Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14246

1 Monday, 24 March 2003

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19 [Open session]

20 JUDGE SCHOMBURG: Before we come to the subject matter of your

21 testimony, may we please hear your name, your first name and if so, your

22 nickname.

23 THE WITNESS: [Interpretation] Petar Stanar, nicknamed Cile.

24 JUDGE SCHOMBURG: And your date and place of birth, please.

25 THE WITNESS: [Interpretation] 13th of September, 1954, Maricka

Page 14248

1 Municipality of Prijedor.

2 JUDGE SCHOMBURG: And your current place of residence, please.

3 THE WITNESS: [Interpretation] Still the same place, Omarska

4 without number, Omarska. I have been living there all the time.

5 JUDGE SCHOMBURG: For procedural reasons, are you in any way

6 relative to the accused in this case, to Dr. Stakic?

7 THE WITNESS: [Interpretation] Yes, we are the sons of two sisters.

8 JUDGE SCHOMBURG: Could you please be more precise. Who --

9 THE WITNESS: [Interpretation] We are children of two sisters of

10 first blood. So we are first cousins.

11 JUDGE SCHOMBURG: This we'll say, it's always extremely difficult

12 to find out these linear or collateral relations. Your mother and the

13 mother of Dr. Stakic, they are sisters. Correct?

14 THE WITNESS: [Interpretation] Yes, yes.

15 JUDGE SCHOMBURG: Then before we start with the testimony, I have

16 to go into some legal details and ask the parties for their submissions on

17 this. Our rules on procedure and evidence don't have any rules on the

18 right to refuse testimony on personal grounds. Nevertheless, a

19 comparative approach seems to give the impression that in a number of

20 countries, the following persons may refuse to testify: The fiance of the

21 accused, the spouse of the accused, even if the marriage no longer exists,

22 a person who is linearly related or related by marriage, collaterally

23 related to the third degree, or related by marriage to the second degree

24 to the accused. This seems to be what some legal systems have in common.

25 But I can't see that the current relationship just demonstrated by the

Page 14249

1 witness grants a right to refuse testimony on personal grounds.

2 Defence, please.

3 MR. LUKIC: In all legal systems of the former Yugoslavia, it

4 would be the ground to refuse the testimony actually. Even further

5 relation, collateral relation would be grounds to refuse the testimony,

6 but we never spoke with this witness so we don't know what is his

7 standpoint.

8 MR. KOUMJIAN: Your Honour, I suggest that we find out if it's

9 theoretical or a real issue, but our submission is that given the

10 importance of cases at this Tribunal and the lack of any privilege stated

11 in the rules, that the witnesses would not have privilege, certainly not a

12 cousin.

13 JUDGE SCHOMBURG: I think the logical order is first to find out

14 what are the prerequisites, and then to ask the witness.

15 May I ask you, Mr. Stanar, do you want, if there would be - and I

16 emphasise "if there would be" - an obstacle by your relation -- based on

17 your relationship to Dr. Stakic to testify in this case?

18 THE WITNESS: [Interpretation] I see no reason for any obstacle. I

19 can answer the questions that you have to put to me.

20 JUDGE SCHOMBURG: Thank you. This is a practical solution. Then

21 we can continue.

22 Questioned by the Court:

23 JUDGE SCHOMBURG: Can we please hear in context your professional

24 career starting at that point of time when you were, as I assume,

25 gainfully employed in the municipality of Prijedor.

Page 14250

1 A. Well, before I started to work in the Municipality of Prijedor in

2 1990, I worked as a driver in Ljubljana, and I was there for 18 years.

3 And when the division came about, I was fired in Ljubljana by my company

4 because I was a Serb, and that was when I returned. And then I spent a

5 year on the waiting list, on a laid-off list. And since I was a

6 professional driver, I applied at the employment bureau, and the

7 municipality gave me the job of a driver.

8 JUDGE SCHOMBURG: And do you recall the exact date when was it

9 that you were gainfully employed in the municipality as a driver?

10 A. I started working there on the 17th of May, 1992.

11 JUDGE SCHOMBURG: Are you still employed by the Municipal

12 Assembly?

13 A. Yes, I am, and I'm still the driver of the President Muharem

14 Murselovic, the current president.

15 JUDGE SCHOMBURG: So may I ask, was there a pool of drivers in the

16 Municipal Assembly, or were you assigned to drive a special car, or were

17 you assigned to drive a special person?

18 A. There were five of us, and we all worked together. As the need

19 arose, we would be issued the order and drive wherever, and we are still

20 five, and we work based on the same principles as we did in 1992, that is,

21 we are issued the order to drive wherever is necessary, and we do that.

22 JUDGE SCHOMBURG: Maybe my question was not concrete enough. Were

23 you assigned, for example -- or as you told us, at the moment you are

24 driving the current president of the municipality --

25 A. The municipality of Prijedor.

Page 14251












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Page 14252

1 JUDGE SCHOMBURG: In 1992, were you the driver of a concrete

2 person, say also at that time the president of the Municipal Assembly?

3 A. The then-president, Milomir Stakic, didn't have a driver of his

4 own. He would ask any of our four, five drivers to take him wherever.

5 And since I lived in Omarska and he lived in Omarska, he would usually

6 call me so if we could go back home. But to drive around for business, he

7 would ask for any of the drivers because there was nobody assigned to him,

8 nobody was there to wait for him.

9 JUDGE SCHOMBURG: Did you have special log books, either related

10 to a certain person or to a certain car?

11 A. No, nothing specific. I had a Jetta, a 12-year-old car that I was

12 issued with first. And I started working there with that car. I didn't

13 have any particular instructions or any particular logbooks. We worked

14 regularly just as we work now.

15 JUDGE SCHOMBURG: When arriving, just that we have an impression

16 of your working day, would you go in the morning first to the building of

17 the municipality and wait there for instructions? Or was it already the

18 day before that you got the instructions "Tomorrow you have to drive Mr. X

19 or Y"?

20 A. It would happen in the morning. We get to work. And they'd tell

21 me the boss is calling you. It was Zeljko Grahovac who was my boss. He

22 gives me several orders, as well you are supposed to go to such and such

23 place. He gives you the order, and we're off.

24 JUDGE SCHOMBURG: So coming back to 1992, who was at that time

25 your superior, your immediate superior in the Municipal Assembly?

Page 14253

1 A. It was Zeljko Grahovac, because I was a driver, so I was under

2 him. But he must have been receiving his orders and tasks from somebody

3 who was above him. But my orders were issued by him.

4 JUDGE SCHOMBURG: And could you please tell us who was the

5 superior to Zeljko Grahovac?

6 A. I don't know. I guess the president or the secretary, one of

7 those two. Just as it is today. But nothing special. Now, my boss is

8 Zoran and at that time it was Zeljko Grahovac. And who was his superior,

9 well, it was either the secretary or the president. I don't know. I

10 don't know who it is today either.

11 JUDGE SCHOMBURG: You told us that you started your work the 17th

12 of May, 1992. And --

13 A. Yes. The other day, I found this decision, and I saw it was the

14 17th of May. That day, I was issued the decision for a trial work for a

15 month. That is, if I proved to be up to the task, then they would decide

16 whether I would be taken on permanently.

17 JUDGE SCHOMBURG: Do you by chance have this document with you,

18 this decision you just mentioned?

19 A. No, I left it at home. I didn't bring it with me. I have it in a

20 drawer, and I could have taken it. I simply forgot it, but there was this

21 document, it says the 17th of May, and I can now prove it and document it.

22 JUDGE SCHOMBURG: So my understanding from your testimony is that

23 there was nothing like a logbook in the cars. And how was your work

24 controlled? Did you have to sign in in the morning and sign out in the

25 evening, or how did it work?

Page 14254

1 A. In the morning, we got to our workplace. We sit down. As we are

2 sitting now in the janitor's room, that is where we could sit. And we sit

3 there and wait for our assignments. There was no logbook kept, but it was

4 natural for us to get to work at 7.00, and then to wait for assignments

5 except when we have to go further away, to Banja Luka or some other place,

6 then we would know it in advance. But otherwise, we are issued with the

7 travel order that says "Municipality of Prijedor." It covers our area,

8 and you just drive around with that travel order which can be valid for a

9 month.

10 JUDGE SCHOMBURG: How many drivers and how many cars were

11 available in 1992?

12 On the channel 4, I just listened B/C/S and not English. Could

13 this please be changed.

14 Can we continue? Okay. So the question was how many drivers and

15 how many cars were available in 1992?

16 A. When I joined in 1992, there were five drivers, me, Dragomir

17 Grandic. This was this man called Bogunovic. Let me try and remember his

18 first name. There was a man called Miro, and a man called Ergelic. There

19 were five of us when I worked there. There were five of us.

20 JUDGE SCHOMBURG: How many cars and please, which kind of cars?

21 Golf? Mercedes?

22 A. There was one Mercedes, one Jetta that I drove, and there were

23 three Lada cars.

24 JUDGE SCHOMBURG: How often did you drive the president of the

25 Municipal Assembly at that time?

Page 14255

1 A. I would be the one who would drive him from home and back home.

2 And I would take him in my Jetta.

3 JUDGE SCHOMBURG: On a daily basis?

4 A. Every day during that period of time.

5 JUDGE SCHOMBURG: What period of time, that would from as from the

6 17th of May until what is important here, September/October 1992; correct?

7 A. Yes, up to then. It was either in September or October that I

8 worked there. And after that, I was mobilised and I was sent to the front

9 line.

10 JUDGE SCHOMBURG: Where lived Dr. Stakic at that period of time?

11 A. In that period of time, he lived in Omarska. He lived in Omarska,

12 and his landlady was -- I don't remember her name. That's where he lived,

13 in Omarska. I really don't know the name of these two ladies in whose

14 house he resided, but there were two ladies. He was their tenant.

15 JUDGE SCHOMBURG: Didn't he live together with his family?

16 A. His family was living with him in rented accommodation.

17 JUDGE SCHOMBURG: And without any doubt, it's your testimony as

18 you sit here that you brought on a daily basis Dr. Stakic in the morning

19 from Omarska and in the evening back to Omarska?

20 A. Up to the 30th of April, the 1st of May, I would drive him

21 regularly. After the 1st of May, we didn't go there any longer.


23 A. Yes.

24 JUDGE SCHOMBURG: So then maybe it was my fault.

25 So please, once again maybe I was misled, did you before you

Page 14256

1 received the final decision that you would drive for the or on behalf of

2 the Municipal Assembly a period of time already beforehand? Because

3 previously you mentioned that you found a decision starting your work the

4 17th of May. And now you're discussing the 30th of April and the 1st of

5 May.

6 A. No, not April. I started in May, so it must have been June. I

7 made a mistake. It was June. May, June, up to June, yes, thereabouts.

8 JUDGE SCHOMBURG: Maybe it can help you, do you recall the

9 so-called takeover of Prijedor which happened, in fact, as you indicated,

10 on the 30th of April to the 1st of --

11 A. I don't remember. I didn't work at that time. I started working

12 later than that.

13 JUDGE SCHOMBURG: But why did you mention on line 9 -- line 21

14 page 9 of today's transcript, "That up to the 30th of April, the 1st of

15 May, I would drive him regularly? After the 1st of May, we didn't go

16 there any longer," which in fact would be in line with other testimonies

17 we heard here in this courtroom before?

18 A. As of the attack on Prijedor, and after that, we didn't go there

19 any longer. I don't know when that happened, whether it was on the 30th

20 or -- I don't remember.

21 JUDGE SCHOMBURG: Do you remember the takeover of Prijedor, which

22 was I think for all citizens of Prijedor --

23 A. No. No, I don't remember the takeover in Prijedor. I wasn't

24 there. I started working when the president of the Municipal Assembly was

25 Stakic.

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Page 14258

1 JUDGE SCHOMBURG: And I think it's in the moment - the parties may

2 correct me if I'm wrong - undisputed among the parties that Dr. Stakic

3 became the president of the Municipal Assembly the 30th of April, 1992,

4 already. So could you please try to recall when it was now exactly that

5 for the first time you drove Dr. Stakic.

6 A. Starting with the 17th of April, that is, the 17th of May, when I

7 started working, I started taking him to Omarska. I would go home and he

8 would come with me. Up to the attack on Prijedor, and then things changed

9 after that.

10 JUDGE SCHOMBURG: Sorry that I don't understand. It reads now:

11 "Starting with the 17th of April, that is, the 17th of May." When did

12 you actually start? Maybe one explanation could be that, in fact, that

13 you got the work the 17th of May, and there was a, call it, test period

14 before you got the final decision that you were gainfully employed.

15 A. No, it says that on the 17th of May, I was given this decision to

16 start working as a driver in the municipality of Prijedor, and I started

17 driving after that.

18 JUDGE SCHOMBURG: Did you maybe, without being a driver in the

19 municipality of Prijedor, on a private or semi-private basis drive

20 Dr. Stakic from Omarska to Prijedor and the way back?

21 A. No, no, I didn't drive him in my private car. I would drive him

22 in the official car. And when we went home, we went home together to

23 Omarska.

24 JUDGE SCHOMBURG: Did you ever drive him in his private car?

25 A. No, never.

Page 14259

1 JUDGE SCHOMBURG: So when you drove Dr. Stakic, did you call --

2 did you get a call by the secretary or by your direct superior asking

3 "Please, Dr. Stakic needs a car today and please take the one" -- I think

4 you mentioned it was a Jetta --

5 A. Yes.

6 JUDGE SCHOMBURG: And then it would be the decision of Dr. Stakic

7 where to go? Or did you already know beforehand what would be the final

8 destination of your ...?

