Tribunal Criminal Tribunal for the Former Yugoslavia

Page 2647

1 Thursday, 1 December 2005

2 [Open session]

3 [The accused entered court]

4 [The witness entered court]

5 --- Upon commencing at 10.21 a.m.

6 JUDGE PARKER: Good morning. I'm sorry there was a little delay

7 with the recording equipment becoming ready.

8 May I remind you of the affirmation you made at the beginning of

9 your evidence, which still applies.

10 Mr. Bulatovic.

11 MR. BULATOVIC: [Interpretation] Good morning, Your Honours. Good

12 morning to everyone in the courtroom.


14 [Witness answered through interpreter]

15 Cross-examined by Mr. Bulatovic:

16 Q. Madam Polovina, good morning. I would like to introduce myself.

17 I am attorney Bulatovic and I am one of the Defence attorneys for

18 Mr. Sljivancanin. All of the warnings or cautions given to you by my

19 colleagues during the questioning regarding the interpretation are valid

20 so that we can do a good job and that it also gets recorded in the

21 transcript. So please pay attention to that.

22 Yesterday you talked about your stay in Vukovar and about your

23 work at Radio Vukovar. Could you please clarify, because I see in the

24 statement that you gave to the representatives of the OTP, that there is a

25 kind of break or interruption in your work. And yesterday you said that

Page 2648

1 you were not permanently employed. So I'm interested, when did you work,

2 if you can tell us the time permanent, and when was it that you were

3 permanently employed?

4 A. The first time I came to the radio was on the 11th of July, 1997

5 [as interpreted]. I don't know how long this period lasted. I was

6 substituting for a colleague, Mirjana Hrpka, who was an anchor there for

7 many years. She had to go on sick leave, so it was necessary to replace

8 her, and I was called by Radio Vukovar and offered this job. I think that

9 this lasted until 1990. After that, my colleague came back from her sick

10 leave and I stopped working at this part-time job. After the auditions

11 were held in June 1991 I returned to work at the radio again. It was not

12 a permanent job but a temporary job. I was offered a permanent position

13 on the 1st of September, 1991.

14 Q. This period, from the end of 1990 until 1991, did you do any work?

15 And if you were employed, what were you doing and where?

16 A. As far as I can remember, I wasn't working other than perhaps

17 giving maths lessons, but I it wasn't actually employed anywhere.

18 Q. Just one intervention on the transcript. Page 2, line 4, it

19 says "July 1997," but I think it should state July 1990, if I'm not

20 mistaken. Is that correct?

21 A. Did I say "1997" or --

22 Q. No, you said it correctly, but this is in the transcript. Well,

23 it's all fine now. This period that I'm asking you about when you were

24 not working, at that time did you go and visit people who were working at

25 Radio Vukovar?

Page 2649

1 A. From time to time, yes.

2 Q. On that occasion or those occasions, did you have any kind of

3 active role in the Radio Vukovar programme in terms of advice or perhaps

4 doing some project or providing suggestions or anything like that?

5 A. No. I helped by -- actually, we're talking about music shows or

6 music programmes. When Sinisa Glavasevic and Branimir Polovina were

7 working, then the listeners would call in. These were music programmes

8 and listeners were able to call in and make requests. And these requests

9 would be granted. The songs would be played. So it was possible to grant

10 listeners' requests because I knew practically where every record or every

11 song was. I know -- I knew the number of each song. There are about

12 16.000 songs. Sinisa would talk with the listener. I would go to the

13 record that the listener had requested. I would take it. Branko would

14 put it on the record-player, and then it would be employed. That was the

15 extent of my help.

16 Q. You've explained that. But now I'm interested in knowing at the

17 time, after having only worked for six months, how could you know where

18 all of these 16.000 records were? How was it possible for you to achieve

19 this? How did you manage to do that? It's a large number of songs.

20 A. Yes, it's a large number of songs but since I was an amateur

21 singer, I was very interested in that topic and I simply remembered --

22 managed to memorise all the songs.

23 Q. Out of 16.000 records you knew exactly which one was where?

24 A. Yes, yes.

25 Q. Well, you said that that was what you were doing when Sinisa

Page 2650

1 Glavasevic and Branko Polovina were doing their shift?

2 A. Yes.

3 Q. Could you please explain to us what Sinisa Glavasevic was doing

4 and what Branko Polovina were doing?

5 A. Sinisa Glavasevic and Branislav Polovina -- actually, Sinisa

6 Glavasevic was an anchor at Radio Vukovar, so he anchored the programmes.

7 Branko or Branimir Polovina was a technician. So they worked together as

8 a team.

9 Q. Sinisa Glavasevic, you said that he was an anchor at Radio

10 Vukovar?

11 A. Yes.

12 Q. All the time until November 11th, 1991, did he work as an anchor?

13 Did he continue to work as an anchor throughout that period in conditions

14 that permitted such work?

15 A. No. He was also a journalist. He was employed as an anchor, but

16 in due time he also became a journalist and then later he became an editor

17 at the radio.

18 Q. You already talked about this, but in order to be more specific do

19 you know the date when he was appointed editor?

20 A. I don't know the exact date.

21 Q. Approximately?

22 A. I think it was probably the -- July or August of 1991. In any

23 case, it was in the second half of the year after the war had already

24 started.

25 Q. After being appointed to this post, did Mr. Glavasevic have live

Page 2651

1 shows on the Radio Vukovar?

2 A. Yes, he did.

3 Q. Did those programmes have any particular name, if you recall?

4 A. I cannot remember the name. They probably did have a name because

5 programming blocks are divided according to their topic or theme, and they

6 each have a name. But I really cannot remember what the names were.

7 Q. Could you please tell me what programming block did his programmes

8 belong to. Was it a political programme, cultural programme, news? What

9 did his programmes cover?

10 A. They covered all kinds of topics.

11 Q. You talked about the programming. Do you know who conceived the

12 programming of Radio Vukovar and Croatian Radio Vukovar in either of the

13 periods of the radio?

14 A. I don't know exactly whether it was one person or a team, but this

15 is the job of the editor-in-chief. This is something that the

16 editor-in-chief would do with the assistance of his colleagues, of course.

17 Q. Could you please tell me what was the ethnic composition of the

18 offices of Croatian Radio Vukovar.

19 A. I think that it was mixed, but I don't know exactly who was of

20 which ethnicity.

21 Q. Since Croatian Radio Vukovar was established, since it was renamed

22 from Radio Vukovar to Croatian Radio Vukovar, do you know how many people

23 worked in the editorial offices or in the offices of Croatian Radio

24 Vukovar since the time you got there in 1991?

25 A. I don't know the exact number. A number of the people were

Page 2652

1 employed. Others worked as associates, but I think the number of these

2 associates was larger than the number of those who were actually

3 permanently employed.

4 Q. You talked about gathering information, that you gathered

5 information during the events that we have discussing here. Can you

6 please explain to me how you gathered information, how did information

7 reach you at Radio Vukovar or Croatian Radio Vukovar? What were your

8 sources of information?

9 A. It depended on the events in town. I couldn't really give you all

10 the different sources, but most frequently we talked with the hospital,

11 with the Main Staff, with the people who were out in the field, out at the

12 checkpoints, and there were various sources. The utilities, water works

13 offices, and so on. We talked with the people at Nama, and so.

14 Q. Very well. What was the manner in which you contacted these

15 people? Did you speak to them directly? Did people go to these points

16 that you mentioned, or was there another way of communicating with all

17 these different people and places?

18 A. There were several ways of communicating.

19 Q. What were they?

20 A. There was indirect -- I'm sorry, there was direct communication,

21 directly talking with these people. Also it was done through telephone

22 calls. Yes. Well, I can't remember any other way. It was either by

23 telephone or we would go to some places directly or people would come with

24 us and we would talk to them.

25 Q. The premises of the Croatian Radio Vukovar were visited by members

Page 2653

1 of the ZNG. What I'm interested in is that during these encounters did

2 you get any information from them and did you provide information to them?

3 Did you exchange information that each of you had?

4 A. Yes, we did exchange information.

5 Q. Could you please tell me what this information was, what kind of

6 information was it?

7 A. I will try to describe -- give you examples.

8 Q. But briefly, please.

9 A. A person, a man, a soldier, would come to us or perhaps we would

10 meet somewhere, but most often they would come to us. And we would learn

11 from that man which checkpoint he was at; what was happening there; which

12 people had survived at that point in time, on that day, of course; who was

13 killed; how far the lines of defence were laid down. And then we would

14 talk to them about what was happening at their locations. They didn't

15 really know what was going on in other parts of town, so we would tell

16 them what happened in the other parts of town and what happened to people.

17 Q. I assume that these were military types of information that they

18 provided or that you talked about?

19 A. Well, I don't know whether that would be military-type of

20 information. These were events in town.

21 Q. But relating to the lines of defence, number of killed, number of

22 casualties, weapons?

23 A. Yes, yes.

24 Q. So we can agree that --

25 A. Well, as far as weapons are concerned, well I don't know --

Page 2654

1 THE INTERPRETER: Could the speakers please not overlap.

2 MR. BULATOVIC: [Interpretation]

3 Q. So we can agree that this information can have the character or

4 could be of a military nature?

5 A. Yes.

6 Q. You say that you had frequent contacts with the hospital. Is that

7 correct?

8 A. Yes. As the radio -- the radio did, but I personally did not have

9 such frequent contacts with the hospital.

10 Q. Did you have anyone specific from Croatian Radio Vukovar who was

11 entrusted with maintaining contacts with hospital representatives, or was

12 this just something that would be on the spur-of-the-moment decision,

13 depending on who was available at the time?

14 A. Approximately until the 15th of October it wasn't strictly

15 allocated who would go to the hospital and when. As of the 15th of

16 October when we moved to the Vucedolska Kapljica basement, we organised

17 ourselves and then it was known who was in which shift and in which team.

18 Four persons would be going to the hospital.

19 Q. You say it was then known who was in which team then. How many

20 teams were there?

21 A. There were three teams.

22 Q. Can you tell me the composition of the teams, each numbers four

23 persons, a total of 12 then?

