Tribunal Criminal Tribunal for the Former Yugoslavia

Page 6729

1 Wednesday, 9th October, 1996.

2 (10.00 a.m.)

3 (Open session)

4 THE PRESIDING JUDGE: Good morning, everyone.

5 MIRA TADIC, recalled.

6 Examined by MR. KAY, continued.

7 THE PRESIDING JUDGE: Mrs. Tadic, you understand that you are still

8 under the oath that you took yesterday to tell the truth?

9 THE WITNESS [In translation]: Yes.

10 THE PRESIDING JUDGE: Very good. Mr. Kay, you may continue.

11 MR. KAY: Thank you, your Honour.

12 Q. Mrs. Tadic, as we concluded the evidence yesterday afternoon you

13 were telling the Court about your husband's job involving

14 carpentry work at Sisak in Croatia. You had also told us about

15 your own work that in the late 1980s was, in fact, at the

16 hospital in Prijedor -- in Kozarac, not the hospital in

17 Prijedor?

18 A. In Kozarac.

19 Q. For how long did Dusko Tadic work in this company with the

20 carpentry business in Croatia?

21 A. About two years.

22 Q. Can you remember the year that that business ended?

23 A. Summer 1989.

24 Q. At that time were you still living in the ground floor of the

25 house in Kalate?

26 A. Yes.

27 Q. For how long did you continue to live in that house?

28 A. In that house, well, we lived there until my father-in-law died

Page 6730

1 in 1989. Then we went back to the family house.

2 Q. When you went back to the family house, was your husband still

3 working in Croatia or had his business finished there and had he

4 returned back to Kozarac?

5 A. Yes, it was finished.

6 Q. When your father-in-law died -- that is Ostoja Tadic, is it

7 not ----

8 A. Yes.

9 Q. --- did you then move into part of the house of the Tadic family

10 with your children?

11 A. Yes.

12 Q. Was it the same part of the house that you had lived in before

13 or was it a different part?

14 A. No, it was a different part.

15 Q. Perhaps if we just look at that photograph we looked at

16 yesterday afternoon? If Exhibit 300 could be put in front of

17 the witness? (Handed) If you actually put it on the monitor

18 and then she can indicate where.

19 A. We were living in that part in the middle. (Indicating).

20 Q. Thank you. If you could leave the photograph there, is that the

21 part of the house that you continued to live in or did

22 eventually you move to another part of the house?

23 A. In the month of August 1991 we moved to the upper part -- the

24 loft actually.

25 Q. If you could just keep your indicator for a moment on the

26 photograph a little bit longer so that we can see it? That is

27 the floor above the ground floor?

28 A. Yes.

Page 6731

1 Q. Thank you. Having had the carpentry business in Croatia, what

2 was Dusko Tadic's next employment?

3 A. Afterwards we were building our own premises and on and off he

4 would go and join his brother who was working in Germany.

5 Q. What work would he do in Germany?

6 A. His brother had a construction company and that is where he

7 worked.

8 Q. Which brother is that?

9 A. Mladen Tadic.

10 Q. Which town in Germany was that?

11 A. Munchen.

12 Q. You have referred to another part of the house where eventually

13 you went to live. Did there come a time when Dusko Tadic opened

14 up a cafe in part of the family home?

15 A. Yes, it was the extension to the family house. Am I supposed to

16 indicate it?

17 Q. Yes, if you could, please?

18 A. [The witness indicated].

19 Q. If you just indicate there? If you could keep it on so that we

20 can see it for a moment longer? That part of the house there on

21 the right-hand side which has a square front, was that built

22 later?

23 A. That entire part I am indicating now was all added as an

24 extension -- that is the part that we built -- and the part down

25 here was the cafe.

26 Q. Was the name of the cafe the Nipon?

27 A. Yes.

28 Q. When did that building work start for the extension to the

Page 6732

1 family home?

2 A. In 1989, spring 1989.

3 Q. So when that work started was your father-in-law still alive at

4 that time?

5 A. Yes, but then in the meantime he passed away.

6 Q. When was the work on that part of the house completed so that

7 you were able to move into that side of the family home?

8 A. I do apologise. I have not quite understood. Are you referring

9 to the business premises or the upper storey?

10 Q. First of all, the upper storey.

11 A. In the upper storey, well, we have moved into it in August 1991.

12 Q. When was the cafe bar opened which is on the ground floor?

13 A. Prior to that, before we moved into the upper storey, by the end

14 of 1990, beginning of 1991, that is when we opened the cafe.

15 Q. Is it right that other people within the town of Kozarac helped

16 at times in doing some of the building work?

17 A. Yes.

18 Q. Was that on a regular basis that people would help on the

19 building work?

20 A. Yes, whenever there was major construction work to be done, but

21 no skilled, highly skilled, workers were required.

22 Q. How was the building of this part of the house paid for? How

23 was it financed?

24 A. A part of that was borne by my husband, another part by his

25 brother and we also loaned some money.

26 Q. Did people also give their services and help for free, for no

27 reward?

28 A. Yes.

Page 6733

1 Q. Is that something that was a tradition or something that was

2 expected in that community of Kozarac, if people were

3 undertaking this kind of work?