9 A. I would be given an order to drive, and I would drive wherever

10 President Stakic told me to go. I would go there.

11 JUDGE SCHOMBURG: So can you please tell us what were the main

12 destinations where you travelled to with Dr. Stakic.

13 A. Well, all over Prijedor, he would visit all sorts of institutions,

14 schools, companies, electrical board, medical institutions. He was in

15 charge of all of these institutions, and he would visit them very often.

16 Sometimes he would go to Banja Luka to the municipality. He went

17 everywhere. He was always on the move. And when he didn't go anywhere,

18 he would receive people in his office.

19 JUDGE SCHOMBURG: You mentioned he would visit all sorts of

20 institutions. Did he, for example, visit the Ljubija mine?

21 A. No, he didn't go to Ljubija because the main office of the Ljubija

22 mine is very close to the municipal building. If he went there, he would

23 go on foot. There was no need for me to drive him there. This office was

24 the main office for the Ljubija mine, and it was behind the municipal

25 building in Prijedor.

Page 14260

1 JUDGE SCHOMBURG: We know. Could you give us some examples of

2 places Dr. Stakic would have visited at that time in the entire

3 municipality of Prijedor. Hamlets, small towns, institutions there.

4 A. He didn't go to these little hamlets. If he went anywhere, he

5 would go to the municipal building in Banja Luka or elsewhere where they

6 needed him. In Prijedor, he visited all sorts of companies, the railway,

7 Zitopromet, Kozaraputevi, public utilities, all such institutions which

8 had problems then as they have them now. He would very often go to the

9 hospital. All sorts of places he would visit. We didn't go to any of the

10 smaller hamlets. There was no need for him to go there. If he went

11 anywhere from outside Prijedor, he would go to Banja Luka mostly.

12 JUDGE SCHOMBURG: So whom would he meet in Banja Luka?

13 A. I didn't leave my car. He would usually go to the municipal

14 building. I don't know who he met with because I remained in the car. He

15 would go into the municipal building to see people there, but I don't know

16 who.

17 JUDGE SCHOMBURG: When he went to Banja Luka, did you travel alone

18 with him or was Dr. Stakic sometimes in the company of others having the

19 same destination in Banja Luka?

20 A. Most often, he would go alone. Sometimes he was accompanied by

21 one of his vice-presidents, either Travar in charge of finances or

22 Savanovic. So there were a few people. Some would accompany him

23 sometimes.

24 JUDGE SCHOMBURG: Was he ever accompanied by Mr. Drljaca?

25 A. I didn't know Mr. Drljaca very well at that time. I only met him

Page 14261

1 later. Mr. Drljaca, he had his own car and he would usually go alone. I

2 didn't see Dr. Stakic socialising with him. And if Stakic came, then

3 Drljaca would also sometimes come on his own accompanied by his own

4 people.

5 JUDGE SCHOMBURG: Did you ever see him together -- or was he

6 accompanied in his car by one of the following persons: Mr. Arsic?

7 A. No, I don't know that person. Only later I heard that he held a

8 post in the army. That's what I heard when I went to the front line, but

9 I never met him.

10 JUDGE SCHOMBURG: Mr. Kovacevic?

11 A. I met Kovacevic later on. He was sitting in a different office.

12 I believe he was the president of the Executive Board. His office was

13 next to Stakic's office, I believe.

14 JUDGE SCHOMBURG: Have you ever been to the office of Dr. Stakic?

15 A. Very rarely, maybe once or twice. But there was no need for me to

16 go up there. Us drivers would be sitting in the janitor's room waiting

17 for our instructions.

18 JUDGE SCHOMBURG: When you waited for your instruction, for

19 example, and, say, Dr. Stakic didn't arrive as envisaged, would you give

20 him a direct call or the secretary?

21 A. He had his own secretary who would call him. I was sitting down

22 there, and if he didn't arrive, then if I was given to drive somebody

23 else, I would drive that person. There was no need for me to wait for

24 Stakic if I had other things to do, then there would be other persons

25 driving him when he showed up later. So there was none of us assigned to

Page 14262

1 a particular person. We would drive people as the need arose.

2 JUDGE SCHOMBURG: Was the car used a sign of the importance of the

3 person you drove? Was there a kind of hierarchy among the cars that, for

4 example, the most important person would drive the Mercedes?

5 A. No, there was no special marks. I had an old Jetta. Later on, I

6 swapped with my colleague. That was only a month later. I swapped a car

7 with a Mile Bogunovic so that the president would be driven in a better

8 car rather than in an old Jetta. That's why I swapped cars with this man

9 some month or a month and a half later.

10 JUDGE SCHOMBURG: Swapping cars, you would say, if I understood

11 you correctly, that from that point on, you drove Dr. Stakic in a

12 Mercedes. Correct?

13 A. I first drove him in a Jetta, and later on I swapped cars with

14 Bogunovic because his car was better. The Jetta was some 15 years old.

15 And that's why I traded cars with this Bogunovic who had a better car, a

16 Mercedes. And after that time, I drove the Mercedes.

17 JUDGE SCHOMBURG: So approximately - I know it's a long time ago

18 and it's difficult to recall - but at what point in time would it be that

19 you started driving Dr. Stakic with a Mercedes?

20 A. Around the 20th of June, or thereabouts. 20th of June, a month

21 and a half after I started working in the Jetta.

22 JUDGE SCHOMBURG: Let me now continue with the question who maybe

23 was accompanying Dr. Stakic on one of the journeys? Was there -- did you

24 ever see a Dr. -- not doctor, sorry. Mr. Radoslav Brdjanin?

25 A. No, I never met Radovan [As interpreted]. Only four or five years

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Page 14264

1 later did I actually find out who Radoslav Brdjanin was. But I never saw

2 him.

3 JUDGE SCHOMBURG: General Momir Talic?

4 A. I never saw him. I heard that he was in Banja Luka, but I don't

5 know him.

6 JUDGE SCHOMBURG: Radovan Karadzic?

7 A. I saw him once. I also don't know.

8 JUDGE SCHOMBURG: Do you recall at what occasion this was that you

9 met Mr. Karadzic? Was it together with --

10 A. It seems to me that I saw him in Prijedor once if I'm not

11 mistaken.

12 JUDGE SCHOMBURG: At what point in time, please, and was it

13 together with Dr. Stakic?

14 A. It seems to me that it was in 1992 when he arrived in Prijedor. I

15 don't remember the date, but I believe that there was Krajisnik, Karadzic,

16 and Biljana together in the new hotel in Prijedor, but I can't remember

17 the date. It seems to me that they stayed there for a day or two.

18 JUDGE SCHOMBURG: Was there a special occasion, a meeting of party

19 or ARK or whatsoever?

20 A. I don't know. I don't have that information. I only know that

21 they came to visit. I believe that that was that. I don't know. I'm not

22 a member of any party. I don't understand politics.

23 JUDGE SCHOMBURG: What about Biljana Plavsic?

24 A. I saw her together with Karadzic and the other man. What's his

25 name?

Page 14265

1 JUDGE SCHOMBURG: Krajisnik maybe?

2 A. Yes, yes, Krajisnik, yes.

3 JUDGE SCHOMBURG: So you mentioned beforehand when driving to

4 Banja Luka, you visited the municipal building. Are you quite sure that

5 this was the municipal building, or was it for the purpose of visiting

6 higher-ranking persons such as those just mentioned before in Banja Luka?

7 A. No, this was the municipal building. I know that building very

8 well. He would enter the building, and I would wait in front of the

9 municipal building.

10 JUDGE SCHOMBURG: And whom would Dr. Stakic meet there in the

11 municipal building?

12 A. I stayed in the car. I didn't get off the car. I didn't go with

13 him. My job was to sit in the car.

14 JUDGE SCHOMBURG: For how long did you work as Dr. Stakic's

15 driver?

16 A. From that day, when I started, that is, the 17th of May, until

17 about the 20th of September or October. I can't remember exactly. And

18 that was the end of it. I was called up by the ministry.

19 JUDGE SCHOMBURG: Did you return as a driver to the municipality

20 of Prijedor after the mobilisation?

21 A. Yes. I returned in 1995, in March, or perhaps February. I

22 returned and was a driver again, and I started -- took over my old job. I

23 became the driver and still drive the president of the municipality and I

24 drive him now as I did all those years earlier.

25 JUDGE SCHOMBURG: In 1995, the president was again Dr. Stakic.

Page 14266

1 Correct?

2 A. No. When I returned, he was not the president. It was Kurnoga

3 who was the president then. Stakic was not the president when I came.

4 Then I must have gone wrong somewhere. It was Kurnoga.

5 JUDGE SCHOMBURG: Do you recall that -- I refer to transcript page

6 10.344 to 345 of the transcript, for the parties only.

7 Do you recall that Stakic and the driver was arrested or taken to

8 custody by some Serb paramilitary forces? Do you recall such an incident?

9 A. No, no, I don't. I wasn't there. Seems that I was mistaken when

10 I said that he wasn't there when I came. I don't remember any of that.

11 Then I must have come in 1996 -- or wait. 1992, 1993, 1995. 1995 or

12 1996? I can't remember. 1996. I returned in 1996. 1996, yes, that's

13 right. I started working in 1996.

14 JUDGE SCHOMBURG: Let's come back to those places Dr. Stakic

15 visited in 1992 when it was not necessary, for example, because the

16 factory or the organisation was that close that it was possible to go by

17 foot, better even to go by foot. What were these other companies

18 Dr. Stakic would visit?

19 A. Well, mostly as I said, he would go to the mines, Zitopromet, and

20 then he couldn't walk there because the public amenities and Zitopromet,

21 they are further away so that he would take the car. The school is

22 nearby. The school is nearby. He could walk there. The court building

23 is nearby, too. But there was nothing specific. He would just walk there

24 because it was all around the corner.

25 JUDGE SCHOMBURG: You just said he would go -- let's start with

Page 14267

1 this, "go to the mines." What do you have in mind and recall when you say

2 he would go to the mines?

3 A. Not the mines as such, the building of the mines, the mine

4 building. That is, the mine administration. Ostoja Marijanovic was the

5 manager, and he was one of the first people that I met because I drove him

6 around. Ostoja Marjanovic was the manager, if I remember well, and

7 Balaban, I also remember him. He was another engineer. There were about

8 five or six engineers who had worked in the mine and he went to see him

9 but I didn't accompany him there. I would either be in the municipal hall

10 or sit in the car.

11 JUDGE SCHOMBURG: Once again, did you ever go to Ljubija together

12 with Dr. Stakic?

13 A. No, I never went to Ljubija with him.

14 JUDGE SCHOMBURG: Did you ever go to Kozarac with him?

15 A. We never went to Kozarac, but we did go through Kozarac. We did

16 go through Kozarac, but not to Kozarac. We never went to Kozarac. There

17 was no need for that.

18 JUDGE SCHOMBURG: At what period in time was it, to the best of

19 your recollection, when you went to Kozarac?

20 A. I've never been in Kozarac. We never stopped there. We would

21 only go through Kozarac on our way to Banja Luka because the road goes

22 through the place. But I was never in Kozarac.

23 JUDGE SCHOMBURG: On this route, did you ever see destroyed

24 buildings, destroyed churches, destroyed mosques?

25 A. Yes, I saw that. As we would travel through, and I know even the

Page 14268

1 date more or less. That was the -- it seems that it was the 30th of April

2 when the two of us were travelling from Omarska to Prijedor, there were

3 barricades in Kevljani, which is right before Kozarac. And that is when

4 we went from Omarska to Prijedor. There were barricades on the road, and

5 20 soldiers with weapons were there. And we passed through. In front of

6 us was a Sarajevo car. And we passed through that morning at half past

7 8.00 on our way to Prijedor. And that day, the -- it seems that the

8 attack took place on Prijedor that very morning. I remember that because

9 I was in the municipal hall, and I was asleep when the attack happened

10 because there was a bed for me in the municipal hall. If I had to stay

11 late, then I would sleep there.

12 JUDGE SCHOMBURG: Is it possible that you are confusing dates?

13 Because you are mentioning the 30th of April.

14 A. May, the 30th of May, the 30th of May. That's when that was

15 because in April I wasn't working at all, as far as I can remember.

16 JUDGE SCHOMBURG: Apparently this special tour was in fact also

17 for you something special. Could you please go into some more details of

18 this tour you took that date around Kozarac on, as you stated, your way to

19 Banja Luka. What happened? Was your car controlled? If yes, by whom?

20 Were there any other problems?

21 A. They stopped us down there in the village of Kevljani. It's right

22 before Kozarac some 10 kilometres from Omarska. And the barricades with

23 iron rods had already been put up there. And that morning, as we went

24 through, the barricades were already on the road, and they stopped us

25 there. And there was a car there, an Audi 100, with Sarajevo plates was

Page 14269












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Page 14270

1 there. And I was behind it. They stopped that car, and we stopped behind

2 the Audi. They didn't ask for the papers. They let through the one

3 before us and then let us through. So that was that morning. And I

4 remember that the next morning, we couldn't get through because the

5 exchange of fire had started by then.

6 JUDGE SCHOMBURG: You stated "they didn't let us through," "they

7 stopped." Who were "they"?

8 A. They were wearing camouflage uniforms, had automatic weapons.

9 They were those Muslims. I couldn't recognise them because they all had

10 uniforms and green berets. They were Berets.

11 JUDGE SCHOMBURG: And then it would be your testimony the next day

12 you faced other problems. You said "We couldn't get through." What did

13 you do in this situation when you couldn't get through? Did you take

14 another route or what happened?

