Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10096

1 Tuesday, 8 March 2005

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.08 a.m.

5 JUDGE ORIE: Good morning to everyone.

6 Madam registrar, would you please call the case.

7 THE REGISTRAR: Case Number IT-00-39-T, the Prosecutor versus

8 Momcilo Krajisnik.

9 JUDGE ORIE: Thank you, Madam registrar.

10 Madam Usher, on the assumption the Defence is ready to continue

11 the cross-examination, I would like to ask you to escort the witness into

12 the courtroom.

13 Mr. Hannis.

14 MR. HANNIS: Your Honour, while we're waiting for the witness to

15 come in I do have a hard copy of our spreadsheet which has the footnotes

16 from 1 to 400 and whatever, with a cross-reference to what the master tab

17 number is where that document is found. If I could hand that up. I've

18 already provided two copies to the Defence.

19 JUDGE ORIE: I take it that you could do that without doing all

20 the work again or...

21 MR. HANNIS: Yes. We had to hide some columns, but we have that

22 for you.

23 JUDGE ORIE: Yes, please. Provide them to the registrar,

24 absolutely.

25 MR. HANNIS: The footnote number appears on the far left column,

Page 10097

1 and I think the Court will be able to follow the rest of it easily.

2 [The witness entered court]

3 THE WITNESS: Good morning.

4 JUDGE ORIE: Good morning, Ms. Hanson. The same procedure as the

5 last few days. I'd like to remind you, perhaps unnecessarily, but I'd

6 like to remind you that you're still bound by the solemn declaration that

7 you've given at the beginning of your testimony.

8 THE WITNESS: Yes, Your Honour.

9 JUDGE ORIE: Mr. Stewart, please proceed.

10 MR. STEWART: Thank you for that document from Mr. Hannis. I'm

11 going to mark it Variant C.

12 The --


14 Cross-examined by Mr. Stewart: [Continued]

15 Q. Good morning, Ms. Hanson.

16 Ms. Hanson, we were looking - well, I think we were - at

17 paragraph 38 of your report. Do you have your report in front of you

18 again this morning?

19 A. Not yet. Yes, I found paragraph 38.

20 Q. And in particular a certain sentence, the second sentence, it's

21 not a long paragraph: "In that capacity, he apparently signed for

22 Karadzic," he being Mr. Krajisnik, "at least two Presidency documents

23 dealing with appointments of commissioners." And Mr. Hannis before court

24 this morning showed me another one which I understood to be in the same

25 category.

Page 10098

1 MR. HANNIS: Yes. And for information of the witness and the

2 Court, it is presentation tab 69 which we showed to Defence counsel and he

3 discussed with his client this morning and I understand it appears to be

4 his signature.

5 MR. STEWART: Yes, well on the basis of the photocopy shown to

6 Mr. Krajisnik, he doesn't as things stand at the moment have any dispute

7 as to that, but I think he has made a slight reservation that he has only

8 seen a photocopy at the moment.

9 Q. But, Ms. Hanson, I'm going to proceed on the footing that that is

10 an extra -- an example, but it is just an extra example. The -- when you

11 describe in your report Mr. Krajisnik as signing in that capacity, what is

12 the basis of your use of that phrase "in that capacity"?

13 A. As a member of the Presidency and tying it to the fact that he was

14 named as the member of the Presidency given the task of the question of

15 commissioners.

16 Q. The documents were -- in the first place the person who was to

17 sign the document and that's shown the typed signature was Dr. Karadzic,

18 wasn't it?

19 A. Yes.

20 Q. So in some sense Mr. Krajisnik was signing on his behalf?

21 A. Yes.

22 Q. And not in his own specific capacity?

23 A. In the Presidency minutes of the 6th of July where Mr. Krajisnik

24 is tasked as the member of the Presidency for the question of

25 commissioners, it is -- the context appears to be dividing up the tasks

Page 10099

1 which until now Mr. Karadzic as the president of the Presidency has -- the

2 decision is in the context of replacing -- of when Mr. -- Mr. Karadzic

3 can't do it all. If I can see -- or if you recall those government

4 minutes, that's the context of agenda item 4. What we do when

5 Mr. Karadzic isn't there and -- but apparently they seem to be dividing up

6 various tasks. But all Presidency documents are type-signed -- to the

7 best of my recollection, Presidency decisions and such are type-signed by

8 Karadzic as president of the Presidency. That's my general understanding.

9 Q. I suppose what it is is this, Ms. Hanson, are you in fact relying

10 upon Mr. Krajisnik's signature of those documents as some reinforcement or

11 strengthening of his role as the member of the Presidency responsible for

12 the work of the republican commissioners?

13 A. I take those signatures as indication that he did -- within the

14 Presidency he did conduct some affairs of the Presidency related to the

15 republican commissioners.

16 Q. You don't suggest, though, do you, that for example if

17 Dr. Karadzic being unavailable and Mr. Krajisnik had been unavailable,

18 that there would have then been any problem about, for example,

19 Ms. Plavsic signing that document -- Mrs. Plavsic, I mean.

20 A. I don't know much about the rules of the procedure of the

21 Presidency, and I don't know much about other signatures -- other people's

22 signatures on other Presidency documents. I focused on the Presidency

23 documents relevant to this issue.

24 Q. Did you check to see whether any other documents apparently coming

25 from Dr. Karadzic were signed by any other member of the Presidency on his

Page 10100

1 behalf in a similar manner?

2 A. I did not check to see that as a particular issue, no.

3 Q. Let's move on to paragraph 43 of your report. You say in the

4 second sentence: "As members of the Presidency, both Krajisnik and

5 Plavsic visited Crisis Staffs and received reports from them on the

6 situation in critical municipalities."

7 Now, of course we're agreed, aren't we, Ms. Hanson, that this

8 report was prepared at a time when one of the indictees still before the

9 court and this trial on this indictment was Mrs. Plavsic?

10 A. Correct.

11 Q. And in fact it's the -- you only give one example, don't you, of

12 Dr. -- of Mr. Krajisnik visiting a Crisis Staff and receiving a report?

13 A. In this report I give that one example. I have given other

14 examples in my presentation.

15 Q. Did you pick the best example here for your report?

16 A. This is what I found to be the best example at the time of the

17 documents I had available then.

18 Q. Do you suggest that one of your other examples is a better

19 example?

20 A. The intercepts that I presented in my presentation plan are also

21 good examples I feel.

22 Q. Let's look at this one then. This is a visit by Mr. Krajisnik to

23 Ilijas, isn't it?

24 A. Yes.

25 Q. Do you know anything apart what can be seen on the documents about

Page 10101

1 the circumstances of Mr. Krajisnik's visit to Ilijas on that occasion?

2 A. On this occasion, no, I do not know more than that document.

3 Q. Do you know anything about the way in which the Dr. Karadzic and

4 Mr. Krajisnik recognised St. Vitus Day that year?

5 A. No.

6 Q. You don't know anything, therefore, and haven't heard anything

7 about different people, Dr. Karadzic, Mr. Krajisnik included, in the broad

8 SDS leadership going to various different places to mark and honour that

9 day?

10 A. I am aware that it was named as the -- a holiday for the army, I

11 believe a day of particular significance for the army. And I believe that

12 the Bosnian Serb leadership did send -- various members of the leadership

13 did attend or take part in some such markings of the day, but in detail

14 I'm not aware of the details of who went where.

15 Q. So what you have seen is consistent with the suggestion that I put

16 to you, that it was that day was much more of a ceremonial day than a

17 business day?

18 A. The document that I have indicates that it combined both ceremony

19 and business because they talk about the -- I don't have the document in

20 front of me, but as I recall they talk about the larger celebration and

21 some speeches and then they specifically name -- mention that the

22 delegation visited the Crisis Staff and was briefed on the events on the

23 ground. And they don't describe it as part of -- they specified it as

24 different from the larger speeches given.

25 Q. Yes. You recall that in the footnote where the delegation was

Page 10102

1 briefed on the situation in the field, which is gained, and we do see that

2 in writing, that's gained from the report or note coming from the people

3 in Ilijas, isn't it?

4 A. I drew that from the report. The report -- the document, yes,

5 appears to stem from Ilijas.

6 Q. They refer to it themselves as a short visit, don't they?

7 A. I don't have the document in front of me but --

8 Q. Well, you can take that from me, Ms. Hanson, that it does say

9 that. That's easily checkable. We won't dwell and spend time on it.

10 There's nothing more that you know about that visit than what we

11 see in that document then, is there?

12 A. That document is my -- the source I use here for that. I --

13 Q. Do you -- I'm sorry.

14 A. I may have seen a newspaper article talk -- and I'm not sure about

15 this, talking in general terms about those kind of St. Vitus Day

16 celebrations. But this is what I use. I'm not relying on anything beyond

17 it.

18 Q. Your report says that both Mr. Krajisnik and Mrs. Plavsic visited

19 Crisis Staffs and received reports on them and situations in critical

20 municipalities. So you are classifying, are you, Ilijas for these

21 purposes as a critical municipality?

22 A. Yes.

23 Q. And what is it -- what are the features of Ilijas that made it a

24 critical municipality on the 28th of June, 1992?

25 A. I do not mean that it was specifically critical on that day, but

Page 10103

1 it was one of the municipalities in the Sarajevo region and as we know

2 that one of the strategy objectives of the Bosnian Serbs was control of

3 part of Sarajevo. Ilijas was the scene of some considerable fighting, and

4 I believe there were some important industries located there, but there

5 were industries throughout the wider Sarajevo region. So I'm not exactly

6 sure which ones were located there. But as a Sarajevo municipality and

7 the scene of fighting, I would call it critical.

8 Q. And are you in your report here in saying that, are you drawing

9 the conclusion that the reason for Mr. Krajisnik visiting Ilijas was that

10 it was in some sense a critical municipality?

11 A. No. I do not say that that was the reason he visited.

12 Q. Wouldn't it have been better to have made that clear then in your

13 report?

14 A. I don't see that as misleading here.

15 Q. Well, you don't agree that that sentence of your report contains

16 the very clear implication that the visits you refer to by Mr. Krajisnik

17 and Mrs. Plavsic were made to municipalities because they were critical?

18 A. I did not mean to tie the actual visit to the determination of

19 whether the municipality was critical or not. We see from the telephone

20 intercepts that when municipalities have a crisis or have something

21 critical to report that on at least two occasions those Crisis Staffs did

22 make contact with Krajisnik. But this sentence here -- I'm -- if you

23 could repeat your -- or I'll just read it here.

24 Q. Well, I can --

25 A. Yeah, I'm sorry. I'm not used to reading the transcripts.

Page 10104

1 Q. No, no, understood.

2 A. I agree that the sentence could be read in that way.

3 Q. But --

4 A. But I did not make it explicit.

5 Q. We confirm you don't now mean it that way?

6 A. I don't mean it that way. I agree it could be read that way.

7 Q. And in fact you have not seen, have you, from the material you've

8 examined any -- well, in the first place any pattern of Mr. Krajisnik

9 visiting critical municipalities?

10 A. Not of him visiting those municipalities, no.

11 Q. You haven't seen any pattern of him having contact with critical

12 municipalities, have you?

13 A. Well, as I indicated in my presentation, he did receive phone

14 calls from Crisis Staffs in municipalities and through the Assembly he was

15 informed as the Assembly deputies spoke of important events in their

16 municipalities. So although he was not visiting the municipalities in

17 question, he was hearing about events on the ground.

18 Q. What is the furthest municipality from Sarajevo where you have

19 been able to identify any such contact or report of any nature with or to

20 Mr. Krajisnik relating to the work of Crisis Staffs?

21 A. Through the Assembly we have reports from Brcko which is on the

22 northern border with Croatia. We have reports from Kljuc and Krupa which

23 are fairly close to the north-west border --

24 Q. I don't wish to talk over you, but I can stop you and shorten

25 there. If you're talking about what appears in the Assembly session, then

Page 10105

1 you have immediately brought us right up to the border.

2 A. Yes.

3 Q. So that's as far as one can get. So I will then specifically

4 exclude that and confine my question, please, to Mr. Krajisnik himself.

5 So that you referred to intercepts, you've referred specifically to this

6 visit. So that's what I'm talking about. I'm talking about the category

7 of direct contacts with or reports to Mr. Krajisnik.

8 And so my question is: What is the furthest municipality from

9 Sarajevo in relation to which you have been able to identify any sort of

10 contact or report?

11 A. In the discussion in the Assembly on commissioners, Mr. Krajisnik

12 says he was aware of the work of the commissioners, and the commissioners

13 he names were sent to I believe Foca and Herzegovina but I don't know

14 which municipalities in Herzegovina specifically. Maksimovic was sent to

15 Trebinje and Mr. Krajisnik indicates he was aware of the work of

16 Maksimovic.

17 Q. Ms. Hanson, are you able to read on the screen in front of you the

18 question which I just put to you. It's about eight lines, starting --

19 A. Yes, identify any further contact or report.

20 Q. Would you just re-read that question and then tell the Trial

21 Chamber whether the answer you've just given is the best answer you're

22 able to give to that question.

23 A. "What is the furthest municipality from Sarajevo in relation to

24 which you've been able to identify any sort of contact or report" --

25 Q. Yes, you need to read the whole question in order to understand

Page 10106

1 what it is I was asking.

2 A. I'm sorry. "Oh, specifically exclude that" -- "I will then

3 specifically exclude that and confine my question, please, to

4 Mr. Krajisnik himself. So that you've referred to intercepts, you've

5 referred specifically to this visit. So this is what I'm talking about,

6 I'm talking about the category of direct contacts with or reports to

7 Mr. Krajisnik. And so my question is: What is the furthest municipality

8 from Sarajevo in relation to which you've been able to identify any sort

9 of contact or report?"

10 So it -- excluding the Assembly sessions, the contacts that I have

11 seen are from Sarajevo-area municipalities, as to whether Vogosca or

12 Ilijas is further away from where Mr. Krajisnik was, I would have to --

13 Q. Well, Vogosca is. But the -- Ms. Hanson, you know that

14 Mr. Krajisnik is from Sarajevo, do you?

15 A. From the Sarajevo area, yes.

16 Q. And do you know that Ilijas is extremely near to where

17 Mr. Krajisnik lived at the time and indeed to where he was born?

18 A. I don't know where he was born. But, yes, I know Ilijas is very

19 close to where he lived.

20 Q. So is it consistent with all material you've seen that on

21 St. Vitus Day in 1992 Mr. Krajisnik was going somewhere near to where he

22 lived for the purpose of that day?

23 A. Yes.

24 Q. Let's look at --

25 JUDGE ORIE: Could I ask one additional question at this moment,

Page 10107

1 Ms. Hanson.

2 Some questions were asked about the critical situation in

3 municipalities. If you would include footnote 83 in your assessment,

4 would that say something about the situation later in June or the

5 situation in Ilijas?

6 THE WITNESS: Yes. It indicates the president of the Ilijas

7 Crisis Staff is describing the situation as critical and asking for

8 assistance. If I may make one clarification about that document in that

9 footnote --

10 JUDGE ORIE: Please do so.

11 THE WITNESS: My apologies. The document as indicated there is

12 not exactly -- doesn't say what I claim because there were two documents

13 side by side, one after another, very similar, and the second one got

14 dropped off. I have a copy of it to show the Court that -- how the error

15 crept in.

16 JUDGE ORIE: Yes, well perhaps, Mr. Hannis, we could give this a

17 follow-up in the further examination?

18 So Mr. Hannis will ask you for further clarification --

19 THE WITNESS: My apologies --

20 JUDGE ORIE: Of course the Chamber is always -- has an open ear

21 and eye for whatever adjustment is necessary.


23 JUDGE ORIE: Since you have the report in front of you anyhow,

24 could I draw your extension to footnote 68 under the heading SAOs --


Page 10108

1 JUDGE ORIE: You give what seems to be two examples. "The Crisis

2 Staff of SAO Birac declared a state of war on the territory." That's the

3 first one.


