Tribunal Criminal Tribunal for the Former Yugoslavia

Page 3276

 1                           Thursday, 3 June 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 2.17 p.m.

 6             JUDGE KWON:  Good afternoon, everybody.  Good afternoon, Doctor.

 7             THE WITNESS:  Good afternoon, sir.

 8             JUDGE KWON:  Different but familiar setting.

 9             Yes, Mr. Karadzic.  Let's start.

10                           WITNESS:  ROBERT DONIA [Resumed]

11                           Cross-examination by Mr. Karadzic: [Continued]

12             THE ACCUSED: [Interpretation] Good afternoon to everybody.

13             MR. KARADZIC: [Interpretation]

14        Q.   Good afternoon, to you, Mr. Donia.  Mr. Donia, I'd like us to

15     look at the period before the parties were established, briefly, and to

16     see which points we agree upon so we don't have to debate them and go

17     through documents that would be superfluous in that place.

18             Now, in my books, and, you know, that I've written several books

19     of poetry, a poetry book for children, a comedy and a novel.  So in my

20     books, did you ever come across anything that would indicate to you

21     that -- what my state of consciousness was which would act against me in

22     these proceedings, for instance?

23        A.   I don't -- I'm not sure how to answer that.  I have read some of

24     your poetry, in particular, and I guess find there a particular style of

25     expression which is really not something that I would say reveals a state

Page 3277

 1     of consciousness that would act against you in those proceedings, no.  I

 2     wouldn't say that.

 3        Q.   Thank you.  Now, have you read my novel, "The Magical Chronicle"?

 4        A.   Unfortunately not, no.

 5        Q.   Thank you.  Well, many of my books receive prizes and I'm not

 6     saying this from the literary point of view but from political

 7     correctness.  All those books were awarded many prizes, from the

 8     Sholokhov prize, smaller ones, bigger ones, the Jovan Ducic prize, and so

 9     on and so forth.  Do you know about that?

10        A.   I don't know about all the names that you just gave, but I know

11     that you have won prizes and your literary works in general have been

12     hailed by a good number of people.

13        Q.   Thank you.  Now, going back to the period before the

14     Serb Democratic Party was formed.  Do you know what my relationship was

15     and attitude towards others and with others in the religious sense and

16     national sense?

17        A.   Well, I think you -- in the national sense you arrived in

18     Sarajevo at the age of 15 from Montenegro and displayed, let's say,

19     loyalty -- kind of a local loyalty to Montenegro which often expressed

20     itself as a kind of a Serb loyalty.  I think that changed a bit over time

21     and became more of a Serb identity, at least as I -- as I understand it,

22     and I'm obviously not able to speak to this like you are, but that in the

23     course of the 1980s, in particular, as you went to Belgrade for several

24     months and spent a year in prison that your Serb identity became more

25     pronounced.

Page 3278

 1        Q.   Thank you.  Now, do you agree that the area I came from in

 2     Montenegro up to the Berlin Congress was in Herzegovina and that to the

 3     present day it is called Old or Ancient Herzegovina?

 4        A.   Yes, mm-hmm.

 5        Q.   Thank you.  Now, did you happen to note in the books of

 6     Vuk Karadzic that it says he's a -- from Herzegovina, Drobnjak, from

 7     Petnjica, and that is all my general area, the area I hailed from and my

 8     particular village?

 9        A.   Well, Petnjica is indeed your home village and then you lived in

10     Savnik for a while and moved to Niksic and finally to Sarajevo.  So I'm

11     aware of that and was not aware specifically of what Vuk Karadzic's

12     association with that area was, but as I indicated earlier, recognise

13     that his family and your family background intersect at some point.

14        Q.   Thank you.  His father was born in my village, in actual fact.

15             Now, do you agree that by joining up with Montenegro we still --

16     we still remained Herzegovinian but with a great love for Montenegro, and

17     that's why we joined up?

18        A.   I'm sorry, joined up when or what -- to what did you join?

19        Q.   Well, Montenegro, at the Berlin Congress, was given independence,

20     just like Serbia.  Isn't that right?

21        A.   Yes, it was, mm-hmm.

22        Q.   And Montenegro, at the time, was given many adjoining

23     territories, and my territory, Old Herzegovina, united with Montenegro

24     rather than remain in Herzegovina which was still under the Turks.

25        A.   Well, it -- Herzegovina was technically under Turkish sovereignty

Page 3279

 1     but under Austro-Hungarian administration after 1878.  Demonstrably it

 2     wasn't then a part of Montenegro.

 3        Q.   But Old Herzegovina, which united with Montenegro, was no longer

 4     under Turk sovereignty as Herzegovina was until 1908.  Herzegovina proper

 5     was under them.  So do you agree that my Durmitor area and

 6     Old Herzegovina with a Serb population was conjoined with Montenegro, and

 7     it was free and that's why we united with it, because it was all Serb

 8     land anyway; right?

 9        A.   Well, there's a number of assertions there, some of which is -- I

10     would -- I would question.  The basic diplomatic outcome of the Congress

11     of Berlin I don't argue with, but to say that these areas in

12     Old Herzegovina were Serb land anyway, I wouldn't necessarily agree with

13     that, no.

14        Q.   But do you know anybody else who was a state?  We call it

15     St. Sava's land.  But in any other state was the population anything

16     other than Serb from time immemorial or from the Illyrians, let's say?

17        A.   Well, I think we've been talking about Montenegro, and many

18     Montenegrins would disagree with you about that statement and note that

19     the land has been inhabited by Montenegrins for a long time.  I would say

20     it is a contested issue.

21        Q.   Very well.  Let's move away from Montenegro.  But at that point,

22     Montenegro was declared Serbian land and the population was that of

23     Czar Nikola, King Nikola later on.  He considered himself to be the Serb

24     ruler.

25        A.   Well, Montenegro was not declared Serbian land at that time.  It

Page 3280

 1     was declared an independent principality.

 2        Q.   Well, it was an independent state, but it was a Serb state, not

 3     part of Serbia but Serb land inhabited by the Serbs.  But never mind

 4     that.  My area was inhabited by a Serb population, and that when we

 5     joined up with Montenegro we did not lose our national identity.  Isn't

 6     that right?

 7        A.   There was nothing about joining Montenegro that would have

 8     changed the national identity in that area, that's correct.

 9        Q.   Thank you.  I want us to throw more light on this, that my Serb

10     national identity became slightly more marked in the 1980s, and we'll

11     come to why in due course.  But do you happen to know that my late father

12     had a Montenegrin Albanian blood brother?  He was a Muslim Albanian.  Did

13     you know about that?

14        A.   That I did not know.

15        Q.   Well, I mentioned that in my interviews, but did you note in my

16     interviews that my next-door neighbour in Niksic was Mahmut Adzajlic, the

17     uncle of the great Montenegrin hero Mujo Adzajlic who was a Muslim and --

18     but fought against the Turks?

19        A.   I have not noted that in your interviews.  I don't have any

20     reason to believe at this time in your life that you harboured ill

21     feelings towards Muslims or toward -- toward Muslims in general or

22     certainly the individual Muslims that you knew.

23        Q.   Thank you.  Do you know that the Montenegrins mostly go to

24     Belgrade to study at university and that they usually study history or

25     law?  A little bit of an anecdote now.

Page 3281

 1        A.   I'm dying to hear it.  I'm interested in why you went to

 2     Sarajevo, but that's another story, I guess.

 3        Q.   Well, I'll explain that too.  Since Radio Belgrade couldn't be

 4     heard in Niksic and Radio Titograd began broadcasting at 12.00, we always

 5     listened to Radio Sarajevo, and we saw Bosnia as something very close to

 6     us, and instead of going to Belgrade like all the other Montenegrins, I

 7     went to Sarajevo because of my love for Sarajevo.  How does that sound to

 8     you, does it sound plausible?

 9        A.   Yes, I would -- that's close to my understanding of how it

10     happened.

11        Q.   Do you agree that in 1960, when I was a 15-year-old boy coming to

12     Sarajevo, that the circumstances and situation in Yugoslavia was very far

13     from any kind of nationalism or disruption of Yugoslavia?

14        A.   That year could be the pinnacle, the high point of Yugoslavia as

15     a state that was really quite free from these nationalist divisions.

16        Q.   Thank you.  Now, what you said a moment ago, that I was well

17     integrated or what was it, what was the word you used, in Sarajevo, that

18     I felt very good in Sarajevo and despite my Montenegrin identity and

19     entity, I took on the Sarajevo entity and identity as well.  So do you

20     accept that where you hail from gives you one identity and your national

21     identity gives you another identity?

22        A.   Well, I don't know about that general proposition.  I think what

23     you're suggesting in general is what I call a hybrid identity, and it's

24     something that actually most of us in one way or another have, a loyalty

25     to a country or a nation and often to a city or locale and sometimes to a

Page 3282

 1     family or even a profession simultaneously, and I think the way you

 2     described your feelings about Sarajevo and your -- I think you're using

 3     in the B/C/S the term "zavicajno," your, let's say, home-base loyalty to

 4     Montenegro.  That's -- that's exactly as I understood it.

 5        Q.   Thank you.  But you're not the only one.  Some Montenegrin

 6     writers, too, saw the fact that I love Montenegro and Montenegro's

 7     entity, my opting for the Montenegrin nation.  But Montenegro for all

 8     Serbs is something that is very respected.  They all respect the ethics

 9     of Montenegro, that the Serbs are -- highly respect the Montenegro

10     ethics, ethos, not ethnos?

11        A.   Yes, but they tell terrible jokes about them.

12        Q.   Well, we all tell jokes like that about all of us.

13             Now, do you know, and I also spoke about this in my interviews,

14     that all my business contacts in Sarajevo were mostly with Muslims?  I

15     don't want to enumerate them all, not to waste time.  The professor who

16     taught me clinical psychiatry was a Muslim, and I chose him.  My internal

17     medicine professor was a Croat, Ivan.  My dentist, according to my own

18     choice, is Faruk, a Muslim.  My lawyers, once again due to my personal

19     choice, are Ekrem and -- I know the surname but I'll remember his name

20     too.  He was also a Muslim, and I think he originated from Kosovo.  That

21     my hairdresser is a Muslim, or barber, and that everything I did in

22     Sarajevo was mostly linked to the Muslims.

23        A.   Well, I think I wouldn't really -- I wouldn't quarrel with that,

24     but I think that the time that you got there and the time that you

25     entered into many of these relationships, no one was paying much

Page 3283

 1     attention to this identity other than as a basis for kind of casual

 2     conversation and personal interest.  So it wasn't really a matter of

 3     I'm -- and I think this is what you're saying, you didn't deliberately

 4     seek out Muslims because they were Muslims for this, but many of the

 5     professional people that you engaged with were Muslims or Croats by --

 6     basically by coincidence.  Is that what I understand you to be saying?

 7        Q.   Well, you understood me correctly, but the fact remains that

 8     those relationships of mine lasted until the outbreak of the war in 1992.

 9     Nothing changed.  My last haircut was at Meha's [phoen].  He was my

10     barber, the best barber in Sarajevo.  And I didn't select him -- I didn't

11     choose him because he was a Muslim but because he was the best, but I

12     didn't not choose him because he was a Muslim.  So I want to link up

13     something that you said, that on the 13th of July -- yes.  I've been

14     asked to slow down for the benefit of the interpreters.  I will.

15             But my point is this:  In Sarajevo, there were very prominent

16     professionals among all three ethnic groups, the Serbs, the Muslims, and

17     Croats, and I always looked at the -- their professional capabilities and

18     didn't choose according to religion.  Do you agree with that?

19        A.   As I understand your life at that time, that's true, yes.

20        Q.   And that went right up until the outbreak of the war.  Even in

21     March, after - what's it called? - the barricades.  Right up until the

22     6th of April I had the same people and interacted with them.  Do you

23     accept that?

24        A.   I'm not sure that it lasted that long for everyone that you were

25     associated with who was of another ethnicity, but I certainly find it

Page 3284

 1     plausible that that was the case with some -- some of those folks.

 2        Q.   Thank you.  I'd like to link that up to what you say in your

 3     report about the origins of Republika Srpska and that I, on the

 4     13th of July, said, I'll read it out in English:

 5              "[In English] At the SDS meeting Karadzic had kind words for the

 6     Muslims, 'Our goal is to repair the relations between the nationalities

 7     and to establish equality, reciprocity, and civil peace.  I believe in

 8     the great potentials of the Muslim nation.  I believe in its simple

 9     humane good.'"

10             This is page 20.  [Interpretation] I haven't read it all out, but

11     that's as far as I got, and what I want to -- us to establish now is

12     this:  That our relationship -- or, rather, whether our relationship

13     towards the Muslims was political or religious, our relationship towards

14     Islam in general, was it the cause of anything?  And in view of the fact

15     that you noticed and recorded those words, do you believe that we really

16     stood by what we said there?

17        A.   You certainly stood by what you said in the subsequent several

18     months prior to the election when the three national parties,

19     particularly the last few weeks of the election campaign, were holding

20     joint rallies, made appearances together.  You made appearances with

21     Mr. Kljujic and Mr. Izetbegovic, worked together to ensure registration

22     of all voters, and in general became a kind of partnered opponents of the

23     Social Democrats and Reformists in the election campaign.  So I see that

24     period right up until the election and a little bit beyond it as

25     characterised by these kinds of cooperative sentiments and -- and

Page 3285

 1     actions.

 2        Q.   Thank you.  You called them Social Democrats and Reformists very

 3     kindly, but we fought against them as Communists for replacing the

 4     regime.  Do you agree?

 5        A.   Well, the name I guess technically at that point was the

 6     Social Democratic Party/League of Communists.  So we're, I think, both

 7     right.

 8        Q.   Thank you.  Now, did you happen to note at the founding Assembly

 9     of the Serbian Democratic Party, and I see that you saw 3.000 people

10     present, did you happen to notice the programme and platform of the

11     Serbian Democratic Party, and, if so, did anything in that programme

12     attract your attention?

13        A.   Well, I believe I summarised a few points anyway in the paper,

14     but frankly, it's been a while since I looked at it.  If you are prepared

15     to refresh my memory or something I'd be -- be happy.

16        Q.   Thank you.  Well I hope we'll be able to call up on e-court the

17     party programme, but let me ask you this:  Do you remember the speech I

18     delivered at the founding Assembly?

19        A.   Generally, yes, but I don't remember specific words or passages.

20             THE ACCUSED: [Interpretation] Can I have 1390 called up, please,

21     which is the programme of the Serb Democratic Party at the founding

22     session on the 12th of July, 1990.

23             MR. KARADZIC:  [Interpretation]

24        Q.   I'm sure you noticed that I didn't wish to be the party president

25     and that I offered the position to everybody else.  Is that right?

Page 3286

 1        A.   That's correct.

 2        Q.   I'm sure you also noted that I proposed that there be a national

 3     wing and a social democratic wing?

 4        A.   Yes.  I referred to that yesterday.

 5        Q.   Thank you.  Since you speak Serbian -- well, perhaps the

 6     Prosecution has the translation of this document.

 7             JUDGE KWON:  Yes, Ms. Edgerton.

 8             MS. EDGERTON:  In fact, this appears on the Prosecution's

 9     65 ter list as 00928, and there is a translation.

10             JUDGE KWON:  Thank you.

11             THE ACCUSED: [Interpretation] Shall we wait for the translation

12     then.  00928.  May we have that called up, please.

13             MR. KARADZIC:  [Interpretation]

14        Q.   I'm going to read it out in Serbian, and we see the English on

15     the screen.

16             "Programme of the Serbian Democratic Party of BH.

17             "In the process of revitalisation of political life in -- of

18     Serbian people in BH in the spirit of liberty-oriented traditions, the

19     Serbian Democratic Party of Bosnia and Herzegovina finds its activities

20     on the following humanistic and civilised principles and objectives.