15 A. Around half past 1.00 that day, we could not get back from

16 Prijedor to Omarska. So we took a round about route through Petrovo Selo,

17 Maricka, and so on to get back to Omarska.

18 JUDGE SCHOMBURG: When visiting mines, did you also visit the

19 Omarska iron ore mine?

20 A. No, no. No. I never went to the Omarska mine, not even near it,

21 because we went through Maricka, which is on the other side to get to

22 Omarska.

23 JUDGE SCHOMBURG: Did you ever go to the Keraterm building?

24 A. No, never. I've never been to Keraterm.

25 JUDGE SCHOMBURG: When driving around the Prijedor town as such,

Page 14271

1 did you ever notice buildings destroyed in the war operations and where

2 was this?

3 A. That morning, at half past 4.00, I was asleep in the municipal

4 hall. But it was the 1st of June. The attack happened at half past 4.00.

5 One could hear a powerful detonation. Something serious had gone off.

6 And I jumped off the bed dressed up. I didn't know what was happening.

7 It was foggy, and there was rain. I remember there was drizzle. Black

8 smoke. Something was firing. The glass panes shattered on the windows

9 because that day, the municipal hall and the SUP were attacked. And the

10 hotel, I couldn't really see what was on fire. I could see that something

11 was burning towards the -- I could see this dense smoke coming towards the

12 municipal hall. But later on I learned that the hotel had been set on

13 fire, and the old hotel called Ribar, that was also on fire. But there

14 was gun fire. There were quite a number of dead people in front of the

15 municipal hall. I could see five or six policemen there dead. I was

16 watching through the window. It was lasting for quite a time. Many

17 people died in front of the municipal hall. They could not be helped

18 because there was a sniper. It was only around 10.00 or past 9.00 that an

19 ambulance car arrived. I could see through the fire and all that they

20 were picking up both the living and the dead and they took them away. And

21 only around 11.00 or 12.00 the situation calmed down slightly so that one

22 could see what was happening and it was then that I saw the hotel was on

23 fire. And it was like that.

24 JUDGE SCHOMBURG: Did you see the destruction of Stari Grad?

25 A. I didn't see Stari Grad because I stayed where I was. I dared not

Page 14272

1 come out. I stayed in the municipal hall because -- I didn't go to Stari

2 Grad. I didn't go anywhere from the municipal hall. I was in the

3 municipal hall all the time because there was gunfire. One could hear

4 detonations, and I never went anywhere.

5 JUDGE SCHOMBURG: In the aftermath of these special events, was

6 Dr. Stakic at all interested in seeing what had happened and asking you,

7 therefore, to drive him to these places?

8 A. Well, no. Like me, because he didn't dare. There was gunfire all

9 around. We were imprisoned, our 6 or 7, in the municipal hall, we simply

10 couldn't get out. Until noon we didn't dare put our heads out because

11 there were snipers firing all the time. There was chaos, and the police

12 was in the chaos so we dared not go anywhere.

13 JUDGE SCHOMBURG: Dr. Stakic at any point in time show interest in

14 what happened in the Omarska camp, in the Keraterm camp, in Trnopolje

15 camp, asking you "Let's go there and see what's happening there"?

16 A. No, as far as I know, I never went to any camp, Keraterm or that,

17 what's it, Trnopolje or Omarska. I was only once sent to take something

18 or drive a repairman to Trnopolje. That was when I went there once, and I

19 saw those civilians walking around the school and the culture centre. I

20 stayed there because the electricians were repairing something or not. I

21 can't remember exactly why I took those people to Trnopolje, but later on,

22 I saw people in Trnopolje. There were lots of them around the school,

23 around the culture centre, around the playground. There were 500 or

24 perhaps a thousand people, people were coming and going, passing through.

25 I don't know.

Page 14273

1 JUDGE SCHOMBURG: Coming back to the initial question, could it

2 happen that also other drivers were asked to drive Dr. Stakic?

3 A. I don't think so because I suppose he would have asked me to come

4 with him because I drove him around. I don't think that anyone else drove

5 him but me.

6 JUDGE SCHOMBURG: Where did Dr. Stakic live precisely in -- you

7 said you started the 17th of May, 1992. Yes, yes, that's right. That

8 day --

9 JUDGE SCHOMBURG: Where did he live precisely?

10 A. Exactly when I was there, he was living in Omarska.

11 JUDGE SCHOMBURG: Where in Omarska, please? The concrete address.

12 A. Well, there are no streets there. He was renting a place at those

13 two sisters. He was living with his family on the upper floor across the

14 street from Mile Rosic's house.

15 JUDGE SCHOMBURG: Across the street from Mile Rosic's house or

16 beside the house of Mile Rosic?

17 A. Next to Mile Rosic's house, right next to it. Just a low hedge

18 between them.

19 JUDGE SCHOMBURG: On the same side of the road. Correct?

20 A. Yes, yes, the same side. The same everything.

21 JUDGE SCHOMBURG: Did Dr. Stakic at any point in time move to

22 Prijedor?

23 A. After this attack on Prijedor and the rest, Stakic had a flat

24 somewhere around the hospital or the health centre. I don't know, but he

25 had a flat somewhere there behind the health centre.

Page 14274

1 JUDGE SCHOMBURG: Did you then pick him up in the morning from the

2 place behind the health centre and bring him back to this place in the

3 evening?

4 A. No. That was -- I don't really know where that flat is. He

5 walked to his workplace in the morning, and I made it from Omarska in

6 different ways because the car was in front of the municipal hall.

7 JUDGE SCHOMBURG: Did you ever drive with Dr. Stakic to Cirkin

8 Polje, the building of the Crisis Staff in Cirkin Polje?

9 A. I never took him to Cirkin Polje. I don't know if he went there

10 with somebody else. He didn't with me.

11 JUDGE SCHOMBURG: Did you ever go together with Dr. Stakic to

12 Sarajevo?

13 A. No, I've never been to Sarajevo.

14 JUDGE SCHOMBURG: A very practical question: When you had to

15 refuel your car, how did this take place? Where did you have to go?

16 A. We had coupons for fuel in Brezicani, and we could get the fuel at

17 all the petrol pumps in Prijedor. We would be issued with coupons and get

18 our fuel at a petrol station.

19 JUDGE SCHOMBURG: Who issued these coupons?

20 A. The official person, the cashier. He would issue it for 200 or

21 500 marks' worth, and you go there, you get your fuel, you come back, and

22 you settle all the accounts.

23 JUDGE SCHOMBURG: Who are these official persons you mentioned

24 just before? Where would you get these coupons or vouchers?

25 A. We would get them in the office upstairs, from the cashier's

Page 14275












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Page 14276

1 office. There were two cashiers in the financial department. There were

2 two of them. And they issued you. They either give you money in advance,

3 some down payment or coupons. You go there. You're given that. You sign

4 it.

5 JUDGE SCHOMBURG: To be quite concrete, was it in the office of

6 Mr. Slobodan Kuruzovic? I make reference to the witness testimony

7 transcript page 7537.

8 A. Slobodan Kuruzovic, I've never heard of him working in the

9 municipal hall. What I heard about him was that he was in Trnopolje.

10 That's when I heard about him.

11 JUDGE SCHOMBURG: What did he do in Trnopolje?

12 A. I don't know. All I heard is that he was sort of a manager of

13 that camp. It wasn't a camp, a reception centre or whatever.

14 JUDGE SCHOMBURG: Coming back to the vouchers, what was printed on

15 the vouchers? Who was issuing the vouchers? Was it the municipality, was

16 it the Crisis Staff, or what was it? What could you read on these

17 vouchers?

18 A. One could read "petrol," "petrol Brezicani" and these were the

19 vouchers which you could use to get the fuel and be issued with an

20 invoice. They could only be used for fuel. Nothing else.

21 JUDGE SCHOMBURG: Could you go to -- with these vouchers to any of

22 the petrol stations in Prijedor or the surroundings, or was this limited

23 to certain petrol stations in Prijedor or in the municipality? Or were

24 they valid all over Republika Srpska?

25 A. Only in Prijedor on the Banja Luka Road at their petrol station.

Page 14277

1 You couldn't use them anywhere else. There are two petrol stations at the

2 railway station, and this one here. And whichever had the fuel, that is

3 where we went.

4 JUDGE SCHOMBURG: So it would be the one -- we are aware that

5 there's at least one petrol station on Banja Luka Road, and your testimony

6 is that it would be the one close to the railway station. Correct?

7 A. No. There is a petrol station in Prijedor across the street from

8 the railway station, and there is this one on the Banja Luka Road. And in

9 Kozarac, also, there was a station that belonged to them. But it wasn't

10 operational because it had been put on fire.

11 JUDGE SCHOMBURG: Did you ever see wearing Dr. Stakic a uniform?

12 A. Stakic as a rule wore a suit. He usually wore a suit. At times I

13 saw him in a uniform, but there would be some troops, some recruits. When

14 they would be going, he would put the uniform then on, on such special

15 occasions, or when he went to lay a wreath down. He would wear a uniform

16 only on some official ceremonial occasions.

17 JUDGE SCHOMBURG: Isn't it true, as we heard it from several

18 witnesses, that there was a special period in time that staff members and

19 officials were asked and required to wear uniforms?

20 A. No, there wasn't such a request. Because, for instance, I was the

21 driver. I never had a uniform because it would not say so anywhere.

22 Nobody had taken a decision. We mostly wore civilian clothes as we drove

23 those cars. There were no ultimatums.

24 JUDGE SCHOMBURG: When wearing a uniform, did Dr. Stakic at the

25 same time wear a pistol?

Page 14278

1 A. I think that he carried a pistol on those occasions when he wore a

2 uniform. He had a pistol. So he had a pistol when he had a uniform. But

3 that happened seldom. It was very seldom that he put on the uniform. And

4 so he also had a pistol, a reserve one, because there were all sorts of

5 gangs around. One had to have a pistol.

6 JUDGE SCHOMBURG: Can you tell me why it was that Dr. Stakic would

7 have to go to, as you said, some troops, some recruits, when he went to

8 lay a wreath down? What was it that brought Dr. Stakic to visit the

9 military forces?

10 A. I don't know. I don't know what he had to do. It was up to me to

11 take him there when a wreath would be laid. Whether he was asked to wear

12 a uniform, I don't know. I only know that he wore a uniform very seldom.

13 He mostly wore very nice civilian clothes, a suit. He only wore a uniform

14 twice or three times as far as I can remember.

15 JUDGE SCHOMBURG: But leaving aside the question of uniform for

16 just a moment, what was it, why was it necessary to visit military forces?

17 A. I never drove any military forces. I don't know where they were.

18 I went to the army myself. When I drove him, we never visited the troops

19 or the military force. I was in the army myself later on, but I myself

20 never took him or anywhere to visit the military.

21 JUDGE SCHOMBURG: The trial stays adjourned until 11.00 sharp.

22 --- Recess taken at 10.33 a.m.

23 --- On resuming at 11.05 a.m.

24 JUDGE SCHOMBURG: Please be seated.

25 Mr. Stanar, during your testimony this morning, I had the

Page 14279

1 impression that related to certain periods of time, you were a little bit

2 confused, and therefore, I have to restart the line of questions once

3 more. Could you please tell us when leaving the area where you were no

4 longer welcome and coming then to the municipality of Prijedor, at which

5 point in time was it that you arrived in Omarska? And where did you live

6 in Omarska?

7 A. I lived in Omarska from the year 1960 up to this very day at the

8 address Prvomajska 147 in the centre of Omarska.

9 JUDGE SCHOMBURG: This morning, you mentioned that beforehand, you

10 were gainfully employed elsewhere. Correct?

11 A. Yes.

12 JUDGE SCHOMBURG: And this was -- yes, please.

13 A. I finished school in Omarska, that is, elementary school. As far

14 as I remember, it was in 1968. It was a long time ago. I was in Prijedor

15 in 1969, 1970, and 1971. And 1971, I started working in the mine for a

16 year. In 1973, I joined the army. In 1975, after the army, I left for

17 Slovenia where I stayed up until the year 1990. After the year 1990, when

18 I was fired in Ljubljana, which was due to the beginning of unrest in the

19 former Yugoslavia, Ljubljana decided to get rid of us, especially of us

20 from Bosnia. I was without work, so I returned to Prijedor. In Prijedor,

21 when I started working in 1990 and 1991, I worked as a haulier with my old

22 truck. Then when there was an opening in the municipality, I applied for

23 that job. I was sent by the employment bureau to start working there as a

24 driver. I've always been a professional driver. I was in Iraq for one or

25 two times. I am a professional driver, and that's why I was employed in

Page 14280

1 the municipality. I have worked as a driver for over 30 years now.

2 JUDGE SCHOMBURG: And please try to recall once again the period

3 of time of importance for us is not the time when you got the

4 aforementioned decision, but when did you actually start being a driver in

5 the municipality of Prijedor?

6 A. 17 May, 1992. I was issued a decision to start working as a

7 driver in the municipality of Prijedor. I have that paper at home. I

8 forgot to take it with me. I should have, but I can fax it to you.

9 JUDGE SCHOMBURG: One thing is a decision; another issue, when did

10 you actually start working? Was there maybe a period of test before you

11 started based on this decision as of the 17th of May, 1992?

12 A. As of May 17, for a month, I was on a trial period. That was

13 that. And that's the only thing I can tell you.

14 JUDGE SCHOMBURG: So let us please know where did you live in

15 Omarska when you came back from Ljubljana? How far was it away from the

16 house where Dr. Stakic and his family lived?

17 A. About 400 or 500 metres. I had my own house. I built my own

18 house in Omarska in 1982. My father also has his own house where I had

19 lived together with my father. He built that house in 1960, and I built

20 my house in 1982, and that's when I moved into my own house from my

21 father's house.

22 JUDGE SCHOMBURG: Did you during the period of time when first

23 coming back from Ljubljana, and then arriving in Prijedor, did you visit

24 sometimes your relatives Dr. Stakic and maybe a little bit further away in

25 the relationship, Milan Rosic?