24 A. We didn't have 12 persons; we had six. Out of those six we

25 composed three teams. My husband and I were in charge of local

Page 2655

1 programming, which was broadcast three times a day for an hour each time.

2 Q. We seem to have misunderstood each other. I wasn't interested in

3 the programming of Radio Vukovar, I was interested in the people entrusted

4 with contacting the hospital or staying in touch with the hospital.

5 A. There were two teams, each composed of two persons.

6 Q. Can you tell me more about these two teams and their composition.

7 A. One was composed of Alenka Mirkovic and Josip Esterajher, the

8 other team comprised Sinisa Glavasevic and Vesna Vukovic. Occasionally

9 they would change teams. Sometimes Sinisa and Josip would go to report on

10 something, but the usual division was Sinisa and Vesna in one team and

11 Josip and Alenka in the other.

12 Q. This type of cooperation -- or rather, this type of communication

13 of Croatian Radio Vukovar with the Vukovar Hospital from the 15th of

14 October stayed in place, as far as I understood it, until the 18th of

15 November when you came to the hospital?

16 A. Yes.

17 Q. And it operated in certain established time intervals or did you

18 play by ear? Did you go on these reporting assignments twice a week?

19 A. Just a minute. I just remembered something. You said that it

20 stayed in place until the 18th of November, and I have to tell you that

21 Alenka and Josip went to attempt the breakthrough through this siege on

22 the 17th.

23 Q. Okay. So that means that it stayed in place until the 17th.

24 A. Now, would you please repeat your question.

25 Q. All right. My question was: Until the 17th of November, 1991,

Page 2656

1 and starting from the 15th of October, 1991, which means a time period of

2 over just more than one month, during that period of time did you have

3 established schedules for these teams to contact the hospital or did you

4 play it by ear?

5 A. We did not have established time. It all depended on the

6 situation.

7 Q. On the 15th of October, 1991, you were in the Vupik shelter?

8 A. Yes.

9 Q. Was there any kind of communication, except for the direct one,

10 between you - and when I say "you," I mean people in the Vupik basement -

11 and the Vukovar Hospital? Did you have telephone line, radio

12 communication, telex?

13 A. As far as I can remember, no, we didn't have anything. We had to

14 go to the hospital in order to obtain information.

15 Q. You said that as Croatian Radio Vukovar you had contacts with the

16 Crisis Staff of the Vukovar defence.

17 A. Yes.

18 Q. Were teams established for those contacts as well or was that done

19 by the same two teams?

20 A. The same two teams did that work.

21 Q. The information you described just a minute ago, was it exchanged

22 in these contacts between you, employees of Croatian Radio Vukovar, the

23 hospital, and the Crisis Staff?

24 A. Yes.

25 Q. Does the name Dr. Matos mean anything you?

Page 2657

1 A. I've heard of him.

2 Q. Did you see him ever?

3 A. Perhaps I did, but without knowing that it was him. I don't know

4 what he looks like.

5 Q. Yesterday you said that in the territory of Vukovar there were

6 Croats from all over Croatia who had come from all over Croatia to assist

7 in the defence of Vukovar. Did I understand you right?

8 A. Yes. People used to come from all over Croatia.

9 Q. You said that you had contacts with them?

10 A. Yes.

11 Q. Did you receive any information from them about, let's say, the

12 sentiments that prompted them and motivated them to come to Vukovar?

13 A. Yes.

14 Q. Do you know, based on these conversations with them, how were they

15 militarily engaged in the units of the so-called Croatian army?

16 A. I didn't determine that they were in any way different from other

17 local Vukovar residents who were included in the defence of Vukovar.

18 Q. Does that mean that they wore uniforms?

19 A. Yes, they did.

20 Q. Did they have some insignia in terms of emblems, badges?

21 A. I'm not sure. Most likely they did, but I couldn't tell you what

22 was written on them, if they had any.

23 Q. Do you know whether those who were outside of Vukovar, who had

24 come from elsewhere, were engaged, in the military sense, in the Vukovar

25 defence in such a way that they were all put into one unit or were they

Page 2658

1 perhaps allocated to various units?

2 A. I don't know. I don't know what their military assignment was. I

3 didn't know the names of the units, how many there were. I had a feeling

4 that all of those who were involved in the defence functioned as one

5 force, in a unified way.

6 Q. Based on your conversations with these people, were you able to

7 learn whether they fought all in one location, let's say Sajmiste, or were

8 there perhaps some of them who were in Luzac, Mitnica, and other places?

9 A. As far as I can remember, for a while they fought in one place, in

10 one location. And later on, depending on the situation and the needs,

11 they were transferred to other locations.

12 Q. You gave evidence about negotiations which were conducted, if I

13 remembered it well, between Mrs. Vesna Bosanac, representing the hospital,

14 and the representatives of the JNA, among whom you've mentioned

15 General Raseta. It remained unclear to me, based on your answers, whether

16 you said that these negotiations were conducted between the 18th and 20th

17 of November, but that there had been some conducted earlier as well.

18 Therefore, I would like you to explain to all of us where these

19 negotiations were conducted and how come you know about any negotiations

20 conducted prior to the 18th of November, 1991.

21 A. In the basement where we were housed, negotiations were conducted;

22 I know this because I saw this and heard this personally. As for the ones

23 conducted between the 18th and the 20th in which Mrs. Bosanac and Marin

24 Vidic, Bili --

25 Q. Mrs. Polovina, I was interested in what preceded the 18th.

Page 2659

1 A. Yes, but you also mentioned the 18th.

2 Q. Let us just hold on for a minute. So prior to the 18th, who

3 negotiated in the basement with whom and about what?

4 A. Dr. Vesna Bosanac negotiated with Raseta, who was her counterpart

5 in that telephone conversation.

6 Q. What were they negotiating about?

7 A. They talked about the evacuation of the population. It was clear

8 at that point that the town would fall soon, it was a matter of hours.

9 Q. Can you please specify in relation to the 17th of September when

10 some of the --

11 THE INTERPRETER: Interpreter's correction, 17th of November.

12 MR. BULATOVIC: [Interpretation]

13 Q. -- when some of the defenders of Vukovar went to break through,

14 including your colleagues. So how long before that date these

15 negotiations were conducted?

16 A. The negotiations between Dr. Bosanac and Raseta were not conducted

17 prior to the 17th as far as I know, because I didn't see and didn't hear

18 anything prior to the 17th.

19 Q. So what you're just describing to us perhaps happened on the 17th?

20 A. At the earliest on the 17th.

21 Q. In addition to Vesna Bosanac, was there anybody else with her

22 present while she talked on the phone and negotiated?

23 A. Marin Vidic, Bili, was present, and as far as I can remember,

24 Dr. Njavro was there as well. But I'm not sure I can remember their

25 conversations with their counterparts in Zagreb. I seem to remember only

Page 2660

1 the voice of Dr. Vesna Bosanac.

2 Q. Were any of the defenders of Vukovar present on that occasion?

3 A. Possibly, yes, but I can't be certain. There were a number of us

4 in the basement.

5 Q. Will you please explain to me the following. You've already

6 touched upon this, but I'm interested in learning more details. How

7 Croatian Radio Vukovar operated from the moment you moved into the Vupik

8 basement until you went to the hospital. Were there any changes in your

9 programming? Did you have any live programmes? Who was the one who went

10 on air?

11 A. From the 15th of October onwards, so throughout the time we stayed

12 in the basement, we had no live contacts because there were no telephone

13 lines, so it was impossible to have them. Our programme was broadcasted

14 three hours a day, three times, one hour, at 8.00, 2.00 p.m., and 8.00

15 p.m. Most of that programming was done by me and occasionally some of my

16 colleagues participated as well.

17 Q. Throughout that period of time from the 15th of October until the

18 18th of November when you arrived in the hospital or, let's say, the 17th

19 of November, did you all stay together there? I mean the teams that you

20 have mentioned, the employees.

21 A. Yes. All of us were there together.

22 Q. Did you ever, from the 17th on, 17th of November, 1991 -- or

23 rather, after the negotiations held by Dr. Vesna Bosanac, on which

24 occasion Dr. Jure Njavro also was present and perhaps some of the

25 defenders as well, did Dr. Vesna Bosanac ever participate in any

Page 2661

1 broadcasts, ever made any announcements live?

2 A. I'm not sure. That's possible. On the 17th we stopped airing,

3 and Sinisa Glavasevic on that day sent -- or rather, broadcast his last

4 reports. I'm not sure what these reports were about. Perhaps they

5 concerned these negotiations.

6 Q. The reports that were sent, in order to compile these reports did

7 you use the information obtained in your contacts with the defence staff,

8 hospital, members of the so-called Croatian army, and was this information

9 used in the reports compiled by you?

10 A. Partially, yes.

11 Q. In which part?

12 A. In the part which concerned the number of the wounded, dead, the

13 situation at the hospital, how was the defence of the town holding up,

14 which parts of the town had been occupied. Towards the end of November,

15 the town had been cut in half, that is to say there was no communication

16 between the part of the town where the downtown area was and the part near

17 Mitnica. Sajmiste had fallen long time before that. Also, the road

18 between Borovo Naselje and Vukovar had been cut off. All of this was

19 taking place in the course of November, and this is what we informed the

20 population about.

21 Q. This information that was including -- included into your reports,

22 was it censored in any way?

23 A. By whom?

24 Q. Well, that's what I'm asking you.

25 A. It wasn't censored internally, but it was censored by Croatian

Page 2662

1 radio.

2 Q. The population of Vukovar, the citizens of Vukovar, covered by

3 your -- the range of the station, did they receive all of the information

4 that you broadcast?

5 A. Yes, they did.

6 Q. Did you check in any way this information, or did you just take it

7 for granted that the information given was accurate? Or did you have any

8 reason to doubt the voracity of the information you were receiving from

9 the hospital from the defence Crisis Staff, that you received from the

10 representatives of the defenders of the town?

11 A. We had no doubt about the voracity of the information. The

12 hospital kept daily records of people who were wounded and killed; that

13 can be checked. As far as the number of shells, of course that was not

14 possible to count quite accurately, so we would always give an estimate.