4 A. Yes, precisely.

5 Q. At this time were you still working in the hospital in Kozarac?

6 A. Yes.

7 Q. Was that as a general nurse or did you have any particular

8 skill?

9 A. A general nurse.

10 Q. I would now like to ask you about relationships between Dusko

11 Tadic and other people within the town of Kozarac by this time

12 in 1990. Did you have many friends in the town?

13 A. Yes.

14 Q. Were those friends of all different ethnic groups, Serbian,

15 Croat and Muslim friends?

16 A. Yes.

17 Q. You had lived with Dusko Tadic for over 10 years by this time.

18 In that 10 years did he have particularly close friends from

19 Kozarac?

20 A. Yes.

21 Q. Who were they?

22 A. Well, one of his childhood friends was Ahmed Kulenovic and he

23 remained friends with him, then Fikret Sakanovic, Emir

24 Karabasic, Hamdo Balic later on, Sefika Arnautovic.

25 Q. You mentioned there Emir Karabasic; had he been a long standing

26 friend of your husband?

27 A. Yes.

28 Q. I would like you now to look at a photograph. There is a colour

Page 6734

1 picture here for you to see and tell me, first of all, if you

2 recognise this photograph which I tender to the Court as D71.

3 MR. KEEGAN: No objection, your Honour.

4 MR. KAY [To the witness]: Do you recognise that photograph,

5 Mrs. Tadic?

6 A. Yes.

7 Q. When was that photograph taken?

8 A. I think sometime in 1985 or 1986 while on summer holiday in

9 Pula.

10 MR. KAY: Your Honour, there are copies here for your Honours and

11 perhaps if that could be put on the monitor?

12 THE PRESIDING JUDGE: No objection to Defence Exhibit 71. It will be

13 admitted.

14 MR. KAY: Thank you, your Honour. It is a small photograph, so if we

15 could have it blown up into as full a size as possible? Can you

16 move it down the monitor a little bit? That is fine.

17 Mrs. Tadic, I would like you to turn to the right and with that

18 pointer if you could indicate who are the people within that

19 photograph that you recognise. Keep the pointer for a few

20 seconds upon each person as you identify them so that we can

21 take in exactly to whom you are indicating.

22 A. This is Stojan Tadic, the eldest of my husband's brothers.

23 Q. Yes.

24 A. This is my eldest daughter, Valentina Tadic.

25 Q. Yes.

26 A. This is myself.

27 Q. Yes.

28 A. And the one sitting here is Emir Karabasic.

Page 6735

1 Q. If that photograph can be moved down a little bit more so that

2 we can see the gentleman in the right-hand corner a little bit

3 better? Thank you. Standing on the right-hand side on the

4 brickwork there, who is that? Yes?

5 A. I do not know. This is not my husband, if you mean him. I do

6 not know.

7 Q. Right. Yes, I thought it was but I am obviously wrong about

8 that. OK. Thank you. So there is a holiday photograph in 1985

9 or 1986 with Emir Karabasic.

10 A. It must have been 1984, 1985, judging by my daughter's age. She

11 must have been four or five in that picture.

12 Q. Do you think your husband took the photograph?

13 A. Yes.

14 Q. So he was on holiday with you and was Karabasic and Stojan Tadic

15 also on holiday with you?

16 A. Yes.

17 Q. How close was the friendship between your husband and Emir

18 Karabasic?

19 A. I do not understand. Do you mean when, in what period of time

20 or?

21 Q. Let us just take it at this time in the mid 1980s?

22 A. They were very close.

23 Q. Then later on in the 1980s, did they remain close friends?

24 A. Not after 1991 and onwards.

25 Q. Until 1991 had they always been close friends or had their

26 friendship drifted apart?

27 A. No, they were always good friends up until 1991.

28 Q. Did they remain friends after 1991 or did there come a change in

Page 6736

1 their relationship?

2 A. They were still friends but they saw each other less

3 frequently. They did not see each other all the time as they

4 used to.

5 Q. Was Karabasic a married man like your husband?

6 A. On and off, occasionally he was and at other times he was not.

7 Q. We have heard evidence in this Court about your husband's

8 qualifications as a karate teacher and that he used to instruct

9 local school children and others in the sport of karate. Is

10 that right?

11 A. Yes.

12 Q. Did he have a karate school in Kozarac?

13 A. Yes.

14 Q. Can you tell us when he started the karate school in Kozarac?

15 A. I think in 1980 or -- yes, in 1980.

16 Q. For how long did that school continue in Kozarac?

17 A. It continued until he left to Libya, 1986. In 1986 Karabasic

18 took over as his deputy.

19 Q. When he returned from Libya, did he continue with the school?

20 A. No, then he was tied up with other work.

21 Q. Did he ever restart the school in Kozarac after he left it in

22 1986?

23 A. No.

24 Q. Did he take part in karate sporting competitions?

25 A. Yes.

26 Q. Were they just local competitions or did he perform elsewhere in

27 Yugoslavia in more national competitions?

28 A. I remember we went to one of the State competitions but only

Page 6737

1 once. That is what I remember.

2 Q. Did he perform his sport of karate in competitions outside

3 Yugoslavia?

4 A. No.

5 Q. Is it right that two of his other brothers were also involved in

6 this sport, the elder brother Mladen?