Page 14281












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Page 14282

1 A. Yes. I knew Stakic from his university days, from his student

2 days. He would sometimes as a student come to visit my father. He was

3 living in Banja Luka, graduated from med school, and then he started

4 working -- I know that he worked in Omarska, in Prijedor, and in Teslic.

5 He worked as a doctor. Whenever he came to Omarska, whenever I came from

6 Slovenia, we socialised. We played football, we shot pools, and things

7 like that.

8 JUDGE SCHOMBURG: This morning, your testimony, page 6, line 6,

9 you mentioned: "Since I lived in Omarska and he lived in Omarska, he

10 would call me so if he could go back home."

11 Let us try to fix these dates where you would drive Dr. Stakic

12 from Omarska or back to Omarska a little bit more precisely. Was it days,

13 weeks, or months?

14 A. From 17 May up to the 1st or the 2nd June, I would regularly take

15 him from Omarska to Prijedor and back. After that, after the attack on

16 Prijedor, we no longer drove there because he lived in Prijedor. He had

17 an apartment there, whereas I travelled from Omarska to Prijedor.

18 JUDGE SCHOMBURG: What would be the route you took from Omarska to

19 Prijedor?

20 A. I would take the old road and a couple of days later, the only --

21 it was passable. But it wasn't safe. So I did what I could. I would

22 sometimes take my own car, sometimes I would drive with my colleague. The

23 situation was bad. Due to the situation, it was difficult and dangerous

24 to travel. There were all sorts of people along the road. There were

25 armed people, thieves, gangs. There were all sorts of people, and I was

Page 14283

1 really scared when I had to travel to Prijedor.

2 JUDGE SCHOMBURG: Is it correct that you travelled the route

3 through Lamovita, Kamicani, Kozarac, Kozarusa, Orlovaca?

4 A. Yes, these are exactly the places that I passed. And in Orlovci,

5 there was a checkpoint, a police checkpoint. There were always six or

6 seven people there. This is where the police manned a checkpoint, and

7 they checked everybody who entered or was leaving Prijedor. You couldn't

8 just go through. You had to wait because there was a checkpoint there.

9 JUDGE SCHOMBURG: This was a checkpoint manned by regular police

10 forces. Correct?

11 A. Yes, the regular police was manning that checkpoint.

12 JUDGE SCHOMBURG: And then following your testimony that as from

13 the 17th of May until approximately the 2nd of June, you would take

14 together with Dr. Stakic the same aforementioned route. Correct?

15 A. Yes.

16 JUDGE SCHOMBURG: Who was it who brought Dr. Stakic beforehand,

17 before the 17th of May from Omarska to Prijedor?

18 A. As far as I heard, I didn't work at that time. But I learned that

19 it was Dragan Grandic who drove him. He was also a driver in the

20 municipality. And he would also drive with Mile Rosic, the man who lived

21 next to him. He worked in Prijedor, and the two of them would travel in

22 Mile Rosic's car every day. When I started working, he stopped travelling

23 with these two, and I started driving him.

24 JUDGE SCHOMBURG: May I ask you, before testifying today here, did

25 you have any contacts with one of the parties, be it the Prosecution or

Page 14284

1 the Defence?

2 A. No, nobody paid me a visit. I was never with any of the parties.

3 I'm here for the first time. Nobody ever visited me.

4 JUDGE SCHOMBURG: Did you discuss your testimony beforehand with

5 other third persons such as Mr. Murselovic or Mr. Milan Rosic?

6 A. Mr. Murselovic found out that I would be travelling to The Hague;

7 and since he had been here before, he told me, you shouldn't have a

8 problem. You just go there and say whatever you know. I know that Mile

9 Rosic also testified here. I saw him once or twice after that. And

10 that's about all the people that I have seen. I haven't seen anybody

11 else.

12 JUDGE SCHOMBURG: Did you discuss during these meetings your

13 testimony and/or the previous testimonies of, be it Mr. Murselovic or

14 Milan Rosic?

15 A. No, they didn't tell me anything. I didn't ask them anything

16 either. I did not feel any need to ask them what had happened to them.

17 It is up to me to say what I know. That's why I did not find it necessary

18 to ask them anything.

19 JUDGE SCHOMBURG: Why was it that on page 9 of today's testimony,

20 line 21, 22, you started testifying about the 30th of April and the 1st of

21 May?

22 A. The 30th of April, as far as I remember, was when Prijedor was

23 attacked. Or was it on the 1st of May or -- between the 30th of April and

24 the 1st of May, I believe this was the attack on Prijedor. Maybe I'm

25 mistaken, but that's as far as I can remember. I don't know.

Page 14285

1 JUDGE SCHOMBURG: When you were in Omarska already at that time

2 waiting to be gainfully employed, were you aware about the so-called

3 takeover of Prijedor Municipality?

4 A. I was not informed about that. I was not interested in that. My

5 only concern was work and what I would be living on. And I was not into

6 politics at all. Only subsequently did I learn there had been a takeover

7 of power in Prijedor, and that would be that.

8 JUDGE SCHOMBURG: Did you know the role your relative Dr. Stakic

9 played in Prijedor Municipality before April 30th?

10 A. I knew that he was the vice-president of the Municipal Assembly

11 while the president was -- let me think. Cehajic. Cehajic was president,

12 and Stakic was vice-president. That's what I heard.

13 JUDGE SCHOMBURG: And who was president of the Assembly, the

14 then-Serbian Assembly after the takeover?

15 A. Believe me, I don't know. I don't know even to this very day.

16 JUDGE SCHOMBURG: Who was president of the Municipal Assembly when

17 you started your work as you told us on the 17th of May?

18 A. Milomir Stakic was appointed president as far as I know.

19 JUDGE SCHOMBURG: Did you drive ever with Dr. Stakic to Belgrade?

20 A. We went to Smederevo on two occasions. We were in Smederevo

21 twice. Two cars went to Smederevo. One was driven by Milorad Sipka, and

22 that car was a Golf, and us, representatives of the municipality, went

23 with them.

24 JUDGE SCHOMBURG: What was the purpose of these two visits to

25 Smederevo?

Page 14286

1 A. They didn't tell me anything. They didn't tell me why they went

2 there. There was Marjanovic, Sipka, Balaban, people from the mines. So I

3 suppose that their job was to discuss something to do with the mine, with

4 the iron ore. But they didn't tell me anything, so I don't know.

5 JUDGE SCHOMBURG: I have to come back to a very special occasion.

6 There is conflicting testimony, some discrepancies, from previous

7 testimonies. The concrete question is did you ever drive Dr. Stakic to

8 the Omarska camp? And maybe it can assist you, together with a

9 high-ranking delegation from Banja Luka and elsewhere.

10 A. No. While I drove, while I drove Dr. Stakic, he never went to

11 Omarska. You call it a camp. I don't know. We would go home to Omarska,

12 but he was never in the camp in Omarska. While I drove him, we were never

13 there in the camp.

14 JUDGE SCHOMBURG: You were not only the driver, but also a

15 relative to Dr. Stakic. Did you ever discuss the purpose of the camp and

16 the atrocities indisputably happened in these camps?

17 A. No, he never talked to me about this camp. This was never a

18 subject of our conversations while we were driving.

19 JUDGE SCHOMBURG: If a witness would testify - I make reference to

20 transcript pages 11.943 until 11.953, for example, if a witness would

21 testify that Dr. Stakic following the takeover, this would be as of the

22 30th of April, did no longer regularly come back to Omarska, what would be

23 your answer, if confronted with this witness?

24 A. I told you that after the attack on Prijedor, Mr. Stakic did not

25 go back to Omarska.

Page 14287












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Page 14288

1 JUDGE SCHOMBURG: But the problem we have based on your testimony

2 until now is, no doubt, whether it was the 30th of April, 1st of May, or

3 the end of May you're referring to. Just recently you mentioned the 2nd

4 of June. Is it possible that you confuse the two months?

5 A. No. I have not confused the dates. You suggested to me the 2nd

6 of June. It was you who suggested it was the 2nd of June. But this was a

7 mistake. In those months, I was -- I don't remember it well, but I know

8 that after the 30th that I've mentioned, then you mentioned the 2nd of

9 June which I accepted. But it wasn't the 2nd of June. No, it was not the

10 2nd of June I'm sure.

11 JUDGE SCHOMBURG: So what was the concrete date you drove the last

12 time Dr. Stakic from Omarska and back to Omarska?

13 A. It was the 2nd of May. When the attack on Prijedor happened,

14 after that, a few days after that, we did not take that route to Prijedor

15 any more.

16 JUDGE SCHOMBURG: Did you ever drive, to change the issue, other

17 members of the family of Dr. Stakic?

18 A. No, I never drove any member of the Stakic family except him.

19 JUDGE SCHOMBURG: Did you ever visit the entire family of

20 Dr. Stakic, being a relative to Dr. Stakic?

21 A. Well, yes, we paid each other visits. I would come to his place

22 and he'd come to mine. We visited one another now and then. But that was

23 before all this happened. Ever since his student days, when he got

24 married, and the war started in Teslic, then he came to Omarska. He and

25 his wife would come to my place, to our place, to see my wife and me. And

Page 14289

1 we were on good terms and so ...

2 JUDGE SCHOMBURG: Thank you. For the moment, I have no further

3 questions but I have to come back to this at a later period of time.

4 Judge Vassylenko, please.

5 JUDGE VASSYLENKO: Mr. Stanar, you said that you were fired from

6 your job at Ljubija mine because of your Serbian ethnicity. Who was the

7 director of the mine at that time?

8 A. That's a mistake, Your Honour. I didn't work in Ljubija. I did

9 start working in Ljubija, but where I was fired was Ljubljana, not

10 Ljubija. But before I went to do my military service, I worked in

11 Ljubija, but that was a different thing. It wasn't the mine. I worked

12 there with the fire place, and that is where I worked for about a year or

13 13 months and 11 days. And after that, in 1973, I went to do my regular

14 military service.

15 And after that, in 1975, I went to Ljubljana. And I worked there

16 until 1990. And that is when I was fired, in Ljubljana, because of all

17 those unrests. I then was allowed to return to Bosnia.

18 JUDGE VASSYLENKO: And when you returned to Bosnia, when did you

19 start to work?

20 A. I had a truck. I was a haulier as of 1990, as of May. From 1990

21 to 1991, I worked as a haulier. And after that, his story, that is, this

22 job at the municipal hall turned up, and I accepted to be a driver for the

23 municipal hall.

24 JUDGE VASSYLENKO: And you worked as a driver in the Prijedor

25 Municipality until what time, what period of time?

Page 14290

1 A. Until the 20th of October, 1992. After that, I reported to a

2 unit.

3 JUDGE VASSYLENKO: Sorry, you reported?

4 A. I received a summons from the military authorities, from those

5 chief ones, and they requested that I join the army. The Ministry of

6 Defence.

7 JUDGE VASSYLENKO: And in your testimony, you state that you

8 worked as a driver of the municipality until June 1992.

9 A. No, the second -- no, I didn't say that. That must be a mistake.

10 That was Omarska/Prijedor as I drove. But I worked until 1992, that is,

11 until October as a driver. After 1992, I stopped working. I joined the

12 army. That's a mistake.

13 JUDGE VASSYLENKO: And then after the army, you again --

14 A. After the army, 1996, no, I've -- remembered, it wasn't 1995. [As

15 interpreted] 1996 it was. After February, that's when I returned again

16 to be the driver for the municipality, and that's what I do to this day,

17 and I still drive around the president, Murselovic.

18 JUDGE VASSYLENKO: At that time in 1996, who was the president of

19 the municipality?

20 A. It was Kurnoga. And after Kurnoga, Stakic became the president

21 once again.

22 JUDGE VASSYLENKO: So you again became the driver for Dr. Stakic,

23 yeah?

24 A. No, no, I wasn't his driver any more.

25 JUDGE VASSYLENKO: But you told that the president of the

Page 14291

1 municipality was Kurnoga, and then after Kurnoga, Dr. Stakic again was

2 elected as president of the municipality.

3 A. I don't know the date. I don't remember that. I know that I no

4 longer drive him -- I started driving when he was not the president any

5 more as far as I can remember.

6 JUDGE VASSYLENKO: Okay. I have no more questions.

7 JUDGE SCHOMBURG: Let me just continue for one other question.

8 You mentioned that previous to the takeover, sometimes Dr. Stakic was

9 taken by Mr. Rosic to Prijedor. This Mr. Milan Rosic testified the 6th of

10 February, 2003, this is page 11.946 of the transcript, when asked by the

11 Defence: "Can you tell us, sir, did at any time after April 30th, 1992,

12 did you have an opportunity to drive Dr. Stakic to the city/town of

13 Prijedor"? The answer was: "No, after that I didn't. A few days later,

14 I didn't really see him." End of quote, just for the purpose. It was the

15 next-door neighbour, he didn't see him any longer.

16 Starting the quote again: "And then later on, I heard that he had

17 an official driver who drove him around, and that he had an official car."

18 Question: "Do you know, sir, the name of that driver that was officially

19 driving Dr. Stakic around?" Answer: "Yes, Petar Stanar who still works

20 in the municipality as a driver."

21 So how is it possible that the next-door neighbour can't see any

22 longer Dr. Stakic in Omarska and that your testimony today is that at that

23 period of time, you drove on a daily basis Dr. Stakic from Omarska to

24 Prijedor?

25 A. He drove him probably until the date when I started driving him.

Page 14292

1 I know that Dragan Grandic, he's a driver who also drove him several

2 times. But after the 17th, I started driving him, and I went on doing

3 that.

4 JUDGE SCHOMBURG: Even though it appears - we have to find the

5 truth - if it appears that at that time, Dr. Stakic did no longer commute

6 on a daily basis from Omarska to Prijedor.

