the name or the signature that's at the
3 bottom left of the page?
4 A. Yes, Nevenka Brkic, note-taker of the Ilok town government. I
5 recognise her signature.
6 Q. Now, Mr. Kraljevic, since you've had an opportunity to read these
7 minutes, can you confirm that the minutes are a true and accurate
8 reflection of the discussions of the community leaders in Ilok at this
10 A. Yes.
11 MR. ZIVANOVIC: Sorry.
12 JUDGE DELVOIE: Mr. Zivanovic.
13 MR. ZIVANOVIC: Sorry, if we can have clarification what does it
14 mean "at this time"?
15 MS. CLANTON: If I may, Your Honour, I was referring to the dates
16 that are in the minutes which span from the 6th of October to the
17 16th of October, 1991.
18 JUDGE DELVOIE: Does that satisfy you, Mr. Zivanovic?
19 MR. ZIVANOVIC: Yes, Your Honours. Thank you.
20 JUDGE DELVOIE: Thank you.
21 MS. CLANTON: And we can take that down now.
22 Q. Mr. Kraljevic, I would like now to turn back to what you were
23 telling me about a moment ago, which was the events that led to the
24 organisation of a referendum on the 13th of October, 1991. As you've
25 explained, this was a referendum for the community related to the
1 ultimatum that we were just talking about.
2 Can you tell me how many questions were put to the people in Ilok
3 in this referendum?
4 A. The referendum was called to be held on the Sunday and there were
5 two questions on ballot papers -- or actually, there were two types of
6 ballot papers. One contained the question whether you are in favour of
7 handing over the weapons to the JNA and to allow the entry -- I'm sorry,
8 it was not in the question. The question was only relating to the
9 handing over of the weapons to the JNA.
10 Attached to this ballot paper and displayed at polling stations
11 and every public places, an ultimatum that had been submitted to us on
12 the 11th of October by the JNA during the talks in Sid, and there was
13 another ballot paper asking the citizens to say whether they were in
14 favour of evacuation or migration of the population in the event of a
15 crisis emerging, by which we meant an attack by the army and their
16 entering Ilok. Because they explicitly said either the weapons and the
17 entry into Ilok or any further negotiations will be suspended.
18 MS. CLANTON: Now if the Registrar could please assist by pulling
19 up 65 ter 00404, which is Prosecution Exhibit 319. This is at tab 7.
20 Q. Mr. Kraljevic, do you recognise the document on the left as a
21 document that you provided to the investigators at the OTP?
22 A. I and my colleagues drafted the wording of this paper. In the
23 first one -- I don't need to read it; is that right?
24 Q. That's correct. Do you recognise this as a document that you
25 provided to the investigators of the Office of the Prosecutor?
1 A. Yes.
2 MS. CLANTON: If we could please have now 65 ter 06442.
3 Q. Mr. Kraljevic, do you recognise the document front of you as a
4 document you provided to the Office of the Prosecutor yesterday?
5 A. Yes. Yes.
6 Q. And can you explain, in the first line where it's handwritten and
7 says "veterinary," what does this place name refer to?
8 A. That's a veterinary station in Ilok. It's located on
9 Radiceva Street, on the road from the centre of Ilok towards Sid. There
10 were five such polling stations and the citizens could vote at these
12 Q. Mr. Kraljevic, is it correct that the names of the polling
13 stations appear on each of the pages that you gave to us yesterday? At
14 the top of the page.
15 MS. CLANTON: If the Registrar could briefly scroll down --
16 THE WITNESS: [Interpretation] Yes.
17 MS. CLANTON: Actually, it's okay.
18 Q. Now, Mr. Kraljevic, you've told us that these documents record
19 the place where the people were voting. What I now want to ask you is if
20 the numbers on the documents reflect the numbers of votes that were cast?
21 A. You will see the signatures of the members of the committee which
22 confirm this. There is also a final report, an aggregate report from all
23 polling stations.
24 Q. Before we get --
25 A. Therefore, the guarantee is provided by the signatures we see
1 here. I don't need to give you any further guarantees.
2 Q. Before we get to the aggregate document that you've mentioned, I
3 want you to explain. On the page that's in front of you, about
4 two-thirds of the way down the page where it says there are 508 ballots
5 reflecting the wishes of 1059 citizens. Can you briefly tell the Trial
6 Chamber why those numbers are different?
7 A. The number of ballot papers where the word "for" was 508 --
8 THE INTERPRETER: Could the witness please repeat the figures
9 once again. Thank you.
10 MS. CLANTON:
11 Q. Mr. Kraljevic, excuse me. The interpreter would like for you to
12 please repeat what you just said about the figures.
13 A. The 508 people encircled the word "for," and at the bottom you
14 see the figure 1059, which includes their family members including
15 children who were ready to move out. So that means that they voted
16 for -- on behalf of all members of their families because children cannot
17 vote. Or, for example, a wife would vote on behalf of both her husband
18 and children.
19 I hope I was clear.
20 MS. CLANTON: Yes. At this time we would like to have this
21 document, 06442, admitted into evidence.
22 JUDGE DELVOIE: Admitted and marked.
23 THE REGISTRAR: It should be assigned Exhibit Number P2020.
24 Thank you.
25 MS. CLANTON: And if the Registrar could assist by please
1 bringing up 06443. This is the second document that was provided by the
2 witness yesterday, and it's at the second tab 59 which should be tab 60.
3 Q. Mr. Kraljevic, a moment ago you mentioned that there was a table
4 that has the aggregate results from the various polling stations. Is
5 this the table that you're referring to?
6 A. Yes.
7 Q. And there's a Roman numeral 1 and there's a Roman numeral 2. Can
8 you briefly explain what Roman numeral 1 reflects and then what Roman
9 numeral 2 reflects?
10 A. Under Roman numeral number 1 is the results of the voting on the
11 handing over of weapons and signing the agreements. The total against
12 were 71 per cent or 2519 people constitutes the number of turnout.
13 And the second ballot paper contains votes of people in the event
14 of a crisis emerging. I think that the total number is, if I see
15 correctly, 2577, which means that 73 per cent were for and 11 per cent
16 were against. Totalling 497 people.
17 MS. CLANTON: At this time we would seek to have this document,
18 65 ter 06443, be admitted into evidence, please.
