Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10853

 1                           Wednesday, 3 September 2014

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 9.01 a.m.

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

 7     courtroom.

 8             Madam Registrar, could you call the case please.

 9             THE REGISTRAR:  Good morning, Your Honours.

10             This is the case IT-04-75-T, The Prosecutor versus Goran Hadzic.

11             JUDGE DELVOIE:  Thank you.

12             May we have the appearances, please, starting with the

13     Prosecution.

14             MR. STRINGER:  Good morning, Mr. President, Your Honours.  For

15     the Prosecution, Douglas Stringer, Sarah Clanton, Lisa Biersay, Case

16     Manager Thomas Laugel and legal intern Marina Marcikic.

17             JUDGE DELVOIE:  Thank you.

18             For the Defence.

19             MR. ZIVANOVIC:  Good morning, Your Honours.  For the Defence of

20     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell, with legal intern

21     Sunna Aevarsdottir.

22             JUDGE DELVOIE:  Thank you.

23             Mr. Hadzic, I remind you that you're still under oath.

24             Mr. Zivanovic, please proceed.

25                           WITNESS:  GORAN HADZIC [Resumed]


Page 10854

 1                           [Witness answered through interpreter]

 2                           Re-examination by Mr. Zivanovic: [Continued]

 3        Q.   [Interpretation] Good morning, Mr. Hadzic.

 4        A.   Good morning.

 5        Q.   I will ask you a question -- we'll discuss a topic that was a

 6     subject of cross-examination, and it has to do with Osijek.  Just for the

 7     record, it's the 22nd of July, page 10.113; 23rd of July, pages 10.200

 8     and 10.221; the 24th of July, pages 10.240 up until 10.319.  There has

 9     been a lot of talk about Osijek here, and you discussed it at length.

10             What I wanted to ask you is this:  Did the government of SBWS

11     have the information and did it take part in any plans to take this town

12     militarily?

13        A.   No, the government was not informed about this, nor did anyone

14     ever discuss that topic with the government or address the government in

15     relation to it.  None of the relevant factors, either military or

16     civilian authorities.  That was never a subject of discussion before the

17     government.

18             THE INTERPRETER:  Microphone, please.

19             JUDGE DELVOIE:  Microphone, please.

20             MR. ZIVANOVIC: [Interpretation]

21        Q.   When you were president of the Republic of Serbian Krajina, that

22     is to say, 1992, 1993, at that time, to the best of your knowledge, the

23     Army of the Republic of Serbian Krajina or, rather, the armed forces of

24     the Republic of Serbian Krajina, did they have any plans to attack this

25     town?

Page 10855

 1        A.   No.  No, I can assert that with great certainty.  And I can say

 2     with great certainty that while I was president of the RSK, to the best

 3     of my knowledge, and according to my information, not a single shell was

 4     fired at Osijek, at least not by the regular forces that were there.

 5        Q.   Mr. Hadzic, during the cross-examination by the Prosecution, you

 6     gave quite a few answers, but I'd just like to ask you one more thing.

 7     Is there anything left that you wanted to say during the

 8     cross-examination that you did not get to say, either because you were

 9     interrupted by the Prosecutor or by me or due to some other reasons or

10     circumstances?

11        A.   Perhaps only two things.  I forgot one the day before yesterday

12     when I was answering your question and another thing I'd like to clarify

13     is as follows:

14     In response to the question put by the honourable Prosecutor concerning

15     the visit of Madam Albright to Borovo Naselje.  Perhaps I'm mistaken, but

16  it seemed to me that he was imputing that I had invited Milan Ilic. Although

17     that doesn't really matter. I think what matters that the truth should be

18     known.  The American embassy from Zagreb agreed on a visit to the local

19     Serbs, and they agreed directly with Milan Ilic that he would be the host

20     and I was subsequently invited by them and I took part in resolving that

21  problem. So it is important for the Trial Chamber to know that if that is it

22  relevant for any reason whatsoever. It is important that they know that this

23  meeting had been agreed upon without any effort on my part. Also, in

24  response to my -- to your question put two days ago, I didn't remember, I

25  thought that you asked what was discussed at Mr. Simovic's on a particular

Page 10856

 1     day. I didn't remember. I said that Mr. Simovic had invited me but he was

 2     in this package of these contacts of ours when we had meetings with

 3     Mr. Wijnaendts and these preparations in Belgrade, preparing to go to

 4     The Hague and Paris twice.  So it was at Simovic's office that we had

 5     these consultations rather than at the Serbian government building.  And

 6     Jovic was there too and I think I was there with him once and another

 7     time Babic and Dzakula were there.  And then he familiarized us with the

 8  problem of the Blue Helmets and Simovic in a way provided us with a service,

 9  some assistance and information before our trip to Paris and The Hague and

10     that is why I went there. So as far as I can remember, that would be all.

11        Q.   Very well, Mr. Hadzic.  I have no further questions.  Thank you.

12        A.   Thank you, too.

13             JUDGE DELVOIE:  Mr. Stringer.

14             MR. STRINGER:  Yes, Your Honour, the Prosecution had intended to

15     request just a few minutes, ten to 15 for, I think, just two matters now.

16     One of them has actually been resolved by agreement with counsel on the

17     admission of one of the items that were raised with the Chamber on

18     Monday.  So we would respectfully request leave to spend about ten to 15

19     minutes with Mr. Hadzic by way of re-cross on two topics.  And then I

20     would like to tender into evidence a few items that did not get tendered

21     during the cross.  This was raised on Monday, Your Honour, with

22     Judge Hall, who suggested that we should consult with the Defence to see

23     whether we could reach agreement on those and we have consulted and we

24     have reached agreement as to all of them but one, and so my intention

25     would just be simply to tender those, so I think just ten to 15 minutes


Page 10857

 1     should do it.

 2             JUDGE DELVOIE:  Please -- yes, Mr. Zivanovic.

 3             MR. ZIVANOVIC:  If I could correct Mr. Stringer:  We reached

 4     agreement to all of them but two.

 5             JUDGE DELVOIE:  Okay.

 6             MR. STRINGER:  Okay.

 7             JUDGE DELVOIE:  We'll see about that.

 8             Yes, Mr. Stringer, you may proceed.

 9             MR. STRINGER:  Thank you, Your Honour.

10                           Further cross-examination by Mr. Stringer:

11        Q.   Mr. Hadzic, just a couple of items based on what was said

12     yesterday, actually, during your redirect examination and one is just to

13     clarify.  You were asked again about an earlier stage of your examination

14     when, actually, Judge Hall had asked you when did you become aware, when

15     did you learn that Arkan was a criminal, that he was wanted by Interpol.

16     And you spoke about that yesterday, and you again mention, as you had in

17     the past, that you linked this to the time-frame in which Arkan became a

18     media personality.

19             What you told Judge Hall was that, you said and this is at 10157:

20     "I can't remember exactly when that was but certainly it became known

21     when Arkan became a media personality when foreign journalists came, the

22     Australian consul came to visit him as well."

23             And I now we have since corrected that reference to Australian

24     Member of Parliament instead of Australian consul.  Is that how it was,

25     that was the time-frame in which you link your knowledge or your learning

Page 10858

 1     that Arkan had a criminal background?

 2             JUDGE DELVOIE:  Mr. Zivanovic.

 3             MR. ZIVANOVIC:  Sorry, if just could be clarified this term

 4     "learned."  And "knowledge" or "learned".  I -- I think that this it is,

 5     in a way, compound.  I think it's not the same, "knowledge" and "learn".

 6             JUDGE DELVOIE:  Mr. Stringer.

 7             MR. STRINGER:

 8        Q.   The question from His Honour Judge Hall was:  "When did you learn

 9     that Arkan was a criminal, that he was wanted by Interpol?"

10             So my question, Mr. Hadzic, is whether you link that learning to

11     the time of the visit of the Australian prime minister?

12        A.   He was never there, the Australian prime minister.  That's the

13     interpretation I received.  I assume that's a slip of the tongue.

14             There are two things that I have to clarify here.  First of all,

15     I understood His Honour Judge Hall properly, I think, because, first, the

16     Prosecutor and I had this dispute about my interview with Mr. Dzuro in

17     2002 and Judge Hall intervened very cleverly and asked about the essence

18     of the misunderstanding.  When I said that whether I knew at the time in

19     2002 that Arkan was a criminal, and I said, yeah, and now the rest is all

20     debatable what knowledge means, what learning means.  To this day, I

21     haven't received any official document from any institution stating that

22     Arkan was a convicted criminal.  Except when I came here to the

23     Detention Unit then I got some of these judgements of his but when I'm

24     speaking, I'm speaking about when I was free.  I learned about him from

25     the Croatian media and I didn't know any of that for sure.

Page 10859

 1        Q.   Judge Hall asked you, he said:  "But, Mr. Hadzic, I do understand

 2     your testimony to be that back in 1991, you didn't know that Arkan was

 3     wanted by Interpol et cetera however at the time of the interview with

 4     Mr. Dzuro did you know?"

 5             And then he says:  "My question is when did you learn that Arkan

 6     was a criminal that he was wanted by Interpol?"

 7             And, Mr. Hadzic, injure response to Judge Hall was:  "You

 8     understood me very well.  In 2002, I told Mr. Dzuro that I'd -- I knew

 9     that when I was talking to him -- I knew that when I was talking to him.

10     As for the time when I learned that, I can't remember exactly when that

11     was, but certainly it became known when Arkan became a media personality

12     when foreign journalists came, the Australian consul came to visit him as

13     well."

14             So, Mr. Hadzic, you're linking this to the visit of the

15     Australian gentleman, and my question is - and I'll finish my question,

16     if I may - the question -- I just want to lock down the time-frame in

17     which that occurred.  My suggestion is that we're talking about

18     January of 1992.

19             MR. ZIVANOVIC:  I would object to this question.  First of all,

20     this part of transcript was read to Mr. Hadzic twice today by

21     Mr. Stringer, and I -- I think that he already asked -- already answered

22     to this question.

23             MR. STRINGER:  I respectively disagree, Mr. President.  I don't

24     think Mr. Hadzic answered at all.

25             JUDGE DELVOIE:  Objection is overruled.

Page 10860

 1             MR. STRINGER:

 2        Q.   Let me try to put it to you this way, Mr. Hadzic.  In response to

 3     Judge Hall, you made a reference to media and the visit of the Australian

 4     gentleman.  Can we agree that this occurred in January of 1992, the

 5     Australian gentleman's visit that we saw in the video?

 6        A.   We can agree.  And I have to explain something here.  I thought

 7     that my words were understood correctly but obviously they are not.  I

 8     did not directly link that visit to knowing that Arkan was a criminal.  I

 9     just said that the visit confused me additionally.  When I saw that a

10     high official of an UN member country was coming to see him and I had

11     information from the Croatian media that he was a criminal so I thought

12     that was not correct.  I thought he was not a criminal because the

13     Australian MP came to visit him because it seemed the other way around to

14     me.  If the Australian MP came to see him that meant that he was not a

15     criminal.  I never received any specific information from anyone about

16     any kind of criminal activity of his and I didn't even know that he had

17     served time in prison, if he was a criminal.  He came with the police

18     from Serbia as part of that system, and I thought that Serbia, as a

19     member of the UN, was duty-bound to arrest criminals.

20        Q.   Can we agree, Mr. Hadzic, that by January of 1992

21     Mr. Raznjatovic, Arkan, was, indeed, a well-known figure in the media?

22        A.   Well, he appeared in the media often.  I didn't even have the

23     possibility to follow all of that, there was no electricity, but he was

24     relatively well-known towards the end of 1991.

25        Q.   The last thing I want to ask you about, Mr. Hadzic, relates to

Page 10861

 1     your testimony about a video-clip that you were shown -- or, actually,

 2     you were asked to comment on, which is the video-clip that you commented

 3     on as P58, and it is the one in which you were asked at the end about

 4     whether Serbs and Croats can live together and it's the video in which

 5     your answer was -- you responded:  "Not the brotherhood and unity type of

 6     co-existence introduced 50 years ago."

 7             That was the video you were asked about by my learned friend

 8     yesterday and that's the one I just want to follow up on now.  Because in

 9     response to the question from your counsel, then, yesterday, what you

10     said was that -- and this is at page 10830.  Counsel asked:  "In that

11     interview and generally at the time was there any distinction between the

12     Croats, judging by the place they were coming from and the like?"

13             And you said:  "No, that never existed."

14             And you were then asked by Mr. Zivanovic:  "I mean, it was a

15     month or two after your interviews which I have shown you so it's war

16     already, the war was raging one could say.  Did you give such statements

17     relating to Croats hailing from Herzegovina or some other area?"

18             And your answer was:  "Not at all.  Nor did anyone try to

19     establish this on the ground.  My statements that were quite sharp in

20     September, I didn't even have a telephone at the time.  I said that

21     because Stipe Mesic and that side were pointing their fingers at us."

22             Do you recall that testimony?

23        A.   I do.

24        Q.   And I just wanted to follow up on it because it gave -- could

25     give the impression that you were using sharp language, sort of at a time

Page 10862

 1     when -- when things were very heated, in terms of war or conflict with

 2     the Croat side, is that the message that you were trying to convey?

 3        A.   No.  When I mentioned Stipe Mesic, I took him as an example but

 4     there were other politicians too who, at the time, gave statements

 5     against the Serbs so I was responding to them.  At that time Mercep

 6     [phoen] said that only shovels were good enough for Serbs, that Serbs

 7     could no longer be managers in Croatia, that they could only be involved

 8     in public works and so on.  Tudjman said then that he was glad that his

 9     wife was not a Serb or a Jew.  In my view, such statements were

10     pro-Fascist, so I said this in order to respond to them.

11             MR. STRINGER:  Could we please have P84.50, which is tab 701.

12        Q.   Mr. Hadzic, I want to take you to something that you said quite a

13     bit later, in July of 1993.  This is in an interview that you gave to the

14     publication Borba.  It's dated 24/25 July 1993, interview with

15     Goran Hadzic, leader of the Krajina Serbs by Branislav Gulan in Erdut and

16     Dalj.  And --

17             MR. ZIVANOVIC:  Sorry.  Sorry --

18             JUDGE DELVOIE:  Sorry, Mr. Zivanovic.

19             MR. ZIVANOVIC:  Sorry, I would object to the use of this

20     document.  It was not used in my re-direct or in the cross-examination.

21     Mr. Hadzic saw it is completely new document.

22             MR. STRINGER:  What was the -- the part of Mr. Hadzic's

23     testimony, Your Honour, that I just referred to indicated that he was

24     using sharp language in September about the Herzegovina Croats.  The

25     point of this is to show that the sharp language isn't just linked to

Page 10863

 1     what was happening at the time, at the heat of the conflict in the fall

 2     of 1991.  It continued for quite some time thereafter.

 3             MR. ZIVANOVIC:  The Prosecution could prove it through his

 4     cross-examination and to use this document if he wanted to prove anything

 5     about action and conduct of the accused, so I object to the use of this

 6     document to this line of questioning.

 7                           [Trial Chamber confers]

 8             JUDGE DELVOIE:  The objection is sustained.

 9             MR. STRINGER:  Your Honour, then, what's left is to tender a few

10     documents into evidence, and the first of these is exhibit -- well, we

11     are tendering 65 ter 1D03021.1 and that is simply a redacted version that

12     we have made of what's already in evidence as D134.  And counsel and I

13     have conferred, and the Defence agrees that 3021.1 could be admitted.