7 A. He didn't travel as of the 2nd or the 3rd. He stopped travelling.

8 Until that day, I drove him regularly to Omarska and back. After that, he

9 lived in Prijedor. We worked normally. I would come, I would drive, and

10 went on driving him, until October.

11 JUDGE SCHOMBURG: He didn't travel as of the 2nd or 3rd of which

12 month, please?

13 A. Not the 2nd of March, but the 2nd of June, after the attack on

14 Prijedor. For two or three days I didn't see him after that. After that,

15 he moved house to Prijedor. He had a flat somewhere behind the health

16 centre there.

17 JUDGE SCHOMBURG: Thank you. We have to come back to this later.

18 Judge Argibay, please.

19 JUDGE ARGIBAY: Good morning, sir. I only have a small question.

20 Today we heard you -- you told us on page 35, line 14, that you were

21 having conversations with Dr. Stakic while we were driving. That's your

22 quote. What about? Can you tell me what -- which were the subjects of

23 these conversations while you were driving?

24 A. Well, the subject, I'm not into politics, I know nothing about

25 politics. I didn't want to know about it. It was mostly what we had done

Page 14293












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13 English transcripts.













Page 14294

1 for the previous weekend, played football, had a walk, talked. Secondly,

2 we never discussed politics. I don't go into it because I know nothing

3 about it. And I didn't want to burden him with that, to ask him something

4 unnecessary. I didn't think I should ask him about that.

5 JUDGE ARGIBAY: Were you asked to drive the car taking some

6 important visitors around Prijedor, Prijedor town or Prijedor

7 Municipality?

8 A. No, no. I didn't ever. I usually did the same thing. When he

9 was in the office, I drove everybody else, the vice-president, the

10 secretary, Travar, repairmen, whoever I was ordered to drive. I went

11 wherever I was told to go. At times, two or three days would pass by

12 without me driving him because I drove others, and that is how we always

13 did it. We were five drivers there, and we all did everything. And if he

14 went somewhere, then I would be issued with a travel order and take him

15 there. But otherwise, I worked as all the other drivers. We had no

16 privileges or anything. We all did the same kind of jobs.

17 JUDGE ARGIBAY: I probably wasn't very clear, but let me put an

18 example. If there was a celebration in Prijedor town or an official

19 ceremony, and some visitors were coming from other municipalities, say,

20 Banja Luka or Sanski Most or whatever, were you asked, asked to drive

21 these persons around to the ceremony or taking them back to the

22 municipality or whatever could have happened?

23 A. No. It wasn't mine to do it. Everybody who came to Prijedor had

24 his own driver, and everybody went there in their own cars. So whenever

25 they came to Prijedor, they would meet in the president's office when they

Page 14295

1 would come to Prijedor, but nobody drove anybody anywhere because they all

2 had their own drivers.

3 JUDGE ARGIBAY: Thank you. I have no further questions.

4 JUDGE SCHOMBURG: As to the fact that we are in the phase of

5 rebuttal, the first line of question would be for the Prosecution now,

6 please.

7 MS. SUTHERLAND: Thank you, Your Honour.

8 Questioned by Ms. Sutherland:

9 Q. Sir, the dates have been differing as you have been giving your

10 testimony this morning. I want to try and place events in relation to

11 things that happened in the municipality. But first, you said that you

12 returned to the municipality around May 1990. Is that correct?

13 A. No, I didn't return to the municipality in 1990. In 1990, I

14 returned from Ljubljana. I said I returned to Prijedor, that is, home, in

15 Omarska. And in 1990, I became a haulier. I had a truck, and I had the

16 authorisation for 1991 to work as the haulier. It has not been written

17 down accurately. I told you everything as it was.

18 Q. Sir, can you please listen to my question. If you don't

19 understand my question, can you ask me to clarify it. My question was did

20 you return to the Prijedor Municipality from Ljubljana around May 1990?

21 That's correct, isn't it?

22 A. Thereabouts, yes, thereabouts. Not quite, yes, thereabouts.

23 April, May, thereabouts. I didn't look up the dates, but there is a --

24 I've got a contract which shows when I started working as a haulier.

25 Q. And you said that after that time, you heard that Cehajic became

Page 14296

1 president. This is Professor Muhamed Cehajic?

2 A. I didn't know anything about him because I had nothing to do with

3 the municipality. I was a haulier. And it was -- I'd never tried for

4 find anything about him. I was a haulier.

5 Q. Please pause there. I want you to answer the questions that I ask

6 you. And the question was, was it Professor Muhamed Cehajic that you

7 heard took over -- became president of the Prijedor Municipality? It's a

8 yes or a no answer.

9 A. No, I didn't hear that he had become the president. I didn't know

10 it.

11 Q. You said in your testimony earlier that you heard that Cehajic was

12 president. My question was, was it Professor Muhamed Cehajic, and this

13 was at the time that Dr. Stakic became the vice-president.

14 A. That is a different question. When that Cehajic was president, it

15 was in 1992, isn't it? But while I worked, I didn't know Cehajic or the

16 other one. That's a mistake. A driver, a haulier, has nothing to do with

17 the municipality. It's another matter to be --

18 Q. Pause, pause. I'm simply asking you whether the person - I'm not

19 asking whether you know him personally. I'm asking you whether the person

20 that you heard was president, you mentioned a person Cehajic. I'm asking

21 you simply, was it Professor Muhamed Cehajic?

22 A. I don't know. I don't know whether he's professor.

23 Q. I'll move on. You said that on the 17th of May, 1992, you began

24 working as a driver in the Municipal Assembly, and you did that until the

25 20th of October, 1992. Yes?

Page 14297

1 A. Yes, that is accurate. It's accurate, yes.

2 Q. You mentioned this morning that on the 30th of May, when you were

3 driving Dr. Stakic from Omarska to Prijedor at around 8.30 a.m. in the

4 morning, you were stopped at barricades near Kevljani. Correct?

5 A. No. No date, that was the attack -- yes, it is correct. Yes,

6 yeah. It is. 8.30, Kevljani, we started for Prijedor at 8.30.

7 Q. Right. You said the date was the 30th of May, but I'm wondering

8 whether you are confused about the date. Do you recall the attack on

9 Kozarac on the 24th of May, 1992?

10 A. Yes, yes, I do. I forgot that. Yes, I realise -- see, I forgot

11 it. The 24th, yes, seven days before the attack on Prijedor. Yes, that's

12 true.

13 Q. And when you were stopped at the barricades at 8.30 in the

14 morning, was this before the attack on Kozarac?

15 A. The attack on Kozarac happened later, from what I heard. About

16 1.00 or half past 1.00, and we passed through at half past 8.00 in the

17 morning.

18 Q. You testified that you drove Dr. Stakic to work from Omarska, from

19 the 17th of May until the attack on Prijedor when he moved into an

20 apartment behind the medical centre.

21 A. Yes, yes that's right. That's true.

22 Q. Did you ever go to this apartment?

23 A. No, I never drove there.

24 Q. You said that around the 20th of June, 1992, you swapped cars with

25 Mile Bogunovic, and you started driving the Mercedes.

Page 14298

1 A. Yes, yes, that's true. I swapped cars because he had a better

2 car. My car was old. We swapped. He gave me his car, and I gave him

3 mine.

4 Q. So up until that time, whenever you drove Dr. Stakic, you were

5 driving the Jetta, and from the 20th of June onwards, you always drove him

6 in the Mercedes?

7 A. Yes, I drove him in a Mercedes from then on.

8 Q. You said a moment ago that you drove other people around, the

9 vice-president, Mr. Travar. When you would drive them around, would you

10 drive them in the Jetta and leave the Mercedes in case Dr. Stakic needed

11 to go somewhere?

12 A. No, unless there was -- unless agreed otherwise, I drove everybody

13 in the Mercedes ever since I got that Mercedes. I didn't change cars

14 ever.

15 Q. You said that you received fuel coupons. Did you see who signed

16 them?

17 A. No, I didn't see who signed them. But the coupon is a coupon is a

18 coupon. It has a stamp and seal, and it says what the value is, and

19 petrol, nothing else. And there were those of 50, 100, 20, and 10.

20 Q. Did you ever fill your car up at the petrol station in Tukovi?

21 A. No, I never went to get fuel in Tukovi. I did in Brezicani, down

22 there where they have the depot, because at times, there was no fuel. So

23 we got the fuel directly from there when the stations were out of it.

24 Q. You testified that you drove Dr. Stakic to lots of different

25 institutions. Did you ever drive him to the Kozarski Vjesnik, Radio

Page 14299












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13 English transcripts.













Page 14300

1 Prijedor offices?

2 A. Radio Prijedor, he went there, yes. Kozarski Vjesnik, no.

3 Radio -- he went to the radio station when they invited him several times.

4 Q. How often would you drive him to the Radio Prijedor offices?

5 A. A few times.

6 Q. Once a week, twice a week?

7 A. Every fortnight I'd say.

8 Q. Did you ever drive him to the SDS offices?

9 A. I don't know where that office is. I don't even know. I never

10 asked, and I don't know where that office is. Because I know nothing

11 about those parties, and I don't know what party he was a member of. It

12 seems that he was a radical in my interpretation.

13 Q. Did you drive him to the building across from the Keraterm camp?

14 A. I never drove him to Keraterm, to that building.

15 Q. No, please listen to my question. Did you drive him to a building

16 which was opposite the Keraterm camp?

17 A. No, I never drove him to that building.

18 Q. You stated that Stakic wore a uniform when he went to see the

19 troops or the new recruits. Did you drive him to the Zarko Zgonjanin

20 barracks?

21 A. No, I didn't drive him up there.

22 Q. Where did he see the troops?

23 A. The troops, he didn't visit the troops anywhere. It was all the

24 army, and I mixed them up because the troops, the young ones drive around

25 there. But it wasn't like that then. It was the troops -- everybody was

Page 14301

1 the troops then. And those were the events, the day of the combatants

2 day, laying wreaths on a monument and one dresses up.

3 Q. What did you mean this morning when you said he would wear a

4 uniform when he went to see troops or new recruits?

5 A. I don't understand. I mean, the uniform, well, one put it on an

6 important date, when somebody -- I said, when wreaths are laid, when

7 somebody is invited to something. That's when one puts the uniform on.

8 JUDGE SCHOMBURG: Sorry to interrupt. The Trial Chamber, after

9 deliberation, decided that it would be necessary now to give a warning to

10 the witness.

11 Rule 91 of our Rules of Procedure and Evidence provides that the

12 Chamber proprio motu may warn a witness of the duty to tell the truth and

13 the consequences that may result from a failure to do so. The maximum

14 penalty for false testimony under solemn declaration shall be a fine of

15 100.000 Euros or a term of imprisonment of seven years or both.

16 A number of discrepancies in your own testimony, and in

17 conjunction with other testimonies, leads us to this warning. And we

18 really have to ask you to tell us the truth and nothing but the truth. So

19 please beware that if you so want, we may confront you with the one or

20 other video telling us something else that is in contradiction with your

21 testimony. But please continue, Ms. Sutherland.

22 MS. SUTHERLAND: Thank you, Your Honour.

23 MR. LUKIC: Excuse me, Your Honour, because this is not the

24 Defence witness, I was reluctant at that time to intervene, and I would

25 like my learned colleague to say the page number and the line number when

Page 14302

1 she puts in front of the witness what he said. And from the page 27, line

2 9, in the transcript, it says some troops, some recruits, but at that

3 time, the witness said only "the recruits," meaning new soldiers.

4 JUDGE SCHOMBURG: I don't recall this, and we have the transcript

5 before us, and you quoted quite correctly from the transcript. Please

6 continue, Ms. Sutherland.


8 Q. Sir, what events would Dr. Stakic wear a uniform to?

9 A. Well, I've just told you, he would put a uniform on on very few

10 occasions. I only saw him in a uniform very rarely. When there was

11 certain events, he would wear that uniform, and I didn't lie when I say

12 that. This is the truth. He wore the uniform very rarely, only for

13 official things. That's when I would see him wearing the uniform, and

14 that is that.

15 Q. Sir, again, please listen to my question. My question was what

16 events would Dr. Stakic wear a uniform to? What are the official

17 occasions that he wore a uniform to?

18 A. He would wear a uniform to receive a military delegation or when

19 he would lay flowers on the monument or when he would go to the barracks.

20 That's when he would wear a uniform.

21 Q. How often did he go to the barracks?

22 A. Very seldom. I saw him only a few times when he went to the

23 barracks.

24 Q. When was this, the time frame?

25 A. I don't remember the dates. In any case, I would drive him there,

Page 14303

1 and I would wait in the car for him to come back after having had his

2 conversation there.

3 Q. Did you ever drive him to Benkovac?

4 A. No, I was never in Benkovac.

5 Q. You said that Dr. Stakic wore a pistol when he wore a uniform.

6 Did you see him carry a pistol when he was wearing civilian clothes?

7 A. No. When he wore civilian clothes, I didn't see him carrying a

8 pistol.

9 Q. Who gave you your pistol?

10 A. I got it from the municipality. Actually, they sent me to the SUP

11 to get the official pistol.

12 Q. When was this?

13 A. After the 30th.

14 Q. What sort of a weapon was this?

15 A. It was a 7.62 pistol, a military-type, a TT762. That's what it

16 says on it, an old model.

17 Q. When you say after the 30th, do you mean after the attack on

18 Prijedor?

19 A. Yes, yes. It was after the attack on Prijedor that I received

20 this pistol.

21 Q. Judge Argibay asked you a question about the conversations that

22 you had with Dr. Stakic when you were driving around. And you said that

23 they were mostly about playing football or what happened on the weekend,

24 and they didn't have anything to do with politics. During the five months

25 that you drove Dr. Stakic around, did you ever ask him if he knew what

Page 14304

1 happened to Muhamed Cehajic, the person whose job he had taken over?