19 JUDGE DELVOIE: Admitted and marked.
20 THE REGISTRAR: It should be assigned Exhibit Number P2021.
21 Thank you.
22 MS. CLANTON:
23 Q. Now, Mr. Kraljevic, you've just told us the results of the
24 referendum that was held on the 13th of October, 1991. I want to ask
25 you, how did you convey the results of the referendum to the JNA?
1 A. The referendum was held on Sunday, the 13th of October. Before
2 that, in the meeting with General Arandjelovic on the 11th, we agreed
3 that after the referendum he would be given all the results on the Monday
4 at 12.00, that is to say, on the 14th of October. Prior to that, we had
5 a session of the town council and we informed all the citizens who were
6 present about the results, at least those who were at the culture hall at
7 9.00. And then at 12.00, we were in Sid where we went to see
8 General Arandjelovic to inform him about the results of the referendum.
9 Q. And was there anyone else present at the negotiations other than
10 the people who were part of your negotiating commission and
11 General Arandjelovic?
12 A. This meeting where information was conveyed was attended by two
13 ECMM members, namely Hugh Cunningham and Petr Kypr. The two were a bit
14 late in arriving at the meeting, but practically, they did attend the
15 entire duration of the meeting.
16 Q. And can you describe for us what happened at this meeting?
17 A. To put it simply, as the chairman of the committee, I informed
18 the General about the decision of the Assembly and the outcome of the
19 referendum. He only said, "Well, that's how you decided," and he
20 suggested that we draw up an agreement on the migration of people from
21 the town.
22 Q. And what did this agreement say?
23 A. I think that this agreement had several clauses, a dozen or so, I
24 don't know exactly. It says that if citizens want to leave and move
25 out -- although when any such notes were made, we lodged protests, it
1 wasn't acceptable. Quite simply, this agreement was simply dictated by
2 the Sid Municipal Assembly to the typist secretary who was also present
3 at the meeting. Mr. Brletic and I were present while this agreement was
4 being dictated to the typist, but we didn't have any room to exert any
5 influence on the contents and conclusion of such an agreement.
6 At the very meeting, we underlined, and we did the same in the
7 presence of the observers, that we didn't want to leave Ilok because that
8 meant that we would have to leave everything behind, and we were
9 wondering about what our prospects were, how people would return and
10 everything was an unknown. We had no place to go. It's very difficult
11 to leave your home and go to an unknown place where you don't know
12 anyone. And the observers also wanted to hear that. But there was one
13 request that was permanently repeated and that is that the JNA must enter
14 the town, must take and confiscate the arms, and must search all the
15 facilities, and if they find someone with hidden weapons, they would take
17 In a nutshell, there was no other way out so we had to sign this
19 MS. CLANTON: I would like the assistance of the Registrar,
20 please, to pull up Prosecution Exhibit 1419, which is 65 ter 5057. This
21 is at tab 36.
22 Q. Mr. Kraljevic, do you recognise this document?
23 A. Yes.
24 MS. CLANTON: If we could go to the last page, please.
25 THE WITNESS: [Interpretation] Yes.
1 MS. CLANTON:
2 Q. Whose signature is on the bottom -- I'm sorry, on the left side?
3 A. Mr. Ivan Mrsic.
4 Q. And on the right side?
5 A. Mr. Dragoljub Arandjelovic, the General, and commander of the
6 area on behalf of the Yugoslav Army.
7 Q. Mr. Kraljevic, just so that the record is clear, do you recognise
8 this as the document that was signed on October 14th, 1991, that we've
9 been discussing?
10 A. Yes.
11 Q. Now, after this agreement was signed, did any of the people who
12 were representing Ilok, any of the people who came as part of the
13 commission, did they have any requests to make or any statements related
14 to how they were going to be able to leave?
15 A. Well, everybody was just saying that they didn't want to leave,
16 but that the army should show at least some degree of benevolence and
17 allow the residents to stay in their home and not move out. However,
18 their position was very firm and there was no way of influencing it.
19 For that reason, the citizens requested at least to be provided
20 with some degree of safety while they were leaving the area, to be
21 allowed to take some of their possessions with them, and these provisions
22 were entered into the agreement. So in short, that would be it, and
23 these requests were approved.
24 Q. Earlier when we were discussing negotiations, you mentioned that
25 there were people who were part of this commission who were
1 representatives from Bapska and that they wished to be able to gather
2 their belongings. Do you recall that any of the people from Bapska were
3 making this request during this meeting?
4 A. Yes. There was Mr. Ivan Sablic, he also requested permits. The
5 General issued passes, and some residents of Bapska went from Ilok to
6 Bapska to gather their belongings. But you see, once they received
7 Bapska, they were thinking of taking a shortcut towards Sid. Although
8 they had the passes, they were stopped on the way. Some of them ended up
9 in the Begejci camp, some were detained in Sid, I think in a sports hall.
10 And some ended in the Begejci camp, including Mr. Sablic, and I think
11 that he was exchanged sometime around the 15th of December, 1991.
12 MS. CLANTON: I'd like for the Registrar's assistance to please
13 pull up 65 ter 00438, which is at tab 14.
14 Q. Mr. Kraljevic, do you recognise this list?
15 A. Yes.
16 Q. Do you recognise the signature?
17 A. Yes.
18 Q. Whose signature is it?
19 A. Mine.
20 Q. And I would like for you to look at this list and tell me if any
21 of the people who are on this list were part of the group that you've
22 described that sought to have permits to go back to Bapska and gather
23 their belongings.
24 A. Miroslav Kolak, Nada Vrbanic, Ivan Mijic, that is number 11, 7,
25 and 3. They were in a passenger car accompanied by another person. When
1 they were leaving Bapska, fire was opened at them without any warning.
2 Mijic was wounded, but survived.
3 Q. Mr. Kraljevic, are you saying that it is not correct where it
4 says that Mijic was killed in Bapska on Bracka Radic Street on the
5 14th of October, 1991? This is number 11.
6 A. Yes. Killed on the 14th of October in Bapska by the JNA on
7 Bracka Radic Street. We can even see the name of the street here.
8 Q. Is it correct that he was killed in this way on the
9 14th of October, 1991, on the street Bracka Radic Street?
10 A. Yes.
11 MS. CLANTON: At this time, Your Honours, we'd like to tender
12 65 ter 00438 into evidence, please.
13 JUDGE DELVOIE: Admitted and marked.
14 THE REGISTRAR: Should be assigned Exhibit Number P2022. Thank
16 MS. CLANTON:
17 Q. Mr. Kraljevic, now I want to talk to you about your departure
18 from Ilok on the 17th of October, 1991. As you were preparing for the
19 departure on that day, can you describe the atmosphere in Ilok?