14             JUDGE DELVOIE:  Admitted and marked.

15             MR. STRINGER:  The next one, Mr. President, and this came up

16     yesterday --

17             JUDGE DELVOIE:  Just one moment.

18             MR. STRINGER:  Yes.

19                           [Trial Chamber and Registrar confer]

20             THE REGISTRAR:  Your Honours, for the record, 1D03021.1 will be

21     Exhibit D134.1.

22             MR. STRINGER:  The next exhibit, Your Honour, is from

23     Mr. Hadzic's suspect interview, and this was used by both parties during

24     the respective examinations.  It is a seven-page excerpt of the suspect

25     interview that relates to Mr. Hadzic's statements to Mr. Dzuro in

Page 10864

 1     relation to the people from Klisa who were -- who were brought to the

 2     training centre and the inquiries that were made after them.  And we

 3     tendered this on Monday.  This was another one Judge Hall suggested we

 4     confer and after conferring, the parties agree that we can tender into

 5     evidence 65 ter 4974.08J, which is the seven-page excerpt that capturing

 6     everything that Mr. Hadzic said on the Klisa issue.

 7             JUDGE DELVOIE:  Admitted and marked.

 8             THE REGISTRAR:  Your Honours, 04974.08J will be Exhibit P3239.

 9             JUDGE DELVOIE:  Thank you.

10             MR. STRINGER:  And that one should be under seal, Mr. President,

11     because --

12             JUDGE DELVOIE:  Under seal, please.

13             MR. STRINGER:  The next ones are documents 1D03606.  It's agreed

14     that that can be tendered into evidence.

15             JUDGE DELVOIE:  Admitted and marked.

16             MR. STRINGER:  Under seal.

17             JUDGE DELVOIE:  Under seal.

18             THE REGISTRAR:  1D03606 will be Exhibit P3240, under seal.

19             JUDGE DELVOIE:  Thanks.

20             MR. STRINGER:  65 ter exhibit 6521.

21             JUDGE DELVOIE:  Admitted and marked.

22             MR. STRINGER:  Under seal.

23             JUDGE DELVOIE:  Under seal, please.

24             THE REGISTRAR:  6521 will be Exhibit P3241, under seal.

25             JUDGE DELVOIE:  Thank you.

Page 10865

 1             MR. STRINGER:  And 65 ter 6561.

 2             JUDGE DELVOIE:  Admitted and marked.

 3             MR. STRINGER:  Public.

 4             THE REGISTRAR:  65 ter 6561 will be Exhibit P3242.

 5             MR. STRINGER:  The last one, Mr. President, is one the parties

 6     disagree.  But the Prosecution would tender two additional excerpts, both

 7     are very short, from the suspect interview that relates -- relate to the

 8     other incident.  The Pap family.  The Sinasi family incident in

 9     paragraph 27.  This was shown to Mr. Hadzic -- it was used with

10     Mr. Hadzic during the cross-examination, 4974.09B, and 4974.08F as in

11     Fox, and so we tender these excerpts, again for impeachment purposes.

12     That way, the Chamber will just have the entirety of it, as it relates to

13     this one incident.

14             JUDGE DELVOIE:  Mr. Zivanovic.

15             MR. ZIVANOVIC:  We object to these two -- two last exhibits.

16     First of them, 4974.09B, we did not see any relevance for -- in this

17     particular case to -- to tender this particular part of his interview.

18             And as for 4974.08F, in -- as far as we could see this part was

19     already in the exhibit 4974.08 -- 08J.  And we see that it would be

20     duplication of these parts of the interview.

21             JUDGE DELVOIE:  Is that an exhibit number you're mentioning,

22     Mr. Zivanovic?  497 --

23             MR. ZIVANOVIC:  4974.08 -- 08F.

24             JUDGE DELVOIE:  Is that --

25             MR. ZIVANOVIC:  It's a part of 4974.08J.  In other words --

Page 10866

 1             JUDGE DELVOIE:  Is that --

 2             MR. ZIVANOVIC:  -- the Exhibit J has -- has the parts -- this

 3     part from Exhibit F.

 4             JUDGE DELVOIE:  Okay.  And that's an exhibit number.  If is --

 5             MR. ZIVANOVIC:  -- it is --

 6             JUDGE DELVOIE:  It is admitted as an exhibit; right?

 7             MR. ZIVANOVIC:  It's not admitted.  J is admitted.

 8                           [Trial Chamber and Registrar confer]

 9             JUDGE DELVOIE:  Okay.  Okay.

10             Yes, Mr. Stringer.

11             MR. STRINGER:  Counsel's correct.  08F, or at least part of it is

12     in 08J, which was just admitted.  This is just because there is overlap

13     in the suspect interview.  The way that Mr. Dzuro organised his questions

14     for Mr. Hadzic, we felt like it's cleaner with 08J being sort of devoted

15     to the Klisa incident, even though it does contain part of something

16     that's relevant for the other case.  And then we respectfully would,

17     again, tender these two excerpts and have those be devoted toward the

18     paragraph 27 incident.  And I would, if I may, respond to counsel's first

19     objection on relevance of .09 B, we strongly disagree; we think it's

20     highly relevant.  It's in this passage where Mr. Dzuro reads part of a

21     statement to Mr. Hadzic that describes an incident of beating one of the

22     annex victims and it continues on to talk about -- well, our submission

23     is that the -- the entirety of the evidence that Mr. Dzuro put to

24     Mr. Hadzic at the time was plenty of evidence to put him on notice and to

25     focus him on the incident itself.  And so we think for completeness

Page 10867

 1     everything that was said to Mr. Hadzic about the incident should be in

 2     the record, and that's what 4974.09B is.

 3             JUDGE DELVOIE:  Yes, Mr. Stringer [sic].

 4             MR. ZIVANOVIC:  I would say that everything contained in the

 5     Exhibit B was put to Mr. Hadzic during his cross-examination and it is in

 6     the transcript, and because of that, I think it is not -- it could not --

 7     it is irrelevant for -- to tender this part of -- of evidence.

 8             As to Exhibit F, I would say that the only -- only difference

 9     between F and J is in that -- that in J, in Exhibit J, Mr. Hadzic hold

10     Milosevic indictment in his hand when he responded to the question of

11     the -- of Mr. Dzuro.  And in F - and it was explored during the

12     cross-examination - he didn't have this part of -- of video has no -- did

13     not depict that Mr. Hadzic had the indictment from Milosevic in his hand

14     when he answered to the questions.

15             MR. STRINGER:  I'll be very brief, Mr. President.  On 09B we

16     didn't read the entire thing to Mr. Hadzic; we read the parts that we

17     thought -- we figured most prominently but as things developed we felt

18     like, in the end, it's better for the Chamber to have everything that

19     related to the incident that so that it can compare and conclude for

20     itself the extent to which Mr. Hadzic would have been in a position to

21     comment on this.

22             As for 4974.08F it would be easier, just if we could quickly

23     bring up page 13 of it on the screen than way the Chamber can see what

24     counsel and I are probably both referring to here.  Counsel has just made

25     a reference to the Milosevic indictment.

Page 10868

 1             4974.08F.

 2                           [Prosecution counsel confer]

 3             MR. STRINGER:  On page 13 of the English --

 4             JUDGE DELVOIE:  Just one moment, Mr. Stringer.

 5                           [Trial Chamber confers]

 6             JUDGE DELVOIE:  Mr. Stringer, did I hear you well?  I think I

 7     did, that you said in the beginning of this long discussion that those

 8     two documents are tendered for impeachment purposes?

 9             MR. STRINGER:  That's correct, Your Honour.  That's the basis

10     they were tendered for on Monday.  The point being that we feel the

11     Chamber could be in a position best -- in a position to compare

12     Mr. Hadzic's description of these incidents during his own testimony here

13     with what he said back when Mr. Dzuro asked him about these and form the

14     conclusions whether, in fact, Mr. Hadzic's recitation or his story is

15     truthful today or not.

16             JUDGE DELVOIE:  Mr. Stringer, a short and simple answer would be

17     most helpful.  It's for impeachment purposes; right?

18             MR. STRINGER:  Yes.

19             JUDGE DELVOIE:  The -- unless you want to add something,

20     Mr. Zivanovic.

21             MR. ZIVANOVIC:  Yes, Your Honour.  Actually, I would answer to

22     this last exchange with Mr. Stringer --

23             JUDGE DELVOIE:  Please answer to the yes only.

24             MR. ZIVANOVIC:  No, no, no.  I didn't have comment about it.

25             JUDGE DELVOIE:  I mean, the -- if it's --

Page 10869

 1             MR. ZIVANOVIC:  -- I just wanted to -- to give the argument as to

 2     impeachment purpose from the point -- as to -- explained by Mr. Stringer

 3     as to Exhibit B.  Because he said -- he actually said that some parts of

 4     this -- this document was not read to Mr. Hadzic, and if it is relevant

 5     for the impeachment, it had to be shown to the witness and it had to be

 6     addressed by Mr. Hadzic.

 7                           [Trial Chamber confers]

 8             JUDGE DELVOIE:  Mr. Stringer, do you have a response to this last

 9     remark of Mr. Zivanovic?  Has it been shown to the witness?

10             MR. STRINGER:  It was not -- all seven pages of it were not read

11     into the record, Mr. President.  That's true.  We did present the parts

12     that we thought that were the most significant.  We didn't read it in its

13     entirety.

14                           [Trial Chamber confers]

15             JUDGE DELVOIE:  Mr. Zivanovic, do you want it to be read out to

16     the witness now, while he is still on the stand?

17             MR. ZIVANOVIC:  Your Honours, I think that the Prosecution had to

18     do it during its cross-examination, and if they did not do it, just --

19     eventually just the read part of transcript -- or of this document could

20     be tendered for the impeachment purpose.

21                           [Trial Chamber confers]

22             JUDGE DELVOIE:  Mr. Stringer, please read to the witness the

23     parts that have not been put to him.

24             MR. STRINGER:  I'm not sure I can remember exactly which parts I

25     did put and which parts I didn't, as I stand here right now, Your Honour.


Page 10870

 1     I'll do my best.  And I believe we need to go into private session for

 2     this, Mr. President.

 3             JUDGE DELVOIE:  Private session, please.

 4                           [Private session]

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 10871











11 Pages 10871-10879 redacted. Private session.
















Page 10880

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10                           [Open session]

11             THE REGISTRAR:  Your Honours, we're in open session.

12             JUDGE DELVOIE:  Yes, Mr. Zivanovic, I should have asked you

13     before going into open session, but you'll tell me whether we -- we are

14     good.

15             THE INTERPRETER:  Microphone, please.

16             MR. ZIVANOVIC:  I would put some questions to the witness.

17             JUDGE DELVOIE:  [Microphone not activated] can we do it in open

18     session?

19             MR. ZIVANOVIC:  Yes, yes, of course.

20             JUDGE DELVOIE:  [Microphone not activated] okay.

21                           Further re-examination by Mr. Zivanovic:

22        Q.   [Interpretation] Mr. Hadzic, following up on the Prosecutor's

23     questions about the Australian MP, or the ambassador as he was described

24     here, or consul, I'm not going to read what you said and what the

25     Prosecutor has already read out to you, but listen to your answer


Page 10881

 1     carefully, to the answer to my questions that I put to you yesterday.

 2     You will find that on page 10.780, starting on page -- on line 24.

 3     Please listen carefully because I will expect you to answer my questions

 4     later.

 5             [In English] [Previous translation continues] ...  let us clarify

 6     one thing.  I think this -- your answer that is recorded in the

 7     transcript, you already said that, namely, that this is not a visit of

 8     the Australian consul, that this was actually a Member of Parliament, of

 9     the Australian parliament so when I put the question about the Australian

10     consul, we don't have to correct that now.  What I'm interested in is

11     it --

12             THE INTERPRETER:  Please slow down.

13             MR. ZIVANOVIC:  "[In English] [Previous translation continues]

14     ... context in which you mentioned.  This visit of the Australian consul

15     in view of the question that was put to, was this in the context of Arkan

16     having become a media star or is the context your knowledge of him being

17     a criminal?  In other words, at that time of the visit of the Australian

18     visitor, or the Australian consul or Member of Parliament had you heard

19     by that that Arkan was a criminal or did you find out only later?

20             "A.  I cannot be very precise, but can I tell you what my

21     understanding of it was?  I said that there were a lot of controversies

22     and I saw that he was being visited by a visitor from Australia, although

23     it is not in the west.  Australia for me is part of the west.  Then I

24     thought he was not a criminal.  I mean I didn't have any document

25     corroborating the stories that were being bandied about and there were

Page 10882

 1     journalists there, journalists of the world media, I mean, rich media

 2     if -- can I put that way.  At world level.  They talked to him and I

 3     thought if what people were saying were true, these journalists would not

 4     be talking to him.  I didn't really deal with Arkan.  I had problems of

 5     my own, but in 1991, I couldn't have known anything about him, whether he

 6     was a criminal, whether he was not a criminal or, rather, these

 7     activities of his and I did not know that he had been in prison in the

 8     west because of his crimes.  I mean, if he serves his sentence then he

 9     becomes an innocent man and if he is a host of an Australian MP and if he

10     acts host to the mayor of Belgrade, if one says that he is a colonel of

11     the state security of the SFRY, I could not discern myself what was true

12     and what was not true.

13             "Q.  All right.  When you answered the question, when did you

14     hear that Arkan was a criminal and that he was a wanted man by Interpol,

15     what did you think this meant, "heard" when it says "heard"?

16             "A.  The media, whether I had read about that in Croatian

17     newspapers, to be more specific, and they didn't have to be correct

18     because the Croatian media were saying that everybody were criminals.

19     Everybody on the other side, on our side, that is, so I could not be

20     believe them.

21             "Q.  Does this mean that practically the source of your

22     information about this, namely, that Arkan was a criminal is actually

23     something that you first read about in the Croatian media and then you

24     realised that he was a wanted man by Interpol?

25             "A.  Yes."

Page 10883

 1             I'll not read some exchange between the Prosecution and the

 2     Chamber and me, and I resume with page 10.783, line 23:

 3             "Q.  Just like to go back to that question of mine that I put to

 4     you in the beginning.  It was to do with your answer when you mentioned

 5     the visit of the Australian MP.  Did you mention that in the context of

 6     Arkan becoming a media star, or did you mention it in the context that

 7     you knew at the time that he was a criminal or, rather, that he was a

 8     wanted man by Interpol?

 9             "A.  No, no.  I did not know then that he was wanted by Interpol

10     because of that visit.  This ambassador, or, rather, this Member of

11     Parliament came to see him as if he were a media star, and I was confused

12     by that.  When I heard that he was a criminal, I started wondering how

13     could the representative of a serious country come and visit a criminal?

14     I said that in that context.

15             "Q.  Perhaps my question was unclear.  Perhaps you misunderstood

16     or perhaps it was misinterpreted" --

17             MR. STRINGER:  Excuse me.  I apologise, Mr. President, especially

18     since the Chamber's given the Prosecution so much of the floor this

19     morning.  We don't see the point of re-reading Mr. Hadzic's testimony

20     into the record from yesterday.

21             MR. ZIVANOVIC:  I wanted to -- to -- to recall Mr. Hadzic about

22     his testimony and to put him -- the question related to the question of

23     the Prosecution on today's questions related to the -- to his knowledge

24     about Arkan was a criminal and wanted by the Interpol.  I'd just like to

25     remind him what was said exactly.

Page 10884

 1             JUDGE DELVOIE:  I think, actually, Mr. Zivanovic, that Mr. Hadzic

 2     has a perfect memory and knows what he said yesterday.  How much do you

 3     want to read more to him?