15 This part that we got from the defenders at the checkpoints was something

16 that we could not check. We couldn't go there; it was too dangerous.

17 Before the war it was possible, but after it got very dangerous we

18 couldn't go. We knew some of the things that they had gone through or

19 complete events that had happened to them, and this is something that we

20 would broadcast as we received it.

21 Q. You said that records were lists were kept by the hospital about

22 all this information. Did you see those lists?

23 A. I did see some lists at the very beginning of the war, but after

24 that, no, because I didn't go to the hospital very often.

25 Q. Can you describe those lists that you saw at the beginning of the

Page 2663

1 war. Were they recorded in a notebook, a pad, on papers?

2 A. I can't remember exactly, but I think that this information or the

3 names of the people were either sent to us by fax, the names of the killed

4 and the wounded, or when we went to the hospital we would be informed

5 about this, we would be shown a document.

6 Q. Since you're not sure about this part, you say that that perhaps

7 arrived by fax.

8 A. I cannot remember exactly.

9 Q. How -- for how long was it possible to maintain a fax connection

10 between the hospital and the Croatian radio?

11 A. In August it was functioning. Perhaps up until a certain date in

12 September it functioned. I don't know exactly.

13 Q. Can you explain to me the programming of Croatian Radio Vukovar in

14 the general scheme. These reports, what was their position, what was

15 their role? Was it to inform the citizens? Did it have a propaganda

16 character in order to raise morale of one side in the conflict? Or was it

17 to satisfy someone's interests? Or was it a little bit of each?

18 A. This part relating to the programming -- actually, as the war

19 continued, it sort of disappeared. There was no programming scheme. The

20 most important thing became to inform the people in the town what was

21 going on. This was the most important thing, followed by the need to

22 inform the rest of Croatia and the world.

23 Q. So the goal was objective informing of the citizens of Vukovar and

24 Croatia, of course.

25 A. The most important thing to us was to preserve human lives and

Page 2664

1 also to raise the morale of people who were stuck in cellars.

2 Q. Yesterday you talked about this, but the explanation still is

3 unclear to me, if that is the way it is, to raise the morale of the

4 defenders. You are also objectively reporting on the events of your town,

5 Vukovar. So according to you what would be the reason of the leadership

6 of Croatia to censor your reports or not to broadcast them as they were to

7 the entire Croatian people?

8 MR. MOORE: I object to that question; it's entirely speculative.

9 JUDGE PARKER: Mr. Bulatovic.

10 MR. BULATOVIC: [Interpretation] Your Honours, I would disagree

11 with the Prosecutor, but I will try to avoid further discussion on this

12 and I will try to ask the witness about this in a different way, with your

13 permission.

14 JUDGE PARKER: Please go ahead.

15 MR. BULATOVIC: [Interpretation]

16 Q. Madam Polovina, do you know what the reason was, did you talk

17 about it amongst yourselves, for the -- these reports being censored,

18 these reports of yours being censored?

19 A. We did ask ourselves why our reports were being censored, but this

20 is something that only the person who decided to censor the reports is

21 able to know.

22 Q. After your conversations about this, did you try, did anyone,

23 maybe the editor-in-chief, Mr. Glavasevic, try to find out from the people

24 from Croatian radio what the reason was for censoring these reports?

25 A. Yes, he did.

Page 2665

1 Q. Do you know if he received a response? And if he did receive one,

2 what was it and who did he get it from?

3 A. As far as I can remember, he didn't receive a response because

4 whenever he wanted to talk to someone in charge, they were not available.

5 I cannot remember whether he ever actually managed to talk about it.

6 Q. I would now like to move on to the 17th when you were at the Vupik

7 shelter. You mentioned the arrival of some people from the PTT, the post

8 office. When was this exactly? I would like to know.

9 A. I cannot remember. Maybe it was night-time. I cannot remember

10 what part of the day it was.

11 Q. Do you remember what day it was?

12 A. No.

13 Q. Was it a day or two before you went to the hospital? Was it on

14 the same day, the 17th?

15 A. No -- well, I think it was the 17th, but I am not absolutely sure

16 whether it was the 17th or whether it was on the night of the 17th and the

17 18th. These -- this visit by the guys from the PTT is connected to the

18 departure of the Main Staff from the cellar, so I cannot remember they

19 came before the commander left or if they came afterwards. But I think

20 that it was probably after that. It was the night between the 17th and

21 the 18th.

22 Q. Well, could you please tell us who these people from the PTT were.

23 What were their names?

24 A. I'm not sure. Yesterday your colleague mentioned a name, I think

25 it was Zugec. I think he could have been there, but I'm not 100 per cent

Page 2666

1 certain. I think he worked at the post office.

2 Q. Do you know what they were doing, what their jobs were in the post

3 office?

4 A. No. No, I don't know exactly.

5 Q. I forgot something. I hope you don't mind if I go back to

6 something that we already talked about relating to the work at Croatian

7 Radio Vukovar. The announcements, reports, or any kind of information, to

8 draft these did you engage any kind of outside assistance? Did you hire

9 people from outside in order to draft these or send messages or anything

10 like that?

11 A. As far as I know, I don't think so, no. We did it all ourselves.

12 Q. Have you ever heard of Professor Louc [phoen] From Osijek?

13 A. I cannot remember.

14 Q. What about Professor Medved from Osijek?

15 A. I heard the Medved last name a few days ago, but I don't know

16 whether it was the Professor Medved or what context I heard the name. I

17 heard the name a few days ago, but I don't know in what context, and it's

18 not something that I can tie to 1991.

19 Q. Another thing about the programming. Do you know that Croatian

20 Radio Vukovar, as part of its broadcasting or programming policy from

21 September to November 1991, also featured some kind of educational

22 programme?

23 A. Yes, I am aware of that.

24 Q. Do you know who worked on that programme, who anchored the

25 programme or actively participated in it?

Page 2667

1 A. Yes, I do. It was the wife of Dr. Njavro. Her name is Lidija, I

2 think her name is Lidija Njavro, and also the sister of my colleague,

3 Vesna Vukovic. Her name was Melita [phoen]. At the time her last name

4 was Budimir.

5 Q. You mentioned Vesna Vukovic several times. Is that her maiden

6 name or her married name?

7 A. That is her maiden name.

8 Q. And what is her married last name, if she got married? I think

9 you were her maid of honour, if I understood it properly.

10 A. No, you misunderstood. My best man was Sinisa Glavasevic. Vesna

11 married in January 1992, and her last name is Oreskovic.

12 Q. Was her husband Tomislav Oreskovic?

13 A. Yes, that is correct. His name is Tomislav Oreskovic.

14 Q. Can you tell us -- I have information that you two are very close,

15 so can you explain to the Trial Chamber who Tomislav Oreskovic is and was

16 he in Vukovar at the time?

17 A. Tomislav Oreskovic is Vesna Oreskovic's husband. Her maiden name

18 was Vukovic. He was one of the defenders of Vukovar in 1991.

19 Q. Was he only a defender or did he have some kind of command role in

20 the so-called Croatian army?

21 A. We are very close, but we really never talked about work all that

22 much. Once he came to Zagreb, and after a considerable time period of

23 treatment he did work in the Croatian army. I think that he did have some

24 kind of rank, but I'm not sure exactly what it's called.

25 Q. Let's move now to the 17th in terms of the agreement to leave

Page 2668

1 Vukovar or breaking out of Vukovar, in the sense that you explained it to

2 us yesterday. You were at Vupik shelter and, as far as I understood,

3 Mr. Glavasevic had gone to the Crisis Staff to see about the terms. Is

4 that correct?

5 A. Terms about what?

6 Q. The terms under which it would be possible to break out, break

7 through.

8 A. Yes.

9 Q. And what did he say when he returned? That he talked with someone

10 from the Crisis Staff, that the Crisis Staff had gone? What did he say?

11 A. Yes, he said that he talked with someone from the Main Staff.

12 They had decided to leave town using some routes. At the time it was not

13 really possible -- well, these were routes leading through cornfields

14 because other routes were dangerous. Sinisa came back, said the command

15 was leaving town. Excuse me. That we could go with them, if we wanted

16 to. And that's when we talked about it. We talked about whether we would

17 go or not.

18 Q. You already talked about that, but we won't take up too much time.

19 You said that you had decided to stay, where you were. And then on the

20 18th you went to the hospital?

21 A. Yes.

22 Q. Well, let's just specify: When did you come to the hospital on

23 the 18th? Was it in the morning, the afternoon, the evening? You did

24 talk about it, but please excuse me for going over it again.

25 A. No, actually I didn't talk about that yet. I really cannot

Page 2669

1 remember which part of the day it was. I know it was the 18th, but I

2 don't remember what time, what part of the day it was.

3 Q. You said that some civilians came to the Vupik shelter, about a

4 hundred of them, from the fairgrounds, from Sajmiste. Who took you to the

5 hospital? Did anyone take you to the hospital or did you go there

6 yourselves?

7 A. I think that we went by ourselves. There was no need for anyone

8 to take us there.

9 Q. Before arriving to the hospital, was Marin Vidic with you at the

10 Vupik shelter?

11 A. Marin Vidic, Bili, did not live at our shelter.

12 Q. I said that -- I didn't say that he lived at the shelter, but I

13 said shortly before you went to the hospital did he come to the Vupik

14 shelter and then go with you to the hospital?

15 A. I cannot remember. I don't think that he did, but I'm not 100 per

16 cent certain.

17 Q. Can you please tell me whether these civilians went to the

18 hospital with you or did they stay at the shelter.

19 A. The civilians remained at the shelter.

20 Q. Do you know the reason for that? You already had the information

21 that Vukovar was, so to speak, lost, that it would surrender. You,

22 yourself, went to the hospital. Did you say anything to these civilians?

23 Did they inquire about anything?

24 A. No, we didn't say anything to them. We decided to leave the

25 shelter and go to the hospital. The people who remained at the shelter,

Page 2670

1 as far as I know, knew nothing about that.