5 JUDGE ORIE: And then on the bottom of the page, last two lines,

6 with a different ERN number, it reads: "SAO Birac Crisis Staff declares a

7 state of war on the basis of..." Is that the same document? Is that the

8 same example, or are these -- unfortunately, I now see that I should have

9 brought binders 5 and 8 to clarify that.

10 THE WITNESS: I believe that one of the documents is a document of

11 the Bratunac Crisis Staff citing the Salvirac [phoen] decision. I would

12 have to check, but they are not the same document to my knowledge.

13 JUDGE ORIE: Yes. Because the description is so similar and

14 although if perhaps you could check that during the next break whether we

15 are talking about one example or two examples.


17 JUDGE ORIE: Yes. Thank you.

18 Please proceed, Mr. --

19 MR. STEWART: Ms. Hanson --

20 JUDGE HANOTEAU: [Interpretation] I have a question to ask.

21 Ms. Hanson.

22 Could you on the basis of the documents that you have consulted or

23 used, could you actually replace this visit of Mr. Krajisnik on June the

24 28th of 1992 for which he was briefed on the situation in the field. What

25 is the situation -- the situation at the particular time in region of

Page 10109

1 Ilijas? I'm going to be very specific. Is this situation a situation in

2 which people live in peace or there is no war; or is it -- the situation

3 in which they were in detention -- the place in which there are detention

4 centres for civilians? Or any abuses committed? Does this appear from

5 the documents you have looked at or does it not appear?

6 THE WITNESS: On my basis of the general understanding of the war,

7 I would say that Ilijas was a front line municipality, being a Sarajevo

8 municipality. It was an area in which there were -- it was in or near the

9 front line of the war.

10 As far as detention centres and so on, I did not look into that

11 specifically for that matter, of what abuses or other such events might be

12 going on in Ilijas at this time. But it was I believe a scene of fighting

13 because the war was there, to the best of my knowledge.

14 MR. STEWART: Your Honour, may I -- may I just comment as a matter

15 of information. As indicated by Mr. Hannis the other day, we have three,

16 I think it is, witnesses coming up in relation to Ilijas in the last few

17 days before the short Easter break.


19 This reminds me of another matter, Mr. Stewart. I'm asking,

20 yesterday you were talking about recess. Were you referring to the Easter

21 recess or the Easter break or ...

22 MR. STEWART: Your Honour, I believed it was clear from the

23 context, but I did specifically confirm to Ms. Philpott, that I was

24 referring -- it's a bit of a misnomer, I must say, but I was referring to

25 the Easter break which I classified in my mind as recess, because even a

Page 10110

1 couple of days is at least some relief.

2 JUDGE ORIE: Perhaps I should have asked her first because I asked

3 her to -- to verify that.

4 Please --

5 MR. STEWART: Yes, Your Honour. Even I wouldn't need four months

6 to deal with that point about Mr. Bjelobrk, Your Honour. Well, not yet

7 anyway.

8 Q. Ms. Hanson, a slight interjection then arising out of what you've

9 just said. Coincidentally, in effect, in connection with His Honour Judge

10 Orie's question, you informed the Trial Chamber very helpfully that there

11 was in fact an error in relation to footnote 83 and the document didn't

12 support it. And I therefore ask whether there are other such errors and

13 discrepancies which you have been able to identify in the course of your

14 work and your evidence, which like that one have not been expressly

15 brought yet to the attention of the Trial Chamber?

16 A. That is the only one I have found so far, other than the changes

17 made in my corrigendum.

18 Q. So it is a complete coincidence that His Honour's question threw

19 up that particular error?

20 A. Yes. And I have -- because that error came to my attention when I

21 was preparing and I wanted to -- I brought a copy just to be prepared to

22 indicate how the error arose.

23 Q. Ms. Hanson, I feel the Trial Chamber will, with respect, endorse

24 this, but may I invite you that at any point if you do yourself identify

25 any error or need for correction for your report that it is brought

Page 10111

1 immediately or as soon as convenient to the attention of the Trial

2 Chamber.

3 A. Yes, thank you.

4 Q. May we turn then -- the way I'm going to do it, with respect, Your

5 Honour, is I have -- of course, we all have transcripts of your evidence

6 so far, Ms. Hanson, your recorded -- by the way, may I ask you, have you

7 had an opportunity of reviewing the daily transcripts yourself of your

8 evidence as we've been going along?

9 A. I have not reviewed them -- reviewed that, no.

10 Q. The -- I'm working from the daily transcripts which do not have

11 the continuous numbering.

12 MR. STEWART: Your Honours, I hope, will understand it's not

13 really practical to do it that way, and we have to work immediately on the

14 daily transcripts we get, and each start at number 1.

15 Q. The -- I want to look first, please, at what is found on

16 Wednesday -- and they're relatively short passages, Ms. Hanson, and you're

17 familiar with this material anyway. So what I'm actually going to do is

18 just remind you of the point. If we do at any stage get into difficulty

19 about it and you feel that you really must see the material in question,

20 then of course please don't hesitate to say so.

21 The -- you referred to deny intercept on -- this was on Wednesday,

22 the 2nd of March, and the transcript reference for everybody's benefit is

23 page 59. And it relates to an intercept of a telephone conversation

24 between Mr. Jovan Tinto and Mr. Krajisnik on the 3rd of April, 1992. And

25 I expect you're pretty familiar and that's pretty firmly in your mind,

Page 10112

1 Ms. Hanson, is it?

2 A. Yes, I recall that intercept.

3 Q. Yes. And it went -- I'm not going to just read once again into

4 the record the whole thing. I'm just going to concentrate, it was in a

5 nutshell -- Mr. Tintor was talking about Muslims coming from Kovilja Glava

6 [phoen], they are on their way towards Gravista, and he said: "Please,

7 it's my duty to inform you," he's talking to Mr. Krajisnik, "of what's

8 going on." And then he referred to -- he said he was calling from the

9 headquarters. He said he had just spoken with Rajko. Do you know or

10 accept that Rajko there was Rajko Kopravica?

11 A. It seems a logical conclusion, but I'm not --

12 Q. You don't know for sure --

13 A. I can't --

14 Q. Right. You have no reason to doubt that that suggestion --

15 A. No.

16 Q. Then Mr. Krajisnik is saying a few lines later on. He says:

17 "Well, best man," he calls him, "we need to try everything to calm the

18 situation down." And then Mr. Mandzic has been there according to

19 Mr. Tintor. Mr. Krajisnik says: "Very important to keep peace." And then

20 Tintor says: "Yes, they're on the move, best man." And Mr. Krajisnik

21 says: "I don't think they are." And it ends up with Mr. Krajisnik

22 saying: "Yeah, because there's panic. You check this. All right. There

23 may be something going on. You need to check on this panic." Tintor:

24 "Yes." Mr. Krajisnik: "Check it and let me know. I'll be here."

25 Ms. Hanson, do you know that Mr. Tintor and Mr. Krajisnik at that

Page 10113

1 time knew each other very well personally?

2 A. They used the personal form of address in this conversation, the

3 informal. They call each other "best man," and in Jovan Tintor's

4 interview -- I didn't play that part but I did look at his entire

5 interview. He says that he knew Krajisnik quite well from before the war.

6 Q. But you don't know more than that then?

7 A. They were both on the Main Board, but how -- that doesn't

8 necessarily mean intimate friends. But from the phone conversation alone

9 it's clear that they know each other well, because as I said they use the

10 informal address.

11 Q. And there's nothing -- from what you see, nothing inconsistent

12 from the proposition that they actually knew each other very well

13 personally and were really close?

14 A. Nothing inconsistent with that, no.

15 Q. And this is Goska, Lagoska [phoen] we're talking again, aren't we,

16 about somewhere which is near to where Mr. Krajisnik lives and is based?

17 A. Yes.

18 Q. And is what you've seen then inconsistent with this being --

19 obviously it's to do with what's happening, Ms. Hanson, I'm not suggesting

20 that, but consistent with it being more in the nature of a personal

21 approach to somebody important to Mr. Krajisnik, somebody important who

22 Mr. Tintor knew well to tell him about the situation, rather than a formal

23 report to Mr. Krajisnik in some capacity, official capacity, in relation

24 to the work of the Crisis Staffs?

25 A. I think it's both because he -- Tintor does say, "It is my duty to

Page 10114

1 inform you." So I see both purposes to this conversation.

2 Q. Is the -- we may have to look at the document for this, but the --

3 do you recall specifically what is the precise sense of the B/C/S or would

4 you need to see the document as well?

5 A. I would need to see the document to refresh my memory.

6 Q. Well, I think perhaps that would be a good idea then. It's master

7 tab 406. Yes, it's the B/C/S which I'm inviting you to have, Ms. Hanson.

8 I'd just like you to read -- I'll just make it clear, Ms. Hanson, at this

9 point I'm not challenging you. I just would invite you to read that bit

10 of the B/C/S so that we can have it interpreted as we go. So I suggest

11 that you start at "I think a conflict would break out" or the B/C/S

12 equivalent of that, that's Mr. Tintor, just Mr. Krajisnik says, "Yeah."

13 A. Tintor says --

14 THE INTERPRETER: I think the interpreter did not understand the

15 witness.

16 THE WITNESS: Krajisnik: "Please it is my duty to inform you what

17 is happening at this moment.

18 MR. STEWART: Sorry, if I may just address the interpreter. It

19 seems that you -- initial understanding -- whatever initial

20 misunderstanding, the interpreters now seem to have understood the witness

21 perfectly well. Is that correct?

22 THE INTERPRETER: Not the first sentence I'm afraid.

23 MR. STEWART: What, about the -- let's just do it again.


25 MR. STEWART: Please, Your Honour. Thank you. I'm obliged for

Page 10115

1 that.

2 THE WITNESS: Tintor: "I think that it's going to blast up

3 there."

4 Krajisnik: "Yeah."

5 Tintor: "Please, it is my duty to inform you what at this

6 moment."


8 Q. So, Ms. Hanson, you're getting -- from that you attach quite some

9 significance to that phraseology, don't you?

10 A. I find it a telling phrase.

11 Q. So you'll link together, just to confirm the understanding, you

12 link together the fact that Mr. Tintor is the head of the Vogosca Crisis

13 Staff, with him saying it's his duty to inform Mr. Krajisnik, and then

14 there's nothing else at that point, is there, 3rd of April, 1992, apart

15 from whatever positions Mr. Krajisnik held at that time?

16 A. Noting simply that Tintor says he's calling from the Vogosca

17 "shtab," [phoen] staff, is another indication of -- is something else I

18 tie to that phrase. But in -- I do not claim that this is a formal report

19 but that as Tintor himself indicated in his interview he had other forms

20 of communicating with Krajisnik and the Bosnian Serb leadership. This is

21 indication, at a minimum, of a head of a Crisis Staff and member of the

22 Main Board communicating to Krajisnik about events on the ground, and that

23 is how I represented it in my presentation.

24 Q. And the duty that is referred to then and which you attach some

25 significance to, what was the basis of that duty then? What -- the

Page 10116

1 position of Mr. Tintor, that's clear, the head of the Crisis Staff; we

2 needn't debate that. So that's one side. And then Mr. Krajisnik's

3 position and the particular structure which made it Mr. Tintor's duty to

4 report this to -- relate it to Mr. Krajisnik, what do you say that was?

5 A. I do not say that it was any specific position because at this

6 point the only normative document for Crisis Staff is the 19th December

7 instructions, the instructions we see coming out later this month. April

8 do say that Crisis Staffs are -- have a link to the republican organs. In

9 this I think it indicative of the overlap at the highest level of a number

10 of different positions, both in the SDS and the Assembly and the Bosnian

11 Serb organs as we discussed when we first presented this intercept.

12 Tintor says at the beginning he's calling the Speaker, but I don't know

13 that means he's calling him because he is Speaker of the Assembly --

14 Q. Can I make a suggestion to you there, Ms. Hanson, he's got the

15 telephone at the Assembly where Mr. Krajisnik works. So he's simply

16 saying who he wants to get through to.

17 A. Yes. That is how I explained it when we first introduced this.

18 Q. So there's no special significance there. That doesn't carry the

19 matter any further than the fact that he wanted to speak to Mr. Krajisnik,

20 does it?

21 A. Correct.

22 Q. Right. So then you -- well, it's this, isn't it, that this is

23 before -- of course before the meeting of the 6th of July, 1992,

24 obviously?

25 A. Yes.

Page 10117

1 Q. Was April. We see that. Mr. Krajisnik -- you have not identified

2 any specific position that Mr. Krajisnik held at that time in relation to

3 Crisis Staffs, specific?

4 A. He was a member of the Main Board, and the 19th December

5 instructions bear the letterhead of the Main Board of the SDS. And as I

6 indicate in my report, it was -- the Crisis Staffs looked to the Bosnian

7 Serb leadership in general terms and saw themselves as part of this system

8 now being set up, the state system now being set up, the system that arose

9 from the SDS party. So as I indicated in my report there, it's the

10 overlap of these organs that lead to some imprecision on the ground but

11 they certainly saw themselves -- these municipal bodies certainly saw

12 themselves as part of the system now at this point being created.

13 Q. Well, Ms. Hanson, on the basis my question included the

14 word "specific" and your answer included the word "general."

15 We'll move on then to this question which is: On the basis of

16 what you've seen as at the beginning of April 1992, so far as there was a

17 specific duty on Mr. Tintor to make such reports, it would have been a

18 duty to make them to Dr. Koljevic, wouldn't it?

19 A. I don't see why Mr. -- Dr. Koljevic specifically at the beginning

20 of April -- as I said in my report, this is the time when Crisis Staffs

21 begin to emerge from the secrecy of being party organs to more public

22 governmental roles and certainly the 3rd of April is still a transient

23 time, as we saw on the 1st of April, the Bijeljina Crisis Staff reports to

24 the SDS Main Board. In terms of Mr. Koljevic's position in the

25 Presidency, I would have to check -- I don't know offhand when the

Page 10118

1 Presidency as that started meeting, but I don't believe -- pardon me, but

2 I don't believe the 3rd of April there was -- the Presidency was meeting.

3 So in that respect I don't see that he would report to Dr. Koljevic

4 specifically.

5 Q. So you're saying the Presidency was of no particular significance

6 as of that date in this context, are you?

7 A. I am not sure, since I have focused in my preparation on the

8 municipal level and did not commit to memory the details of the republican

9 level. I cannot recall the time at which we see the Presidency as such

10 beginning to meet, and I don't want to speak with any certainty on that.

11 Q. The next intercept that you referred to in the same passage of

12 your evidence, that was Wednesday, the 2nd of March, and it was

13 immediately after that one, so it's at the foot of page 61 for the record

14 and reference. You refer to -- and we heard an intercept of -- well, we

15 read anyway, a conversation between Mr. Krajisnik and Mr. Momo Garic on

16 the 21st of April, 1992. You recall that, Ms. Hanson?

17 A. Yes, in general terms I recall it.

18 Q. And Mr. Garic had -- it was Novo Sarajevo Crisis Staff. You

19 summarise it as he's calling Mr. Krajisnik to discuss problems on the

20 ground. And Mr. Krajisnik was saying, Sure, come up, have a meeting. And

21 you say "he's clearly available to Crisis Staff members and interested in

22 the situation on the ground."

23 Do you know that Mr. Garic was also personally close to

24 Mr. Krajisnik?

25 A. I don't know that. If I could see the original B/C/S, I could

Page 10119

1 confirm whether he uses the informal form of address, which is a general

2 indication.

3 Q. Well, let's see that then, shall we. Mr. Hannis is very alert to

4 have that ready for you.

5 MR. STEWART: Thank you.

6 THE WITNESS: They appear to use the formal form of address with

7 each other, but they inquire after each other's -- they know each other.