 4             MR. ZIVANOVIC:  I just have to -- to finish that page, and two --

 5     two -- two lines of the next page.

 6             JUDGE DELVOIE:  Reluctantly, Mr. Zivanovic.

 7             MR. ZIVANOVIC:  Thank you.

 8             JUDGE DELVOIE:  And, by all means --

 9             MR. ZIVANOVIC:  Sorry.

10             JUDGE DELVOIE:  By all means, I'm looking at the clock, we're not

11     going into the next hearing with this, okay?

12             MR. ZIVANOVIC:  Okay.

13             "Q.  Perhaps my question was unclear.  Perhaps you misunderstood

14     or perhaps it was misinterpreted you said I'm reading line 21 in English

15     know then that he was wanted by Interpol because that visit

16     [Interpretation] I did not ask you whether he was a wanted man by

17     Interpol because of the visit but at the time of the visit, did you know?

18             A.  I think that I gave a proper answer than it was

19     misinterpreted.  I said at the time of the visit I did not -- that he was

20     a wanted man by Interpol and I was particularly confused when I heard

21     about this and I thought these were rumours.  A man, a serious man from

22     the European Union would not come and visit him then.  I think that

23     Serbia or Yugoslavia as a member of Interpol should arrest anyone who was

24     wanted by Interpol.

25             "Q.  So when did you hear that?  Can you assess that?  Can you

Page 10885

 1     assess that when it was that you, taking into account that visit by the

 2     Croatian ambassador or I'm sorry, the Australian ambassador?

 3             "A.  Not ambassador, Member of Parliament.

 4             "Q.  Member of Parliament.

 5             "A.  I do not know.  During 1992, I cannot be very specific.

 6             "Q.  Thank you."

 7             That's it.

 8             [Interpretation] To follow up on a question put to you earlier

 9     today by the Prosecutor, tell us again, during the visit of the

10     Australian MP, did you know that Arkan was a criminal wanted by Interpol,

11     as it says here.

12        A.   No.  At that time I did not know that he was wanted by Interpol.

13             MR. ZIVANOVIC:  Thank you.  I have no further questions.

14             JUDGE DELVOIE:  Mr. Hadzic, this is the end of your testimony,

15     and you are now released as a witness.

16             We will adjourn a little bit early -- or just one moment.

17                           [Trial Chamber confers]

18             JUDGE DELVOIE:  Before we take the break, Mr. Stringer, I think

19     your application to have those two documents admitted is still alive?

20     Okay.  The documents are admitted and marked for the purposes mentioned.

21             THE REGISTRAR:  Your Honours, document 04974.09B will be Exhibit

22     P3243.

23             And document 04974.08F will be Exhibit P3244.

24                           [Trial Chamber and Registrar confer]

25             JUDGE DELVOIE:  Mr. Stringer, are they under seal or not.


Page 10886

 1             MR. STRINGER:  Yes, Your Honour, under seal.

 2             JUDGE DELVOIE:  Both.  Both under seal, please.

 3             We'll take -- yes, Mr. Zivanovic.

 4             MR. ZIVANOVIC:  Your Honours, I would inform the Chamber about

 5     one problem we met as to the witness schedule for the week of 8 and the

 6     week of 15 of September.  And I don't know, is it appropriate time to do

 7     it right now or to --

 8             JUDGE DELVOIE:  It is --

 9             MR. ZIVANOVIC:  -- or to wait --

10             JUDGE DELVOIE:  It is, Mr. Zivanovic.  Please go ahead.

11             MR. ZIVANOVIC:  Your Honour, we plan for the week of 15

12     September, we planned to bring here DGH-046 and in our estimate he would

13     take the whole week.  However, on 26 of August, we were informed that the

14     witness was sent to serve his sentence in another country.  We tried to

15     replace him with DGH-009 and we submit this request.  We informed -- on

16     2nd of September, we informed Victims and Witness Section about it and

17     asked to organise his travel for 10 of September.

18             In addition, we asked for -- to another witness.  They are

19     DGH-099 and DGH-034 to organise their travel for 7 or 8 September, and

20     such request was on 28th of August.

21             For all of these witnesses we ask the safe conduct, safe conduct,

22     so we are informed yesterday by the witness and victims section that even

23     if we get the safe conduct -- conduct for these three witnesses they will

24     not be able to organise their travel as planned.

25             So we -- we'll try to -- to -- to fill this gap for the week of 8

Page 10887

 1     of September.  We have two or three witnesses for this week, for that

 2     week, but we -- we don't know whether we'll be able to -- to provide

 3     witnesses who do not ask -- who did not ask either safe conduct or

 4     videolink testimony.

 5             So I just like to inform the Chamber about this problem.

 6             JUDGE DELVOIE:  Do I understand you well that for next week, you

 7     have three witnesses without any specific measures asked for, or do you

 8     have no witnesses at all for next week?

 9             MR. ZIVANOVIC:  No, no, no.  We hope we'll have the witnesses for

10     next week.  We have, I think, one viva voce witness.  We have one witness

11     for whom the protective measures and safe conduct was provided by the

12     Chamber, and it seems that one of the witnesses planned for this week

13     will stay the next week too.  So --

14             JUDGE DELVOIE:  So we will have the next week covered, so to say?

15             MR. ZIVANOVIC:  Almost.

16             JUDGE DELVOIE:  Okay.  But the week after that?

17             MR. ZIVANOVIC:  For the week -- our problem is with the week and

18     a half.

19             JUDGE DELVOIE:  Okay.  Okay.  Okay.  Thank you.

20             MR. ZIVANOVIC:  Sorry, just I'd like to correct the transcript

21     because it seems I -- I erroneously mentioned witness DGH-039 -- 34,

22     sorry.  It should be DGH-035.

23             JUDGE DELVOIE:  Thank you.  This reminds me of the request, the

24     Prosecution's request yesterday about the protective measures decision.

25     It is -- that decision forthcoming and is being prioritised by the


Page 10888

 1     Tribunal.

 2             We take a 30-minutes' break now, and we'll be back at 11.00.

 3                           [The witness withdrew]

 4                           --- Recess taken at 10.30 a.m.

 5                           --- On resuming at 11.01 a.m.

 6             JUDGE DELVOIE:  Mr. Zivanovic, we heard you had another matter to

 7     raise.

 8             MR. ZIVANOVIC:  Yes, Your Honour.

 9             I would just like to answer on the Prosecution's request

10     submitted yesterday --

11             JUDGE DELVOIE:  Oh, yes.

12             MR. ZIVANOVIC:  -- concerning disclosure of identity of two

13     Defence witnesses.

14             Namely, we'll today disclose the identity of DGH-047 through --

15     through the confidential written notice.  And as for DGH-105, we would

16     not yet disclose -- yet disclose his identity until we provide the

17     permission of the competent authorities of Serbia for his testimony.

18             JUDGE DELVOIE:  Thank you.

19             Mr. Stringer.

20             MR. STRINGER:  We appreciate counsel's representation on that --

21             JUDGE DELVOIE:  Mr. Stringer, just one moment.  Just one moment,

22     please.

23             Mr. Hadzic, you have a problem with --

24             THE ACCUSED: [Interpretation] Yes, I'm not receiving

25     interpretation.

Page 10889

 1             JUDGE DELVOIE:  Okay.  We'll have to deal with that.

 2             Do you get interpretation now?

 3             THE INTERPRETER:  Interpreter's note:  We cannot hear Mr. Hadzic.

 4             THE ACCUSED:  Okay, thank you.

 5             JUDGE DELVOIE:  Did you hear Mr. Hadzic now in the interpreters'

 6     booth.

 7             THE INTERPRETER:  Yes, he said:  Okay, thank you.  In English.

 8             JUDGE DELVOIE:  Okay, thanks.

 9             THE ACCUSED: [Interpretation] I'm receiving interpretation, yes.

10             JUDGE DELVOIE:  Okay.  So now everything is in order.

11             Mr. Stringer, could you repeat your intervention.

12             MR. STRINGER:  Just to say thank you on the disclosure

13     forthcoming on DGH-047.

14             As for DGH-105, based on what counsel said, it sounds as though

15     there is some sort of a Rule 70 type of impediment to disclosing his

16     identity and we, of course, accept that.  If that's the case.  And we

17     would expect that the timing of the witness's testimony in -- in terms --

18     in relation to the timing of the disclosure of his identity and statement

19     will be regulated in the forthcoming protective measures decision.  We're

20     just concerned about having sufficient time to prepare.

21             JUDGE DELVOIE:  We'll take that into account, Mr. Stringer.

22     Thank you.

23             The next witness will be brought in.

24             Mr. Gosnell, you are?

25             MR. GOSNELL:  Good morning, or -- yes, good morning, Your Honour.

Page 10890

 1     Just to formally put on record that the Defence calls Amanda Celar as the

 2     next witness.

 3             JUDGE DELVOIE:  Thank you.

 4             MR. GOSNELL:  And Mr. President, just while the witness is being

 5     brought in perhaps I could address a housekeeping matter in relation to

 6     the witness's statement.

 7             At present, the document that is uploaded under the 65 ter number

 8     for the witness's 92 ter statement is -- contains the annexes to that

 9     statement --

10                           [The witness entered court]

11             MR. GOSNELL:  -- in addition to the statement itself and some of

12     those annexes have been admitted, and some -- at least provisionally, and

13     some have not.  And, in any event, it would be best if all of those

14     documents are separated from the statement itself.  So just to advise

15     Your Honour that we do propose to just have the 30 pages of the statement

16     as the -- as the document uploaded at the relevant number.

17             JUDGE DELVOIE:  Thank you.

18             Good morning, Madam Witness.  Thank you for coming to The Hague

19     to assist the Trial Chamber.  If I'm well-informed, you are an English

20     speaker, right?

21             THE WITNESS:  Yes.

22             JUDGE DELVOIE:  Could you please tell us your name and your date

23     of birth.

24             THE WITNESS:  My name is Amanda Celar and I was born on 7th of

25     March, 1944.


Page 10891

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

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

 3     need to point out that the solemn declaration that you are about to make

 4     does expose you to the penalties of perjury, should you give misleading

 5     or untruthful information to the Tribunal.  Please read the solemn

 6     declaration now.

 7             THE WITNESS:  I solemnly declare that I will speak the truth, the

 8     whole truth, and nothing but the truth.

 9             JUDGE DELVOIE:  Thank you.  You may be seated.

10             Mr. Gosnell, I take it you are leading the witness.

11             MR. GOSNELL:  Yes, indeed, Mr. President.  Thank you.

12                           WITNESS:  AMANDA CELAR

13                           Examination by Mr. Gosnell:

14        Q.   Good morning, Ms. Celar.

15        A.   Good morning.

16        Q.   Could we have 1D3607, please.

17             Ms. Celar, do you recognise the document on the right side of the

18     screen in front of you.

19        A.   Yes, I do.

20        Q.   Is that your signature --

21        A.   Yes --

22        Q.   -- down at the bottom right of the page?

23        A.   Yes.

24        Q.   And if we could please go to page 30.

25             Is that, again, your signature?

Page 10892

 1        A.   Yes, it is.

 2        Q.   And do you recognise these two pages being the first and last

 3     page of a statement that you gave?

 4        A.   Yes, I do.

 5        Q.   Could we please move to page 26 of this document.

 6             Just there at the beginning of paragraph 81, is there a

 7     correction that you would like to make?

 8        A.   Yes.  The opening phrase, I would change to:  "It's important to

 9     understand regarding the whole atmosphere and situation at that time."

10        Q.   And with that correction, is this statement true and accurate, to

11     the best of your recollection?

12        A.   Yes, it is.

13        Q.   And does it reflect, in substance, what you would say if

14     questioned on the same subjects?

15        A.   Yes, it does.

16             MR. GOSNELL:  Mr. President, at this time, we would tender for

17     admission 1D3607 and I would specify the first 30 pages of that document,

18     thus, excluding all of the annexes that are currently appended to it, but

19     then we would separately tender as well the six documents that were

20     provisionally admitted to the Trial Chamber's decision of the 28

21     August 2014.  And, if necessary, for the record I can read those 65 ter

22     numbers.

23             JUDGE DELVOIE:  Madam Registrar, would it be helpful to have them

24     read out?

25                           [Trial Chamber and Registrar confer]

Page 10893

 1             JUDGE DELVOIE:  Please do, Mr. Gosnell.

 2             MR. GOSNELL:  The six are:  1D3365; 1D3366; 1D3367; 1D3368;

 3     1D3608; and 1D3609.

 4             JUDGE DELVOIE:  Ms. Biersay.

 5             MS. BIERSAY:  Thank you, Your Honours.  Good morning.

 6             I am standing to let the Court know that we are objecting to

 7     1D3608.  I know that the Trial Chamber issued its decision finding that

 8     the document was relevant and probative.  We, however, think that that

 9     letter should be redacted to reflect the portions that are discussed in

10     the witness's statement.

11             So we would object to the admission of -- that's tab 9, 1D03608,

12     and the Prosecution would not object to a redacted version of that, that

13     only covers the portions discussed in the witness's statement.

14             JUDGE DELVOIE:  Mr. Gosnell, could you eventually agree that?

15             MR. GOSNELL:  This is the first notice I have of this objection,

16     Mr.  President, so --

17             JUDGE DELVOIE:  Shall we MFI it for the moment and wait for,

18     eventually, an agreement between parties?

19             MR. GOSNELL:  Well, in principle I would -- I would ask that it

20     be admitted in the first instance because there is a -- already a Trial

21     Chamber decision addressing the admission of this document and it has

22     been litigated.  So I would suggest that if there is now an objection

23     being brought, it's a matter of reconsideration, and the admitted exhibit

24     can be modified in accordance with any decision by the Trial Chamber or

25     subsequent agreement by the parties.  But, at the moment, I think it

Page 10894

 1     should be admitted in line with the Trial Chamber's decision.

 2             JUDGE DELVOIE:  Ms. Biersay.

 3             MS. BIERSAY:  It's a fair point and I understand the argument.

 4     What we discussed in our opposition, in our 92 ter response in this case,

 5     we said that it didn't -- it wasn't appropriate for admission.  The Trial

 6     Chamber found that it was an integral part and it was relevant and

 7     probative.  Based on that decision that was issued not very long ago, we

 8     believe that the entire document should not be admitted in its entirety

 9     because the basis for the Trial Chamber's agreement that it's appropriate

10     as an associate exhibit said that:  "It clarifies DGH-083's account of

11     events in Osijek and makes positive reference to the letter in her

12     written statement."

13             So the Trial Chamber specifically pointed out to what the witness

14     referred to in her statement as the basis for finding that it was

15     relevant and probative, and so we're now asking that the version that's

16     admitted be limited to those portions referenced by the Trial Chamber.

17                           [Trial Chamber confers]

18             JUDGE DELVOIE:  As such, Ms. Biersay, the objection is overruled.

19             As Mr. Gosnell says, you could eventually file a reconsideration

20     motion but as an objection against something that has been decided, the

21     objection is overruled.

22             So the document is -- the documents are admitted and marked.

23             THE REGISTRAR:  Your Honours, the witness statement document

24     1D3607 receives number D173.

25             And Your Honours [Microphone not activated].

Page 10895

 1             JUDGE DELVOIE:  Try again.

 2             THE REGISTRAR:  Can you hear me now.

 3             I repeat, the document 1D3607 will receive exhibit number D173.

 4             And we would kindly request Defence counsel to re-upload the 30

 5     pages as tendered and admitted and notified so that the number can be

 6     assigned.

