Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11662

 1                           Monday, 22 September 2014

 2                           [Open session]

 3                           [The accused entered court]

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

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

 6     courtroom.

 7             Madam Registrar, could you call the case, please.

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

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

10             JUDGE DELVOIE:  Thank you.

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

12     Prosecution.

13             MS. CLANTON:  Good morning, Your Honours.  For the Prosecution,

14     Sarah Clanton, Douglas Stringer, Case Manager Thomas Laugel, and

15     legal intern Marina Marcikic.

16             JUDGE DELVOIE:  Thank you.

17             For the Defence, Mr. Zivanovic.

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

19     Goran Hadzic, Zoran Zivanovic and Christopher Gosnell, with

20     Jolana Makraiova, legal assistant.

21             JUDGE DELVOIE:  Thank you.  Is your next witness ready,

22     Mr. Gosnell?

23             MR. GOSNELL:  Good morning, Mr. President, Your Honours.  Yes,

24     indeed, she's ready.

25             The witness has some difficulties standing --


Page 11663

 1                           [Defence counsel confer]

 2             MR. GOSNELL:  I'm sorry, could I just ask for private session

 3     briefly, please.

 4             JUDGE DELVOIE:  Private session, please.

 5                           [Private session]

 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                           [Open session]

19             THE REGISTRAR:  We're in open session, Your Honours.

20             JUDGE DELVOIE:  Okay.  And the witness may be brought in.

21                           [The witness entered court]

22             JUDGE DELVOIE:  You may be seated, madam.

23             THE WITNESS: [Interpretation] Is it all right?

24             JUDGE DELVOIE: [Microphone not activated] You may be seated,

25     madam.


Page 11664

 1             THE WITNESS: [Interpretation] Thank you.

 2             Should I get closer or further?

 3             JUDGE DELVOIE:  Good morning, Madam Witness.  Thank you for

 4     coming to The Hague to assist the Tribunal.

 5             First of all, can you hear me in a language you understand?

 6             THE WITNESS: [Interpretation] Yes.

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

 8     of birth.

 9             THE WITNESS: [Interpretation] Karmen Brlic-Jovanovic.  13th of

10     July, 1948.

11             JUDGE DELVOIE:  Mrs. Brlic, you are about to read the solemn

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

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

14     to make does expose you to the penalties of perjury, should you give

15     misleading or untruthful information to this Tribunal.

16             Please read the solemn declaration the court usher will give to

17     you.

18             THE WITNESS: [Interpretation] Should I stand?  I don't have to?

19             JUDGE DELVOIE:  No, you don't have to.

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

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

22                           WITNESS:  KARMEN BRLIC-JOVANOVIC

23                           [Witness answered through interpreter]

24             JUDGE DELVOIE:  Thank you, ma'am.

25             Mr. Gosnell.


Page 11665

 1             MR. GOSNELL:  Thank you -- thank you very much.  Mr. President.

 2                           Examination by Mr. Gosnell:

 3        Q.   Good morning, Mrs. Brlic-Jovanovic.

 4        A.   Good morning.

 5             MR. GOSNELL:  May we please have 1D1167 on the screen, which is

 6     Defence tab 3.  And, Mr. President, I have a hard copy for the witness

 7     and for Your Honours, if I wish.

 8             JUDGE DELVOIE:  Thank you.

 9        Q.   Mrs. Brlic-Jovanovic, do you recognise that document in front of

10     you?

11        A.   Yes.

12        Q.   And what is it?

13        A.   The witness statement which I gave last year to

14     Madam Aleksandra Andric and it was certified by a public notary.

15        Q.   Are you familiar with its content?

16        A.   Yes.

17        Q.   And did you read it before you signed it in its entirety?

18        A.   Yes.

19        Q.   Does it accurately reflect what you said when you gave this

20     statement?

21        A.   Yes.

22        Q.   Would you answer the questions that you were asked the same way

23     again, if you were asked those same questions here today?

24        A.   Yes.

25             MR. GOSNELL:  May I tender, Mr. President, 1D1167 for admission,

Page 11666

 1     along with associated exhibits 1D455 and 1D456.

 2             JUDGE DELVOIE:  Admitted and marked.

 3             THE REGISTRAR:  Your Honour, the statement will become

 4     Exhibit D200.

 5             The associate exhibits will be given Exhibit Numbers D201.200,

 6     and D202.200.  Thank you.

 7             JUDGE DELVOIE:  Thank you.

 8             MR. GOSNELL:

 9        Q.   Mrs. Brlic-Jovanovic, you worked as a journalist at Radio Vukovar

10     before the outbreak of hostilities --

11        A.   Yes.

12        Q.   -- in Croatia; is that right?

13        A.   Yes.

14        Q.   And just so you know there interpreters around the room and a

15     court reporter who is taking down everything that is said and they

16     require that there be a pause between the end of my question and the

17     beginning of your answer so that everything is recorded accurately.

18             At the very last sentence of your statement, which is

19     paragraph 4, you say:

20             "The witness," so that's you, "remembers that love poems and

21     interviews with Branko Kovacevic, a poet from Pacetin who was a doctor,

22     were broadcast on Radio Vukovar and published in Vukovarske Novine."

23             Can you tell us who conducted those interviews that you referred

24     to here with Dr. Kovacevic on the radio?

25        A.   I did.

Page 11667

 1        Q.   And can you tell us how many times you interviewed Dr. Kovacevic

 2     on the radio, approximately?

 3        A.   Several times but not too many.

 4        Q.   And what was the content of those interviews?  What was said by

 5     him; what was asked by you.

 6        A.   What he wrote about, how he felt about publication of his work as

 7     a young author that he was, whether he wanted to continue doing so as he

 8     was a medical rather than a literary expert, and he was full of verve and

 9     intended to keep on doing that forever because that was what he liked.

10     Alongside his regular job as a doctor.

11        Q.   Had his poetry been published in some form?

12        A.   Yes.  I remember one book from early on, and then, later on, I --

13     I didn't really follow it that much.

14        Q.   Was any of his poetry recited during these interviews?

15        A.   At literary evenings.

16        Q.   But during the broadcasts themselves, leaving aside the literary

17     evenings, was any of his poetry spoken, read, or recited?

18        A.   Yes, as something that followed upon the information that I gave

19     about those events.  But he had to do it himself.

20             MR. GOSNELL:  May we have, please, 1D331, which is Defence

21     tab 15.

22        Q.   And while that's coming up, perhaps I could ask you:  How well

23     known was Dr. Kovacevic as a poet in eastern Croatia, let's say?

24        A.   Well, in the beginning, thanks precisely to me, because I wanted

25     to encourage the young people and to present them to the public, such was

Page 11668

 1     also the case with Zoran Calic who is now a recognised man of letters,

 2     whose books are reviewed in many languages.  He's recognised all over the

 3     world, and the reviews are written by renowned men of letters from

 4     various countries.

 5             My intention was always to assist someone who wanted to do

 6     something good.  I wanted to help them to move on up as much as they

 7     could, and I believed that this was something that really deserved

 8     attention.

 9             MR. GOSNELL:  May we zoom in just a little bit in this photograph

10     on the screen.

11             THE WITNESS: [Interpretation] Now it's been reduced in size.

12             MR. GOSNELL:

13        Q.   Now, looking at this photograph, do you recognise the gentleman

14     in the white suit?

15        A.   To me it looks like Branko Kovacevic.  And when this was taken

16     and how fatter he got and how much he changed, I wouldn't know.

17             MR. GOSNELL:  May I tender this document, Mr. President, 1D331.

18             JUDGE DELVOIE:  Admitted and marked.

19             THE REGISTRAR:  Exhibit D203, Your Honours.

20             MR. GOSNELL:

21        Q.   Now at paragraph 4 of your statement, you say:

22             "I had not known Goran Hadzic before I invited representatives of

23     political parties to a confrontation in a radio programme which took

24     place after Easter 1991 and the incidents at Plitvice."

25             Did you interview Mr. Hadzic on that occasion that you referred

Page 11669

 1     to in your statement?

 2        A.   Yes.  Him as well as other prominent leaders of some political

 3     parties that were active in Vukovar at the time.

 4        Q.   And leaving aside the others, can you tell us what political

 5     views Mr. Hadzic expressed to you on this occasion or expressed in

 6     general on this occasion.

 7        A.   He was in favour of compromise, agreement.  He did not oppose

 8     anything that others would say.  He was not too pushy, he did not impose

 9     his opinion on others in order to achieve anything that others would have

10     to follow.

11        Q.   Did he say anything about how to resolve the ethnic tensions that

12     were rising during this period of time?

13        A.   Firstly to remove the weapons which instilled fear in people.

14             Secondly, to place under control the individuals who acted

15     inappropriately, inappropriately to a civilised environment.

16        Q.   Thank you, Mrs. Brlic-Jovanovic.  I'd now like to move to a new

17     subject, and I will not be asking you about the period during which

18     Vukovar was under siege and you were there.  I will not be asking you

19     about that.  But I would like to ask you about when it was that you came

20     to leave Vukovar for the first time as the fighting subsided.

21             Can you tell us about that, please.

22        A.   While the combat operations lasted, my immediate family - that is

23     to say, my husband, my son, my brother-in-law - together with more than

24     100 civilians, were evacuated to the first line of combat activities by

25     the Belgrade Guards Brigade on the 12th of November, 1991.  That was when

Page 11670

 1     we were taken in some vans to a collection point at Velepromet.  That was

 2     around noon.

 3             We were given accommodation.  I have to say it was sad and awful

 4     but that was the only possible thing at the time.  We were given sacks of

 5     rice and pallets to sleep on.  Outside fighting was still going on, and

 6     it was dangerous.  That was before the fall of Vukovar.

 7        Q.   And then how and when did you come to leave Velepromet?

 8        A.   As far as we were concerned, the first time to leave was on the

 9     14th, when lists were made of people who were leaving and where they

10     would be leaving.  Transportation in buses was organised, and the bus was

11     driven by Djuro Filipovic.  He was wearing a military uniform.  He took

12     care both of the list-making and he also confirmed that the persons from

13     the list were, indeed, on the bus.  He would do that at every check-point

14     all the way to Sid.

15        Q.   After you arrived in Sid, when was the first time after that that

16     you returned to Vukovar?

17        A.   On the 16th of November.  Because there was a report from the

18     police station in Sid that the army had moved my mother-in-law and that

19     the father had remained in Vukovar.  During our stay in the big cellar -

20     not in Velepromet but in the cellar, in the basement - at

21     Pavle Radisavljevic's place, we were separated from my father-in-law and

22     mother-in-law.  They had stayed on in their ruin of a house because my

23     father-in-law was practically about to die.  He had wounds, an injury, he

24     was bleeding, and he could not be helped at the time in any way

25     whatsoever.

Page 11671

 1             My mother-in-law told him that he had died but that her request

 2     that he be buried could not be met because of the fighting that was

 3     ongoing.  It was on the 15th that she told us that.  And then she

 4     commanded us to go and fetch him on the 16th and either bury him or buy a

 5     coffin in Sid and then bring him over to Sid.  That was the way she saw

 6     it.

 7             So in Sid, we went close to the fair-ground where there was an

 8     official office at which one had to ask for a pass allowing a person to

 9     leave Sid and go to Vukovar, as combat operations were still ongoing in

10     that area.  We got the pass.  He -- they were asking who was going and we

11     said that it was us, so we got the pass with our own names on it with the

12     stamps and signatures of the officers who were on duty at the time.  They

13     all wore uniforms, the JNA uniforms.  And military police was standing in

14     the room.

15             We then looked around to see who would take us to Vukovar --

16        Q.   May I just interrupt you there for one --

17        A.   The traffic --

18        Q.   -- for one moment, Mrs. Brlic-Jovanovic, and ask for a

19     clarification.  You say that --

20        A.   Yes, go ahead.

21        Q.   -- the military police were standing in the room.  Was it the

22     military police that signed or stamped the pass?

23        A.   No, no.  There was a man sitting at the desk who was on duty and

24     the military police were there to provide our security.  Everything was

25     under rather strict control.  At least that's the way I saw it.

Page 11672

 1        Q.   And was the man sitting at the desk wearing a JNA uniform?

 2        A.   Yes.

 3             MR. GOSNELL:  May we have 1D3735, please, which is Defence

 4     tab 11.

 5             MS. CLANTON:  Excuse me, Mr. President.

 6             JUDGE DELVOIE:  I'm sorry, Ms. Clanton.

 7             MS. CLANTON:  I rise to note that these materials are not on the

 8     Defence 65 ter list.  They are part of the pending third motion for leave

 9     to amend filed by the Defence.  Our response is due today so it has not

10     yet been filed before Your Honours, but to note that we do object to the

11     use of this document and, I believe, five other documents provided by the

12     witness on the basis that they were not timely disclosed to the

13     Prosecution.  They were in the possession of the Defence for six weeks

14     before we were provided with them, and it is not evident from the

15     65 ter summary or the 92 ter statement how they relate to her evidence.

16             JUDGE DELVOIE:  Mr. Gosnell.

17             MR. GOSNELL:  Well, first of all, Mr. President, there's no

18     obligation to disclose documents as soon as they come into the hands of

19     the Defence.  There is no such obligation, so we didn't have an

20     obligation to immediately disclose the documents.

21             Now having said that, of course, we have an obligation to -- when

22     we ask for an amendment of our 65 ter exhibit list, to ensure that we

23     diligently and in a timely way provide those documents and that there is

24     no prejudice to the Prosecution.  Those are the two standards.

25             And I can tell Your Honours that we requested that those

Page 11673

 1     documents be translated on the 4th of August, 2014, and we only did get a

 2     translation back on the 2nd of September.  Now, it is true that that's

 3     too long, and somewhere during that time-period we realised that these

 4     documents had not been prioritised for translation and we asked that they

 5     be prioritised.  And my understanding is that they were disclosed on or

 6     shortly after the date of the translation, namely, the 2nd of September.