20 A. First of all, after the signing of this agreement, we organised
21 for the population to be informed about this agreement and their options.
22 The citizens understood they didn't need much explanation of the
23 situation at Ilok because they could see it for themselves. We just told
24 them that it was up to them to decide what to do because a date had been
25 set and it had been set with the representatives of the JNA, but the
1 evacuation of the population could be done in various ways. They could
2 either leave towards Backa Palanka and Nestin, which is in Vojvodina,
3 that is Serbia, or through Sot, Sid, Adasevac, Lipovac, to Croatia. They
4 could either stay or leave in one of these ways. And the situation
5 itself, I don't know what to say about it. The citizens were informed.
6 They could decide for themselves. We couldn't and wouldn't guarantee
7 that they would fare better if they stayed or left.
8 We didn't know whether anybody would stop them during their
9 departure. We couldn't give any guarantees. The guarantees were given
10 by the army according to the agreement. That would be it in short.
11 Q. During this time period, what kinds of noises or sounds could you
12 hear in Ilok?
13 A. First of all, at that time there was still heavy shelling in
14 Vukovar. There were detonations all the time, aircraft flying over Ilok.
15 And at Principovac, where the JNA units were, there were very strong
16 loudspeakers from which you could often hear folk music with offensive
17 lyrics. Often there was shooting from machine-guns that could be heard
18 on the streets of Ilok. That was the situation.
19 Q. And during this time, what preparations were made in respect of
20 certain items of the cultural heritage of Ilok?
21 A. We spoke about that to Colonel Grahovac. We wanted to evacuate
22 the most important exhibits from the museum because the museum belonged
23 to the population of the town, the inhabitants, so if the inhabitants are
24 leaving, we also wanted to preserve those unique exhibits. They were
25 indeed packed by the museum staff, but at the last moment, an order came
1 in that nothing could be taken away. I can add now that most exhibits
2 have been preserved. During the occupation, one staff member stayed
3 throughout that period and some others also stayed, but the most valuable
4 22 paintings disappeared. They were cut out from their frames and taken
6 Q. Mr. Kraljevic, I would like to go back for one moment, please.
7 You answered a question that I asked and told me about songs that were
8 being played from speakers from where the JNA was at Principovac and you
9 described the lyrics as offensive. Can you tell me what was offensive
10 about the lyrics, what were they saying that was offensive?
11 A. There were all kinds of lyrics. It's better not to go into that.
12 We know what it was about. Three more days only and then there will
13 be -- those things, I really wouldn't speak about it. Everybody
14 understood anyway. Various things had happened even before. People were
15 arrested and taken away --
16 Q. If I ask you to pause, please. I know that you understand why
17 the lyrics were offensive, but for the benefit of everyone in the
18 courtroom, would you please tell us who they were offensive to or in what
19 way they were offensive?
20 A. Well, if there is talk about slaughter, then it is offensive, of
21 course. There are various kinds of songs, songs saying that -- or,
22 rather, expressing no good wishes to the population.
23 Q. Mr. Kraljevic, these songs that you've now described, in the
24 lyrics, who is being slaughtered?
25 A. Who is being slaughtered? Well, you know, it's a campaign of
1 fear. It didn't mean that it would really happen but it's good for
2 instilling fear in people. But it's certainly true that during the war
3 all sorts of things happened.
4 Q. Mr. Kraljevic, you've now said that these lyrics had the effect
5 of instilling fear even if the threat was not actually carried out in
6 terms of an actual slaughter event. What I'm interested in finding out
7 is who felt fear, who felt threatened?
8 JUDGE DELVOIE: Mr. Zivanovic.
9 MR. ZIVANOVIC: Sorry, may we have clarification was it lyrics,
10 poems, poetry or songs?
11 MS. CLANTON: Your Honour, I understood from the translation that
12 he was referring to the lyrics in a song. If you would like for me to
13 clarify with the witness, I can do that.
14 THE WITNESS: [Interpretation] The songs that were being sung,
15 that's what I'm talking about.
16 JUDGE DELVOIE: It's already in the answer, I think, at --
17 THE WITNESS: [Interpretation] The songs that were sung.
18 JUDGE DELVOIE: -- 49, 22 or 49, 21. Yeah.
19 MS. CLANTON:
20 Q. And, Mr. Kraljevic, to go back to my question on this, you've
21 said that the lyrics of these songs and the playing of these songs had
22 the effect of instilling fear in people. Was there a group of people who
23 the songs had the effect of instilling fear in them?
24 A. Members of the civil protection were especially frightened but
25 also the members of the Croatian Democratic Union, the HDZ, because there
1 were always threats to the HDZ, but also to the civil protection and
2 anybody who had any sort of weapon or some such.
3 MS. CLANTON: Your Honour, I'm mindful of the time.
4 JUDGE DELVOIE: Thank you very much, Ms. Clanton.
5 Mr. Kraljevic, this is the time for our second break for half an
6 hour as well. So we will come back at 12.45. The court usher will
7 escort you out of the courtroom. Thank you.
8 THE WITNESS: [Interpretation] Thank you.
9 [The witness stands down]
10 JUDGE DELVOIE: Court adjourned.
11 --- Recess taken at 12.16 p.m.
12 --- On resuming at 12.45 p.m.
13 [The witness takes the stand]
14 JUDGE DELVOIE: Please go ahead, Ms. Clanton.
15 MS. CLANTON:
16 Q. Mr. Kraljevic, before we took the break, we were talking about
17 the departure of the people from Ilok on October 17th, 1991. Can you
18 tell the Chamber, briefly, what time the convoy was supposed to leave?
19 A. On the 17th starting at 7.00 and as long as was necessary for
20 everybody to leave. It meant that the people who wanted to leave with
21 their property on trailers and vans, or whatever vehicles, formed a
22 convoy which then set off. Before that, according to the agreement, the
23 police had to collect the weapons and hand them over to the JNA by the
24 bridge. That was done. As far as I know, it must have been at 7.00.
25 The police did that. I am not familiar with the details of the process.
1 Q. Mr. Kraljevic, I'm going to pause you there. I would like to
2 know now, where were the people who were leaving Ilok supposed to gather?
3 A. They gathered to form a convoy toward the bridge. I don't know
4 how to describe it. It's the main street from -- it leads from Ilok to
5 Backa Palanka and Nestin. That street was packed. But the side streets
6 were also full of displaced persons. Some people were simply in front of
7 their houses, and that convoy slowly moved all day.