2 Q. You said that you didn't know what time of the day it was on the

3 18th when you came to the hospital. As you were walking from the shelter

4 to the hospital, did you see anybody else moving towards the hospital?

5 A. I can't remember.

6 Q. Yesterday when answering the questions of my colleague,

7 Mrs. Tapuskovic, you were shown a map of Vukovar. You put some markings

8 on the map. I'm not going now to trouble either you or the Chamber with

9 the map again, but I will ask you something else. Can you please give us

10 an estimate of the distance between the shelter in which you were, that is

11 to say Vupik shelter, and the hospital. How many metres? Just give us a

12 rough estimate. After all, you studied mathematics and physics, so you

13 must be familiar with measuring?

14 A. Perhaps 500 metres.

15 Q. 500 metres. And what was the distance between your shelter and

16 the shelter where the Crisis Staff had its headquarters?

17 A. Less than that. Perhaps 100 to 200 metres.

18 Q. If I understood well what you showed and marked on the map, the

19 shelter of the Crisis Staff is closer to the hospital than the shelter in

20 which you were?

21 A. As far as I remember, yes.

22 Q. All right. Can you tell me how far is the Crisis Staff shelter

23 from the hospital?

24 A. 300 to 400 metres. These are just estimates. Not a kilometre,

25 not that far.

Page 2671

1 Q. Yes, yes. I understand that this is just an estimate. What about

2 the MUP building? Where was it in relation to your shelter?

3 A. I can't even remember where they were located.

4 Q. Do you know where the court building is?

5 A. I know where it is now because I went there just a few days ago,

6 but as for 1991 I don't remember.

7 Q. Do you know where the Vukovar high school building is?

8 A. I do.

9 Q. Is that the high school that you completed in Vukovar?

10 A. Do you mean in that location or in something else? At the time

11 when I attended secondary school, there was no such secondary school. I

12 attended a different type of a secondary school, not a classical gymnasium

13 that you are referring to. My secondary school was near the market, on

14 the other side of the hospital.

15 Q. All right. Well, let us try to put it in these terms. In 1991,

16 was there a classical high school called "gymnasium"?

17 A. In 1991, I don't know. I attended secondary school between 1981

18 and 1984. What kind of schools there existed in 1991, I don't know.

19 Q. All right. Let us not waste time.

20 A. We have a building in Vukovar that we refer to as the building of

21 the classical gymnasium. Now, whether this is the same building that you

22 are interested in --

23 Q. Yes, that's precisely the building that I'm interested in. Can

24 you please tell me where it is located in relation to the hospital.

25 A. If you leave the hospital and head towards the centre of the town

Page 2672

1 and then head towards Mitnica, on the left side there is the building of

2 the classical gymnasium. This is a hilly area near the Danube. The

3 building of the high school is several kilometres away.

4 Q. All right. I will tell you later why I ask this. And if you know

5 the answer, fine; if you don't, just tell us so. You said in your

6 contacts with the hospital representatives you had lists which you

7 received, either via fax or were given them directly when in the hospital.

8 Please tell us, did you have information as to whether members of the

9 National Guards Corps were treated at the hospital as patients who had

10 been wounded or perhaps members of the Croatian defence forces or any

11 other formation?

12 I have to make a comment concerning the transcript. I also added

13 at the end of my question that I was interested in any foreign nationals

14 that might have been treated at the hospital. This should be on page 26,

15 17 to 18.

16 A. It's a little bit difficult for me to answer this question because

17 I hadn't seen anybody's passport in order to be able to tell you whether

18 they were foreign nationals or not. But yes, there were some people who

19 spoke a mixture of Croatian and English.

20 Q. Do you know how many such people there were there, one or more?

21 Did you see anything yourself?

22 A. No, I didn't.

23 Q. And how do you know this?

24 A. I know only of one such person. Now, whether there were more than

25 one, I don't know.

Page 2673

1 Q. Will you please describe to me your arrival at the hospital on the

2 18th. You said that you were put in a room with some doctors; what

3 doctors?

4 A. I met those people for the first time on that occasion, when I

5 arrived in the hospital. One was called Dr. Vlahovic; I think his first

6 name is Tomislav. The other one is called Dr. Kratofil, from Osijek. The

7 third person was Ante Aric. I don't think he is a physician. I think he

8 was a medical technician. I think he just completed the medical secondary

9 school. We were in a rather small room which had only mattresses and a

10 small cupboard.

11 Q. On the 18th, when you arrived, did you perhaps tour the hospital

12 that evening? Did you go and see any people? After all, you must have

13 known a lot of people. Did you contact any of them, exchange any

14 information with them there?

15 A. I don't remember. I remember touring the hospital, but I don't

16 know whether it was on the 18th or the 19th. I mostly stayed in that

17 room; however, I do remember touring the hospital because I went to see

18 Vesna's then-boyfriend who had been wounded. And on my way to see him, I

19 also visited some other people.

20 Q. All right. Vesna's boyfriend, Tomislav, was wounded. Do you

21 remember where? I don't mean which part of his body; I mean location.

22 A. Yes, in Borovo Naselje. I think that he fought near Trpinjska

23 Cesta.

24 Q. Did you talk to Vesna Bosanac on the 18th when you arrived in the

25 evening? Did you inquire whether there were any news concerning

Page 2674

1 negotiations or any other news?

2 A. I don't remember talking to her.

3 Q. Did you see Dr. Jure Njavro?

4 A. I probably did, but I can't remember all of the persons that I saw

5 during those days.

6 Q. Do you remember seeing Mr. Marin Vidic, Bili, at the hospital?

7 A. I can't be fully certain that I saw him.

8 Q. Tell me, please, this room in which you were with these two

9 doctors, where is it, in which part of the hospital?

10 A. It was definitely on the ground floor, not far from the back

11 entrance. Just a corridor or two corridors away, from the back entrance

12 to the room.

13 Q. Now, when you say "the back entrance," you have to explain to us

14 how many entrances in the hospital there are. Do you know?

15 A. I'm not sure. I know about the main entrance because this is

16 where I entered when I went to visit some of my friends who had stayed in

17 the hospital before the war. So I know about the main entrance, the front

18 entrance, and I learned about the back entrance during those last few

19 days.

20 Q. The back entrance, is it something that is not regularly used and

21 is only perhaps used in exceptional circumstances?

22 A. During peacetime -- I'm not sure. I'm not sure whether people

23 used it or not. I remember always going through the main entrance when I

24 went to the hospital before the war, but I really don't know.

25 Q. All right. Now, in relation to the main entrance, where is the

Page 2675

1 back entrance? Is it on the opposite side of the building, on another

2 side of the building? Is it on the front facade? Where is it?

3 A. The back entrance is not on the same side of the building as the

4 main entrance. The building is between two parallel streets,

5 perpendicular to two parallel streets.

6 Q. All right. And this back entrance, what street does it face?

7 A. It doesn't face any street.

8 Q. All right. The 19th, you spent the night at the hospital. Did

9 anything particular happen at the hospital on the 18th? Was it an

10 eventful day?

11 A. I didn't see anything; however, I heard that people wearing

12 uniforms - I'm not sure what uniforms - had entered the hospital. I'm not

13 sure whether it was on the 18th or the 19th. This is nothing remarkable,

14 but if you are asking me to remember what happened during those days, I

15 can tell you that I remember lying in the room the whole time and going

16 out maybe once or twice to see Vesna's husband. I heard that people in

17 uniforms started entering hospital.

18 Q. When you went to visit Vesna's hospital, Tomislav Oreskovic, were

19 there any other familiar faces there who also came to visit him?

20 A. I can't remember. Most likely yes, but I don't remember. I only

21 remember Tomislav.

22 Q. Does the name Filip Karaula ring a bell?

23 A. Yes, I've heard of him.

24 Q. Tell me, please, what did you hear and how is he known to you?

25 A. I heard that he had fought at Mitnica. I think that he was either

Page 2676

1 one of the commanders or the commander, defence commander, at Mitnica.

2 I'm not sure.

3 Q. On the 18th of November, 1991, you were at the hospital. Did you

4 have any information whatsoever while at the hospital, did you receive any

5 information from people you had contacts with, or did you receive this

6 information from any other source about what had happened to Filip Karaula

7 and the people at Mitnica? Did anything happen to them; and if so, what?

8 I'm trying not to put a leading question.

9 A. I can't remember. I know that in those last few days Mitnica had

10 been cut off. There was no communication with them. I can't remember

11 hearing anything. Later on, I saw it in the media, but back then, during

12 those last days, no, I don't know.

13 Q. So no information reached you about the Mitnica Battalion

14 surrendering on the 18th of November to the members of the JNA?

15 A. No, I don't remember. Possibly yes, but I can't be fully certain.

16 I can't tell you, yes, such-and-such person told me this.

17 Q. I wasn't expecting you to tell me precisely who provided this

18 information to you. I was just interested in learning whether you had

19 heard of this back then.

20 A. I don't remember whether I heard it on that day or later, upon

21 leaving Vukovar, because, you know, these things are not quite clear in my

22 mind anymore.

23 Q. All right. You went to the hospital. What was the reason for

24 your going there? Was it because you had heard that there would be

25 negotiations about the evacuation of the hospital and people within it?

Page 2677

1 Or was it that you had heard information that the population of Vukovar

2 would be evacuated? So these are two different things.

3 A. Neither of the two reasons. If I had to choose, then it would be

4 the evacuation of the population.

5 Q. If it is the evacuation of the population, then did you hear that

6 the population would be evacuated from the hospital?

7 A. I don't remember. I don't remember.

8 Q. The ethnic structure of the people who were in these shelters, for

9 example, the shelter in Vupik where you were, what was the ethnic

10 structure there?

11 A. I don't know, but I think that it was mixed. Mostly it was people

12 of the -- of Croat ethnicity, but there were some others.

13 Q. Which others?

14 A. All those who lived in the area of the Vukovar municipality. It

15 was a multi-ethnic community, so I don't really know exactly. I think

16 there were Ukrainians, Ruthenians.

17 Q. Can you please answer whether there were any Serbs among these

18 people.