 7     And then Your Honours will know that then the motion was filed, the

 8     65 ter exhibit list motion, was then filed on the 5th of September, 2014,

 9     so that's about 17 days ago.  And each of the four travel passes that I

10     propose to use are less than a page long or one page -- a page, two sides

11     but very little text.

12             I would also say, Your Honours, that it was not certain that we

13     would be moving to have these documents added to our 65 ter exhibit list

14     through the month of August, and until we'd made certain decisions about

15     calling this particular witness and about which documents to use.  So

16     that also was a reason for not having disclosed the document at the

17     very -- at the beginning of August.  And I do wish that we had been able

18     to disclose it at the beginning of August but that didn't occur.

19             In any event, there's been more than ample time now for the

20     Prosecution to digest these documents.

21             Now as to whether or not it's covered by the summary, the summary

22     says that the witness will -- perhaps the witness should remove her

23     headphones for this.

24             JUDGE DELVOIE:  Yeah, that's the question, of course, before --

25     before she removes her headphone or even without.

Page 11674

 1             Mrs. Brlic, do you understand English?  Obviously not.

 2             Madam Brlic, do you understand English?

 3             THE WITNESS: [Interpretation] No.  A little.  Very, very little.

 4     Things that pertain to new modern technology, but that's all.

 5             JUDGE DELVOIE:  Okay.  May I then now ask you to remove your

 6     headphones.  Thank you.

 7             Yes, Mr. Gosnell.

 8             MR. GOSNELL:  The witness summary says that she will recall her

 9     experience taking refuge in a shelter for extended periods during the

10     fighting around Vukovar in October and November 1991, her departure from

11     Vukovar around 16 November 1991, and her return about eight days later.

12     And then it continues and I won't go into what's described next.

13             Now, as for the 65 ter exhibit list motion that was filed on the

14     5th of September, it says as follows at paragraph 8:

15             "The witness supplied the Defence on 28 July 2014 with six

16     original travel documents issued by the JNA in 1991 related to herself

17     and her husband."

18             And I must interrupt here, myself, to say that that's a mistake.

19     It's only four travel documents that we're dealing with and two documents

20     of another provenance.

21             And then it says:

22             "Those documents were promptly sent for translation and are

23     sought for addition now that the translations for most of the documents

24     have been received.  The documents' authorisation issued by military

25     authorities for the witness to reside in the conflict zone are

Page 11675

 1     demonstrative of the JNA's overarching authority over civilian movement

 2     and civilian matters."

 3             So there clearly there's notice of why we want to use these

 4     documents and how they relate to the witness's testimony.  And then

 5     finally on Saturday night, unfortunately, it was between 8.00 and 9.00,

 6     there was further precision on the dates of the witness's travel which

 7     should have been indicated by reviewing the documents itself, albeit it

 8     does not correspond precisely to the dates mentioned in the witness

 9     summary.

10             So taking all that, Your Honours, I suggest there's clear notice,

11     no prejudice, ample time to prepare, and we should be permitted to add

12     these documents to our 65 ter list and proceed now with questions in

13     relation thereto.

14             JUDGE DELVOIE:  Ms. Clanton.

15             MS. CLANTON:  Yes, Mr. President, just to briefly respond to a

16     few of counsel's points.  As he indicated, by looking at the 65 ter

17     summary, what it says is that she will discuss her departure and her

18     return.  It does not give any mention of the authorities, of an office in

19     Sid, of the role of the JNA or the military police.

20             And also to respond to the point about what was provided on

21     Saturday evening between 8.00 and 9.00 p.m., what we have received is a

22     handwritten document in B/C/S.  There's no translation provided, and it

23     refers to paragraph 4 of the proofing note which says that the witness

24     wrote a chronology of her movements back and forth between Sid and

25     Vukovar between the 12th and the 26th of November, 1991.  It does not

Page 11676

 1     indicate what specifically is written in this B/C/S handwritten

 2     chronology.  So the Prosecution is not able, between 9.00 p.m. on

 3     Saturday and 9.00 a.m. on Sunday, to have conducted any investigation or

 4     even to have had an adequate translation of the material that was

 5     provided by the Defence, and that is why we say that these materials

 6     should not be added as there is a prejudice to the Prosecution.

 7                           [Trial Chamber confers]

 8             JUDGE DELVOIE:  Mr. Gosnell, this is about five documents.  Am I

 9     right?  Five documents to be added to your 65 ter list.

10             MR. GOSNELL:  There are six proposed.  I would -- the ones that

11     we've been talking about now encompass four.  There's a fifth which

12     involves different issues and the sixth I won't be using, Mr. President.

13             JUDGE DELVOIE:  Okay.  So about these four.  Is the handwritten

14     B/C/S document Ms. Clanton referred to, is that included in those four?

15             MR. GOSNELL:  No, Mr. President.  And just to be clear about

16     that, that document was produced by the witness on Saturday night in my

17     presence, and I deemed it necessary and appropriate under the Rules to

18     disclose any prior statement of the witness.  So it was disclosed to the

19     Prosecution.

20             JUDGE DELVOIE:  Okay.

21             MR. GOSNELL:  And theres no intent to use it at all.

22             MS. CLANTON:  Mr. President, what I understand from counsel's

23     previous submissions, though, was that the materials that we're

24     discussing, the four permits, that those can be understood in light of

25     the information that the witness provided on Saturday in this note.  And

Page 11677

 1     our point is that we cannot be expected to be on notice or to have had an

 2     opportunity to consider the four documents that are at issue in light of

 3     this information given that we aren't able to read it.

 4                           [Trial Chamber confers]

 5             JUDGE DELVOIE:  The objection is overruled.  The four documents

 6     can be added to the 65 ter list.

 7             Please proceed, Mr. Gosnell.

 8             MR. GOSNELL:  Thank you kindly, Mr. President.

 9             May we then have 1D3735, which is Defence tab 11.

10        Q.   Now, Mrs. Brlic-Jovanovic --

11             MR. GOSNELL:  Oh, I'm sorry, the witness doesn't have her

12     headphones on.

13        Q.   Mrs. Brlic-Jovanovic, if you look at the screen in front of you,

14     on the left side, is that the document that you have just described

15     having received on the 16th of November in Sid?

16        A.   Yes.

17        Q.   And you were about to continue --

18             MR. GOSNELL:  Mr. President, I would tender this document,

19     please.

20             JUDGE DELVOIE:  Admitted and marked.

21             THE REGISTRAR:  Exhibit D204, Your Honours.

22             MR. GOSNELL:

23        Q.   And Mrs. Brlic-Jovanovic, you were, before I interrupted you,

24     about to describe how you travelled back to Vukovar.  How did you travel

25     back to Vukovar?

Page 11678

 1        A.   There was no civilian transportation, and you couldn't go on foot

 2     either.  If you had a pass and only then could you be transported in a

 3     military vehicle.  That was the only option.  And that vehicle would be

 4     stopped at every check-point all the way to Vukovar, and then had you to

 5     show your pass again.

 6        Q.   And leaving aside the details of what you did in Vukovar when you

 7     returned on the 16th, can you tell us when you left Vukovar next?

 8        A.   We didn't manage to carry out the task that we had been given by

 9     my mother-in-law and that was either to bury or to find the body and

10     bring it back.  We did not have a reason to linger on.  A jeep took us

11     back, kindly, initially to take us to Sid.  However, the curfew was in

12     place and we were stopped in Negoslavci.  That's where we spent the night

13     with the Ore family, the family of Petar Ore.

14             The following morning, we found transport in an APC or some such

15     vehicle, and we returned to Sid.  We stayed there, but before that, I

16     have to add something that I failed to mention.  When we arrived in Sid

17     we were accommodated in Adasevci.  We stayed with my husband's family.

18     So when we returned to Sid, we spent several days in Adasevci.  And then

19     my mother-in-law insisted that we should go back again and, at all cost,

20     try to find the body of her late husband.

21        Q.   And when did you go back to Vukovar the next time, as best you

22     can recall?

23        A.   There was a lot of family pressure for a few days.  And then, on

24     the 24th, we decided to go back to Vukovar.  We had to undergo the same

25     procedure, i.e., we had to be provided with a pass, but on that occasion,

Page 11679

 1     it was just my husband and I who went there.

 2        Q.   [Previous translation continues] ...

 3        A.   And again the procedure was the same.  The route we took was the

 4     same as the first time round.  Again, we were taken to Velepromet because

 5     that was our only official address that we had at that time.  You

 6     couldn't enter the city.  We could not reach our houses at all because

 7     there were services that monitored the situation and looked after the

 8     safety of civilians.  And they told us that our neighbourhood was not at

 9     all accessible.

10             And then my husband insisted with the military to provide their

11     own men who would --

12        Q.   May I just, Mrs. Brlic-Jovanovic, stop you there for a moment.

13             MR. GOSNELL:  And ask that 1D3728, please, which is Defence

14     tab 8, be brought up.

15        Q.   Now, was that document on the left side of the screen the

16     document that you received on the 24th in Sid to be able to return to

17     Vukovar?

18        A.   Yes.

19             MR. GOSNELL:  May I tender this document, Mr. President.

20             JUDGE DELVOIE:  Admitted and marked.

21             THE REGISTRAR:  Exhibit D205, Your Honours.

22             MR. GOSNELL:

23        Q.   Do I understand correctly that it was the 24th itself, in other

24     words, the same day that you received the pass, when you travelled to

25     Vukovar from Sid?

Page 11680

 1        A.   Everything had to be done right away because there was nowhere

 2     for us to stay.

 3        Q.   And then on this journey which commenced on the 24th, how many

 4     days did you spend in Vukovar before you left again?

 5        A.   We asked for assistance.  Actually, my husband asked for

 6     assistance from the military.  However, when he left together with

 7     several soldiers, we were told that in cases like that, when a house was

 8     so badly burnt, no human remains are left behind.

 9        Q.   And -- and when was it after these activities, if at all, when

10     was it that you left Vukovar?

11        A.   I really can't be sure, but I believe that we returned ... and

12     then we talked to my mother-in-law and tried yet again to do something on

13     our own.

14        Q.   Was there a subsequent occasion when you sought permission to

15     travel back to Vukovar from Sid?

16        A.   We had to.  Every time.  I went to the same office as a matter of

17     course.  The procedure was always the same.

18             MR. GOSNELL:  May we have, please, 1D3729, Defence tab 9.

19        Q.   This is a permit for temporary residence in the zone of combat

20     operations, and the date is the 26th of November, 1991.  The name listed

21     is Radoslav Jovanovic.  Who is that, Radoslav Jovanovic?

22        A.   My husband.  Now he is my late husband.

23        Q.   And do you remember having received this particular document?

24        A.   Yes.

25             MR. GOSNELL:  I tender this document, Mr. President.

Page 11681

 1             JUDGE DELVOIE:  Admitted and marked.

 2             THE REGISTRAR:  Exhibit D206, Your Honours.

 3             JUDGE DELVOIE:  Thank you.

 4             MR. GOSNELL:  May we have 1D3730, please.

 5        Q.   This is, again, a permit for temporary residence in the zone of

 6     combat operations dated 21 December 1991.  Mrs. Brlic-Jovanovic, do you

 7     remember having received this document at around this time?

 8        A.   Yes.  Because we intended to decide where we would live, and we

 9     wanted to go back to Vukovar at any cost.  So we went to learn how that

10     is to be done, because we had no house any longer, we had no food, we had

11     no clothes, but we wanted all that to be resolved in some way or another

12     in our territory.

13        Q.   And was this document issued in the same way and by the same

14     people as you've described in respect of the previous documents?

15        A.   It was issued in the same way, but the location where it was

16     issued was different.  It was no longer the office near the fair-ground

17     but an area in the park.  It was a nice hunting lodge that I suppose

18     belonged to the hunters and the hunters' association from the area.

19             Everything else was still as strict as before.

20        Q.   And the individuals who were at that office, were they the same

21     individuals who had been involved in issuing the previous passes?  Not

22     necessarily the same people but the same description in terms of uniforms

23     and so forth.

24        A.   Absolutely so.  Yes.

25        Q.   And did you, in fact, travel back to Vukovar at around this time;

Page 11682

 1     namely, the date of this document, being the 21st of December, 1991.

 2        A.   Yes.

 3             MR. GOSNELL:  May I tender this document, Mr. President.

 4             JUDGE DELVOIE:  Admitted and marked.

 5             THE REGISTRAR:  Exhibit D207, Your Honours.

 6             JUDGE DELVOIE:  Thank you.

 7             MR. GOSNELL:

 8        Q.   And where did you stay on this occasion when you went back in

 9     December?

10        A.   At the relatives, at my husband's cousin who had returned a day

11     or two before us.  He had returned to his own house which was damaged,

12     but one could use it to spend a night.  There were mattresses on the

13     windows which were no longer in place.  We received some food from the

14     Red Cross.  We slept on the floor.  It was cold and uncomfortable.

15     Terrible, really.  There was no water to be had at all, nor any

16     electricity.  So we kept close together in the same room.

17             And, on the following day, we went around to look if there were

18     any offices there where they would decide what they were going to do with

19     us.  One couldn't walk around the town.  You had to hear from someone who

20     is closest to you where he had gone, so you would go there too.  So that

21     was what we did.  And everything was all right.

22        Q.   Did you at some point seek to find, with your husband, some

23     accommodation where you could stay yourself?

24        A.   We, ourselves, actually didn't.  We waited for others to solve

25     that for us.  The houses where the fighting hadn't been so bad or had

Page 11683

 1     stopped earlier had already all been full of people who had moved in.

 2     And for us who were late, there was nothing good where we could move in.

 3     So we waited for them to tell us:  You can try here, or you can try

 4     there.  And then we would see what we would do.

 5        Q.   And where did you end up after this process of searching?

 6        A.   First we stayed at that cousin's place during all these days.

 7     Together with him and his wife, we would go to the Red Cross to get some

 8     clothes and the first rations.  That was the food, flour, oil, soap for

 9     doing the washing, some canned food.

