1 Thursday, 3 March 2005

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 10.02 a.m.

5 JUDGE ORIE: Madam Registrar, will you please call the case.

6 THE REGISTRAR: Case number IT-00-39-T, the Prosecutor versus

7 Momcilo Krajisnik.

8 JUDGE ORIE: Good morning to everyone. The Chamber apologises for

9 the late start. It's not the snow but rather the small remainders of flu,

10 et cetera, which caused us to start a bit late.

11 Mr. Hannis, are you ready to continue? Ms. Hanson, when you need

12 a break, please stop me.

13 MR. HANNIS: Thank you, Your Honour.

14 WITNESS: DOROTHEA HANSON [Resumed]

15 Examined by Mr. Hannis: [Continued]

16 Q. We left off yesterday, Your Honour, we'd finished tab 144. I'm

17 inviting Ms. Hanson to go to a new topic. In your report, you talk about

18 Crisis Staffs being involved with the Territorial Defence as before the

19 VRS was formed in May of 1992. And tab 145, Your Honours, I don't intend

20 to put this up on Sanction. This is an exhibit in Mr. Treanor's material.

21 This is master tab 242. This was just the constitution. And Article 110

22 was what you wanted to refer to there?

23 A. Yes.

24 Q. Which relates to --

25 A. Yes, Article 110 of the constitution of the RS. Is it possible

1 for me to have the binder?

2 Q. Sure. We should give you your hard copy of binder number 4.

3 A. It mandates municipalities to set up, organise, and manage the

4 Territorial Defence.

5 Q. That's fine.

6 A. I believe that's the wording. But it's to municipal authorities,

7 the municipality as a body. But, as we know, the Crisis Staffs took over

8 all authorities of the municipal assembly. Yes, it is the right and

9 obligation of municipalities to set up and organise the national defence

10 and to manage the Territorial Defence.

11 Q. And I want to go to tab 146 in the presentation binder, master tab

12 101. Could you tell us about that.

13 A. This and the next series of documents are examples of Crisis

14 Staffs setting up TOs, issuing orders to TOs, appointing the commanders,

15 all consistent with the constitution and consistent with the 19 December

16 instructions which said fill up the reserves of the TO and organise

17 defence.

18 So this document is a decision of the Crisis Staff of Bihac of 3

19 May 1992, appointing the TO commander, the deputy commander, and the chief

20 of staff of what they call the 1st Brigade of the Serbian municipality of

21 Bihac.

22 I would also draw your attention to the letterhead which reads:

23 "The Serbian municipality of Bihac and the Bihac SDS municipal board," but

24 it's issued by the Crisis Staff commander indicating the overlap between

25 the SDS, the Crisis Staff, and the municipality as a whole. This is often

1 seen in Crisis Staff documents.

2 Q. And does that one reflect the relationship between the Crisis

3 Staff and the TO?

4 A. Yes. It shows that the commander of the Crisis Staff is

5 appointing the TO commander, which I take to be a sign -- indication of

6 its authority over the TO and its role in setting up the Territorial

7 Defence.

8 Q. And the last item, does it make reference --

9 A. Oh, yes, item number 5. "The brigade commander shall receive all

10 commands and tasks from the Bihac SDS municipal board Crisis Staff." So

11 the Crisis Staff is issuing all commands to the brigade command, and the

12 Crisis Staff itself is identified as SDS municipal board, but also

13 municipality at the top.

14 Q. And --

15 JUDGE ORIE: Can I ask one question in this respect. I didn't

16 find the words "TO," but that's in the heading above.

17 THE WITNESS: Yes, it's only in the title.

18 MR. HANNIS: Thank you.

19 Q. As another example of a Crisis Staff ordering the military unit,

20 can I refer you to presentation tab 147, master tab number 248, and ask

21 you to tell us about that one.

22 JUDGE ORIE: I see that we have two documents under 146. Has that

23 got any specific reason? I also find a decision of the 4th of June, or is

24 that a mistake?

25 MR. HANNIS: Your Honour, I --

1 THE WITNESS: I believe that may have occurred that -- these

2 documents are -- some documents are entered as a range, two documents

3 together. It seems that's how it entered the system, the two pages as

4 one.

5 JUDGE ORIE: Yes.

6 THE WITNESS: I'm not intending to talk about this one.

7 MR. HANNIS: Your Honour, I think that's surplusage.

8 Q. We would move to presentation tab 147, master tab number 248.

9 A. This is an order of the commander of the Crisis Staff of Bosanska

10 Krupa, dated the 5th of April, 1992, and it is an order that the brigade

11 commander -- I'm reading item 2 here, "the brigade commander, battalion

12 commanders, commander of the TO staff, police commander, and operational

13 duty officer are ordered not to leave their place of residence and to

14 report to the Crisis Staff headquarters every two hours."

15 So an indication of reporting -- the Crisis Staff is commanding

16 the TO and expecting reporting from the TO.

17 Q. All right. Presentation tab 48 next in the binder, master tab

18 252.

19 A. This is a decision of the provisional government of Zvornik - yes,

20 two copies are actually necessary - dated the 18th of April, 1992, on

21 forming a special unit of the Territorial Defence, saying that the seat of

22 this special unit shall be in Karakaj, in the standard -- the premises of

23 the firm Standard. The tasks of the special unit shall be "to secure the

24 territory of the Serbian municipality of Zvornik and other duties

25 determined by the government of the Serbian municipality of Zvornik." So

1 provisional government setting up a special unit and saying that it shall

2 be giving the tasks and duties to that unit.

3 Q. And the next two, I believe, also relate to Zvornik. Presentation

4 tab 149, master tab 416.

5 A. Yes, it's two documents. The first one is the provisional

6 government dismissing people from the command of the Zvornik Territorial

7 Defence. This is a decision dated the -- published in the Official

8 Gazette of Zvornik on the 28th of April, but it's referring to a decision

9 apparently brought on the 10th of April. But we see they dismiss, and

10 then the next document is them appointing other members. So the

11 provisional government, as we see here, had the power to dismiss members

12 of the TO command.

13 Q. All right. And next, presentation tab 150 --

14 JUDGE HANOTEAU: [Interpretation] Terribly sorry, terribly sorry to

15 interrupt you.

16 Regarding number 149, just one small precision, if I may. I'm

17 wondering about number 126: [In English] ... war front.

18 [Interpretation] Could you please explain that sentence and

19 perhaps give us the explanation or make a comment regarding that sentence.

20 THE WITNESS: You referred to the left-hand side of the page?

21 JUDGE HANOTEAU: [Interpretation] That is correct, yes.

22 THE WITNESS: This document --

23 JUDGE HANOTEAU: [Interpretation] Do you see the sentence?

24 THE WITNESS: I do, Your Honour. First, I would like to say that

25 this document is a reproduction of -- a translation of the page from the

1 Official Gazette of the municipality of Zvornik, where different decisions

2 would appear, one on the left-hand side of the page and one on the other,

3 so this is a part of a different decision, an earlier decision, if you

4 understand that.

5 What I would take that to mean, I've seen much such similar

6 references in Crisis Staff documents, and I believe they refer to a

7 process known as asanacija, the cleaning up after a battle, removal of

8 dead bodies and dead animals, after the battle is over, the clearing up of

9 the terrain. I see many such discussions. But it's not part of this

10 actual decision.

11 JUDGE HANOTEAU: [Interpretation] I thank you, Your Honour.

12 MR. STEWART: Your Honour, could we point out that the transcript

13 got -- Judge Hanoteau's point clearly related to point number 126. In

14 fact, it is 26, just in case that ever gets missed later, it could be

15 confusing. Judge Hanoteau's point clearly related to number 26.

16 JUDGE ORIE: Thank you, Mr. Stewart.

17 MR. HANNIS:

18 Q. Ms. Hanson, regarding that particular item, is that often referred

19 to as sanitation as opposed to clearing up?

20 A. Yes, asanacija.

21 Q. Yes. I think I began to ask you about tab 150 in the

22 presentation, master tab 253.

23 A. Simply in conjunction with the previous decision, this is a

24 decision of the provisional government forming the TO command. So in the

25 previous decision, they dismissed people and appointed others.

1 They, under number 1, appointed as commander of the Territorial

2 Defence staff is Marko Pavlovic, and it's dated the 28th of April, 1992.

3 Q. Thank you. Now, was there some recognition of this process that

4 was going on at the municipal level, was that recognised at a higher

5 level.

6 Let me refer you next to tab 151. And I think you have an excerpt

7 from that document. It's master tab number 255, and it's the combat

8 readiness report for the VRS that was published in April of 1993. Can you

9 tell us what page you're going to?

10 A. On page 10 of the translation; in the original, 00607349, I

11 believe, to begin with. I'm just checking for the original passage, but

12 I'm sure it's -- yes, it's the third paragraph from the top in the B/C/S.

13 It's at the bottom of page 10 in the English.

14 This, as you said, is the report of the VRS itself, describing the

15 first year of the conflict, so I think it's important to see the army's

16 account of the development in this period.

17 "The control and command function in the framework of the

18 establishment of the army of Republika Srpska developed in two stages:

19 The first from 1st April to 15 June, and the second from that date until

20 today. An important development in the first period was the

21 self-organising of municipal and other regional units on the basis of

22 Territorial Defence units under the political and patriotic influence of

23 the Serbian Democratic Party."

24 Q. And did you have another excerpt you wanted to highlight at page

25 13 in the English?

1 A. Yes. Page 13 in the English; in the B/C/S, it is 00607351. At

2 the beginning -- middle of the page, the middle of the section on infantry

3 units:

4 "The infantry units, which, through self-organisation, grew on a

5 massive scale out of the Territorial Defence and other units, were used

6 only at the beginning of the war according to the decisions of Crisis

7 Staffs and similar authoritative bodies."

8 Q. Thank you. Was there anything additional from that document at

9 this time?

10 A. Well, actually, the next -- the first sentence of the next

11 paragraph is also -- it simply continues the story.

12 "When the army of Republika Srpska was formed, these units were

13 incorporated into it. In places where there were no units of the former

14 JNA to serve as a basis for the formation of new units, they were the

15 foundation for the establishment of infantry units."

16 These passages, I think, give a good summary of what I've been

17 trying to show with the documents. Where there was a JNA, in some places,

18 that was the basis for the future army; in other places, the SDS led the

19 organisation of units which were later -- I'm sorry, which were commanded

20 at the beginning by Crisis Staffs and similar bodies, and later formed the

21 basis for the VRS.

22 Q. And particularly during the time between the outbreak of the

23 conflict in early April and the formation of the VRS in the middle of May,

24 did you see other examples of local Crisis Staffs trying to handle the

25 military units in their areas?

1 A. Yes. I see different exertions of authority over these units

2 during this time period of the takeovers or from Crisis Staffs declaring

3 themselves to be municipal authorities and before the formation of the

4 VRS. We see examples of Crisis Staffs ordering and managing -- claiming

5 influence over these units.

6 Q. Let me start out by, then, asking you about the next tab,

7 presentation number 152, master tab number 198. First of all, can you

8 tell us where that document comes from? And then direct us to the

9 highlighted portion you want to discuss.

10 A. This document comes from Bratunac. It is a decision of the Crisis

11 Staff of the Serbian Autonomous Region of Bihac, which Bratunac fell

12 under, dated the 29th of April, 1992. This document is interesting for --

13 both for its preamble, I would draw your attention to the preamble which

14 says:

15 "That person went to the decision of the National Security

16 Council, the crisis --" so you see that the regional Crisis Staff is

17 basing its action on the decision of the republican level. And then on

18 item 3 on the next page in the translation, it's an order on -- the

19 decision declaring a state of war, and then specifying that "mobilisation

20 shall be carried out by municipal staffs, and all units, including the

21 existing military ones, shall come under the command of the municipal

22 Crisis Staffs and the Crisis Staff of the Serbian Autonomous Region of

23 Bihac."

24 I note this is dated the 29th of April, two days before the

25 Federal Republic of Yugoslavia had been declared, and the status of the

1 JNA in Bosnia was now thrown into question. So we see a regional Crisis

2 Staff saying that all -- even existing military units shall come under the

3 command of the municipal Crisis Staffs.

4 Q. And that would seem to include JNA units.

5 A. It would appear to.

6 Q. Let me ask you next about presentation tab 153, master tab number

7 275.

8 A. This is an order of the War Presidency of Bosanska Krupa, dated

9 the 24th of April, 1992, an order to the command of the 1st Krajina

10 Brigade to destroy three bridges. I would note here that this is

11 explicitly an order, and yesterday, Your Honours noted that a similar

12 document, a month later, was called a recommendation. I think that gives

13 an indication of the transition from earlier, Crisis Staffs and similar

14 bodies directly commanding in some places to a recommendation, more

15 emphasis on coordination.

16 Q. And related to this particular document, that municipality --

17 A. Oh, yes, this is Bosanska Krupa, and they're ordering the brigade

18 to destroy three bridges. You will recall Vjestica's remarks at the 12th

19 of May Assembly session, specifying that they had destroyed certain

20 bridges and were planning to destroy others.

21 Q. Thank you. Next I want to go to presentation tab 154, master tab

22 number 142.

23 A. This is -- these are pages from the diary of Nedeljko Rasula, the

24 president of the Crisis Staff of Sanski Most, in particular, the session

25 of the Sanski Most SDS municipal committee of the 14th of April, 1992.

1 Q. Can you direct us to the excerpt you want to talk about?

2 A. On page 19 in the translation -- starting on page 19, excuse me.

3 The heading is "The Course of Action in Taking Over Power and Establishing

4 the Serbian Municipality of Sanski Most."