19 A. It's possible, but I don't know whether there were any or not.

20 Q. Exactly. It's not possible to distinguish.

21 A. Well, I do not -- I cannot distinguish a man or a person when I

22 see them according to their nationality. I don't know what nationality

23 they are.

24 Q. Was anything happening on the 19th in the morning at the Vukovar

25 Hospital which made an impression on you? Something that has stuck in

Page 2678

1 your mind, something that you remember happened on the 19th?

2 A. I remembered one soldier. I mentioned him yesterday, but I don't

3 know whether this was on the 19th in the morning or what part of the day.

4 But I think that it was on the 19th. This soldier with the Krajina

5 militia insignia, but I cannot remember anything else other than hearing

6 that some people were being taken away from the hospital.

7 Q. Where was this? Was it in the morning? At Noon? Afternoon? Can

8 you remember?

9 A. No, I cannot remember.

10 Q. Does the name Zeljko or Zeljka Zgonjanin mean anything to you?

11 A. Yes.

12 Q. It's Zeljka?

13 A. Yes, Zeljka Zgonjanin, a woman.

14 Q. Who was Zeljka Zgonjanin?

15 A. Zeljka Zgonjanin I think is from the Red Cross. I cannot exactly

16 say what she was, president, secretary. Perhaps she didn't have any

17 particular title, but I think that she was doing something in the Red

18 Cross.

19 Q. Did you see Zeljka Zgonjanin at the Vukovar Hospital on the 19th

20 of November, 1991?

21 A. It's possible that I did. I remember being with her during those

22 last days when I was still in Vukovar, but I don't know whether this was

23 on the 19th.

24 Q. Do you remember, when you saw her, what was she doing in the

25 hospital?

Page 2679

1 A. I cannot remember.

2 MR. BULATOVIC: [Interpretation] Your Honours, is it perhaps time

3 for a break?

4 JUDGE PARKER: We will resume at quarter past, and of course then

5 finish at quarter to 1.00. Could I mention while we're -- quarter to

6 2.00. Could I mention that while we're dealing with this, on Monday,

7 next, we will be sitting at 2.15, but there is a special plenary of Judges

8 at 4.00, so that we will have only the one session from 2.15 until 3.45,

9 if that affects your planning.

10 --- Recess taken at 11.45 a.m.

11 --- On resuming at 12.18 p.m.

12 JUDGE PARKER: Mr. Bulatovic.

13 MR. BULATOVIC: [Interpretation] Thank you, Your Honour.

14 Q. Madam Polovina, we'll continue where we left off. The 19th of

15 November, 1991, you were at the hospital in a room where I think you said

16 there were two [as interpreted] doctors, Mr. Vlahovic, Mr. Kratofil, Ante

17 Aric, and you don't know who the third doctor who was there. Who was

18 there with you from Croatian Radio Vukovar?

19 A. Branimir Polovina was there, Sinisa Glavasevic, and Vesna Vukovic.

20 Q. Did any of the persons who were mentioned, other than the doctors,

21 Vlahovic, Kratofil, and this third doctor whose name you don't know, leave

22 the room and the 20th, in the morning?

23 A. What does "until 20th, in the morning" mean?

24 Q. From the point you came until that morning.

25 A. Very well.

Page 2680

1 Q. Who?

2 A. All four of us would leave the room.

3 Q. How much time did you spend outside of the room?

4 A. Myself, personally, very little.

5 Q. What about the others?

6 A. They did go out of the room on several occasions, but I really

7 couldn't say. We're talking about hours, so perhaps a few hours on that

8 one day, the 19th.

9 Q. The 19th, in the evening, on the eve of the 20th, were you all

10 together in that room?

11 A. Yes, we were.

12 Q. Did you talk about where they were for that -- for those couple of

13 hours on the 19th, what they did, whether they saw anything or heard

14 anything?

15 A. Yes, we did talk about that.

16 Q. Did they tell you anything interesting about the events on the

17 19th?

18 A. They went to see the wounded who were lying in the hospital. They

19 stopped to see some of their friends, acquaintances, talked with them. I

20 found out from them that negotiations were underway or that the

21 negotiations went on that day, and then in the evening I found out what

22 time we had to leave the hospital the next day.

23 Q. On the 19th you also left the room and went around the hospital.

24 Did you notice the presence of a large number of civilians at the

25 hospital?

Page 2681

1 A. Yes. All of them practically were civilians.

2 Q. Can you tell us the approximate number of civilians who were

3 staying at the hospital on the 19th?

4 A. I cannot because I didn't go to see all of these civilians. No, I

5 cannot tell you. I went to the place where Tomislav was lying, but I

6 didn't really go into all of the corridors and the shelters.

7 Q. Which parts of the hospital did you go to see, if for no other

8 reason then out of journalistic curiosity?

9 A. I really cannot remember. All of this was -- when I say "parts,"

10 I mean the areas, the corridors, the rooms. It was all in the -- in the

11 basement.

12 Q. Well, let me put it this way: Earlier you would enter the

13 hospital by the main entrance? Earlier.

14 A. Before the war, yes.

15 Q. Before the war. And then from the main entrance you enter some

16 sort of, perhaps hall, and then the corridors, the entry part of the

17 building?

18 A. I think that there is some kind of a staircase when you enter by

19 this main entrance.

20 Q. So in these corridors, we're talking about the 19th, in this main

21 entrance area, were there civilians in these corridors?

22 A. I wasn't in that part of the hospital on the 19th.

23 Q. All right. Very well. Do you know whether, other than this

24 entrance and exit which you came in by or went out by on the 18th, are

25 there any other exits or entrances in the immediate vicinity?

Page 2682

1 A. I think that there are, but I cannot be 100 per cent certain.

2 There was no official exit or entrance; that was evident.

3 Q. In relation to the street, does this entrance that you're talking

4 about look out on some street?

5 A. Which street do you mean?

6 Q. The same entrance that you entered on the 18th and that you exited

7 on on the 20th.

8 A. Is it facing any street? I don't know -- no, no.

9 Q. Did you have any information in relation to the 19th of November

10 that members of the Yugoslav People's Army entered the hospital, together

11 with representatives of the International Red Cross, on the 19th of

12 November 1991?

13 A. No, I don't think so. I can't remember.

14 Q. On the 19th of November, 1991, did you notice journalists, your

15 colleagues, from foreign television stations taping or filming inside the

16 hospital, in the area where there were wounded persons, civilians, the

17 staff?

18 A. No. No, I didn't notice that.

19 Q. Did you notice that there were members of the media talking in the

20 hospital with any of the hospital staff on the 19th of November, 1991?

21 A. No, I didn't notice that.

22 Q. From your colleagues and the people who were with you in that room

23 and who left the room to see their friends, the wounded, civilians, did

24 you find out that what I just told you was actually happening at the

25 hospital, that the army had arrived and representatives of international

Page 2683

1 organisations, foreign camera crews?

2 A. I heard from my colleagues that enemy soldiers had entered.

3 Q. That's all?

4 A. Yes.

5 Q. Did you have information in -- did you obtain information in any

6 other way that on the 19th of November, 1991, a humanitarian convoy had

7 arrived at the Vukovar Hospital under the auspices of the International

8 Red Cross?

9 A. No.

10 Q. Do you have information or did you have information on the 19th of

11 November that on that day, under the auspices of the Red Cross, whose

12 secretary was the woman that we mentioned, Zeljka Zgonjanin, civilians

13 were evacuated from the Vukovar Hospital?

14 A. Not on the 19th of November, no.

15 Q. Did you have this information or not?

16 A. No, I did not have this information then.

17 Q. So the 19th, in the evening, bedtime, let's say, was it, again,

18 the same people who were in that room, Ante Aric, Kratofil, Vlahovic, and

19 this fourth doctor, and the Vukovar Radio staff?

20 A. The people from the radio were there, but I'm not sure about the

21 other four. All four of them were with us -- I'm not sure if all four of

22 them were with us.

23 Q. Now, regarding Mr. Glavasevic and the 18th, in your statement you

24 said that Sinisa sent in his broadcast on the 18th of November in the

25 evening to Zagreb. What kind of a programme was it? Was it an

Page 2684

1 audio-recording or what?

2 A. It wasn't a programme. I think it's a question of interpretation.

3 It was a report, a telephone report.

4 Q. All right. So it was a telephone report.

5 A. Yes.

6 Q. Well, we're talking about the B/C/S version. It's possible that

7 the translation is bad, but now it's clear. Could you please tell us, if

8 you remember, who gave you the information on the 19th in the evening at

9 what time you should be ready on the 20th, and why did you need -- would

10 you need to be ready?

11 A. I think -- I'm not sure whether Sinisa or Branko told me, but they

12 had the information. But I didn't only hear it from them. I heard it

13 from some other people who were present, some of the doctors, because some

14 people would enter the room. We went out into the corridor in front of

15 the room, so I don't know exactly who it was that told me that.

16 Q. And what did they tell you to be ready for?

17 A. They told me that the next morning we would be leaving, that the

18 citizens would be evacuated.

19 Q. Did they answer -- or did they explain why this evacuation was

20 being conducted? Was it based on some kind of agreement, accord? Was it

21 just spontaneous? Was it organised? Who was organising it?

22 A. They told me that negotiations were conducted and that this was

23 agreed on, that it would be an organised evacuation. That's how I

24 understood it.

25 Q. Now we're gradually moving to the 19th --

Page 2685

1 THE INTERPRETER: Interpreter's correction, we're moving to the

2 20th.

3 MR. BULATOVIC: [Interpretation]

4 Q. And I'm actually very interested in the 20th, it's what interests

5 me the most. On the 19th, in the evening, did anything happen at the

6 hospital that would indicate the existence of any problems? Was there

7 rushing around, a kind of chaotic situation, anything like that? Or was

8 everything normal, as far as it could be normal in those conditions for

9 the preparation of such an operation like that, that was supposed to begin

10 the next day?

11 A. I wouldn't call it normal. All of us were afraid about what was

12 going to happen because we heard that some people had been taken away from

13 the hospital.

14 Q. The 20th, in the morning, you say that you woke up at 7.00?

15 A. At around 7.00.

16 Q. 7.00. Mr. Glavasevic left. Do you know who remained with you in

17 the room? Were the doctors there?