21             "1" --

22             THE ACCUSED: [Interpretation] May we zoom in, please thank you.

23             MR. KARADZIC: [Interpretation]

24        Q.   "Democracy that rests on the abolishment of the monopoly of one

25     political party.

Page 3287

 1             "2.  Peace and co-operation among people as the prerequisite of

 2     development and social progress.

 3             "3.  Freedom and rights to humans and citizens as supreme values.

 4             "4.  Legitimate authority and rule of law.

 5             "5.  Equality as the basis of cohabitation.

 6             "6.  A democratic Yugoslavia as a modern federal state.

 7             "7.  International relations -- internationality relations

 8     founded on mutual respect and tolerance.

 9             "8.  The establishment of equal, fair, and civilised dialogue of

10     legitimately elected representatives of all peoples and citizens.

11             "9.  Bosnia and Herzegovina as a republic with equal rights

12     within a modern federal state.

13             "10.  Kosovo and Metohija within the state of Serbia with

14     autonomy of the Western European type.

15             "11.  Co-operation with the Serbian Orthodox church and its

16     involvement in the life of the Serbian people on an equal basis."

17             Now, I don't have 12 there in the Serbian, but anyway.

18             "Return to cultural, historical and national heritage alienated

19     from" --

20             Do you want me to read it all?  I don't think there's any need

21     for me to go through them all, all these points.  We have the programme

22     before us.

23             JUDGE KWON:  You could have stopped a long time ago.

24             MR. KARADZIC:  [Interpretation]

25        Q.   Yes.  Let's look at number 20; that's an important point.

Page 3288

 1             "20.  The development of rural areas and agriculture by

 2     abolishing the land maximum and taxes and to have agrarian policy to

 3     protect the farmers from the vagaries of agriculture," et cetera.

 4             Was this a programme a correct programme and acceptable to one

 5     and all?

 6        A.   Much of it was.  I think there are a few points here that

 7     provided an entry point into the debates that took place during the

 8     pre-election campaign and on which there were some pronounced

 9     differences, and I would -- if I could go back to the first page,

10     perhaps.  There is -- number 6, the "Democratic Yugoslavia as a modern

11     federal state."  And number 9, "Bosnia and Herzegovina as a republic with

12     equal rights want modern federal state," would become a source of

13     contention.  Not so much for what they said, but for how they were

14     interpreted by you and other party leaders in terms of some of the

15     constitutional debates that we talked about yesterday.

16             I think the -- the rest of this -- certainly point 10 is really a

17     statement of -- almost advocates returning to Kosovo and Metohija the

18     autonomy that it had lost, that had been taken from it by Milosevic in

19     1989, and so I think on that point you would have found -- you did find

20     wide agreement with the other parties.

21             Now, without looking at all the rest of them, I think I've

22     identified two, anyway, that would become the source of contention in the

23     course of the election campaign.  I think pretty much everything else

24     is -- was widely accepted and hailed.

25        Q.   Thank you.  Do you recall then we announced that we would be

Page 3289

 1     forming the SDS on the 26th of March, 1990?  Izetbegovic wrote that he

 2     not even talk to any of the parties that were in favour of the

 3     dismantling of Yugoslavia.  Actually, the SDA party.  It was their first

 4     proclamation in which they announced the setting up of their party.

 5        A.   I -- I don't have a specific recollection of that statement.  It

 6     would certainly be the case that the SDA, the Muslim party, in its first

 7     platform expressed support for Bosnia-Herzegovina as a unified republic

 8     within Yugoslavia and that it should be within Yugoslavia.

 9        Q.   Thank you.  You noticed, then, confirmed that Mr. Izetbegovic,

10     with the other Muslim leaders, actually attended this first founding

11     Assembly, welcomed it, and he said, "What have you been waiting for?  We

12     are waiting for an authentic Serbian party."  Is that not the case?

13        A.   I think his words were more, "We have been waiting for you."

14        Q.   That's right.  Do you recall when somebody from the audience

15     asked him, "What kind of a Yugoslavia are you in favour of?"  And he

16     replied, "I'm in favour of a reasonable federation."

17        A.   Words to that effect I do recall, yes.

18        Q.   Thank you.  Do you remember how I explained why Krajisnik was the

19     president, the speaker of the Assembly, and why he was often in -- on

20     negotiating teams?  In addition to his obvious ability, I also said that

21     it was Izetbegovic's wish for Krajisnik to be on those teams because they

22     understood each other well.

23        A.   I don't have a specific recollection of that statement.

24        Q.   Thank you, but I wish to point out this:  When I said -- when we

25     said that a democratic Yugoslavia is regulated as a modern democratic

Page 3290

 1     state, was this something what -- that Izetbegovic wanted?  He wanted a

 2     reasonable federation.  Was it a step towards that reasonable federation

 3     that he wanted, that we had made to accommodate his wish?

 4        A.   I -- well, I think this enters into the question of what was

 5     meant by "federation" and what was meant by "confederation."  I think

 6     your question, though, is a little bit different in that you're

 7     suggesting, I take it, that Izetbegovic supported Mr. Krajisnik's

 8     participation because he liked his approach to a modern Yugoslavia.  Is

 9     that what you are suggesting?

10        Q.   I want to say that we took into account what sat well with the

11     Muslim side.  So I asked the Muslim side what their opinion would be if

12     Milan Trbojevic or Krajisnik were to become speaker of the Assembly,

13     because we wanted to avoid any misunderstandings.  That is why I chose

14     this formulation, a modern federal state in order for [indiscernible] to

15     be affected with the view that Izetbegovic held.  Do you agree that I

16     managed to do that?

17        A.   Well, I think there are two quite separate topics here.  One is

18     the selection of the president of the Presidency, the president of the

19     Assembly, and the president of the government, which was done in accord

20     with the inter-party agreements after the elections.  And I think we're

21     still talking about the compatibility of the approaches to Yugoslavia

22     which characterised this period right around the founding of the parties

23     but quickly diverged into two quite different views of what it meant to

24     be a modern federal state.

25        Q.   Thank you.  I wasn't clear enough.  I myself was not in favour of

Page 3291

 1     Yugoslavia's remaining the way it was, so the term I used, "modern

 2     federation," is something that I wanted actually to use in order to be as

 3     close as possible to the formulation which Izetbegovic used, which was a

 4     "reasonable federation."  Do you agree with that?

 5        A.   I think the modern -- the formulation of the modern preceded

 6     what -- what Izetbegovic said.  I -- I do not know what consultations you

 7     may have had with him prior to the adoption of the platform, but the

 8     platform was adopted at the founding Assembly on -- in July, and at that

 9     same meeting, I believe, is when he made that statement.  The issues

10     subsequently centred around statements during the campaign where clearly

11     there was a difference of views on what Yugoslavia should be and what it

12     should be called, as well as what it -- what any changes in it should

13     amount to.

14        Q.   Thank you.  Did you note anywhere in my interviews that

15     Izetbegovic and I myself were neighbours and that we used to see each

16     other before either his or my party were set up, and even before this

17     founding Assembly was held I knew what views he held?

18        A.   Fine.  I wasn't aware of -- I don't know how much contact you had

19     with him, but I certainly find that plausible.

20        Q.   Thank you.

21             THE ACCUSED: [Interpretation] Can this document be tendered into

22     evidence and can we call up P929, please, the OTP's document.

23             JUDGE KWON:  928 is admitted.

24             THE REGISTRAR:  As Exhibit D254, Your Honour.

25             THE ACCUSED: [Interpretation] Can we now see document 929 of the

Page 3292

 1     OTP.  That is my speech at this founding Assembly.  First of all, we

 2     should like to see the first page, and then if we could move on to

 3     page 4, please.  We do not have to devote any time to the entire speech.

 4     We just have to focus on the relevant segments of it.

 5             929.  Prosecution exhibit.  65 ter -- 65 ter 00929.  The Serbian

 6     version is there.  Now we need the English one.  Yes.

 7             This is the inaugural speech of the founding Assembly.  Can we

 8     now look at page 4.  Can we see page 4, please.  Actually, in the English

 9     version it is page 3, and it is all right.

10             MR. KARADZIC: [Interpretation]

11        Q.   Please take a look at this penultimate paragraph which starts

12     with "Co-existence."

13             THE ACCUSED: [Interpretation] Could you scroll up the Serbian

14     version a bit, please.

15             MR. KARADZIC: [Interpretation]

16        Q.   "Co-existence has also created some permanent values which the

17     Serbian Democratic Party will nurture and develop.  In that sense, the

18     party shall be open to co-operation" - can we please go to the next page

19     in the Serbian version - "with all democratic organisations in the

20     republic and the country.  We can cannot and shall not co-operate with

21     parties which have even the slightest trace of anti-Serbianism,

22     anti-Yugoslavism, anti-Semitism, and anti-democracy in their programme or

23     dealings.

24             "The name the party is its most complete and its most correct

25     legitimacy.  It is the party of the Serbs in Bosnia and Herzegovina.  It

Page 3293

 1     is a democratic party which will work in the interests of the Serbian

 2     people and citizens and thereby also in the interests of all peoples and

 3     citizens in our region."

 4             Did you notice or did you know, were you aware, of this speech of

 5     mine?

 6        A.   Yes.

 7        Q.   Thank you.  Do you agree that Izetbegovic's standpoint voiced on

 8     the 26th of March to the effect that he would not even talk to parties

 9     that were in favour of dismantling Yugoslavia and his statement that he

10     was in favour of a modern federation, and that this part of my speech, of

11     my programme, were good foundations for a future coalition of these two

12     national parties?

13        A.   As I indicated earlier, I'm not aware of that specific statement

14     from 26th of March.  I am aware that he embraced something in the

15     language that was close to -- I think it was a -- a modern state or a

16     modern -- it could have been modern federation.  It -- I've never been

17     able to figure out exactly who you had in mind with that phrase that you

18     would not -- and would not co-operate with parties who have the slightest

19     bit of anti-Serbian, anti-Yugoslav, anti-Semitic and anti-democratic

20     inclinations.  That seemed to me a wide barn door which could be

21     interpreted by just about anybody to encompass all sorts of parties that

22     you planned not to co-operate with.  It's very open.

23             But I think with the exception of that statement which leaves me

24     a bit puzzled, this was indeed a sound basis for co-operation with the

25     SDA as a partner party.

Page 3294

 1        Q.   Thank you.

 2             THE ACCUSED: [Interpretation] Can we see page 3, paragraph 2 in

 3     the Serbian version.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   And until that is called up, can I remind you that we already had

 6     the Croatian Party of Rights in Zagreb, in Croatia, which inherited the

 7     traditions of the Party of Rights from the Ustasha times, which actually

 8     engender the Ustashas.  Actually, it was the Croatian Party of Rights

 9     that had engendered the Ustasha movement prior to the Second World War, a

10     fascist movement which actually created the Independent State of Croatia.

11             MS. EDGERTON:  Your Honour.

12             JUDGE KWON:  Yes, Ms. Edgerton.

13             MS. EDGERTON:  That's comment by Dr. Karadzic.

14             JUDGE KWON:  Yes.  I've been wondering who's giving evidence.

15             MR. KARADZIC: [Interpretation]

16        Q.   Do you recall, do you agree that the Croatian Party of Rights had

17     set up the Ustasha movement which was at the helm of the independent

18     State of Croatia?

19        A.   No.

20        Q.   Do you agree that the Croatian Party of Rights was restored and

21     that its work was revived in the 1990s, in the early 1990s, in Croatia?

22        A.   There was a political group that was formed called the Croatian

23     Party of Rights that claimed the heritage of the earlier Croatian Party

24     of Rights.  I don't know that it -- we could say it was revived.  It was

25     formed, I would think, anew and claimed those -- that tradition.

Page 3295

 1        Q.   Do you agree that that Croatian Party of Rights again restored

 2     the demands for the -- for the restoration of the Independent State of

 3     Croatia, which would include Boka Kotorska, Srijem and other territories

 4     that it previously included?

 5        A.   I -- to be that specific, I don't know.

 6        Q.   But they published this map, and they said they were reviving the

 7     work of the Croatian Party of Rights upon the same programme.  Do you

 8     agree that the basis for the Croatian Party of Rights is Ante Starcevic's

 9     ideology?

10        A.   In part, yes.

11        Q.   Do you agree that the new, just like the old, Croatian Party of

12     Rights was markedly anti-Serbian, anti-Yugoslavian, and anti-Semitic?

13        A.   No.

14        Q.   Do you agree that the Ustashas were anti-Yugoslav, anti-Serbian,

15     and anti-Semitic?

16        A.   Yes.

17        Q.   You recall you confirmed that we even had certain doubts in

18     respect of President Tudjman when he said that he was happy, that he was

19     fortunate that his wife was neither Serbian nor Jewish?

20        A.   We confirmed that statement, yes.

21        Q.   In the light of that, does this position that we will not

22     co-operate with anti-Serbian, anti-democratic, anti-Yugoslav,

23     anti-Semitic parties, does it now seem justified to you in that speech

24     which we saw?

25        A.   I don't know if it's justified or not.  I simply said I really

Page 3296

 1     don't know what you meant by it.

 2        Q.   But is it clear now when I point out the fact to you that there

 3     existed an even more extreme and even more rightist party than the

 4     Croatian Democratic Union was, and that we could expect that even more

 5     right-wing parties would be formed, and that we had the right to say with

 6     whom we would not be co-operating because we had before our eyes the

 7     existing examples, and the HDZ was partly an a party of that ilk?

 8        A.   Well, as I read it, it looked to me like it opened the door for

 9     you to say you would not co-operate with just about anybody that you

10     chose not to co-operate with.  It was a wide-open designation, and you

11     reserved the right to label any group that you found to be so with one of

12     those labels.

13        Q.   Thank you.  Would you co-operate -- would you have co-operated

14     with a party of anti-Serbian, anti-Yugoslav, anti-Semitic,

15     anti-democratic orientation?  Or any such exclusivist orientation, would

16     you have co-operated, in our shoes, with them?

17        A.   Well, I don't know.  I -- I think you -- when I first read this,

18     I thought you were referring to the League of Communists with your

19     anti-democratic statement.  I would have no trouble co-operating with the

20     League of Communists if I had been in your situation at that time.  But

21     again, I don't know who you meant here, and it seemed to me to leave the

22     door wide open.  So I really couldn't give you a meaningful answer to

23     that question without delving into exactly who you considered anti-Serb,

24     anti-democratic, anti-Yugoslav, or anti-Semitic.

25        Q.   Can I read out for you the second paragraph on page 3.

Page 3297

 1             "The basic -- the basic aim of the party's full and unconditional

 2     civil, national, cultural, religious, and economic equality of the Serbs

 3     in Bosnia-Herzegovina.  We cannot have leading and auxiliary peoples,

 4     first-rate and second-rate citizens, constituent and unconstituent

 5     elements."

 6             It is the second page in the English version.  And we shall see

 7     what Mr. Zulfikarpasic had to say about this, about whom you know quite a

 8     few things.  But let us conclude.  Is this a decent and acceptable

 9     programme and speech at the founding Assembly of this party?

10        A.   I would only be troubled by the degree to which you suggested

11     that the Serb Nation is such an integrated, delineated, highly

12     identifiable group, and furthermore, by the degree to which you saw the

13     previous couple of decades as injuring, depleting the welfare of the Serb

14     people that you postulated as existing.  That seemed to me to open the

15     door to recriminations and blame pointing that would not be constructive

16     in the course of a political party's life.  That observation is -- really

17     goes to the kind of, let's say, concept that you had at that point

18     already of an integral Serbian people and set out about assessing its

19     welfare based on standards that you applied from your own experience

20     and -- and views.  I find the list of objectives of the party to be,

21     again, I have not read through all of them, but those that I have seen

22     here look to me to be laudable.