5 Q. Where is that in the B/C/S?

6 A. In the B/C/S, it is on 01369256. Under item 4 on that list, on

7 the next page in the translation, it says: "The Crisis Staff, consisting

8 of the following members, shall be in charge of all actions." And it's

9 notable that the second listed member of the Crisis Staff is Colonel

10 Nedeljko Anicic. And as the plan indicates in its -- in the following

11 pages, that page and the next, it includes the brigade being ready,

12 ordering readiness of the brigade, presumably to assist in the action. I

13 don't see that next page in the translation. But it's clear that the

14 Crisis Staff is coordinating with the military on the takeover.

15 Q. Thank you. If next we could go to tab 155, master tab number 244.

16 A. This is a request -- a letter, a letter from Ratko Adzic,

17 assigning himself here as commander of the Ilijas VSN BiH. At the

18 letterhead, we can see it's the Ilijas Serbian army command. I would

19 point out that the initials VSN in Serbian would be -- the phrase army of

20 the Serbian people, Vojska Srpskog Naroda, would have the initials VSN.

21 It's not explicated what the VSN means there. But in the letterhead,

22 Serbian army command. Dated the 12th of June, 1992.

23 It is addressed to the president of the Presidency of the Serbian

24 Republic of BiH. He's informing the president on the situation on the

25 ground and requesting three to five tanks and three self-propelled

1 anti-aircraft guns in order to cleanse certain pieces of terrain in the

2 Ilijas municipality.

3 So we see here that Ratko Adzic is also the president -- he's also

4 the president of the Crisis Staff of Ilijas. We see him here calling

5 himself commander of the army, and requesting tanks and aircraft guns for

6 clearing the municipality.

7 The original word is "da ocistim," that I might clear or cleanse.

8 It's a different form of the verb that we see as asanacija.

9 Q. And do we see other examples of Crisis Staff members or Crisis

10 Staff heads also taking a role and commanding military forces?

11 A. Yes. We've seen some documents already where they assign

12 themselves as commandant, commander, which you will recall is the term

13 used in the 19 December instructions. We also have Crisis Staff heads

14 themselves describing their authority over military and civilian

15 authorities.

16 Q. Next I want to take you to presentation tab 156, master tab 223.

17 This is a video of an interview of Jovan Tintor.

18 A. Jovan Tintor was president of the Vogosca Crisis Staff, and a

19 member of the SDS Main Board.

20 Q. And before we start to play this intercept, a couple things. Can

21 you tell us who the interviewer was in this --

22 A. Yes, this is from a television broadcast from 1994, a show hosted

23 by Risto Djogo, called "My Guest, His Truth," and it's an interview of

24 Jovan Tintor covering the foundation of the SDS through the war. So I

25 made three excerpts of what I thought were the most relevant comments from

1 Jovan Tintor.

2 Q. Before we begin to play those excerpts, can you direct the Court

3 and counsel to the page in the hard copy English translation where we're

4 starting?

5 A. We're starting on page 7, 7 on to 8 is the first passage. I'm

6 afraid it will take me a moment to find the B/C/S page.

7 THE INTERPRETER: We note that we don't have a hard copy English

8 translation.

9 MR. HANNIS: We'll see if we can get one.

10 THE WITNESS: The B/C/S begins on 00255238. I can give them --

11 MR. HANNIS: Should we put the English up on the ELMO? I don't

12 know what helps the booth the most.

13 [Intercept played]

14 THE INTERPRETER: [Voiceover]

15 "Risto Djogo: And then, you were the president of the Crisis Staff

16 Vogosca.

17 Jovan Tintor: Yes, I was the commander of the Crisis Staff."

18 THE INTERPRETER: We seem to have a technical problem. As soon as

19 we switch on the microphone, we can't hear the tape.

20 JUDGE ORIE: There seems to be a technical problem.

21 MR. HANNIS: Your Honour, perhaps -- I know before we've tried to

22 play intercepts and other things completely through. I don't know if we

23 could adopt a procedure for this one, because I think we're capable of

24 pausing, if we could just pause every so often and have the interpreter

25 interpret the last speech, the last sentence or whatever, and then

1 continue once they've finished. I don't know if that will work.

2 THE INTERPRETER: There's no problem any more. It seems to be

3 solved.

4 JUDGE ORIE: Okay. Then let's proceed.

5 MR. HANNIS: Should we start at the beginning again?

6 JUDGE ORIE: Yes, please do so.

7 [Intercept played]

8 THE INTERPRETER: [Voiceover]

9 "Jovan Tintor: Yes, I bought that uniform by myself in Novi Sad.

10 Risto Djogo: Then, you were the president of the Crisis Staff

11 Vogosca.

12 Jovan Tintor: Yes, I was the commander of the Crisis Staff that

13 was superior to the military and civil authorities at the time. I took

14 the job very seriously and understood what had to be done at that time.

15 Because, you know that the war in Sarajevo started on the 6th of April.

16 We seized our weapons, the people received their specific tasks, and of

17 course, I went, along with my people, with my units there where the

18 Serbian territory is to defend it and to establish the absolute peace and

19 authority on our territory. However ..."

20 MR. HANNIS:

21 Q. Do you want to make any comment on that excerpt?

22 A. He makes a clear statement that as commander of the Crisis Staff,

23 he was superior to military and civil authorities, and he led his units

24 "to establish authority on our territory."

25 The next passage begins at the bottom of the same page in the

1 English translation, and in the B/C/S, it starts about one-third of the

2 way down page 0 -- the next page, 00255238. I'm sorry -- forgive me,

3 5239.

4 Q. Okay. We'll play that one now, please.

5 [Intercept played]

6 THE INTERPRETER: [Voiceover]

7 "Jovan Tintor: Well you see, when the war already begun ... I

8 didn't have two minutes of military education, but I put myself at the

9 head of these people as commander and a kind of a civilian leader. I took

10 a rifle and organised the people the best I could. The front line I held

11 was big. It wasn't only Vogosca. I believed that I should help all the

12 Serbs living on the territories where they weren't properly connected, so

13 I held 64 kilometres of the front line. From the Jezero hospital ..."

14 MR. HANNIS:

15 Q. Any comment on that?

16 A. Again, a clear statement of his military as well as his civilian

17 authority. And the extent of the front, he's speaking of himself holding,

18 obviously his units holding a large front line, so a clear military role.

19 Next passage begins at the bottom of that same paragraph, still on

20 page 8 in the translation, and on the following page in the B/C/S,

21 00255240, about one-third of the way down that page in the original.

22 Q. Thank you. We'll play that one now.

23 [Intercept played]

24 THE INTERPRETER: [Voiceover]

25 "... I was informed ... I was at a meeting in Vrace where Mr.

1 Kukanjac was to be present too. I wasn't so lucky to meet him at that

2 occasion, but I met our present -- our current General Subotic, President

3 Karadzic, President Krajisnik, Mico Stanisic, Momcilo Mandic ... on that

4 meeting we discussed about joining up in order to cut the city in two and,

5 well, to enter the city. Across that bridge, the former Bratstvo i

6 Jedinstvo.

7 Risto Djogo: The bridge of the Serbian warriors.

8 Jovan Tintor: The bridge of the Serbian warriors, to connect --

9 to join up by using the bridge and to go into the direction of the Vrbanja

10 bridge. Of course, I had an order, well, actually, it was just an

11 agreement to take the military hospital as well and to join up that way

12 also. I was given these instructions and they told me: 'You go to Zuc and

13 wait for the command. Join up with Pofalici, and when you receive the

14 order, Mr. Kukanjac will give the order, then you will go down and cut the

15 city in two. In that way, we will establish contact with both Serbian

16 sides.' And I personally believe, that if we did it then, the war would

17 have stopped right away. Sarajevo would be divided in two enclaves ..."

18 MR. HANNIS: Thank you.

19 Q. Any comment on that one?

20 A. This is also interesting, not just for his assertion of his

21 military role but for his description of going to a meeting with Karadzic

22 and Mr. Krajisnik, as well as other leaders, Stanisic and Mandic,

23 discussing how to divide Sarajevo in two militarily. He says: "I was

24 given an order," and then he corrects himself to an agreement, which

25 implies the meeting had some discussion and they reached an agreement as

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10

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12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.

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15

16

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25

1 to how he and other -- I'm sorry, as to how he would operate on the -- on

2 the ground. And this operation, he says, didn't actually take place as

3 discussed. But I find the meeting, the discussion, and the agreement on

4 further action significant.

5 Q. Thank you. Next I want to ask you about another Crisis Staff head

6 who took some military role. Tab 157, which is master tab 417. This is

7 an intercepted conversation between Nedeljko Prstojevic and a Miroslav

8 Gagovic on the 23rd of May, 1992.

9 Before we play that, can you direct us to where the excerpt you

10 want to talk about begins?

11 A. It begins on page 2 in the English, eight boxes up from the

12 bottom, Prstojevic saying, "however, these people should know." And I

13 will find it -- it begins at the very bottom of the B/C/S 04014074, the

14 very last box and onto the next page.

15 Q. And we'll play that one now.

16 [Intercept played]

17 THE INTERPRETER: [Voiceover]

18 "Nedeljko PRSTOJEVIC: However, these people should know about the

19 Ilidza policy.

20 Milosav GAGOVIC: Yes.

21 Nedeljko PRSTOJEVIC: We have a sort of a big, the highest

22 municipality.

23 Milosav GAGOVIC: Certainly.

24 Nedeljko PRSTOJEVIC: We have our policy in the area of Sarajevo.

25 Milosav GAGOVIC: Certainly.

1 Nedeljko PRSTOJEVIC: Our policy in relation to refugees from

2 Sarajevo.

3 Milosav GAGOVIC: Fine.

4 Nedeljko PRSTOJEVIC: All the Serbs, men, women, children, adults

5 will be accepted by Ilidza.

6 Milosav GAGOVIC: Fine.

7 Nedeljko PRSTOJEVIC: And shall be accommodated.

8 Milosav GAGOVIC: OK.

9 Nedeljko PRSTOJEVIC: Accommodation, food and the rest.

10 Milosav GAGOVIC: Fine.

11 Nedeljko PRSTOJEVIC: Secondly, no Muslim shall be allowed to

12 leave Sarajevo.

13 Milosav GAGOVIC: Sorry?

14 Nedeljko PRSTOJEVIC: We shall not allow the Muslims to leave

15 Sarajevo.

16 Milosav GAGOVIC: Fine.

17 Nedeljko PRSTOJEVIC: ... the same number of the Serbs.

18 Milosav GAGOVIC: OK.

19 Nedeljko PRSTOJEVIC: Because due to ... policy I accepted to

20 perform ... Serbian people.

21 Milosav GAGOVIC: Fine."

22 THE INTERPRETER: Could we hear that passage again, please, thank

23 you?

24 "Nedeljko PRSTOJEVIC: I have accepted it and took it in writing.

25 I also told the press centre to register our views for the history.

1 Milosav GAGOVIC: OK, Nedjo.

2 Nedeljko PRSTOJEVIC: Please, I heard about some negotiations. I

3 heard that they were organising some new convoy. It will not pass

4 through.

5 Milosav GAGOVIC: You're absolutely right. You're commanding, you

6 have control and that's it.

7 Nedeljko PRSTOJEVIC: It will not pass through."

8 JUDGE ORIE: I heard another voice in between, something about

9 repeating a passage. Did I hear that correctly?

10 THE INTERPRETER: Your Honour, the French booth was listening to

11 the B/C/S and was therefore not really able to hear very well this

12 passage. Maybe we could hear it again.

13 JUDGE ORIE: Yes. Let's hear it again, and then I take it the

14 French booth translates the English or ...

15 I'm now on channel 5 so I now can.

16 THE INTERPRETER: Your Honour, we would then be interpreting from

17 English, because we cannot really hear the B/C/S very clearly, if you want

18 to play it again.

19 JUDGE ORIE: We will commence.

20 [Intercept played]

21 THE INTERPRETER: [Voiceover]

22 "Nedeljko PRSTOJEVIC: However, these people should know about the

23 Ilidza policy.

24 Milosav GAGOVIC: Yes.

25 Nedeljko PRSTOJEVIC: We have a sort of big, the highest

1 municipality.

2 Milosav GAGOVIC: Certainly.

3 Nedeljko PRSTOJEVIC: We have our policy in the area of Sarajevo.

4 Milosav GAGOVIC: Certainly.

5 Nedeljko PRSTOJEVIC: Our policy in relation to refugees from

6 Sarajevo.

7 Milosav GAGOVIC: Fine.

8 Nedeljko PRSTOJEVIC: All the Serbs, men, women, children, adults

9 will be accepted by Ilidza.

10 Milosav GAGOVIC: Fine.

11 Nedeljko PRSTOJEVIC: And shall be accommodated.

12 Milosav GAGOVIC: OK.

13 Nedeljko PRSTOJEVIC: Accommodation, food and the rest.

14 Milosav GAGOVIC: Fine.

15 Nedeljko PRSTOJEVIC: Secondly, no Muslim shall be allowed to

16 leave Sarajevo.

17 Milosav GAGOVIC: Sorry?

18 Nedeljko PRSTOJEVIC: We shall not allow the Muslims to leave

19 Sarajevo.

20 Milosav GAGOVIC: Fine.

21 Nedeljko PRSTOJEVIC: ... the same number of the Serbs.

22 Milosav GAGOVIC: OK.

23 Nedeljko PRSTOJEVIC: Because due to ... policy I accepted to

24 perform ... Serbian people.