7 A. Yes.

8 Q. And also the other brother Ljubo?

9 A. Yes.

10 Q. Did the three of them ever have any arrangements for teaching

11 this sport which involved the three of them together, or did

12 they have this interest separately?

13 A. Well, Mladen had his own club in Munchen, Ljubo in Banja Luka

14 and Dule in Kozarac and occasionally, of course, he went to

15 Banja Luka for training from Kozarac.

16 Q. Did the good relations that you have talked about between your

17 husband and the people within Kozarac always continue?

18 A. I have not understood.

19 Q. Did your husband always remain on good terms with the people in

20 Kozarac?

21 A. Yes.

22 Q. In 1990 we are aware in this Court of elections that for the

23 first time were to take place in the former Yugoslavia. Did you

24 ever join a political party?

25 A. Yes.

26 Q. Was that the party of the SDS?

27 A. Yes.

28 Q. Had you ever been a member of a political party before you

Page 6738

1 joined the SDS?

2 A. Yes.

3 Q. Which party was that?

4 A. I was in the League of Communists party.

5 Q. When did you start your membership of the League of Communists

6 party and for how long did it continue?

7 A. I became a member of the League of Communists in the 4th grade

8 of my nursing school, school for nurses. That was in 1979.

9 Q. For how long did your membership continue?

10 A. Up until 1991, roughly speaking, up until I became a member of

11 the SDS.

12 Q. Had your husband Dusko Tadic been politically active in those

13 years that you knew him from when you first met him?

14 A. No.

15 Q. Did he also join the SDS?

16 A. Yes, together with me.

17 Q. What was the reason for the two of you then joining that

18 political party?

19 A. The reason why we joined that political party were the

20 threatening letters we were receiving in 1990.

21 Q. How many letters did you receive of a threatening nature in

22 1990?

23 A. Just one.

24 Q. What did that letter say?

25 A. That letter had a very -- was threatening, saying that we should

26 leave Kozarac and if we do not leave Kozarac within three months

27 that we would be killed, and it was signed by the "Young Muslims

28 from Kozarac", that is the party of SDA -- the SDA party.

Page 6739

1 Q. At the time that you received that letter were you then not a

2 member of the SDS?

3 A. No, I became a member later on.

4 Q. Does that also go for your husband Dusko Tadic?

5 A. Yes.

6 Q. We also know from evidence in this Court about a plebiscite that

7 was held in November 1991 and I would like you to see

8 Prosecution Exhibit 146. Perhaps the English translation could

9 be put on the monitor to assist the Court and the witness look

10 at the original in Serbo-Croat? (Handed) Thank you. It is all

11 right. You have no need to use the indicator; it is just for

12 information purposes. You look at that document we have put in

13 front of you. This is a document dated 8th November 1991 which

14 is in the bottom left-hand corner and slightly off the screen.

15 Do you see that date?

16 A. Yes.

17 Q. At the top of this document it reads that it is an instruction

18 for the plebiscite of Serb people in Bosnia and Herzegovina to

19 be held on 9th and 10th November 1991. There is a decision

20 appointing voting officials for the plebiscite in the area of

21 Kozarac and Vidovici. Do you see that?

22 A. Yes.

23 Q. We see beneath there a list of names. At point (1), for

24 President, your husband is named as Dusko Tadic with a deputy.

25 At point (2) there are other names. Then at point (3) we see

26 for member, Bosa Majkic, and for deputy, Mirjana Tadic. Do you

27 see that?

28 A. Yes.

Page 6740

1 Q. You have been called Mira Tadic, but is that, in fact, your full

2 name, Mirjana Tadic?

3 A. No, no. This is a mistake. My real name is just Mira, but it

4 does speak about me.

5 Q. That is you, though?

6 A. Yes.

7 Q. If you could tell us about this, first of all, from your

8 husband's position. How did he become involved in this

9 plebiscite of the Serbian people in Bosnia and Herzegovina in

10 1991, can you tell us?

11 A. Well, to tell you like this, in 1991 the Serbian people wanted

12 to remain in Yugoslavia, and in the area of Kozarac there were

13 only around 10 per cent of Serbian households and somebody had

14 to organise them. So, we took it upon us to organise this

15 plebiscite, that is, that the Serbian people should express

16 themselves and state whether they want to remain in Yugoslavia

17 and keep this right to live in the country in which -- the state

18 where they have lived up until then.

19 Q. By this time in November 1991 were both you and your husband

20 already members of the SDS?

21 A. Yes.

22 Q. To become a member of the SDS at that time what did you have to

23 do? How did you become a member?

24 A. We simply went to the hospital and became members. That is the

25 only thing we had to do -- simply express the wish to become

26 members.

27 Q. Did you have to fill in a form and was that form sent to the

28 political headquarters of the SDS?

Page 6741

1 A. I do not know. We simply received membership cards. Whether we

2 needed something to fill in or not, I cannot remember but

3 I remember that we received the cards.

4 Q. To receive those membership cards had you spoken to anyone in

5 particular and said, "I would like to join this particular

6 political party"?

7 A. Yes, that needed to be done.

8 Q. Can you remember to whom you spoke?

9 A. Yes, I remember. We went together to the hospital and there was

10 Bogoljub Glusac. He was there as a Legal Officer in the

11 hospital in Prijedor and we talked to him.