23        Q.   Thank you.  And was the Serbian people in Yugoslavia, whatever it

24     was called, was it integrated into a single state, that it was already an

25     achievement, it was something that had already been achieved?  It was not

Page 3298

 1     something that I had to accomplish in 1990.

 2        A.   I'm sorry, what's the question?

 3        Q.   You mentioned that I was in favour of integrating the entire

 4     Serbian nation.  Was the entire Serbian nation integrated in Yugoslavia

 5     in 1918 when it entered Yugoslavia as a unitary kingdom?

 6        A.   Well, I don't think it's -- that those who identify themselves as

 7     Serbs have ever been as integrated, distinct and compact as you suggest

 8     they were at that time.

 9        Q.   I don't understand what you want to say.  What I want to say is

10     this:  In 1918, all Serbs, Croats, Muslims, Slovenes lived in one state

11     through integration, integration with themselves and with other peoples;

12     right?

13        A.   No.  There were a good number of Croats living outside of the

14     Trianon kingdom.  There were -- or the Kingdom of Serbs, Croats and

15     Slovenes.  There were many Muslims living outside that polity, Slovenes

16     in Austria and Italy.  Were they -- were the bulk of those people, the

17     most of those who identified themselves as such residents of the new

18     Yugoslav state or the Kingdom of Croats, Slovenes -- Serbs, Croats and

19     Slovenes, yes, they were, but I wouldn't call them integrated in the

20     sense that they didn't live anywhere else or that they were all compactly

21     joined together in a single polity.

22        Q.   Thank you.  Well, the facts are different to what we're saying.

23     It was a united country that was later divided into banovinas; right?

24     But it remained a unitary state until 1945 or, rather, 1941; it was a

25     unitary monarchy.

Page 3299

 1        A.   Well, maybe it's quarreling with the term, but I think that very

 2     soon as the kingdom -- in the history of the kingdom, the rejection of

 3     much of the Croatian political elite of the form that the state had taken

 4     would bring that into question.

 5        Q.   Thank you.

 6             THE ACCUSED: [Interpretation] I'd like to tender this document

 7     into evidence.  First of all the programme, the platform; and second, my

 8     inaugural speech at the SDS party.

 9             JUDGE KWON:  I think we have already admitted the programme and

10     then we'll admit this speech, which is of three pages, I take it.  Yes.

11     We'll admit it.  Give the number.

12             THE REGISTRAR:  As Exhibit D255, Your Honour.

13             MR. KARADZIC: [Interpretation]

14        Q.   May we back to page number 4 in Serbian to show you that there

15     was co-operation with the Communists and that there was no revanchism.

16     If you omitted to see that, I just wanted to point that out to you.

17     There was no revanchism.  Do you accept that?

18        A.   Yes.  I agree there was no expression of revanchism here.  I

19     didn't suggest there was.  I simply said that in terms of the party, the

20     League of Communists, that it may have been among those that would have

21     been referred to in parties that you had no intention of co-operating

22     with.

23             But I agree with your statement.  There was an open expression by

24     you here of the openness of the SDS to those members of the League of

25     Communists or people who had been members of the League of Communists to

Page 3300

 1     join the SDS if they subscribed to its programme.

 2        Q.   Thank you.  But just to see that we didn't dispute their right to

 3     have their party, and if we look at this paragraph there won't be any

 4     revanchism or anti-communism.  We don't question anybody's right to

 5     political life, to the electoral campaign and participation in the

 6     government.  Furthermore, the party will be open to all democratically

 7     minded Communists, Socialists, and other parties who accept the programme

 8     of the Serbian Democratic Party, et cetera, et cetera.

 9             So we tried to deal with the ideological differences and even

10     them out.

11             THE ACCUSED: [Interpretation] I think we're finished with that

12     document now.  Thank you.  It can be removed from the screen.

13             MR. KARADZIC: [Interpretation]

14        Q.   Now, Mr. Donia, do you agree that the pre-electoral campaign

15     evolved in a tolerant atmosphere for the most part, without any excesses

16     or incidents or impediments?

17        A.   For the most part, yes.

18        Q.   Do you remember that the only thing that we at the time demanded

19     was a different designing, if I can use the term, of the municipalities

20     and the municipal communities?

21        A.   That certainly is not the only thing that you were demanding.  I

22     think it was part of -- it played a role in the electoral campaign and

23     was certainly a part of the general critique of the Communist era that

24     was part of the electoral campaign targeted specifically against the

25     League of Communists party.

Page 3301

 1        Q.   Thank you.  Now, did you happen to note a moment ago in the

 2     programme that we were in favour of abolishing the maximum land holding

 3     and that that existed in Communist Yugoslavia, the land holding maximum

 4     which meant that a household could not have more than ten hectares of

 5     land?

 6        A.   I did note the provision in the platform, yes.

 7        Q.   And do you agree that that was most detrimental to the Serbs

 8     because they were mostly an agricultural people in Bosnia-Herzegovina?

 9        A.   No.

10        Q.   And do you agree that it was mostly the Serbs who lived, mostly I

11     say, in the rural areas, whereas the Croats and Muslims, especially the

12     Muslims, lived in urban areas, in the towns?

13        A.   No.

14        Q.   Very well.  We can prove that very easily.  But do you agree that

15     the new power and authority in all the republics abolished this communist

16     restriction of land holdings to ten hectares and that after that

17     everybody could have as much land as they wanted?

18        A.   I don't know about all the republics, no.

19        Q.   Thank you.  I'm sure you remember and know that we were

20     victorious at the elections.  We beat all the three national parties, the

21     former Communists, rallied in the Reformists and Socialists, and we

22     managed to realise our coalition platform; right?

23        A.   I think it's accurate to say that the three national parties won

24     the election and won it at all levels and in most municipalities.  The

25     former Communists in the form of the Social Democratic Party and the

Page 3302

 1     Reformists did well in certain areas and prevailed, for example, in the

 2     municipality of Tuzla and in -- they did well in Novi Grad, the

 3     municipality of Sarajevo.  The -- so, yes, there was a victory.  Yes, it

 4     was convincing, but it wasn't universal.

 5             The term that I believe you preferred to use at the time was not

 6     coalition platform but, rather, a partnership of three parties, and that

 7     partnership rested largely on respecting the inter-party agreements that

 8     had been reached verbally during the campaign period, and then there were

 9     some actual agreement in writing that inter-party agreements being an

10     agreement to divide offices in each municipality and at the republic

11     level according to the percentage of votes that each of the national

12     parties received.  Those inter-party agreements completely excluded the

13     20 to 25 per cent of those elected in the election of 1990 who were a

14     part of what was called the opposition.  So they were both distributive

15     and exclusionary.

16             JUDGE KWON:  Mr. Karadzic, the Chamber is minded to take a break

17     earlier than usual, if it is convenient.  We'll break now.  Twenty-five

18     minutes.

19                           --- Recess taken at 3.26 p.m.

20                           --- On resuming at 3.54 p.m.

21             JUDGE KWON:  Yes.

22             THE ACCUSED: [Interpretation] Thank you.

23             MR. KARADZIC: [Interpretation]

24        Q.   Mr. Donia, I'm not going to ask you whether you vote for the

25     democrats or republicans, but I see that you feel sorry for our left

Page 3303

 1     wingers, for us not including them in executive power.  Now, do you --

 2             THE INTERPRETER:  Could Mr. Karadzic repeat his question, please.

 3             JUDGE KWON:  Mr. Karadzic, did you note that?  Could you repeat

 4     your question.

 5             THE ACCUSED: [Interpretation] Yes, yes.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   I said that I see you feel sorry for our left wingers, for not --

 8     for us not including them in executive power, but I'm sure you'll agree

 9     that the elections are there to change the powers?

10        A.   Well, some elections change power and some keep it the same.

11        Q.   I'd like to ask you what you meant when you said that we excluded

12     the left-wing parties.  Do you hold that against us?

13        A.   I referred to the inter-party agreements and pointed out that the

14     inter-party agreements as they were struck and carried out were

15     exclusionary in that they excluded from power the Social Democratic

16     Party, League of Communists, and the Reformists and other small parties

17     that won a few seats here and there and that that was -- well, it meant

18     that there was a -- an opposition which became known as the left

19     opposition but, in fact, included parties that were of quite different

20     orientations.  The Reformists really were not a leftist party as much as

21     they were a Reformist Party.  So the agreements did, in fact, mean that

22     the three national parties together monopolised control of power at the

23     republic level, the level of the city of Sarajevo, and in almost all

24     municipalities.

25        Q.   Thank you.  But you're not disputing the fact that these parties

Page 3304

 1     gained their place in legislation and all the boards, the Municipal

 2     Boards.  I mean, the opposition parties; right?

 3        A.   I believe they were excluded from the municipal executive organs.

 4        Q.   From all the executive organs at the level of the republic and at

 5     the level of the municipalities, because they lost power.  But they did

 6     take part in legislative power; right?

 7        A.   In those -- in those areas where they had representatives in the

 8     Municipal Assemblies, yes, they did.  And note the one exception of Tuzla

 9     and, I believe, originally -- was it Vares where they actually did very

10     well also, and I think briefly had a role in the executive of Vares

11     municipality.

12        Q.   Thank you.  Now to move on -- well, before we move on I'd like to

13     go back to your origins of Republika Srpska, page 9, where you say that:

14             "The new constitution according to Serbia -- [In English] New

15     constitution gave additional powers to the president of the republic,

16     including powers -- power to command armed forces in peace and war."

17     [Interpretation] [No interpretation].

18             "[In English] It assured the centralisation of the Serbian

19     Republic by eliminating the autonomy formerly enjoyed by Kosovo and

20     Vojvodina."

21             [Interpretation] Do you agree that Vojvodina and Kosovo, up until

22     1974, had one type of autonomy?

23        A.   They were named autonomous.  One was an autonomous province, one

24     was an autonomous region, and, yes, they enjoyed some degree of autonomy.

25        Q.   Do you agree that with the 1974 constitution they were given a

Page 3305

 1     further degree of autonomy, right up to the fact that they were able to

 2     control Serbia and their legislative power?

 3        A.   They weren't able to control Serbia, but they were given added

 4     autonomy by the 1974 constitution.  As we indicated yesterday, they

 5     acquired many of the characteristics of a republic in the -- in federal

 6     organs.

 7        Q.   Do you remember that Serbia was not able to enact certain laws

 8     until it had the agreement of the Assemblies of Vojvodina and Kosovo?

 9        A.   Up until their -- either the -- as in the case of the Assembly of

10     Kosovo, it was abolished, or in the case of Vojvodina, up until the

11     period of the new constitution, that is 1989, I believe, 1990, that was

12     indeed the case, yes.  I just want to be clear about the time-frame we're

13     talking about, from 1974 to 1990.

14        Q.   Yes.  Now, when in 1989 and 1990 this situation was changed with

15     the constitution, was autonomy abolished or just part of the added rights

16     that they gained under the 1974 constitution?  Were just those abolished?

17        A.   The main components of autonomy were abolished but not all.

18        Q.   And would you agree that even given that situation, that

19     Vojvodina and Kosovo had more autonomy than they had before 1974?

20        A.   No.

21        Q.   Was there less autonomy they had up until 1974 then -- before

22     1974.

23        A.   Yes.  I understand the question, and I have the impression that,

24     yes, they did have less, but if you were, you know, to ask me in what way

25     and specifically what, I couldn't tell you.  So I think my best answer

Page 3306

 1     would be I don't know.

 2        Q.   Thank you.  Now, if I tell you that the aim and intentions

 3     achieved with the 1990 constitution was that Serbia could enact laws

 4     throughout its territory, laws relating to the whole of its territory,

 5     that that was the pivotal point of that constitutional amendment and not

 6     the abolishment of autonomy, would you agree with that?

 7        A.   Well, I would say that the primary purpose and consequence of the

 8     constitution of 1990 was centralisation of Serbia, and that included

 9     dramatically reducing the autonomy that the two areas had enjoyed from

10     1974 to 1990.  I think its primary purpose was to create a more

11     centralised governance, which is in accord with what you just proposed.

12        Q.   Thank you.  But it's not all the same is it, Mr. Donia, I'm sure

13     you will agree, whether autonomy was abolished or whether what was

14     abolished was the exaggerated rights of the provinces to control the

15     legislature and legislative activities of Serbia.  And do you think, for

16     example, that in New Hampshire, if New Hampshire were to make a decision

17     to -- could it stop the functioning of Congress, for example, if it took

18     it into its head to do that?

19        A.   Texas, maybe, but I think the point of this is that the

20     centralisation inherently means reducing autonomy of those parts of the

21     state that the previously enjoyed it.  That would be the case anywhere.

22     And you have stepped into the dispute.  That is, there are residents of

23     Kosovo and Metohija, at least the Albanian residents of Kosovo would

24     argue that these were rights that they were entitled to and were now

25     being denied to them in 1990, and Serbs would say the opposite.  It's

Page 3307

 1     contested.

 2        Q.   Thank you.  I just want to say that we don't see eye to eye

 3     there, that autonomy was abolished.  It was reduced with respect to what

 4     was accorded in 1974, but what I'm saying is that even after that, the

 5     provinces had more autonomy than they had prior to 1974.  But if you

 6     don't agree with that, we'll go on to prove and show that in due course.

 7             Do you agree -- well, you said that no agreement had been signed,

 8     but do you agree that the criteria had been adopted for the distribution

 9     of power and authority among those three parties?

10        A.   Yes.

11        Q.   And do you also agree that a principle was established according

12     to the number of votes or seats in parliament, municipal and others, that

13     that was the numerical criterion that was to be respected?

14        A.   Yes.  That is the case, but the -- my understanding of the

15     inter-party agreement was that certain percentages were awarded that were

16     approximations of the votes received or the delegates won by each party.

17     So the leading party, the first party, got, I believe, the president of

18     the Assembly, the Municipal Assembly, or in the case of the republican

19     government, the president of the Presidency, and so on.  There was a

20     hierarchy created among the three parties which pertained -- which was

21     based on the number of delegates elected from -- in each municipality and

22     at the republic level.

23             THE ACCUSED: [Interpretation] Thank you.  May we now have on

24     e-court 1D93 -- 1392, 1392, please.  Just to have a quick glance at those

25     criteria which were binding upon us.

Page 3308

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Now, do you remember that at lower levels down the chain, if the

 3     chief of a security station was from one party, then the police commander

 4     would be from another party?

 5        A.   First to this document, yes, this is indeed the percentages

 6     agreement that the three parties reached.  I believe this document was

 7     dated December, after the elections were complete, but was clearly the

 8     basis or the result of earlier discussions and agreements.

 9             I became aware of this document, I believe, after I had prepared

10     the origins of RS report, but have been aware of it for some time since

11     then.

12             The key question, in fact, was the issue of who got the chief of

13     police position and who got the chief of the police station job, and then

14     there was a third position, I believe it was head of traffic police or

15     something like that, that entered into the formula.  And, in fact, while

16     that was the most important set of offices to be divvied up according to

17     the agreement, it, in fact, was invoked in a wide variety of other

18     positions in the government and in the -- the government of the republic

19     and in the municipalities.

20        Q.   Thank you.  May I read something to you.  Well, the party that

21     won 5 per cent gets a vice-presidency position, which is on a volunteer

22     basis, not paid.  And from 5 to 10 per cent --

23             MS. EDGERTON:  If I may, Your Honour.  Before Dr. Karadzic begins

24     to read from the document, it's 65 ter number 18514, I'm informed, and

25     the translation of the document should be available within about seven

Page 3309

 1     seconds, I hope.

 2             JUDGE KWON:  Okay.

 3             THE ACCUSED: [Interpretation] Thank you.  That would be better.

 4     I had counted upon Mr. Donia understanding Serbian, so that's why I did

 5     that.

 6             MS. EDGERTON:  It might be about 30 seconds.  I may have

 7     underestimated.