25 Milosav GAGOVIC: Fine.

1 Nedeljko PRSTOJEVIC: I have accepted it and took it in writing.

2 I also told the press centre to register our views for the history.

3 Milosav GAGOVIC: OK, Nedjo.

4 Nedeljko PRSTOJEVIC: Please, I heard about some negotiations. I

5 heard that they are organising a new convoy. It will not pass through.

6 Milosav GAGOVIC: You're absolutely right. You are commanding,

7 you have control and that's it.

8 Nedeljko PRSTOJEVIC: It will not pass through."

9 JUDGE ORIE: Thank you. I admire the speed at which you are able

10 to translate.

11 MR. HANNIS: Thank you.

12 Q. Ms. Hanson, any comment on that one?

13 A. I was struck here by the army commander because Gagovic was at

14 this time acting as commander of the 4th Corps Sarajevo, saying to the

15 commander of the Crisis Staff, "you are commanding, you have control." He

16 is acknowledging Prstojevic's authority in his municipality, and also very

17 indicative of the communications that a commander of the Crisis Staff

18 calls the army commander, says "I'm not going to let a convoy through,"

19 and the army commander says, "you've set the policy," and is accepting

20 that. It doesn't mean that Prstojevic is actually commanding the army per

21 se, but that the army is acknowledging -- the word "command" obviously has

22 some weight in the military terminology, so he's acknowledging the

23 authority of the Crisis Staff in this matter.

24 Q. Thank you. The next two tabs I think you put in for purposes of

25 identifying the speakers to that conversation?

1 A. Yes. Prstojevic is the president of the Crisis Staff of Ilija,

2 and Gagovic as commander -- acting commander of the 4th Corpse.

3 Q. And that's tab 158, master tab 326, regarding Prstojevic; tab 159,

4 master tab 437 regarding Gagovic.

5 Let me go to tab 160 in the presentation, master tab 174. Can you

6 tell us what that document is and what you wanted to show from there?

7 A. This is the minutes of the government session of the 21st of May,

8 1992. We have seen it before on the question of support to Crisis Staffs.

9 Here, I would draw your attention to page 3 of the translation, about

10 two-thirds of the way down. And in the original, on page 3, that is,

11 01245324, the fifth item down. In the original, there is a blank, as

12 indicated in the translation.

13 Q. And is there a corresponding blank in the original?

14 A. Yes, there is a corresponding blank in the original. The

15 government has decided "to bring the decision on" something, the something

16 "of Crisis Staffs as the military was taking over the defence and to

17 create the conditions for work of regular institutions."

18 As we know -- as we saw earlier, at the next session of the

19 government, they do explicitly say to abolish Crisis Staffs. That would

20 be consistent with the phrasing here, because they're saying, since the

21 army is taking over defence, this is the point I wanted to bring your

22 attention to here, they're doing something to Crisis Staffs. As we know,

23 at the next session they decide it should be abolished, so I think it's a

24 reasonable assumption here to say that that's what they're saying, because

25 the army is taking over defence.

1 This is the 19th of May. As we know, at the 12th of May Assembly

2 session, the army -- the establishment of the VRS was announced. It was a

3 formal decision on the establishment on the 19th of May. So two days

4 later, after the VRS has been established, they're noting that the army is

5 taking over defence. And as we know, they took steps at this time to

6 abolish Crisis Staffs, which I think is indicative of the role the Crisis

7 Staffs had until this point in defence. Now they have an army, the army

8 is taking over defence.

9 Q. Let me follow it up, then -- you mentioned this but we'll show it,

10 presentation tab 161, master tab --

11 A. Oh, they did -- they are there. I apologise. I didn't realise

12 we'd be seeing that as well.

13 Q. -- master tab 107, I think, is the point you were trying to make,

14 that two days later --

15 A. Yes, just to say that blank was probably similar to the word

16 "abolish". We don't know what the blank is.

17 Q. Can you direct us to where we are in this document?

18 A. It was item 4 -- this is the minutes of the 23rd of May of the

19 government session, item 4. We have seen this in the various presidential

20 decisions and instructions. Just to point out that one of the processes

21 going on at this time, in addition to forming the other legal organs, was

22 the formation of the army. And Crisis Staffs were to be -- to give up

23 their role, although, as we'll see, they maintained close contact.

24 Q. Next is presentation tab 162, master tab 255. Again, this is the

25 combat-readiness report. And was there an excerpt from here that you

1 wanted to talk about in connection with this?

2 A. Yes. Again, the army itself gives a good description of this

3 process. On page 11 in the translation, I believe it's 11 -- the number

4 is a little cut off. This is -- in the B/C/S, it's 00607349, the fourth

5 paragraph. It's the first paragraph on page -- in the English

6 translation. It says that the second period in the establishment of the

7 army came after -- was the establishment of the Main Staff in May, and

8 then the next sentence: "By a decision of the Presidency of Republika

9 Srpska of 15 May [sic] 1992 on the establishment, organisation, formation

10 and command of the army of Republika Srpska, the organised life and combat

11 operations of the army of Republika Srpska actually started, which, by a

12 decision of the commander of the Main Staff of 16 June, 1992, was directed

13 to pursue the basic strategic interests of the war of the Serbian people."

14 So the army, as we saw from this and previous excerpts, similarly

15 sees various stages in the development of the army. From the SDS-formed

16 units to the Crisis Staffs commanding the first infantry units, to the

17 army up and running, really, by 15 June here, it says the organised life

18 and combat operations actually started. So those time periods are

19 important to bear in mind when thinking about the question of Crisis Staff

20 command of the army.

21 It's also interesting, the last phrase in that paragraph, that the

22 army was directed to pursue the basic strategic interests, which could be

23 a reference to the strategic objectives. It's similar language.

24 Q. In connection with that --

25 JUDGE ORIE: Mr. Hannis, may I just --

1 MR. HANNIS: Certainly.

2 JUDGE ORIE: Ms. Hanson, by reading, you said the 15th of May, but

3 I take it that you wanted to read the 15th of June.

4 THE WITNESS: Yes, my apologies if I misspoke.

5 JUDGE ORIE: Please proceed.

6 THE WITNESS: Thank you.

7 MR. HANNIS: Thank you, Your Honour.

8 Q. Now I'd like to go to presentation tab 163, master tab 264. And

9 to follow up on the point you were making about the strategic objectives,

10 you referred to the strategic objectives of the Serbian people as

11 announced in the --

12 A. In the 12th of May session. We'll see that again in the case

13 studies, another indication of how these strategic objectives were

14 communicated to the ground. But we see an example here at the minutes of

15 a meeting of the command of the 1st Partizan Brigade with presidents of

16 municipalities in their zone of responsibility, dated the 14th of May. So

17 two days after the 12th of May Assembly session, after the declaration of

18 the establishment of the army, the commander of the 1st Brigade meets with

19 the political leaders of the municipalities. Present at the meeting, we

20 see, item 1, Colonel Galic; item 2, Colonel Basar; item 5, president of

21 the Kljuc municipal assembly, Jovo Banjac. He was also acting at this

22 time as president of the Kljuc Crisis Staff. Similarly, item 6, the

23 president of Sipovo municipal assembly, Radislav Djukic, was at this time

24 president of the Crisis Staff of Sipovo.

25 Q. And at this meeting on the 14th of May, 1992, what were the items

1 discussed? Or is there one you want to bring to our attention?

2 A. Well, particular attention, on page 3 in the translation, also

3 page 3 in the B/C/S, that is, 00421535. The president of the Mrkonjic

4 Grad municipal assembly, who was also a deputy at the national assembly,

5 presents the conclusions from the meeting held in Banja Luka. I take this

6 to be a reference to the Banja Luka, that is -- Assembly session, the 12th

7 of May Assembly session that was held in Banja Luka, because the

8 conclusions he presents are all consistent with the conclusions of the 12

9 May Assembly session: To name the armed forces of Krajina - as it is put

10 down here - to name them the army of the Serbian Republic of

11 Bosnia-Herzegovina, and describes how members of the JNA from the area

12 will be members of the VRS; the land forces, air force will be developed.

13 He presents the strategic goals formulated at the meeting in Banja Luka.

14 Number 1, "There must be a state separation of the three national

15 communities; 2, Krajina must be connected with Serbia along the right bank

16 of the Sava River; 3, creation of a corridor along the Drina river valley;

17 4 establishing borders from the Una river to the Neretva river; 5, it was

18 said that Sarajevo must either be divided or razed to the ground; 6,

19 examine the possibility of access to the sea for the Serbian Republic."

20 So it is interesting that we see the decisions of the Assembly

21 being conveyed to presidents of municipalities and army leaders, and they

22 are meeting together to discuss the transformation of the army. And these

23 strategic goals are similarly being transmitted to this municipal level

24 and to the army.

25 I would note that one of the strategic objectives that we do know

1 is formulated at the 12 May Assembly session is not specified here -- oh,

2 it is, the Drina, I'm sorry. I thought the Drina was missing, but it is

3 there.

4 Q. I do have a question about the formulation of the objectives here

5 as compared to how they were stated in the Assembly. In particular, with

6 regard to number 5, Sarajevo --

7 A. Yes, number 5 is the different one. In the Assembly, there is no

8 mention of it being razed to the ground.

9 Q. One of the attendees at this meeting is Colonel Galic --

10 A. Yes.

11 Q. -- who later was involved in the siege of Sarajevo?

12 A. He is one of the attendees.

13 JUDGE ORIE: I'd like to ask you, Mr. -- in 5, I see in the

14 translation, "double-underlined" in the original. That must be another

15 original. We came across that several times, because there's no

16 double-underlining, Mr. Hannis, in 5 of ...

17 MR. HANNIS: Your Honour, I agree. I see what you're talking

18 about. It does have the same ERN number that 01106533 is purporting to be

19 a translation of, so I would assume that that was from a copy.

20 JUDGE ORIE: I take it, as a matter of fact, that it is -- yes, it

21 could be, but perhaps there are several originals. Could you please check

22 that? It's somewhere in the back of my mind, but I must be careful that

23 I'm not mixing up cases, that there are various versions of this document

24 in B/C/S.

25 MR. HANNIS: Your Honour, we will make a note and check on that

1 and report back to you.

2 JUDGE ORIE: Yes. And perhaps if it sounds not familiar to you,

3 to consult colleagues of yours who have been dealing with the matter.

4 MR. HANNIS: I will.

5 MR. STEWART: Your Honour, I wonder at this moment, because I

6 wasn't quite sure what the timetable was intended to be this morning, I

7 did have one practical suggestion, unless Your Honours already had a --

8 something in mind, which --

9 JUDGE ORIE: I am aware that many of you have been in this

10 courtroom when we had not yet started, so I intended to have a break from

11 10 minutes past 11.00 until 11.30. That would be a short break, 20

12 minutes. Then go on after the break until 12.30, and then have another

13 break for 20 minutes until 12.50, and then finished by 13.45.

14 MR. STEWART: Your Honour, I have absolutely no problem with that.

15 The tiny practical suggestion, Your Honour, was this: That the timetable

16 would enable, Your Honours, in fact to have a single break. If Your

17 Honours broke at 11.35 and broke until 12.15, we can manage with one break

18 and then go to the end of the day.

19 JUDGE ORIE: Yes. I considered that. But since some of those who

20 are assisting us were in court all the time, waiting, on the suggestion of

21 Madam Registrar, I decided that we would have two short breaks.

22 MR. STEWART: Yes, of course, Your Honour, then obviously we'll

23 accept and are content with that.

24 JUDGE ORIE: Yes.

25 Please proceed, Mr. Hannis.

1 MR. HANNIS: Thank you.

2 Q. I don't have any other questions about that. Did you have any

3 other comments --

4 A. No, that was -- I'm sorry, I'll just repeat that this is also

5 consistent with what we saw in the description of the role of the

6 deputies, that they are the ones to go to the municipality and convey the

7 decisions of the Assembly. And we see this in practice here.

8 Q. Thank you. Then I would like to go to presentation tab 164,

9 master tab 205. This is an intercepted telephone conversation between

10 General Mladic and Colonel Gagovic and Professor Unkovic on the 13th of

11 May. Can you direct us to which portion of that conversation we'll be

12 listening to?

13 A. In the English translation, about two-thirds of the way down the

14 first page, starting with Mladic saying, "This is General Mladic here."

15 And in the B/C/S, it's the second box from the bottom on the first page of

16 the B/C/S, 03220204.

17 Q. Okay. We'll play that one now.

18 JUDGE ORIE: Before we do so, Mr. Hannis --

19 MR. HANNIS: Yes, Your Honour.

20 JUDGE ORIE: -- it's not suddenly my favorite subject, but in the

21 English version, I find parts emphasised by underlying, whereas I do not

22 find that in the original.

23 MR. HANNIS: I apologise for that, Your Honour. I didn't notice

24 that. I will provide a clean copy to the Court and counsel.

25 JUDGE ORIE: Please do so. Let's now listen to the intercept.

1 MR. HANNIS: Thank you.

2 [Intercept played]

3 THE INTERPRETER: [Voiceover]

4 "Mladic: This is General Mladic here. How are you?

5 Unkovic: Welcome to our house.

6 Mladic: Thank you. May we have luck in our endeavour.

7 Unkovic: May great Lord help you.

8 Mladic: Tell me, do you ... Let me first tell you about what

9 you're interested in.