8 Q. And, Mr. Kraljevic, who was in charge of processing the people in
9 the column, the people and the vehicles in the column?
10 A. It was said by way of informing the people and the people
11 themselves. The column moved slowly. There were also some monitors,
12 they were four of them at the time, and they were going up and down the
13 column. That's what the police did also. But it was an orderly process,
14 and about half a day -- it took half a day to get from Ilok to the
16 Q. Mr. Kraljevic, when you got to the checkpoint, who was at the
18 A. There were people in JNA uniforms, nobody I knew. There were a
19 few people in uniforms who were from Ilok, but it doesn't matter.
20 MS. CLANTON: I'd like Mr. Laugel to please assist by playing a
21 video-clip. It's actually two video-clips and I'd like to play them back
22 to back. The first one is very short. It's 65 ter 04929.4. And this
23 comes from the video with ERN V0003949.
24 If you could just wait one moment, Thomas.
25 He is going to play from 7.05 to 7.58.
1 Q. And I want to make sure that, Mr. Kraljevic, if you need to
2 switch your glasses to able to see the screen, please do so.
3 A. I can see well enough with these. As long as there's no need to
5 MS. CLANTON: We're not going to play the sound on this. It's
6 only for the images, and I want to warn the Chamber that the quality of
7 this video is not very good. We're only going to play a short part, but
8 it will freeze in certain parts but it will pick back up.
9 [Video-clip played]
10 MS. CLANTON: And now I would like for Mr. Laugel to play the
11 video that has 65 ter number 05016.2. This would be starting at
12 31 minutes, 15 seconds to 32 minutes and 20 seconds. I would also like
13 for this one to be played without the sound. I should have said the
14 previous video was at tab 56. This one is at tab 57.
15 [Video-clip played]
16 MS. CLANTON:
17 Q. Now, Mr. Kraljevic, I would like to ask you, do you recognise the
18 town where this footage was taken?
19 A. Yes, there are two situations. One is at Ilok, one of the
20 columns. You can tell by the checkpoints at the points of exit. There
21 are many sandbags and there were many soldiers watching the column leave
22 Ilok. There is also a still of the column at Ilok itself. Some of it
23 was taken at Sarengrad. I saw the Orthodox church there.
24 Q. Mr. Kraljevic, if I could ask you to pause, please.
25 MS. CLANTON: I think this was the part of the video that we were
1 not intending to show, but if it would assist the Court, we could have
2 the witness identify that part. I was interested in the footage that
3 he's already described. It was just a technical thing when we started
4 the clip that it started a bit early.
5 JUDGE DELVOIE: It's your call. Go on, Ms. Clanton.
6 MS. CLANTON:
7 Q. Mr. Kraljevic, the footage of the people and the convoy and
8 soldiers at the checkpoints, are you informing us with your previous
9 answer that this is all footage that was from Ilok?
10 A. Apart from what I said about Sarengrad, yes. Although I cannot
11 be sure of some of the footage. It seems that some of it was not taken
12 at Ilok, but this was.
13 Q. Mr. Kraljevic, the footage you've described of the convoy of
14 people and the checkpoint and the soldiers and the roads that you've
15 identified are in Ilok, does this footage match what you saw and
16 experienced on the 17th of October, 1991?
17 A. Well, yes. I was in that column very long -- it was a very long
18 column. I was part of it. I know what it all looked like. It was a
19 beautiful day. People moved about, talked in groups --
20 Q. Mr. Kraljevic, if I could pause you. I'm sorry, we have limited
22 MS. CLANTON: At this time I would like to have the video-clips,
23 04929.4 and 05016.2, admitted into evidence. There are no transcripts,
24 it's only for the images.
25 Your Honour, I had asked that the two video-clips be admitted
1 into evidence.
2 JUDGE DELVOIE: I'm sorry, I missed that, Ms. Clanton. Admitted
3 and marked.
4 THE REGISTRAR: They should be assigned Exhibit Numbers P2023 and
5 P2024 respectively. Thank you.
6 MS. CLANTON:
7 Q. Mr. Kraljevic, I want to ask you if all the persons who tried to
8 leave Ilok in the convoy on the 17th of October were able to leave in the
10 A. Yes. They were supposed to leave because an order came on the
11 last day that, according to Mr. Grahovac, even the most hardened
12 criminals are free to leave with the column provided they wished to do
13 so. That was apparently a decision reached at a higher level, but I was
14 not interested in that. But I have to say that 17 people were singled
15 out and taken away from the convoy. The check-ups involved the checking
16 of identification cards and those who were doing the checking were
17 comparing the data with some lists, and they singled out the 17 people I
18 mentioned. I myself did not see it. I may have been in the front of the
19 column or in the back, but we received information that 17 people were
20 taken out of the column. Most of them, except for two or three who were
21 wounded and taken to hospital, ended up in the Begejci camp.
22 Q. Mr. Kraljevic, you've explained that you did not see this. It
23 was not in the part of the column where you were at that time, but if you
24 know, can you tell us who pulled these people, these 17 people aside?
25 A. Well, the checkpoints were manned by the representatives of the
1 army and that is what they did. Whether there were any paramilitary
2 troops with them, I cannot tell. Some people had been seen around, but
3 it's not relevant.
4 MS. CLANTON: If I could ask the Registrar to assist by pulling
5 up 02215, 65 ter 02215. This is a list of persons separated from the
6 convoy. It's at tab 24.
7 Q. Now, Mr. Kraljevic, do you recognise this list?
8 A. Yes.
9 Q. Who prepared this list?
10 A. On the basis of various pieces of information while I was working
11 at the government in Zagreb, people came and provided information with
12 regards to those who were separated, but I received information from
13 other sources and other individuals as well, but I cannot tell you
15 Anyway, these 17 people were singled out on that occasion and
16 taken out of the convoy.
17 Q. Mr. Kraljevic, a moment ago you told us that you believed that,
18 other than two or three persons who had been wounded, that many of these
19 people on the list were taken to the Begejci camp. Can you confirm that
20 this is the list with those people you're referring to?
21 A. Are you referring to the ones that were taken to the hospital
22 because they were wounded?
23 Q. I'm asking you to confirm that a moment ago when you said that
24 people who were taken out of the convoy were taken to Begejci, that this
25 list contains the names of some of those people?