2 A. No, I didn't ask him about that. I didn't know the man. I don't

3 know. I didn't ask him anything about that.

4 Q. If you didn't ask him, did Dr. Stakic ever mention it?

5 A. No, he didn't mention any of his -- he didn't talk to me about

6 that.

7 Q. Did you ever drive Dr. Stakic to Sanski Most?

8 A. I was never in Sanski Most.

9 Q. Do you know if any of the other four drivers drove Dr. Stakic to

10 Sanski Most?

11 A. As far as I know, and as far as I've heard, nobody ever took him

12 to Sanski Most.

13 Q. At page 13 this morning, you said that you drove Dr. Stakic to the

14 Banja Luka Municipal Assembly building where he was -- I think you said

15 where he was needed. How often did you go to Banja Luka?

16 A. Not often, a couple of times I went to Banja Luka.

17 Q. Do you recall whether it was in May or June or July? Was it

18 shortly after you started work as a driver?

19 A. I don't remember the exact dates. But it was on a couple of

20 occasions that I took him to Banja Luka. When, I don't know. Whether it

21 was soon after or later on, I don't remember.

22 Q. Did Dr. Mico Kovacevic, the president of the Executive Board, did

23 he ever accompany you to Banja Luka with Dr. Stakic?

24 A. No, he didn't go to Banja Luka with us. That is, when I drove

25 him.

Page 14305












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13 English transcripts.













Page 14306

1 Q. When you drove from Prijedor to Banja Luka, you would have driven

2 past the Keraterm. That's correct?

3 A. I learned later on subsequently where Keraterm was. Yes, it is on

4 that road some hundred or two hundred metres away from that road. And

5 obviously, yes, we did pass by that when we went to Banja Luka.

6 Q. You said earlier that you saw destruction of houses in Kozarac on

7 your way to Banja Luka. Did you see the same destruction in the villages

8 next to Kozarac, that is, Kamicani and Kozarusa?

9 A. I couldn't, because as we were passing through Kozarac and

10 Kamicani on the way to Banja Luka, one could see that there were houses

11 destroyed and burned down if they were close to the road. And that is

12 what I saw.

13 Q. Did you drive Dr. Stakic to Pale on any occasion?

14 A. I was never in Pale.

15 Q. Do you recall a delegation from Banja Luka attending the Prijedor

16 Municipal Assembly building in mid-July 1992?

17 A. Only if that was the delegation that I've already mentioned, that

18 stayed in the Prijedor hotel in 1992. That was Karadzic, Biljana, and

19 that third man. That is the only delegation that I know visited Prijedor.

20 Maybe that was that delegation. And I've mentioned that delegation. I'm

21 not sure of the date. It was in 1992. The third man was Momir Krajisnik

22 [As interpreted].

23 Q. Was that towards the end of your -- of you working as a driver or

24 earlier?

25 A. Thereabouts, afterwards. I can't remember very well, but I know

Page 14307

1 that I was there, and that is sure. But I don't know the date. It was in

2 1992, and I'm sure of that. It was certainly in 1992.

3 Q. And you don't recall any other delegation coming from Banja Luka

4 around the middle of July?

5 A. I don't remember. I don't know what you're talking about.

6 Q. Do you know Predrag Radic?

7 A. No.

8 Q. Do you know Stojan Zupljanin?

9 A. I don't know him either. I heard of all these people later on. I

10 didn't know them at the time.

11 Q. Did you hear from any of the other four drivers about a delegation

12 coming from Banja Luka and visiting the Omarska camp in mid-July 1992?

13 A. I didn't hear that from any of the drivers. And I personally

14 cannot remember any such thing.

15 Q. Where was the janitor's office?

16 A. At the same place on the left-hand side as you enter the town

17 hall, the municipal building.

18 Q. So it was on the ground level?

19 A. Yes.

20 Q. And if a lot of luxury vehicles pulled up outside the front of the

21 municipal assembly, would you recall something like that?

22 A. I don't know. There were always vehicles, a lot of vehicles were

23 always parked there. So it's very hard to recall.

24 Q. And these were luxury vehicles?

25 A. All the vehicles are luxury vehicles, and there are a lot of them

Page 14308

1 parked in front of the municipal building at all times.

2 Q. When people who were driven to the municipal building, when they

3 came to the building, where did their drivers go? Did they wait in the

4 janitor's room?

5 A. They would mostly remain sitting in their cars, or they would come

6 to the basement. There's a cafe there. They would have a cup of coffee.

7 In the janitor's room, there's just the janitor -- actually, two of them,

8 two janitors. And drivers would either sit in their cars or go downstairs

9 to the basement to have a cup of coffee.

10 Q. You testified earlier this morning, and I don't recall the page,

11 that the drivers got their instructions from your superior, Zeljko

12 Grahovac, in the janitor's room. Is that correct?

13 JUDGE SCHOMBURG: Page 14, line 18.

14 MS. SUTHERLAND: Thank you, Your Honour.

15 A. Yes.

16 THE INTERPRETER: Can the witness repeat that answer.

17 A. Are you asking me?


19 Q. You testified earlier this morning that you received your

20 instructions in the janitors' room. Is that correct?

21 A. Zeljko Grahovac had his own office on the first floor. I would be

22 sitting in the janitors' office. When he needed to give me instructions,

23 he would call me upstairs to his office. So he would not come to the

24 janitors' office to give me instructions. It was the other way around. I

25 would go upstairs.

Page 14309

1 Q. But you and yourself and the other four drivers would spend your

2 time, when you weren't sent on an assignment, in the janitors' office; is

3 that correct?

4 A. In the basement drinking coffee, in the janitors' office, or in

5 the front of the building sitting in the car.

6 Q. Right. When you were downstairs in the basement having coffee,

7 did you see drivers from any other municipalities, for example, Sanski

8 Most, Bosanski Novi, Bosanska Krupa, Banja Luka?

9 A. I didn't know these drivers. I was a new, a new driver. And I

10 did not know these drivers well. I only knew those four who worked with

11 me.

12 Q. Even if you didn't know them personally, did you see drivers from

13 other municipalities who had brought people to the Prijedor Municipality

14 building?

15 A. I saw drivers, but I didn't know them personally. I didn't know

16 any other drivers but the ones whom I got to know when I joined them.

17 Q. You mentioned Drago Mandic and a person named Mile Bogunovic. And

18 you mentioned a person named Miro. Do you recall now his last name?

19 A. I remember Miro Bjelanovic and this is not Dragan Mandic, but

20 Dragan Grandic, Grandic. And Miro Bjelanovic.

21 Q. You also mentioned a person named Ergelic. Do you also recall his

22 first name?

23 A. I can't remember, but he left for America. He stayed on after me,

24 and then left for America.

25 Q. Do you recall seeing foreign journalists visit the Municipal

Page 14310

1 Assembly building in -- around the beginning of August 1992?

2 A. I was not aware of that.

3 Q. Did you hear from any of the other four drivers about these

4 international journalists visiting Prijedor?

5 A. No, I didn't hear anything from them.

6 Q. Did you drive Dr. Stakic to Maricka village for the second

7 anniversary of the SDS around the end of July, beginning of August 1992?

8 A. I did not take him to Maricka.

9 Q. Did you ever drive Dr. Stakic to the Manjaca camp in the Banja

10 Luka Municipality?

11 A. We were never in Manjaca in Banja Luka.

12 Q. Around the 20th to the 25th of August, did you ever drive

13 Dr. Stakic to the military barracks in Banja Luka or in Doboj?

14 A. I was never in Doboj or in the military barracks in Banja Luka.

15 Q. How often would Dr. Stakic leave the Municipal Assembly building

16 in the car?

17 A. Rarely. He would seldom go places. He would spend more time in

18 the municipality, and people would come to see him. Only when we had to

19 go to Banja Luka or to Smederevo, then I would receive an order, and I

20 would take him. And that's where he would go out for a day or two days.

21 Q. Did you ever pick up Dr. Stakic from the SUP building? I'm sorry,

22 it's across the road.

23 A. No.

24 Q. Withdraw that question.

25 A. It's across the road.

Page 14311












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Page 14312

1 Q. Did you ever pick him up from the fish restaurant near the

2 hospital, the restaurant called Oskar?

3 A. I did go there on several occasions when he would have lunch

4 there, I would go to Oskar.

5 Q. Who were the people that he would be having lunch with on the

6 occasions you went to pick him up?

7 A. I mostly stayed in the car. I didn't get out of the car. And I

8 didn't see the people who he was sitting with. And mind you, I hadn't

9 been there for 20 years, and I didn't know people very well. I knew a few

10 people who worked with him in the municipality, and I know that he had

11 lunch with them in Oskar. Sometimes people from Zitopromet, he would go

12 to see the director of that company, Mr. Vasa Cvijic, and he would

13 sometimes have lunch with him as well.

14 Q. Did you ever take or pick up Dr. Stakic from the Tri Asa

15 restaurant in Omarska?

16 A. Yes, on several occasions, he went there to have lunch. When we

17 were returning from Banja Luka on several occasions, we would have lunch

18 there.

19 Q. Who else did you see Dr. Stakic having lunch with in the Tri Asa

20 restaurant?

21 A. The people he travelled with, and there was also the boss of that

22 restaurant, Nijaz Gazic [phoen], and very few other people. Maybe

23 sometimes Nedjo Delic. He is the owner of Evropa. We would sometimes go

24 to his place, sometimes for lunch or dinner. These were the two

25 restaurants which were open, and where you could have either breakfast or

Page 14313

1 lunch. There very few restaurants open in Prijedor, maybe two or three

2 more.

3 Q. You said earlier this morning at page 31 that you used to shoot

4 pool with Dr. Stakic. Who were the other persons that you both played

5 with?

6 A. Mostly my colleagues from Omarska, my neighbour Novo Skake married

7 the son of the boss. Mostly the colleagues that we knew. There was a

8 pool table in Tri Asa, and on Saturdays and Sundays when we didn't work,

9 we would shoot some pools there. And there were very few places where you

10 could go out to and spend time.

11 Q. Did Simo Drljaca play pool with you?

12 A. Simo Drljaca was not with us at that time. I didn't know him at

13 that time. It was only later on that I found out who Simo Drljaca was. I

14 met him later on, and then they told me, well, this is Simo Drljaca.

15 MS. SUTHERLAND: Your Honour, this would be a convenient time.

16 JUDGE SCHOMBURG: The trial stays adjourned until a quarter to

17 1.00.

18 --- Recess taken at 12.28 p.m.

19 --- On resuming at 12.51 p.m.

20 JUDGE SCHOMBURG: Please be seated. And please continue,

21 Ms. Sutherland.

22 MS. SUTHERLAND: Thank you, Your Honour.

23 Q. Sir, besides the 7.62 millimetre pistol, were you given any other

24 weapons?

25 A. No, I wasn't given any other weapon. That was the only one I had.

Page 14314

1 Q. You mentioned that you went to Smederevo on two occasions with

2 Mr. Marjanovic. Is that in Serbia?

3 A. It is, yes. Via Belgrade, you go through Belgrade, and then

4 Smederevo comes after it. It's in Serbia.

5 Q. Where did you go in Smederevo?

6 A. The hotel was -- the steel works in Smederevo. I don't know where

7 that is. I think it's Smederevo, some rail carriages, steel works,

8 something like that. I didn't go in. I was in the hotel.

9 Q. I want to turn now to the Municipal Assembly. Can you tell the

10 Court what you did on a normal day. You arrived at work at 7.00 a.m.

11 What did you do after that?

12 A. Well, you have your coffee. If there is nothing to do, then you

13 wait either in the cafeteria downstairs or at the janitor's, drop by. If

14 there is something to do, perhaps I'm given the instruction to drive that

15 person, so I go, I come back. And then 10 or 15 times a day, take the

16 cleaning woman there, or take the janitor, because there's always some

17 problem here, some problem there. Always lots of work.

18 Q. Where were you taking them?

19 A. Well, if something's wrong, to have it repaired, or I take the

20 mechanic to repair it. Or if need be, if necessary, I take somebody to

21 the bank. Or if one has to go and get coupons, then I go and get that.

22 So whatever there was to do, I had to be there, and I had to go wherever

23 they sent me.

24 Q. Who did you drive the most in the Municipal Assembly building?

25 What person?

Page 14315

1 A. Well, I didn't keep a record. I drove people. I was at the

2 disposal of everybody who worked in the municipality -- in the Municipal

3 Assembly.

4 Q. Did you act as a courier and deliver messages?

5 A. No, the messenger was a messenger, and he's got his job. I only

6 drove.

7 Q. Who was the messenger?

8 A. I can't remember who was the messenger then. I know who it is

9 now, but I can't remember who it was then.

10 Q. Did you ever have to deliver documents to anybody?

11 A. Nothing important, no, I didn't have to do it. Always something

12 trivial, I didn't have anything important to take to anyone.

13 Q. Would you say that you were busy for most of the day?

14 A. Well, at times, there was more work; at times, there was less

15 work. At times, there wasn't really much to do. So sometimes there was a

16 lot of work, and sometimes there wasn't. So you sit and wait.

17 Q. And this is the same for the other four drivers?

18 A. Same, same. We all did the same kind of thing.

19 MS. SUTHERLAND: I have no further questions, Your Honour.

20 JUDGE SCHOMBURG: Let's first turn to the unanswered questions.

21 Further questions by the Court:

22 JUDGE SCHOMBURG: On page 48, you were asked, line 12, "What are

23 the official occasions that Dr. Stakic wore a uniform to?" Answer: "He

24 would wear a uniform to receive military delegations."