10 Unkovic: Yes?

11 Mladic: Koljevic will come ... Koljevic ...

12 Unkovic: Mmm.

13 Mladic: ... Ostojic and myself will represent our side.

14 Unkovic: Excellent.

15 Mladic: There. So there is no need for you to have a

16 representative as Ilidza. You can, however, join us and let us know about

17 your problems there, if it is safe for you to come. The most important

18 thing now is that the military formations, no matter who they belong to,

19 be put under the command of the 4th Corps HQ, to Gagovic.

20 Unkovic: Yes?

21 Mladic: All this. Units shall be brought to strength, formed,

22 organised and everything must be all right.

23 Unkovic: Excellent.

24 Mladic: Have you understood me?

25 Unkovic: Yes.

1 Mladic: I'll give you further instructions when we get together.

2 Unkovic: Excellent.

3 Mladic: There.

4 Unkovic: One more question.

5 Mladic: Yes?

6 Unkovic: We have some Arkan's men here.

7 Mladic: Yes?

8 Unkovic: Are they under our command?

9 Mladic: All of them are. All under arms are under my command, if

10 they want to stay alive that is.

11 Unkovic: Excellent. Excellent.

12 Mladic: So, all those shall be under our command. No one shall

13 do things on their own, and the five-day cease-fire must be observed.

14 Unkovic: Yes.

15 Mladic: But, in case they attack you, approach you, then you will

16 destroy them.

17 Unkovic: Of course.

18 Mladic: There.

19 Unkovic: Sure thing."

20 MR. HANNIS:

21 Q. Any comment on that one, Ms. Hanson?

22 A. Again, I would note the date here, the 13th of May, the day after

23 the announcement of the establishment of the VRS. Unkovic identifies

24 himself as from the Crisis Staff from Ilidza, and Ratko Mladic addresses

25 him directly, saying that units shall be filled with men, formed,

1 organised, and put under the command of the 4th Corps, Gagovic. That is,

2 again, consistent with the process of the establishment of the army. And

3 also the question of Arkan's men, Mladic insisting that all -- anyone with

4 a gun, even the paramilitaries, such as Arkan's men, are under "our

5 command." Unkovic says "our command," indicating the united command. I

6 don't think he's claiming here his Crisis Staff authority, but rather,

7 We're all on to the same side, they're under our command.

8 The direct contact itself is significant; that a member of the

9 Crisis Staff is talking directly with Mladic. Mladic -- the first subject

10 on whether Koljevic will come and Ostojic's question of negotiations about

11 the airport, and Mladic is saying, You can come and let us know your

12 problems. So clear contacts between Crisis Staff and military leadership,

13 and a commonality of purpose here.

14 Q. Thank you.

15 MR. HANNIS: Your Honour, the next one is another intercept of

16 about the same length, so perhaps this would be a good time for the break.

17 JUDGE ORIE: It is 10 minutes past 11.00, so perhaps before we go

18 to the next one, we'll have a break of 20 minutes now.

19 --- Recess taken at 11.10 a.m.

20 --- On resuming at 11.35 a.m.

21 JUDGE ORIE: Mr. Hannis, please proceed.

22 MR. HANNIS: Thank you, Your Honour.

23 Q. I was ready to go next to presentation tab 165, master tab 266.

24 This is another intercepted conversation, Your Honours, between Ratko

25 Mladic and a Glisa Simanic on the 25th of May, 1992. Ms. Hanson, could

1

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4

5

6

7

8

9

10

11

12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

1 you direct the Court to where we're beginning.

2 A. Yes, we're beginning almost at the beginning. The third line of

3 the conversation on page of the translation, and similarly, the third box

4 on the first page of the B/C/S. I would note before we begin that Glisa

5 Simanic was a member of the Crisis Staff of Trnovo, and when we get to the

6 Trnovo Crisis Staff, we'll see a quite lot about Glisa Simanic.

7 Q. Thank you. We'll play that one now.

8 [Intercept played]

9 THE INTERPRETER: [Voiceover]

10 "Simanic Glisa: The line was interrupted.

11 Mladic Ratko: Who are you?

12 Simanic Glisa: Glisa Simanic.

13 Mladic Ratko: From Trnovo?

14 Simanic Glisa: Yes.

15 Mladic Ratko: This is General Mladic here.

16 Simanic Glisa: How are you?

17 Mladic Ratko: Excellent. What's going on over there?

18 Simanic Glisa: Well, we have a ... some movement by their forces

19 from the direction of Konjic.

20 Mladic Ratko: Where are they headed?

21 Simanic Glisa: They're headed ... a convoy of trucks has set out.

22 We think they could only be ...

23 Mladic Ratko: I asked where they were headed. I didn't ask you

24 to think. Where are they headed?

25 Simanic Glisa: From the direction of Konjic towards the village

1 of Lukomir.

2 Mladic Ratko: Lukomir? And then?

3 Simanic Glisa: Yes. Then towards Sabici and Trnovo.

4 Mladic Ratko: All right. And then by way of Lukomir and Sabici?

5 Simanic Glisa: Yes, yes. This convoy is on the move now.

6 Mladic Ratko: On the move? How many of them are there?

7 Simanic Glisa: We don't know that.

8 Mladic Ratko: And who ... do you have the means to stop this

9 convoy?

10 Simanic Glisa: No, because this is ...

11 Mladic Ratko: Well, of course not, because you waste time in

12 Trnovo sitting in bars. Comrade, form a group of ten to twenty soldiers,

13 intercept the convoy and capture them. Do you understand me?

14 Simanic Glisa: Listen ...

15 Mladic Ratko: You listen to me. Did you hear what I ordered you?

16 Simanic Glisa: Yes.

17 Mladic Ratko: That's what you will do. Find a way to penetrate

18 through there and set up an ambush somewhere in those woods, wait for

19 them, check them out, capture them and fucking chase them away. And don't

20 give me that bullshit like we went here or we went there. You're not

21 reconnaissance but infantry. Is the road towards Dobro Polje and Kijevo

22 negotiable?

23 Simanic Glisa: Barely.

24 Mladic Ratko: Why?

25 Simanic Glisa: We heard some kind of explosion down at the dam.

1 We've just sent a reconnaissance to check it out. It seems they have

2 mined the road down there.

3 Mladic Ratko: Never mind. Let them mine it. Anything else?

4 Simanic Glisa: We don't have any other interesting information

5 for now.

6 Mladic Ratko: You see what it's about? Is it you or them who

7 controls Trnovo?

8 Simanic Glisa: It's us.

9 Mladic Ratko: You have Trnovo under control?

10 Simanic Glisa: Yes.

11 Mladic Ratko: Excellent. So, one can get through to Trnovo?

12 Simanic Glisa: From the direction of Dobro Polje.

13 Mladic Ratko: From the direction of Dobro Polje?

14 Simanic Glisa: No problem.

15 Mladic Ratko: Excellent. Check that thing down there and you'll

16 have to get in contact with those ... I'm offering them peace if they want

17 peace. And tell them, those Muslims there, that they had better not start

18 anything because they'll go to hell.

19 Simanic Glisa: I understand.

20 Mladic Ratko: And whenever they want it I'll come to talk.

21 Simanic Glisa: I understand.

22 Mladic Ratko: There. I will designate a place for our meeting.

23 You just get in contact with them sometime today and let me know. I will

24 come and tell everyone where we'll meet.

25 Simanic Glisa: I understand."

1 MR. HANNIS:

2 Q. And your comment on that one?

3 A. Well, as I said, Glisa Simanic is a member of the Trnovo Crisis

4 Staff, and here he's getting orders from Ratko Mladic. The word he says

5 -- is translated as "I understand it," it means that "razumijem" but it's

6 also the military equivalent of "yes, sir," what you say when you're given

7 an order. If you hear the intonation, it sounds very much like yes, sir.

8 It's also interesting here, Mladic is expecting further contact

9 with Simanic, authorising him to negotiate in his name, talk to the

10 Muslims, get back to me, we'll arrange a meeting. And, as the order makes

11 clear, ordering him to take military action to seize a convoy.

12 Q. Thank you. The next tab, presentation tab 166, master tab 44, is

13 a document you put in to show who Simanic was.

14 A. Yes. We'll see this document again in the Trnovo case study, but

15 it's notable here that he is -- it's minutes of the Trnovo SDS municipal

16 board, 27 December 1991. Simanic is named as coordinator for crisis

17 situations. And we see him speaking to Mladic in a moment of apparent

18 crisis.

19 Q. I have a translation question. It appears in the English in that

20 document. The name is Glisa Simanic. I note that the original document

21 is a handwritten document. Do you know from other information that it

22 should be Glisa Simanic?

23 A. Yes. We will see that name in many of the Trnovo documents, and

24 the handwriting is not the clearest. But perhaps the interpreters could

25 confirm. It's in the original at 02280490 that it appears to be more

1 Simanic than Simonic.

2 Q. We'll take your word for it. We don't have it in Sanction to put

3 it up for the interpreters.

4 A. Okay. I can put it up.

5 Q. Perhaps we can see it on the ELMO.

6 THE INTERPRETER: Simanic.

7 MR. HANNIS: Thank you.

8 Q. Next I'd like to go and ask you regarding now, after the formation

9 of the VRS in May 1992, did you see a change in how the Crisis Staffs were

10 interacting with the military?

11 A. We see continued close coordination and contacts with the military

12 in this time period. As the military structures are being set up and

13 empowered, we see more assertion, naturally, of militaries having their

14 own command structure and command authority over the units. But we see

15 continued close contacts, which is part of the coordinating functions of

16 the Crisis Staff that we saw in the normative documents, that coordination

17 of defence was one of their principle roles. And we see this borne out.

18 Even as the military has their own command structures, they are in close

19 contact with the municipal authorities, in this case the Crisis Staff and

20 the War Presidencies --

21 Q. And that's reflected in the next set of documents?

22 A. Yes.

23 Q. Let me take you to tab 167, master tab 201.

24 A. This is the minutes of the Crisis Staff of Bosanski Petrovac on

25 the 10th of June, 1992. I would just note here that a representative of

1 the command is here. I take that to be the military unit there. It's

2 clear in other items what kind of military -- it's a little vague right

3 here, but we'll see other documents that make it clear they're talking

4 about military command.

5 Q. And tab number 168, which is master tab 267. Tell us what that is

6 and what you want to refer us to.

7 A. If I could put the highlighted version on the ELMO, because this

8 binder does not seem to have the updated translation. If I could just do

9 that. This is minutes of the meeting of the Kotor Varos Crisis Staff from

10 the 6th of July, 1992. Under item 2 in the minutes, then number 2 within

11 that: "It was agreed to replace the municipal Crisis Staff with a War

12 Presidency that would comprise the municipal assembly president, the

13 executive committee chairman, the secretary of the secretariat for

14 national defence, public security station chief, secretary of the

15 secretariat for the economy, and the commander of the largest unit

16 carrying out combat operations within the municipality."

17 Notable here that the date is the 6th of July, so we can see that

18 the Crisis Staff does -- is replaced with a War Presidency, but much later

19 than the decision we saw issued on the 31st of May. But the makeup is

20 similar and is consistent with the idea of coordination of defence and

21 other municipal organs, so specifying the commander of the largest unit in

22 the municipality is to be a member of the War Presidency.

23 Q. And actually, at that time in July, wouldn't it have been,

24 according to the series of documents, we have going from Crisis Staff to

25 War Presidency to War Commission, it should have been a War Commission --

1 A. As the documents are written, yes, it would appear. But we have

2 seen so many War Presidencies at this time that it's not surprising -- it

3 is quite consistent with the pattern we see, that they are not always War

4 Commission, often War Presidencies, yes.

5 Q. Next, let me take you to presentation tab 169, master tab 141.

6 A. This is a document we've seen before, but I just wanted, in this

7 case, to point out, as I did at the -- first time I showed it. I don't

8 mean to bore you with repetition. It's conclusions of the Crisis Staff of

9 Sanski Most on the 30th of May, but I wanted to note here that under item

10 10, Branko Basara, commander of the 6th Krajina Brigade, is a member of

11 the Crisis Staff. If you'll recall, he was also at that meeting of the

12 14th of May that we looked at before the break. So, again, the military

13 commander is included in the Crisis Staff.

14 Q. Thank you. Next, I'd like to show you tab 170 in the

15 presentation, master tab 273. This is from the command of the 1st Krajina

16 Corps.

17 A. This is an order of the 1st of July, of the 1st Krajina Corps

18 command. I would take you to the top of page 2 in the translation; in the

19 B/C/S, on the second page, 01029804, the fourth paragraph from the bottom.

20 Q. And what is General Talic directing?

21 A. General Talic here says that: "Zone commanders shall establish

22 personal contact with organs of authorities who are duty-bound to perform

23 the tasks for which they are responsible. The latter cannot command units

24 located on the territory of the municipality."

25 As I said, this is the 1st of July, so we would expect here,

1 according to the army's account of its establishment, that by now it is --

2 its actual life, operational life, has begun. So it is consistent with

3 that pattern that Talic is now saying that regional -- zone commanders

4 should establish contact with the municipal authorities -- here it says

5 simply organs of authorities, but it appears to be referring to the

6 municipalities, and that those organs of authority cannot command units,

7 indicative, perhaps, of the fact that some did command before the

8 establishment of the army. Now the army is asserting its command

9 authority over units.

10 Q. And tab 171 in the presentation, master tab 284, is this a

11 reflection of at least one Crisis Staff recognising that difference, that

12 now there is an army?