1 A. With the exception of two, all of them.
2 MS. CLANTON: At this time, Your Honours, I would like to have
3 65 ter 02215 admitted into evidence, please.
4 JUDGE DELVOIE: Admitted and marked.
5 THE REGISTRAR: It should be assigned Exhibit Number P2025.
6 Thank you.
7 MS. CLANTON:
8 Q. Now, Mr. Kraljevic, I want to move on to a new topic and that is
9 what you learned about the situation in Ilok after the time that you had
10 left Ilok.
11 Now, while you were mayor of Ilok in exile in Zagreb, can you
12 tell us how you collected information about the situation in Ilok, in
13 particular related to the people who were still there?
14 A. I can tell you that in the town of Ilok itself, there remained
15 probably approximately 1300 inhabitants that we might say were
16 representative of the Croatian community. The majority of Slovaks, if
17 they left at all, went towards Backa Palanka, which is quite
18 understandable because they had large families in Vojvodina. As a rule,
19 they came back very soon thereafter.
20 Q. Mr. Kraljevic, sorry, I need to ask you to pause, please. The
21 question that I asked you relates to when you were serving as mayor. How
22 did you get information about what was happening to the people who had
23 stayed behind in Ilok?
24 A. Yes, I'm sorry. All I wanted to say was that there were people
25 who stayed behind in Ilok who were later expelled. And those who were
1 not expelled managed to go via Vojvodina to Hungary, and then across the
2 border between Hungary and Croatia, they would reach Zagreb, and it is
3 from them that we received information. Some people used telephones
4 provided by the International Community. There were various ways of
5 communication, but the information was mostly provided by the people who
6 managed to cross the border, especially after these expulsions.
7 Q. Mr. Kraljevic, you've just mentioned expulsions taking place in
8 Ilok after the time that you left. Do you know who caused people to be
9 expelled from Ilok?
10 A. According to the statements given by the individuals coming from
11 the area, the situation was somewhat peaceful while Colonel Grahovac was
12 in Ilok. He was in charge of maintaining law and order in the town
13 itself and it seems that that was the situation then. However, he left
14 the area in January, late January, he left his position, and practically
15 the command of the town was taken over by the police and the local
16 self-government, and this is particularly a time that was very difficult.
17 But also in the period immediately after our departure, and this was
18 reflected in people being brought into the police premises, being
19 interrogated, and a huge number of people were expelled.
20 Q. Mr. Kraljevic, you've told us about two time periods here.
21 You've said immediately after -- or in the months after the column left
22 that people were taken into police stations and mistreated. And then, if
23 I understand correctly, you've told us that after Colonel Grahovac left
24 the area, you said it was a very difficult situation. Can you elaborate
25 a bit more about what you know about it being a very difficult situation?
1 A. The houses that were vacated were being plundered. People used
2 to come from other areas as well, various individuals who were looting
3 the town. Soon thereafter, people started moving into the houses. There
4 were refugees from western Croatia in Backa Palanka and they started
5 moving into those houses in an organised manner. The keys to the houses,
6 if they were left at all, were left with neighbours. If it was
7 impossible to open the door, then they were forced opened. But people
8 were moving out and, as far as I can tell, it was done in a rather
9 organised way.
10 Some people may not have been very happy and they started looking
11 for better houses, especially if there were elderly people living alone
12 in those houses, and they were subjected to maltreatment in order to
13 drive them out of their houses and to move somebody else into them.
14 Q. Mr. Kraljevic, you've told us about people being mistreated by
15 the police and then also as part of this -- what you've said was an
16 organised system to remove people from their homes. I want to ask you,
17 who did you hear was operating in Ilok at this time and involved in the
18 commission of these crimes?
19 A. Are you referring to the authorities or what? I don't know.
20 Q. I'm asking you who you believe -- who you heard was responsible
21 for the crimes that were committed against civilians who remained in
23 MR. ZIVANOVIC: Sorry --
24 JUDGE DELVOIE: Mr. Zivanovic.
25 MR. ZIVANOVIC: -- may we have the reference where the witness
1 said that people being mistreated by the police.
2 MS. CLANTON: If you just give me one moment, Your Honour.
3 Your Honour, on page 31 of the -- oh, I'm sorry. It just moved.
4 31 of the temporary transcript at lines 11 to 13.
5 MR. ZIVANOVIC: Sorry, it states that people being brought into
6 the police premises, not being mistreated.
7 MS. CLANTON: What I see is that it says they were brought into
8 the police premises and being interrogated and a huge number of people
9 were expelled.
10 Would it assist for me to ask the question -- a different
11 question to the witness?
12 JUDGE DELVOIE: As long as you don't give the qualification of
13 mistreatment if the -- if the witness doesn't. So you could ask him.
14 MS. CLANTON:
15 Q. Mr. Kraljevic, a moment ago, you said to us and I'm going to read
16 this from the transcript because it's important what is recorded, you
17 said that:
18 "... people were brought into police premises, were being
19 interrogated, and a huge number of people were expelled."
20 Could you describe for us what you heard about the way that they
21 were interrogated and who was interrogating them?
22 A. You know, it's difficult for me to say something explicitly in
23 such a way. The people who were brought in know best what happened to
24 them. There are quite a few statements provided by such individuals. I
25 myself didn't collect them, but if necessary, we can review them because
1 there is a multitude of persons who provided statements to that effect.
2 I am reluctant to make any comments in their name.
3 Q. Mr. Kraljevic, based on what you heard from these people, can you
4 answer the question that I asked you, which was: Who was interrogating
5 them and what you heard about the interrogations?
6 MR. ZIVANOVIC: It was asked and answered.
7 MS. CLANTON: Your Honour, I don't -- I'm sorry.
8 JUDGE DELVOIE: I don't agree, Mr. Zivanovic. It was asked but
9 it wasn't answered.
10 MR. ZIVANOVIC: In the quoted part of the transcript it was said
11 that they were interrogated in police premises.
12 JUDGE DELVOIE: But that's no answer to the question. Please
13 proceed, Ms. Clanton.
14 MS. CLANTON:
15 Q. Mr. Kraljevic, I said a moment ago, I need for you to focus on my
16 question, which is: Based on what you heard, who interrogated people in
17 the police premises and what did you hear about the interrogations
19 A. It is true that people were questioned on the police premises.
20 They were held captive in the cellar and they were maltreated. A lot of
21 people can confirm that, if necessary. But at this point in time, I find
22 it difficult to collect as many people who can testify to that, but it is
23 beyond doubt that people were maltreated, severely maltreated.