12 Q. Had you had any political documents or books concerning the

13 philosophy of the SDS and what its political standpoint was for

14 policies on various matters?

15 A. No, we did not have anything. Probably there is the Statute of

16 the Party, but we did not have it.

17 Q. Once you had joined as members, were you or your husband sent

18 any political books indicating the policies of this political

19 party?

20 A. No.

21 Q. Had you or your husband read political books?

22 A. No, as far as I can remember, the Party did not have any books,

23 maybe there was the Statute, but we did not read it.

24 Q. Had you read other books on politics, political science?

25 A. Yes.

26 Q. What were they?

27 A. I read the Islamic declaration by Alija Izetbegovic.

28 Q. When was that?

Page 6742

1 A. That was in 1992.

2 Q. I am now talking about 1991 and this time of the plebiscite, and

3 the time that you had joined the political party, the SDS.

4 A. At that time I did not read any political books.

5 Q. How did it come about then that your husband was appointed a

6 voting official in the area of Kozarac and Vidovici?

7 A. Well, that happened because Dule had most free time. Only he

8 and I could organise that. We were young. All the others came

9 from village households and they had more tasks to do.

10 Q. So who asked you and he to organise the plebiscite?

11 A. The President of the Party, I think, Simo Miskovic.

12 Q. Where was he based?

13 A. In Prijedor.

14 Q. Did he come from Kozarac originally?

15 A. No.

16 Q. Did he have any connection with Kozarac?

17 A. You think with Kozarac or with our family?

18 Q. Either, if you can help us with this?

19 A. I do not know whether he had any connections with Kozarac, but

20 he was otherwise -- he was linked to our family. He was the --

21 he was a witness at my -- at a wedding of my brother-in-law

22 Stojan Tadic, best man.

23 Q. Whereabouts was the plebiscite held?

24 A. In the courtyard of the church, at the church office.

25 Q. Did it take place over those two days of 9th and 10th November?

26 A. Yes.

27 Q. What actually happened on those days of 9th and 10th November?

28 A. On 9th and 10th November the plebiscite was held. That is,

Page 6743

1 every person that wanted to express feelings to remain within

2 Yugoslavia, they could go to the plebiscite and vote, no matter

3 what nationality they were.

4 Q. Did many people vote in Kozarac?

5 A. No. Mostly people of Serbian nationality went to vote.

6 Q. Can you remember how many people turned up to vote over 9th and

7 10th November?

8 A. I cannot remember how many people, maybe 70 to 100, not more

9 than that. That is more or less.

10 Q. Were those people Serbs who lived in Kozarac or Vidovici?

11 A. Yes, those were Serbs, I think. A couple of Muslims turned up

12 as well and some Ukrainians.

13 Q. At this time then at the end of 1991 how were relations within

14 the community of Kozarac between the various ethnic groups?

15 A. Tense.

16 Q. What was the reason for that tension?

17 A. The reason for the tension was because the Serbs wanted to

18 remain in Yugoslavia the way that Yugoslavia was. At that time

19 the Muslims wanted their state, Bosnia, and the Croats also

20 wanted a state of their own. That was the reason, and everybody

21 was turning and following their leaders.

22 Q. We have referred to the SDS and you and your husband. Was there

23 actually a party headquarters or office established for the SDS

24 in Kozarac?

25 A. Not in Kozarac. The headquarters were in Prijedor.

26 Q. That then is why you had to go to Prijedor with your husband to

27 meet someone to say you wanted to join the Party?

28 A. Yes.

Page 6744

1 Q. Were there any other political parties that were active in

2 Kozarac at this time in 1991?

3 A. Yes, in Kozarac the other party that was active was the SDA

4 party.

5 Q. How were they active in Kozarac?

6 A. Well, they held meetings in Kozarac. People would become

7 members of the Party. Their ideology was spread.

8 Q. How did this affect you as Serbs living in Kozarac at this time?

9 A. Well, let me tell you, as all of them went into their Party and

10 their -- turned towards their people, suddenly all the people

11 became very politicized. So the effect upon us was that we

12 turned towards our Party and our people.

13 Q. You told us about the threatening letter that your husband

14 received. Had there been any other problems that you

15 experienced directed against you or your husband or where you

16 lived?

17 A. Yes, there was not only this letter of a threatening nature.

18 After that letter, there were phone calls. There were also

19 pressures expressed at your workplace. You could not behave

20 freely. You had to watch out what you were saying. You should

21 not take part into any political discussions. Everything was

22 different.

23 Q. At this time you were still working in the hospital in Kozarac,

24 is that right?

25 A. Yes.

26 Q. When did your husband's cafe open for business?

27 A. In early '91.

28 Q. What was the business like? Was it good or poor?

Page 6745

1 A. Well, medium.

2 Q. What sort of people went to that cafe?

3 A. In what nationality?

4 Q. Yes.

5 A. All nationalities, some Serbs, mostly Muslims, some Croats. It

6 depended, but that was the population structure in Kozarac.

7 Q. Your husband was the proprietor of the cafe. Did he have any

8 people who worked there as waiters and helped out?

9 A. Yes.

10 Q. What nationalities were they who worked with him in the cafe?

11 A. Muslims and Serbs.

12 Q. Can you name any of the Muslim people who had worked there for

13 him?