25 What kind of military delegation, composed of whom?

Page 14316

1 A. Well, I didn't mean that. Now, it turns out that that was that

2 way. But it was the welcoming party. When one says military delegation,

3 it's when the army is celebrating something or when there is a review.

4 That's what I meant. Nobody else. When the army has its day, its

5 celebration, that's what the delegation -- that's what one calls a

6 delegation. I don't understand anything else. So that is that

7 delegation. They get together, and they take flowers there and that's it.

8 I didn't mean anything else.

9 JUDGE SCHOMBURG: But these were your own words "military

10 delegation." On what level?

11 A. Well, that's how I said, military delegation. Since I was with

12 the army later on, when somebody more important comes, so when one of the

13 superiors comes, that's what I meant.

14 JUDGE SCHOMBURG: Who were those superiors and superior to whom?

15 A. I don't know whom do you mean? What superior officers? Stakic

16 went, for instance, to visit them. If he went to the barracks, he would

17 go there. And if there was a review, then that was that. That's what is

18 called a delegation. These are the seniors that I meant, commander, his

19 deputy, if that is what you had in mind, that's it.

20 JUDGE SCHOMBURG: It's not what I have in mind. But I want to ask

21 you whom did you see there? Whom did Dr. Stakic meet there that you call

22 military delegation, superiors?

23 A. Well, I'd take him there, and I'd stand -- a military delegation

24 is how shall I put it, the commander of the barracks. That's the military

25 delegation, the barracks commander. Right, so that is where the review

Page 14317












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Page 14318

1 was and where people was lined up, and there was nothing else but that.

2 JUDGE SCHOMBURG: Who was the barracks commander?

3 A. I don't know. Perhaps it was Rajlic. I don't know. I didn't

4 know those people. It seems to me -- I think it was Rajlic. Rajlic,

5 Rajlic. Or Zeljaja, or Radmilo Zeljaja. He was, too. That's what I

6 learned. I didn't really know that much. I didn't really know that many

7 people. That's what I heard, Radmilo Zeljaja and Rajlic, the two of them,

8 they were the number ones.

9 JUDGE SCHOMBURG: Do you recall an occasion when Dr. Stakic went

10 to meet, call it, armed forces together with Mr. Arsic, addressing these

11 military personnel?

12 A. I don't know what they talked about. I'd take him there, and I'd

13 wait until he finishes his conversation, and then I take him back.

14 JUDGE SCHOMBURG: So then let's turn to another delegation you

15 were, in fact, aware of. You spoke about Karadzic - it's on LiveNote

16 today, page 51, line 14 - you said: "That was Karadzic, Biljana -" I

17 think was Biljana you speak about --

18 A. Biljana Plavsic, yes.

19 JUDGE SCHOMBURG: And that third man, and later you said Momir

20 Krajisnik.

21 A. Krajisnik, of course, yes.

22 JUDGE SCHOMBURG: Yes. And once again, the attempt, you left your

23 job because you were mobilised exactly when?

24 A. The mobilisation, when I left, that was -- that was sometime --

25 the mobilisation was sometime in December. I reported to the unit -- I

Page 14319

1 mean, I reported to the unit in December.

2 JUDGE SCHOMBURG: And approximately what was the last day you

3 drove Dr. Stakic?

4 A. I can't remember. I can't remember the date.

5 JUDGE SCHOMBURG: October, September, November?

6 A. October. I think it was in October.

7 JUDGE SCHOMBURG: And then this meeting in 1992 where there was a

8 delegation in Prijedor Hotel composed of Karadzic, Plavsic, and Krajisnik,

9 was it in October, September, or even earlier?

10 A. I can't remember the date. But I know that it happened. I can't

11 give you the date because I'm not sure.

12 JUDGE SCHOMBURG: At that point in time, you were still the driver

13 of Dr. Stakic. Correct?

14 A. I think I was, yes.

15 JUDGE SCHOMBURG: You said you started the 17th of May driving

16 Dr. Stakic.

17 A. Yes. Yes.

18 JUDGE SCHOMBURG: Had you ever heard of a Crisis Staff in

19 Prijedor?

20 A. Not in the beginning, I didn't know what it was. But later on, I

21 found out what it was.

22 JUDGE SCHOMBURG: What was it?

23 A. Well, a group of people who bring authority, if I can put it that

24 way.

25 JUDGE SCHOMBURG: Would it be correct that the Crisis Staff was

Page 14320

1 established by an order of 20 May, 1992?

2 A. Oh, I know nothing about that. I know it existed, but I don't

3 know when it was founded.

4 JUDGE SCHOMBURG: You testified that during this period of time,

5 you brought Dr. Stakic from Omarska to Prijedor and back. Did it happen

6 that the one or other day, Dr. Stakic had to leave later than usual?

7 A. Yes, yes. At times, he stayed longer. He wouldn't go back at

8 3.00, that he'd be kept at a meeting longer than that.

9 JUDGE SCHOMBURG: Was Dr. Stakic ever on a night shift in the

10 Crisis Staff?

11 A. I don't know about his being on duty.

12 JUDGE SCHOMBURG: Do you know that Dr. Stakic was president of the

13 Crisis Staff at that time?

14 A. I wasn't aware of that. Afterwards, I heard some details, but was

15 it he or somebody else, it seems to me, I'm not sure.

16 JUDGE SCHOMBURG: But wouldn't it be correct that you, as a

17 driver, should know and especially that you should know when it was to

18 bring Dr. Stakic as it is still your testimony to Omarska during then

19 maybe even nighttime?

20 A. No, I didn't. Never at night. It was almost as a rule, the

21 working hours, perhaps a couple of hours longer, but we didn't travel by

22 night.

23 JUDGE SCHOMBURG: In the municipal building, was there something

24 like a communications centre for the Crisis Staff? Maybe to refresh your

25 recollection, in the basement?

Page 14321

1 A. Yes, there's still something down there. I don't know what. But

2 there's still something down there, something like a communications centre

3 or something.

4 JUDGE SCHOMBURG: Did you ever see Dr. Stakic going to this place?

5 A. I did see him going to that place, but he also came to have coffee

6 like we did because I often slept there. There was my bed there, and I

7 slept there on a number of occasions, if that's it.

8 JUDGE SCHOMBURG: Would it be your testimony that this place where

9 you slept on several occasions, it was within this special communications

10 centre or close to this centre?

11 A. This was down there, in the basement, in the cellar. Everything

12 was down there, the room where you could lie down, under the ground in the

13 cellar. You had two beds there, so you could lie down.

14 JUDGE SCHOMBURG: What could be the reason that you had to sleep

15 there when it was for you to drive Dr. Stakic home day by day after the

16 office hours, as you testified previously?

17 A. I had to spend the night there on a couple of occasions when it

18 was dangerous, when the attack happened, that is when I spent some -- one

19 or two nights there because I dared not go home. It was dangerous to go

20 home at that time, and that is why I spent those nights there.

21 JUDGE SCHOMBURG: Sorry, I can't understand this answer. You

22 lived in Omarska. You told us that you drove Dr. Stakic to Omarska. Why

23 was it then that you had to spend nights in the municipal building in

24 Prijedor?

25 A. Well, I couldn't go home. When I had nothing to get home with,

Page 14322

1 that is when I stayed to spend the night in Prijedor. When I didn't have

2 any means of transportation, when I didn't have my car, then I had to

3 spend the night there because there was nowhere else I could go.

4 JUDGE SCHOMBURG: So let's try another time. Please tell us the

5 exact hours you worked. You started in the morning, after the 17th of

6 May, picking up Dr. Stakic at his home. Correct?

7 A. Yes, yes, it is.

8 JUDGE SCHOMBURG: That was about 6.30, that you could be at

9 7.00 --

10 A. Thereabouts. 6.00.

11 JUDGE SCHOMBURG: And when would you bring Dr. Stakic regularly

12 back to Omarska?

13 A. Well, we returned around 5.00, 6.00, 4.00, 3.00, depending on how

14 long he was busy, because he didn't always have regular hours. He would

15 stay longer. There were no working hours so that he would stay to work

16 there longer, and I waited for him.

17 JUDGE SCHOMBURG: And then when returning home to Omarska, you

18 stayed with your car in Omarska until the next morning. Correct?

19 A. Correct. Until that date, I left the car at my place, and I would

20 pass by his house to fetch him, and then we would go on to Prijedor.

21 JUDGE SCHOMBURG: So was there any reason for you during this

22 period of time to go back to Prijedor and to sleep in Prijedor?

23 A. During that period of time, it did not happen that we went back

24 and slept in Prijedor.

25 JUDGE SCHOMBURG: But on other occasions, you said "We went back

Page 14323












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Page 14324

1 and slept in Prijedor." It was, in fact, that both of you slept in

2 Prijedor? Did Dr. Stakic also sleep in the building of the Municipal

3 Assembly?

4 A. I slept. And that morning, Stakic also slept with me on that day,

5 on the 30th. He was also with me. He also slept there. That night, that

6 is the night that I spent there.

7 JUDGE SCHOMBURG: And why was it that Dr. Stakic slept there on

8 that day, together with you?

9 A. I don't know why, but we spent that night there. We were both in

10 the municipal hall, and we slept there, and the janitor was there. And

11 many others, we were quite a few there. Because we did not go back home.

12 JUDGE SCHOMBURG: Were there any special plannings or other needs

13 justifying to stay there and sleep there during this special night?

14 A. It wasn't a special night. It just happened. It wasn't planned.

15 We didn't go back, and I slept there, and he was there, too.

16 JUDGE SCHOMBURG: Did you ever see Dr. Stakic going to any place

17 where the incidents happened, say, Hambarine, Kozarac?

18 A. No, no. Mr. Stakic didn't go with me to Hambarine, Kozarac. We

19 didn't go to those places.

20 JUDGE SCHOMBURG: We heard a lot about places you haven't been

21 following your testimony at all. May I ask the usher, therefore, to put

22 on the ELMO, please, Exhibit S1.

23 Let's turn the story the other way around. Looking on these small

24 towns, hamlets, town of Prijedor, to the best of your recollection, where

25 have you been together with Dr. Stakic?

Page 14325

1 A. Well, we mostly visited Prijedor, Kozarac, Lamovita, and Omarska.

2 We passed that way all the time, except that day when we couldn't get

3 through. This is the route that we used, Prijedor, Kozarusa, Kozarac,

4 Babici, and Lamovita, Omarska. And then we went through Maricka and Cela

5 on our way back the next day, via Cela, Maricka, and then back to Omarska.

6 That would be the route.

7 JUDGE SCHOMBURG: What about all the other places, hamlets, small

8 villages, you can see on this map?

9 A. We didn't go up there to Hambarine, Ostra Luka, no, I didn't.

10 Tomasica, no I didn't go there. Maricka, yes. Gradina, I did go to. Now

11 a little bit -- Brezicani, yes I have been there. Palanciste, yes, I have

12 been there. And that's about it. Those are the places that I went to.

13 JUDGE SCHOMBURG: What was the purpose of visiting Maricka?

14 A. Maricka, the purpose -- well, it wasn't a visit. We were

15 returning via Petrovo and Cela, Tomasica, or Cela, Maricka, Omarska, when

16 we couldn't get through, that was when we went on our way back.

17 JUDGE SCHOMBURG: So it would be your testimony that the president

18 of the Assembly didn't pay a visit to any other parts of the Prijedor

19 Municipality together with you. Correct?

20 A. With me, he didn't. He did not visit those other places with me.

21 The places that I mentioned, yes, I went to them. I drove him to those

22 places. Those others, no, I didn't go there.

23 JUDGE SCHOMBURG: Did you ever see Dr. Stakic driving a Golf car?

24 A. I don't know. A Golf? I didn't see him drive it. Perhaps

25 privately, but I don't remember. He had a car - I don't know - before,

Page 14326

1 but I don't know what he drove.

2 JUDGE SCHOMBURG: Did you ever meet colleagues of yours, drivers

3 of Autotransport Prijedor?

4 A. I didn't see them.

5 JUDGE SCHOMBURG: Did you see women -- first of all, women, men

6 lining up in front of the SUP building?

7 A. Oh, yes, that I did see. I saw them queueing up there, standing,

8 yes, as I came out of the municipal hall, I could see them standing in a

9 queue in front of the police station. Yes, a hundred- or

10 two-hundred-metre long queue. Yes, I did see that.

11 JUDGE SCHOMBURG: And what was the reason for these people queuing

12 up in front of the SUP building?

13 A. I don't know. Perhaps they were being issued with some cards. I

14 think they were being issued with some papers. I don't know what they

15 were doing. I don't know. I know they were waiting for something in the

16 queue.

17 JUDGE SCHOMBURG: Isn't it true, sir, that you perfectly well

18 knew, sir, that these people were queuing up to get a certificate that

19 they could leave Prijedor Municipality together with their relatives?

20 A. I don't know. I know they were waiting for certificates of some

21 sort, but I don't know what.

22 JUDGE SCHOMBURG: Sir, there's always a likelihood what persons do

23 or don't. Is it really your testimony that you never discussed the

24 question why these people were lining up in front of the SUP building

25 together with Dr. Stakic? Did you never discuss this?

Page 14327

1 A. There was no need for me to ask him that because I didn't want to

2 address the conflict. I wasn't interested in that. I simply saw people

3 in a long queue, and there was quite a crowd. So I saw what was

4 happening, but I didn't want to ask. It was not necessary for me to ask

5 about that. That wasn't mine, but I did see them waiting there. Yes, I

6 did see that.

7 JUDGE SCHOMBURG: Unfortunately, I don't have the concrete page

8 before me in the moment. But previously, you testified about a radical.