24 Q. Mr. Kraljevic, if you know, by whom were they severely maltreated
25 when they were detained or held captive in the cellar of the police
2 A. Well, the police. Who else? I don't know. If anyone else was
3 granted access to the police, then it's the police's mistake.
4 Q. Mr. Kraljevic, I'd like to go back to the question now that I was
5 asking you before and I think I should ask you again.
6 I want to know, who did you hear, other than the police, who did
7 you hear was operating near Ilok and was responsible for the commission
8 of crimes after the time that you left?
9 A. There were various individuals either from Ilok or from elsewhere
10 who would come, break into houses during the night, plunder, beat people,
11 expel them, et cetera. There were many instances of that kind and this
12 was particularly apparent from the statements, and these incidents were
13 mostly happening in Bapska and Sarengrad because there was a lower level
14 of presence of monitors and that is why there was a higher incidence of
15 such cases.
16 Q. And, Mr. Kraljevic, you've said that there were various
17 individuals who were engaged in this behaviour. When you were a mayor in
18 exile, did you ever hear that there were any groups that were described
19 as having engaged in this behaviour, members of any group?
20 A. Well, there were various groups in the area of Ilok dressed in
21 military uniforms. There were many of them. There were references made
22 to Red Berets, Seselj's men. These people were wearing various uniforms.
23 They would sometimes identify themselves by a variety of names. They
24 would burst into people's houses pretending to be policemen and identify
25 themselves as policemen although they were not.
1 MS. CLANTON: I'd like the assistance of the Registrar, please,
2 to pull up 65 ter 01407. This is at tab 17.
3 JUDGE DELVOIE: Ms. Clanton, I'm told that you are running out of
4 time. How long would you --
5 MS. CLANTON: This is my last series of questions, I think not
6 more than five or ten minutes, Your Honour.
7 JUDGE DELVOIE: Okay.
8 MS. CLANTON: Thank you.
9 Q. Mr. Kraljevic, do you recognise this as a document that you
10 provided to the investigators of the Office of the Prosecutor?
11 A. Yes.
12 Q. And if you could assist, can you tell us, as it's marked as
13 illegible in the English, what the title of this document is on the page
14 that's in front of you?
15 A. It says the list of persons expelled between the 1st of January,
16 1973, but I cannot see the exact date. Anyway, it's November of the same
17 year. And we can see below the list of the expellees, their names, their
18 date of birth --
19 Q. I need to ask you to pause for a moment, please.
20 A. And the place of birth.
21 Q. A moment ago, we asked -- I asked you what the title of the list
22 was and you said that these were people that were expelled in 1973; is
23 that correct?
24 A. I'm sorry, 1993.
25 Q. Thank you. And you've clarified that the date that is difficult
1 to read is the 20th of -- did you say November, 1993?
2 A. Now I can see, it's the 20th. I can see better now.
3 Q. Thank you for assisting with that.
4 MS. CLANTON: If the Registrar could assist by going to the last
5 page, please. Sorry, it's page 5, I believe.
6 THE WITNESS: [Interpretation] The year is the same, only it's a
7 continuation covering the period between the 20th of November and
8 31st of December, 1993.
9 MS. CLANTON:
10 Q. Thank you for providing the dates. I would like to ask you now,
11 go back to what you were saying a moment ago about this list. I want to
12 confirm that what you've told us is that this is a list of people -- just
13 one moment, please. You said these were people who lived in Ilok and it
14 has their names and their dates of birth. What other information is
15 provided here?
16 A. And the dates of expulsion. I don't see any other details. The
17 name of the street and when the person was expelled.
18 Q. Mr. Kraljevic, on this list, for example, the first line on the
19 page that's currently displayed which says Marijan Solakovic, this person
20 is listed next to the town Ilok. I'd like for you to tell us --
21 A. Bapska.
22 Q. I'm sorry, Bapska, you're right. I would like for you to tell us
23 whether this list includes the surrounding communities of Ilok.
24 A. This list contains the names only of the people from the area
25 where I was mayor, that is to say, Ilok, Sarengrad, Bapska, and Mohovo.
1 So these lists pertain only to these places, Sarengrad, Bapska, Mohovo.
2 There was approximately 10.000 inhabitants in that area.
3 Q. And Mr. Kraljevic, just to clarify your last answer, you said
4 that the list contains the names of people who were expelled from the
5 area that is part of Ilok, and that was Sarengrad, Bapska, and Mohovo.
6 Does the list also include people who were expelled from the town of Ilok
8 A. Yes.
9 MS. CLANTON: Your Honours, I would like to have this document
10 admitted, please, 65 ter 00417, into evidence.
11 JUDGE DELVOIE: Admitted and marked.
12 THE REGISTRAR: It shall be assigned Exhibit Number P0226. Thank
14 MS. CLANTON: Your Honour, at this time I have no further
16 JUDGE DELVOIE: Thank you. Cross-examination.
17 MR. ZIVANOVIC: Thank you, Mr. President.
18 Cross-examination by Mr. Zivanovic:
19 Q. [Interpretation] Good afternoon, Mr. Kraljevic. My name is
20 Zoran Zivanovic. I'm Defence counsel of Goran Hadzic.
21 Let me ask you first, on page 31, you said that the situation was
22 calm for as long as Grahovac was there, who was in charge in maintaining
23 law and order in Ilok, and that this situation prevailed until January.
24 Can you tell us the year?
25 A. 1992. A day or two later, I don't know.
1 Q. According to your information, because I know you were not there
2 on the spot, was this area still under the JNA control after that period?
3 A. I said that it was relatively peaceful, but even before the
4 killing of the people in Ilok, it was relatively peaceful.
5 I'm sorry for putting it like this. I'm sorry -- I believe that
6 the army had no influence on the events any longer.
7 Q. I have different information.
8 MR. ZIVANOVIC: [Interpretation] Could we now see a document, a
9 document of an international organisation that was on mission in
10 Yugoslavia, 1D404. They made a survey of human rights.
11 I think the report has not been translated. It's a very long
12 report and not all of it is significant, but I will read out an excerpt
13 that refers to Ilok. It's on page 5.
14 It's the last paragraph. I will not read out all of it because
15 it is mostly about known facts discussed here. But the last paragraph
17 "[In English] The mission has evidence that Ilok is not under
18 civilian administration but under direct rule of JNA and paramilitary
20 Q. [Interpretation] That's why I'm asking if you are certain that
21 the relevant time is January 1992 because if we look at this report, we
22 will see on the cover page that it was made in May 1992. Are you sure
23 that the JNA no longer controlled the area from January 1992?