14 A. Let me remember. There was a young man called Suad and before

15 that Sead from Kalate worked there. Then the son of Adil

16 Jakupovic, Braco Jakupovic -- many worked there.

17 Q. Did your husband's cafe ever become a place where only Serbs

18 were welcome?

19 A. No.

20 Q. Could his cafe have survived if he only restricted it to people

21 from one ethnic background, just Serbs?

22 A. No.

23 Q. Were there any acts taken by people against the cafe?

24 A. Yes.

25 Q. What were they?

26 A. For example, the rumours stating that Muslims could not enter

27 the premises.

28 Q. Was that true?

Page 6746

1 A. No.

2 Q. Did some Muslims stay away from the premises as a form of

3 boycott?

4 A. Yes, mostly the Muslims from the centre of Kozarac boycotted the

5 cafe.

6 Q. Why was that?

7 A. The reason for it was that there was a Serb who held the cafe,

8 who owned the cafe.

9 Q. Were the other cafes in Kozarac owned by Muslims?

10 A. Yes.

11 Q. Was there any damage that was committed against the cafe?

12 A. Yes.

13 Q. What was that?

14 A. On two occasions the shop window was broken and at one time the

15 cafe was broken in and burgled.

16 Q. How did your husband Dusko react to these events?

17 A. He reacted in a way because he wanted to stay there till the

18 end.

19 Q. Did he himself commit any acts against other people as some sort

20 of revenge within the town?

21 A. No.

22 Q. As we enter 1992 and some five months before the conflict in

23 Kozarac, what was the state of relations like in the town

24 amongst the different ethnic groups?

25 A. The relations were tense. Apparently, we would say "hello" and

26 talk, but there were no close contacts or visits. Everybody was

27 just minding their own business.

28 Q. What was causing this tension?

Page 6747

1 A. Because people were simply afraid of one another.

2 Q. Were you or your husband adding to this tension? Were you or

3 your husband adding to this climate?

4 A. We could not add to it because we were a minority. We were more

5 or less the only ones there.

6 Q. Were the wishes of both of you that you could live there in the

7 family home and run your business?

8 A. Yes.

9 Q. Were the wishes of both of you that your children could be

10 brought up in Kozarac?

11 A. Yes.

12 Q. Did people begin to leave Kozarac in 1992?

13 A. Yes.

14 Q. What sort of people began to leave? Were they only of one

15 nationality or were they of various ethnic groups?

16 A. Only the people of Muslim nationality started to leave, that is,

17 women were taking the children out.

18 Q. Do you know where these people were going to?

19 A. Mostly they were going to their relatives in Zagreb, in Germany,

20 wherever they could.

21 Q. Did all the Serbs remain in Kozarac?

22 A. Yes.

23 Q. Did there come a time when they started to leave?

24 A. No, I left first. I left the first with my children.

25 Q. When did you leave Kozarac first of all?

26 A. On 1st April 1992.

27 Q. Why did you leave on 1st April 1992?

28 A. Because at that time in Kozarac it was not safe any more. We

Page 6748

1 were in a minority. The Muslim people became organised. They

2 had their barracks, they wore uniforms, held arms. I was afraid

3 because for my life and for the life of my children, and that is

4 why I left Kozarac.

5 Q. On 1st April 1992 were you working until that date in the

6 hospital in Kozarac?

7 A. Yes, until that date.

8 Q. Did you ever go back to working at the hospital in Kozarac after

9 that date?

10 A. No, never again.

11 Q. On 1st April 1992, then, where did you go to?

12 A. Then I went to Banja Luka.

13 Q. Where did you go to stay?

14 A. For four days I was staying with my brother-in-law in Banja

15 Luka, Ljubomir Tadic.

16 Q. After that four days where did you go to next?

17 A. Then I went to a village near Sanski Most, Kozice.

18 Q. What was your connection with that village?

19 A. A friend of mine comes from that village and she invited us to

20 come and stay.

21 Q. For how long did you stay there? When did you finish living

22 there?

23 A. Until 29th April.

24 Q. When you say you went to live there, did you take your children

25 with you?

26 A. Yes, I took my children and my mother-in-law came along as well.

27 Q. Did Dusko Tadic go with you and live away from Kozarac at this

28 time?

Page 6749

1 A. No, he took us there. He drove us and then he went back home on

2 the same day.

3 Q. When you were taken by him, was that to Ljubo's house or to

4 Kozice?

5 A. Kozice.

6 Q. How did you get to Ljubo's house in Banja Luka?

7 A. Ljubo drove us from Kozice to Banja Luka.

8 Q. Did Ljubomir Tadic have a car?

9 A. Yes, he had a utility vehicle.

10 Q. What sort of vehicle was that?

11 A. It was a zastava, white coloured, what we call a "combi".

12 Q. When Dusko Tadic took you to Kozice and, you told us, drove you

13 there, what vehicle did he drive?

14 A. He came along -- no, Ljubo drove us and Dule came along. He was

15 not driving.

16 Q. Did your husband own a car at this time?

17 A. No.

18 Q. Has your husband ever owned a car?

19 A. Yes.

20 Q. Can you tell us when that was?

21 A. It was between 1981 and 1985. That is when we did have a car.

22 Q. After you returned from Libya, did he ever own a car then?

23 A. No.

24 Q. Having stayed in Kozice for nearly a month, where did you go

25 after you left that place?