13 A. Yes. It's page 4 to 5 in the English.

14 Q. And what document is this from?

15 A. Yes. This is the bulletin of the Crisis Staff of Kotor Varos.

16 This is issue number 3 of the 26th of June, 1992. You'll recall that we

17 saw -- we looked at issue number 6 yesterday. Yes, at the bottom of the

18 second page in the B/C/S, 00416213. At the very bottom of page 4: "The

19 Crisis Staff concluded that it does not have the right to interfere in the

20 professional work of the police and army, nor does it wish to do so. But

21 it does request that they themselves undertake security and the creation

22 of conditions for full security on the municipal territory."

23 So this is a Crisis Staff that is distancing itself from command

24 of those units, saying it's a job for professionals. But you'll recall

25 that we did see in Kotor Varos, they named the commander of the largest

1 unit as a member of the War Presidency, when it was established. This

2 phrasing, you will recall, is also consistent with Djeric's instructions

3 of 26 April 1992, which said, prevent any interference in the command of

4 the TO and the army because that is -- of the police, because that is a

5 job for professionals.

6 Q. Thank you. I want to go to tab 172 in the presentation, master

7 binder 124 -- master tab 124. This is an article from a publication

8 called Glas. Can you tell the Court what Glas was?

9 A. It was a daily newspaper in the RS, I believe from Banja Luka.

10 Q. And what is the excerpt you wanted to bring to the Court's

11 attention?

12 A. This is an article from the 7th of July, 1992, from a press

13 conference held by Colonel Bogdan Subotic, Defence Minister of the Serbian

14 Republic. He is saying that it is -- he's informing the public of the

15 government decree on disbanding Crisis Staffs in all municipalities where

16 conditions exist for the operation of legal authorities. In particular,

17 the third paragraph of the translation; in the original it's on page

18 00951907, it's the third paragraph of the black box text. It's a

19 newspaper article -- newspaper front page, and there's a lot of articles,

20 but the last one on the front page.

21 "'Experience,' says Subotic, 'so far shows that the jurisdictions

22 of Crisis Staffs and military organs were not always clearly delineated,

23 so minor misunderstandings occurred.'".

24 Q. Now, I want to move to another topic regarding the military and

25 the Crisis Staffs. Now that the army has been created and there appears

1 to be some recognition that that's a separate professional body, did that

2 end relationships between Crisis Staffs and the military?

3 A. Not at all. Relations remained very close, because the Crisis

4 Staffs continued to play an essential role in supporting the military

5 units in their municipalities and in coordinating, sharing information

6 with the military leadership, as we saw. The military presence was a

7 constant on many -- most Crisis Staffs, it's a constant pattern we see.

8 And this whole question of the support is something we see throughout the

9 time period. I've been trying to describe the various phases and

10 variations in the question of command and orders to units, but the

11 question of supporting units is something we see consistently throughout

12 the time period and throughout the different municipalities. So we can

13 put aside more complicated issues of variations and look at the consistent

14 coordination, support.

15 Q. And the next series of documents, there's some examples of that

16 support?

17 A. Yes. The first two are just a few of -- just two of very

18 numerous, numerous examples of mobilisation. This is one of the --

19 Q. The first one would be presentation tab 173, master tab 250.

20 A. The announcement of the Crisis Staff of Vogosca, dated the 11th of

21 May, 1992.

22 Q. And --

23 A. Announcing general mobilisation. I would also note here that the

24 municipal Crisis Staff is using the seal, the stamp, of the SDS municipal

25 office for its documents. Another indication of the overlap. But this is

1 one of many mobilisation orders, announcements.

2 Q. Another example of that, presentation tab 174, master tab 418.

3 A. This is from the Crisis Staff of Zvornik. As I mentioned before,

4 Zvornik had, in the first few days of the conflict, a Crisis Staff which

5 then formed a provisional government. We don't have them co-existing.

6 But this is one of the few documents from the Crisis Staff of Zvornik.

7 Again, an order on mobilisation.

8 Q. Next, let me show you presentation tab 175, master tab 272. This

9 is a report from the Krajina Corps. Could you direct the Court to the

10 excerpt you want to discuss?

11 A. Yes. It's at the bottom of page 2, the last full paragraph -- the

12 last paragraph on page 2.

13 Q. And in the B/C/S?

14 A. In the original, I'm just looking, it's on page 3 in the B/C/S,

15 that is, 00900794. And in the middle of the paragraph: "In future, the

16 commands of regiments, brigades --" I'm sorry, forgive me.

17 "In future, the commands of regiments, brigades, and independent

18 battalions must forward individual applications to the municipal and

19 communal Crisis Staffs because they are able to organise supplies, housing

20 and welfare benefits for the families of conscripts." Just a notation of

21 the army's view of the role of Crisis Staffs after the formation of the

22 army structures.

23 Q. Next, presentation tab 176, master tab 216. This is a document

24 dated the 2nd of June, 1992, from the Bosanski Samac Crisis Staff, and

25 another variation of support.

1 A. Yes, just indications of the kinds of support a Crisis Staff gave.

2 A decision of the Samac Crisis Staff of the 2nd of June. Under item 1,

3 the Crisis Staff instructs the executive committee to purchase 500

4 uniforms for the needs of the special purpose battalion of the VRS which

5 is stationed in the municipality.

6 Q. Now, tab number 177 in the presentation, master tab 147.

7 A. It's a decision of the Crisis Staff of Ilidza, dated the 10th of

8 May, 1992, saying, "Regarding the issue of the transfer of soldiers and

9 officers from the JNA to the army of the Republic of Serbian --" this is

10 before the actual establishment of the VRS.

11 At the top of the page 2 in the translation, under item 2 in the

12 B/C/S original: "The Crisis Staff and the Assembly of the Serbian

13 municipality of Ilidza takes upon itself the responsibility for caring for

14 the families of the Serbian soldiers and officers during the war, and for

15 making arrangements for their housing and employment after the war."

16 It also promises them other benefits and security. So just an

17 indication of the kind of support the Crisis Staffs offered militaries.

18 Q. All right. And next in the series, tab 178 in the presentation,

19 master tab 215. This is from Prijedor.

20 A. Yes. This is an interesting document. It is a report dated the

21 17th of June, 1992, of the logistics base of Cirkin Polje of the Prijedor

22 Crisis Staff. And it's reporting basically on the vehicles and other

23 resources of this logistics base. I would bring your attention to page 1,

24 the preamble, which says that: "Pursuant to the decision on the general

25 and public mobilisation, the decision of the Crisis Staff of the Serbian

1 municipality of Prijedor and the order of the commander of the Serbian

2 army Territorial Defence staff of Prijedor municipality, Major Slobodan

3 Kuruzovic, troops and equipment were mobilised in the logistical support

4 staff."

5 You can see that the Crisis Staff decision was needed for the

6 setting up of this support staff.

7 Q. And is there another excerpt?

8 A. Yes. There's an interesting excerpt on page 5 in the translation,

9 which I will find now in the original. This is on page 5 in the original,

10 P0008408. It notes in the first paragraph of the translation, top of page

11 5, that is -- I'm sorry, first paragraph on page 5, that they've sent a

12 report to the Crisis Staff and garrison command on sending supplies to

13 other staffs. Then the first full paragraph: "We would like to point out

14 that from the day of the takeover and the establishment of the logistics

15 section in the Serbian army TO staff in Prijedor up to 10 June 1992, in

16 addition to many sanitation and medical measures, we have also provided

17 the weapons and ammunition for sector staffs and secured and delivered

18 about 100.000 meals to members of the police and Serbian army TO units."

19 The next paragraph mentions accepting the restructuring of the

20 army in accordance with the decision of the Assembly of 12 May 1992.

21 And then the next paragraph, saying that a meeting of 10 June 1992

22 -- "A meeting of the Crisis Staff of the Serb municipality of Prijedor

23 and the garrison command, held on 10 June 1992, attended by Major Slobodan

24 Kuruzovic, commander of the Serbian army staff, as well as --" it names

25 some other commanders. "All instructions given by the garrison command

1 and the Crisis Staff relating to the transformation of the Territorial

2 Defence into the army of the Serbian Republic of BH were accepted. With

3 this in mind, we have taken a series of measures and steps in cooperation

4 with the garrison command logistics with the goal of providing full

5 material support to members of Serbian army units and police officers in

6 the municipality area, and providing food supplies to the prisons in

7 Keraterm and Omarska."

8 Q. All right.

9 MR. HANNIS: Your Honours, that's the last tab in binder number 4.

10 We're ready to hand up presentation binder number 5.

11 Q. Ms. Hanson, I think in the -- this next binder, we also have a

12 couple more examples of Crisis Staff support for the military.

13 A. Yes. As I --

14 Q. I'll get to that in a moment while we change binders.

15 JUDGE ORIE: May I put one question in relation to the last

16 binder.

17 THE WITNESS: Mm-hm.

18 JUDGE ORIE: This was a report of the Prijedor municipality Crisis

19 Staff, the logistics base in Cirkin Polje. To whom was it addressed, and

20 to whom was it sent? Where was it found?

21 THE WITNESS: It was found, I believe, with other documents of the

22 Prijedor Crisis Staff, but it is -- I don't have it in front of me, I

23 can't check the internal evidence, but there's no addressee, obviously,

24 there. We do see many summaries of reports of the work -- several

25 summaries of reports of work of the Crisis Staff to their municipal

1 assemblies. But the date of this is earlier than -- I believe we see the

2 Prijedor Assembly meeting in July. I don't take it to be then. I can't

3 say from the face of that document to see whom it is addressed.

4 JUDGE ORIE: Would there be a possibility for you to find out, I

5 don't know whether this is the only version of this report that exists or

6 whether it has been found in other places as well, to find out to whom it

7 was sent, even if not addressed, and who might have received it.

8 THE WITNESS: I will look into that.

9 JUDGE ORIE: Yes.

10 MR. HANNIS: Thank you, Your Honour.

11 Q. Now we're in presentation binder number 5, and the first tab,

12 presentation 179, master tab 219. Still talking about examples of

13 support.

14 A. Yes. This is the conclusions of the provisional government of

15 Zvornik of -- dated the 4th of June, 1992, but it shows the provisional

16 government setting the pay for members of a Territorial Defence, saying

17 that they will be paid by the -- under Article 4, paid by the accounting

18 service of the provisional government.

19 Q. Okay.

20 A. So an indication of the government providing the pay for what they

21 called Serbian Army Territorial Defence. In article 1, it's explicated

22 Serbian Army and Territorial Defence, indicating in May that this is a

23 period of transition. There's different units, different names. The

24 provisional government is paying them.

25 Q. And finally, in connection with this series of documents,

1 presentation tab 180, master tab 220.

2 A. This is -- it's called a recapitulation of transactions from the

3 cashiers of the Crisis Staff. It is found with other documents of the

4 Vogosca Crisis Staff. Although I do not see anything here specifying

5 that, I took it to mean the Vogosca Crisis Staff because it's among their

6 own documents.

7 Under item 1, I would just note, of their income -- I'm sorry,

8 under item 2, the outgoing payments, forgive me. If you look at the

9 bottom of the page, of the total outgoing payments of 22 million dinars,

10 14 million went to soldiers' daily allowance. So the bulk of their budget

11 was soldiers' pay. It indicates the extent to which Crisis Staffs devoted

12 themselves to supporting soldiers.

13 Again, to give you a rough order of magnitude, according to the

14 official exchange rate of the 1st of June - this is only rough, but to

15 give you a rough idea - 22 million is about 70.000 U.S. dollars.

16 Q. That concludes the documents I think --

17 JUDGE HANOTEAU: [Interpretation] Excuse me, I have a question.

18 How were these Crisis Staffs budgeted? I mean, where did they find that

19 money? Where did that money come from? Who decided what amount they

20 would get? Who decided how the money would be allocated between the

21 various Crisis Staffs? I would be grateful if you could answer that

22 question.

23 THE WITNESS: Well, this document may be able to answer it. If we

24 look at the top item, their income, the first line, it says "aid" and then

25 it says "SRBiH". It's translated "as aid to Socialist Republic", but I

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1 think that's a confusion, because in this case, the SR -- the S is more

2 likely to refer to Serb Republic. And it says "aid to" in English but if

3 I could just show the interpreters what the original is, it simply says

4 "aid" and then "SRBiH" could also be in B/C/S "aid from." We saw in the

5 accounts of the Ilijas Crisis Staff that the bulk of their income came

6 from the government of the Serb Republic of BH. We saw in the minutes of

7 the government sessions that they discussed giving loans to Crisis Staffs.

8 We'll see in Trnovo a similar assistance given from the government. Given

9 that I read this phrase, "pomoc SRBiH" it makes more sense to read it's

10 aid from the government. If it's "aid to," it could perhaps be voluntary

11 subscriptions from people, people just voluntary sending money and aid to

12 the government. But it's 5 million dinars, I don't know -- there's not

13 enough indication here to say it came from the government, but we've seen

14 that elsewhere.

15 As to how the resources were allocated, we simply see in the

16 government minutes that they discussed requests from different Crisis

17 Staffs, but no indication in the minutes of various merits of these Crisis

18 Staffs.

19 Also, other sources of income, according to this - could you put

20 the translation back up - money from a petrol station, money from a cafe,

21 and municipal accounts from the Giro account, it says, so preexisting

22 Municipal accounts. We'll see also in Trnovo other sources of municipal

23 income.

24 JUDGE HANOTEAU: [Interpretation] Yes. But my question was the

25 following: There was no regulation stating that each Crisis Staff would

1 receive a specific budget. Because when we look at this, everything seems

2 to be a bit anarchic, money cashed by a park bar, withdrawn from a Giro

3 account, from a petrol station. Do you have any comments about this?