24 A. As far as I know, Colonel Grahovac was no longer there then. If
25 there were units of the JNA, well, I think there were such units in all
1 of the occupied area. Now, how much influence the ones or the others
2 had, I don't know, but most people say that the paramilitaries had more
3 influence. But that doesn't exclude that the JNA played a part as well.
4 Q. Let me ask you something else in connection with this. Do you
5 know that at that time in the area there were town commands?
6 A. I personally was not involved, but I know what was generally
7 known and I will gladly answer any question I can answer.
8 Q. I may not have been clear enough. Do you know that after your
9 departure from the area, did you have information to that effect that the
10 JNA established town commands in the places that had been taken by its
12 A. Yes, there was information that there were always some commands
13 in place, but who took part in that command, I don't know, nor do I know
14 the influence or how much of a say any given group had.
15 Q. Now I would like us to see the following. You spoke about the
16 negotiations process with Colonel Grahovac, later with Arandjelovic and
17 co-workers. Here's what I would like to know: During those
18 negotiations, did you have contact with the government in Zagreb? Did
19 you get instructions from them concerning the demands of the JNA?
20 A. I personally didn't have such contact but some members did. For
21 example, Ivan Uros, who left Ilok, he was a member of parliament. I
22 think that he left on the 30th of September and went to Zagreb. As far
23 as I know, there were contacts but I'm not sure how that went, by phone
24 or in another way.
25 Q. When you mentioned him, you said that on the 30th of September,
1 he went to Zagreb?
2 A. Yes. Actually he didn't go to Zagreb. He went to Belgrade and
3 Skopje and then made it to Zagreb.
4 Q. But I'm interested to hear if anybody of you who stayed at Ilok
5 during those negotiations with the JNA, did any of these persons have
6 contact with the government in Zagreb to inform them of the demands of
7 the JNA and ask for instructions what should be done?
8 A. I don't know that. But two or three representatives of the
9 Croatian government came to Ilok after four days and spoke to JNA
10 representatives. That is once the convoy had left. They arrived at Ilok
11 and had talks in the castle. The talks were about the displaced persons
12 returning to their towns and villages. That's why they had arrived. You
13 may not have that information, but I do.
14 Q. Do you know if before your departure they had been in contact
15 with the JNA to suggest them that, in other words, suggest to the army
16 not to remove you from there?
17 A. Well, you know, I'm saying that the representatives who were at
18 the civil protection staff did contact Zagreb, but what they spoke about,
19 I cannot say. But I can say briefly that the advice was: You know what
20 the situation is and you decide whether you want to leave Ilok or not.
21 We were mature enough to make our own decisions in the Ilok case.
22 Q. Let us see a document that the OTP showed you.
23 MR. ZIVANOVIC: [Interpretation] It's P2020.
24 Q. These are the minutes taken at a polling station or from -- does
25 it refer to all of Ilok?
1 A. This was one of the polling stations in Ilok, one of five.
2 Q. Was it the most important polling station?
3 A. No, it was an average polling station or even a smaller one.
4 Q. Could you please explain the last paragraph that says that a
5 total of 508 ballots were cast and that this represents the votes of over
6 a thousand citizens. I understood that those who voted did not only vote
7 for themselves but also for others.
8 A. Yes, for their spouses and children. If you vote for yourself
9 and your spouse, then you get over a thousand votes, you know. It wasn't
10 so easy to move about and people had other things to do. The situation
11 was extremely tense and people didn't really care so much about these --
12 about this vote.
13 Q. You said that on the 30th [as interpreted] of October the
14 referendum was held and you mentioned a meeting at Sid on the 14th of
15 October, and in that context, I believe you mentioned two European
17 A. They were monitors.
18 Q. Yes, exactly. The names are Kypr and Cunningham; right?
19 A. Yes.
20 Q. Can you tell me which meeting they attended, the one after the
21 referendum on the 14th of October?
22 A. Yes. This specifically was after the referendum when the
23 agreement about the departure was signed.
24 Q. Did they have an opportunity to see the text of the agreement?
25 A. Yes. There was an interpreter. We brought her along. She was a
1 teacher of English and translated the whole text and interpreted
2 everything that was said at the meeting.
3 JUDGE DELVOIE: Mr. Zivanovic, I take it your purpose was not to
4 confuse the witness on the dates, but I see that your question was: "You
5 said that the 30th of October the referendum was held ..."
6 You see the difficulty? And then you ask whether it was after
7 the referendum on the 14th of October.
8 MR. ZIVANOVIC: That's an error in transcript. I spoke about
9 13th of October.
10 JUDGE DELVOIE: Okay. Thank you very much.
11 MR. ZIVANOVIC:
12 Q. [Interpretation] It was wrongly recorded in the transcript that
13 the date in question was the 30th of October and it has now been
14 corrected to the 13th.
15 A. Yes, I understood that.
16 Q. On the occasion of that meeting, did the European monitors
17 comment what was happening, that is, on the other hand, the proposals of
18 the JNA, on the other hand, what you were requesting?
19 A. Yes. They asked questions but did not comment. They only wanted
20 to hear the opinions of the two sides. But not often, it was only twice
21 or three times.
22 Q. Do you remember what was being discussed?
23 A. They wanted to know why people were leaving the town because it
24 seemed strange to them that anybody was willing to leave their homes.
25 Q. Whom did they ask? You? I mean, I don't mean you personally?
1 A. Yes, they asked us. But they were also interested in hearing
2 from the army why people had to leave the town.
3 Q. And what kind of answer did they get?
4 A. From me or ...
5 THE INTERPRETER: The speakers are overlapping.
6 THE WITNESS: [Interpretation] I believe I explained why we were
7 leaving our homes, and the General said that they had to enter to
8 preserve law and order. It was very -- it was a very brief explanation.
9 MR. ZIVANOVIC:
10 Q. [Interpretation] They didn't comment that in any way?
11 A. No.
12 Q. You said that a meeting was held on the 11th of October, 1991,
13 also with the JNA?