26 A. Then we came to the family house in Kozarac.

27 Q. For how long did you stay there?

28 A. Three days.

Page 6750

1 Q. Why did you only stay there for that short period of time?

2 A. On the fourth day we were forced to flee Kozarac.

3 Q. Can you tell us what happened then on that day?

4 A. On that day when we fled Kozarac or on the day before, what was

5 the reason?

6 Q. No, on the day that you fled Kozarac, what happened on that day?

7 A. On that day there was general chaos in Kozarac. Everybody was

8 in uniform or in shelters, women and children, and we were not

9 invited to go to the shelters and so we wanted to leave Kozarac.

10 Q. How did you leave Kozarac on that day?

11 A. On that day we left together with our priest, Mladen Majkic, in

12 his car.

13 Q. Mladen Majkic, did he have a family?

14 A. Yes.

15 Q. What did his family consist of?

16 A. His wife, Veselka Majkic and his daughter, Mladena Majkic.

17 Q. Had you made any arrangement with the priest, Mladen Majkic,

18 that you would leave Kozarac on that day prior to the event

19 happening?

20 A. We did not really agree on anything. We were not expecting

21 anything like that. That is what happened and we got ready

22 hurriedly and then we left.

23 Q. What time of the day was this?

24 A. In the afternoon -- you mean when we left Kozarac?

25 Q. Yes.

26 A. Early evening.

27 Q. Can you remember the date?

28 A. The date? Yes, it was on 3rd May.

Page 6751

1 Q. When you left in the car of the priest, who travelled in that

2 car?

3 A. The priest and his family, in other words, his daughter and his

4 wife, I myself and my husband and my two children and my

5 mother-in-law.

6 Q. Was it easy for all of you to fit in the car?

7 A. No, we could hardly fit in.

8 Q. Why was the priest, Mladen Majkic, leaving Kozarac on that day?

9 A. Because on the day before his wife was attacked.

10 Q. Did they live in a house in the grounds of the church?

11 A. [No translation].

12 MR. KAY: I am sorry, I did not get a translation of the last

13 answer. Madam, could you come closer to the microphone?

14 THE PRESIDING JUDGE: Mrs. Tadic, would you repeat your answer,

15 please?

16 THE WITNESS: Yes, the house was on the grounds of the church.

17 MR. KAY: Thank you. You had been in Kozarac for only some four

18 days at that time. Do you know if other Serb families had left

19 Kozarac in the meantime?

20 A. No, I do not know.

21 Q. During those four days at the beginning of May 1992 did your

22 husband, Dusko Tadic, remain with you in Kozarac?

23 A. I do apologise I have not understood the question.

24 Q. For those four days that you returned to Kozarac before you left

25 with the priest, Mladen Majkic, had your husband remained also

26 in Kozarac?

27 A. Yes.

28 Q. Was it possible for you to drive on the main road when you left

Page 6752

1 Kozarac at this time in early May?

2 A. No, we did not drive along the main road.

3 Q. Can you tell us then what happened, what route you took?

4 A. Well, when we left down the main road we were stopped by Sead

5 Bahonjic with an automatic rifle when we arrived at the

6 junction, and he told us we were not allowed to leave Kozarac.

7 Then we said we were going to go to the police station and we

8 were going to ask for authorisation to leave, but we did not

9 stop there. We drove across Kozara and we arrived at the last

10 checkpoint and Mr. Salkanovic was there with a rifle and a hand

11 grenade.

12 Q. Madam, could you speak more slowly because we have to listen to

13 this and it is difficult to take it all in. I would like you to

14 go back to the beginning again just so that we can get it more

15 slowly.

16 A. OK. I do apologise.

17 Q. Can you take it from the point when you described someone as

18 stopping you with a rifle, what happened there?

19 A. Yes, Sead Bahonjic in a camouflage uniform wearing glasses and

20 an automatic rifle stopped us and told us we were not allowed to

21 leave Kozarac.

22 Q. Whereabouts was this that he stopped you?

23 A. As you leave the churchyard in the Omladinska Street, you turn

24 right on the road to Banja Luka or Kamicani.

25 Q. Why did he stop you there at that point?

26 A. He said we were not allowed to leave. I do not know why he

27 stopped us.

28 Q. You mentioned earlier that you said that you would return to the

Page 6753

1 police station to obtain authorisation. Did you do that?

2 A. No. We only told him we were going to the police station. But

3 we did not stop there, but we continued on the road to

4 Makrovica.

5 Q. So did you drive out of Kozarac on a different road?

6 A. Yes.

7 Q. Did that road take you through Mrakovica in the direction of

8 Mount Kozara?

9 A. Yes, yes.

10 Q. Perhaps if we just look at that plan of that map D13 here so

11 that we can get that in mind? If a copy could be put in front

12 of the witness and a copy -- yes, put a copy actually on the

13 overhead monitor so the witness may indicate to us. (Handed).

14 Madam, that is the map that you looked at yesterday, you may

15 recollect. If you could just take a moment to familiarise

16 yourself with it because I am going to ask you to point to where

17 you went on 3rd May in a moment. Can you see Kozarac marked in

18 the middle of the map?