10             When we left for Vukovar, we managed to persuade our relatives

11     that if it was fine for us, that they should return as well.  So then my

12     brother-in-law went to find something for himself and his mother, and he

13     got some sort of certificate saying that he could clean an area, because

14     we wanted everything to be close rather than to be scattered all over,

15     because the situation was really awful.  He managed to get a house that

16     was whole on the outside and, on the inside, it was only the lower ground

17     floor that could be used 70 or 80 per cent.  The windows had to be closed

18     with rags and so on.

19        Q.   If I can just interrupt you, Mrs. Brlic-Jovanovic.  Am I

20     understanding that this is the house that you ended up living in, staying

21     in?

22        A.   Yes.

23        Q.   And was some form of authorisation required for you to be there?

24     In that particular house.

25        A.   There was an authorisation about that particular house which was

Page 11684

 1     issued to my brother-in-law, to his name, and he had requested it.

 2             I have to note that during the days that followed, on several

 3     occasions military patrols had come unannounced.  One could call them

 4     that because they were all uniformed.  I was particularly unhappy about

 5     that because I was afraid.  I didn't know and didn't understand why they

 6     would care about this, but they tried to calm me down, they told me not

 7     worry and that they said that those who were in town at the time were

 8     doing this, that we should not be afraid for our own security, that we

 9     could keep the door unlocked.  And, actually, it was not even possible to

10     lock them because there were no locks and very often there were no doors

11     at all.

12             In that building, even the toilet on the floor was half-ruined

13     and there was no outer wall, but it was standing and it was some sort of

14     roof over our heads.

15             MR. GOSNELL:  May we have, please, 1D3736, Defence tab 12.

16        Q.   Can you tell us your brother-in-law's name?

17        A.   Milovan Jovanovic.

18        Q.   And this is a document which at the top left says:

19     "Serbian District of Slavonia, Baranja, and Western Srem."

20             It's entitled:

21             "Certificate.  This is certify that Milovan, son of Veljko, has

22     been duly reported to this service and is properly recorded.  We hereby

23     request that the apartment at Preradoviceva 2 be cleared and cleaned

24     without hindrance until the final decision of the commission."

25             Do you remember this, your brother-in-law receiving this document

Page 11685

 1     or having this document?

 2        A.   Yes.  And he was very proud of having managed to take care and

 3     having provided a place where we could all find accommodation and live.

 4     He, as the younger brother, had managed to provide for his family.

 5        Q.   And did you yourself subsequently move out of Milovan's house and

 6     go somewhere else to stay?

 7        A.   This was the sort of accommodation that wasn't adequate even for

 8     two persons, let alone more than that.  People of different ages, the

 9     elderly mother, myself, there was no room for beds or anything, and the

10     roof leaked so that in bad weather I would spend all day on the steps

11     trying to squeeze water out of various cloths because there was no roof.

12     It was a two-storey house, and so I tried to keep it dry so that we could

13     stay downstairs with a candle and we had a small stove which we used for

14     heating.

15        Q.   Yes, Mrs. Brlic-Jovanovic, if I could just take you back, please,

16     to my question, which was whether you at some stage moved out of

17     Milovan's house and went to stay in a different house.

18        A.   Yes.

19        Q.   And you can just tell us yes or no to that question --

20        A.   Yes, yes.  Yes, yes.  Yes, yes, yes.

21        Q.   And did you or your husband receive a document similar to this

22     one in respect of the accommodation you moved into?

23        A.   It was the same document.  My husband and his brother went to

24     obtain it.  I didn't go, so I have no idea where the service that was in

25     charge of resolving such issues may have been located.

Page 11686

 1        Q.   And did you understand that this document, which is called a

 2     certificate, entitled you to live in that house permanently?

 3        A.   No, no.  Not at all.  It was clear to everyone that that was a

 4     temporary solution, regardless of even what some sort of commission may

 5     have decided.  I believe that private property is inviolable.  I still

 6     consider it such to this day and I don't think I will ever change my mind

 7     about that.

 8             MR. GOSNELL:  May I tender this document, Mr. President, 1D3736.

 9             JUDGE DELVOIE:  Which, Mr. Gosnell, is not one of the four -- is

10     it one of the four?

11             MR. GOSNELL:  You are absolutely correct, Mr. President.  I

12     apologise.  I would seek leave to add this to the 65 ter list.  It is one

13     of the documents that is the object of our motion of the 5th of

14     September, 2014.

15             JUDGE DELVOIE:  Yes, Ms. Clanton.

16             MS. CLANTON:  Yes, Your Honours, we don't object to the document

17     being added at this time, in light of Your Honours' previous ruling.

18             JUDGE DELVOIE:  The document is admitted to the 65 ter list and

19     marked.

20             THE REGISTRAR:  As Exhibit D208.  Thank you.

21             JUDGE DELVOIE:  Thank you.

22             MR. GOSNELL:  No further questions at this time, Mr. President.

23             JUDGE DELVOIE:  Thank you, Mr. Gosnell.

24             Are you ready, Ms. Clanton?

25             MS. CLANTON:  Yes, thank you, Your Honour.


Page 11687

 1             JUDGE DELVOIE:  Please go ahead.

 2                           Cross-examination by Ms. Clanton:

 3        Q.   Good morning, Mrs. Brlic-Jovanovic.

 4        A.   Good morning.

 5        Q.   My name is Sarah Clanton, and today I will be asking you some

 6     questions on behalf of the Office of the Prosecutor.  If at any time my

 7     question is confusing or complex, please feel free to ask me to clarify.

 8             Now, the first thing that I want to ask you about today has to do

 9     with your background.  I saw from your statement that you went to school

10     in Vukovar and that you also lived in Vukovar at that time; is that

11     correct?

12        A.   Yes.

13        Q.   And also that you were a journalist at Radio Vukovar since 1972;

14     is that correct?

15        A.   Yes, from the 2nd of June that year.

16        Q.   And it says in your statement that you were born in Osijek.  Can

17     you tell me when it was you moved to Vukovar?

18        A.   Yes.  Before I was to be born, my father was sent to the Varazdin

19     museum by a decree and I was supposed to be born there.  However, my

20     mother's relatives had a house and were living in Osijek so my mother

21     went to her family to give birth there, and then she was to return to

22     Varazdin.  After Varazdin, when I was around one year old my father was

23     transferred to Bjelovar to take charge of the museum there.  After that,

24     by a decision on the founding of the museum in Vukovar, at the initiative

25     of Dr. Antun Bauer, Antun Bauer, my father was appointed as the director

Page 11688

 1     of the town museum in Vukovar in the 1950s.  And so Mom and I also moved

 2     there.

 3             Since then, I have lived continually in Vukovar.  And all my

 4     years of service, all my years of employment, were at Radio Vukovar and

 5     Vukovarske Novine.  That is to say, the Vukovar newspaper, which had a

 6     single editorial office up until the events of 1991.

 7        Q.   Thank you.  And you referred earlier today to your late husband

 8     whose name was Radoslav Jovanovic.  Where was your husband from, what

 9     town?

10        A.   My husband was born in Vukovar.  He never went anywhere.  He had

11     always lived in Vukovar.  We attended high school together.  We were

12     classmates.  Later on, he studied agriculture in Osijek, and his

13     speciality was mechanization in agriculture.  And he then got a job at

14     Vupik.

15        Q.   Mrs. Brlic-Jovanovic, I believe you've said earlier that there

16     was some sort of a family home that was in Sid.  Was this a home of your

17     husband's family or your family?

18             JUDGE DELVOIE:  Mr. Gosnell.

19             MR. GOSNELL:  Sorry, the witness --

20             THE WITNESS: [Interpretation] Not in Sid but in Adasevci, near

21     Sid.

22             MR. GOSNELL:  That dealt with my objection, Mr.  President.

23             JUDGE DELVOIE:  Okay.

24             MS. CLANTON:

25        Q.   And if I could clarify, ma'am, is this a home in Adasevci, near

Page 11689

 1     Sid, that was in your husband's family?

 2        A.   Adasevci.  All right.

 3        Q.   Is it correct that this was a home related to your husband's

 4     family?

 5        A.   It's perhaps 4 or 5 kilometres away from Sid.  It's a huge

 6     village.  And that was what my husband's mother - that is to say, my

 7     mother-in-law - inherited from her grandparents.  She had married in

 8     Vukovar too, and her cousin -- her younger brother, actually, remained

 9     living at the family estate.

10        Q.   And was your husband of Serbian ethnicity?

11        A.   Yes.

12        Q.   And I see from the first page of your statement that you are of

13     Croatian ethnicity; is that correct?

14        A.   Yes.

15        Q.   Now, during the time-period we're talking about here, which would

16     be around the beginning of 1991 into the summer and the autumn of 1991

17     while you were in Vukovar, can you tell me if your husband belonged to

18     any military group or any armed forces?

19        A.   No.  Because after recruitment, he had been relieved of having to

20     serve the army for health reasons and he never had a single day of

21     military obligation.  He was permanently relieved of any obligations with

22     the army after all possible medical examinations that had he to undergo

23     in Zagreb several times.  Eventually he confirmed, by his state of health

24     and his life, the accuracy of the military medical examinations.  He had

25     two strokes and high blood sugar and high blood pressure and suffered

Page 11690

 1     from gangrene eventually and he was an invalid in a wheelchair.  And he

 2     was an opponent of anything that could drag him away from his home, his

 3     family, his job at Vupik.  He was in charge of the agricultural pharmacy.

 4     He had to undergo treatment several times at the Vukovar Hospital.

 5        Q.   Excuse me, Mrs. Brlic-Jovanovic.  I'm sorry to interrupt you.  I

 6     understand from your answer that because of health reasons, your husband

 7     had no military obligation, was not part of any military structure.  I

 8     just want to be very clear:  Did he support any volunteer group, or

 9     himself work as a volunteer during this time?

10        A.   No.  He didn't want to join any political parties.  He never had

11     anything to do with it.  He never supported it.

12        Q.   Now, we've heard during your direct examination -- my learned

13     friend showed you a permit that was dated the 21st of December, 1991.

14     And from that permit, am I correct in understanding that that is the time

15     that you returned to Vukovar on a more or less permanent basis?

16        A.   Well, such was our family decision.  However, we needed to find

17     accommodation and then clean it all up and clear it up, and we really

18     decided to be there and nowhere else.  We reported ourselves for rations

19     and for health services and for any possible job that might turn up in

20     Vukovar.

21             MS. CLANTON:  Your Honours, I see the time.

22             JUDGE DELVOIE:  Thank you, Ms. Clanton.

23             Madam Brlic-Jovanovic, this is the time for our first break.  We

24     take 30 minutes, and we will be back at 11.00.

25             Court adjourned.

Page 11691

 1                           [The witness stands down]

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

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

 4                           [The witness takes the stand]

 5             JUDGE DELVOIE:  Please proceed, Ms. Clanton.

 6             MS. CLANTON:  Thank you, Mr. President.

 7        Q.   Mrs. Brlic-Jovanovic, before the break, I had asked you if it's

 8     correct that you and your family returned on approximately the

 9     21st of December to Vukovar and stayed after that time, and you said that

10     you took the decision as a family and you were then in Vukovar cleaning

11     up your home, the home you were living in.

12             I want to clarify that after that time, you were resident in

13     Vukovar.

14        A.   We went several times to fetch food from my uncle and we went to

15     do our laundry where we could.  In my uncle's house, we would do our

16     laundry.  We would receive some food.  We tidied ourselves up and then we

17     returned.  It was already winter time.

18        Q.   There --

19        A.   And then we spent the Catholic Christmas holiday in Vukovar.  I

20     can tell you that I was pleasantly surprised that some of our

21     acquaintances from before congratulated me.  But just me.

22        Q.   And when you say that you tidied yourself up "and then we

23     returned," you mean returned to Vukovar where you were living?

24        A.   Yes.

25        Q.   Okay --

Page 11692

 1        A.   Yes, yes, yes.

 2        Q.   Thank you.  Now, in your statement, it says that you qualified

 3     for retirement in 2008; is that correct?

 4        A.   When I turned 60, I still fell under those provisions of the law

 5     in Croatia.  Currently it is different.  You have to be older or have

 6     more pensionable years, but yes, I was retired right on time, when I --

 7     at first opportunity.

 8        Q.   And --

 9        A.   In the meantime - maybe you will be interested to know - in the

10     meantime after 1991, I have not worked anywhere.  My husband was very

11     ill.  Our living conditions were anything but good and then his health

12     deteriorated, and then my brother-in-law went missing.  We have still not

13     been able to find him.

14        Q.   And, yes, Mrs. Brlic-Jovanovic, you did anticipate my question.

15     If I understand your answer, you did not work as a journalist after 1991.

16     That's correct, isn't it?

17        A.   No, no.  On the 24th of August, 1991, was the last day I worked.

18     And then on the 31st of August, 1991, was the day that was recorded in my

19     work booklet as my last pensionable day.

20        Q.   Thank you.  And I would like also to confirm at this time that

21     you have no personal or social connection or relationship with

22     Goran Hadzic; right?

23        A.   Since I saw him during those talks in 1991 - I believe that it

24     was in April of that year - I've never seen him or met him again.  I

25     haven't had any reason to contact him after that.  If people needed me,

Page 11693

 1     they could always find me.  He didn't.

 2        Q.   Thank you.  Now, what you've just mentioned, April 1991, that's

 3     the time-period that I want to talk about now.

 4             And you've testified about this, and it's also in your statement

 5     that you interviewed Mr. Hadzic after the incident at Plitvice.  And my

 6     question for you is:  Would you agree with me that at this time the

 7     environment was somewhat tense?