 7             The next document, 1D3365 will be Exhibit D174.173.

 8             Document number 1D3366 will be Exhibit D175.173.

 9             Document number 1D3367 will be Exhibit D176.173.

10             Document 1D3368 will be Exhibit D177.173.

11             Document 1D3608 will be Exhibit D178.173.

12             And document number 1D3609 will be Exhibit D179.173.

13             Thank you.

14             JUDGE DELVOIE:  Thank you.

15             MR. GOSNELL:  Mr. President, I have copies of the witness's

16     statement that has just been admitted.  I would request, since I will be

17     referring to a couple of documents during my examination that will be

18     pulled up on the screen and thereby displace her statement that

19     Mrs. Celar be given a copy so she has it to hand, if I ask her to refer

20     to it, or if she asks to refer to it, and I also have copies for

21     Your Honours, if you wish.

22             JUDGE DELVOIE:  Yes, Mr. Gosnell, if you have them, it's always

23     helpful to have them at hand.

24             MR. GOSNELL:  Could we please turn to page 18 of the document --

25        Q.   -- which, Mrs. Celar, is your statement.

Page 10896

 1             And about three lines down in that page, which is the

 2     continuation of paragraph 52, you say:  "I spoke with many of these

 3     refugees as I was involved in distributing humanitarian assistance in

 4     Baranja."

 5             And just to situate you, this is during the time-period following

 6     January of 1992.

 7        A.   [Microphone not activated] yes.

 8        Q.   Can you tell us something about your daily activities during 1992

 9     under the rubric of humanitarian assistance.  What did that entail?

10        A.   First of all, we asked -- we were tasked with asking friends if

11     they could spare.

12             [Technical difficulty]

13             JUDGE DELVOIE:  It's -- could you hold it for a moment,

14     Mrs. Celar, there is a problem with your microphone.

15             Could you repeat your answer.

16             THE WITNESS:  Some days, not every day, we would meet friends and

17     people we knew to ask them if they could spare something from their

18     house, objects, like a cup, a plate, knives and forks.  So that any newly

19     arrived refugees could be given some of the minimum items if -- that they

20     lacked.  We would also go and try and greet newly arrived people, greet

21     them simply really with a coffee and there wasn't a lot to give them.  If

22     we could give them some flour or -- this in the very early days, the

23     Red Cross wasn't organised then very well to provide them with food.  So

24     we used to collect and give out what we could.

25             MR. GOSNELL:

Page 10897

 1        Q.   And by 1992, approximately how long had you been living in

 2     Croatia?

 3        A.   Well, it's from -- do you mean in Osijek or do you mean in

 4     Baranja?

 5        Q.   Well, in -- in Croatia generally?

 6        A.   In Croatia generally that was from 1987.

 7        Q.   And you are a native English speaker --

 8        A.   Yes.

 9        Q.   Can you tell us how good or bad your Serbian was in January 1992.

10        A.   Well, I would have said it was only reasonable.  I could

11     understand basic conversations, and then sometimes some of them spoke

12     English, so we used a mixture of -- of that.

13        Q.   You anticipated my -- my next question, which is how it was that

14     you communicated with the -- the refugees whom you were assisting,

15     whether you -- you used, in general, Serbian, or did they speak English,

16     or did you have interpretation of some sort?

17        A.   I can't really be specific because I can't actually remember, but

18     it was a mixture of all that.  Sometimes I understood them.  I could

19     certainly understand people in distress.  I was usually accompanied by

20     somebody who spoke English and Serbian because they were -- I had close

21     friends like that.  Usually -- sometimes it was translated for me.

22     Sometimes it didn't need translation.

23        Q.   And would you say that -- how frequent would you say were your

24     contacts with refugees, let's say, during the -- the year 1992 as a

25     whole?

Page 10898

 1        A.   Well, it was very often -- very frequent.  Early in 1992, before

 2     the attacks, it was daily.  And then after it was probably less, but I

 3     saw of them frequently, really, because we -- we befriended a lot of them

 4     but the one who were in Beli Manastir not the ones who were in the

 5     villages around.

 6        Q.   And you've just referred to attacks.  Which attacks are you

 7     referring to?

 8        A.   I'm talking about particularly the 3rd of April.

 9        Q.   Right now, if we could look at paragraph 53 of your statement.

10     You say:  "Most of the refugees told me that they had come from other

11     parts of Croatia, more specifically, the areas bordering on the Baranja,

12     the Knin area, Western Slavonia, and the Vukovar area... the refugees to

13     Baranja from Knin and Western Slavonia would have had to pass through

14     Bosnia and Serbia."

15        A.   Yes.

16        Q.   Now if I can just ask you for one point of clarification on that.

17     Did the refugees explain to you whether they had travelled continuously

18     from Western Slavonia and Knin, in a single journey or did they mention

19     whether they had stopped and stayed for any interval of time in Serbia

20     before moving on to Baranja?

21        A.   No, I don't recall that I ever had a conversation regarding that.

22     Not that I can remember.

23        Q.   Did any describe whether they had stayed in -- for any period in

24     Serbia before coming to Baranja?

25        A.   No.  My impression was that because they came with nothing a lot

Page 10899

 1     of them, carrier bags, I suppose I assumed they came straight to Baranja,

 2     but I can't say for sure.

 3        Q.   And did the refugees tell you or express how they expected they

 4     would remain or stay in Baranja?

 5        A.   No.  The overwhelming sense I got from them was that they were

 6     pleased to be in a place of safety but they were so shocked.  It was hard

 7     to -- they didn't really have normal conversations in those early days.

 8     It was later on, after they'd been there for a while, that they would

 9     wanted to talk about where they wanted to go or if they wanted to go.

10        Q.   Where did they say they wanted to go?

11        A.   Home.

12        Q.   And home for them was the places from which they had

13     originated --

14        A.   Yes.

15        Q.   Now if I can just continue with paragraph 53.  "Their desire to

16     come to Baranja as opposed to Serbia, for example, may have been a result

17     of family relations or a desire to stay as close as possible to the

18     places from which they had fled.  They were from Croatia, after all, and

19     it would be normal to want to stay in Croatia - just as Ilija and I did."

20             And then down at paragraph 55, related to this:  "I never heard

21     that these refugees were bussed in as part of a policy to displace

22     Croats."

23             And then further along in paragraph 55, page 18 over to page 19,

24     you say:  "Some refugees came for one or two months and would then leave

25     as soon as they found somewhere to go in Serbia."

Page 10900

 1             Now, where -- what do you mean when you say "found somewhere to

 2     go in Serbia"?  Where could or would they find to go in Serbia?

 3        A.   Well, a lot -- they -- they didn't want to go and join -- go to a

 4     camp in Serbia, so they were trying to find a job somewhere where they

 5     thought perhaps there would be housing or family members that could take

 6     them in.  But the situation in Serbia was very difficult because of -- I

 7     think the embargo had made the economic climate there pretty desperate,

 8     and so that's what they were searching for, somewhere to be permanent, I

 9     think.  I don't think they regarded Baranja as permanent because the

10     climate was awful.

11        Q.   Was your impression from speaking to refugees that they

12     considered they were welcomed in Serbia?

13        A.   No, they didn't feel welcome in Serbia.

14        Q.   And you've referred to camps.  Do you know anything about these

15     camps?  Did any of them describe to you the conditions in the camps that

16     you've just referred to?

17        A.   No, I just heard that there were camps in Serbia for displaced

18     people and that they weren't very comfortable or -- I didn't know

19     anything about the camps, really, only odd bits of things I had heard.

20        Q.   Was it your impression that the refugees that you did speak to

21     about the camps considered those conditions to be less favourable than

22     those they found in Baranja?

23        A.   Yes.

24        Q.   Could we please have P2400, which is Defence tab 16.

25             Now, Mrs. Celar, at various points in your statement you describe

Page 10901

 1     biased media coverage of events in Croatia --

 2        A.   Yes.

 3        Q.   -- in particular, by western media sources.  And I'd now like to

 4     look together with you, please, at one example of western media coverage

 5     of events in Baranja, in particular --

 6        A.   Excuse me, I can't really read this.  It's far away from me.  Can

 7     it be magnified?

 8             MR. GOSNELL:  Any possibility we can blow up the English version

 9     a little more?

10        Q.   Is that better, Mrs. Celar?

11        A.   Yes.  Thank you.

12        Q.   Now I'd like to go through some portions of this news report from

13     The Independent newspaper, dated 27 September 1992.  Can I first ask you,

14     were you in Baranja at this time?

15        A.   Yes.

16        Q.   Paragraph 2 seems to refer to a conversation with

17     Borivoje Zivanovic, who is described here as the self-styled mayor of

18     Beli Manastir, who is reported as "predicts a 1.000-year Serbian Reich in

19     Baranja and is helping to create what appears to be a hermetically sealed

20     state under the impotent gaze of UN peacekeepers."

21             And if we can now skip to page three of this document, please.

22             At the very top of the page there, which is now being zoomed in,

23     the first paragraph:  "The imported Serbs are not allowed to leave

24     Baranja, even to visit Serbia in case they jump ship.  Only Croats and

25     Hungarians are allowed out of the enclave."

Page 10902

 1             Now, first of all, is it true that Serbs were not permitted to

 2     leave Baranja --

 3        A.   Absolutely not true.

 4        Q.   And what was the procedure for leaving, if you were a Serb?

 5        A.   Well, I believe it was the same procedure for everybody,

 6     including me, and I had to go to the opstina and get a document about

 7     leaving, and it would be stamped.  And then I'd show that at Batina, and

 8     I could leave.  And when I came back in, I had to re-register at the

 9     opstina and have my paper stamped that I could be there.  But everybody

10     did that.

11        Q.   And were -- were such permissions granted --

12        A.   Yes --

13        Q.   -- in practice?

14        A.   Yes.

15        Q.   Now if we can go back to page 1, please, of this document there's

16     this reference in this language of predicting a 1.000-year Serbian Reich

17     in Baranja.  Do you think it's plausible that Mr. Zivanovic would have

18     used that particular language?

19        A.   No, I don't think it's plausible at all.

20        Q.   And why not?

21        A.   Because he wasn't that sort of person.  I knew him and he was

22     really trying to establish some sort of order and normal life for people

23     in -- certainly, in Beli Manastir.  I was only ever really in

24     Beli Manastir at this time, so I don't know about the villages.

25        Q.   Is the reference to a "Reich" something that in your experience

Page 10903

 1     would have been likely for someone of a --

 2        A.   -- [Overlapping speakers] ... I don't believe he would have ever

 3     said that.

 4        Q.   Now if we could look down at paragraph 4 of this -- this page.

 5     It says:  "More than 50 Hungarians and Croats have been murdered in

 6     recent weeks."

 7             Now this is a document dated the 27th of September.  Can I ask

 8     you whether you heard whether there were any murders on this scale.  Here

 9     it says 50 Hungarians and Croats.  Were there any murders on that scale

10     occurring during that time-period?

11        A.   No, I never heard of any such murders.

12             Can I also say that Mr. Zivanovic used my husband as an

13     interpreter, because he was one of the few that was well versed in

14     Serbian and English languages, and he always translated for him.  So

15     that -- on reflection, the conversation with Mr. Zivanovic, I'm sure he

16     would have called my husband to translate because we didn't have any

17     reporters there.  Only one.  Only one other reporter came at that time.

18        Q.   The article continues:  "Almost every Croatian church in the

19     region has been blown up."

20             Now, is -- is that true, to your knowledge --

21        A.   No, it's not.  And Jack Klein attended some church services in

22     the village of Suza and some of the other villages, Hungarian villages,

23     there in late 1994, 1995.  And other UN personnel had attended -- they

24     were either Calvinist services or Catholic services.  They weren't the

25     Serbian churches and those church services were being held all during

Page 10904

 1     that time and the priest there, the Catholic or the Calvinist priest

 2     because my husband attended and acted as translator for those services.

 3     The two churches I knew that were blown up was one in -- well, they

 4     weren't blown up, they were burnt down actually.  It was arson.  The one

 5     in Jagodnjak -- no, sorry, Ceminac, and the one in Beli Manastir.

 6     Because when the -- particularly the one in Beli Manastir, because when

 7     it was set fire to, alarms went out and people ran up there, including my

 8     husband and he managed to take out the Bible and the priest's mantle and

 9     other things from the altar and he brought them home.  Although I'm a

10     Protestant, not a Catholic, I looked after them until 1996 and just

11     before we left, I handed them to the -- a family I referred to later

12     Rakajic [phoen] family, for them to return to the church.

13        Q.   The document or this article says that no Catholic priests are

14     tolerated.

15             Is that true?

16        A.   Well, no, they left.  But the Serbian priests had all come from

17     Croatia and the Catholic priests, as far I know went back but.  There was

18     never any discussion about not tolerated them.  In fact, in -- when my

19     father died in June 1991, I went to the Catholic priest in Ceminac to ask

20     him if I could talk to him about the death of my father, but he didn't

21     invite me in so I eventually went to find the Orthodox priest.  I felt I

22     needed to talk to a priest at that time.  That was in June that my father

23     died, in 1991.

24        Q.   Now if we can turn over to page 2 of this article, third

25     paragraph down, which is in the middle of the page, there's a quote

Page 10905

 1     attributed to someone named Blandina Negga:  "Ms. Negga described the

 2     level of terrorism in UN zones as very high, adding that 99 per cent of

 3     the victims are non-Serbs."

 4             Now, we don't know what she may mean by terrorism, but is it true

 5     that 99 per cent of the victims of crime were Serbs?

 6        A.   No --

 7        Q.   Sorry, were non-Serbs?

 8        A.   No, I would say that the wrong word is being used there.  There

 9     was a high level of criminality.  I was a victim.  I lost my camera,

10     which was in the -- one of the repair shops which was raided and

11     everything taken.  And on a smaller level, when all the women were alone

12     at night, if their husbands were on the front line, we locked ourselves

13     in and I had all my livestock stolen one night.  And others had their

14     livestock stolen too.

15        Q.   "Ms. Negga," the article continues, "linked the rise in terrorism

16     to the bussing into Baranja mainly by night of thousands of Serbian

17     refugees from Bosnia and other parts of Croatia.  The import of Bosnian

18     Serbs at the request of the local Serbian authorities cannot be stopped

19     by the UN."

20             Are you aware whether any of the refugees with whom you came in

21     contact were Bosnian Serbs instead of being from other parts of Croatia?

22        A.   I personally never met anybody who said they'd come from Bosnia

23     as a refugee.  And the only buses I was ever aware of were when they

24     brought back the women and children, all the women and children of

25     Baranja area, in -- in May 1991.  They took all the -- those that wanted

Page 10906

 1     to go, women and children, were evacuated to Serbia to Prigorica [phoen]

 2     I think it was called, and after September 1991 when some sort of order

 3     had been restored they brought them back in those and there were many

 4     hundreds of women and children brought back.  But they were the people

 5     who lived there and were returning to their homes because the fighting

 6     had stopped then.

 7        Q.   And were those buses coming into Baranja at night?

 8        A.   Nobody would have been able to come to Baranja at night because

 9     they closed the bridge.  There was a curfew.  It was extremely dangerous

10     to come from Batina bridge from Knezevi Vinogradi towards Beli Manastir

11     and on one occasion when I was in an UN vehicle being taken to somewhere,

12     they told me to lie down in the back seat and that was in the afternoon

13     because of snipers along the road.  It was dangerous.  But the town

14     itself at night was just pitch black.  Nobody went out and it was as

15     quiet as you could imagine.