8 They inquire after each other's well being.


10 Q. And this is -- this of course is local, isn't it, to

11 Mr. Krajisnik? It's Novo Sarajevo?

12 A. Yes, it's in the Sarajevo area.

13 Q. Would you have drawn the inference that because Mr. Garic was a

14 member of the Crisis Staff, that shows that Mr. Krajisnik was available to

15 Crisis Staff members; that's the way you've put it?

16 A. Yes.

17 Q. Expressed generally.

18 A. Yes.

19 Q. Now, Ms. Hanson, I want to make it clear, not necessarily

20 suggesting, I leave it entirely neutral as to Mr. Krajisnik would have

21 rejected approaches. But we have -- so far what you've identified is

22 Mr. Tintor and Mr. Garic both well-known to Mr. Krajisnik. Do you accept

23 that it is -- one should apply considerable caution to moving from such

24 contacts with people who are well-known to Mr. Krajisnik to some general

25 proposition that he had a function and was available to Crisis Staff

Page 10120

1 members across the board?

2 MR. HANNIS: Your Honour, I think that mischaracterises her

3 testimony. She didn't say members across the board. She just said

4 members.

5 MR. STEWART: The point is the same if I simply strike, as

6 Mr. Harmon would say, the phrase across the board.

7 THE WITNESS: As we see from the 19 December instructions, Crisis

8 Staff members were to include Assembly deputies and members of the Main

9 Board. In both those contexts Mr. Krajisnik would know Crisis Staff

10 members. Other members of the Main Board have also been identified as

11 Crisis Staff members in their municipalities. And it is precisely because

12 Crisis Staffs were set up by the SDS, and Mr. Krajisnik was a leader of

13 the SDS and the Assembly he would know Crisis Staff members in a variety

14 of contexts. And similarly Crisis Staff members who wanted to contact the

15 leadership might not think in rigid categories of for this particular

16 issue I contact such a person, but I think that to a large extent they

17 would rely on their pre-existing acquaintances whom they knew in informal

18 channels of communications as well as formal.


20 Q. Ms. Hanson, embedded in that answer is something which I put to

21 you, which is that of course personal -- in politics, which this was among

22 other things, of course personal contacts are continually used and

23 exploited, aren't they?

24 A. Yes.

25 Q. So that what I was suggesting to you was that great caution needs

Page 10121

1 to be applied in inferring from the use of those personal contacts

2 specific formal responsibilities and duties. Do you agree with that as a

3 general proposition?

4 A. I -- I'm looking at your question now that I've learned to use it.

5 The question of specific formal responsibilities and duties. I do not

6 infer from these conversations that we've been discussing that these

7 Crisis Staff members thought that Mr. Krajisnik had in his -- had specific

8 formal responsibilities for those Crisis Staffs. I read it rather that

9 they see him as a member of the leadership of the state, someone to whom

10 they can turn, and someone to whom they should inform of events on the

11 ground.

12 Q. Do you get any impression from the documents you've read and these

13 intercepts that Mr. Krajisnik was more than capable of being a calming

14 influence on the people who came in contact -- had contact with him?

15 A. We certainly see that in the Tintor intercept where he is trying

16 to calm Mr. Tintor and saying I don't think there is -- I don't think this

17 calls for panic.

18 Q. And there is an impression there, isn't there, Ms. Hanson, that

19 Mr. Tintor was panicking?

20 A. He was alarmed. His voice doesn't sound, I would say, panicked,

21 but he is clearly alarmed about the events on the ground, and

22 Mr. Krajisnik is endeavouring to calm him.

23 Q. So do you get any impression, then, that's what's happening there

24 is what will often happen as a person who is very panicked and wound up

25 will naturally contact somebody that their experience shows is going to

Page 10122

1 calm them and instinctively contact somebody, experience shows, who is

2 likely to calm them down.

3 A. I'm reluctant to get into the psychology of the conversation,

4 because once again I return to the phrase "my duty to inform you" he is

5 not just saying, I'm worried, he's informing somebody who he thinks can

6 assist in this situation or who should know about this situation at least.

7 I take it as simply more than calling a friend who would calm him down.

8 Q. Yes, to be -- to try to be fair, Ms. Hanson, I'm not trying to put

9 you in that -- extra role of an expert psychologist; that would be rather

10 unfair. I was simply asking whether you had got that impression from your

11 reading of all the documents.

12 A. Again, I certainly see it -- I see that attempt to calm in this

13 intercept.

14 Q. Now, the next -- I don't want to dwell on that intercept anymore,

15 and we can move on. You also in your evidence, and it's pretty much in

16 the same part of evidence, Wednesday, 2nd March, at page 64 you refer to

17 an Assembly session. It's the May the 12th Assembly session. And you

18 refer to a speech of Mr. Radic's and it's -- the reference is there. And

19 Mr. Radic had said: "At the intervention of the president of the

20 Assembly," Mr. Krajisnik, "we released that Ustasha, that Ivo Stanic whom

21 I had taken prisoner. This is what I regret having done most." And the

22 use of the word "Ustasha" confirms what in fact is the case that

23 Mr. Stanic was Croat.

24 A. I assume from the name Ivo and as you say from the reference to

25 Ustastha. They use Ustasha generally to mean Croats on the enemy side.

Page 10123

1 But, yes, I would take that to mean --

2 Q. We see that --

3 A. Yes. From that statement, from his speech I would logically infer

4 that Ivo Stanic was a Croat.

5 Q. That's what the Defence put to you anyway, Ms. Hanson.

6 A. Yes.

7 Q. Then you said -- you noted here because it's indicating that Radic

8 received a direct intervention -- I'm sorry, received an intervention from

9 the president, from Krajisnik as president of the Assembly, and I'm not

10 suggesting there's any other president referred to here, that is

11 Mr. Krajisnik, and "released the prisoner upon his intervention even

12 though Radic did not want to do it."

13 Ms. Hanson, that's not - and say if you wish to be refreshed with

14 the actual document - but I put to you that's not what Mr. Radic is

15 saying. He's not saying he did not want to do it. He is saying he

16 regretted having done it, which is something quite different, isn't it?

17 A. I wouldn't say it's quite different. I inferred his not wanting

18 to do it from his statement of regret. That's, I think, a reasonable

19 inference. I don't -- I don't know how else to read that he regrets

20 having done it unless he is -- I'm -- I don't see -- that's how I make the

21 connection. I think it's justified by his expression, but -- and I don't

22 understand the difference entirely that you're drawing.

23 Q. Ms. Hanson, you want to let your son use your car and your son

24 goes out and uses your car, you want to do it, you want him to have it.

25 He smashes it up - my son's never done this - but he smashes it up, you

Page 10124

1 regret the fact that you let him take your car out that night. But it

2 wasn't that you didn't want to do it at the time. Do you understand that

3 simple distinction?

4 JUDGE ORIE: Mr. Stewart, if it's of any use to you, you've drawn

5 our attention and the attention of Ms. Hanson to the original text and you

6 see a difference which I can follow and ...

7 MR. STEWART: Thank you, Your Honour.

8 Q. It's this, just to clear this up, Ms. Hanson, the impression given

9 by your evidence then is that Mr. Radic didn't want to do something and

10 that in some way Mr. Krajisnik overrode him.

11 A. I understand the differences; you explained it with your analogy.

12 I would say he did something that was against his inclinations, and he did

13 that thing because of Mr. Krajisnik's intervention. But I understand the

14 difference and the Court has --

15 Q. Well, Ms. Hanson, I'm going to put to you very specifically

16 because after all apart from everything I do have instructions from

17 Mr. Krajisnik in relation to certain things, that what happened was that

18 Mr. Radic in no way overrode, that Mr. Krajisnik did use his position to

19 get Mr. Stanic released because Mr. Stanic was a deputy of the Assembly,

20 so he was one of Mr. Krajisnik's colleagues and he did get him released.

21 Do you know -- do you -- what, do you know anything to contradict that,

22 Ms. Hanson, is question number one?

23 A. No. I do not know anything and that is consistent with what

24 Radic says.

25 Q. And then in the same batch of evidence, if you like, that was

Page 10125

1 Wednesday, the 2nd of March then at page 65, you then referred to and gave

2 evidence about an intercept of a conversation between Mr. Momcilo

3 Krajisnik and Mr. Mirko Krajisnik. And you know -- I expect it was

4 expressly recorded somewhere in your evidence, but you know that Mr. Mirko

5 Krajisnik is Mr. Momcilo Krajisnik's brother?

6 A. Yes, I do.

7 Q. And also that this all relates to one of the Sarajevo

8 municipalities?

9 A. Yes, to Rajlovac.

10 Q. Which is Mr. Krajisnik's own -- his home municipality, if you

11 like. Do you know that?

12 A. Yes.

13 Q. And there seems a bit of vagueness here on Mr. Momcilo Krajisnik's

14 part about this -- well, I'll just remind you. Momcilo Krajisnik. Now

15 Mr. Krajisnik here: "Okay. Tell me how things are going in Rajlovac.

16 You know ...

17 "Mirko: Which things?"

18 No disrespect; it's just easier that way.

19 "Momcilo: That man from the municipality the one that came

20 recently, the commissioner.

21 Mirko: Yes, yes, he's not there. He said he would be absent

22 two days. I don't know where he is. But apparently he will be here at

23 the meeting tomorrow.

24 Momcilo: Okay."

25 You agree that Mr. Krajisnik doesn't seem to be greatly in the

Page 10126

1 picture about what is going on there?

2 A. He is inquiring about his whereabouts as far as I know or whether

3 he's come or not. So he's trying to learn.

4 Q. About his --

5 A. About him, yes.

6 Q. And about something happening in his own home municipality?

7 A. Yes.

8 Q. From his own brother?

9 A. Yes.

10 Q. Ms. Hanson, you're not going to draw any significant inference

11 from that, are you?

12 A. I draw inference from the fact that he's inquiring about the

13 commissioner.

14 Q. And what's the date of that? I'm just reminding myself.

15 A. It's late June.

16 JUDGE ORIE: 22nd of June, 1992.

17 MR. STEWART: I'm very grateful, Your Honour.

18 Q. There was a lot going on then, isn't there?

19 A. Yes.

20 Q. Not surprising that Mr. Mirko Krajisnik or Mr. Momcilo Krajisnik

21 talk about a little bit more -- I was going to say next week's football

22 match; wrong time of year perhaps.

23 A. No, not surprising.

24 Q. A talk about cricket would be surprising, but that's another

25 matter.

Page 10127

1 The -- let's then look at what you say about the role of the

2 Assembly and the members of the Assembly. You referred to -- and again,

3 Wednesday, the 2nd of March you referred to -- it's tab -- presentation

4 tab 108 --

5 JUDGE ORIE: May I first perhaps, Mr. Stewart, correct myself. I

6 was referring to the date of tab 120, and only now looking at it a bit

7 better you're referring to tab 119 in the presentation tab binder, which

8 is the 20th of June, so two days before the date I mentioned.

9 Please proceed.

10 MR. STEWART: Yes, thank you for the -- thank you for that

11 correction, Your Honour. I'm obliged.

12 Excuse me, Your Honour, I'm wondering which is the more convenient

13 reference document here. Yes.

14 Q. At -- it's at page 55 of your transcript, Wednesday, the 2nd of

15 March, you referred to presentation tab 108 which is a record or a

16 transcript of the 17th Session of the Serb Assembly on the 26th of July,

17 1992. And you referred specifically to comments by Mr. Jovo Mijatovic

18 where he said: "It is the MPs," that is the Members of Parliament, "who

19 are to transfer the authority of the republic to the municipalities and

20 from the municipalities here, an indication of their view of the role of

21 assemblymen."

22 That's -- well, that would be a fairly standard uncontroversial

23 view of the role of any Member of Parliament pretty much in any

24 parliament, wouldn't it?

25 A. Consistent, I think, with the general role of parliament members,

Page 10128

1 yes.

2 Q. And if we look -- I would invite you to be given this then,

3 please. This is presentation binder 3, tab 108. Is this something -- may

4 I inquire, I'm sorry, I'm not sure the person to ask for my inquiries. Is

5 this something that can be brought up on the screens?

6 MR. HANNIS: Yes. And I've just handed it to Ms. Hanson, and the

7 portion you're talking about is highlighted.

8 MR. STEWART: Thank you very much.

9 Q. May I check with you the page number. Page 58 of the translation;

10 that's what you've got, haven't you?

11 A. Yes.

12 MR. STEWART: Can we just scroll up, please, a tiny bit. Thank

13 you. And then back to -- I'm sorry, here we are.

14 Q. Do you see in the middle of what we've got on the screen now it

15 says "this strong central power." Do you see that?

16 A. Mm-hmm.

17 Q. "This strong central power should also manifest itself in one

18 more issue, and that is the fact that in this moment the Presidency and

19 the government should get extraordinary authorisations in order to be able

20 to act promptly in certain situations. If we need to say more, as most

21 MPs have already noticed a strong central authority should also manifest

22 itself in the status MPs. Everyone has said and our president has

23 repeated several times that an MP represents authority."

24 Again, Ms. Hanson, do you -- the nature of all the research and

25 study you've done over the years, do you agree that generally speaking in

Page 10129

1 parliaments throughout the world, members of that parliament tend to be

2 very jealous of their status very concerned to ensure that their status

3 and authority is properly recognised?

4 A. I don't have any basis for making a general statement about other

5 parliamentary systems. I would say that parliamentary members do see

6 themselves as having an important role -- they're part of the government,

7 they're part of the authorities, but as far as their jealousness of their

8 role, I don't want to make a statement regarding their jealousness.

9 Q. You've never seen that as a feature of political life in all your

10 studies over the years?

11 A. I have seen it, but I'm just reluctant to speak of all

12 parliamentary systems all over the world as you seem to be talking about.

13 Q. And then what it says: "Everyone has said" --

14 JUDGE ORIE: Before we continue, Mr. Stewart, I get the feeling I

15 do not know whether Mr. Krajisnik is able to follow because on the

16 computer evidence screen I've got pages which seem not to be the right

17 ones because I see that the last three digits of the ERN number, the

18 relevant pages, that is page 59 and 60 should be 553 and 554, as I see now

19 523 on my screen, page 29. And I really have some difficulties in

20 combining them since I would very much appreciate it if Mr. Krajisnik at

21 least has an opportunity to follow on the screen the original B/C/S.

22 MR. STEWART: Yes, I'm not sure, Your Honour. I don't wish -- I

23 don't wish to bring any pressure on Mr. Krajisnik in relation to this.

24 I'm not sure whether he is immediately concerned as he is able to get the

25 B/C/S translation -- interpretation as I am reading it. If he is

Page 10130

1 concerned at this moment, then of course he will say so.

2 JUDGE ORIE: Concerned or not it is a general concern of the

3 Chamber that Mr. Krajisnik is able to follow if he wants to.

4 MR. STEWART: Your Honour, indeed. I am heartily endorsing that,

5 Your Honour. I am suggesting in relation to this specific piece of

6 evidence --

7 JUDGE ORIE: Then you --

8 MR. STEWART: -- if he has that opportunity and isn't concerned,

9 then I am not concerned on his behalf right now at this particular point.

10 JUDGE ORIE: Then you may continue and at the same time the OTP

11 will try to follow the general guidelines.

12 Please proceed.

13 MR. STEWART: Yes, I'm obliged. But the general point I entirely

14 100 per cent accept, Your Honour. I do wish Mr. Krajisnik to be able to

15 follow, of course.

16 Q. And then this Mr. Jovo Tovic I think it says, isn't it, has

17 said: "Everyone has said and our president has repeated several times

18 that an MP represents authority. However, an MP is anything but

19 authority. An MP is someone with who every scumbag and low-life can do

20 what they please. This has especially proved at checkpoints where we have

21 single out certain ministers right here. There are checkpoints where we

22 do not know who is appointed for, who controls whom, and not to mention

23 that some MPs cannot pass certain checkpoints and are being mistreated

24 even by legally that authority which now considers itself legally elected.

25 I suggest that the question of status does not reflect as flat rate,"

Page 10131

1 that's what's written there, "but rather in certain authority writes and

2 responsibilities of the MPs that they have to undertake in the wartime

3 period. It is the MPs who are to transfer the authority of the republic

4 to the municipalities and from the municipalities here."

5 Now, that last sentence is the highlighted passage, but do you

6 agree, Ms. Hanson, that the picture presented by this particular Assembly

7 member of the situation and the way in which their work is done presents a

8 rather more difficult and complicated picture than simply of people able

9 to perform their duty of transferring authority backwards forwards,

10 republic to municipalities and municipalities to republic?