19 A. You mean the town of Kozarac?

20 Q. Yes.

21 A. Yes.

22 Q. Can you see that, the triangle that is at the bottom of Marsala

23 Tita Street?

24 A. Yes.

25 Q. Can you see where the Mutnik Mosque is indicated, if you

26 progress up Marsala Tita Street towards Rajkovici?

27 A. Yes, but I do not know where the mosque is. Where is the sign

28 for the mosque?

Page 6754

1 Q. It is a round circle beside the road, beside that yellow road

2 beneath the "K" of Mutnik. Can you see that?

3 A. I do see the circle, if that is what it is.

4 Q. That is what it is. Perhaps if that could now be put on the

5 monitor? You indicate with that pointer, if you are able to,

6 where it was that you were first of all stopped by the man with

7 the rifle. That is right. We have the triangle there in the

8 middle of the screen.

9 A. That is the Marsala Tita Street.

10 Q. That is right. Can you tell us where the man ----

11 A. That is where the junction is.

12 Q. Yes.

13 A. That is where he was. We were supposed to turn and go down this

14 road and he was standing there and then we went down this road

15 to the hospital, then through this street to the main street and

16 then all straight ahead to Mutnik, and the last checkpoint was

17 here in Rajkovici. There was another man and the first one was

18 standing here.

19 Q. Thank you.

20 A. Is that OK?

21 Q. Yes, thank you very much. That is very clear. Was that man at

22 the first place where you stopped at a checkpoint or was he just

23 standing there on his own?

24 A. No, that is where the barricades were in the yard of Stoja

25 Coprka. There is a bunker. There were a few people in there,

26 more than one, but he was the one who stopped us but there was a

27 whole group of them there.

28 Q. When you turned around and went back through Kozarac towards

Page 6755

1 Rajkovici, were you stopped there at another checkpoint?

2 A. Yes, the last barricades, they attempted to stop us but we did

3 not stop.

4 Q. So you passed through the barricade there and then where did you

5 go after that?

6 A. There were no further barricades from Rajkovici, and all the way

7 down to Banja Luka, we followed down that road.

8 Q. When you arrived in Banja Luka on this day, 3rd May 1992,

9 whereabouts did you go?

10 A. We went to my brother-in-law's, Ljubomir Tadic.

11 Q. Did you remain with the priest, Mladen Majkic, and his family at

12 Ljubomir Tadic's or did he go elsewhere?

13 A. He stayed with us that night and then on the day after he left.

14 Q. For how long did you stay at Ljubo Tadic's?

15 A. I stayed at Ljubo Tadic's about three to four days, until we

16 found our own accommodation.

17 Q. Did your husband Dusko remain with you at Ljubo's house?

18 A. Yes, until Thursday, until we found another accommodation.

19 Q. I would like you now to look at another photograph and it is

20 D62A. (Handed). Can you tell us if you recognise that

21 photograph?

22 A. Yes.

23 Q. What is it of?

24 A. This is the house where we were staying, but we were on the

25 other side, on the ground floor. That is the house where we

26 were in the Koste Jarica Street in Starcevica.

27 Q. You referred to staying on the other side. Could you look at

28 D62B now? (Handed). Mr. Usher, if you could put both

Page 6756

1 photographs on the monitor after the witness has identified

2 them. D62B, do you recognise that photograph?

3 A. Yes, that is that part of the house where we were staying.

4 Q. Thank you. If you could put both photographs on the monitor

5 now, Mr. Usher? You said that that house was in Koste Jarica

6 Street. Did you know who owned that house?

7 A. No, I did not know the owner. All I know is that there was a

8 Croat woman whose husband was Ukrainian and in November, the

9 previous year, she had left for Germany.

10 Q. So was anyone living in that house when you went to stay there?

11 A. No.

12 Q. The place where you had been staying the previous four days with

13 Ljubo Tadic, was that a house or a flat, an apartment?

14 A. It was a flat. It was Ljubo's flat.

15 Q. How many bedrooms were in that flat?

16 A. No bedrooms.

17 Q. Is it a large flat or a small flat?

18 A. It is very small.

19 Q. Did he have his family living with him there?

20 A. Yes.

21 Q. Would there have been room for your family and Ljubo's family to

22 have remained together in that flat?

23 A. No.

24 Q. How did you come then to move into the house in Koste Jarica?

25 A. Because we just could not all stay in such a small one room

26 flat, and then a friend of Ljubo's found us this other

27 accommodation which he was keeping an eye on, as it were, and so

28 we went to see him and we decided to get that, that we would

Page 6757

1 stay there.

2 Q. You said that the part of the house that you lived in was around

3 the other side. Did you live in the whole of this house, which

4 we can see has ----

5 A. No, that house was not habitable, just one room was really

6 habitable. Am I to show it on the picture?

7 Q. Yes, please.

8 A. This was the only room that was habitable. This was the hall

9 and the living room. It was all one part, and there was one

10 regular room on this side.

11 Q. Was it a completely built house? Had it been finished in its

12 state of building?

13 A. No, no, it was not finished. Only one room, as I said, was

14 completely finished.