 8             JUDGE KWON:  It's coming.

 9             MS. EDGERTON:  Yes, indeed it is, Your Honour.

10             THE ACCUSED: [Interpretation] May we just have the page in

11     English first, please.

12             MR. KARADZIC: [Interpretation]

13        Q.   So from 5 to 10 per cent, one vice-presidential volunteer

14     position, and one position in the executive government; right?  Then from

15     15 to 20 per cent -- other, rather, from 11 per cent to 20 per cent

16     there's a vice-presidential place, a professional, and one department.

17     From 21 to 32 per cent, one vice-presidential place to be filled by a

18     professional in two departments.  From 33 per cent to 50 per cent the

19     stronger side can choose first, either to be president of a municipality

20     or president of the other sector.  That's the municipal government;

21     right?

22        A.   Yes.  And I do hope you'll go on and read:  "Napomena lijeve

23     stranke se ne uzimaju u obzir."

24        Q.   Well, we'd had enough of them for 45 years, in actual fact.  Do

25     you agree that we had enough of the left-wing parties by that time?

Page 3310

 1             JUDGE KWON:  Excuse me, what Dr. Donia said was not translated.

 2             THE WITNESS:  Okay.

 3             JUDGE KWON:  And unfortunately I checked it myself, but there

 4     seems to be no English translation.

 5             MS. EDGERTON:  Actually, my colleague has to -- I think they know

 6     what to do, Your Honours.  Something technical involving re-releasing the

 7     document so that my colleague Mr. Reid can attach the translation to it.

 8             JUDGE KWON:  Thank you.

 9             THE INTERPRETER:  Note:  The left-wing parties are not taken into

10     account is what it says.

11             MS. EDGERTON:  In fact, as I've seen how fast these two are

12     working, my respect for them has risen commensurately.

13             THE ACCUSED: [Interpretation] Mr. Donia said that the note at the

14     bottom says that the left-wing parties are not taken into consideration,

15     and my answer to him was that we had them for all of 45 years and that

16     we'd had enough of them.

17             MR. KARADZIC: [Interpretation]

18        Q.   And do you agree that 45 years of a leftist monopoly was quite

19     enough?

20        A.   You sound like you're still bitter.

21        Q.   Well, no.  I was a dissident, but the fact remains that the

22     people decided to elect another government.  Do you agree?  A different

23     government.

24        A.   Well, the electorate voted for the three national parties, first

25     and foremost; but it was the decision of the three national parties

Page 3311

 1     working together to exclude the League of Communists and other parties

 2     that were -- made up the left opposition, which was in contradiction to

 3     what you had stated at the founding Assembly of the SDS, that the members

 4     of the League of Communists were free to participate in the government.

 5        Q.   All right.  They all could participate in the government, but our

 6     standpoint was that there would be no revanchism, that there would be no

 7     lastration [as interpreted].

 8             THE ACCUSED: [Interpretation] Can we now see the next page.

 9             MR. KARADZIC: [Interpretation] Do you agree that this is there

10     where the -- where two parties had won at the elections and came to

11     power?  And on the next page we have three parties sharing the power.  So

12     the first page we had power sharing by two parties in West Herzegovina.

13     There were the Muslims and the Croats.  There were no Serbs there.  Do

14     you agree with that?

15        A.   Yes, okay.  So just to clarify, one page - I'm not sure which

16     one - addresses a situation in which three parties, all three national

17     parties, won certain numbers of votes, and the other is if only two

18     parties competed essentially and won votes in a municipality.  Is that --

19     I think that's what I'm seeing.

20        Q.   Thank you.  That is right.

21             THE ACCUSED: [Interpretation] Can we see the next page in the

22     English version.

23             MR. KARADZIC: [Interpretation]

24        Q.   These are also mixed communities with all the three ethnic

25     communities participating, and all the three parties made it to the

Page 3312

 1     municipal parliament.

 2             JUDGE KWON:  I'm afraid that we don't have the translation of the

 3     second page.

 4             THE ACCUSED: [Interpretation] All right.  I move to tender this

 5     document.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Mr. Donia, until that is done, do you agree that this was an

 8     agreement struck by the parties who had won over 80 per cent of the seats

 9     in the respective government bodies?

10        A.   I think about 80 per cent is right.  I'm not too sure it quite

11     got to 80 per cent, but in some municipalities it got to more and in some

12     nowhere near that.

13        Q.   Thank you.  But at the republican level it was approximately

14     80 per cent; right?

15        A.   Yes.

16        Q.   Thank you.  Do you remember that immediately following the

17     elections I proposed that in order to ease political tensions that an

18     expert government rather than a party government be formed?  Government

19     of experts.

20        A.   Yes.

21        Q.   And as, you know, this was not accepted.

22        A.   That's correct.

23        Q.   Do you agree that the Serbian Democratic Party adhered to that

24     position and delegated to the government at the central level experts

25     except for one party person.  So those people were not, with the

Page 3313

 1     exception of Mr. Ostojic, party people.

 2             Let me remind you.  Mr. Ostojic was a member of the party and the

 3     president of the Executive Board, and the other members of the cabinet

 4     were not members of the Serbian Democratic Party.  Do you agree with

 5     that?

 6        A.   I don't recall.  I know there were 18 ministers appointed

 7     altogether, and something like a third of them were appointed by the SDS.

 8     I don't remember how many were party members.

 9        Q.   Let me try to jog your memory.  There were 18 ministers, but

10     there were also deputy ministers in all 36 members of the government,

11     because the deputy minister is also a member of the government; right?

12        A.   Yes.  It -- the term "government" being the equivalent of what in

13     the United States is the cabinet or in European systems is the council of

14     ministers.

15        Q.   Yes.  Thank you.  Do you remember that where the minister was a

16     Serb -- or, rather, from the SDS, the deputy minister was either from the

17     HDZ or the SDA and vice versa?

18        A.   Yes.

19        Q.   Thank you.  Do you remember that the vice-premier on behalf of

20     the SDS was Dr. Miodrag Simovic, who was not a member of the SDS?

21        A.   Yes.  Dr. Simovic being a constitutional lawyer, I believe, at

22     that time and today.

23        Q.   In the previous regime he had been persecuted, and he was on the

24     slate of the Serbian Democratic Party.  Do you remember that the minister

25     of justice was Ranko Pejic, who had also been a minister in the previous

Page 3314

 1     regime and who had also been persecuted?

 2        A.   I don't know anything about any prosecution or persecution of

 3     either Dr. Simovic or Mr. Pejic.  I just know that they were in the

 4     positions that you indicated.

 5        Q.   Can I give you a summary.  Miodrag Simovic was the vice-premier,

 6     Momcilo Pejic was in the finance department.  Perhaps you have a list.

 7     Perhaps the OTP has a list.

 8             JUDGE KWON:  Yes, Ms. Edgerton.

 9             MS. EDGERTON:  Your Honour, I don't have a list, but with

10     respect, I would suggest that it's inappropriate for Dr. Karadzic to be

11     delivering a summary.  It would -- if he has something to ask of

12     Dr. Donia in respect of these individuals, it would best be in the form

13     of a question.

14             JUDGE KWON:  Agreed.

15             THE ACCUSED: [Interpretation] Thank you.  I thought that would be

16     more expeditious.

17             MR. KARADZIC: [Interpretation]

18        Q.   Do you remember that Momcilo Pejic was the finance minister and

19     he was not a member of the Serbian Democratic Party?

20        A.   I remember that he was appointed Finance Minister.  I don't know

21     what his relationship to the democratic -- Serb Democratic Party was.

22        Q.   Do you remember that both Pejics, Momcilo Pejic and Ranko Pejic,

23     had been ministers in the preceding period, in the Communist period?

24        A.   No, I don't recall that.

25        Q.   Do you remember that the deputy minister of health was

Page 3315

 1     Dr. Tatjana Starovic-Medan and that she was not a member of the SDS?

 2        A.   I do recall that she was deputy minister of health, but again I

 3     don't know anything of her relationship to the SDS.

 4        Q.   Thank you.  Do you remember that Professor Branko Djeric was a

 5     minister for development, I believe.  He was not a member of the SDS, but

 6     he was a member of the political council as a nonparty member, nonparty

 7     person.

 8        A.   I'm familiar with Professor Djeric's biography later on in the

 9     war.  He was, I believe, prime minister of the government of the RS, but

10     I don't know of his relationship to the SDS at the time that he assumed

11     this ministerial position.

12        Q.   Thank you.  Do you remember that the agriculture minister was

13     Professor Milivoje Nadazdin, who also was not a member of the SDS?

14        A.   No.

15        Q.   If I tell you that they all were eminent experts in their

16     professions and were not members of the SDS, this is something that you

17     will not challenge.  I mean, you have no information to the contrary.

18        A.   I have no information about it.

19        Q.   Do you recall that leading the slate of the Serbian Democratic

20     Party in the Sarajevo electoral district was the president of the

21     cultural society Prosveta, Professor Maksimovic, who at that moment was

22     not a member of the SDS and was ipso facto a nonparty person?

23        A.   You seem to be qualifying that.  I remember Professor Maksimovic

24     as an SDS member from very early on, and perhaps he was not at that

25     moment, but I think he became a member very soon.

Page 3316

 1        Q.   You are right.  Do you remember that Milan Trbojevic was among

 2     the first six and that he never actually became a member of the SDS and

 3     he was a deputy to parliament?

 4        A.   That I didn't know.

 5        Q.   Thank you.  Do you remember that in the Banja Luka electoral

 6     district the -- leading the slate was Vojo Kupresanin, who was the head

 7     and founder of a small party, the Homeland Front, which joined up with

 8     for the needs of election, for the purpose of the election?

 9        A.   Do I remember he led the slate?  I do remember that, and I know

10     of the Homeland Front.  I know that the Homeland Front was active in the

11     Banja Luka area.  I was not aware that he was the head and founder of it.

12        Q.   Do you remember that Mr. Vitomir Zepinic was the deputy minister

13     of the interior and that was never a member of the SDS?

14        A.   Yes.

15        Q.   Do you accept that none of the chiefs of security services

16     centres -- no.  Let me begin this way:  Do you know what security service

17     centres were in contrast to station -- public security stations?

18        A.   No.

19        Q.   Security stations exist in every municipality, whereas centres

20     are at the level of a number of municipalities; right?

21        A.   I -- I have no reason to doubt that.

22        Q.   Thank you.  Did you -- you did properly notice that there was

23     quite a struggle around those positions.  Did you notice that there were

24     many contenders for those positions in Banja Luka and there --

25             THE INTERPRETER:  I'm sorry, the interpreter is unable to follow

Page 3317

 1     Mr. Karadzic.  Could he please slow down.

 2             JUDGE KWON:  Mr. Karadzic, the interpreters were not able to

 3     follow you, so could you slow down and then repeat what you just said.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   So in Banja Luka there were two streams contending to appoint two

 7     honourable people, Jevto Jankovic was a judge and a member of the party,

 8     and Stojan Zupljanin was not a member of the party but he had experience

 9     as a policeman.  Do you remember that I, and this was published, with

10     Zepinic, actually decided that the person with the police experience

11     should be appointed to that position?

12        A.   No.

13        Q.   If I tell you now that in all the centres of security services

14     none of the chiefs of security service centres on the list on the slate

15     of the Serbian Democratic Party in both republic and state security

16     departments were members of the SDS?  Would you accept that?

17        A.   Not without further evidence of it.

18        Q.   A correction.  Simo Drljaca, in Prijedor, was a member of the

19     party, but do you know that Stojan Zupljanin was not a member of the

20     party?

21        A.   No, I don't know that.

22             JUDGE KWON:  Yes, Ms. Edgerton.

23             MS. EDGERTON:  Your Honours, two points.  This has gone on for

24     some long time now, and I'm actually completely at a loss as to what the

25     relevance of this line of questioning might be.  And the second is about

Page 3318

 1     the formulation, in fact, of these questions, Your Honour.  I've risen a

 2     couple of times on the comment and evidence-giving by Dr. Karadzic, and

 3     it seems to me that every single one of these successive questions is

 4     formulated with a statement of evidence by the accused before he gets to

 5     the actual question, and I'm wondering how much longer this should go on

 6     for.

 7             JUDGE KWON:  Mr. Karadzic, the Chamber would like to remind you

 8     that only Dr. Donia's answers are evidence.  Any comment, statement, or

 9     observation by yourself at this point is not evidence.  So we would like

10     to remind you of what we said previously:

11             "The Chamber is concerned that you are not making more effective

12     use of your time for your cross-examination.  The Chamber is therefore

13     contemplating setting time limits on your cross-examination of each

14     witness which we will determine on a witness-by-witness basis and which

15     you will be required to comply with unless you can show good cause why

16     additional time is necessary.  Should you not demonstrate during your

17     cross-examination that you are seriously taking our advice, the Chamber

18     will begin to impose such a time limit."

19             So bear that in mind, and following the advice you take from your

20     legal advisors as well as the Bench, conduct your cross-examination

21     efficiently.  We'll see.

22             THE ACCUSED: [Interpretation] Thank you.  Well, possibly

23     paradoxically, I might be losing time in my attempt to gain time and

24     avoid entering into greater investigation with Mr. Donia or establishing

25     the truth with Mr. Donia.  So maybe that's the mistake I have been

Page 3319

 1     making, which is not my intention, of course.  But this line of

 2     questioning is very important for me, because it is my case that the

 3     Serbian Democratic Party won power but did not seize it but handed it

 4     over to the experts.  And that's a very important point, a landmark for

 5     many things from the pre-trial brief, and later on we'll see why.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Now, Mr. Donia, do you agree that in the executive power and

 8     authority the Serb Democratic Party did not appoint party cadres,

 9     predominantly party cadres, but cadres that it found in the various

10     services, who were already there?

11        A.   If by "party cadres" you mean party members, I think in the main

12     that was the case for the -- for the cabinet, for the government of

13     Bosnia-Herzegovina, in the main.

14        Q.   And do you agree that in the police force and in the top

15     positions we did not bring in anybody who was not already, for example,

16     in the police force and that those people weren't party members, except

17     in Prijedor?

18        A.   No, would I not agree.

19        Q.   Can you give us the name of a high-ranking police officer who was

20     a party member?

21        A.   I just simply can't accept the proposition that was the -- the

22     way that you put it to me.

23        Q.   What about Vitomir Zepinic as deputy minister, the highest Serb

24     post in the Ministry of the Interior.  Was he ever a member of the party?

25     Let's take him as an example.

Page 3320

 1        A.   Well, that was not the -- oh, the highest Serb post in the

 2     Ministry of the Interior.  To my knowledge, he was never a member of the

 3     SDS.

 4        Q.   And if I tell you that he wasn't -- that Mico Stanisic at that

 5     time was not either, or any of the chiefs of the security services, would

 6     you agree with me there, or do you have proof and evidence that that was

 7     not the case?

 8        A.   I don't know about Mico Stanisic.  I know that he was shortly

 9     thereafter a party member, but I don't know about the time that you're

10     speaking of.

11        Q.   And did you happen to notice that the leadership of the party was

12     subjected to serious criticism for having given over power and authority

13     to the experts rather than party members?

14        A.   No.

15        Q.   Thank you.  Now, do you agree that the Serbian Democratic Party

16     won the post of president of the Assembly.  The SDA had the post of

17     president of the Presidency and the HDZ the post of prime minister.

18        A.   That's how it came out.  I don't know that the -- you could say

19     that the SDS won the post of president of the Assembly.  That was a

20     product of the inter-party agreements, and the parties under the

21     inter-party agreement, the national parties, acquired the right to

22     designate those three positions because of the percentage of -- of votes

23     that had -- that they'd won at the republic level.

24        Q.   So you agree that we first of all divided up the posts and then

25     saw who the people were to fill those posts.