11 A. He's indicating that -- yes, there is some circumstances or some

12 places in which assemblymen have not been getting the respect that he

13 feels they should have.

14 Q. The picture is a lot for difficult than they want it to be, isn't

15 it?

16 A. He's describing difficulties, yes.

17 Q. And then on the next page of the same day --

18 JUDGE HANOTEAU: [Interpretation] Just on this same page.

19 Ms. Hanson, I would like you to comment this red highlighted

20 sentence. I do not understand how a member of the Assembly could be in

21 charge of transferring the republic authority, i.e., to represent the

22 republic at the level of municipalities. In the notion that I have of a

23 democratic system, I do believe that the role of the MP is to listen to

24 whatever citizens have to say and expectations and also to transfer

25 decisions made by the Assembly to them. What I do not understand: How

Page 10132

1 the MP should be in charge of transferring the republic authority towards

2 the municipalities. He's not an agent of the republic; he's elected but

3 he's not an agent of the republic such as a district prefect, for

4 instance. I don't understand this sentence. Could you explain it for me,

5 please.

6 I'd like to take the floor again. So what it would mean, if I

7 interpret correctly, it would mean that we entrust the MP, a role

8 of "missi dominici" of the republic. He does represent the republic on

9 the field and that's how I understand this sentence. Is this the way it

10 should be read?

11 THE WITNESS: Just to clarify, I'm personally not familiar with

12 the role of "missi dominici." In order to answer your question fully, if

13 that could be explained to me. That's how it appears on the transcript,

14 "missi dominici."

15 JUDGE HANOTEAU: [Interpretation] Mrs. Hanson, would that mean that

16 the MP, that in your understanding that the MP is the representative of

17 the republic vis-a-vis the municipalities?

18 THE INTERPRETER: Correction of the interpreter, for the

19 municipalities.

20 THE WITNESS: Yes, that is my understanding, bearing in mind that

21 we know that deputies of the Assembly were to be members of the Crisis

22 Staff and the Crisis Staffs become the municipal authorities and do so, as

23 we saw from the Assembly discussions in February and March, looking to the

24 Assembly for instructions about how to set up a state because the whole

25 Bosnian Serb state is being created at this point, and they see the

Page 10133

1 Assembly as one of the engines -- one of the core organs of the state and

2 also the engine for the establishment of this state. And since they are

3 creating their own state, they are giving themselves authority, and the

4 Assembly they see as the supreme authority. And they go to the

5 municipalities as members of the Crisis Staffs and as representatives of

6 the republican authorities. We also saw that in the discussion on

7 republican commissioners in November 1992 where they say it doesn't matter

8 whether it's a commissioner or a deputy, what matters is the psychological

9 effect. Someone coming to the municipalities is seen as representing, in

10 that passage, the republican organs in general. But specifically, I tied

11 that here to their role on Crisis Staffs and to the role in the Assembly

12 in the establishment of the Bosnian Serb state.

13 MR. STEWART: Your Honours, I --

14 JUDGE HANOTEAU: [No interpretation].

15 MR. STEWART: So sorry, Your Honour. I notice the time.

16 JUDGE HANOTEAU: [Interpretation] Thank you.

17 JUDGE ORIE: Since we have this document in front of us, I would

18 have one additional question, especially on the speech of Mr. Mijatovic.

19 In the beginning of his speech, and that's on page 57, he refers

20 to discussions in the club sessions, which are announced. He says: "We

21 are told that we are going to have a club session after the first two

22 points, probably meaning most of us; that it would be better if we discuss

23 the issues that bother us calmly among us without making them public."

24 I noticed that -- I hope you'll forgive me that I do not remember

25 exactly the moment when you said this, I remember that you said something

Page 10134

1 about after the break, or something like that. Was this a pattern that

2 part of the problems were discussed in public and that sometimes everyone

3 thought it better to not publicly discuss matters either to reach

4 agreement or for whatever reason? Is that something you came across more

5 than on the occasion?

6 THE WITNESS: I recall Krajisnik's speech on the 24th of March,

7 1992, saying a single method will be applied. I think we'll hear more

8 about it in the form of instructions at the Deputies' Club. He does not

9 say there explicitly, so as not to discuss it in public, but he is

10 referring to the Deputies' Club as another way of communicating

11 information.

12 We also see, in general, that the Deputies' Club I think tended to

13 meet before each Assembly session there would be a meeting. And there

14 was, to the best of my knowledge, not the same formal transcript made of

15 those meetings. I am not aware, in the parts that I have read of the

16 Assembly minutes, other explicit references to doing it without making

17 them public, but I was reading the Assembly minutes more with an eye to

18 discussions of the municipal level and not of the relationship between the

19 Deputies' Club and the Assembly. The --

20 JUDGE ORIE: Yes. I'm just re-reading your answer. So you say

21 that in general, the Deputies' Club tended to meet before each Assembly

22 session --

23 THE WITNESS: That is my understanding. Again, I have to repeat,

24 I did not prepare and really fix in my mind the details of the republican

25 procedures for this presentation. But that's my understanding, in

Page 10135

1 general, of my study of --

2 JUDGE ORIE: And would those who would have access to those

3 Deputies' Club meetings, would they have majority or a minority in the

4 Assembly?

5 THE WITNESS: I believe it was much the same body. I'm not sure

6 of the make-up of the Deputies' Club, but I believe it was the SDS

7 deputies, which is almost the entire Assembly --


9 THE WITNESS: -- to my understanding.

10 JUDGE ORIE: Thank you for that answer.

11 We will adjourn until 11.00.

12 --- Recess taken at 10.35 a.m.

13 --- On resuming at 11.10 a.m.

14 JUDGE ORIE: Mr. Stewart, before I give you an opportunity to

15 proceed, perhaps it would be wise, since footnote 83 is on my mind,

16 although not all the time, perhaps we could have the clarification.

17 THE WITNESS: Yes, Your Honour. I found the documents in

18 question, and they are two different documents. The error -- oh, footnote

19 83, yes.

20 JUDGE ORIE: We have two issues.


22 JUDGE ORIE: Footnote 83 and footnote -- let me see, footnote --

23 MR. HANNIS: 68.

24 JUDGE ORIE: -- footnote 68. Yes, perhaps we first deal with 68

25 because we specifically put that question to you.

Page 10136

1 THE WITNESS: Yes. They are two different documents. The error

2 is in my description of the second document.


4 THE WITNESS: The footnote refers to the relationship of the

5 regional Crisis Staffs in the RS state system. And the -- just to show

6 you the first document, that is, 00835801, to show that it's quite clearly

7 what I say it is, it is the declaration of a state of war --


9 THE WITNESS: -- on the Serbian Autonomous Region of Birac. So

10 that is as described the footnote and it is cited as the National Defence

11 Council of the RS.

12 The error is in the description of the second document, which is

13 listed in the footnote as 00835773, but that it's -- it's actually a

14 three-page document and the relevant portion is on the last page,

15 00835775. It's a document by the Crisis Staff of Bratunac, which cites:

16 "A decision of the National Security Council and a decision of the cell

17 Birac Crisis Staff and a decision of the commissioner of the government of

18 the Serbian Republic for Birac."

19 And it is not as described in the footnote, my apologies, where

20 the error crept in. But it is relevant in the text, describing the role

21 of the regional Crisis Staffs in the system.

22 JUDGE ORIE: I take it will give you some confidence that we even

23 read every detail of the footnote to compare them.

24 THE WITNESS: You know the numbers better than I.

25 JUDGE ORIE: Yes. And when we have footnote -- so in the

Page 10137

1 description, could we have -- I mean it would be a waste of paper. Could

2 we have the proper description of that source given to us, because I think

3 it does not appear in the list clearly, because if I look at footnote 68

4 in the -- well, let's say the database, then I have -- let me just have a

5 look. 68 is --

6 MR. HANNIS: Your Honour, I believe there are four references to

7 footnote 68, and the last one is on page 19 of the spreadsheet and it

8 makes reference to a 6th May decision of the Bratunac --


10 MR. HANNIS: -- Crisis Staff.

11 THE WITNESS: That is the decision.

12 JUDGE ORIE: That is the decision you wanted to refer to?


14 JUDGE ORIE: So we have the description now, and that is

15 presentation tab 310, at least that's what I see from my list. And that's

16 presentation binder 5, tab 310, or master binder 5, tab 200. And I do see

17 that it was already in evidence, is that correct, P57 and 57.1?

18 MR. HANNIS: Correct, Your Honour.

19 JUDGE ORIE: That having been clarified, we now move to footnote

20 83, the Ilijas request for manpower.

21 THE WITNESS: I'm sorry, the footnote number again was?

22 JUDGE ORIE: 83, as far as I remember.

23 THE WITNESS: 83, yes.

24 JUDGE ORIE: Yes --

25 THE WITNESS: -- 83 in the documents, yes.

Page 10138

1 There is no error now that I see. I must have been -- my

2 apologies. It is the document that I said it was. The error must have

3 been in my simply reviewing quickly the documents. There are two, as I

4 said, side by side that are quite similar, but in fact it is the correct

5 ERN; there is no error. I was confused when reviewing, and I'm glad to

6 report that it is correct, now that I see --

7 JUDGE ORIE: Yes, having read it, it seems to be an invitation for

8 paramilitaries to come to their assistance --


10 JUDGE ORIE: -- and issued by a Crisis Staff.

11 THE WITNESS: Yeah. There are two such invitations and they were

12 right next to each other in the -- in the evidence record. And one is to

13 one organisation and I had thought I had got the wrong organisation cited,

14 but in fact the one cited is as described to the Serb volunteer guard.

15 And I was confused, not when writing; I was confused later. My apologies

16 for that -- for the waste of time and the confusion.

17 JUDGE ORIE: Then, Mr. Stewart, we can proceed.

18 MR. STEWART: Thank you, Your Honour.

19 Q. Ms. Hanson, as a follow-up to Judge Hanoteau's question, I

20 actually can't think of a better way of putting this point to you but with

21 a very short slight anecdote. There was an English Member of Parliament

22 at Westminster who in years gone by when he was criticised for not

23 appearing very often in his constituency responded, he wouldn't be

24 able to get away with it these days, but responded by saying, I am elected

25 to represent Tunbridge Wells at Westminster and not Westminster in

Page 10139

1 Tunbridge Wells.

2 Now, I put to you that actually does encapsulate what is also the

3 position here as far as the Serb Assembly is concerned, that the Assembly,

4 and this was, with respect, I believe the Judge Hanoteau also was putting

5 to you, that the Assembly members are elected to represent the people for

6 the constituency or the district that elects them, and they are not

7 elected to represent the government or any republican authority in their

8 district.

9 A. The deputies that make up the Assembly -- that make up the Bosnian

10 Serb Assembly were elected to the Assembly of the Republic of Bosnia, and

11 they set up this separate assembly which, as I said, played a crucial role

12 in the formation of the Bosnian Serb state and the whole -- the Bosnian

13 Serb authorities were defining that authority, the authority of the

14 Assembly of the state as they created the state. And as we see, Karadzic

15 said to the deputies, "You are members of the supreme organ of authority."

16 So the special role of the Assembly in the formation of the Bosnian Serb

17 state gave the deputies a role which they did not have in, for example,

18 the British system.

19 Q. Well, I -- Ms. Hanson, we're not here to have a -- though it would

20 be very interesting, no doubt, to have a seminar or a debate about

21 political theory, practice, practice a bit more perhaps. But I have to

22 put it to you -- well, you use the British example, the United Kingdom

23 example. I would like to put it to you that in describing the Assembly as

24 a supreme organ, that is entirely correct in this sense, that it's the

25 legislature, isn't it?

Page 10140

1 A. It is a legislature, yes.

2 Q. And when it passes laws, those are the laws that have to be

3 applied by the courts and have to be observed by the citizens. We'll

4 leave aside the Republika Srpska/Bosnia element. But in Republika Srpska

5 terms, that's the position, isn't it? It's the supreme organ because it

6 passes the laws, and when it passes the laws, those are the laws, the

7 courts have to apply the laws, and the citizens within Republika Srpska

8 are expected and it is their civil duty -- civic duty to obey the laws.

9 Do you agree?

10 A. Yes.

11 Q. So in that sense it is very clear how and why the Assembly is

12 described as the supreme organ?

13 A. When Karadzic describes the assemblies as a supreme organ, he then

14 goes on to discuss how the assemblymen should go to the municipalities and

15 sit with the presidents of the municipalities and carry out -- implement

16 the policies of the Assembly. That is the context of Karadzic's

17 reference.

18 Q. Are you talking about -- well, let's be clear which reference you

19 are talking about then. There's one thing we can confidently agree upon

20 is that Dr. Karadzic made a lot of speeches.

21 A. Yes, I agree with that.

22 Q. You're talking about the Assembly Session on the 24th of March,

23 1992, aren't you, found at presentation tab 110, master tab 389. Is that

24 correct? You --

25 A. I believe it is tab 110. If I can see it I can confirm.

Page 10141

1 Q. Yes, I believe it is as well, Ms. Hanson. Let's make sure that

2 we're on the same hymn sheet here. I'm slightly thrown because I'm

3 looking at the transcript where it's referred to as tab 110 in the

4 presentation binder and then as master tab 389, but when I go to master

5 tab 389, I find something completely different. So if you'll give me one

6 moment, I'm sure we can sort this out.

7 JUDGE ORIE: It is 1 --

8 MR. STEWART: Reasonably short we can short it out.

9 JUDGE ORIE: It is what the cover page says as well, binder 11,

10 tab 389.

11 MR. STEWART: Oh, I see what's happened, Your Honour. It's that

12 the binder which I very kindly have been allowed to borrow for immediate

13 use from this shelf has actually had this particular item removed, and

14 perhaps that's because you've got it, Ms. Hanson.

15 THE WITNESS: I believe I've got Mr. Hannis's copy as it's

16 annotated.

17 MR. STEWART: I don't know who has the one that's come out of this

18 bundle. But, Your Honours, with respect, I can probably manage with the

19 references.

20 Q. The particular passage you talk about, Dr. Karadzic saying: "The

21 deputies are members of the supreme organ of authority, the Assembly. Now

22 they must literally stay with the presidents of the municipalities."

23 But in order to -- did you have some other part of what

24 Dr. Karadzic says on that occasion in mind as demonstrating the point

25 which you were apparently seeking to make?

Page 10142

1 A. Those two sentences and then the next one that's highlighted --

2 Q. Is that up on our screen now?

3 A. "We do not need that" -- saying -- to give the entire

4 passage. "A municipality president is basically the one who should be

5 obeyed; that is the way it must be. We know our deputies and we can be

6 sure they are very serious-minded people. None of them is power-loving

7 and would mistreat a president of a municipality or undermine his

8 authority. We do not need that because the president of the municipality

9 is the one who carries out our plans."

10 Q. You see so when you gave your answer a few minutes ago -- this is

11 your answer, 44, line 1. Page 44 line 1: "When Karadzic describes the

12 assemblies as a supreme organ, he then goes on to discuss how the

13 assemblymen should go to the municipalities and sit with the presidents of

14 municipalities and carry out, implement the policies of the Assembly.

15 That is the context of Karadzic's reference."

16 Now, you see, what I'm putting to you is that, Ms. Hanson, that

17 precisely misstates both the correct position and what Dr. Karadzic is

18 saying because he is precisely not saying, You go out there and implement

19 the policies of the Assembly. What he's saying is: You sit down with the

20 people who live there, you sit down with the people that work there, you

21 talk to them, you listen to them, and they do what they have to do in

22 their locality. Do you accept my summary as I've just put it to you?

23 A. No. Because he says: "The president of the municipality is the

24 one who carries out our plans."

25 Q. Ms. Hanson, we're going to go endlessly around in circles. This

Page 10143

1 is precisely what I'm putting to you, that whereas your answer talked

2 about the assemblymen going out to implement the policies of the

3 Assembly. What's being talked about very specifically by Dr. Karadzic is,

4 it's the president of the municipality who does the implementation. Do

5 you agree?

6 A. He is saying that the president of the municipality does the

7 implementation, yes.