16        Q.   Why didn't people go out?

17        A.   They were frightened, really.  There were incursions.  There was

18     fear, even if they weren't actually -- because most of the men were gone

19     at night onto the front lines and the women stayed in because they were

20     afraid to go out.  Even the old men were formed into some sort of small

21     bands, and they went out and guarded the water installation which was in

22     the fields along -- near where we were living.  And they went to protect

23     that.  And then, of course, the shelling would start in the evening, so,

24     all together, it was better -- we usually -- if shelling wasn't there, we

25     stayed in.  We'd open windows to talk to each other across the street and

Page 10907

 1     if the shelling had started then we'd quickly run to the basement -- if

 2     you didn't have a basement, you had to go to a neighbour's basement.

 3             MR. GOSNELL:  Could we have 1D3367, please, Defence tab 6.

 4        Q.   And just to situate ourselves in your statement, you describe the

 5     arrival of UNPROFOR, starting at paragraph 70 onwards.  And I would, in

 6     particular, direct your attention to paragraph 74, which is relevant to

 7     this document.  And this document appears to be a code cable from

 8     Goulding to Nambiar dated 23rd of March, 1992.  And it reads:

 9             "Please find attached cable received at headquarters today from

10     Ms. Amanda Brook, an English woman married to a Serb and resident in

11     Beli Manastir who has corresponded in the past with us.  Please advise

12     whether this allegation accords with information you have on continuing

13     cease-fire violations in that area."

14             Now before we turn over to look at the correspondence in

15     question, can I ask you whether you know what previous correspondence

16     appears to be referred to in this code cable?

17        A.   No, I don't have any personal recollection of personally

18     corresponding with them.  I would suppose it might have come from the

19     reports I was sending to Ian Greer in London organisation, and they

20     were... But I don't have any recollection of talking to the UN before

21     this time.

22        Q.   And if we go over to page 2, please.

23             Now I won't, Mrs. Celar, attempt to read this verbatim because

24     there are some spelling errors but I think the gist is clear for all of

25     us to see without having to read it.

Page 10908

 1             Can I just ask you what circumstances led you to right this

 2     particular cable.

 3        A.   There was tremendous fear at that time amongst everyone because

 4     the shelling had intensified into the town, and my husband, amongst

 5     others that were patrolling along the banks of the Drava came back and

 6     said to me that they were massing there, they thought Croatian forces

 7     were massing there, had lots of boats ready to come across the river

 8     Drava.  And that they expected an attack, a full attack.  There had been

 9     small incursions where some of the soldiers on the front line had been

10     killed, and he said to me, Can you please see if can you do anything?

11     They were waiting for the implementation of something from the UN so I

12     can't remember the number, implement 743, as referred to here.  So we

13     thought if they implemented that at the United Nations then the UN forces

14     would be able to come out from behind all these barricades they'd built

15     and were behind in Beli Manastir.  And we were very afraid that there

16     would be a big attack.

17        Q.   Now, these UN forces that you have just referred to and you have

18     implicitly answered my question but were they already there at this time,

19     were they present?

20        A.   Yes they had been there -- if I recall from around 16th

21     August but nobody knew quite what they were doing there.  Because they

22     took over the army, the Yugoslav army dog training barracks.  Once they

23     all left then the UN came and they built a lot of sandbag emplacements

24     around the front of the -- there was a lot of buildings there it was a

25     complex and they sat behind them and, at first, people just looked at

Page 10909

 1     them and, later on, started to ignore them because they -- we -- nobody

 2     knew quite what they were doing there.  We supposed they were waiting for

 3     this mandate to be implemented, but the fear amongst the population was

 4     that -- the suspicion was that they were waiting for the Croats to

 5     attack.  Because it was perfectly obvious to everyone that something was

 6     going to happen and they were waiting to see if the Croats would be

 7     successful before intervening.  This was what was a strongly held view by

 8     the people I spoke to.

 9        Q.   How far was that dog training centre that you referred to from

10     your house, where you lived?

11        A.   Maybe 2 kilometres.  It was at the beginning of the entrance to

12     the town of Beli Manastir, on the road leading into the town itself.  So

13     I'm not very good with distances.  Maybe 2 kilometres.

14        Q.   And to try to pin down the date more accurately, can you situate

15     in time how long before you sent this telegram did UN forces arrive?

16        A.   Well, they had already arrived.  I said they were there but I

17     didn't feel --

18        Q.   Sure, Mrs. Celar, if I can just intervene.  I understand they

19     were already there but can you remember how long before you sent this

20     cable had they arrived?

21        A.   They had been there from about the 16th of the month, and --

22        Q.   And by the month, you mean the month of March?

23        A.   Yes.  But that's when we noticed them.  I don't know how long

24     before they -- I don't know whether there were people that came before

25     they actually established themselves there.

Page 10910

 1        Q.   And rather than sending a cable to Shashi Tharoor, why didn't you

 2     simply go to their base and convey this particular information to them?

 3        A.   I didn't feel -- we felt that they were not actually very

 4     supportive of the situation and we felt they were on the side of the

 5     Croatian people and that they weren't very interested in -- this is just

 6     an impression.  I have absolutely no basis for saying that but that was

 7     the opinion of all the people, that they were all waiting.

 8        Q.   At paragraph 76 of your statement, you describe having a meeting

 9     with some representatives of the Belgian Battalion who apparently,

10     according to you are -- or have been sent in response to this particular

11     cable that you've sent.  And you said:  "I told them that the only way

12     that they could be ignorant of the fighting was if they were not engaging

13     in any patrolling."

14             Now did -- and this is not mentioned in your statement, but did

15     they, Mr. Malherbe or anyone else, part of this group that came to see

16     you, did they say anything about whether they were or were not patrolling

17     in response to your complaint?

18        A.   They said -- there was a conversation that went something like

19     this.  He said, Why did you send that cable?  I said, Because everybody

20     is afraid of an imminent attack and there are incursions already

21     happening.  And he said, We have no record of any incursions or any

22     fighting.  And I said, Well, you wouldn't because you're not there on the

23     front line checking what's happening.  You can't see anything when you're

24     all behind your bunkers at the top of Beli Manastir.  And he said, We

25     have no mandate to do any patrolling.  We're not allowed to go and

Page 10911

 1     patrol.  So I said, If you don't go and patrol there, you won't see any

 2     fighting.  They're not doing it in the town, it's on the River Drava.

 3        Q.   On paragraph 74 of your statement and I suppose now we can pull

 4     that up on the screens please.  Now, that's D173, page 24, and you

 5     describe that there was an infantry attack that occurred on the 3rd of

 6     April, 1992, and you say:  "Infantry came across the Drava, and tanks

 7     crossed the Hungarian border in support of the attack, from what I heard.

 8     Do you know whether the UN forces present there did anything in response

 9     to this attack?

10        A.   No, I -- no.  We collected in the -- we -- we were called about

11     4.00 in the afternoon to go and watch the lorries coming back from the

12     front line to -- really to go and see if your husband or son, whatever,

13     were with -- they brought the wounded back, and it was very much a

14     Serbian -- I didn't see any UNPROFOR.

15        Q.   Did you ever subsequently hear that they did anything in response

16     to this attack --

17        A.   No.

18        Q.   Did you ever hear what was the ethnicity of those who were

19     working for the UN forces based in Beli Manastir?

20        A.   The -- the people who were working within the BelBat complex were

21     all Croatians, from Croatia, and most of the Serbs that were working as

22     interpreters and staff, including my husband, after that mandate was

23     implemented, were -- they were working for CIVPOL as translators and

24     support staff.  But that was for CIVPOL, not for the BelBat.

25        Q.   If we can look at the middle of paragraph 77 of your statement,

Page 10912

 1     you are describing a meeting with some Belgian officers who are part of

 2     BelBat and the JNA commander in the area, Mr. Krstic.  And you report

 3     here that Colonel -- or that Mr. Malherbe said:  "You don't understand,

 4     Amanda, these people are not civilised like us.  They don't behave the

 5     same way we do."

 6             Can you tell us for clarity what you understood him to mean when

 7     he said "these people"?  Who was he referring to?

 8        A.   Well, he is referring to the Serbs that were in the area where

 9     they were acting.  And the impression I got was the way I would imagine

10     as if they were colonialists that were treating with the local

11     inhabitants.  He was very dismissive.  Actually, I got very angry with

12     him and I did say I am appalled that they can ap point people as ignorant

13     as you are of the culture, how old the Serbian culture is.  And then I

14     childishly said to him, Whereas Belgium is only about 200 years old how

15     can you make such a distinction about Serbs?  It was ignorance.  I was so

16     angry because he assumed that nobody else in the room spoke English,

17     which I understood they did they afterwards, but they didn't choose to at

18     the time.  And I was embarrassed that they could hear this sort of

19     conversation.  I thought it was dreadful.

20        Q.   And who you characterise generally between BelBat and the local

21     population in Beli Manastir as you observed it, or heard about it?

22        A.   It was very poor.  It wasn't friendly.  I didn't hear of

23     people -- I heard of people being offended by the way they presented

24     themselves.  They tended to swagger, do a lot of swaggering about and all

25     the more noticeable because it was so different with the Pakistani


Page 10913

 1     Battalion in Darda and later CIVPOL, who everybody got quite friendly

 2     with.  In a -- not in a bad way.  Respected each other, I would say.

 3        Q.   And do you know whether there was any sentiment locally about

 4     whether BelBat should be replaced by a contingent of a different

 5     nationality?

 6        A.   Yes, they didn't want -- they thought BelBat were on the side of

 7     Croatians.  They had no -- that was the impression of the populace.

 8        Q.   Do you think it was justified that there was that wish to replace

 9     them?

10        A.   If it would have helped the situation I think it would have been

11     far better.  Because there is always a certain amount of paranoia in a

12     situation like that.  But it certainly didn't help to bring a feeling of

13     any sort of security for the population.

14        Q.   Thank you, Mrs. Celar.

15             MR. GOSNELL:  [Microphone not activated] Mr. President, no

16     further questions at this time.

17             JUDGE DELVOIE:  Thank you, Mr. Gosnell.

18             Ms. Biersay.

19             MS. BIERSAY:  If I could have just one moment to reorganise.

20             JUDGE DELVOIE:  Okay.

21             MS. BIERSAY:  I -- I look at the clock --

22                           Cross-examination by Ms. Biersay:

23        Q.   And I greet you.  Good afternoon, Mrs. Celar.

24        A.   Good afternoon.

25        Q.   My name is Lisa Biersay.  We haven't met, and I will be asking

Page 10914

 1     you questions on behalf of the Office of the Prosecutor.  I have been

 2     granted three hours to ask you questions, that time may be shorter, or I

 3     may request a longer time.  It all depends on how efficient we are with

 4     questions and answers.

 5             THE INTERPRETER:  Interpreter's note:  Kindly observe pauses

 6     between questions and answers.  Thank you.

 7             JUDGE DELVOIE:  Did you hear that, Mrs. Celar?

 8             THE WITNESS:  Yes.

 9             JUDGE DELVOIE:  That is because --

10             THE WITNESS:  I'm sorry.

11             JUDGE DELVOIE:  No, no, there's no problem.  It's just to let you

12     know that when people are speaking the same language, there's still need

13     for translation and interpretation, and the interpreters, of course, need

14     time to do that.  So if we can avoid overlap between questions and

15     answers that would be very nice.  Thank you.

16             MS. BIERSAY:  It's likely it was meant for me.

17        Q.   From reading your materials and listening to you, you talk a lot

18     about your husband, Ilija Celar --

19        A.   Yes.

20        Q.   I have the sense that you and Ilija Celar have a very tight bond?

21        A.   Yes, we have a wonderful marriage.

22        Q.   And you've been married for how many years at this point?

23        A.   Well, we were partners at first and then married, but 27 years in

24     total.

25        Q.   And from what I gathered from the materials, it was love at first

Page 10915

 1     sight that has endured time.  Is that right?

 2        A.   Yes.

 3        Q.   And, in fact, the Netherlands is a special place for the two of

 4     you?

 5        A.   Yes.

 6        Q.   Because that's where you met?

 7        A.   We met in Amsterdam.

 8        Q.   Did he also come with you on this trip to the --

 9        A.   No.

10        Q.   Netherlands?  And why not?  Why didn't he come?

11        A.   We have a farm and there's nobody else to take care of the

12     livestock and I also rescue dogs and nobody will volunteer to look after

13     seven dogs.

14        Q.   Now back in 1987, it was because of your love for Ilija Celar

15     that you moved to a new country.  Is that fair to say?

16        A.   We discussed where we'd both like to live actually.  And he was

17     due to go to South Africa and I didn't want to go to South Africa.  He

18     didn't want to live in England.  We found Amsterdam too expensive and we

19     thought the then-Yugoslavia would be a lovely place to live.

20        Q.   So again, because of your relationship, that why you --

21        A.   Yeah, mutual decision to go somewhere nice to live together.

22        Q.   And because of that bond you took on the challenge of learning a

23     new language --

24        A.   Yes, and also because I teach English there.

25        Q.   And learning a new culture?

Page 10916

 1        A.   Yes.

 2        Q.   And you had to learn a very complicated and long history of the

 3     region and all the people there.

 4        A.   I didn't have to.  When we first moved there, it was Yugoslavia

 5     and I wasn't aware at all of different ethnic groups.  I just wasn't

 6     aware of it at first because there were -- there is a lot of

 7     intermarriage there, tremendous amounts of intermarriage.  So my

 8     brother-in-law was Croatian and his wife was Serbian.

 9        Q.   And when you say that when you moved there you weren't aware of

10     all the different ethnic groups how did you come to learn about the

11     different ethnic groups?

12        A.   Well, if you listened to people talking and some of the people

13     wanted to talk to me because I was English and there weren't many English

14     people living there, if any.  I don't think there were any and they

15     wanted to tell me their history.  They were very proud of their history

16     but it was usually about Yugoslavia and about Tito, because there was

17     still Communism when I first went there but a very easy -- a very easy

18     form of Communism.

19        Q.   Is it fair to say that you learned the language, the culture, the

20     history, mostly through your interactions with Ilija Celar?

21        A.   Not the language, because he insists on speaking English all the

22     time because he wants to perfect his language.

23        Q.   So your home language was --

24        A.   Was English --

25        Q.   English.

Page 10917

 1        A.   And I learned more English -- I was very lazy.  Everybody I met

 2     wanted to speak English to practice their English.  So for a long time I

 3     didn't learn as much as I could have done.  But I actually learnt it from

 4     girlfriends that didn't speak English that I -- taught me or neighbours,

 5     I was drinking coffee with.  It was a very sociable society.

 6        Q.   So the language you learned from other people, and the history

 7     and the culture and all of that, you learned mostly from Ilija Celar.

 8        A.   Well, I read.  I'm a -- I'm an independent person.  Ilija

 9     discussed what happened on Kosovo and things like that, but he didn't

10     particularly -- he taught me some of it or if I asked questions but I

11     asked other people.  I didn't just ask him.

12        Q.   Now, I'm just looking at the clock but I think we'll have enough

13     time to start this segment.  I would like some help in understanding the

14     timeline of where you lived in the former Yugoslavia.  So when you first

15     arrived in 1987, you lived with Ilija Celar's mother in Jagodnjak.  Is

16     that right?

17        A.   Yes.  And also, at the same time, we stayed with his sister in

18     Ceminac.

19        Q.   In Ceminac?

20        A.   We stayed in both places at some point.

21        Q.   Did you have stable home in Jagodnjak did you stay there for a

22     certain period of time --

23        A.   No.

24        Q.   Or you --

25        A.   We stayed between the two places and they've got families and

Page 10918

 1     they didn't really have very big houses.  We stayed really until we

 2     managed to find a property in Osijek, which is what we were looking for,

 3     to go and live in Osijek.