18 A. I remember that Ante Aric was there. As for the others, I don't

19 know. I know for a fact that Branimir Polovina and Vesna Vukovic were

20 there.

21 Q. You mentioned Ante Aric several of times. Can you tell me, how

22 was he dressed, do you remember, on the 20th?

23 A. I can't remember. I think he had a white coat and pants, but I

24 don't know for sure.

25 Q. In terms of his white coat, did he have a white suit or -- you

Page 2686

1 don't know. All right.

2 You say that you left the room at around 8.00 and then you went

3 out through the back entrance, as you had been told. This is what your

4 statement says, the statement given to the OTP. I'm interested in

5 learning who told you that, to go out through the back entrance, and where

6 were you told this?

7 A. We lay in that room, the room where we were upon arriving in the

8 hospital. I can't remember whether we opened the door, whether there was

9 any door, but at any rate very close to our room -- I don't know whether I

10 was still lying in the room or that was in the corridor. The room was

11 just crowded with mattresses. It wasn't a very comfortable room, and

12 there were no other chairs. We could just lie on mattresses. And then

13 one soldier came and said, "You have to leave." I had an impression that

14 he was tasked with checking whether there were any people left in the

15 rooms, and this is how he came to our room and told us we had to leave.

16 Q. You said "a soldier"?

17 A. Yes.

18 Q. Whose soldier?

19 A. The JNA soldier.

20 Q. I'm sure that you're no expert for military issues. I'm just

21 interested in learning whether that was an ordinary soldier or somebody

22 who held a rank.

23 A. I wouldn't say that he held a rank. I think he was just a

24 rank-and-file soldier.

25 Q. Did you see next to this rank-and-file soldier any other troops in

Page 2687

1 the corridor in front of the room where you stayed? Were there any other

2 troops there?

3 A. I can't remember.

4 Q. And then you left. Once you left and went outside, were there

5 already people standing there in front of the hospital?

6 A. Yes.

7 Q. After your departure, did other people come out of the hospital or

8 were you the last ones to leave it?

9 A. I can't be positive about it. I can't say whether anybody

10 remained back. There were people outside, and my impression was that we

11 were among the last ones so leave but I'm not sure.

12 Q. Tell me, among the people who were outside in front of the

13 hospital -- you're not sure whether these people left with you or not, but

14 did you see any doctors among these people?

15 A. No. As far as I can remember, no.

16 Q. Do you know what happened to the doctors?

17 A. At that time, as I was leaving the hospital, I didn't know.

18 Q. All right. Let's define one thing, just to be clear about the

19 timing. You woke up at around 7.00, and what time was it when you left

20 the hospital? It could have been what time?

21 A. I think it was at about 8.00.

22 Q. At about 8.00. Did you know - and if so, who did you learn it

23 from - that at the time the doctors had been invited to attend the medical

24 staff meeting at the hospital?

25 A. Yes, I heard about that. When I left the hospital, there were

Page 2688

1 many women around me. We started talking, and then I learned that the

2 medical staff had gone to discuss something.

3 Q. Do you know where these discussions of the medical staff with

4 somebody else were taking place?

5 A. No, I don't know.

6 Q. Do you know who they discussed with, the medical staff?

7 A. At the time, no. I didn't know.

8 Q. When you say "at the time, no," does that mean that at some other

9 time, later, you learned who they had discussed this with?

10 A. I know this, but I saw this later on television. I think that I

11 also heard it in that convoy as we were travelling to Zagreb.

12 Q. Tell me, please, what did you hear on television? Was it

13 something related to the discussions of the medical staff?

14 A. Yes.

15 Q. Can you please describe it to us.

16 A. It wasn't the meeting of the medical staff. It's just that I

17 heard that Dr. Bosanac and Marin Vidic, Bili, went somewhere with

18 Sljivancanin to discuss something.

19 Q. On that morning?

20 A. I'm not sure.

21 Q. I'm referring to the 20th in the morning.

22 A. The 20th in the morning, I'm not sure about that.

23 Q. I'm asking you this because in your statement -- if you don't

24 remember it, I can give you the statement. I will read this out

25 correctly, trust me. It says in your statement as follows.

Page 2689

1 "At 8.00 in the morning, we left the room and we went out of the

2 hospital through the back entrance, as we had been told. I was with Vesna

3 Vukovic and my husband. At the same time, three doctors were invited to

4 attend the meeting between the medical staff and the JNA representatives."

5 Did you state this?

6 A. Yes.

7 Q. That's precisely why I asked you this. In 1995 this is what you

8 told the investigators. So you had this information, and if you had this

9 information did you also know who were these JNA representatives who had a

10 meeting with the medical staff and what did they discuss?

11 A. No, I don't know that.

12 Q. When you came out of the hospital on the 20th in the morning, you

13 say that you "saw" -- my husband [as interpreted] -- "Mr. Sljivancanin

14 then."

15 A. Yes.

16 Q. In addition to him, did you see any other members of the military,

17 any other officers or was he the only one?

18 A. There were some other soldiers there, members of the military. He

19 wasn't the only one.

20 Q. Were these people with ranks?

21 A. No, I don't know whether they had any ranks. I just assumed that

22 there is a certain hierarchy in the army and that everybody has to have a

23 rank or hold a post of some sort.

24 Q. All right. And this is where you separated?

25 A. No, we didn't separate on our own. We were separated.

Page 2690

1 Q. Please don't take me wrong. I meant no harm by saying so. You

2 were told to separate. First you mentioned four groups, then you

3 mentioned two groups. You said that you were not mistreated but were told

4 to take out some items from your bags, namely all sharp objects. Would

5 you please tell me who told you this and who did this, if something like

6 this was done.

7 A. A soldier.

8 Q. How many of you were there outside? 250? 300? 100?

9 A. Less than that. Not more than a hundred, but I'm not sure.

10 Q. Was there just one soldier who was inspecting your bags and

11 confiscating sharp objects, or were there several soldiers doing that?

12 A. Several of them but not too many, perhaps three or four.

13 Q. You say that there were wounded among them who stood there?

14 A. Among whom?

15 Q. Among the people standing outside in front of the hospital.

16 A. Yes.

17 Q. In your statement you say that you saw Ante Aric there as well?

18 A. Yes.

19 Q. Did you talk to him?

20 A. No, we were not allowed to talk.

21 Q. You said yesterday that you didn't talk as you stood there. Who

22 prevented you from talking?

23 A. Veselin Sljivancanin.

24 Q. So from 8.00, when you left the hospital, until you departed from

25 there, Veselin Sljivancanin stood there the whole time?

Page 2691

1 A. No, I'm not sure that he stood there the entire time.

2 Q. Did you notice on the 20th, in the morning, the JNA ambulances

3 being parked there in front of the hospital?

4 A. I can't remember. When we stood there, separated, in front of the

5 hospital, no, not in that area.

6 Q. When you gave a statement to the Prosecutor, you said "some men

7 walked around even though they had been wounded. Some were seriously

8 wounded."

9 Do you remember that?

10 A. Yes.

11 Q. "As far as I know, those who were seriously wounded were taken in

12 an ambulance to Zagreb."

13 Do you remember that?

14 A. Yes, yes.

15 Q. All right. So when were these seriously wounded people taken to

16 Zagreb in ambulances? I just refreshed your memory?

17 A. Yes, you did, but you're talking about the 20th in the morning.

18 Those who were seriously wounded were taken to Zagreb in the same convoy

19 in which I travelled, so I was on a bus.

20 THE INTERPRETER: Microphone for counsel, please.

21 THE WITNESS: [Interpretation] Shall I continue?

22 THE INTERPRETER: Microphone for counsel, please.

23 THE WITNESS: [Interpretation] I had an impression that you

24 interrupted me.

25 MR. BULATOVIC: [Interpretation]

Page 2692

1 Q. No, no, I didn't. Please continue.

2 A. All right. So the bus that I was travelling on, naturally with

3 other people, there were other women and children there, was followed by

4 several ambulances carrying the wounded.

5 Q. All right. You say that after that, European observers came. You

6 said that they had come from the opposite side of the hospital.

7 A. Yes. When I say "the opposite side," I'm referring to the side

8 which is opposite the side where the men stood from where they were taken.

9 That was in the late morning. I'm not sure about the exact time.

10 Q. You say that several foreign journalists came at the same time?

11 A. Yes, I saw them.

12 Q. And then you say that they were able to talk to whomever they

13 wanted?

14 A. I think that's right because I saw some women from my group

15 talking to journalists.

16 Q. That means that somebody remained in front of the hospital, not

17 all of you were boarded on buses, if they were able to stay there and talk

18 to them?

19 A. I don't understand what you're saying. The men were taken away.

20 They turned a corner. Us women, we remained standing there; I don't know

21 for how long. And then after that, European monitors and foreign

22 journalists came in.

23 Q. All right. You said they could talk to anybody they wanted, but

24 they mostly talked to officers and doctors. How many officers, in your

25 view, were there?

Page 2693

1 A. I don't know how many.

2 Q. Two? Three? Five?

3 A. I'm not sure that all of them were officers. I guess an officer

4 implies a rank. Is that right?

5 Q. Yes.

6 A. I'm not sure that they were officers in that case. They wore

7 uniforms. Ten at the most. I'm not sure.

8 Q. You say that they talked to JNA officers and doctors. Can I

9 conclude, based on that, that in front of the hospital there were JNA

10 officers and doctors standing together?

11 A. I don't remember, but I don't think so. I don't know.

12 Q. Amongst the doctors of the Vukovar Hospital who were standing in

13 front of the hospital, did you happen to see any members of the Yugoslav

14 People's Army, an officer wearing a white coat over his uniform?

15 A. I cannot remember.

16 Q. Very well. Since you were at the hospital frequently or, let's

17 say -- frequently, I mean you have contacts with people in the hospital,

18 did you know a doctor by the name of Mladen Ivankovic?

19 A. I didn't know him personally.

20 Q. Very well. On the 20th, amongst the doctors, did you see

21 Dr. Njavro and Dr. Vesna Bosanac at the hospital, on the 20th, or in front

22 of the hospital?