8 Q. Thank you. And very specifically in the sentence before he says

9 that: "Our deputies, serious-minded people, they would not undermine the

10 authority of the president of a municipality, doesn't he?

11 A. Yes, he does.

12 Q. Now, from what you've seen of all the Assembly sessions and you've

13 seen a lot and you've read -- I take it, Ms. Hanson, at some point you've

14 read all the transcripts of all the Assembly sessions which you've

15 mentioned in the course of your evidence?

16 A. No. I read the passages identified by -- as a -- identify --

17 identified those passages where the speaker is known to be a member of a

18 Crisis Staff, and I read their speech -- or a commissioner.

19 Q. Did --

20 A. Or other parts that were relevant. But I did not read every

21 Assembly session beginning to end.

22 Q. So somebody else made a prior selection of relevance, did they,

23 before you got down to reading those relevant passages?

24 A. Someone else identified every speaker, and on the basis of that

25 list of who's speaking at what time, I went to the Assembly sessions -- to

Page 10144












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

13 English transcripts.













Page 10145

1 the relevant parts of the Assembly sessions.

2 Q. Are you able to say then from what you have read whether it was

3 the general practice for deputies to report in Assembly sessions on --

4 well, ranges of specific local issues from their constituencies?

5 A. Of the passages I mention -- of the passages that I looked at in

6 detail, that was one of what they -- one of their topics that they talked

7 about was reporting on issues of importance from their municipality. They

8 also discussed the laws under consideration. There were other topics of

9 discussion as well. As I say, I'm not going to speak about the part that

10 I did not -- the parts that I did not look at in detail.

11 Q. Ms. Hanson, if I put a proposition to you, then you can either say

12 that you don't know from the reading you've done or answer it as best you

13 can. But what we actually see in this Bosnian Serb Assembly is, once

14 again, something not unusual as far as parliaments are concerned.

15 Deputies, Members of Parliament, will raise issues of policy concern, of

16 major concern, they will use particular local issues to illustrate their

17 points, they may raise from time to time particular local matters of

18 special importance, but the tolerance of their colleagues for listening to

19 any detailed accounts of their own problems in their own constituencies

20 will have its limits because it is not a forum for reporting in detail by

21 deputies on what's happening in their locality. Would you agree with

22 that?

23 A. I can only answer on the basis of what I read from the Assembly

24 sessions, and in there I see they do report on the municipalities, and I

25 do not see evidence of other deputies saying, Enough already, we don't

Page 10146

1 want to hear about that. So on the basis of what I said, I can't entirely

2 agree with your proposition.

3 Q. How many municipalities were represented in the Bosnian Serb

4 Assembly, Ms. Hanson?

5 A. I don't know the exact number. Not everyone, simply because of

6 the structure of elections to the Bosnian republican parliament chambers,

7 which then obviously created who were the deputies for the Bosnian Serb

8 Assembly. So not every municipality, but certainly every -- from all

9 regions of Bosnia.

10 MR. STEWART: Your Honours, there's a point at which Your Honours

11 can read the transcripts of the Assembly sessions and so the picture of

12 the debate is one that Your Honours can get.

13 JUDGE ORIE: We certainly can, Mr. Stewart, and the Chamber

14 notices that now and then the interpretation of those words is not the

15 same between Defence and the expert.

16 Please proceed.

17 MR. STEWART: But, Your Honour, I'm trying, although the line is

18 sometimes a difficult one, of course I'm trying to avoid simply taking

19 cross-examination time in what's actually a debate or an argument about

20 interpretation. The time for that sort of thing will come later.

21 Q. The -- Ms. Hanson, you have not seen any written reports by

22 individual deputies to the Speaker or President of the Assembly,

23 Mr. Krajisnik, in relation to the work of Crisis Staffs, have you?

24 A. No, I have not.

25 Q. Or in fact of Mr. Krajisnik in any capacity?

Page 10147

1 A. We have the written report of the work of the Novo Sarajevo Crisis

2 Staff, which we saw was -- oh, forgive me, that was a government session.

3 No, I have not seen written reports to Mr. Krajisnik on the work of Crisis

4 Staffs, although we do see that the -- there is a National Security

5 Council at the end of April reviewed a report on the work of Crisis

6 Staffs, but I have not seen a written version of that report.

7 Q. And you've not seen any -- well, to qualify this, apart from the

8 major documents that are being looked at, the instructions given -- those

9 by the government in April 1992 and then the December 1991 document, but

10 you have not seen, have you, any written directives coming from the

11 Assembly to Crisis Staffs, have you?

12 A. No written directives, although I have indicated the instructions

13 to Crisis Staffs in the -- spoken in the Assembly.

14 Q. I just want to move on now to a different point which arises out

15 of paragraph 45 of your report which concerns the military role of Crisis

16 Staffs. And then where it starts at that point and then I want to pick

17 the matter up at the end of paragraph 46 where you have a sentence: "The

18 Kljuc Crisis Staff claimed that no significant and important questions

19 from the military and police domain were resolved without the Crisis

20 Staff."

21 And then in the footnote that quote is expanded a bit. There is a

22 general question here, a point I've noticed, Ms. Hanson. The translations

23 which appear in your footnotes are in many, if not practically all cases,

24 different from the translations we have. Is this because you did your own

25 translations as you went along from the B/C/S documents that you were

Page 10148

1 working from?

2 A. Yes. In some cases the English translation had not yet been made;

3 in others, I didn't consult it at all because I worked primarily with the

4 B/C/S original documents.

5 Q. In this particular item which I wonder if you could have is

6 presentation binder 7 at tab 245 according to my note. It's also master

7 binder 4 at 148, if that's more convenient.

8 JUDGE ORIE: Could we have the B/C/S on the computer evidence and

9 could we have the translation on the ELMO.

10 MR. STEWART: Thank you, Your Honour.

11 JUDGE ORIE: I brought the first four binder but not number 7.


13 Q. Now, the passage that I'm looking for here, Ms. Hanson, is at

14 page 3 of the translation. I'm sorry I can't help you immediately where

15 it is in B/C/S, but it's not a very long document.

16 A. We're still trying to find.

17 Q. And it's a sentence which in the English translation -- it's a bit

18 in your footnote that you start off the translation as: "VRS commanders,"

19 and in the translation we have the paragraph begins: "Throughout the

20 armed conflict."

21 Do you see that? You probably have the B/C/S --

22 A. But the presentation tab 245 is not the work of the Crisis Staff.

23 Q. Well, I'm so sorry. It's probably better then if we do master

24 binder 4, tab 148. That's -- my apologies. I'm confident about the

25 master binder reference.

Page 10149

1 A. It's presentation tab 243, if I may use, because we have that.

2 Q. Oh, yeah. I thought that's what I said, but never mind.

3 A. I'm sorry, because in the transcript it said 245.

4 Q. Yes, in fact, you're quite right, Ms. Hanson. I had corrected an

5 earlier note somewhere else and I read the earlier one. So it's 243.

6 Presentation binder 6, 243. And 4, 148 as well.

7 A. Yes, I'm just finding the exact B/C/S.

8 MR. STEWART: Your Honour, my apologies, it's not simple

9 incompetence on my part; it's complicated incompetence because of the

10 changing of numbering as we've been going along.

11 JUDGE ORIE: No one thought about incompetence.

12 THE WITNESS: I found it.

13 MR. STEWART: Sorry, Your Honour?

14 JUDGE ORIE: No one thought about incompetence.

15 MR. STEWART: Thank you, Your Honour, for that.

16 THE WITNESS: It is the first paragraph on the B/C/S page

17 00349534.


19 Q. So anyway, it's -- well, either translation. But the -- your --

20 I'll read from the translation in the binder: "Throughout the armed

21 conflict representatives (commanders) of the Army of the Serbian Republic

22 of Bosnia and Herzegovina regularly participated in sessions of the Crisis

23 Staff and the War Presidency. These representatives were in command of

24 and conducted combat activities to defend the territory and citizens of

25 the Kljuc Municipal Assembly against Muslim extremists and maintained good

Page 10150

1 cooperation with the Crisis Staff of the Kljuc Municipal Assembly. All

2 questions related to the army and police were resolved within the Crisis

3 Staff of the Municipal Assembly."

4 Now, first of all, Ms. Hanson, I entirely accept that your

5 translation can perfectly legitimately be different in the sense that it's

6 actually ordered differently -- that those sentences can be -- two

7 translations can structure the translation in a different way, and that's

8 what's happened. But somewhere along the line that passage which appears

9 in the binder translation "these representatives were in command or then

10 conducted combat activities to defend the territory and citizens of the

11 Kljuc Municipal Assembly against Muslim extremists" seems to have got

12 lost. Can you comment on that?

13 A. Yes. My footnote references are intended to summarise the

14 information that I drew from the original document and to point the reader

15 to which part of the document. I agree, this is a -- in the nature just

16 of a summary and parts of that section were left out. And in that

17 respect, the quotation marks are not warranted in that it's not a

18 completely one-for-one translation, but it summarised what I wanted the

19 reader to look for in the original document.

20 Q. Well, Ms. Hanson, I think that perhaps that occurred, it happens

21 in a number of other cases, you appear to be perfectly straightforwardly

22 accepting that where something appears in quotation marks it ought to

23 embrace everything that falls between the beginning and end of those

24 quotation marks.

25 A. Where there are not quotation marks, yes, I'm generally

Page 10151

1 summarising; where there are quotation marks, it is my translation of the

2 B/C/S or if I did consult the English translation -- it is intended to be

3 more a word for word -- a literal excerpt. However, I cannot claim that

4 in the final polishing I went through and checked everything that is in

5 quotation marks. So some summaries have apparently entered.

6 Q. It's not a completely trivial point here, is it, anyway because

7 what's got lost is that these representatives of the VRS were in command

8 of and conducted combat activities is making it very plain, isn't it, that

9 as far as the military responsibilities, the actions are concerned, it is

10 they who are in control and command?

11 A. That is clearly stated in this passage. How -- I would simply

12 note that I cite this passage in support of the statement regarding the

13 commmonality of purpose, not of the military command of the Kljuc Crisis

14 Staff.

15 MR. STEWART: Excuse me, Your Honour, I'm just tracking down my

16 reference here. Yes.

17 Q. At --

18 MR. STEWART: Apologies for the pause, Your Honours.

19 Q. Paragraph 50, you report, last sentence it begins on 23, it's the

20 last line on 23: "In other cases" -- I beg your pardon, it's the previous

21 sentence. "In a few cases", that three lines up, it's a few lines up on

22 the bottom of page 23. "In a few cases the heads of the Crisis Staffs

23 styled themselves commanders and took their control over local forces to

24 the point of assuming direct command of local units."

25 And you give a number of examples and I'm not going to grind

Page 10152

1 through them all, Ms. Hanson, but I am going to take you to one which is

2 Ilijas, that's over the page at footnote 86, page 24, you say: "Ilijas"

3 the footnote says, "Ratko Adzic was president of the Crisis Staff and

4 called himself the commander of VSN BiH Ilijas." And VSN is just VRS

5 proper. A different time when the terminology was slightly different.

6 A. That's my understanding of VSN.

7 Q. And then you've got letter from Adzic to the president of

8 Presidency. And you dealt with this matter on Thursday, the 3rd of March,

9 in your evidence. It starts at page 11. You refer to the letter and then

10 you say: "So we" -- page 12 of the transcript it was, line 3. It's a

11 short passage, Ms. Hanson. "We see here that Ratko Adzic is also the

12 president. He's also the president of the Crisis Staff of Ilijas. We see

13 him here calling himself commander of the army and requesting tanks and

14 aircraft guns for clearing the municipality."

15 Do you know what Mr. Ratko Adzic's position was in the army before

16 the date of this particular letter?

17 A. No, I do not.

18 Q. Do you know that he was in fact a general or at least -- I

19 understand general, but at least a senior -- a very senior officer in the

20 army?

21 A. No, I do not know that.

22 Q. And that the -- so you don't know that the reason why Mr. Adzic

23 would have called himself commander of the army in that particular place

24 is because he was?

25 A. I -- I'm not saying that he wasn't. Saying that he is president

Page 10153

1 of the Ilijas Crisis Staff which -- the transcript doesn't indicate -- I

2 was saying we see, it was kind of an elliptical comment in ellipsis. He

3 is otherwise president of the Ilijas Crisis Staff. We don't see-- we

4 couldn't really see it in that document, but that this document, the

5 president of the Crisis Staff uses a military term "commander" -- calls

6 himself commander, was commander. I'm simply referring to the terms of

7 that letter, that he was a commander.

8 Q. Well, Ms. Hanson, I put it to you, that's not good enough. There

9 are, and I want to clear away any battle lines that don't exist, but there

10 are cases of people styling themselves commanders, there are cases of

11 people strutting around in uniforms with weapons because the opportunity

12 to be soldiers has been presented to them. But you give this as an

13 example supporting the text. And the text is: "In a few cases the heads

14 of the Crisis Staffs styled themselves commanders and took their control

15 over local forces to the point of assuming direct command of local units."

16 And I'm suggesting to you that it's utterly inappropriate to use as a

17 support for that text somebody who was styling himself the commander

18 because he was, because he was, a senior officer in the army and took his

19 control over local forces to the point of assuming direct command of local

20 units because he was the commander of the local units and he would have

21 been signaling failing in his duty if he hadn't actually performed his

22 function as a senior officer of the army. Do you agree?

23 JUDGE ORIE: Could we have the translation on the ELMO, because I

24 see that we have the ...

25 THE WITNESS: I qualify that sentence to include those cases where

Page 10154

1 they called themselves commanders, but certainly I will -- I was not aware

2 of Adzic's position in the army or that the exact nature of the units

3 under his control, but I will gladly accept that that is -- if that is the

4 case that he is calling himself commander because he is commander and is

5 commanding units. I --


7 Q. In the same way that General Eisenhower styled himself commander

8 and chief of the allied forces in Europe because he was?

9 A. He had, I imagine, an appointment, a commission, to that position.

10 I don't know the nature of Avdic's position at that point. I do not know

11 enough about -- I don't know anything about his previous military

12 position.

13 Q. I should say, out of respect to General Eisenhower, I don't think

14 he was the supreme commander was probably the phrase. Ms. Hanson --

15 JUDGE ORIE: May I ask, Mr. Stewart, it's not entirely clear to

16 me. I tried to fully understand. Mr. Adzic was appointed in the VSN BiH

17 and by whom because that question is based upon he being the commander of

18 that army and it's not entirely clear. And since Ms. Hanson says he

19 doesn't know of his position --

20 MR. STEWART: Your Honour, I'm not in a -- I'm not in a position

21 to give the details of the history of his commissions --

22 JUDGE ORIE: But if you include it in your questions.

23 MR. STEWART: I'm trying to answer Your Honour's question. My

24 instructions are, I can't give you more specific detail, that he had been

25 a professional soldier and he didn't suddenly become an officer.

Page 10155

1 JUDGE ORIE: No, I do understand that. I fully understand and you

2 make comparison with General Eisenhower. Of course I do agree that I know

3 his position and he was a general, but that doesn't make him

4 automatically, for example, the commander in chief of the Madurodam

5 forces. That's -- I'm trying to find out what exactly we are talking

6 about. I think I'm not at this moment disputing, apart from that it's not

7 for me to dispute, it's just for me to understand.

8 MR. STEWART: No, I understand.

9 JUDGE ORIE: I try to understand whether he was just a general

10 before and now is a general in a force which is not entirely familiar to

11 me, the Ilijas Serbian army command, and at the bottom it says the Ilijas

12 VSN BiH. I don't know who is responsible for appointing people in that

13 army and whether his appointment as a general prior to acting in this

14 formation had any relation with this specific function. So I'm trying to

15 find out -- he was a general so he now says, now I'm a commander. It's

16 not uncommon for generals to say, I'm in command.