 4        Q.   And when did you make the move to Osijek?

 5        A.   I think it was in early -- early 1988.  After the Serbian

 6     Christmas, which is in January.  So I think it was -- could have been

 7     February.  I can't precisely remember the date.

 8        Q.   Sounds like Jagodnjak and Osijek are two very different types of

 9     places, like one is very big compared to the other?

10        A.   Well, Osijek is the town over the river, a regional town, big

11     town, and Jagodnjak and Ceminac are in Baranja, in the villages.

12        Q.   Did you get to know Jagodnjak and the people there even though --

13        A.   Not at that time.

14        Q.   Okay.

15        A.   Later on, I did, but not at that time.

16        Q.   When you say later on, when would that have been?

17        A.   After we left Osijek in 1991.

18        Q.   So if I understand you correctly, it's after you left Osijek that

19     you learned, really, the people and the town of Jagodnjak.  Do I

20     understand that correctly?

21        A.   And Ceminac.

22        Q.   And Ceminac.

23        A.   Because we had a flat in Jagodnjak that belonged to Ilija's

24     brother who was a doctor in Germany and didn't use it and he let us use

25     the flat.

Page 10919

 1        Q.   And where was that apartment?

 2        A.   Near the medical centre.

 3             MS. BIERSAY:  I'm looking at the time, Your Honours, would this

 4     would be a good time for the break.

 5             JUDGE DELVOIE:  It would, Ms. Biersay.

 6             Mr. Gosnell.

 7             MR. GOSNELL:  Sorry to raise this.  I don't have an exhibit list

 8     yet from the Prosecution.  Maybe there won't be any exhibits used.

 9             MS. BIERSAY:  No.  It should have been released about ten minutes

10     ago.  I'll check it.  But we'll take care of it during the break.  Thank

11     you for raising it.

12             JUDGE DELVOIE:  Thank you.

13             Court adjourned.

14                           [The witness stands down]

15                           --- Recess taken at 12.14 p.m.

16                           --- On resuming at 12.47 p.m.

17                           [The witness takes the stand]

18             JUDGE DELVOIE:  Ms. Biersay, please proceed.

19             MS. BIERSAY:  Thank you, Your Honour.

20        Q.   I'd like just to go back to our conversation about Jagodnjak.

21     You described that you were living in a flat that was near the medical

22     centre.  Was that an apartment building or a house?  What was it?

23        A.   It was flat that was given to the doctor --

24        Q.   Could you get a little closer to the --

25        A.   Sorry.

Page 10920

 1        Q.   It's not picking up.  There you go.

 2        A.   It was the flat that belonged to the medical centre which --

 3     Ilija's brother was the appointed doctor for that medical centre although

 4     he was in --

 5        Q.   Sorry to --

 6        A.   -- Germany.

 7        Q.   -- interrupt.  Just to describe what kind of structure it was?

 8        A.   It was a single story building.  The medical centre was on the

 9     left and the flat was on the right.

10        Q.   I think I understand.

11        A.   It was single story but just split into two rooms.

12        Q.   So after you moved to Osijek, you continued to travel to

13     Jagodnjak, I would imagine, to visit --

14        A.   Oh yes.

15        Q.   Ilija Celar's --

16        A.   And Ceminac, for family.  And also, I can`t remember the name of

17     the other little town there.

18        Q.   And how --

19             JUDGE DELVOIE:  Could we remind you not to overlap, please.

20             MS. BIERSAY:

21        Q.   How frequently would you make the trip from Osijek to Jagodnjak,

22     say, in a week?

23        A.   Well, I -- it would depend on what was happening.  And it was a

24     two- or three-year period, so it depended if there was a family Slava or

25     celebration or wedding or just to see them socially.  I think we used to

Page 10921

 1     go there most Sundays for lunch because they worked all during the week,

 2     so it was probably weekends we went, unless there was a holiday or a

 3     celebration.

 4        Q.   And so for what time-period did you live in Osijek total?

 5        A.   From the beginning of 1988 until when we left in April, I think

 6     it was April, 1991.

 7        Q.   Where did you go after you and Ilija Celar left Osijek?

 8        A.   Well, we went to that flat in Jagodnjak.

 9        Q.   Got it.  When -- how long did you stay in that flat?

10        A.   I stayed there until June, the 17th.  And then my father died, so

11     within a couple of days I travelled back to England.  And I didn't see

12     the flat again until probably the next year to go and retrieve some of my

13     possessions.  The first time it was safe to go back there.  I didn't live

14     in it again after that time.

15        Q.   And which flat are we talking about now?

16        A.   Jagodnjak.

17        Q.   When did you start living in Beli Manastir?

18        A.   When I came back from England.  October, in 1991.

19        Q.   How did you find the house or the place where you lived in

20     Beli Manastir?

21        A.   I went -- I was escorted from the bridge in Batina.  I'd had a

22     call from a -- I'd had a call from a journalist that Ilija had been

23     wounded and Ilija had given him a message to try and get the message to

24     me.  So this journalist rang me at my home in England and that's why I

25     came back in October, I think, and I came to the bridge, but I didn't --

Page 10922

 1     I didn't have any sort of paperwork.  So they took me from the Batina

 2     bridge, straight to the police station in Beli Manastir.  And then when

 3     they found out who I was, one of the wives of one of the people in

 4     Ilija's group, came and took me to her house for a few days, and then

 5     they said that there was another house that -- they'd put all the special

 6     forces fighters in one district of the -- of this -- of Beli Manastir so

 7     that if they -- when they had an alarm because there weren't that many of

 8     them they could find them and they could respond to the alarm.  So I

 9     didn't find out actually where I was going to live and I didn't live in

10     it until after January 1992.

11        Q.   So where did you live between October 1991 and January 1992?

12        A.   With --

13             THE INTERPRETER:  The speakers are kindly reminded to pause

14     between question and answer.  Thank you.

15             MS. BIERSAY:  Thank you very much for the reminder.  I will be

16     more mindful.

17             THE WITNESS:  I lived with Ilija's nephew and niece who were

18     living in their aunt's house in Beli Manastir.  Their aunt was Croatian

19     and had gone to Croatia, and this is where the father is Croatian and

20     their mother is Serbian.  And they'd stayed in Serbia.  So they were

21     living in the aunt's house and I stayed with them until Ilija came out of

22     hospital, I think.  Until Ilija came out of hospital.

23             MS. BIERSAY:

24        Q.   Okay.  I'd like to back up just a little bit from October 1991 to

25     January 1992, you lived with family --

Page 10923

 1        A.   Well, I believe that's right.

 2        Q.   Where in Beli Manastir was that?

 3        A.   In -- I can't remember the name of the street.  It was where the

 4     other house was, where we moved into when Ilija came out of hospital.

 5        Q.   So in January 1992, you moved into a house in Beli Manastir where

 6     you would stay for a long period of time.

 7        A.   Yes.

 8        Q.   And how did you find the house that you --

 9        A.   Well, I didn't find it.  I just moved into it.  I had no idea.

10        Q.   Let me just finish my question.  We will help each other and the

11     translators and the interpreters as well.

12             How did you and Ilija Celar come to live in the place where you

13     moved in January of 1992?

14        A.   I only knew -- that was where I was told was where we were going

15     to live.  And that the special forces because the whole street had about

16     five or six other people that were in the special forces that were living

17     there as well, including -- it was the house next door to the house that

18     Ilija's niece and nephew were living in.

19        Q.   Do you remember the name of -- that street?

20        A.   Truthfully, I don't.

21        Q.   I'll ask you another question in the meantime.  Is it fair to say

22     that when you were actually in the former Yugoslavia from 1987 to 1993,

23     you lived in Jagodnjak, sometimes Ceminac, Osijek, or Beli Manastir?

24        A.   Yes.

25        Q.   What period of time was Ilija Celar in hospital?  You said that

Page 10924

 1     it was after he came out of hospital that you moved to this permanent --

 2     more permanent address in January 1992.

 3        A.   No, he must have come back in the October because I went back to

 4     Britain, I'm sorry, I'm getting confused.  It was in October that we

 5     moved into this -- I stayed with these -- until he came out of hospital.

 6     He came out of hospital at the -- sometime before I went back to Britain

 7     which would have been November.  I'm not absolutely clear of that period,

 8     because it was very traumatic.  My father had just died and Ilija had

 9     been injured and my journey from the airport to Baranja was dreadful.  I

10     think we moved into that place in November.

11        Q.   What you just described as a very traumatic period of time from

12     June until the end of 1991 for you?

13        A.   Until November.  And then I went back to England, because it was

14     so dangerous, there was so much shelling, Ilija really didn't want me to

15     be there.

16        Q.   Did there come a time when you and Ilija Celar became politically

17     involved, politically active?

18        A.   No.  I have never been politically active.

19        Q.   Did you or Ilija Celar support the SDS, which is very popular

20     then in Jagodnjak in 1991?

21        A.   I don't know whether Ilija did, but I had nothing do with

22     politics at all.  I've always regarded myself, and I still do, as a guest

23     in the country and as such I've never got involved with politics.

24        Q.   You referred to yourself as a guest in the country and I'm -- I

25     recall having read somewhere where you described yourself as a

Page 10925

 1     Serbophile?

 2        A.   I am.  I love Serbs.  I didn't mean to say I think I'm a Serb.

 3     I'm not.  I shall always be English.

 4        Q.   So are you saying that do not know, whether Ilija Celar supported

 5     the SDS?

 6        A.   Well, I suppose he did.  But he doesn't vote.  He is not a very

 7     political person.  But I can say that he is a nationalist if that means

 8     he was of that party.  He hasn't got a very good opinion of politicians.

 9        Q.   But you would describe him as a nationalist?

10        A.   Yes.

11        Q.   Just quickly, regarding the special forces fighters who were

12     living in this district, that house that you lived in, in the end of 1991

13     to 1992, who were they?  Who are these special forces fighters that you

14     talk about?

15        A.   Well, if you understand that the first 18, was started -- when

16     the fighting started on August the 19th in Beli Manastir, there were a

17     group of 19 who met to discuss how they were going do defend themselves

18     because they felt under attack and they were the core, that when they

19     were attacked by the Croatian police, that was the first -- that was the

20     beginning of the fighting in Beli Manastir and others came to join them,

21     I think in total -- some of them got killed.  There were about 46 of them

22     and there were very few of them.  And they then, as I say in here, that

23     the Croatians thought there were far more of them.

24        Q.   Okay.  Thank you.

25        A.   It's all to do with that and it's all those -- the ones who

Page 10926

 1     formed themselves into a defensive group, I would say.  It wasn't a

 2     political group.  It was a defensive group.

 3        Q.   I understand.  And Ilija Celar was a member of this special

 4     forces fighters.

 5        A.   Yes.

 6        Q.   In paragraph 3 of your statement, you describe hearing the slogan

 7     "Croatia for Croats" during the 1990 election campaign?

 8        A.   Yes.

 9        Q.   And in response to some questions asked by Mr. Gosnell, you

10     explained that by the end of 1992 your Serbian was reasonable?

11        A.   Yes.

12        Q.   And I wondered where were you hearing these slogans?  TV?

13        A.   TV -- well, we used to watch Croatian television, always, because

14     they had far better programs on than Serbian television.  And I would see

15     various news items or a few things impressed me that I didn't like with

16     the -- not exactly your question, but when they had church services

17     they'd got Croatian flag around the candles which I thought was

18     offensive.  There were a few things that I didn't -- but that was nothing

19     to do with -- I didn't discuss it with anybody.  It's just I was watching

20     what was happening.

21        Q.   Okay.  It will be important for each of us to track each other as

22     far as questions and answers.

23        A.   All right.  Sorry.

24        Q.   So just to be a little more concise.

25        A.   Precise.

Page 10927

 1        Q.   Thank you.  So my question to you was regarding the slogans you

 2     were hearing and given the challenges you had with the language, where

 3     were you hearing these slogans?

 4        A.   Well, this wasn't a difficult slogan to understand.  Hrvatska za

 5     Hrvate, I knew what that meant.

 6        Q.   I have another --

 7        A.   We had friends that -- when we went there initially, it was

 8     Yugoslavia.  Everybody -- I didn't hear any ethnicity that's why I --

 9     this came as a slow process.  I can't say it suddenly happened.  It just

10     came in, insidiously, I would say.

11        Q.   And where else would you get your information about current

12     affairs?  Croatian TV, is that the only place?

13        A.   Croatian television.  Well, friends.  We had a lot of friends

14     that came and visited us.  A lot of them spoke English.

15        Q.   And they would tell you, keep you abreast of what was happening?

16        A.   Well, it depended which perspective they were coming from.  We

17     had all sorts of friends.  We didn't limit ourselves to Serbian friends.

18     We had Croatian friends.  As I said, there were so many mixed marriage

19     friends.  One of my most dear friend is a Muslim.  It came from very

20     different sources.

21        Q.   Those source would say include the media, your friends, your

22     partner, Ilija Celar?

23        A.   Could have.  Yes, I would certainly know his opinion on things.

24        Q.   Now, in your statement you also describe how rhetoric about

25     Croatia's Fascist past.  I think what you say is that it provoked genuine

Page 10928

 1     and extreme fear amongst Serbs living in Croatia?

 2        A.   Yes.

 3        Q.   So if I understand you correctly, are you saying that Serbs

 4     became fearful because of what they heard Croatian politicians saying?

 5        A.   It was more than that.  It was the flag.  It was the uniforms.

 6     And it was this statement that they'd got to sign in order to stay at

 7     their place of work, the contract, because they were all replicas of what

 8     had been used during that independent state of Croatia.

 9        Q.   And how did you know about the independent state of Croatia?

10        A.   Well, I'd known it because I studied previously the history of

11     World War II.  I also met Michael Lees, who worked with the Chetniks.

12        Q.   When you say worked with the Chetniks you actually served --

13        A.   During the Second World War, he was with the Chetniks.  And I

14     didn't necessarily agree with him because he was -- he was a royalist,

15     and didn't have a good word to say about Tito, really.  Whereas lots of

16     people did have nice things to say about Tito.  It was -- my conception

17     of what the country would be like wasn't anything what it was like in

18     reality when I got there.

19        Q.   Okay.  One of the events that made Serbs more fearful would be

20     the discussion about Croatia's Fascist past; right?

21        A.   Yes.

22        Q.   You also mentioned that talk about the past genocide against the

23     Serb people also triggered fear in them, right?

24        A.   Yes.

25        Q.   Did it trigger fear in Ilija Celar?

Page 10929

 1        A.   I wouldn't describe it as fear.  He was deeply unhappy.  Ilija

 2     was essentially, when I first knew him before the war began, a Yugoslav

 3     and a lot of our friends were perfectly satisfied with the status quo.

 4        Q.   Excuse me, Mrs. Celar.  Just to back up one -- one minute.

 5             You said, I wouldn't describe it as fear.  He was deeply unhappy;

 6     right?

 7        A.   Yes.

 8        Q.   Okay.  If I could just ask you why wouldn't you describe that

 9     as -- as fear?

10        A.   Well, it's not a -- it's not something I'd describe as -- as --

11     as -- a fear, because nobody believed there was going to be any fighting.

12     Everybody said, It's only these leaders that are -- the rhetoric but

13     people won't actually fight each other.  We're related to each other.

14     We're family.  The big -- Croats came to our house.  They didn't come as

15     Croats; they came as friends and they would have an opinion about what

16     was happening for independence for Croatia.  We would have our opinion

17     about it.  We would talk about in those days or disagree with them.  We

18     had a visitor who had been a refugee in the Second World War, had -- and

19     talked what she was going through.  She was a Croat.