 8        A.   Absolutely, yes.  However, the head count was still okay.  And

 9     there was still a chance in the offing that people would agree and that

10     nothing bad would happen.  My desire then and still is, despite

11     everything that I've been through, that we should all live normally, help

12     each other, and respect each other.  And in that sense, I invited

13     representatives of all political parties.  They were all accommodating,

14     they all came, they all spoke in a civilised manner, and nobody insulted

15     anybody else.  I liked Goran Hadzic's stance.  He was not as talkative as

16     one would have expected.  He was just a normal person, very civilised and

17     well-mannered and soft-spoken.

18             MS. CLANTON:  Now if could I have the assistance of the Registrar

19     to pull up 65 ter --

20        Q.   Are you okay, ma'am?

21        A.   Yes, I keep losing the sound.  I'm trying to adjust my

22     headphones.  Now it's okay.  I believe that I wouldn't have any problems

23     hearing now.

24        Q.   Okay.  If you do have any difficulty, let us know and the usher

25     can help you with the headphones.

Page 11694

 1        A.   Then if something is amiss I adjust my headphones, but now it's

 2     okay.

 3        Q.   Now, during this time do you recall that ministers, including

 4     Croatian Minister of Interior Boljkovac and his deputy minister,

 5     Slavko Degoricija came to Vukovar to diffuse tensions that we've just

 6     discussed.  Do you recall that?

 7        A.   Yes, I was present, not during the talks.  I spent in the room

 8     adjacent to Mr. Boljkovac's room with all the other journalists.  We all

 9     waited for the conclusions from the meeting.  The journalists didn't have

10     access to the talks themselves.  And then the representatives of the

11     Serbian villages or Serbian parties, or whatever, gave their own demands,

12     to put it that way.  And then I asked Mr. Boljkovac to allow --

13        Q.   I'm sorry to interrupt you.

14             MS. CLANTON:  If I could ask for the Registrar to bring up

15     1D02192.  And this is at tab 12.

16             I don't believe that's the correct document.  1D02192.  Yes,

17     that's correct.  Thank you.

18        Q.   Now, Mrs. Brlic-Jovanovic --

19             MS. CLANTON:  If we could have the assistance as well of the

20     Registrar to zoom in a bit.

21        Q.   -- I want to ask you a few questions about what you've just told

22     us, this visit, and we see here a newspaper article.  Can you tell me if

23     you're able to see it, please.

24        A.   I have a magnifying-glass which I brought with me, but still I

25     can't see anything.  Maybe you could provide me with a hard copy.  My

Page 11695

 1     eyesight is really not good.  I can't see a thing.  If possible, you

 2     could perhaps provide me with a hard copy and then I'd be able to answer

 3     by either yes or no.

 4             MS. CLANTON:  Your Honours, I do have a hard copy available for

 5     the witness.  If it would be possible for the usher -- and to note that I

 6     have written the 65 ter number on it but it's otherwise clean.

 7             JUDGE DELVOIE:  Okay.

 8             THE WITNESS: [Interpretation] Thank you.

 9             MS. CLANTON:

10        Q.   Ma'am, what I want to confirm is that what you were just telling

11     us about the journalists who were waiting in the next room and that you

12     were waiting to hear the outcome of the talks, that this article is about

13     those same events?

14        A.   On two occasions, and I was there on both those occasions, the

15     first time there was a meeting with the military leadership of the JNA,

16     we were supposed to go to Borovo Selo.  Mr. Stane Brovet was there, he

17     was an officer.  I remember that occasion much better because people had

18     been vetted beforehand.  I couldn't go, but I found out that everything

19     went well and then I covered the event for the newspapers.

20             And as for this particular occasion, when Mr. Boljkovac came, I

21     talked only to him at the very end of all the meetings that had taken

22     place.  I'd rather have him say what was concluded.  I didn't want to do

23     that just based on the papers that were provided to us.  And then

24     Mr. Boljkovac accepted that after everybody left, he would say something

25     into the microphone and I recorded the conversation.  Actually, it was my

Page 11696

 1     colleague Jusuf Cehajic, he recorded that interview.  He died in

 2     shelling.

 3             Mr. Boljkovac in haste misplaced that document, everybody was

 4     looking for it, and then I asked if he would allow me to look for it.

 5     And he allowed me to go through his pockets, through the pockets of his

 6     jacket, and I did find the document.  I did not have the time to read the

 7     document but rather we recorded his words.  He gave us a short summary of

 8     what was in the document and what had happened during the meeting.  And,

 9     that I remained in -- on good terms with Mr. Boljkovac and I even had his

10     telephone number in Zagreb, a number that I could call if I needed to ask

11     him something, to inquire about something.  He gave me his telephone

12     number.

13        Q.   And, Mrs. Brlic-Jovanovic, based on everything you've told us

14     just now about your presence after these talks, I would like to confirm

15     that what's written here, which I believe is in the Vukovarske Novine

16     newspaper, is as you recall.  Excuse me.

17        A.   Yes, one might say so.

18        Q.   And, ma'am, in particular, I would just ask you:  In this article

19     it's talking about options for easing tensions and takes steps to present

20     individuals from causing unrest.  This is also consistent with your

21     recollection?

22        A.   Yes.

23             MS. CLANTON: [Microphone not activated] Your Honours, I would

24     tender this document at this time.

25             JUDGE DELVOIE:  Mr. Gosnell.

Page 11697

 1             MR. GOSNELL:  I note there is a notation in the English saying:

 2     "Page 2 missing."  I'm not saying that that makes the first page

 3     inadmissible but I wish to note that for the record particularly in

 4     respect of the witness's second-last answer.

 5             JUDGE DELVOIE:  It's on the record.

 6                           [Trial Chamber and Registrar confer]

 7             JUDGE DELVOIE:  The document is admitted and marked.

 8             THE REGISTRAR:  As Exhibit P3264, Your Honours.

 9             JUDGE DELVOIE:  Thank you.

10             MS. CLANTON:

11        Q.   Mrs. Brlic-Jovanovic, we've heard that you worked until the

12     24th of August, 1991.  And now I'd like to ask you to confirm whether

13     certain people whose names I'm going to read out were your colleagues in

14     this time-period between about the 4th of May, 1991, and the

15     24th of August, 1991.

16             So if I provide their names, I'd like for you to say yes or no if

17     you recall that they were your colleagues at what was then Croatian Radio

18     Vukovar.

19        A.   And if I say yes or no, will you allow me to say something about

20     those people and what I knew about them at the time?  I can explain why

21     I'm asking that.

22        Q.   Unfortunately, our time is limited today so I do ask you to

23     confine your answer to yes or no --

24        A.   Very well, then.

25        Q.   -- if you recall them now.

Page 11698

 1        A.   Very well, very well, yes.

 2        Q.   The first person is Zdravko Seremet.  Do you recall that he was a

 3     member of Croatian Radio Vukovar during this time period?

 4        A.   Seremet was his name, Seremet, S-e-r-e-m-e-t

 5        Q.   Yes, I have mispronounced his name.  Zdravko Seremet, do you

 6     recall that he was a member --

 7        A.   Yes.

 8        Q.   And the second --

 9        A.   He was nominated and appointed by Minister Hitrec after the

10     correction of the wrong name from the telegram that had arrived before

11     the decision on his appointment.

12        Q.   And now the second person, I will probably also mispronounce his

13     name but do you recall that Josip Esterajher was one of your colleagues

14     at Croatian Radio Vukovar?

15        A.   Josip Esterajher, E-s-t-e-r-a-j-h-e-r, that's how it was spelled

16     at the time.  Later on it was Germanised, but at that time that is how it

17     was spelled.  Shall I add something?  He was appointed as the

18     editor-in-chief.

19        Q.   And -- excuse me.  If you could just -- I think you were getting

20     there, I apologise, that he was an employee of Croatian Radio Vukovar.

21        A.   Yes.

22             MS. CLANTON:  I apologise to the court reporter.  My question was

23     for the witness to tell me whether or not he was a member of Croatian

24     Radio Vukovar at the time.

25        Q.   Now I'd like to move on to another person.  Do you recall that

Page 11699

 1     Sinisa Glavasevic was a member of Croatian Radio Vukovar or, I should

 2     say, an employee?

 3        A.   Yes.  He was a technician I worked with.

 4        Q.   And Branko Polovina, do you recall that he was --

 5        A.   Yes.

 6             THE INTERPRETER:  Could the witness be asked to wait for the end

 7     of the question.

 8             THE WITNESS: [Interpretation] Yes, the two of them worked

 9     together as a team.  Both of them worked with me.  At first that's how it

10     was, and then Sinisa took over the management of the radio.  After I left

11     he was still there.

12        Q.   Ma'am, I have been asked by the interpreters to suggest that you

13     could please until after I've finished my question.  The problem is with

14     the interpretation.

15             The next person I wanted to ask you about is Vesna Vukovic.  Do

16     you recall that she was an employee as well?

17        A.   Yes.

18        Q.   And Alenka Mirkovic?

19        A.   Alemka, yes.

20        Q.   And a gentleman named Stjepan Penic.  Do you recall that he was

21     also an employee?

22        A.   Yes, but he was killed before all the others had joined.  All the

23     previous names were the names of the people who joined later in July or

24     August.

25        Q.   And the last person I wanted to ask you about is

Page 11700

 1     Svjetlana Polovina, do you recall that she was an employee?

 2        A.   Yes, yes, she was.  She was an anchor of a show and she married

 3     Branko.

 4        Q.   Now, Mrs. Brlic-Jovanovic --

 5        A.   May I be allowed to add something?  Something about the

 6     time-frame.

 7        Q.   Mrs. Brlic-Jovanovic, I would like to continue with my questions

 8     due to time constraints.

 9        A.   Very well.  Aha, you have more questions?  Okay.

10        Q.   Now, what you've just told us about Mr. Penic, you said that he

11     was killed before all the others had joined.  And what I want to ask you

12     is if you know that he was killed -- that there was a member of the Dalj

13     Territorial Defence who bragged that he had killed Stjepan Penic?

14        A.   Stjepan Penic lived in Dalj, and the last time he came to the

15     radio was to see me.  After that, we heard that he was killed together

16     with a group of people.  Stjepan, whom we called Stevo, he was killed,

17     set on fire, and it was my task to organise a commemorative service in

18     Vukovar for him.  And just a day before, I was with Sinisa Glavasevic and

19     Branko Polovina, we travelled via Djakovo to the commemorative service in

20     Osijek which was organised by Glas Slavonije.

21        Q.   Just a moment ago you mentioned Sinisa Glavasevic.  Do you know

22     what happened to Sinisa Glavasevic after the fall of Vukovar?

23        A.   I didn't know then.  I heard later, much, much later, recently.

24     I didn't know for a long, long time.  I didn't know about anybody, any of

25     my other colleagues.

Page 11701

 1             MS. CLANTON:  If I could ask for the Registrar's assistance to

 2     please pull up 65 ter 6660, which is at tab 30.

 3        Q.   Mrs. Brlic-Jovanovic, are you able to see the photograph that's

 4     on the screen?

 5        A.   Sinisa.

 6        Q.   What is this person's last name, please?

 7        A.   Glavasevic.

 8        Q.   And, Mrs. Brlic-Jovanovic, the caption says that he is in an

 9     improvised studio in besieged Vukovar.  Did you work from this improvised

10     studio as well?

11        A.   No.  I was still in the official studio until the 24th of August.

12     I don't know what happened after that or where the locations were.

13             MS. CLANTON:  Your Honours, we would tender this photograph into

14     evidence.

15             JUDGE DELVOIE:  Admitted and marked.

16             THE REGISTRAR:  Exhibit P3265, Your Honours.

17             MS. CLANTON:

18        Q.   Now, a moment ago you said that for a long time you didn't know

19     what happened to your colleagues.  Do you know now what happened to

20     Sinisa Glavasevic and Branko Polovina?

21        A.   Yes, but I don't know when or why or how.  I have no information

22     about that whatsoever.

23        Q.   Do you know that they were killed at Ovcara?

24        A.   I heard that.  I can't tell you when exactly, but this is more

25     recent information.  When all sorts of commemorative events were

Page 11702

 1     organised and when his young son Bojan was already a grown-up man.

 2        Q.   Now I'd like to go back to the time-period that Mirko Stankovic

 3     was the editor-in-chief of Radio Vukovar.  This is in paragraph 1 of your

 4     statement.

 5             Now, do you know, Mrs. Brlic-Jovanovic, that after he left

 6     Radio Vukovar that he went to go work for Politika, which is

 7     Belgrade-based media, I believe?

 8        A.   I don't know where he worked, but I do know that he continued

 9     working in the media as a journalist.

10             MS. CLANTON:  If I could have the Registrar's assistance to bring

11     up 65 ter 6659.

12             Your Honour, this is a newspaper article, and due to the size of

13     the print I have made a copy for the witness.  If I could please have the

14     usher's assistance.

15        Q.   Now, Mrs. Brlic-Jovanovic, you've indicated that you know that

16     Mirko Stankovic continued to work as a journalist.  This is an article

17     that I believe was published in September of 1992 in Vukovarske Novine.

18             I want to ask you, this article says -- the title is: "Commander

19     in a trilby," and there's a photograph of a man identified as

20     Stanko Vujanovic.  Do you know who Stanko Vujanovic is?

21        A.   I've not seen this text before.  I did not know that there was a

22     newspaper Vukovarske Novine.  I thought that everything was over after

23     the fall of Vukovar.  I really didn't know that the paper continued being

24     published, and if it did, not a single copy ever reached me.  And to be

25     honest, I really didn't care after that.

Page 11703

 1        Q.   Ma'am, do you recognise the name of the author?  I believe if you

 2     turn to -- or if you look on the right page, above the photograph that's

 3     been crossed out, can you indicate for us who the author is?

 4        A.   Well, the article was signed by Mirko Stankovic.  M, in this

 5     case, stands for Mirko.  That's his first name.

 6        Q.   And I understand that you've not seen this article before.  Do

 7     you know who Stanko Vujanovic is?

 8        A.   He was a taxi driver in Vukovar before the war.  But I really

 9     didn't know anything about him, and there was no reason for him to be of

10     any importance for me.