Page 3321

 1        A.   That -- I think that's in the main the case.  It certainly is the

 2     case with the three positions you just named at the republic level and

 3     also at the level of the city of Sarajevo.  I'm sure it was the case at

 4     many municipalities as well.

 5        Q.   Thank you.  Now, do you agree that the Ministry of the

 6     Interior -- well, that the minister post went to the SDA and the minister

 7     of defence post went to the HDZ?

 8        A.   Those two national parties did indeed designate the people for

 9     those two positions, yes.

10        Q.   Do you agree that the Serbian Democratic Party did not ask for

11     any of those positions but instead asked for the Ministry of Agriculture

12     and the Ministry of Finance?

13        A.   Yes.  Professor Koljevic, in his diary and account of that

14     particular time notes that you had decided not to seek those two

15     positions, that is, the Ministry of the Interior, Ministry of Defence,

16     because the JNA was the dominant military force in the area, so you

17     thought it was -- there was no point in seeking those positions because

18     they were of much less consequence because of the JNA's presence.

19        Q.   But do you agree that the Croats were very sensitive to the fact

20     of who was going to be minister of defence in view of the presence of the

21     JNA and that we made a concession in that regard, and that we agreed that

22     the minister of defence should be a Croat?

23        A.   I'm not aware of what negotiations may have led to those

24     designations.  I could only say, on the basis of Professor Koljevic's

25     observation, that you didn't regard those two ministries as -- as

Page 3322

 1     important to -- for the SDS to seek.

 2        Q.   Thank you.  Do you agree that the reconstitution of the Assembly

 3     in his speech, Mr. Izetbegovic's, in mid-January, still remained in

 4     favour of the preservation of Yugoslavia?

 5        A.   Yes.

 6        Q.   Do you agree that it was a surprise to one and all when, on the

 7     31st of January, Mr. Izetbegovic launched the initiative to adopt the

 8     declaration on sovereignty for Bosnia-Herzegovina?  We're now speaking

 9     about 1991; right?

10        A.   January 1991.  No, I don't think it was a surprise to one and

11     all.  I would certainly agree that he was the instrumental person in

12     launching that initiative and that the -- basically the leadership of the

13     SDA and most of the HDZ backed that initiative.

14        Q.   Do you agree that the SDS was against that and that in February

15     Mr. Izetbegovic spoke at the Assembly, and we mentioned that yesterday.

16        A.   The -- a number of SDS delegates in the Assembly spoke against

17     the proposal for the declaration of sovereignty once it had been offered

18     in the course of the discussion in, I think -- on the 27th of February,

19     yes.  You spoke, I believe, also at that Assembly for -- I think for the

20     first time in the Assembly.

21        Q.   Thank you.  You confirm that Mr. Avdo Campara, the secretary of

22     the Assembly, on the occasion confirmed that we had the right to send the

23     issue up to the council for the realisation of national equality, and

24     that it was on that basis that any further adoption of that declaration

25     was deferred?

Page 3323

 1        A.   It was -- we can see a specific ruling.  We were looking at the

 2     session yesterday, and he ruled on constitutional grounds that the

 3     application of more than 20 delegates to the Assembly would trigger the

 4     referral of the proposed legislation to that body, and that until such

 5     time as a decision was reached by that body, the measure could not be

 6     voted upon.  It could be discussed but not voted upon.

 7        Q.   Thank you.  Now, let's go back a bit.  Do you remember that on

 8     the 7th of January, 1991, in Sarajevo, the resolution of the Muslim

 9     intellectuals was made public, calling for a sovereign Bosnia.  It was

10     published on the 8th of January, broadcast in the media.

11        A.   Your Honours, you asked me yesterday if I would take advantage of

12     the opportunity to review the transcript of that session that we've just

13     been talking about.  I wonder if I could respond to that inquiry maybe at

14     this point, because we have just -- just been talking about it.

15             JUDGE KWON:  Yes, please.

16             THE WITNESS:  I don't know if it's available to bring up again,

17     the -- the transcript of the session of the 27th of February.

18             JUDGE KWON:  Is it Exhibit P969?

19             MS. EDGERTON:  In fact, Your Honours, the whole session is -- the

20     transcript of the whole session of the 27th of February is 65 ter 06291.

21             MR. KARADZIC: [Interpretation]

22        Q.   While we're waiting for that, I want to ask you:  Do you know

23     about this declaration, the resolution of the Muslim intellectuals of the

24     8th of January?

25        A.   I -- yes.  It's a long time since I've looked at it.  I don't

Page 3324

 1     recall much of what it said.

 2        Q.   And do you remember that the Presidency of the SFRY, on the

 3     9th of January, issued an order on the dissolution of all irregular armed

 4     forces and the surrender of weapons introduced in the country illegally,

 5     and that this task was to be carried out by the 19th of January, whereas

 6     Croatia asked for an extension of the dead-line by 48 hours?

 7        A.   Yes.

 8        Q.   Thank you.  We can now move on to the 27th of February.

 9        A.   The page on which this occurs is -- in the internal pagination

10     is, I believe, 27/1.

11             JUDGE KWON:  I'm only being amazed by your memory, Doctor.

12             Yes, Ms. Edgerton.

13             MS. EDGERTON:  The -- if Dr. Donia is referring to the page that

14     was displayed yesterday, that's e-court page 101 of this document, and

15     this document is not translated yet, unfortunately.

16             THE WITNESS:  Yeah.  The -- I was hoping we might go back to

17     page -- you see the 6.  Just back one page to the very bottom of page 5,

18     because I think this passage will add meaningful context to the statement

19     that Mr. Izetbegovic name -- made.  Let's see.  Yes.

20             MR. KARADZIC: [Interpretation]

21        Q.   Are you going to read it out or --

22        A.   This is your language, sir.  Starting with [Interpretation] "But

23     let me continue," beginning with that.  [In English] This --

24        Q.   I see that:

25             "But I'll continue to seek for a solution which, as I said, will

Page 3325

 1     fulfil both conditions.  In my opinion there are two minimum conditions

 2     to be filled.  First, the -- a sovereign democratic Bosnia as a whole,

 3     and the second important point is" -- may I have the next page, please.

 4     "A sovereign integral and democratic Bosnia, and a peaceful road to that.

 5     So not through a civil war and dead bodies.  The route to that Bosnia

 6     should be sought and verified, and we should launch a quest for that road

 7     and use every opportunity to advance in that direction.  Those two -- but

 8     those two conditions which I mentioned here, a sovereign and integral

 9     Bosnia-Herzegovina and a peaceful road to it, do not have the same value.

10     Because of a sovereign Bosnia, I would give up peace, but for peace in

11     Bosnia I would not give up a sovereign Bosnia.  (Applause).  Similarly,

12     because this is contentious and the subject of polemics in the scale of

13     values of Bosna Yugoslavia as a ratio, if I had to choose, BiH would come

14     first and then Yugoslavia.  That's how it stands for me.  (Applause)."

15             Is that sufficient?

16        A.   Just one more sentence, Dr. Karadzic.  I appreciate your

17     tolerance.  Just at the -- or shall I?

18             "[Interpretation] You will now have the opportunity of assessing

19     whether or not my views are something that are -- is acceptable and all

20     right and something that the Assembly stands by, and for me what is

21     particularly important -- something that is particularly important for me

22     and backed up by the citizens of Bosnia-Herzegovina but by Yugoslavia as

23     well.  It's a political and historical equality for Bosnia-Herzegovina as

24     a reality."

25             [In English] So he opens this to questions about what he has just

Page 3326

 1     said and asks for inquiries and input in a sense.  And I'd like to go

 2     down, if I could, one more page and point out that Dr. Karadzic was the

 3     next speaker after these words were spoken.  Now, I believe that is

 4     actually on the next page at the top or -- I'm sorry.  It's after this

 5     speech.  This speech goes on to page 7, 8, 9, and 10.  So it's -- it will

 6     be five pages down from where we are right now.  And below the box that's

 7     just been created, you see that Dr. Karadzic makes a brief speech, and he

 8     corrects a quote that Mr. Izetbegovic had taken from an interview that

 9     Dr. Karadzic had done with the Belgrade newspaper "Borba," but makes no

10     mention of the words that he had just heard from Mr. Izetbegovic.

11             Would you like, Your Honour, to read - it's just about a

12     page - through that speech, or is my, perhaps, testimony to that --

13             JUDGE KWON:  If necessary, Ms. Edgerton will take it up.

14             THE WITNESS:  Okay.

15             JUDGE KWON:  Mr. Karadzic, please continue.

16             MR. KARADZIC: [Interpretation]

17        Q.   That was precisely what I wanted to say, but I had nothing

18     against it because it's a fact that I always strove for having a federal

19     state and federal laws predominantly.  That's what it says here.  Thank

20     you.

21             Mr. Donia, do you remember the agreement of the 18th of March?

22     And we'll come back to that later on, but tell me first, did that

23     agreement fulfil Izetbegovic's criterion as expressed here?  Or rather,

24     two criteria that he set, an integral and sovereign Bosnia.

25        A.   I'm sorry, what agreement of 18 March?

Page 3327

 1        Q.   The Lisbon Agreement.  And all three sides, on the 18th of March,

 2     subscribed to it, that Bosnia step down from Yugoslavia, that its borders

 3     be kept, that it was integral and sovereign.

 4        A.   What you've characterised as the Lisbon Agreement, Dr. Karadzic,

 5     was an agreement in principle that was to be the basis for further

 6     negotiations, and all three national parties, represented by their

 7     leaders, subscribed to the principles but were very careful not to

 8     finalise the agreement, including you.  You were very explicit that you

 9     would not agree to anything that had not been signed, and this document

10     had not been signed.

11             So I would dispute that there was a final agreement on the

12     18th of March, 1992, and further point out that that is some 14 months,

13     13 months, after this -- these statements were made by -- by him and by

14     you in the Bosnian Assembly and that much had changed in that period of

15     time.  Many other interim agreements in principle had been reached, many

16     of them had been breached and that the situation really was radically

17     altered, both in terms of the situation on the ground and the position of

18     the primary political participants.

19        Q.   Mr. Donia, would you agree with me that two questions remain to

20     be addressed, the maps and the question of the army, on the

21     18th of March, that is.  Did we agree that we would continue our

22     discussions about the maps to determine them more precisely, that the

23     basic map was adopted as a starting point, but that what remained was to

24     discuss the map and the question of the army?

25        A.   The agreement was characterised at the time by you, by the

Page 3328

 1     EC negotiators as an agreement in principle as to be the basis for

 2     further negotiations.  What specific issues were agreed upon and not

 3     signed and what remained to be resolved, I don't know.

 4        Q.   But we proclaimed it publicly, that what remained to be done was

 5     to define the maps and to resolve the question of the army as a

 6     referendum question, that the referendum should confirm the agreement

 7     reached.  All the principles were adopted.  All that remained to be done

 8     was the map.  The map was adopted as a basis but the issue of the army

 9     was left to the end.  And that was published, it was made public,

10     completely public?

11        A.   Well, I'm sure there's documentation to the effect of what was

12     announced publicly, and there's plenty of documentation on the character

13     of the agreement in principle in the extensive discussions in the

14     11th Assembly -- the Bosnian Serb Assembly and in your own statements and

15     the statements of other leaders.

16        Q.   Was the -- was the minutes -- were the minutes adopted in total

17     or just a part of it because this was a joint Assembly?

18        A.   Are we back in 1991 now in -- in the Assembly that we're looking

19     at?

20             JUDGE KWON:  Just a second.

21             MR. KARADZIC: [Interpretation]

22        Q.   I'm talking about this text that you and I have been reading.

23             JUDGE KWON:  We're talking about a minute which is of 252 pages,

24     but our practice has been to admit it in its entirety.  So you'd like to

25     replace this with the previous one which has been already admitted?

Page 3329

 1             THE ACCUSED: [Interpretation] I don't know what has been admitted

 2     so far.  The part that I started to read, and Mr. Donia concluded, refers

 3     to Mr. Izetbegovic.  Of course, I have nothing against the entire minutes

 4     be admitted into the file.  If that is more convenient for the Chamber,

 5     the part which refers to Mr. Izetbegovic's words, what he said.

 6             JUDGE KWON:  We'll admit it being marked for identification.

 7             MS. EDGERTON:  Your Honour, may I just offer something that might

 8     assist --

 9             JUDGE KWON:  Yes.

10             MS. EDGERTON:  -- the Trial Chamber.  Subject to what

11     Dr. Karadzic, of course, and Dr. Donia say, the passage at which

12     President Izetbegovic begins speaking is at page 96 of this

13     65 ter number 06291, and it ends at page 105.  And in terms of the

14     translation issue, perhaps this might assist in providing Your Honours

15     and my colleagues in the courtroom with the appropriate context to be

16     able to evaluate the discussion and not unduly burden anybody.

17             JUDGE KWON:  And Mr. Karadzic's speech that followed.

18             MS. EDGERTON:  Which I can check, but I think those are the two

19     pages that follow.  So 106 and 107.

20             JUDGE KWON:  I note it's Mr. Krajisnik's speech, albeit brief.

21     With that note, we'll admit it being marked for identification.

22             THE REGISTRAR:  As MFI D256, Your Honour.

23             JUDGE KWON:  Yes, Mr. Karadzic.

24             THE ACCUSED: [Interpretation] Thank you.

25             MR. KARADZIC: [Interpretation]

Page 3330

 1        Q.   Can we now go back, Mr. Donia, to what you said before, that we

 2     should establish the causes and the consequences and their mutual

 3     relationship.  To that effect, do you recall that in the period prior to

 4     the elections and up to this moment, up to February 1991, we spoke about

 5     communities or municipalities, about the need to set up new communities

 6     of municipalities?

 7        A.   There -- yes.  There was -- you and the party had discussed

 8     communities of municipalities and establishing new communities of

 9     municipalities prior to this speech, yes.

10        Q.   Do you agree with me that that was based on the constitution?

11        A.   There -- there is -- there is a part of this question I can't

12     answer, but there was a provision in the constitution of

13     Bosnia-Herzegovina from 1974 that provided for communities of

14     municipalities to be established with the purpose of aggregating

15     municipalities for certain specific functions.

16             What I don't know is what legislation or other constitutional

17     provisions may have been involved in the creation of such communities and

18     municipalities, whether the republic Assembly had to agree to them,

19     whether the republican -- whether the republic Presidency had to agree to

20     them and what steps were required in order to establish these communities

21     of municipalities.  In fact, a number of them existed by 1990, including,

22     significantly, the Banja Luka community of municipalities, which

23     incorporated 12 or 15 municipalities in and around Banja Luka.

24        Q.   Thank you.  Can we just clarify one thing.  You know what the

25     local commune is, of course.  Do you agree this is a smaller territorial

Page 3331

 1     unit which is comprised within a municipality?

 2        A.   Yes.  I think we can say the smallest administrative unit in the

 3     republic, in fact, in most of Yugoslavia.

 4        Q.   Thank you.  Do you agree that a local commune can comprise

 5     several villages, or a large village can comprise a number of local

 6     communes?

 7        A.   Yes.

 8        Q.   Thank you.  Do you know what an "atar," which is a village area,

 9     is?  Is this the territory of a village?

10        A.   I don't know.

11        Q.   So a local commune can have a number of villages, and every

12     village has its own boundaries with their forest, their woodlands, their

13     meadows.  Do you know that?

14        A.   A couple questions there.  A local commune can include a number

15     of villages.  Normally, it did not.  Normally, a village was a local

16     commune or "mjesna zajednica," but it could have more.  And a large

17     village could consist of several "mjesna zajednica" or local communities.

18        Q.   If we imagine the boundary of a village, and the territory is

19     called in our language an "atar," do you agree that during the

20     Communists, such a territory was, for the most part, socially owned

21     property in that period?

22        A.   Yes, that's true.  Socially owned, that kind of vague category of

23     land which was not owned by any individual or enterprise but belonged in

24     some sense to the state or to the -- administered often by the local

25     municipality.  I concur with you.