23 A. I don't think so, but I don't remember. I don't think so, though.

24 Q. Very well. You were at the Vukovar Hospital from the 18th, you

25 don't know from exactly what time, until the morning of the 20th. You had

Page 2694

1 contacts with Mr. Marin Vidic, Bili, the president of the Crisis Staff.

2 You had contacts with representatives of the town defenders. You

3 exchanged information for the purposes of providing information to the

4 public. And I'm interested: Did you ever hear that between the Vukovar

5 Crisis Staff and the Vukovar Hospital staff there was a plan made about

6 attempting to save as many members of the ZNG as possible, also of the

7 military police and the MUP, during the evacuation? And this was agreed

8 on in the following that: That a group of the members of the armed forces

9 of the Republic of Croatia would be placed on the list of the working

10 group, which was allegedly servicing the hospital; that another group

11 would be issued with certificates of wounding; and that their uniforms

12 would be hidden. Do you know anything about this?

13 A. This is a very long sentence -- actually, it's several sentences.

14 You began by mentioning the period from the 18th to the 20th, that I was

15 in contact with Marin Vidic, Bili, and Dr. Bosanac. I cannot actually

16 remember having contacts with them in that period.

17 Q. Madam, we didn't understand each other.

18 A. I've just looked at the screen and --

19 Q. Well, we didn't understand each other.

20 A. You mentioned the period between the 18th and the 20th.

21 Q. This is in connection with your arrival at the hospital which

22 means --

23 THE INTERPRETER: Could the speakers not overlap.

24 THE WITNESS: [Interpretation] You mentioned the date I arrived at

25 the hospital and I was in contact with Marin Vidic, Bili, and --

Page 2695

1 MR. BULATOVIC: [Interpretation]

2 Q. Let's try this way -- yes, it was a long sentence. From the

3 contacts that you had as somebody who was employed at the Croatian Radio

4 Vukovar and which were maintained with the Crisis Staff, with the Vukovar

5 Hospital, with representatives of the National Guards Corps, did you have

6 any information about a plan being agreed on, namely a plan being made,

7 how, during the evacuation, to save as many members of the National Guards

8 Corps, the MUP, and military police as possible?

9 A. No, I didn't have that information.

10 Q. Did you hear anything about this while you were staying at the

11 hospital on the 18th from an unspecified time and then the whole day and

12 night of the 19th and then the 20th in the morning?

13 MR. MOORE: With the utmost respect, the witness has answered this

14 question. It's being asked just in a different way because the Defence

15 got an answer they do not wish.

16 JUDGE PARKER: The first answer does appear to cover the whole

17 period from the 18th to the 20th, Mr. Bulatovic. That's certainly the way

18 we would understand it.

19 MR. BULATOVIC: [Interpretation] You are right, Your Honours.

20 Q. Madam Polovina, I see from your personal data that you completed

21 high school in 1984 and that you studied in Osijek, that you left your

22 studies in 1989. In the period from 1989 until 1990, were you continually

23 in Vukovar?

24 A. Yes.

25 Q. During that time that you spent in Vukovar and also during the

Page 2696

1 time that you spent these two time periods working at Radio Vukovar and

2 Croatian Radio Vukovar, you are sure to have met many people and gotten to

3 know many people who were important in the life of the town of Vukovar.

4 Am I right?

5 A. I did meet these people, but I really didn't get to know them all

6 that well. Mostly I spent time with my long-term friends. I didn't

7 really get very close to the people that I met in this capacity.

8 Q. I'm going to tell you several names of people that I'm interested

9 in, and if you have heard of these people could you please tell me, first

10 of all, whether you have heard of these people and what you know about

11 them. I asked you about Filip Karaula. Did you hear about a name

12 called -- a man called Blago Zadro?

13 A. Yes, I did hear of him.

14 Q. What did you hear? Who is that man? What does he do? What is

15 his profession?

16 A. Blago Zadro is no longer living. He was killed at Trpinjska

17 Cesta, I think sometime in October. He was a commander of the defence of

18 Borovo Naselje. I think he was the commander of that sector.

19 Q. As journalists -- as a journalist of Croatian Radio Vukovar, did

20 you have any contacts with him?

21 A. Yes, telephone contacts.

22 Q. Does the name Josip Gazo mean anything to you?

23 A. No. I heard of the Gazo last name. The name Josip I know, it's

24 known to me, but those two names together I really cannot recall.

25 Q. Did you hear about Stipan Radas?

Page 2697

1 A. I cannot remember.

2 Q. Did you hear of a person named Vlado Rimac?

3 A. I know of the last name Rimac, but the name Vlado with the last

4 name Rimac doesn't ring any bells.

5 Q. Have you heard of the name Ivo Madjarevic?

6 A. Ivo Madjarevic, no, I cannot recall that either.

7 Q. Did you hear of Franjo Mujic?

8 A. No.

9 Q. What about Branko Krizmaric?

10 A. No.

11 Q. What about Slobodan Mandic?

12 A. No.

13 Q. What about Franjo Djurica, the chief of the police

14 administration in Vukovar at a certain period, if I may assist you?

15 A. I heard of the Djurica last name, but those two names together,

16 no.

17 Q. Have you heard of Ferencz, Kovac?

18 A. Yes.

19 Q. What did you hear about him?

20 A. The man worked at the registry office and he performed the

21 marriage ceremony when he I married my husband.

22 Q. Did you hear of a person called Ivica Franic, nicknamed Srna, if

23 that means anything to you?

24 A. I've heard of the Srna nickname, but I haven't heard of Ivica

25 Franic. I cannot connect it to that name. But I did hear of Srna.

Page 2698

1 Q. What did you hear about that nickname? Who does it refer to?

2 A. I heard that it was a person who was a fighter in the Vukovar

3 defence forces.

4 Q. Did you hear of a person called Ivica Arbanas?

5 A. Yes.

6 Q. What did you hear about him?

7 A. He also was a fighter.

8 Q. Have you heard of Marin Pliso?

9 A. Pliso, that last name is familiar to me but I really don't know

10 what the first name is of the person.

11 Q. Stipo Pole?

12 A. Yes.

13 Q. What did you hear about Stipo Pole?

14 A. Stipo Pole worked at the police. He was one of the commanders I

15 think or a chief or -- or someone who was in the police leadership in

16 Vukovar.

17 Q. What about Milenko Vukovic?

18 A. No.

19 Q. I have one more name. Did you hear of Ante Roso?

20 A. Not while I was in Vukovar. This is a name that I became more

21 familiar with after the war from the media.

22 Q. While you were in Vukovar you never heard of that name?

23 A. I cannot remember.

24 Q. As a journalist, a person whose business is objective reporting -

25 that's the function of the media - you have certain contacts. So based on

Page 2699

1 the contacts that you have, do you have any information about the

2 relations in the Crisis Staff of the Vukovar defence vis-a-vis the

3 Republic of Croatia and also the relationships between people performing

4 certain functions within the Crisis Staff? Was everything functioning as

5 it was supposed to? Were there any misunderstandings? And if there were,

6 what they were about? And did you report about any of these

7 misunderstandings between anyone?

8 A. I personally did not receive such information from the people who

9 were at the staff, but I did hear that their -- I heard that the

10 relationships were not so good towards the end. I heard this from my

11 colleagues.

12 Q. I have my last question now, and I think that will be sufficient.

13 If you know, please tell me: Do you know anything about the activities of

14 Tomislav Mercep in relation to Serbs in Vukovar? About arrests of

15 prominent Serbs, killings of Serbs, the mining of Serb houses, and any

16 kind of intimidation?

17 A. I don't know.

18 MR. BULATOVIC: [Interpretation] Your Honours, thank you very much.

19 I have completed my cross-examination.

20 JUDGE PARKER: Thank you very much, Mr. Bulatovic.

21 Mr. Moore.

22 MR. MOORE: Your Honour, there is one matter before my learned

23 friend perhaps concludes. Really, it relates to cross-examination

24 vis-a-vis the morning of the 20th. Of course the witness said that

25 Mr. Sljivancanin was outside - this is in chief - and was spoken to by

Page 2700

1 ladies about what was happening to the men and an explanation given by

2 Major Sljivancanin to those wives. That has not been dealt with by my

3 learned friend. Can I take it then that it is accepted by the Defence

4 that that was said by Major Sljivancanin? Because the witness should have

5 an opportunity, if that is going to be disputed, the witness must have an

6 opportunity of clarifying that matter and having an ability to reply.

7 JUDGE PARKER: Mr. Moore, if no Defence counsel pursues that

8 issue, the expectation is that it is not disputed.

9 MR. MOORE: If that's the Court's view, then I have no problems

10 with that. Thank you very much.

11 JUDGE PARKER: And I'll pause in case some Defence counsel wishes

12 to dispute it, but I think I've found one.

13 MR. LUKIC: [Interpretation] Well, perhaps, it's not right. My

14 colleague was asking the questions --

15 JUDGE PARKER: Mr. Lukic, perhaps he should take over. We don't

16 change horses in the middle of a gallop.

17 MR. BULATOVIC: [Interpretation] Your Honours, I absolutely

18 understand my learned friend from the Prosecution, what he's seeking with

19 this objection. But my line of questions was directed at establishing the

20 presence of Mr. Sljivancanin and certain places. So I think that in the

21 course of the proceedings we will continue also to prove this. I am not

22 disputing the fact that my client was there on the 20th. Whether he was

23 in all the places throughout that whole period is something else. I think

24 the statement of this witness is saying something which is quite different

25 from what the Prosecutor is asserting. However, later in the course of

Page 2701

1 the proceedings we will seek to establish that. I cannot have a person

2 violating all the laws of physics and space in that sense, if it were --

3 if it was to be the way the Prosecution is claiming. But we will continue

4 to pursue this as we continue with the proceedings.

5 JUDGE PARKER: I think, Mr. Moore, you can take it that the

6 subject matter of the conversation is not in dispute.

7 MR. MOORE: But would the Court just hear my submission for a

8 short -- a short submission in relation to it?