4 THE WITNESS: Well, as we saw, the Crisis Staffs take over all the

5 competencies and duties of the municipal assembly, and municipal

6 governments were financed from various local taxes as well as from -- I'm

7 talking about the preexisting system. The municipality would have its own

8 accounts, would have local taxes and then aid from the state. I'm not an

9 expert -- I'm not that familiar with the previous financial systems. But

10 when the Crisis Staffs took over the municipal government, they also took

11 over the municipal accounts. So we see that the bulk of their money

12 coming from the municipal accounts. There is nothing in the documents,

13 the normative documents we've seen, that set out how Crisis Staffs should

14 operate. There's no mention of their budget. So I can't tell you more

15 than that.

16 JUDGE HANOTEAU: [Interpretation] Thank you very much.

17 MR. HANNIS:

18 Q. Ms. Hanson, let me ask you a couple more questions to follow up on

19 the Judge's question. With regard to this, you've described the 5 million

20 dinar amount as aid from the republic. And it seems to make sense that it

21 is from rather than to, because this is in the column listing their assets

22 as opposed to --

23 A. That's why I think that's a more logical interpretation.

24 Q. And a question about the preexisting system of collecting taxes,

25 are you familiar with the acronym SDK?

1 A. Yes. That's the social accounting office. It's called -- every

2 municipality would have this -- it was an important -- one of the

3 important municipal organs. Payments were made as the way of transferring

4 payments between companies and governments and bodies and so on.

5 Q. And that was in existence before the war broke out?

6 A. Yes. But taking one of the -- a common pattern we see in

7 takeovers includes taking over the SDK offices and therefore getting

8 control of their assets.

9 Q. That was something that was discussed in the planning stages?

10 A. Yes. We see Karadzic makes reference to it in an October speech

11 as one of the things that they should -- institutions which the Serbs must

12 control -- get control of, he says, even in those municipalities where we

13 maybe have the majority, we still haven't gotten control of all our

14 institutions, including the SDK.

15 Q. And with regard to the Judge's questions about who made decisions

16 about which Crisis Staffs might receive which amounts of money from the

17 republic, have you seen anything in the documentation, other than

18 something like we discussed yesterday, I believe, in government minutes

19 where they were -- had an agenda item talking about loans to Crisis

20 Staffs?

21 A. Beyond those government -- we see -- I know we see some specific

22 discussion of that in Trnovo. But at a larger level, on a larger -- a

23 discussion at the republican level of how to allocate funds, I'm not

24 familiar with anything at this moment.

25 Q. Now, this sort of concludes our discussion about the support of

1 the military by Crisis Staffs, and I think we're ready to move on and talk

2 about relations between the Crisis Staffs and the police. Was there

3 anything else you wanted to say in summing up on military and Crisis

4 Staffs?

5 A. Well, I'd just like to say that the military question is the most

6 complicated, with the most variables, so it's been a little, perhaps, hard

7 to sort out. The bottom line, the common denominator everywhere, is the

8 coordination and the support, the commonality of purpose. As Subotic

9 says, they were minor disagreements, but they were minor, and it was over

10 who actually may be ordering. But the consistent pattern we see on that

11 question everywhere is close coordination and support.

12 Similarly for police -- not similarly. For police, it is a

13 simpler picture, not so many variables. So we see many orders to police,

14 and we'll get to that section now. I'm saying we're putting the hard part

15 behind us.

16 Q. Okay. To segue into that, we're going to show some documents

17 regarding the police relations with Crisis Staffs. You say the picture

18 was simpler or more consistent in what way with the police?

19 A. As stipulated in the 19 December instructions in municipal Crisis

20 Staffs -- municipal Crisis Staffs, we do so the head of the police, either

21 the chief of the police station or the commander of the police, as members

22 of the Crisis Staff. We see reports from police to the Crisis Staffs on

23 their operations in the municipalities. We see orders from the Crisis

24 Staffs to the police. That is, again, consistent with how the police

25 functioned. They had their own command structure, of course, but taskings

1 would be given at the municipal level. They didn't get their day-to-day

2 taskings from their ministry.

3 We also see Crisis Staffs involved in setting up the police

4 forces, setting up Serbian police forces, taking over police stations and

5 dismissing non-Serbs from the police. Again, this is consistent with the

6 19 December instructions, which, for both variant A and B, stipulate

7 mobilising Serbs into the reserve police forces and taking over the police

8 station.

9 Q. Let me turn, then, to presentation tab 181, master tab 74. I

10 think you have a couple of examples for us of the creation of separate

11 Serb police departments within the municipalities.

12 A. Yes. A few examples. This is -- the first one is from Brcko.

13 This is a summary of the events and situations, basically a summary --

14 from internal evidence of -- yeah, it's signed the War Presidency at the

15 last page, it's signed the War Presidency of Brcko municipality.

16 Q. Is that a summary of the activity --

17 A. Of the War Presidency, or the events in the municipality.

18 Q. Can you direct us to the excerpt you want to --

19 A. Yes, it's on page 3 in the English translation. I'm -- it's on

20 page 4 in the B/C/S, that is, 00741400. It's the fourth paragraph in the

21 B/C/S, and the third paragraph in the English page 3.

22 "When the war began, various military formations started to

23 arrive in Brcko to help out. Since Brcko was part --"

24 No, I'm sorry, I'm reading the wrong -- forgive me, I'm reading

25 the -- I was reading the wrong one.

1 "When the war began and the public security station was taken

2 over, the same day, the War Presidency appointed Dragan Veselic chief of

3 the public security station and began staffing the station with new

4 people, including Serbs who had been employed there before."

5 So a description of the War Presidency's role in setting up a Serb

6 police -- police station.

7 Q. All right. Let me show you tab 182 in the presentation, master

8 tab 285, from another municipality. Actually, this document appears to be

9 a Ministry of Interior of the Socialist Republic of Bosnia, concerning

10 statements of policemen who had worked before the war broke out and were

11 removed.

12 A. Yes. You can see from the date, the 24th of March, 1992. It's at

13 the very -- it's from very early on. So I think their statements are of

14 interest. And the policemen's account of what happened, it's on -- in the

15 original, 02048151, the second paragraph; similarly on page 2 of the

16 translation, the second paragraph. These policemen report that they've

17 met with the chief of the public security station in Pale, when they went

18 to -- where they worked, and the chief of police, Malko Koroman "informed

19 them of the decision by the Crisis Staff of Pale municipality and the

20 government of the Romanija Serb Autonomous District, that all policemen of

21 Muslim nationality must hand in their weapons and equipment issued to

22 them."

23 So some policemen are recounting in this statement their

24 experience that they were told the Crisis Staff had decided that they

25 could no longer work there.

1 Q. Now, after separate Serb police stations or commands were formed

2 in the municipalities, did you see examples that they were working closely

3 with the Crisis Staffs?

4 A. I saw many examples of orders from the Crisis Staff to the

5 municipal -- the police in the municipality.

6 Q. Let me show you tab 183 in the presentation, master tab 278. This

7 is from Prijedor municipality.

8 A. Yes. This is a "Summary of conclusions, orders, and decisions

9 adopted by the Crisis Staff/War Presidency relating to the SJB and the

10 regional command from the 29th of May to the 24th of July, 1992."

11 Q. And did you want to highlight some of those particular decisions?

12 A. Yes, some of those decisions. On the second page, number 2, "The

13 order to military police and SJB organs to confiscate all illegally

14 confiscated or misappropriated property." This order requires the police

15 to immediately report to the Crisis Staff on their execution of this

16 order.

17 Further down on that same page: "The order of the 6th of June,

18 1992, obliging the SJB to use its members to control not just the Pecani

19 settlement but also the other parts of town, and not to allow people to

20 arbitrarily stay at or move into the homes of relatives and friends."

21 On the third page of the translation, in the middle of the page,

22 "The order of the 17th of June, requiring the SJB and regional command to

23 form within two days a unified intervention platoon with 20 members each,

24 with a basic task of preventing theft and other criminal activities."

25 And the last one we'll look at again in a slightly different

1 context.

2 Q. All right.

3 MR. HANNIS: Your Honours, I note the time.

4 JUDGE ORIE: Yes, Mr. Hannis. If this is a suitable moment for

5 you to have the break, then we'll have the break until 10 minutes to 1.00,

6 and then continue for another 55 minutes.

7 --- Recess taken at 12.30 p.m.

8 --- On resuming at 12.55 p.m.

9 JUDGE ORIE: Mr. Hannis, please proceed.

10 MR. HANNIS: Thank you, Your Honour.

11 Q. Ms. Hanson, I think we're still talking about Crisis Staffs and

12 dealing with the local police. I want to go to tab 184 in the

13 presentation, master tab 289. This is another document from Prijedor.

14 And --

15 THE WITNESS: May I, before we start this, is it possible for me

16 to ask for some clarification from the Chamber? Your Honour asked me to

17 look into that document from the logistics base.

18 JUDGE ORIE: Yes.

19 THE WITNESS: And I'm just wondering, I understand my -- that I

20 cannot talk about my testimony with any of my colleagues, but may I

21 inquire of them if they have had occasion to learn more about that

22 document, or not?

23 JUDGE ORIE: Mr. Stewart, I invited the witness to see whether she

24 could find any further source. If she would limit her communications with

25 her colleagues just to any information that might be found, and to whom it

1 was addressed or whom would have received --

2 THE WITNESS: Or other copies.

3 JUDGE ORIE: Yes, or other copies.

4 MR. STEWART: Your Honour, that seems very practical, and we'd

5 have no objection to that.

6 JUDGE ORIE: Then you're allowed to do so, but limited to that

7 subject.

8 THE WITNESS: Thank you, Your Honour. I understand.

9 MR. HANNIS: Thank you, Mr. Stewart.

10 Q. Ms. Hanson, that document, master tab 289, presentation 184.

11 Another document from Prijedor?

12 A. Yes. It is a document from the chief of the public security

13 station, Simo Drljaca, to the Crisis Staff of Prijedor, dated the 1st of

14 June, 1992. It's in reference -- it's a report on the police

15 implementation of orders of the Crisis Staff, so we're saying -- the

16 police are saying the conclusion -- various conclusions, to what extent

17 they are being observed and implemented. I would note here is reference,

18 the first reference to conclusion number 02-111-108/92, "by which the

19 release of prisoners is prohibited is being fully observed." We'll see

20 that conclusion again in a moment. This is an indication of the reporting

21 of the police to the Crisis Staff on the implementation of Crisis Staff

22 orders and conclusions.

23 Q. A couple more examples I want to show you that relate to police

24 and Crisis Staff relations. Presentation tab 185, master tab 290, from

25 Sanski Most.

1 A. Yes. The conclusions of the Crisis Staff of Sanski Most of the

2 27th of April, 1992. Under item 4, the Crisis Staff decides that Mirko

3 Vrucinic conduct affairs of the head of the public safety station of

4 Serbian municipality of Sanski Most. The Crisis Staff also proposes to

5 the Assembly of the Serbian municipality of Sanski Most to appoint Mladen

6 Lukic as the president -- that's the executive committee, that's not

7 relevant to the police, I'm sorry. Just the first sentence is relevant to

8 the police.

9 You will note -- we would note from earlier -- the earlier

10 document on the composition of the Sanski Most Crisis Staff, that Mirko

11 Vrucinic was a member of the Crisis Staff and they're appointing him as

12 head of the police station.

13 Q. And next, presentation tab 186, master tab 291, from Sanski Most.

14 A. Yes. It's an order of the Crisis Staff of Sanski Most to the

15 police station, the public security station, dated the 6th of June,

16 ordering the police to evacuate 150 prisoners to Manjaca.

17 Q. Now, that takes me --

18 THE INTERPRETER: Microphone, please.

19 MR. HANNIS: I'm sorry.

20 Q. That takes me to another topic. Was there anything else you

21 wanted to say about the interaction with the police before I go on to talk

22 about Crisis Staffs and detention facilities?

23 A. Well, we've only shown a few documents here, but in my report I

24 also point the way to many other such documents on police. It's not a

25 long section because I think it's fairly clear what the picture was, but

1 I'd be glad to answer further questions about it, if necessary.

2 Q. Okay. For now, then, let me turn to the issue of detention

3 facilities. Were the Crisis Staffs involved in either the establishing or

4 control or access to detention centres?

5 A. Yes. We see that in the municipalities, that Crisis Staffs, in

6 some cases, set up detention centres, could order the detention or release

7 of prisoners or the movement of prisoners. So we'll look at several

8 documents that indicate the relationship between Crisis Staffs and

9 detention centres in their municipalities.

10 Q. In that regard, then, let me show you presentation tab 187, master

11 tab 295. First of all, tell us what this document is, and then direct us

12 to the excerpted portions you wish to talk about.

13 A. This is a fairly lengthy document that I will refer to a number of

14 times. I think we have them as separate tabs, just to not keep flipping

15 back to this one. But it is a report compiled by the Banja Luka SCB,

16 security services centre, on the basis of reports from the police of

17 Prijedor, Bosanski Novi and Sanski Most. It says that this report was

18 compiled pursuant to a decision of the chief of the security services

19 centre of August 1992, and the report is dated August 1992. So the first

20 part of the document we'll be looking at is a compilation of the different

21 individual, three reports from those police. But it gives a good

22 indication of what the police had to say about the events in the

23 municipality.

24 Q. And with regard to two particular municipalities, can you tell us,

25 is there an excerpt on page 1 regarding Prijedor?

1 A. There's an excerpt on the first page of the English text, which is

2 apparently page 2 of the translation; in the B/C/S, it is -- the sentence

3 begins on B0032527, but the bulk of the quote is the next page, B0032528.