17 MR. STEWART: That's so, Your Honour.

18 JUDGE ORIE: I'm trying to find out and trying to understand both

19 your question and the answers and I'm trying to find out whether your

20 question includes that since he was appointed - and then of course I'd

21 like to know by whom - commander of the Ilijas VSN BiH or that he was --

22 well, let's say a general in the JNA before and suddenly appears, I'm

23 saying "appears" as a very neutral term, as commander of the Ilijas VSN

24 BiH, in order to both understand the answers and your questions, I need

25 more than just, He was a general so he appears now here as a general. I

Page 10156

1 do need this information as well in order to understand and to assess

2 whether the report of Ms. Hanson in this respect shows any shortcomings,

3 yes or no.

4 MR. STEWART: Yes, may I do it this way, Your Honour.


6 MR. STEWART: I 100 per cent accept what Your Honour has said in

7 the sense that the Trial Chamber needs this material to assess Ms.

8 Hanson's report. With respect, Your Honours don't necessarily need all

9 that material now. Some evidence from the Defence would give Your Honour

10 those details, and I'm -- without taking a lot of time or instructions

11 from Mr. Krajisnik and researching, I can't give Your Honour the details.

12 The point -- just so that Your Honour can fairly understand the question

13 and the answer at the moment, the point I'm essentially putting to

14 Ms. Hanson is that there was no question of Mr. Adzic just self-styling

15 himself, calling himself something he wasn't, that what he is calling

16 himself in this document is what he actually legitimately was, as -- Judge

17 Hanoteau has a question I see, Your Honour.

18 JUDGE HANOTEAU: [Interpretation] Madam, in the document that we

19 have in front of us on the screen, Mr. Ratko Adzic calls himself commander

20 of the Ilijas VSN BiH. In your footnote you also say that he also is or

21 was president of the Crisis Staff. Right?

22 My question: So in a way he accumulated two titles, two

23 functions. In this kind of request or demand that emanated from the

24 Crisis Staff and was addressed to the Presidency, was it usual that the

25 president of the Crisis Staff as another title to his own, even if his

Page 10157

1 title is legitimate? Are there any other cases in which he uses both

2 titles?

3 THE WITNESS: I have not -- I do not recall any other document

4 from Ratko Adzic in which he uses both titles. He does sign some

5 documents or uses the title "president of the Crisis Staff" in some, and

6 in this document "commander." I have not seen any from him in which he

7 uses both, nor do I recall at the moment any other Crisis Staff presidents

8 using a title -- using two titles in such a document.

9 JUDGE HANOTEAU: [Interpretation] Do we have to interpret this

10 assertion of a military title as being a militarisation of the Crisis

11 Staff, meaning that the Crisis Staff is playing an essential part in

12 coordinating military action? Could this have that kind of meaning for

13 you?

14 THE WITNESS: Yes, very much so. I cite this in my report as an

15 example of those places where the overlap at the level of the Crisis Staff

16 was almost complete, where the president of the Crisis Staff was a

17 commander or called himself a commander signs here, signs as commander, is

18 a commander. An example of where the Crisis Staff had, as I said, almost

19 complete overlap with the military command roles, I suggest this is the

20 most extreme end of what I call the spectrum, and we do not see this

21 everywhere. But when you have one and the same person as president of the

22 Crisis Staff and as an army commander, you see the strongest example of

23 the militarisation of the Crisis Staffs.

24 JUDGE HANOTEAU: [Interpretation] Madam, one last question as to

25 the addressee of this letter. Who was this letter addressed to in your

Page 10158

1 opinion?

2 THE WITNESS: Radovan Karadzic was the president of the Presidency

3 at this time.

4 JUDGE HANOTEAU: [Interpretation] Thank you, Madam.


6 Q. Ms. Hanson, when you say in response to His Honour Judge

7 Hanoteau's question: "When you have one and the same person as president

8 of the Crisis Staff and as an army commander, you see the strongest

9 example of the militarisation of the Crisis Staffs," I put it to you that

10 actually in the case of Mr. Adzic it's precisely because he is properly

11 performing his duties as an army officer that he writes this letter in

12 these terms and signs it in that capacity because it is very specifically

13 relating to a military matter.

14 A. Yes, this letter is a military matter. He signs it as a military

15 commander.

16 Q. In fact, as your report recognises, there's a -- there's a huge

17 range of -- a huge range of relationships between Crisis Staff and

18 military, isn't there, at this time?

19 A. Yes.

20 Q. That in some cases the military just get on with their job as

21 soldiers, in some cases the Crisis Staff, perhaps because there isn't such

22 a military strength, the Crisis Staff kit themselves out in uniforms, get

23 their weapons, and regard themselves as the soldiers. That's right, isn't

24 it, as a picture of the range and variation?

25 A. Not exactly. The only reference I have of Crisis Staffs kitting

Page 10159

1 themselves out in uniforms and getting their weapons is in Kljuc where

2 they have this decision to allow themselves to wear uniforms and carry

3 weapons. When I'm saying -- not that the Crisis Staff themselves are the

4 soldiers, but in some places we see the Crisis Staffs establishing local

5 units and arming them and in some places issuing them orders.

6 Q. Now, Ms. Hanson, I want to move on to look at these various

7 documents, including the one which -- you have not generally used that

8 particular label, but it's been used often Variants A and B, it's been

9 often used in this trial and in other trials. The -- can we take, please,

10 the -- you told the Trial Chamber I think that as far as you were

11 concerned the best version of this -- that document the -- well, no, let's

12 start somewhere else, please, first. Master binder 1, tab 21.

13 Now, this was the recommendation dated the 11th of December, 1991,

14 emanating from the 3rd Assembly Session of the Bosnian Serb Assembly.

15 That's right, isn't it?

16 A. Yes.

17 Q. And it recommends -- this is just a recap because you've given

18 evidence about this, Ms. Hanson, recommends to the Deputies' Club those

19 assemblies where the rule of majority vote is used to impose decisions

20 that run counter of the interests of the Serb people to take appropriate

21 decisions on the establishment of municipal assemblies of the Serbian

22 people. So, rephrasing that, that's -- that's municipalities where it's

23 the Muslims because they're the national group in question. The Muslims

24 are in control?

25 A. And/or the Croats. It doesn't specify Muslims.

Page 10160

1 Q. That's absolutely right, Ms. Hanson. But for practical purposes

2 in most cases we're talking about Muslim control.

3 A. There were also municipalities where the Croats were the majority.

4 JUDGE ORIE: Yes, the most important thing is that for non-Serbian

5 majority.

6 MR. STEWART: Of course.

7 THE WITNESS: Non-Serbian.


9 Q. And this is -- there's nothing secret about this document.

10 It's -- and there's no ambiguity about its source, is there?

11 A. None.

12 Q. And in fact there isn't any ambiguity about where it's going or to

13 whom it's addressed, is there?

14 A. That all seems clear.

15 Q. That all seems very clear.

16 Q. Then when we get to the document Variant A and B -- we can stay

17 with the same binder, I appreciate you don't have the actual binder. But

18 the document is tab 23 in the same binder, master binder 1. And I'm

19 taking that because I think you referred to this document as the most

20 complete version of --

21 A. Yes. There's one passage that in some translations is rendered as

22 illegible but not in this one so I find it the best --

23 Q. It's the best working tool.

24 A. Yes.

25 Q. The -- first of all, from your perusal of all the documentation in

Page 10161

1 this case, can you offer an explanation of why this document

2 says: "Serbian Democratic Party of Bosnia and Herzegovina Main Board" on

3 the cover sheet and is then typed -- signed at the end "SDS Crisis Staff"?

4 A. Well, as to why it says "Main Board" we know the Main Board

5 existed; we know its role in the SDS. We know there was a meeting of the

6 Main Board on the 20th of December.

7 As for the SDS Crisis Staff, we do see reference to SDS Crisis

8 Staffs or -- I'm sorry, an SDS Crisis Staff at the republican level. We

9 see a -- references in March during the barricades. Karadzic also as

10 early as the summer of 1991 says in an intercept, We have a Crisis Staff

11 here. He seems to be referring to the republic level of the SDS.

12 Q. Have you seen documentation relating -- apart from just what

13 you've just mentioned, have you seen documentation relating to the SDS

14 republican level Crisis Staff?

15 A. I have mentioned now the references. Those are the references I

16 know of.

17 Q. That's all?

18 A. Yes.

19 Q. Are there documents that tell you and through you the Trial

20 Chamber the membership of that Crisis Staff?

21 A. The March references there are also -- now that I say -- I believe

22 intercept references to the March Crisis Staff, but since that was March

23 and I think in the context appears to be related to the barricade -- the

24 question of the barricades in Sarajevo, I couldn't even say it's the same

25 as this. So I believe in those intercepts Rajko Dukic is mentioned in

Page 10162

1 that intercept, but I can't with any certainty connect that to this

2 typed-signed Crisis Staff.

3 Q. What was your reaction when you first saw on this document that it

4 said "Main Board" on the cover sheet and different organ, SDS Crisis

5 Staff, at the end of the document?

6 A. I can't recall my original reaction, but I --

7 Q. Was it --

8 A. -- do not see them as necessarily mutually incompatible in that we

9 see -- at the republic -- in the municipal level we see Crisis Staffs

10 formed within the municipal boards. So it is -- it certainly struck me

11 that there is no other reference at this time to an SDS Crisis Staff.

12 Yes, that struck me. But the front page reference to the Main Board -- it

13 didn't strike me as -- necessarily, as I say, in conflict with the front

14 page description of the Main Board.

15 Q. It's odd, though, isn't it?

16 A. It is anomalous in that there are no other references at that

17 time.

18 Q. It's odd. Ms. Hanson, it's simply odd, isn't it, to have one

19 organ referred to on the cover sheet of the document and then an

20 apparently different organ to having its title, name, at the end, as

21 the -- in some sense the signatory. It is odd, isn't it?

22 A. It's unusual, yes. Odd, anomalous.

23 Q. Well, unusual, odd. I'm not going to quibble about three

24 syllables or one, Ms. Hanson.

25 So my question following from that then is: Isn't it obviously

Page 10163

1 sufficiently odd to cry out for further inquiry and as much inquiry as can

2 reasonably be carried out into explaining that discrepancy?

3 A. The question of a Crisis Staff in December is sufficiently odd.

4 We have looked for reference -- I know other people in my section have --

5 we have discussed, what is this Crisis Staff? We have looked for other

6 references. That's how I am aware of the other references I have

7 mentioned.

8 Q. It sounds as if you haven't quite come up with an answer.

9 A. Well, when one doesn't receive positive identification, we can't

10 say -- no other Crisis Staff -- no such republican level Crisis Staff at

11 this time has been found, so no, yet -- there have been no yet -- until as

12 far as this date no other citings of this. So it's negative results. I

13 can't prove a negative. Nothing else has been found.

14 Q. Just it may be in passing, it may not, it depends. But the very

15 last sheet, page, in the B/C/S section of this tab is a page of

16 handwritten -- not a photocopy of the page, of handwritten material. Can

17 you cast any light on that, who wrote it?

18 A. I don't know who wrote it. It would appear to be an indication of

19 the distribution of this --

20 Q. Well, we've got the translation, so we see 93A.

21 A. 93A, 93B. The -- there's a reference to Mico, perhaps Stanisic.

22 And under 93C, Banja Luka Stojan, also to Gorazde Tuzla.

23 Q. Yes, we see that -- I'm sorry, I don't want to stop you from

24 answering the question, Ms. Hanson. I'm not asking you to go through the

25 content.

Page 10164

1 Can I, though, ask you this: Have you any idea of the date of

2 this document? The page, I'm talking about.

3 A. My -- I have not consulted the original in the vault, but the fact

4 that it was stamped together suggests to me that it was written on the

5 back page of the document or on something attached to it. And as for the

6 date of the drawing -- the date of the writing, I can't say anything more

7 about it than -- we only have what's there. There's nothing else to date

8 it.

9 Q. It's not even clear whether it was written in 1991 or 1992 or as

10 opposed to later, is it?

11 THE INTERPRETER: Mr. Stewart, microphone please.

12 MR. STEWART: Thank you for the reminder.

13 THE WITNESS: There's one that might date. It says: "Assembly

14 tomorrow." "Recognition of Krajina regions have been proclaimed in the

15 Assembly," so those are consistent with shortly after the time of this

16 issuing wouldn't not appear to be referring to anything after 1992, but

17 there's certainly nothing -- no date given in the writing or anything to

18 indicate exactly when it was written.


20 Q. The -- you have said that there was a meeting of the SDS Main

21 Board on the 20th of December, 1991. Can we look, please, at -- it's

22 presentation binder item 12.

23 [Trial Chamber and registrar confer]

24 JUDGE ORIE: Mr. Stewart, if you could find a moment a little bit

25 earlier than usual, that means not later than within the next five minutes

Page 10165

1 to have the break.

2 MR. STEWART: Well, actually, Your Honour, now wouldn't be a bad

3 moment because --


5 MR. STEWART: -- this particular document which has been a

6 horrendous one to identify, I wouldn't mind sorting that out.

7 JUDGE ORIE: Yes. Then we'll have the short break now and we'll

8 resume just after 20 minutes to 1.00.

9 MR. STEWART: Yes, thank you, Your Honour.

10 --- Recess taken at 12.19 p.m.

11 --- On resuming at 12.47 p.m.

12 JUDGE ORIE: Mr. Stewart, please proceed.

13 MR. STEWART: Thank you, Your Honour.

14 Q. Ms. Hanson, so far as -- and whichever particular version of this

15 document, the instructions Variants A and B that we're talking about, you,

16 I take it, have no reliable idea of when and how it was prepared?

17 A. No.

18 Q. Or indeed by whom?

19 A. I am aware of a letter from the SDS in response, I believe, to a

20 request for information which stated that this was -- the document was

21 written by -- I believe it says a group of retired JNA officers. However,

22 the rest of that letter -- the claim that the SDS knows nothing more about

23 the document I find contradicted by the evidence I have seen. So I do not

24 give that letter much credibility.

25 Q. The -- your position that there was an SDS Main Board meeting on

Page 10166

1 the 20th of December, 1991, that's placed on the -- the diary of

2 Mr. Grkovic. Is that right?

3 A. Yes.

4 Q. Could we look at that item, please. It's actually in master

5 binder 9 at tab 372 -- 372.

6 JUDGE ORIE: For those that not yet on the master level --

7 MR. STEWART: Sorry, Your Honour?

8 JUDGE ORIE: For those not on the master level, what would be the

9 presentation number?

10 MR. STEWART: So sorry, Your Honour. It's presentation binder --

11 it's tab 12. In fact, I'm -- the master binder that I have for this goes

12 backwards, so it looks it's if -- rather than being 372, it's actually

13 374. I naively thought that the tab before 373 would be 372, but call we

14 old-fashioned. It's actually -- I think it's master binder 374.

15 Q. But anyway, I see you're looking at the B/C/S version of that

16 document, Ms. Hanson.

17 A. Yes.

18 Q. It actually shows, doesn't it, at the top of -- I'm reading from

19 the translation, but -- the English translation in the bundle, but you can

20 perhaps confirm that it matches. It's got handwritten Friday, 20th

21 December, 1991, at the top. Correct?

22 A. Yes.

23 Q. And then underneath: "1600 meeting at the Main Board in the

24 Deputies' Club." Is that a correct translation?

25 A. Yes.

Page 10167

1 Q. And then at the very bottom there's a sort of interjection which

2 is shown in a box in the translation under the heading 19th of December,

3 1991, and then a number of -- well, dashed or bullet-point type items. Is

4 that right?

5 A. Yes.

6 Q. And then at the very bottom of the page in the English

7 translation - it may not be at the bottom of the page in the B/C/S - it

8 says again: "1600 Main Board."

9 A. Yes.

10 Q. And then -- it's over the page in the English translation,

11 wherever exactly it is in the B/C/S, it says: "For Monday at 1800 and

12 GO," that's Main Board, "and Deputies' Club of SDS Sarajevo."

13 Do you see that?

14 A. I don't have that in the B/C/S. It's not on that page in the

15 B/C/S nor do we seem to have that page of the translation.

16 Q. Right.

17 MR. STEWART: Excuse me, Your Honour, you --

18 THE WITNESS: That's the general recollection, but I do not have

19 it.