20        Q.   Okay.

21        A.   No -- I'm sorry, it's just very complicated.  It's not simplistic

22     at all.

23        Q.   It`s not simplistic; is it?

24        A.   No.

25        Q.   So that's why I would ask you to listen to my questions and I

Page 10930

 1     apologise, because I will have to continue trying to bring you back to

 2     the question.

 3        A.   Okay.

 4        Q.   One of the things you talked about, you talked about the flag --

 5        A.   That was explained to me --

 6        Q.   One moment, let me just finish the question.  You described the

 7     flag being something that upset Serbs --

 8        A.   Yes.

 9        Q.   -- right?  You describe in your statement that the flag of

10     Croatia in 1990/1991 was the exact same flag was used by the Fascists in

11     the 1940s --

12        A.   That's what I was told.

13        Q.   And my question to you is:  What was the basis of that?  Who told

14     you that.

15        A.   Well, I just think it was a point of discussion that was brought

16     up when we were talking about it.  I don't recall anybody saying this

17     is -- the start of the discussion about the flag and -- and this sort of

18     thing was begun when we saw these black shirts in Osijek, when I was out

19     shopping --

20        Q.   I understand the context --

21        A.   And that led to us discussing whether the people, and with Ilija,

22     and saying what's going on?

23        Q.   So --

24        A.   -- and during those discussions --

25        Q.   Mrs. Celar, one moment, please.  My question to you is how did

Page 10931

 1     you get your information about the flags being the same and I believe you

 2     answered that.  You said that people told you; right?  Was Ilija Celar

 3     one of the people who told you?

 4        A.   He could have been.  I can't categorically tell you who

 5     specifically at that time told me this sort of information.

 6        Q.   Had you actually seen the flags?

 7        A.   No.

 8        Q.   So you actually don't know if they're exactly the same, do you?

 9        A.   No, only by what I've read and heard, but I hadn't seen it.

10        Q.   You also referenced the pledge of allegiance as being something

11     that instilled fear in Serbs?

12        A.   Yes.

13        Q.   And you say that it was exactly the same language that had been

14     used by the independent state of Croatia.  What is the basis for --

15        A.   It's the same thing.  It was the discussion said that the flag,

16     the insignia of the uniforms and -- it was the three things that the --

17     the paper that they had to sign of allegiance to Croatia were all

18     replicas of what had been used in that government.

19        Q.   And this is what you heard from Ilija Celar and others?

20        A.   And others, when we discussed it.

21        Q.   Mrs. Celar, in your statement, you say that you did not hear

22     rhetoric from the Serb side about Greater Serbia.  You said that it arose

23     later and had little appeal.  Do you recall that from your statements?

24        A.   I never really heard anybody talking about Greater Serbia.

25        Q.   So the answer to my question is yes --

Page 10932

 1        A.   I never heard it.

 2        Q.   What does the phrase "Greater Serbia" mean to you?

 3        A.   Well, I would imagine that a Serbia that could expand borders and

 4     take over the countries.

 5        Q.   So the expansion of borders --

 6        A.   I would imagine so.  That's what it would mean to me literally.

 7        Q.   When did you start hearing that kind of rhetoric?

 8        A.   I never heard that sort of rhetoric.  I'm just answering what

 9     that would mean to me.

10        Q.   I understand --

11        A.   I heard Yugoslavia.  At that time it was Yugoslavia.

12        Q.   So in 1991, 1992, you were not hearing Serbs talk about the

13     adjustment of borders?

14        A.   Well, I was told that they were -- that there were other

15     reasons -- yes.  Okay.  I heard about the adjustment of borders like

16     this.  That Baranja had never been Croatian and, therefore, it should

17     never be Croatian territory and that Tito had drawn the borders as he saw

18     fit and nobody challenged it.  That's what I heard.

19        Q.   I see.

20        A.   Ultimately, I know borders were drawn at difference times.  At

21     that was at the time when you -- when people get together and put

22     grievances together, that's what I heard.

23             JUDGE DELVOIE:  Mr. Gosnell.

24             MR. GOSNELL:  Apologies for the interruption, Mr. President, but

25     what was put by my learned friend at page 78, line 1, you did not hear --

Page 10933

 1     "In your statement you say that you did not hear rhetoric from the Serb

 2     side about Greater Serbia."

 3             That's not precisely what is in Mrs. Celar's statement.

 4             MS. BIERSAY:  I'm happy to read it.

 5             MR. GOSNELL:  And I apologise for the delay in noting that.

 6             MS. BIERSAY:

 7        Q.   Paragraph 5:  "I would add that neither at this stage nor later

 8     did I hear any equivalent rhetoric from the Serb side concerning

 9     Greater Serbia."

10             And Mrs. Celar answered my question.  So now I'd like to ask you

11     another question --

12        A.   Yes.

13        Q.   You talked about the expansion of borders and I wondered in what

14     context did you hear that kind of discussion, about it -- Baranja never

15     being Croatian, should never be Croatian territory, and so forth?

16        A.   That was later.  That was after the fighting began and we went to

17     live in Baranja and that I heard my husband and others saying that they

18     were really -- if -- an autonomous area is what they'd like.  To be

19     neither affiliated with -- if it couldn't be Yugoslavia, they didn't want

20     to be part of Serbia and they didn't want to be part of Croatia.  They

21     thought about an autonomous area, like Luxembourg.

22        Q.   And you heard that from Ilija Celar?

23        A.   Yes.

24        Q.   Have you heard of Vojislav Seselj?

25        A.   Yes.

Page 10934

 1        Q.   I would like to play tab 16 which is Exhibit 1726.

 2             And I will tell you that the information I have is this is

 3     April 1991, and it's Seselj in Plitvice.

 4             MS. BIERSAY:  Actually, if we could wait one minute before

 5     starting.  I understand that we have a new protocol of checking with the

 6     booth to see whether or not the transcript is ready to go?

 7             JUDGE DELVOIE:  And a very helpful one, Ms. Biersay.

 8             MS. BIERSAY:  It has been proven to be very helpful, indeed.

 9             So I'm just awaiting confirmation from the booth that they have

10     P1726.

11             THE INTERPRETER:  We have it, Your Honours.

12             MS. BIERSAY:  And so I'd like to go ahead and play this.

13                           [Video-clip played]

14             "THE INTERPRETER: [Voiceover] Serbia, Serbia.  Serbian people

15     live here.  This is Serbian land and it will remain Serbian forever.

16     After calling the decision on the establishment of the Serbian Autonomous

17     District of Krajina historical Seselj said, Serbian brothers and sisters,

18     you find yourself in the front lines defending the Serbian cause.  The

19     Serbian state borders.  You are in the most difficult position and you

20     are the pride of the whole of Serbdom.  He has promised them they would

21     not left to themselves and that all the Serbs in Croatia have only one

22     party, the Serbian Democratic Party.  You have a wise and brave

23     leadership headed by the heroic Dr. Milan Babic.  Those who divide the

24     Serbian people he labelled as traitors.  Only Ante Markovic's mercenaries

25     and those of foreign intelligence services believe today that there are

Page 10935

 1     more important problems that your defence, your protection.  They offer

 2     you up to Tudjman.  They would sell you.  You will not be sold or

 3     betrayed.  Instead of calming them down, Seselj sent a message to the

 4     gathered people as follows:  We are sending a message to the new Ustasha

 5     head of state and Ustasha regime in Croatia.  Serbian heads have rolled,

 6     struck down by the Ustasha hands in the Serbian Krajina, as Serbian head

 7     rolled in Serbian Western Srem and Slavonia as well.  We will avenge

 8     Serbian blood.  We will."

 9             MS. BIERSAY:

10        Q.   Would you agree with me that that rally in Plitvice was very well

11     attended?

12        A.   Well, yes.

13        Q.   And you heard when Seselj talked about defending the Serb cause

14     and defending Serbian state borders?

15        A.   Yes.

16        Q.   Did you hear about that big rally and speech in Plitvice?

17        A.   I wasn't aware of it.

18        Q.   -- in April --

19        A.   -- I may have seen it, but it didn't really concern me.  I

20     wasn't -- I mean I -- he was a politician.  He has nothing to do with me.

21        Q.   Did you hear about the rally?

22        A.   I can't say that I did.  I may have done at the time but it's not

23     something that stayed in my memory as important.

24        Q.   Do you know that Seselj came to Jagodnjak to give a speech?

25        A.   I heard -- yes, I heard he was there, and I know Ilija went to

Page 10936

 1     see him but I didn't go.

 2        Q.   Did Ilija Celar tell you what was said at that rally?

 3        A.   Not really.

 4        Q.   Well --

 5        A.   I knew that he rallying the Serbs.

 6        Q.   Let me play for you tab 6, which is exhibit 240.

 7             MS. BIERSAY:  One minute, please.

 8                           [Prosecution counsel confer]

 9             MS. BIERSAY:  Just one minute, please.

10        Q.   While we're checking the technical issue of the tab number, did

11     you ever hear about the concept of distinguishing between Croats who were

12     natives to Baranja versus others who had come after the war?

13        A.   Which war do you mean?

14        Q.   The Second World War.

15        A.   After Second World War, my husband's family came from Bosnia.

16     They were relocated there in 1948.  I heard that.

17        Q.   For Croats, did you hear that there was reference to Croats being

18     brought in after the Second World War?

19        A.   Well, yes, because the Germans had all gone.

20        Q.   Okay.  So --

21        A.   But nobody differentiated between how many Croats came and how

22     many Serbs came.

23        Q.   I understand.  So tab 7, exhibit 240 if I could get a

24     confirmation from the booth.

25             THE INTERPRETER:  We have it.

Page 10937

 1                           [Video-clip played]

 2             "THE INTERPRETER: [Voiceover] This is a nice occasion so I will

 3     try to show you a historical fact.  Croats who live here came to your

 4     fields and to your homes, Pavelic colonised them here because they were

 5     good butchers.  They still live here to this day.  The Hungarians here

 6     don't wish to be the same as those in Backa because they primarily serve

 7     Tudjman.  This is Serbian land and they must realise that they are

 8     intruders and they will have to leave if they don't want to live nicely

 9     with us.  They are perpetually trying to put us down, to destroy our

10     borders and our graveyards.  Hungarians must not dig up..."

11             MS. BIERSAY:

12        Q.   I paused it here where it is subtitled, "to destroy our borders

13     and our graveyards," to ask you if you recognise anyone on the stage.

14        A.   The man on the right I have seen before but I don't know his

15     name.

16        Q.   On the right --

17        A.   On the right.

18        Q.   In the front?

19        A.   Yes.

20        Q.   With the white shirt and the grey jacket.

21        A.   Yes, with the white --

22        Q.   And no -- no tie?

23        A.   No tie.

24        Q.   You recognise him --

25        A.   Yeah.

Page 10938

 1        Q.   But you don't recall his name?

 2        A.   And -- Seselj is there.  I don't know who the speaker is.

 3        Q.   This is Milan Paroski.

 4        A.   I don't know.

 5             MS. BIERSAY:  Could we continue.

 6                           [Video-clip played]

 7             "THE INTERPRETER: [Voiceover] ... Medieval archeological finds

 8     because all they will find are Serbs.  Now they have stopped their

 9     archeological research.  This is the truth so whoever comes and tells you

10     that this is his land, he is a usurper.  He has come to take the land and

11     you have the right to kill him like a dog."

12             MS. BIERSAY:

13        Q.   Did Ilija Celar tell you that someone at the rally said that

14     this -- anyone who asked for this land is a usurper and you have the

15     right to kill him like a dog?

16        A.   No.

17             MS. BIERSAY:  We'll continue.

18                           [Video-clip played]

19             "THE INTERPRETER: [Voiceover] The Croats can leave Yugoslavia

20     wherever they please, but they have to note that they cannot take a

21     single foot of Serbian land with them, not a single acre that holds

22     Serbian villages, churches, Serbian death pits, death camps, Serbian

23     Jasenovac.  If we were to allow that we would unworthy of our glorious

24     ancestors, and we would have to feel ashamed before our descendants, the

25     Croats may create their own state but only west of the

Page 10939

 1     Karlobag-Ogulin-Karlovac-Virovitica line.  That's right.  Everything east

 2     of that line belongs to the Serbs and we shall not allow the Croats to

 3     manipulate the Serbs who are Bunjevci and the Serbs who are Sokci.  They

 4     are Catholic Serbs and we hope that soon their eyes will be also be

 5     opened and that they will realise what role the Vatican and the Ustasha

 6     want them to play against the Serbs."

 7             MS. BIERSAY:

 8        Q.   You heard Seselj mention that Croats were free to have their own

 9     state but west of the Karlobag-Ogulin-Karlovac-Virovitica line?

10        A.   Yes.

11        Q.   Had you heard that before?

12        A.   No.

13        Q.   Today is the first time you're hearing of this line from Seselj?

14        A.   Yes.

15        Q.   Ilija Celar never talked to you about that line?

16        A.   No.

17        Q.   He didn't tell you that it was discussed at the rally that he

18     attended?

19        A.   No.  Because there were lot of rallies and there were lots of

20     things being said.  That was before the war started and there were a lot

21     of meetings he went to.  I didn't -- we didn't talk about that.

22        Q.   So when Ilija Celar went to these meetings --

23        A.   Excuse me.  I don't know where that line is anyway.  I know where

24     Vinkovci is, but I don't know what line you're talking about.

25        Q.   Perhaps tomorrow I will bring a map so that can you see that it's

Page 10940

 1     west of Baranja.

 2        A.   Okay.

 3        Q.   How frequently would Ilija attend these meetings?  You said he

 4     was attending, if I understood correctly, all the time.

 5        A.   Well, I probably wasn't there when this happened.  What date was

 6     that meeting with Seselj exactly?

 7        Q.   This is in April of 1991.

 8        A.   Okay.  Well, then I was there then.

 9        Q.   Well, you said he told you about it?

10        A.   Yes, that was in 1991.  I knew there was a meeting in Jagodnjak

11     and Seselj was there.  But I left in -- around about June the 19th, I got

12     a flight.  Actually I flew from Zagreb, I think, to go to my father'

13     funeral and then I didn't come back until the October, so if there was

14     meetings, I was aware then when the fighting started but I wasn't aware

15     of how many meetings or what Ilija was doing during that time.

16        Q.   So there is a meeting -- it's P70.50 that describes also a

17     meeting in Beli Manastir around February 1991.  Did you hear -- do you

18     remember that one?  You would have been there then.

19        A.   No, in 1991 we would have been in Osijek.

20        Q.   You would have been in the --

21        A.   Yes --

22        Q.   -- country.

23        A.   -- In Osijek.

24        Q.   And if we can take a look, I believe.

25             If we could look at tab 3, Exhibit P70.50.  And according to the

Page 10941

 1     records I have, this is an article from February 1991.  Certainly in

 2     1991.  And I know that probably have trouble, and if we could go towards

 3     the middle.  If you go to the very middle where it says:  "One hour after

 4     the rally."

 5             Do you see that?

 6        A.   Yes.

 7        Q.   "So one hour after the rally" - and they're talking about a rally

 8     in another place - "protest was held in Beli Manastir also.  One of the

 9     speakers said that Baranja has never been Croatian and that it won't be

10     anymore and locals agreed with that."