4 Referring to Prijedor, on the -- page 2 in the English translation, the

5 middle paragraph:

6 "The Crisis Staff of the municipality of Prijedor decided to

7 organise reception and accommodation in the settlement of Trnopolje for

8 persons who sought protection, and that prisoners of war should be held

9 for processing in the building of the Keraterm RO in Prijedor or in the

10 administration building and workshop of the iron ore mine in Omarska."

11 Q. And at page 6 of the English, and I believe it's page 8, or

12 B0032534, can you tell us what it says about detention facilities in

13 Sanski Most.

14 A. Yes. On page 6, at the beginning of the section on -- I'm sorry,

15 it's -- it's the sixth page of the translation, but it's page 7 in my

16 numbering here.

17 Q. My mistake.

18 A. The beginning of the section on Sanski Most. "From the beginning

19 of the armed conflicts in the area of the municipality of Sanski Most, the

20 end of May 1992, the municipal Crisis Staff made a decision ordering the

21 setting up of collection and investigation centres in the premises of the

22 sports hall, the facilities of Betonirka, and the large workshop of the

23 Krings factory. As a result of a special decision of the Crisis

24 Staff, a prison was set up in the Betonirka facility, a warden and

25 assistant warden were appointed, and police employees were engaged in

1 security matters together with members of the army."

2 The next paragraph, one sentence in the middle of the next

3 paragraph: "A number of persons were brought on the direct order of the

4 municipality's Crisis Staff."

5 Q. Let me take you to the next tab, which is 188 in the presentation,

6 master tab 299. This relates to the role of a Crisis Staff and the

7 establishment of a detention facility in Prijedor municipality.

8 A. Yes. It's a report of the Prijedor police station, dated the 31st

9 of May, 1992, sent to the Crisis Staff, among others, and also to police

10 members. It's describing the establishment of the Omarska camp, noting

11 that, in the first sentence, he says, "in accordance with the decision of

12 the Crisis Staff," the police chief orders -- pardon me, "that the

13 industrial compound of the Omarska strip mine shall serve as a provisional

14 collection centre for people captured in combat or detained on the grounds

15 of the security services operational information." It's a lengthy order

16 describing all the steps of establishing the Omarska camp.

17 Q. And that document was from whom?

18 A. From the chief of the public security service, Simo Drljaca.

19 Q. To whom was it addressed?

20 A. If I could --

21 Q. If you can tell.

22 A. Yes. It's sent -- I was looking at the addressees at the end.

23 There's no immediate addressee on the first page, but it is sent to the

24 Crisis Staff, to the security services coordinator, to the security

25 services in Banja Luka, to the chief of police, to the chief of security,

1 to the director of the iron ore mines, and to files. And the indication

2 on the -- there's some handwritten indications that would seem to say this

3 copy was received by the iron ore mines and security, it says.

4 Q. Thank you. Next, tab 189 in the presentation, master tab 298.

5 This is a document dated 8 July 1992, from Kotor Varos.

6 A. From the minutes of the War Presidency of Kotor Varos of 8 July

7 1992. Under item 1: "Due to problems in the work of the public security

8 station, a decision has been made to use the hall in Piljana saw mill

9 temporarily as a prison, and it's been recommended that all detained

10 persons be transferred to the Piljana hall in the future."

11 Q. Thank you. Presentation tab 190, master tab 420. This is a

12 document from the 20th of May, 1992, in Foca.

13 A. It's from the warden of the penal and correction facility, Foca,

14 dated the 20th of May, 1992, to the Crisis Staff of the Serbian

15 municipality of Foca. "Request to appoint authorised persons. We hereby

16 request the appointment of authorised persons for questioning and

17 examination of captured persons who have been brought to the penal and

18 correctional facility, Foca."

19 Q. And the name of the warden?

20 A. Milorad Krnojelac.

21 Q. Next, presentation tab 191, which is master tab 301. This is from

22 the 15th of May, 1992, from Bosanski Samac.

23 A. Yes. A decision of the Crisis Staff of Bosanski Samac, dated the

24 15th of May, 1992. "All people of Croatian nationality on the territory

25 of the Serbian municipality of Bosanski Samac shall be isolated and

1 deployed to vital facilities in the town and in villages."

2 Deployed, I would note the original is "rasporedjeni" sent to, or

3 put in. Deployed sounds a bit military in this context. It's not wrong

4 but ...

5 I would also point out, in this context, according to the census

6 of 1991, in Bosanski Samac, there were about 14.000 Croats, about 45 per

7 cent of the population.

8 Q. Now, I guess I didn't make the transitional point I wanted to make

9 before when we were talking about Crisis Staff involvements in detention

10 facilities. Now we're going to talk about particular people that are

11 chosen to be placed in those facilities?

12 A. This is obviously still dealing with detention facilities, but to

13 show in addition to setting up detention centres, Crisis Staffs were

14 ordering whole categories of people be detained. So although this is not

15 specified which detention centre, I find it significant here, just the

16 order of the Crisis Staff, that an entire category of people - in this

17 case, Croatian nationality - be detained.

18 Q. In a similar vein --

19 JUDGE HANOTEAU: [Interpretation] Terribly sorry to interrupt you.

20 You've added one point, madam. You've said in that municipality, the

21 municipality of Bosanski Samac, there were 14.000 Croats. Did I

22 understand you correctly?

23 THE WITNESS: Yes. That's based on the census.

24 JUDGE HANOTEAU: [Interpretation] I just wanted to find out, what

25 was the total of the population proportionately speaking? What was the

1 total amount of the population? Who were the other members of this

2 municipality? Thank you.

3 THE WITNESS: I will bring next time the census -- the official

4 census results. It was 45 per cent of the population. I do not recall

5 right now what that means in total, but that would mean about 30.000 in

6 total. It's 45 per cent were Croats.

7 MR. HANNIS:

8 Q. And can you tell the Judge what other ethnicities lived in

9 Bosanski Samac, the significant numbers?

10 A. Serbs were the other large number.

11 JUDGE ORIE: I have a question in relation to this document to you

12 as well. You said, or introductory said, it was those people selected as

13 being sent to those prison facilities. If I read --

14 THE WITNESS: Detention is not -- sorry.

15 JUDGE ORIE: If I read the heading of this letter, then it says

16 something about incessant bombardments, reasonable grounds that aircraft

17 are being guided, that there's a collaboration with criminals, and that on

18 the basis of that, all people of Croatian nationality on the territory

19 shall be isolated and sent to, as you said it to us, to vital facilities

20 in the town and in villages. I mean, I can't imagine that someone would

21 understand this to be rather sending people not to detention facilities

22 but to places where the municipal Crisis Staff would expect further

23 bombardments to take place, and that it was not, therefore, mainly to

24 detain them but rather to -- well, one might think of human shields as a

25 measure of protection against bombardments. But since this document was

1 introduced as a -- well, as the involvement of the municipal Crisis Staff

2 with detention, I wonder, what makes you take this position and why you,

3 as an expert, would say that the other interpretation would be the wrong

4 one?

5 THE WITNESS: It's not relating to one detention centre per se,

6 and I think your interpretation of putting them in --

7 JUDGE ORIE: I said that one could possibly --

8 THE WITNESS: Yes, yes, I agree. One could, and I think that is a

9 reasonable interpretation. But I would say that if you are identifying a

10 category of all Croats and putting all of them in vital facilities as

11 human shields, that seems to me is a form of detention. They're not --

12 it's not for their protection, it's not of their own free will, it's

13 moving them, because they're Croats, to different places and keeping them

14 there.

15 MR. STEWART: Your Honour --

16 JUDGE ORIE: On the other hand, if I can ask you a different

17 question. You're talking about 14.000. At the same time -- therefore, I

18 said it's a possible interpretation, because I would say managing 14.000

19 people as human shields is -- would not be an easy task. So therefore I'm

20 also giving some opposite, but I'd rather first the expert answer the

21 question.

22 THE WITNESS: I gave that figure to give you an idea of the makeup

23 of Samac and how many people -- I have seen no other evidence that this --

24 that 14.000 people were rounded up and used as human shields. It does

25 seem unlikely or impractical, given the numbers involved and that they

1 were not -- the Serbs were not in overwhelming majority in that

2 municipality to be able to control so many people.

3 I see -- I think its intent is what's of interest here to me more

4 than, perhaps, what -- whether this was -- whether that many people were

5 actually detained, but that it was a category that the Crisis Staff

6 thought it had the order -- the authority to decide the fate of those

7 people in that way, to decide where they would be -- that they would be

8 rounded up and sent somewhere.

9 JUDGE ORIE: Yes, thank you.

10 Mr. Stewart, you were on your feet. Mr. Hannis was on his feet.

11 MR. STEWART: As Winston Churchill said of his understanding of

12 mathematics, the moment has passed.

13 JUDGE ORIE: The moment has passed. You're sitting again.

14 Mr. Hannis.

15 MR. HANNIS: A couple things, Judge.

16 Q. In relation to the population figure, what was the date where that

17 number comes from?

18 A. 1991.

19 Q. That's the 1991 census. As of May 1992, I know you're not an

20 expert on Bosanski Samac, but was there any evidence that some of the

21 Croatians may have left the municipality by that date?

22 A. There was no evidence from the census, since that was taken in

23 1991. In my general understanding of the conflict, yes, many Croats had

24 left by then. But I couldn't point you to one piece of evidence.

25 Q. I don't know, but maybe it would be helpful to me if you could go

1 to the original B/C/S where this statement about "All people of Croatian

2 nationality" shall be put in isolation and taken to vital facilities?

3 JUDGE ORIE: Mr. Hannis, I do understand that the French

4 translation was a bit behind. I think we're there again. Please proceed.

5 MR. HANNIS: My apologies. Let me start again.

6 Q. Could you read from the original B/C/S that sentence about "All

7 people of Croatian nationality shall be put in isolation..." I want to

8 hear the translation.

9 A. [Interpretation] With this decision, on the basis of this

10 decision, in the territory of the municipality of -- Serbian municipality

11 of Bosanski Samac, all members of the Croatian ethnicity shall be taken

12 into isolation and put up, distributed, in vital institutions in the town

13 and the villages."

14 MR. HANNIS: Thank you, Your Honour. I understand the reading you

15 had is one possible interpretation. I wasn't sure if it meant "put them

16 in isolation and put them in vital facilities," or do some of each with

17 parts. I think that's all I had on that one.

18 Q. Let me move on to the next tab, unless there are further

19 questions. If not, I'll go to presentation tab 192, master tab 302.

20 A. This is minutes of the Crisis Staff of Bosanski Petrovac - I would

21 note that this time it's calling itself simply Petrovac - the 30th of

22 June, 1992. On page 2 in the translation, under "Conclusions," this is on

23 the bottom of the first page in the B/C/S: "Until the prison in Kozolua

24 [phoen] is made operational, a plan should be made to arrest and bring in

25 under custody all Muslims fit for military service who are thought to be

1 capable of causing any harm to the Serbs."

2 Q. Thank you. Did you have any information on the 1991 census

3 population in Petrovac?

4 A. I believe Petrovac was approximately - I'm sorry, I don't have it

5 off the top - about 80 per cent Serb, and I'm -- in the order of

6 magnitude, about 1.000 Muslims. I don't want to speak off the top of my

7 head on that, I'm sorry.

8 Q. Okay. I think you indicated in your report, or perhaps somewhere

9 else, that there were approximately 3.200 Muslims.

10 A. 3.200, I'm sorry.

11 Q. You mentioned that now it was referring to itself simply as

12 Petrovac as opposed to Bosanski Petrovac.

13 A. Yes.

14 Q. Any significance to that?

15 A. Rejecting the Bosnian identification of Bosanski Petrovac, I would

16 take that to be.

17 Q. Thank you. I want to now go to tab 193 in the presentation, this

18 is master tab number 306, from Sanski Most.

19 A. Conclusions of the Crisis Staff of Sanski Most, dated the 4th of

20 June, 1992. Under item 1 of the conclusions: "Mirko Vrucinic, Nedeljko

21 Rasula and Colonel Nedjo Anicic shall be in charge of resolving the issue

22 of prisoners and their categorisation and deportation to Manjaca. 1st

23 category - politicians; 2nd category - nationalist extremists; 3rd

24 category - people unwelcome in Sanski Most municipality."

25 Q. Any definition of that third category?

1 A. Not in this document, no, of what is unwelcomed or undesired.

2 Q. Let me take you next to tab 194 in the presentation, master tab

3 454.

4 A. This is a report on some aspects of the work done to date and the

5 tasks ahead, written by the Serbian Republic Ministry of the Interior,

6 dated the 17th of July, 1992, and addressed to the president of the

7 Presidency and the Prime Minister. That is added in handwriting on the

8 front page, it's not in the letterhead that it's addressed. I'm just

9 looking -- yes, it's on page 3 of the translation, and also the third page

10 of the B/C/S, 03246858, in both cases the first paragraph. This is the

11 Ministry of Interior reporting that: "The army, Crisis Staffs and War

12 Presidencies have requested that the army round up or capture as many

13 Muslim civilians as possible, and they leave such undefined camps to

14 internal affairs organs. The conditions in some of these camps are poor.

15 There is no food. Individuals sometimes do not observe international

16 norms ..." et cetera.

17 Q. And this was a report of which --

18 A. The Ministry of the Interior, apparently to the president of the

19 Presidency and to the Prime Minister.

20 Q. Thank you. Next I'd like to show you presentation tab 195, master

21 tab 295. This is a document we looked at earlier with a different

22 excerpt, this one pertaining to Prijedor.

