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
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
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 --
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]
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,
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
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.
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
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
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,
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.
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
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
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
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
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
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
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.
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
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.
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
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
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
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
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
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,
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?
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,
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
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?
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.
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;
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
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
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
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
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
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
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.
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
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.
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
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
1 of the town museum in Vukovar in the 1950s. And so Mom and I also moved
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
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
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
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
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
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
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
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.
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
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 --
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,
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.
1 A. Then if something is amiss I adjust my headphones, but now it's
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
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
1 colleague Jusuf Cehajic, he recorded that interview. He died in
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
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
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.
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
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.
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
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
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
25 Q. And the last person I wanted to ask you about is
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
4 Q. Now, Mrs. Brlic-Jovanovic --
5 A. May I be allowed to add something? Something about the
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.
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
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
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
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.
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
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
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
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
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.
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?
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?
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.
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
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
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
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
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
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
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
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?
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?
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
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
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.
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
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
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.
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]
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
22 A. Yes. Do you want me to go through the whole chronology of my
24 Q. No --
25 A. Could that be of any interest --
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
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
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
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.
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
25 Q. And was Goran Hadzic, if you recall, introduced as a member of
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
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
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
13 A. No.
14 Q. And you didn't know that he was interested in training dogs
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?
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
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.
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.
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.
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
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
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
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
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
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
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:
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
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
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?
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
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.
1 A. Mm-hm.
2 Q. Is it correct that they're referring to Mirko Stankovic in this
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
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
25 A. No.
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 --
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.
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
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.
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
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
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
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
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
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
1 Q. "News and market barometer," any poets interviewed or poetry
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.
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
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
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
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.