11        Q.   In the time since you returned to Vukovar, during the war period

12     and after, did you ever hear that Stanko Vujanovic was the deputy TO

13     commander, that he was part of the Petrova Gora Territorial Defence?

14        A.   No.

15        Q.   And did you ever hear that he was convicted in 2005 and sentenced

16     to 20 years' imprisonment for the killings at Ovcara?

17        A.   I heard stories.  When texts were published about former

18     citizens, there were comments about people that people knew.  I myself

19     didn't know anybody, nor did I have any contacts with him.

20        Q.   Did you have any contacts with Mirko Stankovic in 1992 or 1993?

21        A.   When we were in Sid, I had his address.  His other address.

22     Because the first address was at the house of the mother of director of

23     Radio Sid.  Mirko Stankovic caused a fire there.  He was thrown out and

24     he was provided with another accommodation.  He was very good.  He was

25     excellent at propaganda.  I believe - I'm not claiming - that a lot of

Page 11704

 1     the things that he wrote about had nothing whatsoever to do with the

 2     reality of things.

 3        Q.   Ma'am, if could I ask you to look at the first column on the left

 4     side you've been provided, I believe it's the bottom paragraph in the

 5     Cyrillic.  And the language I want to direct your attention to starts

 6     with:  "This story followed that path ..."

 7        A.   Where do I start reading?

 8        Q.   The paragraph begins with:  "This story followed that path and we

 9     will try to help you discover something ..."

10             On the left-hand side, the far bottom column.

11        A.   Yes, okay.  Yes.

12        Q.   And what it says here is:

13             "We -- we will try to help you discover something you did not

14     know about another one of our heros from these parts, Stanko Vujanovic."

15             And then the second part that I want to direct your attention to,

16     in your version this would be on the right-hand page.  If you could look

17     on the right-hand side, the middle column.

18        A.   Is it here?  This is where I --

19        Q.   Yes.

20        A.   -- find it, is that so?

21        Q.   Yes, I simply wanted to direct your attention to what

22     Stankovic -- what Mirko Stankovic has said to introduce Mr. Vujanovic.

23     And now if you could -- I realise it's a lengthy article, if you could

24     look at the second page, please.  So the right-hand page you have and

25     then in the middle column, the first full paragraph in the middle.  And

Page 11705

 1     here we have a quote from Stanko Vujanovic.  It says:

 2             "These two peoples can no longer be together.  Any future contact

 3     between them would mean a new war, annihilation" --

 4        A.   Can somebody come and help me to find this?  I simply can't

 5     locate the passage.

 6        Q.   Ma'am, I'd like to help you.  Could we look at the right-hand

 7     page?  So you see how it is taped together?  Yes.  And then on the

 8     right-hand page, so if you're looking at it in front of you -- yes, the

 9     page that's on the right.

10             MR. GOSNELL:  I would have no objection if the Prosecutor wishes

11     to highlight the passages concerned, if that will assist.

12             MS. CLANTON:  Yes, thank you.  I would be happy to do that.

13             THE WITNESS: [Interpretation] Yes, yes, yes.  Yes, that would

14     really help me.  Let's not waste time.

15             MS. CLANTON:  Thank you.  If the usher could assist.

16             THE WITNESS: [Interpretation] Let somebody mark the passage.

17             MS. CLANTON:  Excuse me.  If the usher could assist.

18             THE INTERPRETER:  Interpreter's note:  We are also not seeing the

19     correct page in B/C/S.

20             THE WITNESS: [Interpretation] May I feel free to read it, please,

21     just to see what it's about.

22             MS. CLANTON:

23        Q.   Yes.  So Mrs. Brlic-Jovanovic, my question was, I wanted to

24     direct you to this passage where Stanko Vujanovic is quoted.  And to make

25     the record clear, this is the section where he says that:  "These two

Page 11706

 1     peoples can no longer be together," and he mentions that if the Ustashas

 2     step on Serbian land, it will be fatal for them and that further contact

 3     means a new war.  Did you see that section?

 4        A.   Yes, I do.  I can see it.

 5        Q.   Now, would you agree that it's fair to say that this reporter,

 6     Mr. Stankovic, and the publication, which is Vukovarske Novine, are

 7     putting Stanko Vujanovic forward as a hero, an important person in

 8     Vukovar?

 9        A.   As I have no information that he would be so important, and

10     knowing that Mirko Stankovic waged a propaganda war, I don't find it

11     strange that something as ugly as possible, as bad as possible, and

12     almost unreal was written.

13             MS. CLANTON:  Your Honour, we would tender this document for

14     admission into evidence.

15             JUDGE DELVOIE:  Admitted and marked.

16             THE REGISTRAR:  Exhibit P3265, Your Honours.

17             JUDGE DELVOIE:  Thank you.

18             THE REGISTRAR:  I apologise, P3266.

19             MS. CLANTON:

20        Q.   Now, Mrs. Brlic-Jovanovic, earlier today you talked to my learned

21     friend about poetry and about the poetry that was read on Radio Vukovar.

22     First I want to ask you, from your statement, I see that you hosted a

23     programme called "Sundays at Ten."  Is this the only programme that you

24     appeared on, on Radio Vukovar?  I'm talking about the time-period from

25     1985 to 1990.

Page 11707

 1        A.   That was my permanent obligation, but I also made reports for

 2     other shows for the news every day, for the news programme.

 3        Q.   Now, I have a few questions about one of the exhibits that was

 4     admitted with your statement.

 5             MS. CLANTON:  This is 1D00456, please, which is Defence tab 1.

 6     Excuse me, 2.  And Prosecution tab 8.

 7             Your Honour, I would like to ask for the usher's assistance to

 8     provide a hard copy to the witness.

 9        Q.   Ma'am, I'm interested in the part at the very bottom of the page,

10     the bottom section.  And what we have here is a programme from

11     Radio Vukovar and it's for the time-period --

12        A.   Yes.

13        Q.   -- from October 1990 to March 1991.  Now, if we look at this

14     programme for Sunday, it has a listing of what's been broadcast between

15     8.00 a.m. and 11.00 a.m.; do you see that?

16        A.   I'm looking for it.

17        Q.   I believe that it's laid out Sunday, Monday, Tuesday --

18        A.   It's there, yes.  Yes, I have found it.

19        Q.   And then if we look at every other day of the week, so Monday

20     through Saturday, it appears that the programming that's listed is from

21     1.30 p.m. to 5.00 p.m.; do you see that?

22        A.   Yes.

23        Q.   My question for you is:  What was played on the radio at other

24     times?  The schedule shows what was played for three to five hours a day,

25     but what was played at other times?  What was broadcast?

Page 11708

 1        A.   Lots of music.  In my time, various genres, least of all the

 2     classical music.  Mostly pop, folk.  We were obliged to make a list

 3     because there was the author's agency, so we had to have a complete list

 4     in order to pay what was due.

 5        Q.   Now, you've told us that you did have poetry that was read on

 6     your programme.  That's right, isn't it?

 7        A.   Not just that.  It depended.  You mean on "Sunday at Ten"?

 8        Q.   Or any other programme that you hosted?

 9        A.   In the news as well.  In the news as short reports after some

10     events.  If something happened on the previous day, then on the following

11     day you would say such and such a thing took place.  And if it was really

12     worth it, then there would be a shortened version where something short

13     would be reported.

14             Once there was a famous harp player, Rajka Dobronic, and I had to

15     fight to have a report on her in the news as the central information

16     report.  I wanted to have an audio recording from her concert.  So

17     everything was to be informative and really brief.  Even if it was poetry

18     you would say, for example:  Yesterday evening in such and such a place a

19     book was published.  There we had the audience.  The best place was this.

20     We are glad that as the author you agreed to appear, so can you just

21     briefly read to us what you -- and then you say thank you.  And it would

22     be all over.

23        Q.   So, Mrs. Brlic-Jovanovic, if I understand from your last answer,

24     poetry was read on your programme but also there were other things on

25     your programme, such as the news?

Page 11709

 1        A.   The news were compulsory, but the news were like that because

 2     this was a local institution.  To inform the public you had to mention

 3     all the more important decisions of various organs in the town, and there

 4     was not much time left to fit in much of anything else, least of all

 5     something that is sheer fun.

 6        Q.   And what you've described about having topics other than just the

 7     local news, in respect of poetry, in particular, how frequently was

 8     poetry on the radio?

 9        A.   But little.  Not much.  There was no interest.  Everyone waited

10     much more for the sports programmes.  That was the integral part of every

11     news, every programme, and on the news programme that would be a

12     shortened version.  And if there was anything else, then I wouldn't

13     really know because something may have been mentioned in the programmes

14     on languages of various ethnicities.  These were hosted by my colleagues

15     who were of that particular ethnicity and I couldn't speak those

16     languages.  And as I was not the editor-in-chief, then they were not

17     obliged to provide me with translations or anything like that.  We had

18     the Ruthenian and Ukrainian languages.  That was the permanent editorial

19     office.  We also had Hungarian.  That was only the news programme for the

20     day.  A lady was doing that part time.

21        Q.   If I could interrupt you for a moment.

22        A.   We also had Slovakian.

23        Q.   I understand from what you said that there were programmes in

24     other languages.  What you've told us is that with your programme, it had

25     mixed content.

Page 11710

 1             My question now is:  For other journalists who had programmes on

 2     Radio Vukovar, did any of them have a programme that was dedicated to

 3     poetry?

 4        A.   No.  No one did anything special.  We all prepared the daily news

 5     programmes together.  And then the journalists were in charge of various

 6     areas.  One was tasked to cover the sports, like I had "Sundays at Ten,"

 7     and mine was the most mixed.  It was the greatest potpourri, that's where

 8     anything that may be interesting for the listeners to hear about during

 9     one hour would be included.  So we would have one report and then one

10     song.

11        Q.   Now, Mrs. Brlic-Jovanovic, did you ever hear that other

12     presenters or hosts or journalists would have poetry on their show,

13     possibly in the manner you've indicated where there would be a report and

14     then a song or a report and then some other type of presentation?

15        A.   No one else did.

16        Q.   But you agree that the other journalists, hosts of radio

17     programmes, that their shows were of a mixed nature as well, that they

18     had, for example, music and news and interviews on their programmes too?

19        A.   I'm not receiving interpretation.  Yes.

20        Q.   Ma'am, did you hear my question?  If not, we can ask the usher to

21     assist.

22        A.   They didn't have programmes that would be their personal ones,

23     where they were the authors of the programme like the one on "Sundays at

24     Ten" was.  They just made reports for other programmes, for the news

25     programmes and so on, or if it was a children's programme.  So they were

Page 11711

 1     only in charge of making specific pieces, short presentations or reports.

 2     They did not have a term and so that they could say:  Well, this is now

 3     my time that would be devoted to poetry only or to something else, like I

 4     had this specific time that was scheduled for me and then I was in

 5     charge.

 6        Q.   Mrs. Brlic-Jovanovic, other persons who worked at the radio also

 7     had programmes that they hosted though; right?

 8        A.   Yes.

 9        Q.   And you've said that you -- I asked you if you had heard that

10     other presenters or hosts would have poetry on their programme from time

11     to time.  You said you had not heard that.  But my question for you now

12     is:  If poetry was played on the radio, it would have been played in and

13     amongst other types of material that were broadcast; isn't that right?

14             MR. GOSNELL:  That's, Mr. President, calling for speculation.

15             JUDGE DELVOIE:  Ms. Clanton.

16             MR. GOSNELL:  And if I could just say one more thing.  There have

17     already been two questions asked on this direction.  Apparently the

18     Prosecution doesn't like the answers it's getting.

19             MS. CLANTON:  Mr. President, I simply wish to be clear on the

20     answer from the witness.  I can try to rephrase my question.

21             JUDGE DELVOIE:  Please do.

22             MS. CLANTON:

23        Q.   Do I understand correctly, Mrs. Brlic-Jovanovic, that the

24     programmes that were played on Radio Vukovar had mixed content; that is,

25     you would yourself be able to say that you hosted a programme that had

Page 11712

 1     different components?

 2             MR. GOSNELL:  That's asked and answered at line 13 and then the

 3     answer at line 19.

 4             JUDGE DELVOIE:  It is, Ms. Clanton.

 5             MS. CLANTON:  And if I could ask the witness if she is aware that

 6     it was the same for other persons who worked at Radio Vukovar.

 7             MR. GOSNELL:  Again that's the same question that was -- that's

 8     at line 13 and line 19.  That was what that question was about, other

 9     people, not the witness.

10             MS. CLANTON:  Mr. President, I understand that my learned

11     friend's objection has to do with calling for speculation.  As

12     Mrs. Brlic-Jovanovic who worked there since 1972 and is well versed in

13     the operations of Radio Vukovar, it's simply whether she considers that

14     the other programming was also of a mixed nature.  To the best of her

15     knowledge.

16             MR. GOSNELL:  The objection at this time, Mr. President, is asked

17     and answered.

18             JUDGE DELVOIE:  Please move on, Ms. Clanton.

19             MS. CLANTON:  Thank you, Mr. President.

20        Q.   Mrs. Brlic-Jovanovic, you indicated that in addition to the

21     programming which we see on the schedule that I provided to you,

22     Radio Vukovar was always on the air and that music was being played; is

23     that correct?

24        A.   Yes.

25        Q.   Were there also advertisements that were played?

Page 11713

 1        A.   Yes.

 2        Q.   And so broadcasting on Radio Vukovar, we see from the schedule

 3     that depending on the day, there were seven to 12 programmes, then

 4     supplemented by music and advertisements.

 5        A.   Precisely so.

 6        Q.   And you've stated that you're aware that when somebody published

 7     something or they won an award, that their poetry might be read on the

 8     radio.  Do you recall that testimony?

 9        A.   Yes.

10        Q.   And is it your testimony that this is the only time that poetry

11     or other literary publications would be read on the radio?