23 A. Yes.

24 Q. Tell us again what this report is.

25 A. This is the report of the police stations of Prijedor, Sanski

1 Most, and Bosanski Novi, as then compiled by the security services centre

2 in Banja Luka. I had made a distinction in my report. Perhaps it's too

3 fine a point to make a difference now, but in addition to establishing

4 setting up detention centres and ordering the detention of various people

5 or categories of people, Crisis Staffs also could order the transfer of

6 prisoners between detention centres.

7 So we see this on page 4 of the English, first sentence -- first

8 paragraph, and it's on the bottom of the third page in the B/C/S,

9 B0032529: "On 27 May 1992, pursuant to the decision of the Crisis Staff

10 of the municipality of Prijedor, all the prisoners from Keraterm facility

11 in Prijedor were transferred to the facility in Omarska."

12 Q. Thank you. Next, I'd like to go to tab --

13 JUDGE HANOTEAU: [Interpretation] Yes, I have a question, Witness.

14 I would like to understand, what is the Commission for the Inspection of

15 Municipalities? Could you please tell me what sort of organisation that

16 is, what was its role? Were there several commissions in charge of

17 inspections? Were there several commissions of that type? Who had set up

18 these organisations? Can you please give us some background information

19 about this institution.

20 THE WITNESS: This appears to be a police institution rather than

21 a municipal institution, and I don't know anything more about it than in

22 this report, I'm afraid.

23 JUDGE HANOTEAU: [Interpretation] Thank you, Witness.

24 MR. HANNIS: Your Honour, I think we'll hear some evidence from

25 some other witnesses about which institution established this commission.

1 Q. Regarding the timing of that report, the date on that report?

2 A. 18 August 1992.

3 Q. Okay. Are you aware of anything that happened in connection with

4 the detention facilities shortly prior to that time that may have had a

5 relation to the creation of this commission?

6 A. Yes. They became publicly known at this time in the media. There

7 was a great deal of international media attention on these detention

8 facilities.

9 Q. Thank you. In addition, I guess you've used these last two

10 examples of prisoners being transferred in and out. Did you see some

11 additional documentary evidence of that in the form of payment for

12 transportation?

13 A. Yes, I did.

14 Q. Let me refer you to tab 196, master tab 305, from Zvornik

15 municipality.

16 A. Yes. On the last page of the translation -- it's a series of

17 documents, bills. We've seen some other bills from Zvornik before. If I

18 can just -- yes, similarly, it's on the last page of the B/C/S, 01328458,

19 a list of various transportations taken -- undertaken on the order of the

20 provisional government by a transport company, and now they're charging

21 the provisional government for it.

22 The fourth item on the list, dated the 15th of July, 1992, "the

23 transport of 600 prisoners from Zvornik via Bijeljina to Batkovic."

24 Q. Thank you. Now, we've talked about the Crisis Staffs' involvement

25 in deciding who gets put in detention facilities and the movement from

1 detention facilities. Did you also see evidence that the Crisis Staffs

2 were making decisions or issuing orders about who got released from

3 detention facilities?

4 A. Yes. As a related power, they could also order the release.

5 Q. Let me show you tab 197 in the presentation, master tab 460.

6 A. This is a decision of the Crisis Staff of Prijedor from the 2nd of

7 June, 1992. "Decision on the release of imprisoned persons. Article 1:

8 All Serbs who have been imprisoned by mistake are hereby released from

9 further imprisonment."

10 Q. Did it make any reference to non-Serbs imprisoned by mistake?

11 A. No, no reference to non-Serbs as such.

12 Q. Thank you. Next, I'd like to show you presentation tab 198. This

13 is from Prijedor. It's master tab 278.

14 A. Yes. It's a document we've seen before, and perhaps it would have

15 been more efficient to say everything at once, but I'd had, as I said,

16 made some fine distinctions. The last -- on page 3 of the English, the

17 third from the bottom, conclusion -- third paragraph from the bottom:

18 "Conclusion of the 2nd of July, 1992, forbidding the individual release of

19 prisoners from Trnopolje, Omarska, and Keraterm." This was, again, the

20 list of conclusions, orders, and decisions adopted by the Crisis Staff,

21 the War Presidency of Prijedor relating to the SJB and the regional

22 command.

23 Q. And does this appear to be the order we saw referred to by the

24 police as being followed by them?

25 A. Now, I had said so at the time, but now I'm not sure about the

1 date. If I could just check the date on that one, because I don't want to

2 make a connection -- do you remember which tab --

3 Q. I'm looking at the tab. I believe it's P184, or 183. These were

4 both related to --

5 A. Yes, 183 is the same document, it's the list. My apologies. Yes,

6 it can't be the same order, because it's a different number, and actually

7 the report on the implementation predates by one day the date ascribed to

8 this. So my apologies to my earlier assertion that we'd see that order.

9 It's a similar order, apparently, but it is not the same order.

10 Q. Thank you. Let me go, then, to presentation tab 199, master tab

11 309. This is from Vogosca Crisis Staff, the 26th of May, 1992.

12 A. Another order of release, this by the Crisis Staff of Vogosca, the

13 26th of May, 1992. "The prison warden is ordered to release 154 people

14 and take them to the village of Svrake, to Sarajevo and to Vogosca."

15 Q. All right. Let me show you presentation tab 200, master tab

16 number 421. This is from the acting warden, Mr. Krnojelac, from Foca, on

17 the 15th of May, 1992, addressed to the Crisis Staff.

18 A. Yes. He's forwarding to the Crisis Staff one detainee's request

19 for release, indicating that he at least saw the Crisis Staff as having

20 the authority to approve or not the request for release.

21 Q. And I think that completes our examples concerning release of

22 prisoners from detention centres -- detention facilities.

23 A. Yes.

24 Q. The next topic in your report, in paragraph 60 of your report, you

25 talk about the status of non-Serbs in the Serb municipalities as being a

1 theme of the work of the Crisis Staffs. And the first document I want to

2 show you in connection with that is at presentation tab 201, master tab

3 310, from the Celinac municipality. Can you tell us about that?

4 A. Yes. This is a decision on the status of the non-Serb population

5 of Celinac municipality, dated the 23rd of July, 1992, of the War

6 Presidency of Celinac. It's fairly -- several pages, but it's an

7 interesting Celinac. It's fairly -- several pages, but it's an

8 interesting document, so I'll take you through some of it. First of all,

9 the very title says what it's about, the status of the non-Serbs. And the

10 War Presidency says in Article 1 that: "Combat operations in Celinac and

11 elsewhere have given rise to basic reasons for giving the non-Serbian

12 population of Celinac a special status."

13 Article 2 is a listing of some of the non-Serbs, 34 names, mostly

14 Muslim with one, apparently, Croat name, the last one.

15 Article 3 says that citizens -- non-Serbs, because it says

16 "citizens from Article 1," that means non-Serbs, "may live unhindered

17 within the boundaries of their property to work and produce, to satisfy

18 their day-to-day requirements."

19 Article 4: "Non-Serbs shall be permitted to leave Celinac in an

20 organised fashion, provided that the entire family household leaves."

21 Under Article 5: "Non-Serbs are forbidden from moving around

22 Celinac town between 1600 and 0600 hours. They are forbidden from

23 lingering in the street, catering facilities, and other public places.

24 They are forbidden from bathing in the rivers Vrbanja and Josava, hunting

25 and fishing; forbidden from travelling from their settlement to other

1 towns without permission from the competent municipal organ; forbidden

2 from owning any kind of firearm, regardless of whether or not a permit to

3 carry such has been issued; forbidden from moving or using cars; forbidden

4 from gathering in groups with more than three men; forbidden from

5 contacting relations who are not in the municipality; forbidden from using

6 communications systems apart from the post office telephone; forbidden

7 from wearing any kind of uniform; forbidden from selling real estate and

8 exchanging apartments without special permission from the competent

9 municipal organ."

10 Article 6, they are obliged to show -- turn out for work

11 obligations and not to do anything to desecrate the struggle of the

12 Serbian people for its freedom.

13 And then Article 7 is special restrictions on the people listed in

14 Article 2. They may not make any contact with other people in the

15 neighbourhood or further afield, and may not move between 0000 hours and

16 24 hours, essentially 24 hours a day, except when called for work

17 obligation.

18 Article 8, the War Presidency can offer -- can issue special

19 consent that these do not apply to certain people.

20 Q. Did you have any information concerning the 1991 census data on

21 the population of Celinac -- Celinac municipality?

22 A. Yes. About 11 per cent of the population was Muslim, and the rest

23 Serb. Virtually no Croats, as the list would suggest. And about 2.100

24 Muslims in this case.

25 Q. Okay. Thank you. I'd like, then, to show you presentation tab

1 202, which is master tab number 119.

2 MR. HANNIS: I'm sorry, Judge.

3 JUDGE ORIE: May I ask one question: So do I well understand that

4 these specific measures would apply to approximately 1 per cent, a little

5 bit over 1 per cent, of the --

6 THE WITNESS: 11 per cent.

7 JUDGE ORIE: I beg your pardon?

8 THE WITNESS: 11 per cent.

9 JUDGE ORIE: No, but I'm looking at the list, the list in Article

10 --

11 MR. HANNIS: 2.

12 JUDGE ORIE: -- 2, that specific measures, or would you say

13 Article 1 --

14 THE WITNESS: Article 1 is the non-Serb population. Then Article

15 2, they list certain people. And under Article 7, it is a little

16 confusing, but under Article 7, they say those people named in Article 2,

17 that is the list of people, they cannot move anywhere --

18 JUDGE ORIE: No, I missed the reference to -- yes, it's clear to

19 me now. Thank you very much for your clarification.

20 MR. HANNIS: Thank you.

21 Q. Now, do you have the next tab from Sipovo in front of you?

22 A. Yes. That document from Celinac is, by far, the most sweeping

23 action of Crisis Staff or War Presidency on the status of non-Serbs, but

24 we do see that, as I mentioned, as a theme in many Crisis Staffs' work.

25 So on a smaller scale, but just to show that it was not the -- the

1 preoccupation was not limited to Celinac, we have the minutes of the

2 Sipovo municipal Crisis Staff, this one from the 19th of May, 1992. On

3 page 5 in the translation, and in the B/C/S -- it will take me a moment, I

4 apologise, to find. Because they are handwritten, it does take a moment.

5 Q. I believe it's 02194138.

6 A. Thank you.

7 Q. If I have the right excerpt.

8 A. Yes, it looks right.

9 MR. STEWART: Could we just say on the transcript that it's tab

10 202. Mr. Hannis referred to it as the next tab. It's quite a way back,

11 just so that people reading it future can see that.

12 MR. HANNIS: Thank you, Mr. Stewart. That's correct and it's

13 master tab 119. I appreciate that.

14 A. In the B/C/S, it's on the top of the page you gave, 02194138, and

15 on page 5 in the English, in the centre of the page, number 5. The Crisis

16 Staff is discussing the distribution of humanitarian aid. One Crisis

17 Staff notes that there are Muslims on the list of those supposed to

18 receive social welfare, and another Crisis Staff member says that it

19 should be discussed -- distributed exclusively to Serbs. The conclusion

20 at this point is to refer that to the party. The Crisis Staff doesn't

21 actually decide on that matter, but it's something of interest to the

22 Crisis Staff.

23 Q. And did you have another excerpt in this document?

24 A. Yes. I was going to refer to it when we get to the dismissals

25 from employment. But if it's easier now --

1 Q. Since we're close to ending time, why don't you talk about it now

2 when you have the document out?

3 A. The next page in the English, the bottom of page 6 in the English

4 --

5 Q. I believe it's on 4139 in the B/C/S.

6 A. Yes, on the bottom of that page in the B/C/S. "Firing Muslims

7 from specific positions: In the post office; the fire station; the

8 petrol station. Replace the butcher, and other Muslims in various

9 management positions in Vitorog." Vitorog would be a company. I don't

10 know of what.

11 Q. Thank you.

12 MR. HANNIS: I note the time. This would be a good time to end

13 now.

14 JUDGE ORIE: Thank you, Mr. Hannis. Just for our information, the

15 Chamber is fully aware that we have caused a delay of one hour this

16 morning. Is your time scheduling one hour more than you said yesterday,

17 or is it --

18 MR. HANNIS: It might be slightly more. I looked at what remained

19 last night. The case studies that we want to do for the three

20 municipalities, I thought, would go quicker than this does, but at looking

21 at the documents, it might go at the same rate or a little longer. I'm

22 still hoping that maybe by eliminating some things I can finish by the end

23 of the day tomorrow. I don't think I'll be done any earlier than that.

24 JUDGE ORIE: Yes. Will you please take care that we can finish by

25 tomorrow. Of course, you sometimes have to set some priorities, and it

1 might be because, of course, some of the material here now is already in

2 the footnotes, although we don't have the related documents, and sometimes

3 it's just one line read from a document where -- well, we could have read

4 that line from a document as well. So you're invited to do it in a way

5 which draws our specific attention to the most important aspects you'd

6 like to draw our attention to, and at the same time, you're instructed to

7 finish your examination-in-chief by tomorrow.

8 Ms. Hanson, with the amendment I gave in this hearing for your

9 request, you're instructed not to speak with your colleagues, apart from

10 the topic we discussed earlier, and I would like to see you back tomorrow

11 morning at 9.00, in the same courtroom.

12 We will adjourn until tomorrow morning.

13 --- Whereupon the hearing adjourned at 1.45 p.m.,

14 to be reconvened on Friday, the 4th day of March,

15 2005, at 9.00 a.m.

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