21 Q. You'll need the next page which I'll endeavour to get for you

22 straight away. Yes, you need the next page. I have to ask this back,

23 Ms. Hanson, because I've borrowed this binder from the registry at the

24 moment. It's SA 043906 is the reference number it bears at the tope. I

25 promise Ms. Philpott I'm going to make sure the this piece of paper gets

Page 10168

1 back in her binder. Is that correct, that that's now continued?

2 A. For Monday, at 6.00, Main Board and Deputies' Club SDS Sarajevo.

3 JUDGE ORIE: Could we have a look at the document.


5 Q. Ms. Hanson, all I'm going to put to you is that you yourself don't

6 know whether there was a meeting of the 20th or on the 23rd or both or, in

7 theory, neither?

8 A. This is the basis of my saying that there was a meeting of the

9 Main Board on the 20th. This document is the basis for that.

10 Q. Yes. So where we see that -- because we now see that there is an

11 entry of there being a meeting arranged apparently at 4.00 on Friday,

12 the 20th, and 4.00 -- 6.00, I beg your pardon, on the Monday, the 23rd.

13 You -- I'm slightly repeating myself -- you simply don't know whether

14 there was two meetings or whether there was a replacement on the meeting

15 on the Monday for one that was postponed on the Friday. You just don't

16 know?

17 JUDGE ORIE: Mr. Stewart, you say something about the 23rd. I'm

18 not able to follow you.

19 MR. STEWART: Sorry, Your Honour, I had understood that Friday,

20 the 20th of December.


22 MR. STEWART: And then on the next page of the English translation

23 for Monday at 1800, Monday --

24 JUDGE ORIE: Yes. I have no -- in the tab you gave us, I do not

25 have the next page.

Page 10169

1 MR. STEWART: Oh, Your Honour, I'm so sorry. That was the page

2 that the witness sought. It -- I suspect what's happened is that it's not

3 got into the presentation binder, but it is in the main binder only. I

4 see Mr. Hannis nodding.

5 JUDGE ORIE: Could we have a look then at the translation

6 because --

7 MR. STEWART: Yes, Your Honour, the same may apply that it's only

8 in the master binder. Your Honour, shall I hand this up to the one to

9 the --

10 JUDGE ORIE: Yes, if you can do that without war with

11 Ms. Philpott.

12 MR. STEWART: She's been extremely tolerant so far, Your Honour.

13 She'll give me another sticker to make sure that the place is not lost,

14 but this time I can stick it myself.

15 Q. Do you need this one from me? You don't. Thank you so much.

16 Yes, so at the top there we see for Monday, Ms. Hanson. I'd added

17 on the 23rd --

18 MR. STEWART: And, Your Honour, on an assumption which I had

19 made.

20 Q. Please tell me if it would be unwarranted, Ms. Hanson, that the

21 Friday as the 20th and then it's the same Monday that the writer is likely

22 to be talking about following that Friday?

23 A. Yes, that seems likely. Because we see also on that page

24 Saturday -- there was an Assembly session on the 21st, and then it says

25 Sunday, 22nd. So it seems logical that Monday is the 23rd.

Page 10170

1 Q. I don't want to dwell on this too long. Ms. Hanson, it's just

2 this, isn't it: That you do only know about these meetings and dates of

3 these meetings from these pieces of paper?

4 A. Well, we have the minutes of the Bratunac Municipal Board on the

5 23rd of December distributing material entirely consistent with the

6 19 December instructions, saying it came from a meeting of the SDS -- I

7 believe he uses the word "Presidency." So I would say there was a meeting

8 by the evening of the 23rd of December. That is another indication of a

9 meeting at this time, but it's not specifically the Main Board on the

10 20th.

11 Q. But if the Bratunac document is an accurate report, it signifies,

12 or it shows that the document came into Bratunac hands earlier than

13 the 23rd?

14 A. By the evening of the 23rd, at which point Deronjic is sharing it

15 with the rest of Bratunac.

16 Q. Yes. Ms. Hanson, I understand what you're saying. You're saying

17 that the document can't have fallen into their hands at a meeting at 6.00

18 on Monday because that would have been too late.

19 A. I would have to check the time of the meeting in Bratunac, but my

20 inclination is to say it wasn't -- it couldn't get from Sarajevo to

21 Bratunac that evening all in one. So my inclination is to say it was

22 before the evening of the 23rd.

23 Q. Understood. The -- well, then -- that's the date of the meeting.

24 So far as the -- your report is concerned, paragraph 14.

25 MR. STEWART: Your Honour, I'm putting intact -- and it is intact

Page 10171

1 I think, isn't it? I'll do that later, Ms. Philpott.

2 Q. Paragraph 15 of your report -- I'm sorry, 14. You say that: "The

3 19th of December, 1991, instructions set out the preparations in two

4 distinct stages for the takeover of power at the grass roots level and the

5 division of Bosnia and Herzegovina along ethnic lines."

6 And I'm just inviting you, and let's look at that master binder

7 tab 1, item 23, just inviting you to indicate where that document shows

8 that it was preparations for the division of Bosnia and Herzegovina along

9 ethnic -- I'm sorry, I've walked away from the microphone. Where it shows

10 that it was preparation for the division of Bosnia and Herzegovina along

11 ethnic lines.

12 A. It is instructing the SDS to form municipal organs for the Serbian

13 people, to mobilise and create a Serbian police reserve and to then take

14 over power in the municipality in Variant A or, in those areas where Serbs

15 were a majority, in Variant B. And the sum total of those actions is

16 creating separate municipalities, separate municipal authorities on ethnic

17 lines.

18 Q. Ms. Hanson, it is a leap from what this document says to the

19 proposition that it was preparation for the division of Bosnia and

20 Herzegovina along ethnic lines, isn't it?

21 A. I think that dividing municipalities along ethnic lines is the

22 intention of this document. It was distributed, as we know, widely, so

23 such divisions would take place throughout Bosnia at the municipal level

24 according to this document.

25 Q. Does it -- where does it refer in this document to the division of

Page 10172

1 the municipalities in terms of territory, population?

2 A. Under Variant B where it says these measures are to be taken --

3 implemented in those areas where Serbs are a majority, that's in the first

4 section, item 3 on the first page --

5 Q. Sorry, did you say A or B?

6 A. No, the very first section before Variant A.

7 Q. Yes. In the introduction?

8 A. In the introduction. Under item 3 it says: "These tasks,

9 measures, and activities are to be carried out throughout the territory of

10 the socialist republic, completely in municipalities where the Serbs are a

11 majority and partially where the Serbs are in a minority."

12 And under Variant B it indicates that certain measures are to be

13 taken out -- taken -- are to be implemented in those places. Territorial

14 I would assume where Serbs are the majority in terms of the food reserves

15 and of the stockpiles and the security. Overall the division is in the

16 municipal government dividing the municipality along ethnic lines and that

17 the Serbs are setting up their own municipal organs.

18 Q. So when you talk about the division of Bosnia and Herzegovina

19 along ethnic lines, you're talking about politically and organised in

20 government and local government terms, are you?

21 A. And within the municipalities. We see in the Variant B

22 municipalities an actual division of the territory in that some parts of

23 the municipality would be declared the Serbian municipality. We see

24 actual agreements on the territorial or proposed -- I'm sorry, not

25 agreements, but proposals for division of the municipalities proposed by

Page 10173

1 the SDS on the actual territory, naming which streets would be divided.

2 We don't see that in this document, but we see in the declaration of

3 Serbian municipalities in Variant B municipalities, that some territory is

4 declared as belonging to the Serb municipality and other parts of that

5 municipality are not. So it is also a territorial division.

6 Q. Ms. Hanson, this is not, I assure the Trial Chamber, an area of

7 major exploration for purposes of this case for the purposes of this

8 case. But have you in the course of your work on Crisis Staffs for the

9 purposes of this report and more widely as you have described it to the

10 Trial Chamber, have you also examined and considered any material in

11 relation to the establishment of Crisis Staffs by the Muslim community

12 during the corresponding periods?

13 A. I am aware that both Muslim and Croat communities had Crisis

14 Staffs. I've also encountered the term "War Presidency" for some -- in

15 some of those municipalities. I did not examine them for the purposes of

16 this report nor have I ever been -- had an inquiry to respond to --

17 regarding those -- in those terms there are other members of the team who

18 deal with the structures of the Bosnian Muslim forces and the Bosnian

19 Croat forces.

20 Q. But you are well aware, are you, that significant actions were

21 also being taken by the other relations for these purposes, but that's --

22 if I leave Croats on one side certainly because the significance of the

23 Muslims in this matter is rather greater for our purposes, but that

24 significant actions were being taken by the Muslim community in relation

25 to Crisis Staffs, in relation to preparations which might be defensive in

Page 10174

1 some circumstances, might be aggressive in other circumstances, towards

2 the end of 1991 and early 1992?

3 A. I will certainly agree that there were Crisis Staffs as I said on

4 both the Muslim and the Croat side, and I would like not to leave the

5 Croats aside simply because I see that term used more -- I'm more aware of

6 the term "Crisis Staff" used among the Croats, not -- I certainly see

7 it -- I believe that there were municipal Crisis Staffs that involved both

8 Muslims and Croats in more mixed municipalities, or more specifically

9 ethnic -- so I agree there were Muslim Crisis Staffs. I simply -- as a

10 term "Crisis Staff" as opposed to "War Presidency," I see that more among

11 the Croats which is why I'm not going to put it aside entirely.

12 As for the actual actions they have -- they took at this time

13 period, I did not look into those actions specifically, and I have no

14 basis for comparing what they did with the actions of those Crisis Staffs

15 which I did look at, the Bosnian Serb Crisis Staffs.

16 Q. Ms. Hanson, the -- December 1991 and just -- let's assume for the

17 moment that this document was disseminated in the way that you have

18 concluded to the people, to whom it went, and so on. Nobody in December

19 1991, the Serbs, the Muslims, the Croats, heard -- nobody knew what was

20 going to happen over the next few months, did they? Nobody knew whether

21 there was going to be widespread war in Bosnia and Herzegovina or whether,

22 with a bit of hope, that might be avoided?

23 A. What did happen was the result of choices people made. People on

24 the ground didn't know -- no one can know the future, but people can have

25 plans and make decisions and take steps. So the future -- the events that

Page 10175

1 happened were not blind forces but the result of choices made on all

2 sides.

3 Q. This -- I'm going to try and short circuit this as much as

4 possible. This particular document, Ms. Hanson, does simply not, in its

5 own terms, it does not imply the division of Bosnia and Herzegovina along

6 ethnic lines?

7 A. It implies the division of municipalities along ethnic lines and

8 it is to be implemented throughout Bosnia. And in understanding the

9 document, one has to look at what the people involved said about the

10 document and how they referred to it and how they treated it. And I've

11 indicated that in my presentation, the references that even -- Karadzic

12 says taking over real functions. It was a plan for action, and those

13 actions were taken.

14 Q. Now, do you say that the actions -- actions were taken anywhere in

15 accordance with this document, item by item, and implementing the whole

16 list of instructions contained in this document? Do you -- can you -- can

17 you identify a single municipality that carried out 80 per cent of the

18 items in this document?

19 A. Well, I couldn't put a figure on it, but if you look at the Novo

20 Sarajevo receipt of that document and their implementation, they assign

21 people to a good number of the tasks as specified in there. Of course,

22 the available evidence does not allow me to make one -- make a checklist

23 that every municipality carried out -- or any municipality did every

24 single thing. We don't have a record -- a document -- a record that would

25 indicate that, but we see a consistent pattern of the main steps being

Page 10176

1 implemented on the basis of this document.

2 Q. Do you agree that -- well, no, let's put it another way. Where

3 the Serbs are in majority in a municipality, what, from your reading of

4 the documents, do you suggest was the point of variant A?

5 A. To take over all organs of authority, to have the Serbian police,

6 because even in Serb majority municipalities, non-Serbs were in the

7 municipal organs generally in proportion to the representation in the

8 population, or at least in proportion to the results of the election,

9 which, as we know, generally went to the national parties. So not all

10 municipal positions would be held by Serbs or SDS members, and variant A

11 is making sure that those are the SDS members who have those positions in

12 a parallel government, if necessary.

13 Q. So what you're -- what you're saying is that it was -- it was more

14 productive and it was a better plan to have a parallel government than to

15 use your effective political control of the existing government?

16 A. I don't know whether it was better, but that is the choice made in

17 this document as I read it.

18 Q. Let's look at what Dr. Karadzic said at the 50th Republika Srpska

19 Assembly, which we find in master binder 2, at tab 49.

20 MR. STEWART: Excuse me one moment.

21 Q. I can tell you what -- I can tell you what I'm looking for,

22 Ms. Hanson. I'm looking for where Dr. Karadzic refers to A and B.

23 A. That's what --

24 Q. -- you have dealt with --

25 A. Yes, we have it on the ELMO. It's page 323 of the English

Page 10177

1 translation, and in the B/C/S, it's 00846058.

2 Q. "At the moment --" thank you. "At the moment the war began in the

3 municipalities where we were in the majority," that's just over halfway

4 down the page, "we had municipal power, held it firmly, controlled

5 everything. In the municipalities where we were in the minority, we set

6 up secret government, Municipal Boards, Municipal Assemblies, presidents

7 of Executive Boards. You will remember the A and B variants. In the B

8 variant, where we were in the minority, 20 per cent, 15 per cent, we had

9 set up a government and a brigade, a unit, no matter what size, but there

10 was a detachment with a commander."

11 That last bit in the B variant, "we have set up a government and a

12 brigade, a unit, a detachment with a commander," that doesn't fit the

13 content of that document in variant B, does it, Ms. Hanson?

14 A. They speak of mobilising the reserve police and the TO. And as I

15 explained in some municipalities, the SDS and the Crisis Staffs did form

16 TO units. It's not an express statement. The brigade, unit, detachment

17 with a commander as such is not specified in the 19th December

18 instructions.

19 Q. Are you aware from your reading of the papers that by the time it

20 got to 1995, which this was, that there was, in effect, a dispute between

21 the civilian leaders, Dr. Karadzic, and the military leaders, in effect,

22 as to what had gone wrong?

23 A. I am aware of a conflict. The substance of the conflict I'm not

24 sure of, but I certainly agree there was a conflict between civilian and

25 military authorities, yes.

Page 10178

1 Q. And there was -- there was a considerable amount of -- or there

2 were a considerable amount of claims being made on both sides about how

3 much they had done for the Serb cause?

4 A. As I said, I'm not aware of the substance of the conflict between

5 the two.

6 Q. But that's right, isn't it?

7 A. I don't know.

8 Q. That the -- you're not even aware that there was -- there was that

9 tenor of the debate at that time?

10 A. Not -- as I say, I have not referred to any -- I have not looked

11 specifically at any of the speeches and debates about that. It's -- it

12 seems consistent, but I am not going to answer with any confidence that I

13 know that.

14 Q. And it's your inference that Dr. Karadzic is referring to the same

15 documents that we've been looking at, the instructions from December 1991,

16 variants A and B, as they've come to be known?

17 A. Yes, that is my inference.

18 Q. What was the -- how do you fit together, then, the instructions

19 for operation of Crisis Staffs which were issued by the government under

20 Mr. Djeric on the 26th of April, 1992? Why were those necessary at that

21 time?

22 A. Because at that time in many municipalities, Crisis Staffs had

23 come out of secret and had declared themselves to be the municipal

24 governments and to be part of the Bosnian Serb state. And these are

25 instructions from the government on how they are to operate in the Bosnian

Page 10179

1 Serb state. We saw in the Assembly request from Vjestica and others, Give

2 us instructions, and Djeric saying, Don't take actions into your own

3 hands, you will get instructions. I tie all those together as part of the

4 evolution of the Bosnian Serb state and definition of role of Crisis

5 Staffs in that state.

6 Q. Your thesis is that they already had those instructions back in

7 December 1991?

8 A. They had one set of instructions. They had the 19 December

9 instructions, but they were asking, as we saw in the municipality -- in

10 the Assembly minutes, for more and they received more.

11 Q. The instructions of December are far more detailed than the

12 instructions given later, weren't they, assuming they were given?