Page 3332

 1        Q.   Thank you.  That means that one area, village area, or atar,

 2     belonged to that village or to that territorial unit.  The socially owned

 3     property belonging to that particular territorial unit.  Namely, that the

 4     villagers of another village were not allowed to fell wood in the atar,

 5     or in the district, the area of another village.

 6        A.   I think that socially owned land, which accounted for probably

 7     half, I think a little over half of all of Bosnia-Herzegovina, was indeed

 8     socially owned.  It was not owned by a village or a municipality or any

 9     territorial unit but was defined as socially owned land which was then

10     under the administration, if you will, if those entities.

11        Q.   Thank you.  Do you agree that the Communist regime actually

12     acquired such social ownership of property by actually seizing,

13     appropriating private property, after the revolution?

14        A.   There certainly was some of that, but this practice of common

15     lands which did not belong to any one person goes back centuries, and

16     existed in the Ottoman period in Bosnia, was a big factor in some of the

17     discussions about land reform in the Austro-Hungarian period, from 1878

18     to 1918, and also in the time of the Kingdom of Yugoslavia.  So as a

19     matter of historical continuity, it had been there a long time, but there

20     were some seizures of property that took place in the five years after

21     1945.

22        Q.   Thank you.

23             THE ACCUSED: [Interpretation] Can I just ask for 65 ter 18514.

24     That is the power-sharing criteria for power sharing between these three

25     parties.  And can I also ask for a map of Bosnia-Herzegovina with

Page 3333

 1     municipal boundaries drawn up.  The number of the map is number 2.

 2             JUDGE KWON:  I think we haven't assigned the number for the

 3     documents regarding criteria, so we'll give it number -- marking for

 4     identification pending translation of the second page.

 5             THE REGISTRAR:  Yes, Your Honour.  That will be MFI D257.

 6             JUDGE KWON:  Thank you, Mr. Karadzic, for reminding that.

 7             THE ACCUSED: [Interpretation] Can we get this map.  My marks are

 8     02, namely the second map from 0701 to 0703.  That is the Karadzic maps

 9     binder.

10             MR. KARADZIC: [Interpretation]

11        Q.   Mr. Donia, until we see this -- these, do you agree that the

12     seats of communities of municipalities had administrative institutions,

13     such as the public auditing service, the tax administration, the security

14     services centre?  In other words, that it was -- that they were states in

15     a nutshell?

16        A.   No.

17        Q.   Can you tell us what your concept, how you see the seat of

18     community of municipalities?

19        A.   Well, they certainly had no -- none of the attributes of

20     sovereignty which would make them qualify as a state.  I hope there's not

21     a translation problem here, but they were not states.  They were

22     typically associations of municipalities created for specific purposes,

23     such as sewer systems and water and in some cases administrative

24     convenience of financial or administrative character.  They could indeed

25     have public auditing service units which was actually a powerful

Page 3334

 1     financial tool for directing monies.  Money didn't pass anywhere in the

 2     former Yugoslavia without going through a public auditing service.  So

 3     the name "Public auditing service" is bit misleading.  It's actually much

 4     more powerful than just auditing.  It's actually a -- almost like a

 5     regional bank.  So it could have some of those administrative

 6     institutions, but it always was a creature of the municipalities that

 7     made it up.

 8             THE INTERPRETER:  Microphone, please.

 9             MR. KARADZIC: [Interpretation]

10        Q.   If I tell you that -- and I believe it that it is Article 52 of

11     the 1955 constitution, which hasn't changed, which said that

12     municipalities had the possibility to pool into municipality communities,

13     and one of those communes would usually be the seat of that community and

14     would contain all these institutions which you, too, have now listed.  Do

15     you agree with that?

16        A.   Yes.

17        Q.   Thank you.

18             THE ACCUSED: [Interpretation] Can we please call up this map.

19     Perhaps it is map number 2, and the binder is 0701 to 0723 on e-court.

20             JUDGE KWON:  We can't seem to find, locate, the 65 ter number.  I

21     was told that it's time to take a break, and in the meantime we'll be

22     able to see the map through e-court.  Twenty-five minutes.

23                           --- Recess taken at 5.16 p.m.

24                           --- On resuming at 5.44 p.m.

25             JUDGE KWON:  Yes, Mr. Karadzic.

Page 3335

 1             THE ACCUSED: [Interpretation] Thank you.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Mr. Donia, can I ask you to cast a glance at this map and to tell

 4     us whether this is a map with the municipal boundaries of Bosnia and

 5     Herzegovina drawn in.

 6        A.   Yes, it is.

 7        Q.   Do you agree with me that the city of Sarajevo is drawn in as a

 8     single entity without the boundaries of the city municipalities

 9     indicated?

10        A.   Yes, that appears to be the case.

11             THE INTERPRETER:  Microphone, please.

12             JUDGE KWON:  Microphone.

13             THE ACCUSED: [Interpretation] Can we scroll it up a bit, please.

14     And a bit more so that we can see Trebinje on the map.  And slightly

15     more.  Thank you.

16             MR. KARADZIC: [Interpretation]

17        Q.   Mr. Donia, in the southern-most part we have Trebinje, Ljubinje,

18     Bileca, Nevesinje, and Gacko municipalities; is that correct?

19        A.   Yes, mm-hmm.  Yes.

20        Q.   Do you agree that these are municipalities with a marked Serbian

21     majority?

22        A.   As -- as I recall, they all have Serbian majorities, yes.

23        Q.   Do you remember that these are traditionally designated as

24     Eastern Herzegovina?

25        A.   Yes, they are.

Page 3336

 1        Q.   Do you agree that as part of Stolac Municipality there is a place

 2     which is called Berkovici and which used to be a municipality?

 3        A.   No.

 4        Q.   You don't know that, or you deny it?

 5        A.   You asked me if I recalled.  I do not recall.

 6        Q.   But if I tell you that Berkovici used to be a municipality and

 7     was later annexed to Stolac, would you accept that?

 8        A.   No.

 9        Q.   So you are actually denying it.

10        A.   I'm open to see evidence that that was the case and would welcome

11     doing so.

12        Q.   Thank you.  Does it sound sensible if I tell you that

13     Berkovici -- the development of Berkovici stopped altogether the moment

14     Berkovici was annexed to Stolac Municipality?

15        A.   I don't know that.

16        Q.   Thank you.  Are you familiar with the term "gerrymandering"?

17     That is from the American political lingo.

18        A.   That's a term from American political corruption, yes.

19        Q.   Yes, that is right.  Thank you for the explanation.  It's put

20     much better.  Your formulation is much better.  It consists of

21     manipulating electoral districts, constituencies, in order for a minority

22     party to win the elections and win power; right?

23        A.   Not quite, no.  The term "gerrymandering" comes from a governor,

24     Gerry of Massachusetts, in the early 19th century, who redrew electoral

25     districts in such a way to ensure his own re-election, and the district

Page 3337

 1     that he drew to ensure his own re-election looked like a salamander on a

 2     map, and so the term came to refer to efforts by an existing power holder

 3     to assure re-election usually through creating some very odd-shaped

 4     collection of electoral stations in order to marginalise or out-vote a

 5     certain group of people.

 6        Q.   Thank you very much for this explanation.  This is what Gerry

 7     did, but the gerrymandering phenomenon can be applied to all such kinds

 8     of manipulation, can it not?

 9        A.   No.  It is specifically a manipulation to ensure re-election.

10        Q.   Thank you.  Do you know to which community of municipalities

11     these Eastern Herzegovina municipalities belong and where the seat is?

12        A.   What period are you talking about?

13        Q.   Before the 1990 elections.

14        A.   No, I don't.

15        Q.   Would it occur to you that it would be natural for Trebinje to be

16     that seat, which is a well-developed city with a developed industry and

17     would naturally be the seat of those municipalities?

18        A.   Well, there might be a couple candidates amongst those

19     municipalities that you've mentioned to be the seat of a community of

20     municipalities.  I don't know specifically which one was or if there was

21     one.

22        Q.   If I tell you that all these Serbian municipalities are

23     associated, are linked up, with Mostar as their seat, would it make sense

24     to you that these municipalities had reason for dissatisfaction, because

25     Mostar was rapidly developing at their expense?

Page 3338

 1        A.   You've characterised these as Serbian municipalities, and I

 2     wouldn't accept that characterisation.  They, in fact, all had mixed

 3     populations.  They did indeed have Serb majority populations, but the

 4     towns, in particular, had quite diverse populations, at least most of

 5     them did, and had their -- it was as a unit a somewhat distinctive

 6     economic category or type of area which it was quite rural and fairly

 7     rocky terrain, a lot of agricultural productivity in it.

 8             I don't know why Mostar would be logical or illogical as a seat

 9     of a community of associations that included these municipalities.

10     Mostar, of course, is the most important, largest city in this part of

11     Bosnia-Herzegovina.  It's -- it had been at that time quite economically

12     developed, very mixed population in terms of both class and ethnicity, so

13     would be certainly a strong candidate to be a suitable centre for such a

14     community -- or association of municipalities.

15        Q.   Is not New York a good candidate for a capital of New York State,

16     and Albany is, actually, the capital?  Why would Mostar be developing at

17     a rapid pace and Trebinje be lagging behind?  Do you believe that to be a

18     democratic gain, a democratic achievement?

19        A.   I don't accept that Mostar was developing faster than Trebinje.

20     I don't have the numbers of or economic metrics to know that.

21        Q.   Yes, I can live with that, but I should like to put the following

22     fact to you:  These municipalities have a population which is over

23     80 per cent majority Serbian.  Their development was totally slowed down,

24     not to say stopped, over a number of decades.  Do you think that a seat

25     of financial power and of administrative power, of economic power,

Page 3339

 1     investment power which was in Mostar, if it had been in Bileca or

 2     Trebinje, would it have had an impact on the development of this entire

 3     region?

 4        A.   Well, that's a rather socialist way of thinking about it.  I

 5     really don't think that the issue of, let's say, putting the seat one

 6     place or the other is not necessarily going to make an impact on the

 7     development of the region.  There very well could be that the most

 8     financially and administratively developed seat would be the most

 9     desirable, because it could take advantage of all the resources available

10     to a somewhat larger city in order to develop the entire region.  So I

11     don't accept the premise that if you just plunked the seat of a community

12     of municipalities in a remote area that it would automatically lead to

13     economic development.

14        Q.   Trebinje is not in a remote area.  It is the centre of

15     Herzegovina.  Are you contesting the fact that Eastern Herzegovina

16     developed at a slower pace than Mostar, as also had other regions in the

17     Neretva River valley?

18        A.   I'm saying I don't know.  I don't have the -- I'm sure that's a

19     very knowable fact based on economic indicators.  I don't have those

20     economic indicators at hand, nor do I have an active recollection of

21     looking at them and so I can't answer the question.

22        Q.   Thank you.  I hope that next week I will be able to show you

23     something, some of these things.  Did you encircle on this map the

24     boundaries of these municipalities towards Trebinje -- or could you.

25     Could you.  Could you please encircle on this map the boundaries of these

Page 3340

 1     municipalities.

 2        A.   What?  I'm sorry, what are you asking?

 3        Q.   Could you draw a circle round the Serb community of

 4     municipalities moving towards Mostar.  Just draw them in, mark them.  The

 5     boundaries of Gacko, Nevesinje, up to Mostar, those municipalities.

 6     Circle them, to Stolac and so on.

 7        A.   I don't -- I haven't agreed that there was a community of

 8     municipalities of Eastern Herzegovina.  I have not seen evidence that

 9     there was or when it was created or anything of the kind or what

10     municipalities made it up.

11             JUDGE KWON:  Mr. Karadzic, if that was your purpose, we can

12     see -- the Judges can see the map ourselves.  We can see where Mostar is,

13     and we can see all the municipalities you referred to.

14             MR. KARADZIC: [Interpretation]

15        Q.   Yes, thank you, but do you agree that these municipalities belong

16     to the community of municipalities of Mostar?  That's common knowledge.

17     It was generally known.

18        A.   No, I don't.

19        Q.   Thank you.  Now, do you see the municipalities of Foca, Gorazde,

20     Cajnice, Rudo, Visegrad?

21        A.   Yes.

22        Q.   And do you agree that that's what we call Old or Ancient

23     Herzegovina?  The other part was Eastern Herzegovina, and this is

24     Old Herzegovina, the area from which I originate, as I said earlier on.

25        A.   Yes.

Page 3341

 1        Q.   Do you know where the seat of this community of municipalities

 2     was?

 3        A.   I don't know the -- that there was a community of municipalities.

 4     I don't know -- I know there were communities of municipalities prior to

 5     1990.  I know approximately which ones belong to the Banja Luka community

 6     of municipalities, but exactly what municipalities were members of the

 7     others and where their seats were, I don't know.

 8        Q.   If I tell you that the seat of this community of municipalities

 9     was in Gorazde, which was predominantly Muslim, and not in Foca, which is

10     larger and more developed and which was populated by a Serb majority

11     until recently or an equal ratio of the population, what would you have

12     to say to that?

13        A.   I'd want to see the documentation on its creation and see, in

14     fact, what the seat was.

15        Q.   Well, you would have to know that.  It's the subject of your

16     expert report.  You must know that, because it's a question of the

17     political history of the Bosnian crisis.  If in your report you object to

18     Karadzic's position whereby the municipalities were re-partitioned, then

19     you'd have to seek the reasons for that, why Karadzic was asking for

20     that.

21             My case is that Gorazde developed in an accelerated fashion

22     compared to Foca, and especially Cajnice, which was became -- was

23     desperate, and Rudo too, because the seat of that community of

24     municipalities and all the institutions, political, economic, financial

25     power, was situated in Gorazde, and that's what I'm putting to you.

Page 3342

 1     That's my case in this particular point, and that's why we asked for a

 2     reorganisation of the municipalities based on the constitution.

 3             Do you consider that -- do you not consider that you should have

 4     checked out what it was that Karadzic was asking for if you objected to

 5     his proposals?  Shouldn't you have looked into the matter?

 6        A.   I think I, Dr. Karadzic, described your general critique of the

 7     municipal structure.  I think I described it fairly.  I did not go into

 8     the individual municipal situations other than mentioning, I think,

 9     Ozren, which you mention numerous times in your speeches and articles and

10     interviews.

11             I, frankly, have not heard you make this case before, and I am

12     not convinced it is the case that the seat of a community of

13     municipalities would far outstrip in development the other municipal

14     seats of municipalities that are a part of that community.  First time

15     I've heard you make it and I would certainly need to be convinced that

16     that's the case.  And I think to do that you would have to look at all

17     the communities of municipalities and see what happened to their seats

18     over several decades, because the thesis is not self-evident, not

19     self-evidently true that you would get a rapid economic growth of a

20     single administrative centre of such a relatively thin administrative

21     level.

22        Q.   Very well.  We'll show that in due course and we'll come to

23     Ozren, too.

24             THE ACCUSED: [Interpretation] But can we move the map down a bit

25     now, please.

Page 3343

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Can you see where it says Srebrenica and Bratunac?

 3        A.   Yes.

 4        Q.   Now, Srebrenica and Bratunac, do they resemble a salamander?

 5        A.   Well, I don't know.  That's -- that's a judgement call.  I don't.

 6     I don't see a salamander, no.

 7        Q.   Well, with respect to gerrymandering, you mentioned salamander,

 8     and if I tell you that at the top of that horn you have Skelani, which

 9     would have developed quite properly had they been given the territories

10     which belonged to them, and the municipalities of Srebrenica and Bratunac

11     were distorted in this way.  Would you agree with that?

12        A.   No.

13        Q.   And do you know that Skelani was a municipality at one time?

14        A.   No.

15        Q.   Thank you.  Now, do you see Lopare, Ugljevik?  Do you know that's

16     where Mount Majevica is?