12        A.   I would say yes.  Perhaps only it may be a problem for you or -

13     how should I put it? - it should be simplified, this notion of the

14     programme.  The editor-in-chief decided on the programme.  That was the

15     standard procedure and it was the standard programme.  There were

16     objections that it was boring because people knew exactly when they would

17     hear certain things.  And in order to make things less monotonous, then

18     there was the intention, at least in my show on "Sundays at Ten," to make

19     things more colourful.  And in other shows, they would be devoted only to

20     specific fields and they could only expand reports connected to the

21     specific subjects.  We didn't have anything that was devoted only to

22     poetry or, for example, to music, where somebody would play during an

23     entire time slot.  That was impossible.

24        Q.   Mrs. Brlic-Jovanovic, when you were not at work, when you were

25     not at the office, did you listen to the radio all day, every day?

Page 11714

 1        A.   The editor-in-chief had to do that and the directors were doing

 2     that.  Later on, it turned out that some people were suspended because

 3     they did not provide correct information.  He was very strict about it.

 4     And no one would ever even think of changing this programme scheme

 5     without consulting the editor-in-chief.

 6        Q.   So if I understand correctly, it was the editor-in-chief who was

 7     authorised to determine the programming and it was also the

 8     editor-in-chief who was responsible for listening to the radio at all

 9     times?

10        A.   Yes, he had to because he needed to know what was broadcast, and

11     that was something he was in charge of.  Because, otherwise, it wouldn't

12     be serious business if he hadn't known what he was doing.  His title was

13     editor-in-chief.  I was responsible for my show.  The editor of the news

14     programme was held responsible for his news.  And we tried to respect

15     truthful and objective reporting, and we tried to provide accurate

16     information.

17        Q.   And, Mrs. Brlic-Jovanovic, in the time-period from 1985 to 1990,

18     you were never the director or editor-in-chief of Radio Vukovar?

19        A.   No, no, no.  No.  I was first junior journalist and then a

20     journalist and then a junior associate and then editor.  You needed years

21     to acquire status.  Years of work.

22        Q.   Thank you.  You mentioned before that you thought it was a good

23     thing to try to promote what people were doing in terms of their

24     interests or their hobbies and that on your programme on the radio this

25     is something you tried to broadcast.

Page 11715

 1             I'd like to know whether all of the poets that you recall, if

 2     they were all equally well known in Vukovar?

 3        A.   It's not a big town.  You have to have in mind how big Vukovar

 4     is.  So it happened that at some literary events, you would always see

 5     the one and the same people.  If it was art events, always one and the

 6     same people.  If it was musical, the same.

 7        Q.   If I could interrupt you for a moment --

 8        A.   All right.

 9        Q.   Excuse me, if I could interrupt you for a moment.  In particular,

10     you've mentioned Zoran Calic --

11        A.   Calic.  Zoran Calic.

12        Q.   And my learned friend asked you about Branko Kovacevic, also a

13     poet.  Isn't it true that some of these poets were further along in their

14     poetic interests or careers than others?

15        A.   No, no.  Branko was only beginning as a younger man.  Zoran Calic

16     definitely even younger.  When I mentioned Calic, that was for about

17     three to four years back, but from the time when I presented him to the

18     public for the first time, it's been almost 20 years.  That was the

19     period in which he managed to collect all the awards and acknowledgments.

20     But initially, these were the local kids who summoned up courage to do

21     something and then we wanted to encourage them, to present them to the

22     public, and to learn about them, to see what they were doing.  There was

23     another one.  I don't remember his name any longer but his nickname was

24     Seki.  And his first stepping-stone to move forward, so he found support

25     and donors, and then the issue was who wrote about him first.  He didn't

Page 11716

 1     have many supervisors to speak so, and I even felt unnecessary, in a way,

 2     when he said that I had written the first review of whatever he was

 3     writing at that time.

 4             And I have to say that up until recently, they all very happily

 5     remembered those first days of their careers and the occasions on which

 6     someone mentioned them publicly for the first time.  But perhaps there

 7     were those who had no courage to begin working like that and may have

 8     gone somewhere further afield.  We also had co-operation with Radio

 9     Osijek, and we daily sent them reports about major events.  It was the

10     Voice of Slavonia and Radio Osijek.  The late Stjepan Penic was in charge

11     of that.

12        Q.   Mrs. Brlic-Jovanovic --

13        A.   Sorry?

14        Q.   I think we have enough from your last answer.  If I could ask you

15     my next question, please.

16             I'd like to know if you know of a poet from Vukovar named

17     Ivan Baranjek?

18        A.   No.  Baranjek?

19        Q.   Ivan --

20        A.   Or perhaps you wanted to ask me about Baranjek.

21        Q.   Yes, Baranjek, Ivan Baranjek.

22        A.   Yes, it's difficult, pronunciation of our language.  Yes, I knew

23     him.  He was on good terms with my father and he used to attend cultural

24     events, but to be honest, I don't remember in what form he published his

25     works, nor have I ever read them.  Because from the moment when I began

Page 11717

 1     working in the information system, I followed various fields when I was

 2     tasked to do so, and then I concentrated on that and did not pay much

 3     attention to other fields, nor was I obliged to do that.  I even didn't

 4     have the right to.

 5        Q.   Mrs. Brlic-Jovanovic, I understand that you are then familiar

 6     with Ivan Baranjek and you said that he was present at cultural events.

 7     Did you also know that Ivan Baranjek supported the efforts of persons who

 8     were interested in poetry?

 9        A.   No.

10        Q.   Ivan Baranjek had published three books of poetry at this time.

11     You said that you weren't familiar with them.  I'd like to ask if you

12     knew that he had a studio behind his house where he would have his

13     friends, his acquaintances, other poetry enthusiasts, or his customers

14     around to talk about poetry or paintings?

15        A.   No.  For me, it's something completely unknown.  First of all, I

16     had no idea where he lived or what he had there, in terms of equipment,

17     and if he had something like that, then I think it was -- he kept a low

18     profile.  It was not made public.  Or at least I didn't know about that.

19        Q.   Mrs. Brlic-Jovanovic, you do know, though, that Ivan Baranjek was

20     somebody who wrote poetry.  That's right, isn't it?

21        A.   Yes.  But what kind and such-like, no.

22        Q.   And did you know that his poetry was read on Radio Vukovar?

23        A.   Not while I had the obligation to do that type of work.  Perhaps

24     before I came to the radio or while I was in charge of other departments,

25     and I cannot comment on that.

Page 11718

 1        Q.   Is it your evidence that he did not read his poetry or his poetry

 2     was not read on your show?

 3        A.   No, it wasn't.

 4        Q.   And when did you first hear of a poet from Pacetin named

 5     Branko Kovacevic?

 6        A.   I couldn't tell you the year.  I just know that he's younger than

 7     me and that he -- how should I put it?  He was a bit insistent.  He

 8     offered himself and he sent invitations, and I knew him as the younger

 9     brother of my classmate.  She used to be my best friend in one period,

10     and so I looked at it and it was very nicely organised.  The whole town

11     was informed and then they came to the museum hall.  It was all prepared

12     as if a very distinguished guest would be there.  And, therefore, I

13     covered the event in an appropriate manner.

14             In such places, we would have celebrations promoting books, for

15     example, of Djordje Radosevic, who was a native of Vukovar, and he was a

16     writer now residing in Belgrade.

17        Q.   Mrs. Brlic-Jovanovic --

18        A.   He had received all possible state and international --

19        Q.   I'm sorry to cut you off.  I think we've strayed past what my

20     question was, and I note that it is the time for the second break.

21             JUDGE DELVOIE:  Thank you, Ms. Clanton.

22             Mrs. Brlic-Jovanovic, we take the second break, 30 minutes.

23     We'll be back at 12.45.

24             Court adjourned.

25                           [The witness stands down]

Page 11719

 1                           --- Recess taken at 12.15 p.m.

 2                           --- On resuming at 12.47 p.m.

 3                           [The witness takes the stand]

 4             JUDGE DELVOIE:  Please proceed, Ms. Clanton.

 5             MS. CLANTON:  Thank you, Mr. President.

 6        Q.   Mrs. Brlic-Jovanovic, I'd like to briefly go back to something

 7     that we discussed before the break.  We were talking about the Vukovar

 8     poet whose name was Ivan Baranjek and I asked you if you knew that his

 9     poetry was read on Radio Vukovar.  This is at page 55 of the temporary

10     transcript.  And what you said was that it was not, and I'm going to

11     quote, "not while I had the obligation to do that type of work."

12             Is there a time that you were not in a position to know or you

13     were not obligated to do the type of work that would relate to a poet

14     like Ivan Baranjek having his work read on the radio?

15        A.   That could only be while I was on maternity leave for a year,

16     after the birth of my son.  That was in 1975 and one part of 1976.

17        Q.   And, Mrs. Brlic-Jovanovic, you continue in your answer, you said:

18             "Perhaps before I came to the radio or while I was in charge of

19     other departments ..."

20             Can you confirm there was a time you were in charge of other

21     departments?

22        A.   Yes.  Do you want me to go through the whole chronology of my

23     employment?

24        Q.   No --

25        A.   Could that be of any interest --

Page 11720

 1        Q.   No, thank you.

 2        A.   Very well, then.

 3        Q.   What I wanted to ask you was that you've indicated that there was

 4     a time when you were in charge of other departments and that you wouldn't

 5     be able to say for sure --

 6             THE INTERPRETER:  Could the witness please be instructed not to

 7     interrupt the Prosecutor during the question, to wait for the question to

 8     end.

 9             JUDGE DELVOIE:  Madam Brlic-Jovanovic, please don't interrupt the

10     Prosecutor while she is still putting the question to you.  Just wait

11     until she has finished.  If not, we have a problem of overlapping and

12     that's a problem for the interpreters.  Thank you.

13             MS. CLANTON:

14        Q.   Now, to go back to my question, without going through the

15     chronology of your employment, just to confirm that you've said there was

16     a time you were in charge of other departments and it's therefore

17     possible that Ivan Baranjek's poetry was read at that time?

18        A.   I don't know.

19        Q.   Mrs. Brlic-Jovanovic, we were talking about Branko Kovacevic

20     before the break.  I asked you about when you first became aware of him,

21     and you said you did not recall the year.

22             MS. CLANTON:  If I could have the Registrar's assistance, please,

23     to provide 1D00484.  And that's at tab 9.  And I do have a paper copy for

24     the witness, if the usher would assist, please.  Thank you.

25        Q.   Now, Mrs. Brlic-Jovanovic, you did not recall the year when you

Page 11721

 1     first became aware of the poet Branko Kovacevic.  The document I'm

 2     showing has been provided, I believe, from one of his publications and it

 3     lists his involvement in various poetry collections.  And if we look at

 4     this document, it says:

 5             "He has co-authored the following collections of poetry."

 6             And then it listed five -- four, excuse me, collections that were

 7     all published between 1981 and 1983.  The first one is called "Hazy Gaze"

 8     and the last one is "Arches of the Future."

 9             And I want to ask if seeing this limited biography of

10     Mr. Kovacevic which contains some of his publications helps refresh your

11     memory about the time that you first became aware of a published poet

12     named Branko Kovacevic?

13        A.   The first book of his does ring a distant bell, and I mean his

14     first independent book of poetry.

15        Q.   This is the one listed as "Enthusiasm of the Sprout"?

16        A.   Yes.  I -- I do recall that title.  It sticks in my memory.

17        Q.   And, Madam Witness, we don't have a date of that publication,

18     "Enthusiasm of the Sprout," but what I want to ask you is if these other

19     publications, which were published in the early 1980s, help refresh your

20     memory on whether Mr. Kovacevic was a poet who was known to you at that

21     time?

22        A.   The titles don't tell me much.  The only one that seems to still

23     be present in my memory is the last one, "The Enthusiasm of the Sprout."

24     I seem to be able to associate that title with that name.  The rest, no.

25     Doesn't tell me much.

Page 11722

 1        Q.   And, Mrs. Brlic-Jovanovic, did you know that Goran Hadzic and

 2     Branko Kovacevic were friends?

 3        A.   No.  This is the first time I hear that.

 4        Q.   Now, ma'am, in your statement, you've talked about and we've

 5     already discussed some of your professional obligations, your

 6     responsibilities, and one of those responsibilities was to monitor the

 7     Vukovar Municipal Assembly; is that correct?

 8        A.   Yes.

 9        Q.   And it said in your statement that the first time you met

10     Goran Hadzic was when he was an SDS, Serbian Democratic Party,

11     assemblyman at the Vukovar Municipal Assembly.  That's correct, isn't it?

12        A.   Yes.  Just a remark, if I may.  I didn't actually meet him, but I

13     noticed him.

14        Q.   And, Mrs. Brlic-Jovanovic, this is -- the time-period I'm talking

15     about is before the incident in Borovo Selo in May of 1991.  And you told

16     us today, which is at page 7 of the transcript, that you interviewed

17     Goran Hadzic and other prominent leaders of some political parties after

18     the events in Plitvice.

19             Do you recall the names of the other people --

20        A.   Plitvice.

21        Q.   Thank you.  Do you recall the names of the other persons who were

22     on the programme with Goran Hadzic at that time?

23        A.   Slavko Dokmanovic.  Mercep.  I can't be positive about any of the

24     others.

25        Q.   And was Goran Hadzic, if you recall, introduced as a member of

Page 11723

 1     the Serbian Democratic Party?

 2        A.   Yes.

 3        Q.   Was he introduced as a member of the Serbian National Council?

 4        A.   I wouldn't know.  No, no.

 5        Q.   And at the time that you interviewed Mr. Hadzic, Mr. Dokmanovic,

 6     and Mr. Mercep, was Goran Hadzic well known as somebody who had been

 7     arrested at Plitvice?

 8        A.   Yes.

 9        Q.   And so, Madam Witness, your knowledge of Mr. Hadzic at the time

10     was as a politician, the time being 1991, and not as a poet; is that

11     correct?