13 A. I do assume they were given, as I've indicated in my presentation.

14 They are more specific about some matters about specific steps to be taken

15 in the municipal level. Djeric's instructions speak more to the general

16 functions of the Crisis Staff and their role in the state. There is one

17 thing rather specific in Djeric's instructions that -- on the question of

18 moving artillery and controlling the use of artillery seized in war

19 operations. That seems quite specific. But on the whole, it does not

20 have the same itemised list that we see in the 19 December instructions.

21 It does itemise what are to be the tasks of the members of the Crisis

22 Staff, and as I indicated in my presentation, they generally correspond to

23 the taskings of the 19 December instructions.

24 MR. STEWART: No further questions, Your Honour.

25 JUDGE ORIE: Thank you, Mr. Stewart.

Page 10180

1 Mr. Hannis, is there any need for re-examination?

2 MR. HANNIS: Your Honour, I did have some areas that I wanted to

3 address --


5 MR. HANNIS: -- if I may. Thank you.

6 Re-examined by Mr. Hannis:

7 Q. Ms. Hanson, I want to direct you to the topic of the July

8 Presidency session where there was the discussion about Mr. Koljevic

9 requesting to step down and the reason he gave was of his perceived

10 failure to control the republican commissioners.

11 MR. HANNIS: I think, Your Honour, this was from the 7th of March,

12 and at page 81 of the transcript where that discussion begins.

13 Q. Did you take that comment by him to indicate that he was the only

14 member of the Presidency that had up to that time sole responsibility for

15 the war commissioners?

16 A. No, I don't see that -- such a specific reference in his speech.

17 He just is -- seems to be listing the things that aren't going well and

18 the problems he's facing, but he does not seem to be claiming sole

19 responsibility.

20 Q. In connection with that I would like to show you a document that

21 was not in the presentation but is in your master binder at master

22 tab 169. Yes.

23 MR. HANNIS: I'm sorry, Your Honour, I misspoke. This is in

24 Mr. Treanor's binder. This was an exhibit that came through him in P65,

25 and it's at master tab 169. We've made copies of this just to hand around

Page 10181

1 now so we don't have to go find Mr. Treanor's binders. And the ERN of the

2 B/C/S I think is 0076-7932, and the English is 0081-4294 through 95.

3 Q. Do you have a copy of that document?

4 A. Yes, I do.

5 Q. And if I'm correct, this is a Presidency session on the 25th of

6 June, 1992, a couple of weeks before the one where Mr. Koljevic is asking

7 to be relieved.

8 A. Yes.

9 Q. Can you have a look there and tell us -- I think there's a

10 reference to Mr. Koljevic actually being assigned to a particular duty in

11 connection with commissioners.

12 A. Yes. It's the last item of the minutes, and it says that

13 Dr. Koljevic is charged with appointing commissioners of the Serbian

14 municipality of Sarajevo centre.

15 Q. Do you know did Mr. -- did Dr. Koljevic have any particular

16 relationship with the Sarajevo centre municipality in terms of where he

17 lived, where he was from, or where he had family?

18 A. I believe he was from Sarajevo. I don't know that it was the

19 centre municipality per se, but he was from Sarajevo.

20 Q. Now, if he had had complete responsibility for all matters

21 relating to commissioners, would it have been necessary to make a specific

22 designation for him to appoint a commissioner?

23 A. It doesn't seem logical, no.

24 Q. And in that document, was there some reference to the issue that

25 comes up later on in July - I think raised by Branko Djeric - about

Page 10182

1 assigning or dividing responsibilities among the various members of the

2 Presidency?

3 A. Yes. The item immediately above the item I just read, top of the

4 translation, page 2, that working bodies of the Presidency be set up and

5 authority and responsibilities be precisely divided among the members of

6 the Presidency would appear to relate directly to that division of

7 labour -- of tasks that we see at the Presidency session in July.

8 Q. So it appears that this is still an issue that hasn't been

9 resolved?

10 A. Correct. That's how it appears.

11 Q. Now I want to go to presentation tab 122. I don't know if we need

12 to get the whole thing. This was the discussion of the Assembly session

13 where there was discussion about the commissioner -- the war

14 commissioners. Do you recall that?

15 A. The November 1992.

16 Q. Yes. Perhaps we should give it to you.

17 A. There's several long speeches, Krajisnik and Maksimovic, and

18 Mijatovic.

19 Q. Yes. And what I wanted to ask you about was Mr. Krajisnik's

20 speech where he mentioned the commissioners with whom he had personally

21 had dealings and was aware of what they had been doing, if you can find

22 that.

23 A. In the English translation it's page 104. The speech begins on

24 the previous page, but page 104. I think the relevant section -- and in

25 the B/C/S 02149731.

Page 10183

1 Q. Now, what I'm interested in, this relates to the issue of what

2 information Mr. Krajisnik might have had in terms of reports about what

3 was happening in various municipalities. Can you tell us which

4 commissioners he mentions by name as the ones that he dealt with?

5 A. Mirko -- he says about each one of our members. He says: "I was

6 informed about each one of our members." Then he names Mirko Mijatovic,

7 Jovo Mijatovic, Cancar, Marko Simic, Branko Simic, and Vojo Maksimovic.

8 Cancar I take to be Petar Cancar.

9 Q. Who was from where? If you remember.

10 A. Foca, I believe.

11 Q. Now, we've seen in your presentation some documents concerning

12 appointments of some of those commissioners, and just to save a little

13 time, if it's all right with Defence counsel, I want to mention some of

14 those individuals and what documents they appear in. Jovo Mijatovic was

15 in presentation tab 75 which was one of the ones that Mr. Krajisnik has

16 signed and he was appointed for Ilijas; Marko Simic was appointed for

17 Stari Grad in presentation tab 74; and Vojo Maksimovic was in presentation

18 tab 67 for Foca.

19 Now, I want to ask you about presentation tab 69 which was the

20 June 16th appointment of Dragan Jovanovic. Do you have that in the

21 binder?

22 A. 69, no.

23 Q. I think that's in presentation binder number 2. This is another

24 one that we have an indication from Defence counsel that appears to be

25 Mr. Krajisnik's signature based on his viewing of the Xerox copy. Can you

Page 10184

1 tell us the date of that appointment?

2 A. The 16th of June, 1992, appointing Dragan Jovanovic as republican

3 commissioner for Ilijas.

4 Q. And he replaces somebody?

5 A. Jovan Tintor.

6 Q. And what has happened to Mr. Tintor according to that document?

7 A. He's been transferred to a new position.

8 Q. Okay. So this was June 16th, 1992, after Mr. Krajisnik was a

9 member of the expanded Presidency?

10 A. Yes.

11 Q. And before the July 10th session where there was discussion about

12 dividing up the duties and making him responsible -- or making him the

13 point of contact for matters relating to commissioners?

14 A. Yes.

15 Q. With regard to signatures, we've seen on other documents sometimes

16 when it is not signed by the person whose typewritten signature appears

17 that the word "za" appears in B/C/S. Can you tell us what that means?

18 A. "Za" means "for," and therefore he is -- in this context it means

19 signing for the type-signed name.

20 Q. These three documents that have Mr. Krajisnik's signature for the

21 appointments, did you see the word "za" on any of them?

22 A. No. That does not appear.

23 Q. Thank you. Now I want to move on to the discussion about a

24 document from Zivinice, if you can understand my pronunciation.

25 Zivinice. That was the SDS and a "Crisis Staff" dealing with the issue of

Page 10185

1 roadblocks. Judge Orie asked you a question about the nature of that

2 Crisis Staff and asked you -- I think the phrase he used was it

3 conceivable that maybe that was a Crisis Staff that had a retarded start

4 or a late start?

5 A. Yes.

6 Q. Now, do you recall telling us about Mr. Karadzic speaking in the

7 March 1992 Assembly session and telling the deputies to go home and form

8 Crisis Staffs?

9 A. Yes. He says "urgently in those where you have not yet formed

10 them," I believe he says.

11 Q. So if there's not a Crisis Staff in Zivinice in February 1992,

12 that's not inconsistent with what Mr. Krajisnik is saying in March of

13 1992?

14 A. No. I take it that statement of Karadzic's to read that in fact

15 not all municipalities had formed a Crisis Staff by that time.

16 Q. Let me move on to another topic dealing with reporting by Crisis

17 Staffs up to the higher levels of authority. Do you recall the discussion

18 pertaining to the Stari Grad municipality? There was a report from them

19 about -- requesting an investigation of somebody in a particular business

20 and appointing somebody else as the acting director.

21 A. Yes. I recall the discussion about that document.

22 Q. I think Mr. Stewart asked you a question about the significance of

23 that report, and this was in May of 1992.

24 A. Yes.

25 Q. According to the instructions from the government in late April of

Page 10186

1 1992 from Branko Djeric about the operation of Crisis Staffs, was there a

2 reporting requirement in those instructions?

3 A. Yes. There was a reporting requirement to the central and

4 regional state organs.

5 Q. And relating to those questions, one of the last things that

6 Mr. Stewart asked you was about the Variant A and B instructions on the

7 one hand and the April 1992 instructions from the government. One of the

8 differences has to do with the timing. Correct?

9 A. They came out at very different times in the development of the

10 Bosnian Serb state.

11 Q. And in terms of take-overs of municipalities, had take-overs

12 occurred before December of 1991?

13 A. No.

14 Q. And after April 24th or 26th of 1992, had take-overs occurred?

15 A. Yes.

16 Q. One of the questions also related to contacts between the accused,

17 Mr. Krajisnik, and local Crisis Staffs or representatives of local Crisis

18 Staffs. Now, I'm not sure if this was in your presentation. You did talk

19 about Kljuc municipality and the diary of Mr. Bajic who kept minutes of

20 the Crisis Staffs. Do you recall mention in that document of a

21 February 5th, 1992, meeting in Doboj?

22 A. Yes, I do recall that.

23 Q. And did that involve a meeting between Mr. Krajisnik,

24 Mr. Karadzic, and representatives of local and regional Crisis Staffs?

25 A. Yes, it did.

Page 10187

1 Q. This is a minor point, but I want to take you to the intercept,

2 the phone conversation between Mr. Krajisnik and Mr. Tintor where -- I

3 think we can do it without the document. You were asked about whether

4 this was just a personal contact or a business contact. This is the one

5 where Mr. Tintor indicated he thought it was his duty to inform

6 Mr. Krajisnik of certain matters.

7 A. Yes.

8 Q. And you mentioned that he -- Mr. Tintor asked for the Speaker when

9 he first got on the line.

10 A. Yes.

11 Q. And there's the obvious point that the call is being made to his

12 office and it would be natural to ask for the Speaker. Do you recall that

13 there was -- in the conversation Mr. Tintor apparently speaking to people

14 at his end of the phone about who he was speaking with?

15 A. Yes, he says the president -- I believe the words "predzjednik."

16 But in terms of presiding, without it right in front of me, I think that's

17 a reading of it.

18 Q. That's fine. I can refer the Judges to that document to see.

19 I want to ask you about a question Judge Hanoteau asked you

20 concerning the reference in the Assembly about the MPs or the deputies

21 transferring authority of the Assembly to the municipalities. I think

22 Judge Hanoteau asked you the question about: Wasn't this a democratic

23 government at the time? I guess that's my question. Is this a democratic

24 government in the terms that you or I might think of of a Western-type

25 democracy?

Page 10188

1 A. No. As I pointed out, these deputies were not elected to this

2 body. They left the body to which they had been elected and formed their

3 own and assigned it authority.

4 Q. And with regard to the authorities in the municipality, and the

5 Crisis Staffs in the local municipalities, in Variant A municipalities,

6 some of those people had been elected to the Municipal Assembly?

7 A. Yes.

8 Q. But in the Variant B municipality, was that the case?

9 A. Fewer would have been -- generally the sharing out of municipal

10 positions was done along the lines of the local election results, so it

11 generally reflected the ethnic makeup, so there would be some SDS people

12 and some municipal positions in Variant B municipality, but fewer -- many

13 fewer than in Variant A.

14 Q. In fact the Crisis Staffs were not the officially elected

15 representatives but was rather a body to deal with the emergency

16 situation?

17 A. Yes.

18 Q. Who had the power to appoint or dismiss members of Crisis Staffs

19 in municipalities? And I'm talking about SDS Crisis Staffs.

20 A. Yes. The appointment is done through the instructions of -- from

21 the Main Board, the 19 December instructions, through Djeric's

22 instructions, naming who is going on to a Crisis Staff. There's no

23 discussion of who has the power to dismiss them.

24 Q. I want to take you to two other points quickly, and then I thing

25 I'll be finished. Ratko Adzic, do you know what his position was before

Page 10189

1 the war?

2 A. No, I don't.

3 Q. I guess we'll wait for some further information from the Defence.

4 Do you know he was elected mayor of the municipality and was not a member

5 of the JNA at that time?

6 A. That jogs with my general understanding that he was as

7 president -- became president of the Crisis Staff because he was president

8 of the municipality. Yes, that's my general understanding.

9 Q. The document that we looked at where he is saying that as a

10 commander that was addressed to the Presidency, making a request for

11 certain --

12 A. Tanks --

13 Q. -- certain military matters, within the VRS and in the JNA, would

14 it be typical for a military commander to address the Presidency directly

15 as opposed to his own commander or the Main Staff of the army?

16 A. It would not be typical. One would expect an address via army

17 channels.

18 Q. And finally with regard to the Variant A and Variant B

19 instructions, Mr. Stewart asked you the question about, did you find it

20 odd that the cover page said Main Board and the typed signature page said

21 SDS Crisis Staff. Do you recall that?

22 A. Yes.

23 Q. And he talked to you about the dearth of evidence of an SDS

24 republic level Crisis Staff?

25 A. Yes.

Page 10190

1 Q. Do you find that odd or consistent with trying to set up a secret

2 government?

3 A. It's entirely consistent with trying to set up a secret

4 government.

5 Q. Thank you.

6 MR. HANNIS: Your Honour, I have no further questions at this

7 time.

8 JUDGE ORIE: Thank you, Mr. Hannis.

9 [Trial Chamber and registrar confer]

10 JUDGE ORIE: Mr. Stewart, am I wrong when I assume that you would

11 have further questions for Ms. Hanson on the basis of re-examination?

12 MR. STEWART: I have no further questions --

13 THE INTERPRETER: Microphone for counsel.

14 MR. STEWART: I'm sorry, I didn't put on my microphone. I have no

15 further questions, Your Honour.


17 [Trial Chamber confers]

18 JUDGE ORIE: I am a bit in doubt what to do at this moment. I

19 would have to go through my notes again to see whether I would have any

20 additional questions. I'm just informed that my fellow Judges would most

21 likely have no further questions. Would it be possible, Ms. Hanson, to

22 remain, stand by, and follow instructions even when it's not certain that

23 we'd have further questions for you. We'd of course, then, immediately

24 let you know if there are any further questions. If, however, there would

25 be any further questions, we would like to see you back tomorrow morning.

Page 10191

1 It will certainly not take much time, because if I have any questions,

2 it's mainly in terms of clarifying issues.

3 Therefore, I would like to instruct you not to speak with anyone

4 about your testimony you have given, neither about the testimony you may

5 be about to give, and to remain on stand-by for tomorrow morning. If

6 we'll not call you back anymore, I would already like to thank you for --

7 well, not having come a far distance, but at least having come and

8 answered many questions of the parties and of the Bench until now. But it

9 might be that there are two or three more.

10 Mr. Hannis, this also means that even if there would be further

11 questions for Ms. Hanson tomorrow, that it certainly will not take long

12 and that you should be prepared to call your next witness.

13 MR. HANNIS: Mr. Tieger will be ready. If you could advise us

14 before the end of the day, then the appropriate one of us will show up at

15 9.00.

16 JUDGE ORIE: Yes. Then we'll adjourn until tomorrow, same

17 courtroom, 9.00. And we might see you back tomorrow morning, Ms. Hanson.

18 --- Whereupon the hearing adjourned at 1.46 p.m.,

19 to be reconvened on Wednesday, the 9th day of

20 March, 2005, at 9.00 a.m.