17        A.   Yes.

18        Q.   Do you know that on Serb territory there was a municipality

19     called Priboj, and now we can't even find Priboj on the map.

20        A.   What do you mean by "Serb territory"?

21        Q.   Well, that area was populated 100 per cent by Serbs.  That's what

22     I mean.

23        A.   What area was that again?

24        Q.   The -- well, Mount Majevica, Lopare, Ugljevik, that area, moving

25     towards Tuzla.

Page 3344

 1        A.   Well, I don't know the exact composition of those municipalities

 2     in 1991, but I do know that none of them were a hundred per cent Serb.

 3        Q.   Well, was Bosnia 100 per cent Muslim?

 4        A.   Of course not.

 5        Q.   How, then, can we justify attempts to have Bosnia become

 6     independent when it's not even 50 per cent Muslim, whereas here your

 7     criterion is you're questioning Majevica as being 100 per cent Serb?

 8     Priboj was almost 80 per cent Serb and the municipality was abolished.

 9        A.   Well, I note you've exaggerated the number or the percentage in

10     the first time you asked me the question.  Now you've come down to say

11     it's almost 80 per cent.  So your representations here are inconsistent.

12        Q.   Well, what I'm going to say is that it's not essential how much

13     over 50 per cent, but the fact is that Priboj was a municipality, whereas

14     now I have to use a magnifying glass to find it.  It's to the southern

15     reaches of Ugljevik, and it's died a natural death.  There's nothing

16     there anymore.  It's a very small place now because the municipal seat

17     was abolished and joined to the neighbouring municipalities.

18             So do you consider or do you think that the municipality never

19     existed at Majevica?

20        A.   Do I think that the municipality never existed at Majevica?  I

21     don't think you've even suggested there was a municipality at Majevica.

22        Q.   The Priboj municipality on Mount Majevica.

23             Now, do you agree, Mr. Donia, that municipalities in the world

24     range from 1.500 to 5.000 inhabitants as a general rule?

25        A.   The municipalities in the world?

Page 3345

 1        Q.   In most countries in the world.

 2        A.   No.  No.

 3        Q.   Do you agree that the average population of municipalities in the

 4     Soviet Union and Yugoslavia was 40.000?  In all other countries the

 5     figure was less.

 6        A.   That's about the average in Bosnia.  I -- or was the average

 7     in -- in about 1991.  I don't know about Soviet Union.

 8        Q.   Yes.  It was around 40.000.  And do you know that in other

 9     countries the number of inhabitants is significantly lower?  For example,

10     Greece has 8.500 on an average.  All the rest have less than that.  Are

11     you aware of that?  Is that something you know about?

12             JUDGE KWON:  How is it assisting the Chamber, Mr. Karadzic?

13     Let's move on to your next question.

14             THE ACCUSED: [Interpretation] Well, you'll see,

15     Your Excellencies, that gerrymandering and the manipulation --

16     manipulations with the population and municipalities is a pre-eminently

17     political category and that that's what led to the crisis.  But never

18     mind, let's move on.

19             MR. KARADZIC: [Interpretation]

20        Q.   Now, Mr. Donia, do you see the municipality of Bijeljina,

21     Ugljevik, Lopare, Zvornik?  Do you see those municipalities?

22        A.   Zvornik, Lopare.  I'm sorry, what was the other one?  Bijeljina?

23        Q.   Bijeljina and Ugljevik.  Do you agree that Bijeljina, Ugljevik

24     and Lopare belong to Semberija and Majevica?  Semberija and Majevica,

25     that general area.

Page 3346

 1        A.   If you're using the term geographically, yes, that would be the

 2     case.

 3        Q.   Do you know where their seat was, the community of

 4     municipalities, I mean?

 5        A.   Well, again, I don't know the precise communities of

 6     municipalities that existed prior to 1990.  I know that not all

 7     municipalities belonged to a community of municipalities, and I

 8     furthermore don't know where their seats were.

 9        Q.   And what was the regional centre of these municipalities?

10     Perhaps you'll find it easier to answer that way.  Do you agree that the

11     regional centre of these municipalities was Tuzla and not Bijeljina?

12        A.   I don't know.

13        Q.   And if I tell you that it was Tuzla and that Tuzla had an

14     accelerated development and that it wasn't Bijeljina and that Bijeljina

15     is just beginning to develop now, what would you have to say to that?

16        A.   I think that's the case, but the reasons for the accelerated

17     development of Tuzla didn't have anything to do with municipal -- being

18     the seat of a community of municipalities.  To my knowledge, Tuzla really

19     grew upon its salt deposits and the substantial industrialisation that

20     was put there, including the soda chemical plant and other facilities

21     that were developed in the municipality.

22        Q.   And how do you now explain the fact that Bijeljina is flourishing

23     although it went through the war and sanctions and poverty, that suddenly

24     Bijeljina is flourishing and developing because it's now the regional

25     centre?

Page 3347

 1        A.   Well, I've been to Bijeljina but I saw it as actually having

 2     developed in the socialist period a great deal.  I wouldn't agree with

 3     the characterisation.  Again, it may be some numbers that -- some

 4     economic metrics that can establish this, but it's a place that's grown

 5     rather dramatically, I think, under socialism.  In fact, that whole strip

 6     along the Drina River there is actually developed a great deal.

 7        Q.   And if I tell you that Bijeljina started developing after this

 8     latest war, the civil war, our war, when it became a regional centre and

 9     that everything is flourishing there, how else could you explain that but

10     to say that income from Bijeljina no longer goes to Tuzla?

11        A.   Well, I think you're wrong about, really, the trajectory of

12     development throughout the socialist period.  I understand that you have

13     plenty of reasons to be unhappy with Communists and Socialists, including

14     some very personal reasons, but I think you have to acknowledge that the

15     development of Bosnia-Herzegovina under socialism was enormous,

16     particularly in the first 30 years of -- of socialism, and that virtually

17     every city grew larger.  The economy really prospered.  Industrialisation

18     was widespread, population increased and became more literate.  So those

19     are all simply facts of the era of economic development under socialism.

20     So I'd submit that you probably can't find much of a town that didn't at

21     one time or another prosper more so than it had in earlier decades under

22     socialism.

23        Q.   Do you consider that the development of Bosnia-Herzegovina was

24     regionally well balanced, and did you see in our platform the call for a

25     well-balanced regional development?  That was one of the points in the

Page 3348

 1     platform of the Serbian Democratic Party.  Just take it one by one.  Did

 2     you notice in our programme or platform the call for equitable regional

 3     development or well-balanced regional development?

 4        A.   Yes, I do recall that.

 5        Q.   Do you claim that a well-balanced regional development existed in

 6     Bosnia-Herzegovina?  Before these elections, I mean.

 7        A.   I think it depends on how you define the regions.  The --

 8     certainly the development in the Sarajevo area was probably the most

 9     dramatic and the greatest.  There were other areas that didn't

10     industrialise at the rate of Sarajevo, and, in fact, most regions

11     probably didn't industrialise at the rate Sarajevo did.  But in general,

12     I think the -- I haven't seen evidence to suggest that regions, whole

13     regions, were dramatically backward relative to the rest of the republic.

14             I remember when the Banja Luka leadership started to organise the

15     community of municipalities of Bosanska Krajina.  The principal promoter

16     of that project was Dr. Dusko Jaksic, who was then the director of the

17     economic institute in Banja Luka.  As far as I know, he still is.  And

18     when that political demand arose for -- to correct the backwardness of

19     Bosnian Krajina, he, who was the principal promoter of the idea, frankly

20     told interlocutors that there were no numbers to show that.  So I think

21     it -- it remains in my mind to be established that there was this

22     discrimination against regions or backwardness of regions based on some

23     political criterion.

24        Q.   Well, we'll come to that Mr. Donia, but do you see Gracanica,

25     Lukavac, Maglaj, Zavidovici, Banovici, and those two rivers there, to the

Page 3349

 1     left is the River Bosna, passing through Maglaj, and to the right is

 2     Braca, which goes from Lukavac, Gracanica, and they -- their confluence

 3     is in Doboj.

 4        A.   Yes, I think we probably just lost everybody else in the room,

 5     but I know what area you're speaking of, yes.

 6        Q.   Now, in between these two rivers, is Mount Ozren there between

 7     those two rivers?

 8        A.   Yes, that's right.

 9        Q.   Now, do you know that up on Mount Ozren there was a municipality

10     at one time called Petrovo Selo?

11        A.   No, I don't -- didn't know that.

12        Q.   Do you know that that municipality was abolished and Ozren, which

13     was 100 per cent Serb, inhabited by Serbs, was divided up among the

14     neighbouring Muslim municipalities?

15        A.   Well, I object to your characterisation of the neighbouring

16     municipalities as Muslim, and I don't know the administrative history of

17     that -- of the Ozren area prior to 1991.

18        Q.   Thank you.  What I'm trying to say, Mr. Donia, this is something

19     that every peasant there knows, namely, that their lives and development

20     virtually ceased when the municipality of Petrovo was abolished.  Now

21     they again have that municipality.  Municipality of Petrovo and Ozren, as

22     an area, were divided among the other municipalities in each of which the

23     Serbs became a national minority.

24             Did you know -- do you know why I'm talking about Ozren as a

25     paradigm, not as Ozren in its own right?

Page 3350

 1        A.   You're talking about Ozren as a paradigm?  I'm -- what do you

 2     mean by that?  I'm not sure.

 3        Q.   What I'm saying, that a compact Serbian entity was abolished as a

 4     municipality and was divided among the other municipalities, the adjacent

 5     neighbouring municipalities, in which the Serbs became a minority.

 6        A.   Okay.  Well, first of all, that's not gerrymandering because

 7     there was no anticipation of elections at the time the administrative

 8     boundaries were drawn.  I take it what you have done is gerrymandering,

 9     in the wartime period and immediately afterwards, to assure Serb parties

10     would -- would prevail in those areas.

11             The -- if you look at the distribution of Serb villages that I've

12     looked at around the -- just south of Doboj in that Ozren area, what you

13     get is indeed a serpentine kind of configuration, and to look at those

14     villages as a municipality would be contrary to the whole notion of a

15     municipality as it existed under socialism and which I explained a couple

16     of days ago, which was a municipality was to have a centre, a seat,

17     bearing the same name as the municipality.  It was to be as economically

18     self-sufficient as possible.  It would be surrounded by land that is

19     partly agricultural, partly simply socially owned land that would be

20     essentially free space and suburban villages, and the purpose of that

21     notion of a municipality was, in fact, geographic and economic.  It was

22     designed to encourage economic development, and that is the level at

23     which economic development was encouraged under socialism.

24             The communities of municipalities were incidental to that

25     fundamental unit of analysis or administration which, as you know, became

Page 3351

 1     a socio-political community in the definition of socialist-era

 2     constitutions.

 3             So I understand your -- your critique of -- and your use of Ozren

 4     in particular as an example of this, but I do believe that if you

 5     actually made a municipality out of Ozren, it would be largely ethnically

 6     homogenous and would probably defeat the possibility of economic

 7     development because it would be so geographically contorted and not have

 8     the diversity that one would look for in a developing region like that.

 9        Q.   But you agree with me that in a democracy the people should have

10     been asked what it was that they wanted.

11        A.   As a general principle, I would agree with that.

12        Q.   Thank you.  Can we take a look at Western Bosnia.  You see

13     Bosanski Petrovac, Titov Drvar, Bosansko Grahovo, and Glamoc.  Do you

14     know where the seat was, to which community of municipalities did

15     Bosanski Petrovac and Drvar belong?

16        A.   Are you talking about the period before 1990?  I don't know.

17        Q.   Their seat was at Bihac, and those municipalities were

18     devastated.  The people left.  There was no industry.  There was no

19     economy.  The people abandoned the area.  Do you believe me or should I

20     give you the figures?

21        A.   Well, I'd love to see the figures.  I do want to point out that

22     in this case one is dealing with an administrative centre that had been

23     an administrative centre for that part of Bosnia going back well over a

24     hundred years.  So -- and the same would be true of -- of Mostar.  When

25     the Austrian -- Austro-Hungarian administrators came in, they selected

Page 3352

 1     basically the five or six largest towns to be administrative centres in

 2     somewhat the same spirit as municipalities were later created under the

 3     socialist government.  So the -- again, the argument you're making here

 4     is not to me at all self-evident, that purely dumping a -- making a place

 5     an administrative centre would result in a flourishing economy or in

 6     outstripping other areas.

 7        Q.   But, Mr. Donia, a million and a half Serbs are listening to this,

 8     and three million Muslims and Croats in Bosnia and Herzegovina, they know

 9     exactly what I'm talking about.  Where there is the administrative centre

10     of a community of municipalities, there you have the economic power, the

11     money, the finance, the investments.  Everything is there, and everything

12     from the pertaining municipalities go there.

13             Do you know that Glamoc and Bosansko Grahovo were linked up with

14     Livno, and that Glamoc and Bosansko Grahovo lagged behind tremendously in

15     their development whereas Bosansko Grahovo did not -- sorry, whereas

16     Livno did not.

17        A.   I think you've just overestimated our listening and watching

18     audience by about 4.5 million, but the economic development of these

19     areas I -- I don't pretend to know the relative economic development of

20     each, and I'm not convinced that the, let's say, differential development

21     of one city to another is based on whether it's the seat of a

22     municipality -- community of municipalities or not.

23        Q.   Do you agree that before the Second World War, Kalinovik had

24     25.000 inhabitants, and before this war 5.000 inhabitants?  Kalinovik is

25     a predominantly Serb municipality between Foca and Kalinovik.

Page 3353

 1        A.   I'm not familiar with either -- the population at either time.

 2             THE INTERPRETER:  Interpreter's correction:  Between Foca and

 3     Nevesinje.  Sorry.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Mr. Donia, you have stated your position vis-a-vis our political

 6     view that communities of municipalities were -- are just and detrimental

 7     [as interpreted] from the economic standpoint to us, that the motives of

 8     those who did this were ethnocentric.  Do you agree with me that you had

 9     to know these things that I'm asking you about in order to draw such a

10     conclusion, namely, that the Serbs were making some demands about

11     municipality boundaries which actually were not justified?  And we see

12     that those boundaries changed, and they changed because of the moves made

13     by the Communists.

14        A.   I think there's about five questions there, and I'm going to try

15     and sort them out.

16             You state that I expressed the viewpoint that the motives of

17     those who did this were ethnocentric.  I did not make that statement.

18             I have looked --

19        Q.   Sorry, I was not precise myself.  You -- you said that our demand

20     encroaching upon the municipalities or the communities of municipalities

21     was some sort of a politically subversive action, something which was not

22     desirable and was not justified.  Is that correct?

23        A.   No, I don't think that's correct.  I noted your critique of the

24     municipal structure and stated that -- I mean, I've looked at Sarajevo

25     more than anyplace else, and I also looked at Bosnian Krajina to some

Page 3354

 1     degree, and based on looking at those areas, I did not see an

 2     ethno-national factor in the determinations of municipal boundaries under

 3     socialism, and I think I indicated that in the main, or for all practical

 4     purposes or something like that, the drawing of municipal boundaries was

 5     not driven by ethnicity, and I stand by that.  I think the municipal

 6     boundaries that we're looking at today were basically created with the

 7     intent of having rational economic development units within

 8     geographically manageable administrative areas.  And there were other

 9     factors that went into those boundaries.

10             The fact of the matter is that developing 109 municipalities is

11     an extraordinary undertaking for a government, any government, and is

12     probably about the lowest unit that one could realistically expect to

13     have an impact on in terms of economic development.  And even then, a lot

14     of those -- you can go into any one of these municipalities even today

15     and see factories, some of them abandoned, some of them very small, that

16     were put there during the socialist period to try to contribute to the

17     economic self-sufficiency of municipalities.