12        A.   He didn't look like one, did he?

13        Q.   In your statement, you've said at paragraph 4 that you don't know

14     if Goran Hadzic privately wrote poems.  Do you recall saying that to the

15     investigator for the Defence?

16        A.   Yes.

17        Q.   And earlier this morning, I asked you if it was correct that you

18     did not have any personal or social relationship with Goran Hadzic,

19     either in the 1990s or now, and you said that you did not.  Do you recall

20     that testimony?

21        A.   No.  No, no.  Yes, yes, yes.

22        Q.   Perhaps I should break my question into two parts.  I apologise

23     for the confusion.  This morning I asked you --

24        A.   Maybe you should, yes.

25        Q.   Okay.  This morning I asked you whether you had a personal or

Page 11724

 1     social relationship with Goran Hadzic.  Do you remember that I asked you

 2     that question?

 3        A.   No.  Yes, yes.

 4        Q.   And when I asked you that question this morning, you said that

 5     did you not have a personal or social relationship with Goran Hadzic.  Do

 6     you recall that?

 7        A.   I do.

 8        Q.   And so, Mrs. Brlic-Jovanovic, is it fair to say that you didn't

 9     know at the time, in 1991, about any of Mr. Hadzic's personal interests?

10        A.   Yes, as a matter of fact, no, I didn't know.

11        Q.   So, for example, you didn't know that he was interested in

12     karate?

13        A.   No.

14        Q.   And you didn't know that he was interested in training dogs

15     either?

16        A.   No.

17        Q.   Were you aware that Goran Hadzic attended Branko Kovacevic's

18     poetry reading?

19        A.   No.

20        Q.   And did you also, then, not know that he did so after being

21     invited by Branko Kovacevic?

22        A.   Please repeat your last question.  But only your last question,

23     nothing else.

24        Q.   Did you know that Goran Hadzic attended the poetry reading of

25     Branko Kovacevic after being invited by Branko Kovacevic?

Page 11725

 1        A.   That is possible.

 2        Q.   But this is not something you knew at the time for a fact?

 3        A.   No.

 4        Q.   And, Mrs. Brlic-Jovanovic, did you know that Goran Hadzic read

 5     poetry with his girlfriend?

 6        A.   No.

 7        Q.   The next thing I want to ask you about has to do with the role of

 8     the radio during the time that Vukovar was under siege.  During the time

 9     that you worked for Croatian Radio Vukovar, would you agree with me that

10     the radio was an important method for sharing of information?

11        A.   Yes.

12        Q.   And would you agree that during the summer of 1991, that it was

13     known that there was Croatian Radio Vukovar that was operating in

14     Vukovar?

15        A.   Yes.

16        Q.   And you would agree with me that this was known in Zagreb?

17        A.   It was our duty to send daily reports to Zagreb about our

18     operations and our shows and any other information of significance for

19     the entire state.  It was our obligation to broadcast that from Vukovar

20     studio, and that was announced as being broadcast from Vukovar for the

21     entire territory of Croatia.

22        Q.   So, based on your last answer, is it fair to say that this would

23     also have been known in Belgrade?

24             MR. GOSNELL:  Objection.  That's calling for speculation,

25     Mr. President.

Page 11726

 1             JUDGE DELVOIE:  Ms. Clanton.

 2             MS. CLANTON:  I can rephrase the question, Mr. President.

 3             JUDGE DELVOIE:  Please do.

 4             MS. CLANTON:

 5        Q.   Mrs. Brlic-Jovanovic, you confirmed that you knew that the

 6     broadcasts and the fact that there were broadcasts was known in Zagreb.

 7     Do you know if this was the same in Belgrade?

 8        A.   I'm not in a position to know who was listening to what and

 9     where.  But it would have only been expected because communications were

10     free-flowing.  There was freedom of communication.  So anybody could

11     follow anything.

12        Q.   And is it correct that a person with a radio in the Vukovar area

13     could pick up the signal of a broadcast from another area that was not

14     too far away?

15        A.   We always monitored the Radio Vukovar range because before the

16     1990s, the technology was -- was renewed.  But there were areas where one

17     could follow our broadcast as well as areas where one couldn't.  However,

18     this is a technical issue which I cannot comment upon.  I can't tell you

19     exactly how far our broadcasts reached and where we could be heard

20     without any technical problems and where not.

21             MS. CLANTON:  If I could please have 65 ter 6662, which is at

22     tab 32.

23        Q.   Now, this document is only in English so I'm going to read what

24     it says and it will be translated to you.

25        A.   Very well.

Page 11727

 1        Q.   This document is a report from Radio Belgrade and it's entitled:

 2     "Radio on Croatian synchronised attacks."  Now the attack is the

 3     26th of August, 1991.

 4             I understand that you had stopped working two days before the

 5     26th of August.  Now, what I want to ask you about, Mrs. Brlic-Jovanovic,

 6     in this text we see that Radio Belgrade is reporting on what they were

 7     told by Ilija Kojic, who was the minister of the Territorial Defence in

 8     the government of the SBWS, Slavonia, Baranja, and Western Srem.  The

 9     radio was reporting about attacks on particular villages.

10             MS. CLANTON:  And for Your Honours, if we look at the third

11     paragraph down, I'd like to read what this Radio Belgrade report says.

12     It says:

13             "Information and programmes broadcast by the Croatian Radio

14     Vukovar are not only incorrect, but are also directly adding fuel to the

15     fire.  For instance, the radio broadcast the invention that nine tanks of

16     the Yugoslav People's Army have been destroyed so far.  The fact is that

17     so far only one tank has been hit and that it has already been repaired.

18     Vukovar Radio is also appealing to women to form a human barrier and stop

19     the units of the Yugoslav People's Army."

20             That's the end of the quote.

21        Q.   Now, Mrs. Brlic-Jovanovic, my question for you, what I want to

22     ask is that based on what I have read to you from a Radio Belgrade

23     report, does that help you affirm whether or not the reports of Croatian

24     Radio Vukovar were themselves part of the news?

25             JUDGE DELVOIE:  Mr. Gosnell.

Page 11728

 1             MR. GOSNELL:  Mr. President, the witness does not have this

 2     document in her own language.  I think it would at the least to be fair

 3     to tell her the date.

 4             MS. CLANTON:  Mr. President, I indicated the date.  It was the

 5     26th of August, 1991.

 6             JUDGE DELVOIE:  Yes, indeed.

 7             MS. CLANTON:

 8        Q.   Ma'am, do you --

 9             MR. GOSNELL:  My apologies.

10             JUDGE DELVOIE:  Thank you.

11             MS. CLANTON:

12        Q.   Ma'am, do you need me to repeat the question?

13        A.   No.  After the 24th of August, which was the last day I went to

14     work, I had no information as to who broadcast what.  However, I knew

15     something else.  While I was still there, before I suffered a serious leg

16     injury, some misinformation was broadcast with a view to spreading

17     propaganda.  I can corroborate that by saying that the chief of the

18     police administration in Vukovar, Mr. Stipo Pole even requested that

19     nobody be sent for written daily reports on the situation on the ground

20     because he wanted only me to come to fetch those reports.  Otherwise he

21     thought that -- that there would only be confusion on the ground and he

22     would suffer unpleasant consequences.  That is why he left his telephone

23     number in his drawer.  He said jokingly that if I was interested in

24     anything else, that I should call him, because he didn't trust anybody

25     else.

Page 11729

 1        Q.   Mrs. Brlic-Jovanovic --

 2        A.   I told him if I couldn't come myself that --

 3        Q.   I apologise.  I have limited time so I'm going to move on from --

 4        A.   Well, you can see it at the end.  At the end.

 5        Q.   Mrs. Brlic-Jovanovic, I understand that you stopped working on

 6     the 24th of August and what you've said is that you had no information

 7     after that date about who broadcast what.  I've read you this excerpt

 8     from Radio Belgrade as an example to ask you whether you would agree that

 9     during the time-period, let's say, the month of August, 1991, when you

10     were at radio -- Croatian Radio Vukovar, that you knew that your news was

11     itself part of the news that was being broadcast?

12             JUDGE DELVOIE:  Mr. Gosnell.

13             MR. GOSNELL:  Mr. President, first, I think the question is

14     vague.  And, secondly, because the document itself sources a person as

15     being the basis for the information, it -- it's not actually clear that

16     the proposition or that the basis for the question exists.  That there's

17     a source cited.  So it's actually not clear that the broadcast is being

18     heard elsewhere -- if that's what my friend means, and I'm not sure from

19     the question.

20             MS. CLANTON:  Mr. President, if it would perhaps clarify, the

21     report is from a person named Branko Pjetlovic.  My understanding is that

22     this is the person who read the report or was responsible for its

23     dissemination on Radio Belgrade.

24             MR. GOSNELL:  And in the --

25             JUDGE DELVOIE:  Just one moment, Mr. Gosnell.  I'm trying to

Page 11730

 1     understand.

 2             Yes, Mr. Gosnell.

 3             MR. GOSNELL:  But it's the first five lines that indicate where

 4     the information came from, and we don't know where that person mentioned,

 5     i.e., Mr. Kojic, was at the time that he conveyed that information to the

 6     radio.

 7             MS. CLANTON:  Mr. President, I did indicate when I first pulled

 8     up this document that there was a quotation attributed to Mr. Kojic and

 9     that it was about the attack, the co-ordinated attack in these villages.

10             MR. GOSNELL:  But, Mr. President, that's not the problem.  The

11     problem is that there's a question about, isn't it true that -- that this

12     radio station was the basis or was being heard elsewhere.  And that's the

13     part that, I think, is assumed.  It hasn't been established.

14             MS. CLANTON:  That is the question for the witness,

15     Mr. President.  If this document assists her in considering whether she

16     knew at the time, and I said August 1991, that the broadcasts of Croatian

17     Radio Vukovar were being reported on, monitored elsewhere; for example,

18     Radio Belgrade.

19             JUDGE DELVOIE:  Didn't she answer that one?

20             MS. CLANTON:  Mr. President, I apologise, I do not think that she

21     has.

22             JUDGE DELVOIE:  Yes, Mr. Gosnell.

23             MR. GOSNELL:  Mr. President, I think she did.

24             MS. CLANTON:  Mr. President, I can move on.

25             JUDGE DELVOIE:  That's what I was -- that is what I intended to

Page 11731

 1     suggest, Ms. Clanton.  Thank you.

 2             MS. CLANTON:

 3        Q.   Mrs. Brlic-Jovanovic, are you aware that in June of 1991, Serb or

 4     Serbian Radio for Slavonia, Baranja, and Western Srem was established?

 5        A.   I don't know.

 6        Q.   Ma'am, did you ever hear that Mirko Stankovic was the head of

 7     Serbian or Serb Radio, that was set up in late June 1991?

 8        A.   No.  But I would ask you for permission to add a question;

 9     namely, where was the seat or the headquarters of that newly formed radio

10     station?

11        Q.   Madam Witness, I can show you a document.

12             MS. CLANTON:  If I could please have 1D00605, which is at tab 36.

13     And for this one, I would need to provide a hard copy to the witness.

14        Q.   Ma'am, I've put a square brackets around the paragraph.  Are you

15     able to see it?

16        A.   I can see it, but it's blurred and it's impossible to read.

17        Q.   Ma'am, I have a --

18        A.   I'm trying, but ...

19             MS. CLANTON:  It would be page 2 in the English, please.

20             And it's the very last paragraph of the article which I've

21     provided to the witness.  As she has difficulty reading it, may I have

22     Your Honours permission to read the short paragraph to the witness.

23             JUDGE DELVOIE:  Please do.

24             MS. CLANTON:

25        Q.   Ma'am, this report says the following in quotes:

Page 11732

 1             "A Serbian Radio report from Borovo Selo managed to reach Vukovar

 2     using an indirect route.  The weak station is sending its information via

 3     other, more powerful radio stations.  According to this information, life

 4     in Borovo Selo was normal today.  In other words, it was only exposed to

 5     sniper fire, while the heavy weapons were silent.  Borovo Selo made a

 6     hasty assessment of the damage that was caused by three days of

 7     continuous attacks from Borovo Naselje.  According to the Serbian Radio,

 8     many houses were damaged, especially on the southern side of the

 9     village."

10             Now, Mrs. Brlic-Jovanovic, you asked me about the area or the

11     place where Serbian Radio for Slavonia, Baranja, and Western Srem was

12     located.  This article suggests that they were reporting from

13     Borovo Selo, and I want to know if this refreshes your memory about the

14     establishment of Serbian Radio for Slavonia, Baranja, and Western Srem?

15        A.   No, I don't know.  I'm not familiar with this detail.

16             MS. CLANTON:  Mr. President, I am aware that I'm running out of

17     time.  I have one more question on this subject and then I had one other

18     brief question for the witness.  With Your Honours' leave, could I please

19     continue?

20             JUDGE DELVOIE:  Please do.

21             MS. CLANTON:

22        Q.   Mrs. Brlic-Jovanovic, you recall that when I asked you questions

23     this morning, I asked you about your colleagues, including Vesna Vukovic

24     and Sinisa Glavasevic.  You indicated that they were working at Croatian

25     Radio Vukovar in the summer of 1991.  Do you remember that testimony?

Page 11733

 1     I'm sorry, ma'am, the answer was not recorded on the transcript.  Do you

 2     recall that testimony?

 3             THE INTERPRETER:  The witness is waiting for interpretation.

 4             THE WITNESS: [Interpretation] May I say?

 5             MS. CLANTON:

 6        Q.   Yes.

 7        A.   They were added as assistants to the office of the Croatian Radio

 8     Vukovar.  They just arrived one day and said:  We'll be working with you

 9     from today on.  And there were also two girls in addition to them.  Now

10     what their names were, I can't really remember.  They were also at the

11     disposal if the permanently employed journalists from the editorial

12     office needed any help.  But there was no competition or anything.  I

13     don't know how these persons -- except for Sinisa Glavasevic, who was

14     employed by decision of the commission earlier, and Vesna Vukovic and

15     Alemka Mirkovic simply appeared there.  It was said that they were the

16     assistants to help the old journalists who were the members of the

17     editorial office from before, and the other two girls I mentioned who

18     weren't there for a long time.