11        A.   Yes, that was a general sentiment.

12        Q.   Are you aware that Goran Hadzic also made a distinction between

13     Croats that he claimed were put in Baranja by Pavelic?

14        A.   No.  I was under the impression that or what Ilija told me was

15     that Baranja was governed by -- Hungary during the Second World War and

16     wasn't part of the Republic of Croatia and that's -- was his basis for

17     saying that it's never been Croatian and very few Croats lived there

18     according to the censuses.  There were very few Croatians living in

19     Baranja.  There were mainly Serbs, Germans, Hungarians and Jewish people.

20     So, no, I'm not aware of -- I didn't know Mr. Hadzic and I've never heard

21     it.

22        Q.   You didn't know Mr. Hadzic --

23        A.   No.

24        Q.   In your statement, you said that you heard that he was a gentle

25     soul.  Where did you hear that from?

Page 10942

 1        A.   Well, that's what I heard from when people discussed.  Other

 2     women, they discussed various people that were in charge or -- I never

 3     quite knew who was in charge anyway.  They discussed people, and we gave

 4     our opinion about people, and -- and on one occasion Arkan came to visit,

 5     came there, into Baranja, after the war started and they said did I want

 6     to go and see him and I said -- I gave my opinion about him.  But they

 7     had different opinions about him.  They thought he was handsome, a bit

 8     like a pop star.  I said I think he's a criminal.  This is just what I

 9     said at the time.  So we expressed opinions about people.  Excuse me, the

10     exception to that is Borivoje Zivanovic.  I met him on several occasions,

11     because he was at the slava we went to, so I've actually met him.

12        Q.   And he worked sometimes, or actually a lot of time with

13     Ilija Celar?

14        A.   He didn't work with him.  Ilija was his interpreter and he called

15     him on occasions when he needed an interpreter, in his words, that he

16     could trust.  That knew the language enough and not pretended to know the

17     language.

18        Q.   After the war started, you say Arkan came to visit on one

19     occasion.  Do you recall when that was, was that in 1991 or in 1992?

20        A.   It must have been while the fighting was still going on because I

21     remember, that is, one of the wives was very upset, because she said

22     Arkan had implemented a new law for the front line and that the men were

23     there for ten days and got eight hours off to go home and get changed and

24     do something, chop wood for their wives or whatever.  And Arkan brought

25     in a sort of law that for every minute that the man was late back to the

Page 10943

 1     front line he got a day in jail.  And her husband had got 30 days in jail

 2     because he was 30 minutes late.  So he was resented.  That's all I know,

 3     apart from being asked if I wanted to go and look at him.  That's all I

 4     know about him.

 5        Q.   Where was he going to be if he was going to be looked at?

 6        A.   He was in the middle of Beli Manastir or somewhere.  I don't know

 7     where because I didn't go.

 8        Q.   Turning now to Exhibit P144, which is tab 4.

 9             And if we could go to page 2 in the English, please, to the very

10     top.

11             And this is an interview with Goran Hadzic, and I wanted to focus

12     on the section that starts:  "The Croats."

13             "The Croats, the native one, so-called Sokci, they are passive

14     too, Croats, Herzegovina men, Dalmatians, even Zagorje men, all of them

15     who settled after 1941, they are very dangerous, as they know that one of

16     our goals when we gain control is to return all Pavelic volunteers."

17             So were you familiar with the idea that those Croats who were

18     considered Pavelic volunteers would be returned, so to speak?

19        A.   I wasn't aware there was any distinction, and both me and my

20     husband were instrumental in ensuring that any Croats who wanted to stay

21     could stay and if we could possibly help them, if they were being

22     intimidated, we would try and get it stopped.

23        Q.   We'll get to that --

24        A.   It's not political about -- you know, I wasn't political.  I have

25     no idea what they were talking about, what they were saying.  I didn't

Page 10944

 1     take any -- I didn't take notice of Milosevic either.  I'm not a

 2     political person.  I'm not interested in politics and I never have been.

 3        Q.   I'd like to show you another document.  I believe it is tab 66.

 4     It's P2955.2913.

 5             And I -- this is an article, and I believe the date that has been

 6     given to it is September of 1991.  And I'd like to direct your attention

 7     to the bottom of the first page.

 8        A.   I wasn't there then.  I was in England.

 9        Q.   I understand.  And I'd like to read this section:  "People from

10     Herzegovina, Imotska region and Zagorje, who were however colonised in

11     our districts by Pavelic during the war will be given return tickets,

12     said Hadzic.  Further to the question, do you have problems with

13     colonised Serbs who are extremists?  Hadzic relied, no, we do not."

14             You would agree with me that the return and return ticket concept

15     here is the same as the one that I showed you right before this document?

16        A.   Yes.

17             MR. GOSNELL:  Objection, Mr.  President.  I don't think that's an

18     appropriate question for this witness.  It involves a combination of

19     speculation and conjecture and logical inference from the text in front

20     of her, but not anything she knows or witnessed or learned about.

21             MS. BIERSAY:  And that is exactly my point.

22             JUDGE DELVOIE:  Please proceed.

23             MS. BIERSAY:

24        Q.   You were a bit of a media sensation when you came back and you

25     were in Baranja because of the -- your testimony before parliament in

Page 10945

 1     1991 and also you gave some interviews; is that correct?

 2        A.   I was on Sky News, giving the situation as it was in Baranja.

 3        Q.   And locally I wanted to focus more on local journalists who

 4     were --

 5        A.   In Baranja?  Do you mean?

 6        Q.   Or they could come from other places?

 7        A.   Journalists didn't come there.

 8        Q.   Okay.

 9        A.   There wasn't a local newspaper operating.  I wasn't a sensation

10     in Baranja.  The only people that came to see me were a television crew

11     brought by an English man from Belgrade to make a documentary programme

12     about my living there.

13        Q.   Okay.  So I believe that will be tab 90.  It's 65 ter 6568.  And

14     I wanted to go to 1 hour, 26 minutes, and 33 seconds, to 1 hour, 27

15     minutes, and 11 seconds.

16                           [Prosecution counsel confer]

17             MS. BIERSAY:  Actually, for some context, let's begin at 1 hour,

18     24 minutes and 31 seconds.

19             THE INTERPRETER:  The interpreters have got it.

20                           [Video-clip played]

21             "THE INTERPRETER: [Voiceover] Although she has lived in

22     Beli Manastir for quite a while, the English woman from our next report

23     is more popular in the United Kingdom media than our own.  Why is this,

24     and what does she think about the Croatian army threatening to storm into

25     Baranja?  Vesna Ilic [phoen] has the report.  We have come to Baranja to

Page 10946

 1     Beli Manastir to meet Amanda Brook who is more popular in Great Britain

 2     than she is here.  Over there she delivers speeches in parliament and

 3     talks to television stations and newspapers in an effort to show the

 4     Serbian side of the current war.  It was love that brought her to Osijek

 5     from Coventry, five years ago.  She met Ilija Celar at a business meeting

 6     in Amsterdam and they have been together since.  She happened to be in

 7     Beli Manastir's basement when the town was liberated.  She was shocked

 8     with the fact ..."

 9             MS. BIERSAY:  Pause it right there she happened to --

10        Q.   First of all, is that the interview for the documentary that you

11     had --

12        A.   No, this is Serbian television.  I -- I don't remember this at

13     all.  But the man I greeted at the gate was the English man, he is

14     Serbian/English, he brought a film crew to make a film.

15        Q.   What is his name?

16        A.   Michael Stojsalovic [phoen].

17        Q.   And there, the journalist says she happened to be in

18     Beli Manastir's basement when the town was liberated?

19        A.   That's not true.  I wasn't there.  I was in England.  She also

20     says I appeared on numerous television programmes which is also untrue.

21     They weren't interested in me in England.  I mean, I was nobody really.

22        Q.   You were --

23        A.   I was on Sky News because Bika Reid [phoen] arranged for me to be

24     on Sky News.  Other than that, I wasn't --

25        Q.   Where do you think they got the information that you happened to

Page 10947

 1     be in Beli Manastir's basement --

 2        A.   I have absolutely no idea, because it's not true.

 3             MS. BIERSAY:  Could we continue.

 4                           [Video-clip played]

 5             "THE INTERPRETER: [Voiceover] The Serbian women were willing to

 6     commit group suicide rather than be captured by the Ustasha.  Yes, I

 7     joined the Serbian lobby because I was ashamed and still am ashamed of

 8     the British media bias.  I know I wouldn't be living with Serbs if they

 9     were capable of committing the atrocities they are being accused of.

10     They publicised some of it on television and in newspapers but now when I

11     wanted to speak about the Belgians, the foreign reporters are nowhere to

12     be seen.  I have spoken with the UNPROFOR commander, a Belgian man.  He

13     is openly anti-Serbian, as opposed to the Swedes, who are neutral.  We

14     come from old democracies, the Belgian man said.  I told him that Belgium

15     was 250 years old while the Serbian people had a tradition several

16     centuries long.  The latest attempts by Amanda Brook to inform the

17     British people about the tragedy taking place in Croatia was the case of

18     Franjo Sretkovic.  Franjo is a Croat who was abducted in Zagreb only for

19     being a Yugoslav, a Communist, and for being married to a Serb woman.

20     They beat them in Osijek the same way they beat the Serbs.  We, here,

21     asked to exchange him.  They let us have him for 6.000 German marks

22     Franjo and I have written to the Times and Sky News.  Franjo signed and

23     was willing to testify.  Nobody in Britain cared.  I feared the arrival

24     of the Croatian refugees because I believe Tudjman is capable of

25     sacrificing his own refugees as an excuse to attack us.  I know it is

Page 10948

 1     hard to leave your house but many of the local Croats were living in

 2     German-owned houses for being good Communists.  Those houses are

 3     currently inhabited by Serbian refugees.  If the army of the new

 4     democratic state of Croatia came, it would get rough.  I would leave

 5     Baranja together with the Serbian women.  Where would you live?  In

 6     Serbia.  In Belgrade?  I don't like cities.  I would definitely live in

 7     the countryside, in Serbia or in Montenegro."

 8             MS. BIERSAY:

 9        Q.   Mrs. Celar, in this interview, you also reference local Croats

10     being put in German owned houses for being good Communists?

11        A.   Well, I don't know why I said that.  I was trying to make the

12     point as I made in the British press, that opinion that when the British

13     press was saying -- it was -- it's hard to judge that without seeing what

14     I was responding to in the British press.  I had written a lot of letters

15     that weren't being published in the British press, and one of them was in

16     answer to them saying that the Croatians had been forced out of Baranja

17     and lost their homes and had lived there for centuries when in fact --

18     this is what I was responding to.  At least I think it was that.  That

19     Baranja was a very special area that people had -- had been transient

20     there.  Most people hadn't been there for 50 years.  They'd all been

21     brought in.

22        Q.   What was the point of making that distinction?  To drive home the

23     fact that Croats didn't belong there any way?

24        A.   I didn't say that that they didn't belong there.  I meant if you

25     took a Serbian perspective, that Croats had taken over other people's

Page 10949

 1     house and that somebody was now taking their house.  That is what I was

 2     talking about.  It was also a time of -- it tremendously stressful that

 3     time, very stressful that time.  I can see how tired I was in that.  That

 4     was done while the fighting was going on.  This took place, didn't it,

 5     sometime after -- I don't know the date.  But that is definitely at a

 6     time when -- before the mandate started.  When the fighting was

 7     happening.

 8        Q.   According to the information I have, this was around the time

 9     that there was talk about Croat refugees returning to the Baranja area.

10     So this was in September, around September of 1992.

11        A.   Well, there was still shelling, I think, when that happened, when

12     they did that.  I don't -- it was a very emotive moment.  Highly charged,

13     emotional.

14        Q.   I -- I notice -- or heard that you were giving the interview

15     in -- towards the end of 1992 in English.

16        A.   Yes.

17        Q.   But you were speaking to a Serbo-Croatian speaker.

18        A.   Yes.

19        Q.   Why didn't you -- you'd been there at that point, what, five --

20     five years.  Why didn't you speak Serbo-Croatian?

21        A.   I didn't, because it's very different -- it's one thing to

22     understand Serbian and speak Serbian but to give -- it's very hard to

23     give specific opinions in Serbian.  I've never had the language and still

24     don't have that core language when you can adequately express emotion.

25     It's still a basic -- well, I understand very well.  Expressing myself is

Page 10950

 1     another thing.

 2        Q.   In the time that we have left, I'd like to take a step back and

 3     talk about the departure from Osijek in 1991 --

 4        A.   Right --

 5        Q.   -- in April 1991 --

 6        A.   Yes.

 7        Q.   You describe leaving Osijek in paragraph 18, I believe, of your

 8     statement.  Now from what I understand, it was Ilija Celar who told you

 9     that you and he had to leave; is that right?

10        A.   Yes.

11        Q.   And he was the one who told you that the police or the HOS had

12     targeted him as a Serbian radical; right?

13        A.   Yes.

14        Q.   And he -- from your statement, it's not clear whether he believed

15     he was targeted for arrest or killing, so it sounds very muddled.  The

16     information --

17        A.   If you were targeted in Croatia in those times, you didn't make

18     the distinction about being arrested or being killed.  To be targeted was

19     frightening.

20        Q.   And who gave him this information?

21        A.   Well, it was actually a Croatian policeman that worked in the

22     police force in -- who we were friends with.

23        Q.   And what's the name of that person?

24        A.   I don't know his name.

25        Q.   You don't --

Page 10951

 1        A.   I never knew his name.

 2        Q.   You never knew his name?

 3        A.   No.

 4        Q.   And how do you know it was him?

 5        A.   Well, Ilija told me.  But he didn't tell me his name.

 6        Q.   So Ilija Celar said the Croatian policeman that I know told me

 7     that --

 8        A.   Rang me and told me this.  And then my neighbour, when I

 9     subsequently rang Mitzi, who now lives in America.  She's a Croatian.  As

10     I say, when I asked her to go and feed my cat the next day, she said she

11     couldn't get near our house because it was surrounded by black-shirted

12     men.

13        Q.   And in order to leave Osijek, you had time to organise a lorry?

14        A.   Yes.

15        Q.   What kind of lorry was it?

16        A.   Just with a -- quite a big lorry with a flap at the back.

17        Q.   And you were able to load your belongings onto this lorry?

18        A.   Yes.

19        Q.   And my question to you, Mrs. Celar, did you consider that you and

20     Ilija Celar were voluntarily choosing to leave Osijek in April 1991?

21        A.   Well, I would say that we left because we were frightened.

22        Q.   Okay.  Thank you.

23             MS. BIERSAY:  I have no further questions for today.

24             JUDGE DELVOIE:  Mr. Gosnell.

25             MR. GOSNELL:  Mr. President, just given the line of questioning,

Page 10952

 1     I wonder if I could request that Your Honour give a particularly clear

 2     instruction to this witness regarding contacts with others.  Just to make

 3     sure that there's no transgression of the requirements of the oath.

 4             JUDGE DELVOIE:  Thank you -- thank you, Mr. Gosnell.

 5             Madam Celar, the Court, now adjourned for the day, we will

 6     continue your examination tomorrow at 9.00, and what I need to tell you,

 7     and what Mr. Gosnell asked me to underline, is that you continue to be a

 8     witness, even out of court, as long as you are on the stand, which means

 9     that you cannot discuss your testimony with anyone, and you can't have

10     contact with either of the parties.

11             THE WITNESS:  I understand.

12             JUDGE DELVOIE:  Is that clear?  Thank you.

13             THE WITNESS:  Yes, I understand.

14             JUDGE DELVOIE:  Court adjourned.

15                           [The witness stands down]

16                           --- Whereupon the hearing adjourned at 1.59 p.m.,

17                           to be reconvened on Thursday, the 4th day of

18                           September, 2014, at 9.00 a.m.