18             I would point out that you are looking at this from a strictly

19     national viewpoint, strictly ethnic viewpoint, and you're tying those

20     proposals to your claims of Serb land, and that's fine.  I am not saying

21     that's illegal to advocate or even to ultimately achieve.  I'm not making

22     that judgement, but I am pointing out that it is linked to your

23     understanding of what Serb land is and that the municipality redesign

24     that you have in mind would, in fact, be gerrymandering in creating solid

25     Serb areas that would be overwhelmingly Serbian composition, leaving the

Page 3355

 1     rest aside.

 2        Q.   Thank you very much.  Thank you for saying that this is a legal

 3     and legitimate thing, but this is not how I read it in your paper.  But

 4     let me ask you this:  Who would actually have endured it if

 5     municipality -- the municipality of Berkovici continued to exist?  To

 6     whose detriment would that be if the municipality of Petrovo, on Ozren,

 7     continued to exist, and other municipalities?  Who would that -- who

 8     would be -- have been hurt by that?  Why would it have been detrimental

 9     to anyone?

10        A.   I take it, then, you're proposing to re-establish those now

11     long-gone municipalities?  Is that what you're proposing?

12        Q.   Well, they were established.  Berkovici exist again.  Petrovo

13     exists once more.  And the people, the community, now has its income, and

14     they continue to develop.  They can have their own school now.  They can

15     have their own development, which was arrested when those municipalities

16     were abolished.

17             Now, do you believe, justified or not, that in socialism it was

18     very important where the SDK, the social accounting service, was, where

19     the bank was, where the Municipal Committee was, the inter-municipal

20     committee of the League of Communists was seated, where the

21     self-management community of interest was?  You know what the SIZ, the

22     self-management community of interest, was, for health, for education and

23     so on.  So all these financial institutions which had their hands on the

24     income of the entire community.  Do you agree that under socialism, that

25     was concentrated in the seats of these communities of municipalities?

Page 3356

 1        A.   No.

 2        Q.   Well, where, then, were these institutions if not in this

 3     community of municipalities and their seats?

 4        A.   Well, many of them were municipal-level institutions, and I think

 5     you're attributing too much grandeur to the communities of municipalities

 6     that existed under socialism.

 7        Q.   And why then -- why did this become important -- we wanted to

 8     redesign the community of municipalities?

 9        A.   Well, it became important because you adopted it as a tool to

10     weaken, cripple, and eventually disable the government of

11     Bosnia-Herzegovina.  You used it as a state-building tool for the

12     rudiments of a new Bosnian Serb polity with the intent of superseding

13     Bosnia-Herzegovina as it existed in 1991.

14        Q.   Do you mean to say that we intended to create a Serb state in

15     Bosnia in July 1990, when we formed the party and set out the party

16     programme?

17        A.   No, I don't mean to say that.

18        Q.   But at the time, we had criticisms of regional development.  Do

19     you accept that our motive was regional development, which in the Serb

20     lands was lagging behind because the incomes of those regions were placed

21     in the hands of the centres which did not belong to those areas but

22     exploited them.  Simply speaking, those areas were exploited.

23        A.   Dr. Karadzic, the things that you did in the early 1990s set the

24     economic development of Bosnia back 50 years.  You destroyed the economy.

25     You destroyed the infrastructure that it was dependent upon, and to

Page 3357

 1     suggest that this now has turned into a situation of economic prosperity

 2     after the war in Republika Srpska is to me just an implausible assertion.

 3        Q.   Ah, well, Mr. Donia, you have now expanded my task.  I now have

 4     this question to ask you:  Did we, in 1990, even think of

 5     regionalisation?  Did it enter our head at all?

 6        A.   Well, I don't know.  The first activities in favour of

 7     regionalisation I can see on -- in mid-January 1991.  So whether this

 8     occurred to you as a -- as a project, that is, to form regional

 9     associations based on the SDS initiative, whether that occurred to you in

10     1990, I don't know.

11        Q.   But let's stick to what all of us can know, and that is that our

12     pre-election campaign was that the boundaries of the municipalities and

13     the communities of municipalities should be adapted to the wishes and

14     needs of the democratically -- the democratic intentions of the

15     population living there and the population who wanted to live better,

16     have a better life, and that there was no question of any autonomous

17     regions in Bosnia-Herzegovina; isn't that right?

18        A.   Again, I note several questions here.  Certainly the proposal to

19     redraw municipal boundaries was a part of the pre-election campaign.  I

20     didn't see much evidence that it was linked to the economic dimension in

21     the course of the campaign.  You clearly had one or two points in your

22     platform that were contributed or devoted to economic development, but

23     very little of that then actually found its way beyond maybe the first

24     few weeks of the campaign and was pretty well forgotten about after the

25     campaign was over.

Page 3358

 1             I --

 2        Q.   Thank you.  Since this map has not got any markings on it we

 3     won't be tendering.  May we have D255 next, please, which was already an

 4     exhibit, just to show you that Mr. Izetbegovic had set out before him in

 5     our platform -- well, that the SDA never had any criticism to make about

 6     those activities of ours.

 7             THE ACCUSED: [Interpretation] May we have D255 next, please.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   So that we can establish, Mr. Donia, when it was that the Serbs

10     found the need to create autonomous regions and when they found the need

11     to create Republika Srpska, because without them we cannot make these

12     sweeping statements.

13             Now, look at the last paragraph there:

14             "Everywhere, especially here in Bosnia-Herzegovina, we were for

15     the most part devoted to the system which seemed to have been established

16     to ensure our national annihilation.  In the time of the greatest

17     devotion to the regime and the system, the greatest impoverishment

18     occurred precisely in those devoted Serbian areas, and Serbian areas

19     loyal to the system were the very ones to suffer economic and cultural

20     decline and large-scale migration.  Several hundred thousand Serbs left

21     Bosnia and Herzegovina in this period, and Bosnia and Herzegovina was

22     left without their progeny.  Territorial organisation broke down the

23     natural Serbian entities in Bosnia and Herzegovina, and the Serbian

24     nation was reduced to an inferior economic, demographic, and political

25     position."

Page 3359

 1             This is an extract taken from a speech, the introductory speech

 2     at the founding Assembly, my speech, and nobody had anything to say about

 3     that because it can be borne up -- it can be substantiated by any

 4     economic analysis.  Do you agree with that, Mr. Donia?

 5        A.   I think I noted earlier that my concern with your speech at the

 6     founding Assembly was the degree to which you had already formulated this

 7     notion of a Serb people as a homogenous whole and coherent population

 8     group, and this is what I had in mind.  The notion that Serbs were the

 9     victim of the socialist period just to me is counter intuitive.  It

10     misstates the whole character of the socialist government and its -- its

11     intentions and its policies.  I think that actually one later in the

12     campaign more commonly heard the proposition that the government had, in

13     fact, retarded the economic development of all three peoples in that

14     period when you and others were holding the joint rallies amongst the

15     various parties.

16             So I -- I think you're expressing here a kernel of an idea that

17     developed much later and much more, let's say, convincingly, if you

18     will -- not convincingly but tied to a specific programme which was

19     designed to remedy this, but that specific programme was, in fact, based

20     on a single party and mono-ethnic initiative that took wing in 1991.  It

21     wasn't, to my mind, there as a specific proposal or initiative in the

22     time of the electoral campaign or even in the few weeks after the

23     election, but it did have its origins in -- in early 1991.

24        Q.   Mr. Donia, do you consider that the Serb people did not exist as

25     an entity but that I tried to create it?  Is that what you're saying?

Page 3360

 1        A.   I wouldn't say you tried to create it.  I'd say you looked at it

 2     as a kind of national revival.  You were trying to raise the

 3     consciousness, the national consciousness of those people who could

 4     potentially think of themselves as Serbs, and perhaps for one -- one or

 5     another reason describe their identity as hybrid or as Yugoslav or as

 6     something else, and you wanted those people to think of themselves as

 7     Serbs and to behave as Serb nationalists at -- which meant embracing the

 8     ideals and programme of the SDS.

 9             THE ACCUSED: [Interpretation] May we see page 3 of this same

10     document, please.

11             MR. KARADZIC: [Interpretation]

12        Q.   Mr. Donia, do you think that the Serbs in Bosnia should have been

13     something other than the Serbs in Yugoslavia?

14        A.   Well, I think they were different from Serbs east of the Drina in

15     certain limited ways.  Their situation was different.  They were involved

16     in the lives of other republics and had specific ideals that appealed to

17     them, although I think in general the Serb -- let's say, Serb national

18     leaders shared many ideals and many -- and Serbs share the same basic

19     allegiance to their national identity.  But there were some differences,

20     and I think -- I personally find those very interesting.  I think the --

21     one of them was that Serbs west of the Drina seem to be more oriented to

22     the Serb experience in the Second World War than did Serbs in Serbia

23     proper.

24        Q.   And do you agree that the Serbs from Nis and the Serbs from

25     Novi Sad are different among themselves than the Serbs from Bosnia and

Page 3361

 1     Sumadija?

 2        A.   Yes, I think you could think of them as, if you will,

 3     subcommunities of a broader national community of people who shared the

 4     Serb identity in Yugoslavia.

 5        Q.   What I'm concerned about, Mr. Donia, is this:  You seem to

 6     consider that we generated something in Bosnia-Herzegovina which we did

 7     not have the right to.  Do a million and a half Serbs in

 8     Bosnia-Herzegovina have the right to fight for their economic -- well,

 9     for their equality, equality with others, for their economic prosperity,

10     cultural identity, and national identity?  Do they -- this collective of

11     a million and a half people, do they have their rights, the rights to do

12     that?

13        A.   I think all people have the rights that you basically described,

14     all citizens of any polity should have those rights.  They do not have

15     the right to -- should not have the right to eliminate those of other

16     groups from territories that they claim or claim huge blocks of territory

17     which are to be devoid of those that are currently living there.

18        Q.   Are you making a judgement, then?  Are you saying that the Serbs

19     in Bosnia-Herzegovina wanted to do that, wanted to do it that way?

20        A.   I'm simply saying that they have a lot of rights, should have

21     those rights, along with other citizens of Bosnia-Herzegovina.  They

22     should have those same rights as other citizens have, but that when it

23     comes to destroying other -- the basis of other groups, that they should

24     not have those rights, and neither should any another group.

25        Q.   Well, all right.  We'll come to that.  But are you suggesting

Page 3362

 1     that's what the Serbs did?  Is that your position, that the Serbs did

 2     what you said they did and that which they should not have done?

 3        A.   I mean, talking about the period that -- let me make clear.

 4     Talking about the period that we're talking about, which is prior to

 5     January 1991, absolutely not.  I am not making that suggestion.  I think

 6     if you get into 1992, much of that happened.

 7        Q.   We will clarify that in due course, but, Mr. Donia, do you think

 8     that the formation of the Croatian Democratic Union, the Croatian Party

 9     of Rights, the Party of Democratic Action, did it have some other root

10     but the ethnic root, which you do not allow for the Serbs?

11        A.   No.

12        Q.   So all those parties which started out in 1990, mostly in the

13     west, had -- well, the main parties that won the elections both in

14     Slovenia and Croatia and Bosnia-Herzegovina had an ethnic motive, an

15     ethno-democratic stream, motive.

16        A.   The -- there was, as I discussed yesterday, to me a fluorescence

17     of democratic national activity going back to very late 1989, when it

18     became evident that multi-party elections would be held in Bosnia and in

19     Yugoslavia in some form.  Part of that activity, much of that activity,

20     fluorescence, if you will, took place in support of the formation of

21     national parties.  Some of it was non-national.  Some of it could even be

22     called anti-national, but it was a product of the arrival of democracy.

23     And so people formed parties by the dozens and hundreds in the former

24     Yugoslavia at that time and their nature and programmes were as diverse

25     as one could find in a -- in a newly emerging democracy.

Page 3363

 1        Q.   Thank you.  Do you agree that the Croatian Democratic Union as a

 2     predominantly national party in Croatia quite literally wiped out all the

 3     other parties?  It had a major victory.  That's my first question.  Yes

 4     or no.  That will suffice.

 5        A.   Wiped out other parties?  No.  It did not wipe out other parties.

 6     It had a victory which was actually less than an absolute majority in the

 7     elections because of the -- but won the majority of seats because of the

 8     first-past-the-post system that had been voted into effect by the

 9     outgoing Communist-dominated legislature.

10        Q.   And the Croatian voters had an alternative.  They had others to

11     vote for, but they opted for the HDZ.  Is that right?

12        A.   I think I just said that they -- the HDZ did not receive a

13     majority of the votes.

14        Q.   I think that they won most of the seats, but I think we also

15     agree that the Party of Democratic Action was formed before the Serbian

16     Democratic Party.  Isn't that right?

17        A.   Well, I indicated that if you look -- if you -- if the measure

18     that you'd like to use to recognise parties as having organised is their

19     founding Assemblies, that the Party of Democratic Action was formed in --

20     on May 26 and the SDS was formed in early July.  There are other measures

21     that one could use.  I think that's a reasonable one to use, and if

22     you'll agree that that's the reasonable one to use, then it would be the

23     case that the SDA was formed before the SDS.

24        Q.   Can anybody in the world claim that the Serbs in

25     Bosnia-Herzegovina would have formed the Serbian Democratic Party had all

Page 3364

 1     that not been preceded by the superior or significant victory of the HDZ

 2     in Croatia, the HDZ activity in Bosnia-Herzegovina and the Party of

 3     Democratic Action's formation?  Do you think that the SDS would ever have

 4     been formed had these others not previously been formed?  Do you have a

 5     shred of evidence to prove that that would not have happened?

 6        A.   I think you're asking me to prove a negative, but I would point

 7     out, as I did yesterday, that there was a great deal of organising

 8     activity going on, at least starting with the first month of 1990, that

 9     eventually culminated in the organisation of the SDS.  I think that the

10     specific form that the SDS took was a product of a number of factors.

11     One was the recognition by yourself and others that to form the party as

12     an affiliate of a party in a neighbouring republic was ill-advised.  The

13     HDZ, of course, did that, and I think was not a particularly successful

14     thing to do.

15             Also, your own hesitancy to get involved in -- as president of

16     the party certainly played a part in the specific form that the SDS

17     eventually took, and perhaps significantly the advice of Mr. Cosic and

18     others which kept the SDS in Croatia from becoming the parent of the SDS

19     in Bosnia, which could then be formed as a separate distinct body from

20     the party that Mr. -- Dr. Raskovic was heading in Croatia.

21             JUDGE KWON:  Mr. Karadzic, we'll adjourn there for today and for

22     this week.  So over the weekend plan and think about your -- the

23     remaining of your cross-examination and plan your conduct so as to be

24     able to pose more precise and focused questions, thereby shortening your

25     overall cross-examination time.

Page 3365

 1             On Monday we'll be hearing -- we will be sitting in the morning

 2     in Courtroom I, but given that there will be a Judges' Plenary at 1.00,

 3     so we will adjourn at 10 to 1.00.  So I'm telling you for the purpose of

 4     your planning.  And if necessary, we'll go back -- we'll go into private

 5     session and then we can discuss it in the absence of the witness, but

 6     there's a motion regarding a witness who will be coming end of this

 7     month, and now I'm wondering whether the Defence is minded to respond to

 8     that motion or -- or it is minded to object to it?  Can I know in

 9     advance?

10             MR. ROBINSON:  Yes, Mr. President.  Actually, Dr. Karadzic and I

11     haven't yet had a chance to discuss that, but we can let you know

12     tomorrow.

13             JUDGE KWON:  Could you do that in writing tomorrow?

14             MR. ROBINSON:  Yes.

15             JUDGE KWON:  Thank you very much.  I wish you all have a good

16     rest over the weekend.  Monday, 9.00.

17                           --- Whereupon the hearing adjourned at 7.05 p.m.,

18                           to be reconvened on Monday, the 7th day

19                           of June, 2010, at 9.00 a.m.