14 A. With General Arandjelovic, at Sid.
15 Q. On that occasion, there was discussion about the JNA action at
16 Lovas that had happened on the previous day, the 10th?
17 A. Yes.
18 Q. And that meeting was attended by Rendulic, Adam Rendulic?
19 A. Yes.
20 Q. He's from Lovas?
21 A. Yes, was the manager of the co-op.
22 Q. Do you know when he came to Ilok?
23 A. I don't know when exactly but there were -- people were coming
24 from Lovas to Ilok on a number of occasions. Whether he went to and fro,
25 I don't know.
1 Q. Was he in Lovas when the JNA attacked?
2 A. I don't know. I cannot answer that.
3 Q. I'll immediately explain why I'm asking because I see that at
4 that meeting, it was mentioned that 22 people were killed in Lovas?
5 A. Yes.
6 Q. That's why I'm interested to hear how it happened that you knew
7 on the following day how many people had been killed?
8 A. Some of the population of Lovas fled in our direction. I didn't
9 say that they knew the exact number but that there had -- but they said
10 that they -- there had been many victims, about 20 or so. And then a
11 grave was also dug up. And Hugh Cunningham, the observer, also went to
12 Lovas and spoke to Mr. Devetak, who confirmed that. He also got a list,
13 and I saw the list of people.
14 Q. I just wanted to hear whether as early as the 11th of October you
15 had the exact number of casualties or if you just knew that there had
16 been casualties but didn't know the exact number.
17 A. There was talk about 20-odd casualties.
18 Q. You also said that General Arandjelovic told you on that occasion
19 that many people were killed as an act of revenge for a soldier that had
20 been killed, but you said that no soldiers were killed in Lovas?
21 A. Yes. It was never published, any kind of information was never
22 published that a soldier had been killed. I just think that was a kind
23 of excuse or pretext to justify the crime of this magnitude.
24 Q. In other words, since you couldn't read or hear about that
25 anywhere else, you don't think that that actually happened, that that was
1 just an excuse?
2 A. It was never mentioned again. Nobody ever mentioned his name or
3 the fact that a soldier was killed.
4 Q. The Prosecutor showed you document P316.
5 MR. ZIVANOVIC: [Interpretation] If we can have it again, please.
6 I believe that is a letter sent to Bapska.
7 Q. I can see here that he says that Bapska was a peaceful place and
8 the population was requested to submit their weapons. Were you aware of
9 the existence of any weapons in Bapska?
10 A. Yes, there were rifles but in the possession of the civilian
12 Q. When you say "civilian protection," what are you referring to?
13 A. I'm referring to the residents of Bapska.
14 Q. In other words, those were not members of the Croatian Guards
15 Corps or the MUP?
16 A. Well, there were their representatives as well, of course.
17 Q. And they decided not to accept this but chose to withdraw to
19 A. Well, the population was fleeing and leaving, but they refused to
20 accept this ultimatum.
21 Q. They didn't want to surrender the weapons; is that what you're
23 A. Yes.
24 Q. Just one clarification. You said that before all these conflicts
25 started, certain Serbs used to spend the night in Backa Palanka.
1 A. Yes.
2 Q. How do you know that? How do you know that they only went there
3 to spend the night?
4 A. Well, that was common knowledge. I don't know. There were
5 articles in newspapers about that. But these people did indeed go over
6 there to spend the night in order to create some kind of psychological
7 pressure. Everybody used to say that this was organised from the outside
8 in order to portray the situation of uncertainty for people in Ilok. I
9 believe that that was the only reason. I don't think that they were
10 really afraid but, rather, they wanted to create an atmosphere of fear.
11 Q. But I don't understand how can you create an atmosphere of fear
12 if these people come back and spend the whole day in Ilok. If something
13 bad was to happen to them, it could happen during the day as well?
14 A. Well, I don't know. Everybody was playing games. Look, for
15 example, the daily "Politika" wrote at the time that 11 people were
16 killed in Ilok and their bodies were displayed in the square for people
17 to see. This was a totally unprovoked fabrication. There was no
19 Q. One more thing. You said that about five Ilok policemen refused
20 to put on the new Croatian coat of arms. Are you referring to the
21 checkered coat of arms?
22 A. Well, you can call it that although we prefer to call it the
23 Croatian coat of arms.
24 Q. Do you know why they refused to wear it?
25 A. They know that themselves, but there's also some kind of
1 atmosphere being created there that this is a coat of arms associated
2 with the Ustasha, not with Croats.
3 Q. Mr. Kraljevic, thank you very much. I have no further questions.
4 A. Thank you.
5 JUDGE DELVOIE: Ms. Clanton, do you have anything in redirect?
6 MS. CLANTON: No, Your Honour.
7 JUDGE DELVOIE: You don't?
8 MS. CLANTON: No.
9 JUDGE DELVOIE: Mr. Kraljevic, this is the end of your testimony.
10 You are released as a witness. We thank you very much for coming to
11 The Hague to assist us, and we wish you a safe journey home.
12 The Court Usher will escort you out of court. Thank you very
14 THE WITNESS: [Interpretation] Thank you, too, Your Honours. It
15 was a pleasure to testify here.
16 [The witness withdrew]
17 JUDGE DELVOIE: Mr. Olmsted.
18 MR. OLMSTED: Thank you, Mr. President. I have the unfortunate
19 job of informing you that we do not have another witness this week. This
20 is the result of a number of things. First and foremost, the waiver
21 issue with regard to the witness -- I don't know if he has --
22 JUDGE DELVOIE: He has. He has.
23 MR. OLMSTED: -- protective measures so I don't want to mention
24 his -- he was again scheduled this week. He couldn't come and therefore
25 we had to scramble to find additional witnesses, and this is the best we
1 could do at this stage. A number of witnesses that we've already
2 scheduled or already arranged them four or five times, and we just could
3 not get someone here to fill that potential gap.
4 Secondly, the cross-examinations were much shorter than
5 anticipated. Again, we've raised this before. It would be helpful if
6 the Defence could give us at least a week or two notice of how long they
7 intend to cross at least at the point of -- obviously they don't know
8 what we're going to ask on direct examination, but just based upon what
9 they believe they can, that would help us a little bit in anticipating
10 that there would be these kind of gaps. But we -- I think next week we
11 have a full schedule, so hopefully it's going to work out fine.
12 JUDGE DELVOIE: Okay. In the meantime, I hope that instead of
13 court time, you will enjoy the sunshine.
14 MR. OLMSTED: Your Honour, we will.
15 JUDGE DELVOIE: If that's all, court adjourned.
16 ---Whereupon the hearing adjourned at 1.59 p.m.,
17 to be reconvened on Monday, the 10th day of
18 June, 2013