9 Who was this radical person you mentioned previously?

10 A. I mentioned that with regard to the president, when you mentioned

11 him and what he was. That's what I mentioned that. I don't know whether

12 he was a member of the SDS or a radical. I believe that is when I said

13 something about that, in that regard.

14 JUDGE SCHOMBURG: What was "radical" with Dr. Stakic?

15 A. I don't know what the difference is. I was not sure what the

16 party was. I know that the word "radical" was mentioned, but I don't

17 remember. I was not a member of any party. I only heard something like

18 that.

19 JUDGE SCHOMBURG: For the moment, I don't have any further

20 questions.

21 The Defence is prepared for the line of questioning? Please,

22 Mr. Lukic.

23 Questioned by Mr. Lukic:

24 Q. [Interpretation] Good afternoon, Mr. Stanar. My name is Branko

25 Lukic. Together with John Ostojic, who is not with us today, and with

Page 14328

1 Mr. Cirkovic, I represent Mr. Stakic's defence before this Tribunal.

2 I will start from last things first. Judge Schomburg asked you

3 about who is radical. Did you mean the party that he belonged to? Did

4 you refer to the party?

5 A. I don't know whether he was a member of the Radical Party or the

6 SDS or some other party. I never asked him what party he was a member of.

7 And that's why I didn't know which party he belonged to.

8 Q. When we make mention the word "Ljubija" and the word "Ljubljana"

9 we understand what these two are all about. But for the Honourable

10 Judges, can you tell us where Ljubljana is, in which republic?

11 A. Ljubljana is in Slovenia, and Ljubija is in Donja Ljubija. These

12 are two totally different places. One is in Slovenia, and the other is in

13 Bosnia-Herzegovina. Those are two different states.

14 Q. You were talking about one morning, when you tried to go through

15 Kozarac, and then -- was it on the way to work or from work?

16 A. To work.

17 Q. On that evening, did you manage to go back home through Kozarac?

18 A. No, we didn't go back through Kozarac.

19 Q. From that day on, is it true that you no longer could go through

20 Kozarac on the way from Prijedor to Omarska?

21 A. For three or five days, one couldn't go through Kozarac.

22 Q. I am jumping from one subject to another to clarify some technical

23 issues. You were asked about petrol vouchers or coupons. And you said

24 that you received those from the cashier. Was that cashier somebody who

25 had an office in the Municipal Assembly building?

Page 14329

1 A. Yes, he had his office or she had her office in the Municipal

2 Assembly.

3 Q. Do you remember their names? You said that there were two persons

4 involved in that.

5 A. Yes, there were two persons involved, but I can't remember their

6 names. I know who they were -- I know who they are now. Gordana Mijic

7 [phoen] is one of them, and the other person is Stana [phoen]. But who

8 they were at that time, I don't remember.

9 Q. In any case, at that time, you did not receive petrol vouchers

10 from Slobodan Kuruzovic?

11 A. Yeah, that is correct, I didn't receive them from Slobodan

12 Kuruzovic. We received them from Brezicani, and then we would take them

13 to the petrol station, to Brezicani or the railway station. And when

14 there was no petrol at the petrol stations, then we would go to the

15 Brezicani warehouse or storage and we would obtain petrol from there if

16 there was no petrol to be had from any of the petrol stations.

17 Q. Mr. Stanar, when you were testifying about recruits being sent off

18 to the army at the occasions that Dr. Stakic attended, amongst others, did

19 you notice people from humanitarian institutions attending those send-offs

20 and also there are women among them from Kovasavski Stija [phoen], for

21 example?

22 A. Yes, there were women and people like that.

23 Q. And just another clarification, if I may: In Smederevo, in

24 Serbia, is there a huge iron works?

25 A. Yes, there is. That is the biggest iron works factory in Serbia.

Page 14330

1 That's where rail wagons are made and other such things. That is what I

2 know.

3 Q. When you came across the barricades in Kevljani in the Kozarac

4 region, was that a week or even before that time, even earlier, the attack

5 on Prijedor, if you can remember? If you can't remember --

6 A. I can't remember. I did go that way, but I don't remember when

7 that was. I'm not sure. And if I'm not sure, I can't give you an answer.

8 Q. Thank you very much.

9 MR. LUKIC: [Interpretation] I have no further questions to ask

10 you.

11 JUDGE SCHOMBURG: Judge Vassylenko.

12 Further questions by the Court:

13 JUDGE VASSYLENKO: Mr. Stanar, today you stated - it's page 56,

14 lines 11, 12 - "On several occasions, we had lunch in the restaurant when

15 we were returning from Banja Luka." May I ask you to clarify, whom did

16 you mean by saying "we"?

17 A. President Stakic, and if vice-president was with him or the

18 secretary, generally, and I was with them, and then we would stop for

19 lunch and we would have lunch all of us together.

20 JUDGE VASSYLENKO: On what occasions Dr. Stakic travelled to Banja

21 Luka?

22 A. When he went to the Municipal Assembly of Banja Luka, when he went

23 there or elsewhere, then he would stop by.

24 JUDGE VASSYLENKO: How many times Dr. Stakic travelled to Banja

25 Luka?

Page 14331

1 A. While I was his driver, it may have been six or seven times that I

2 took him to Banja Luka.

3 JUDGE VASSYLENKO: And what institutions Dr. Stakic visited in

4 Banja Luka? Whom did he meet in Banja Luka?

5 A. I don't know who he met with. I would take him to the municipal

6 building. I would park the car there. He would enter the municipal

7 building, and then I don't know who he met. I would usually sit in the

8 car and wait for him.

9 JUDGE VASSYLENKO: And Dr. Stakic never explained to you why he is

10 going to Banja Luka, whom he is going to meet, and what business he is

11 going to perform in Banja Luka?

12 A. Well, I was a driver, and it is not becoming a president to talk

13 to a driver. And although we knew each other, he would never discuss

14 official business with me. We would mostly chat, if anything.

15 JUDGE VASSYLENKO: I have no further questions.

16 JUDGE SCHOMBURG: Who was the strongest politician in 1992 in

17 Prijedor Municipality?

18 A. I don't know. I'm not a politician, and I cannot answer that. I

19 simply don't know.

20 JUDGE SCHOMBURG: Prosecution, any additional questions?

21 MS. SUTHERLAND: Just one, Your Honour.


23 Further questions by Ms. Sutherland:


25 Q. Sir, are you aware that the authorities of the Autonomous Region

Page 14332

1 of Krajina had offices in the Banja Luka Municipal Assembly building?

2 A. No, I was not aware of that. As a matter of fact, I hear this for

3 the first time now.

4 MS. SUTHERLAND: No further questions.

5 MR. LUKIC: Your Honour, as my colleague, John Ostojic, likes to

6 say, with the Court's permission, but I forgot to ask two or three

7 questions. They are not emanating from your questions and the

8 Prosecutor's. Thank you.

9 Further questions by Mr. Lukic:

10 Q. [Interpretation] At one point, you stopped driving Dr. Stakic to

11 Omarska. However, you continued living in Omarska, and you yourself

12 travelled to Omarska.

13 A. Yes, I continued commuting from Prijedor to Omarska every morning.

14 I would go to Prijedor to work there. And I still do that. Every

15 morning, I travel to Prijedor for work.

16 Q. For example, could it happen that once you had already left for

17 Omarska, that Dr. Stakic stayed in the municipal building or returned to

18 it without you being aware of that?

19 A. Yes. On Saturdays, Sundays, for example, or after working hours,

20 there was no way for me to know who was doing what. It would be the

21 janitor who would know that.

22 MR. LUKIC: [Interpretation] Thank you. I have no further

23 questions.

24 JUDGE SCHOMBURG: Any further questions? This is not the case.

25 Then the witness is excused. Only a final question, to be correct, you

Page 14333

1 were served the subpoena ducas tecum that you should bring along logbooks

2 or similar records of the driving hours, the driving destinations. Did

3 you try to get these, or weren't there any records? Would this be your

4 testimony, that there was never a record taken about the destinations whom

5 you would drive, at that time, no control at all?

6 A. At that time, when I drove, there was no logbook. It was not

7 recorded who was travelling where. We just had travel orders which said

8 who was going where on what day. At the end of the month, we would hand

9 over all of our travel orders to Zeljko Grahovac. So we did have our own

10 orders. You maintained your records. We didn't record the names of the

11 people we drove, but we did record the destinations. That is still the

12 same. For example, today, we receive our orders, and then we fill out

13 those orders with the destinations, be it Sarajevo, Belgrade, Banja Luka.

14 Again, not the names of the persons that we drove. In the past, we didn't

15 even enter the destinations where we drove to.

16 JUDGE SCHOMBURG: Sorry, but I can't understand this. You said in

17 the past we didn't even enter the destinations where we drove to. So it

18 would be just a piece of paper where you can read "order" by, and then

19 nothing, nothing about the passenger, nothing would be the destination?

20 What would be the sense of such document?

21 A. It is a travel order valid for a month allowing you to move about,

22 around Prijedor. This allowed you to travel all over Bosnia-Herzegovina.

23 And if you are to go somewhere else, for example, to Croatia or to

24 Belgrade, you need different travel orders. If you are in Prijedor, then

25 you don't need any such thing. We had a piece of paper in which we

Page 14334

1 recorded the number of kilometres that we did on that particular day, so

2 we would enter the number of kilometres we started with, enter the number

3 of kilometres we ended the day with, and we would sign that on every day,

4 for every day. These were our -- these are our travel orders.

5 JUDGE SCHOMBURG: But just a moment ago, you stated: "We just had

6 travel orders which said who was going where on what day. At the end of

7 the month, we would hand over all our travel orders to Drago." So what's

8 now correct? Did you have such travel orders which said who was going

9 where on what day, or didn't you? Which part of your testimony is

10 correct, the first or the second?

11 A. Both are correct. If you are in Prijedor and it's the vicinity,

12 then we have monthly orders. If we travel somewhere else, then we have

13 different orders.

14 JUDGE SCHOMBURG: Then my question would be, why didn't you bring

15 along these different orders where one could find the passengers and the

16 destinations?

17 A. I didn't know this would be necessary. But I can send all of

18 those to you from the day when I started working. Actually, with the

19 document on the day when I started working.

20 THE INTERPRETER: Interpreter's correction.

21 JUDGE SCHOMBURG: So these documents would be available?

22 A. Yes, I can send you the travel orders. However, I'm not sure

23 whether I'll be able to find the travel orders from the year 1992 in the

24 files. A lot of those documents have gone missing. I'm not sure whether

25 they are still available. I can make some inquiries and see whether they

Page 14335

1 are still available.

2 JUDGE SCHOMBURG: Having received the court order, did you make

3 any attempts to find these travel orders?

4 A. No, I didn't have time to do that. I was away in Sarajevo for

5 three days. I was in Brcko for two days. I came back on Saturday. At

6 11.00 on Saturday, I checked in, and then three days later, I left. So I

7 really didn't have the time to do anything. I left in a bit of a hurry.

8 JUDGE SCHOMBURG: So I can't see any additional questions. This

9 concludes your testimony. May I ask the usher to escort the witness out

10 of the courtroom. Thank you.

11 [The witness withdrew]

12 JUDGE SCHOMBURG: Madam Registrar, what is the latest update? Has

13 Mr. Kuruzovic already arrived so that he would be prepared to testify

14 already tomorrow?

15 THE REGISTRAR: I have not had such information, so I think we're

16 still on the information that he would arrive tomorrow and be ready to

17 testify on Wednesday. But I can double-check and inform you during the

18 day.

19 JUDGE SCHOMBURG: So the parties will be informed, because there

20 was some rumour that he would already arrive today, and then we would take

21 the opportunity and continue already tomorrow with the testimony of

22 Mr. Kuruzovic in case the parties are prepared.

23 MR. LUKIC: We are prepared, Your Honour.

24 MR. KOUMJIAN: We're not prepared now, but hopefully by tomorrow.

25 JUDGE SCHOMBURG: Okay. If it's possible, we should start with

Page 14336

1 this tomorrow. We heard already the submissions on the rebuttal witnesses

2 of the OTP. And then we heard no submission until now related to the,

3 once again, requested for admission Donia report "Bosnia Krajina in the

4 history of Bosnia-Herzegovina." May I ask the Defence, what is your

5 opinion?

6 MR. LUKIC: Your Honour, as you already know, our team divide our

7 work, and that's in the purview of Mr. Ostojic's duties, and he'll be here

8 with us tomorrow morning. So if it's not too late, I would ask you kindly

9 to leave it until tomorrow morning.

10 JUDGE SCHOMBURG: That's reasonable. So in any event, we will

11 continue, but not tomorrow morning, tomorrow at 2.15 in Courtroom II.

12 Because this week, we were -- we would sit tomorrow in Courtroom II in the

13 afternoon; on Wednesday, in Courtroom I in the morning -- no, in Courtroom

14 II in the morning; on Thursday, there would be a -- we would sit again in

15 Courtroom II, and maybe once again on Friday, in Courtroom I in the

16 afternoon. But things may change from hour to hour, let's wait and see.

17 MR. LUKIC: Yes, Your Honour. Madam Registrar was kind enough and

18 she provided us with the schedule. It was my mistake when I mentioned

19 tomorrow morning.

20 JUDGE SCHOMBURG: It's no problem. And as I mentioned just a

21 minute before, it might be that there are other changes due to overlapping

22 cases in the moment.

23 So are there any other issues to be discussed right now? Nothing

24 from the Prosecution, nothing from the Defence.

25 This concludes today's hearing. The trial stays adjourned until

Page 14337

1 tomorrow, quarter past 2.00, Courtroom II.

2 --- Whereupon the hearing adjourned

3 at 1.50, to be reconvened on Tuesday,

4 the 25th day of March, 2003, at 2.15 p.m.