9 With the utmost respect to my learned friends, there are two

10 issues here: One whether Major Sljivancanin was present when individuals

11 were taken from the hospital at, let us say, the morning; and two, that

12 Major Sljivancanin was spoken to by women who inferentially were concerned

13 about their husbands. And a reply was given -- a reply was given. We

14 would submit that is a significant conversation, and inferences could be

15 drawn in relation to that reply.

16 Now, if my learned friend is going to submit later on about Major

17 Sljivancanin, these two areas, in my submission, must be dealt with now.

18 Firstly, was Sljivancanin there or not? And secondly, if he was there,

19 did he have such a conversation and indicate that, in actual fact, the men

20 were going to be separated from the women, taken to the JNA barracks, and

21 then re-united? Because the Prosecution case has always been that this

22 was a deliberate attempt to placate individuals, isolate the men who were

23 then subsequently killed. It is one of the key issues of the case, in our

24 submission.

25 JUDGE PARKER: Thank you, Mr. Moore. As I have indicated, there

Page 2702

1 has been no suggestion to the contrary in the course of cross-examination

2 by three Defence counsel.

3 MR. MOORE: Thank you very much. May I deal with short points on

4 re-examination -- at least I hope they'll be short points. Madam --

5 JUDGE PARKER: It looks, Mr. Moore, that Mr. Bulatovic wants to

6 say more.

7 MR. BULATOVIC: [Interpretation] Your Honour, I don't think that

8 Mr. Moore understood me. If, at this point in time, we accepted to

9 proceed in this manner, establish things or not establish things, then all

10 of us should be on one side. It is up to the Trial Chamber to assess what

11 has been established based on each testimony. At this point in time, I do

12 not wish and I am not going to give this assessment. I'm going to do this

13 when the time comes. Thank you.

14 JUDGE PARKER: So that there can be no misunderstanding in the

15 future, the subject matter of Mr. Moore's observation and the Chamber's

16 indication of the position arises out of Rule 90(H), subparagraph ii,

17 which requires that: "In cross-examination of a witness, counsel shall

18 put to that witness the nature of the case of the party for whom that

19 counsel appears and which is in contradiction of the evidence given by the

20 witness."

21 That being so, there having been nothing put to this witness to

22 suggest that there was not that conversation and that its content was not

23 as the witness has indicated, the understanding of the Chamber is that

24 those matters are not in dispute. That's the sole point of what has been

25 discussed. The Chamber is in no way indicating that there are final

Page 2703

1 findings of fact being made at this point or that it will not be open to

2 the Defence to put its case and to put submissions following that. It's

3 just that on an issue of this nature, if it really is the case of any

4 member of the Defence teams -- sorry, any one of the Defence teams that

5 there was no such a conversation that morning, then that needs to have

6 been put to the witness.

7 Now, with the air all clear about that, Mr. Moore, if you would

8 carry on.

9 MR. MOORE: Thank you very much.

10 Re-examined by Mr. Moore:

11 Q. Madam, you told us about the convoy when you left on the 20th, the

12 convoy that you travelled on. That was the convoy that you described

13 having the ambulances. How many men travelled on that convoy with you, if

14 you can assess percentage-wise?

15 A. I wouldn't be able to say with accuracy because I was on the bus

16 and it was only women on the bus with me. As the convoy travelled, the

17 buses were moving and I kept looking back because Veselin Sljivancanin had

18 said that the men would go to the barracks for a brief questioning and

19 then would follow us. Therefore, I kept looking back to see if there were

20 any additional vehicles joining our convoy and travelling with us to

21 Zagreb. Based on that, on that looking back, I know that there were

22 several ambulances carrying the wounded.

23 There is another issue, which is that at one point in time when we

24 arrived in Vojvodina, my colleague, Vesna Vukovic, who had travelled with

25 me up to that time, moved into the vehicle in which her husband who was

Page 2704

1 wounded was travelling.

2 Q. If we talk about the convoy itself and the travelling from

3 Vukovar, did there come a time when the buses disembarked, when people got

4 off the buses?

5 A. Yes.

6 Q. And did you have an opportunity of seeing how many men or women

7 actually got off those buses?

8 A. No, I wouldn't be able to say because we disembarked, and I'm not

9 sure whether that was in Sremska Mitrovica or we had already reached Novi

10 Sad. I really don't remember. I know that we were allowed to get off the

11 buses at one point. I can remember that. But how many people, I really

12 don't know.

13 Q. I didn't ask about people. I asked about the division between

14 male and female. Are you able to assess the percentage of male or

15 female --

16 MR. BULATOVIC: [Interpretation] Your Honours.

17 JUDGE PARKER: Mr. Bulatovic.

18 MR. BULATOVIC: [Interpretation] Your Honours, I'm objecting to

19 this line of questioning of my learned friend because I don't see how this

20 arises or what this arises from. These issues were not brought up by any

21 of the Defence counsel during cross-examinations. None of the Defence

22 teams asked the witness in cross-examination about the movement of convoy

23 after it left Vukovar and travelled to Sremska Mitrovica.

24 JUDGE PARKER: Mr. Moore.

25 MR. MOORE: The witness gave evidence about convoys, but in any

Page 2705

1 event the issue, the core issue, of this witness's evidence -- one of the

2 core issues is the fact that men were taken away and went around the

3 corner and that there had been separation. And all three of my learned

4 friends cross-examined on that issue, as far as I can recollect. But in

5 any event --

6 JUDGE PARKER: But, Mr. Moore, how does it arise for

7 re-examination?

8 MR. MOORE: It arises for re-examination because in our submission

9 the Court would be entitled to know whether in actual fact separation has

10 been occurred and not merely was intended.

11 JUDGE PARKER: Isn't that subject of evidence in chief?

12 MR. MOORE: It is a matter for evidence in chief and it was dealt

13 with in chief vis-a-vis the separation. But in our submission it arises

14 out of the cross-examination because the witness herself was asked about

15 ambulances and whether in actual fact ambulances escorted the convoy.

16 JUDGE PARKER: But to say, Mr. Moore, that -- in my view it's not

17 a matter for re-examination.

18 MR. MOORE: Thank you very much. I'll move on.

19 JUDGE PARKER: Mr. Vasic, have you been left alone too long. I'm

20 sorry, I'm not ignoring you.

21 MR. VASIC: [Interpretation] Thank you, Your Honours. You

22 pre-empted what I was going to say. I have nothing to add to that. I

23 just wanted to applaud what you said.

24 JUDGE PARKER: Mr. Moore.

25 MR. MOORE: Thank you very much.

Page 2706

1 Q. You were asked about the exchange of material between the hospital

2 and the Crisis Staff. Do you remember those questions?

3 A. Exchange of material? You mean information?

4 Q. Yes.

5 A. Yes, yes.

6 Q. What sort of information was exchanged?

7 A. Information about the number of the dead, wounded, even some

8 individual cases were discussed. We would receive information about what

9 had happened to an individual person. So it wasn't just the figures that

10 we were given. We also received information about the situation in the

11 hospital, the supply of medication, and so on.

12 Q. Finally this, it's really a point of clarification as much as

13 anything. In evidence in chief, that was replying questions to myself,

14 you were asked about Sajmiste and you seemed to suggest that that had --

15 that part of the town had been taken, to use your words, in the first half

16 of September.

17 In cross-examination, it seems to be that you were suggesting that

18 that area fell on the -- on and around the 15th of October. I can give

19 the page numbers if it assists my learned friends. Can you, for

20 clarification, please, tell the Court, if you know, actually when it was

21 that Sajmiste had been taken. Was it September or was it another

22 occasion?

23 A. As far as I remember, Sajmiste was not occupied and did not fall

24 on one particular day. We can't pick a day when that happened. I think

25 it went house by house or street by street. It was a gradual process.

Page 2707

1 These people who arrived after the 15th of October into our basement had

2 been staying in a shelter in Sajmiste. I don't know where this shelter

3 was, whether it was close to the town or not. I don't know how combat

4 operations unfolded and on what day a particular part of Sajmiste fell.

5 It was a gradual process. It took some time for that to happen.

6 Q. Do you know where the JNA barracks in Vukovar is located, the area

7 of the municipality?

8 A. Yes. It is near Sajmiste, in that area.

9 MR. MOORE: I have no further questions. Thank you very much.

10 JUDGE PARKER: Mrs. Polovina, you'll be pleased to know that that

11 is the end of your questioning, the end of your evidence. You'll be now

12 free to return to your home. The Chamber would thank you for coming to

13 The Hague and for the assistance you've given. You may now go with the

14 court officer.

15 THE WITNESS: Thank you.

16 [The witness withdrew]

17 JUDGE PARKER: Mr. Moore.

18 MR. MOORE: The next witness is Mara Bucko. I'm entirely in the

19 Court's hands whether it's appropriate to start now.

20 JUDGE PARKER: 14 minutes, given a minute or two to get her, we'd

21 certainly manage 12 minutes. Do you think that would be useful?

22 MR. MOORE: For my part, I think not. But --

23 JUDGE PARKER: You think not?

24 MR. MOORE: I think -- I'm quite willing to assist my learned

25 friends. So there's no mystery about it, it was our intention in the

Page 2708

1 witness list to call her husband first. For various reasons, Your Honour

2 will see also that there was another witness called Koprcina, and we

3 re-appraised the case and we informed my learned friends some time ago we

4 would not be calling that witness. There was an element of duplication.

5 So, as an element of that, we brought witnesses forward. So we saved a

6 day and a half in relation to that witness.

7 JUDGE PARKER: That's the first good news the Chamber has had for

8 a long time.

9 MR. MOORE: There's other good news, but you don't know about it.

10 So --

11 JUDGE PARKER: Very well then. I think we might call it an early

12 finish.

13 MR. MOORE: Thank you very much.

14 JUDGE PARKER: That's very tricky to start a long witness just a

15 few minutes short of the day. So we will resume again tomorrow at 9.00.

16 --- Whereupon the hearing adjourned at 1.33 p.m.,

17 to be reconvened on Friday, the 2nd day of

18 December, 2005, at 9.00 a.m.