19        Q.   I think you've answered my question.

20             Is it correct that oftentimes Sinisa Glavasevic and Vesna Vukovic

21     worked as a team?

22        A.   I know at that time while I was still there, the team was

23     Sinisa Glavasevic and Branko Polovina as the logistics, if I may put it

24     so.  And how this was divided later, who would be doing what and who

25     would be helping whom, that's something that I couldn't know.  The only

Page 11734

 1     thing I know for sure is that Sinisa Glavasevic and Branko Polovina would

 2     go to Zagreb, even during the first air-strikes, and they took the

 3     recordings --

 4        Q.   Mrs. Brlic, I'm going to stop you there.  I believe you have

 5     answered my question.  I would like to show you a passage of a book.  The

 6     narrator here is Vesna Vukovic.

 7             MS. CLANTON:  And if I could ask for the Registrar to please

 8     bring up 65 ter 6658, which is at tab 28.  And I have a paper copy for

 9     the witness, if the usher could assist.

10             If we could have the second page, please.  And also the next page

11     of the English.

12        Q.   Now, Mrs. Brlic-Jovanovic, the passage that I circled, since you

13     have a copy, I'm not going to read it.  Have you had a chance to read it?

14        A.   Yes.

15             MS. CLANTON:  For Your Honours, this is the paragraph that starts

16     with:  "However, in early August ..."

17        Q.   Now in this paragraph we see that Vesna Vukovic is recounting a

18     conversation she had with Sinisa Glavasevic and they saw something that

19     they said was Stankovic's contribution to Novi Sad TV.  Ma'am, would you

20     agree with me that they're talking about Mirko Stankovic here?

21             Perhaps it would be of assistance as well if we look at the

22     paragraph above the one that I circled.  It says:

23             "We did not see Mirko Stankovic," and it says that he was in

24     Borovo Selo and Negoslavci.

25             So am I -- if you could just listen to my question.

Page 11735

 1        A.   Mm-hm.

 2        Q.   Is it correct that they're referring to Mirko Stankovic in this

 3     paragraph?

 4        A.   Yes.

 5        Q.   And what they're talking about is a report from Mirko Stankovic

 6     that was on Novi Sad TV.  My question is:  While you were working at

 7     Croatian Radio Vukovar, did you ever hear about what was broadcast on

 8     Novi Sad TV?

 9        A.   No.

10        Q.   We see here that your colleagues were able to see what was

11     broadcast on Novi Sad TV.  Did you ever watch Novi Sad TV?

12        A.   No.  May I say something?  All this, what Mirko Stankovic could

13     publish, was part of the propaganda war which I mentioned to you at the

14     beginning.  And this second part, this conversation, is something based

15     on memory, and it is a part of something written by a third person.  It's

16     something re-told.  And when someone wants to achieve something while

17     re-telling, then he can make all sorts of things out of it.

18             So I do not believe the first, the second, or the third element

19     here.

20        Q.   Mrs. Brlic-Jovanovic, you just said that this was part of the

21     propaganda war which you had mentioned to us before, and my question is:

22     Were reports by Mr. Stankovic or others that you would consider to be

23     propaganda, were they known to you when you were still working in

24     Vukovar?

25        A.   No.

Page 11736

 1        Q.   Mrs. Brlic-Jovanovic, you've said that this was something that

 2     was being done for propaganda purposes.  Are you saying that the

 3     propaganda wasn't something that you heard?

 4        A.   I didn't hear it.

 5        Q.   Ma'am, you've discussed your programme on Radio Vukovar and

 6     briefly your career as a journalist.  Why didn't you work as a journalist

 7     after you returned to Vukovar in 1991?

 8        A.   I first had to resolve where I would live.  Then I had to take

 9     care of my ill husband, his elderly mother, because everyone else, my

10     whole family, the relatives on his side because there were no longer any

11     left of mine, we were looking for a place to live.  Then we looked for a

12     way to provide treatment to my late husband.  And then it was my personal

13     decision to never work in journalism.  Because simply I was disgusted

14     with everything, on all sides.  I prefer that everything be known and

15     then let us see but not have someone try to brainwash you with some other

16     information.  My decision was not to work as a journalist any longer.

17             And after the peaceful reintegration it was offered to me start

18     working again in the same line of work, but I said thank you and I

19     decided that I didn't want to.  My husband was in a critical condition.

20     He had had strokes and gangrene and he was in a wheelchair and so on and

21     so forth, and I could not accept any daily obligations any longer to be

22     away from home, and no one coerced me to that in any case.

23        Q.   Mrs. Brlic-Jovanovic, you described during your testimony this

24     morning that you were at Velepromet from approximately the 12th to the

25     14th of November, 1991.  And I wanted to ask you what -- what kind of --

Page 11737

 1     what kind of armed forces or military groups did you see while you were

 2     at Velepromet on those dates?

 3        A.   All who were walking around there wore uniforms.  I could

 4     recognise some people from the earlier peacetime life.  Those were

 5     representatives of the civilian police from Vukovar.  There were also

 6     people wearing military uniforms whom I did not know.  I recognised the

 7     commander - how would we call him? - the director of Velepromet,

 8     Milovan Cvetkovic.  I'm sorry, I stand corrected, Milovan Cvjeticanin,

 9     with a J.

10        Q.   Mrs. Brlic-Jovanovic, did you see persons who were dressed as

11     Chetnik or -- Chetnik volunteers?

12        A.   No.

13        Q.   And did you recognise anybody who appeared to be part of the

14     Territorial Defence?

15        A.   Well, I'm not sure how I would have been able to distinguish

16     between the Territorial Defence and the regular army.  I didn't know the

17     insignia or who wore whose uniforms, who got which uniforms, because

18     sometimes even elderly ladies would be taken out of basements and they

19     had nothing to wear so they would put on some thick, coarse woollen coats

20     and trousers which may have seemed ridiculous but they didn't have

21     anything.  I received footwear for the first time because in the basement

22     I was wearing pink summer slippers and I had some sort of skiing winter

23     jacket, and then they found footwear for me that I could walk in.

24        Q.   Mrs. Brlic-Jovanovic, you described the room you were in at

25     Velepromet and that you received rice and there were pallets to sleep on.

Page 11738

 1     If you recall, were --

 2        A.   It wasn't a room.  It was a section of the basement where shells

 3     couldn't kill people who were down there.  It was some sort of

 4     underground warehouse.  There were pallets and there were all of us who

 5     came from this one basement and other people.  We did receive good

 6     blankets, thick ones, and there was a very small stove, and that was an

 7     area perhaps bigger than this courtroom.  And people lay one next to the

 8     other like sardines, and curfew was imposed so people couldn't walk

 9     around as they wished.  The first evening, no provision of food was

10     organised.

11        Q.   Mrs. Brlic-Jovanovic, if I could interrupt you, please.  If you

12     recall the room -- I'm sorry, the warehouse area that you were in, were

13     most of the people in that room Serbs or were they Croats?

14        A.   Mixed.  From our sector of the fair-ground, as they arrived, they

15     were all mixed.  Our former neighbours, even people whose children were

16     wearing the ZNG uniforms and others who not in such a situation.  And

17     everyone was sad, in a very dejected mood, desperate that something like

18     that had happened.  The last supply of food that we had, we carried it,

19     some meat that we could cut.  We carried it with us because we didn't

20     know how long everything would last, so that we wouldn't starve.  We had

21     no water left and that was the last food we had.  If Radoslav needed it,

22     he was a diabetic and he couldn't live without medication and food.  So I

23     brought that and I distributed it among people I knew and those I didn't.

24     It -- it was like Jesus when he had three fish and then he managed to

25     feed a great number of people.


Page 11739

 1             So whenever you saw anyone else that was still alive, you would

 2     be happy because there were people that you didn't know about.  And it

 3     was no longer important who was a Serb or a Croat.  They were happy that

 4     they had managed to leave the underground torture that they had gone

 5     through.

 6        Q.   Thank you.

 7             MS. CLANTON:  Mr. President, that concludes my cross-examination.

 8             JUDGE DELVOIE:  Thank you, Ms. Clanton.

 9             Mr. Gosnell, anything in re-direct?

10             MR. GOSNELL:  Briefly, Mr.  President.

11             May we have 1D456, please, which is Defence tab 2.

12                           Re-examination by Mr. Gosnell:

13        Q.   Mrs. Brlic-Jovanovic, how many years in total did you work at

14     Radio Vukovar?

15        A.   Well, from 1972, 2nd June 1972, until the 24th of August, 1991.

16     There was a period of one year when Igor was about to be born and he was

17     born in 1976, so between mid-1975 and mid-1976.  So my years of

18     pensionable employment were calculated as 18 years and -- 18-odd year,

19     less than 19.

20        Q.   And how many years did you work at the programme "On Sundays at

21     Ten"?

22        A.   The last few years.  Because those who had been there before me

23     at the radio worked on that programme.  I can't say exactly when that --

24     but, in any case, from the moment when I got employment, I had to be

25     questioned so they would determine whether I would be capable of doing

Page 11740

 1     the work.  It was at the same time --

 2        Q.   If I could just interrupt you, Mrs. Brlic-Jovanovic, and I do

 3     apologise.  When you say "a few years," was it more or less than three

 4     years that you were working on "On Sundays at Ten"?

 5        A.   More than three years.

 6             MR. GOSNELL:  And looking at the schedule, the radio schedule, in

 7     the English, I'd like to turn to page 2, please, and look under

 8     "Saturday."  And everyone can rest assured that I'm not going to go

 9     through every single programme but I'd like to go through a few.

10        Q.   The first item at 1300 hours on Saturday:  "Overview of the day's

11     programme."

12             Ever hear any local poets interviewed there or any poetry read

13     during that programme?

14        A.   No.

15        Q.   What about for the next item:  "KALI-EPP of local radio stations

16     (folk music)," ever hear any local poets interviewed or poetry recited on

17     that?

18        A.   No, no.

19        Q.   "Music Evergreens (popular music)," ever hear any local poets

20     interviewed on that or any poetry recited?

21        A.   It couldn't have been so because the speaker who announced that

22     programme was on duty in the afternoon and he played both music and he

23     announced things and he did everything himself.  He did not have orders

24     or authorisation to include the sort of reports that you mentioned in the

25     programme.

Page 11741

 1        Q.   "News and market barometer," any poets interviewed or poetry

 2     recited?

 3        A.   No.

 4        Q.   What about on "Together on Saturdays"?

 5        A.   No.  Preparations for weekends were already under way and

 6     proposals relative to weekends, there was a show title:  "What to do on

 7     the weekend," and there were proposals as to where to go, what to see in

 8     Baranja, an outing Valpovo, for example.

 9        Q.   Were you familiar with the programming on each of these

10     channels -- on each of those programmes?

11        A.   When we prepared shows we always had discussions at the editorial

12     board, so whenever something happened, I was the one who was reproached

13     for insisting on fine art or excavations in Vucin Dol, the others

14     insisted on sports, and there were also those who didn't want to

15     participate in economic shows because they thought that they were boring.

16     But pretty much things did not depend on us.  We would be invited to

17     press conferences and meetings from which we had to report.  We had to

18     have commercials and -- because they were paid.  We had music shows that

19     had to meet all sorts of requirements and they had to suit all the

20     tastes.  They -- we had to play music from all over the world or

21     Yugoslavia, of all genres, pop music, folk music.  And we did not exclude

22     anybody, the old settlers or the newcomers.  The only thing that we did

23     not play were the so-called ganga music.  If somebody decided to play

24     that, I'm sure that the editors would have hanged themselves.  This may

25     sound flippant but we never played ganga.

Page 11742

 1        Q.   So the content of the radio programmes on this schedule was

 2     discussed at these editorial board meetings that you just referred to?

 3        A.   Not every day.  But meetings did not have to be officially

 4     announced.  There would always be comments, people discussed things among

 5     themselves.

 6        Q.   And did any of the programmes on this schedule, not just Saturday

 7     but the rest of the week, did any of them, to your knowledge, let's say,

 8     over the course of the last ten years that you worked there, did any of

 9     them have interviews with local poets or poetry recitations other than

10     "On Sunday at Ten"?

11        A.   No.

12                           [Defence counsel confer]

13             MR. GOSNELL:

14        Q.   You said during your cross-examination that Goran Hadzic did not

15     look like a poet.  Can you tell us what you meant by that, please.

16        A.   I'm not a psychiatrist or psychologist, so I really can't say

17     anything of much importance.  I can just speculate.  But I don't think

18     that I'm well suited to provide any comments.  I don't want to offend

19     anybody.

20             However, in my view, he should be more talkative.  He should be a

21     man of more words, like me, for example.  He should be a playful soul;

22     whereas he was a very serious gentleman.  I really can't go on

23     commenting.  I seem be misbehaving, I'm sorry.

24        Q.   Mrs. Brlic-Jovanovic, thank you very much.  That concludes my

25     examination.


Page 11743

 1             JUDGE DELVOIE:  Mrs. Brlic-Jovanovic, this concludes your

 2     testimony.  We thank you again for coming to The Hague to assist the

 3     Tribunal.  You are now released as a witness, and we wish you a safe

 4     journey back home.  The court usher will escort you out of the courtroom.

 5                           [The witness withdrew]

 6             JUDGE DELVOIE:  If there's not -- nothing else, Mr. Zivanovic.

 7             MR. ZIVANOVIC:  Not for today, Your Honours.  Our next witness

 8     will be here tomorrow morning.

 9             JUDGE DELVOIE:  Court adjourned.

10                            --- Whereupon the hearing adjourned at 1.53 p.m.,

11                           to be reconvened on Tuesday, the 23rd day of

12                           September, 2014, at 9.00 a.m.