15 Q. Did it have electricity?

16 A. Yes.

17 Q. Did it have water?

18 A. Yes, in the kitchen.

19 Q. Were the walls plastered and decorated?

20 A. Yes.

21 Q. What were the conditions like within this part of the house?

22 A. In that part of the house there were good conditions.

23 Q. The rest of the house, the other three storeys that we can see

24 from the front of the house in the photograph on the left, what

25 was their condition like?

26 A. It was not a finished house. There was nothing. It was not

27 plastered or -- I just think there was electricity, there were

28 cables in all these other parts on the first and the second

Page 6758

1 floor and the loft.

2 Q. This part of the house round the back, was that the basement to

3 the house?

4 A. Yes, that is the basement. On this side you cannot see it. You

5 can see it on the other side. That is the basement.

6 Q. Who was the friend of Ljubo's who allowed you to stay there who

7 had been keeping an eye on the house?

8 A. It was a friend -- the brother of a friend of Ljubo's, Nihad

9 Alic and his name was Nedim Alic.

10 Q. Did you meet Nedim Alic?

11 A. Yes, we knew them. For a long time before that we had known

12 them.

13 Q. What was the arrangement about this house in Banja Luka that you

14 could stay there?

15 A. Well, they had given us the house so we could stay there and

16 protect the house as well, because he had the keys to the house

17 and as it was not lived in there were quite a few burglaries.

18 It was broken into several times, and so basically it was

19 convenient to both of us because we were staying at the house

20 and so it was mutually profitable.

21 Q. Did he indicate that the owner of the house might want to return

22 and live in the house?

23 A. Yes.

24 Q. What would have happened if that owner had returned?

25 A. Well, nothing would have happened. We would have moved out and

26 she would have been free to move in.

27 Q. You said that you left Kozarac with your children, your

28 mother-in-law, Dusko Tadic. Were you all living together in the

Page 6759

1 basement of that house from that fourth day in Banja Luka?

2 A. No, we stayed. I myself, my mother-in-law and the two daughters

3 and Dule went back to our family house in Kozarac.

4 JUDGE VOHRAH: Mr. Kay, can you clarify this? Do you call this

5 portion in 63B the basement part of the house?

6 MR. KAY: Yes, your Honour.

7 JUDGE VOHRAH: Is it the ground floor?

8 MR. KAY: Looking at the first photograph 62A and seeing the three

9 storeys there, this is actually a submerged portion ----

10 JUDGE VOHRAH: I see, thank you.

11 MR. KAY: --- at the rear. If you go on the right-hand side, you

12 walk down a steep slope.

13 JUDGE VOHRAH: Thank you.

14 MR. KAY: Is that right, Mrs. Tadic?

15 A. Yes.

16 Q. I would like to clarify your last answer, please. Did you all

17 remain living in that basement of the house?

18 A. When we moved into the basement of that house, I myself, my

19 mother-in-law and my two children, once we have cleaned it up

20 and we could move in, once that was done, Dule went back to

21 Kozarac, to our family house, and we for security reasons stayed

22 there.

23 Q. For how long was Dule Tadic then living at that house with you?

24 A. I have not understood this. What period of time do you have in

25 mind?

26 Q. Well, we are dealing with the time that you move into the house

27 and, as you told us, that it had to be cleaned and then he went

28 back to Kozarac. I want you to tell us when he went back to

Page 6760

1 Kozarac, for how long he had been at the house?

2 A. From Sunday, on 3rd May, when we arrived at our -- at my

3 brother-in-law's, Ljubomir Tadic, we spent Sunday night at his

4 place. Monday, Tuesday and Wednesday we stayed there.

5 Throughout that time we were staying at my brother-in-law's flat

6 while we were cleaning up the other house. I was washing the

7 rugs and Dule was painting the walls, etc. Then on Thursday

8 when we moved into that house, Dule left for Kozarac. He did

9 not stay with us. He just simply helped us move in.

10 MR. KAY: Thank you. That would be a convenient moment, your Honour.

11 THE PRESIDING JUDGE: We will stand in recess for 20 minutes.

12 (11.30 a.m.)

13 (The Court adjourned for a short time)

14 (11.50 a.m.)

15 MIRA TADIC, recalled.

16 Examined by MR. KAY, continued.


18 MR. KAY: Thank you, your Honour.

19 Q. Having moved into this house in Koste Jarica, did you come to

20 know any of the people who lived around you in that

21 neighbourhood?

22 A. Yes.

23 Q. Can you tell us who your neighbours were?

24 A. There was Dragoje Balte and his wife and also the grandmother on

25 the other side.

26 Q. Had you known Mr. Balte before you moved into this house?

27 A. No.

28 Q. How often did you see him?

Page 6761

1 A. [No translation].

2 MR. KAY: Sorry, I did not get an answer there, your Honour. It is

3 cut out.

4 THE PRESIDING JUDGE: I think we have a need for another

5 interpreter -- just wait a moment.

6 THE INTERPRETER: Could you just repeat the question, please? We are

7 waiting.

8 MR. KAY: I think the microphone may have cut out, your Honour.

9 Q. How often did you see Mr. Balte?

10 A. We would see him often.

11 Q. You told us that Dusko Tadic left to go to Kozarac after you had

12 moved into the house. Did he ever visit you back there? Did he

13 ever return from Kozarac for periods?

14 A. Yes, he would visit. He visited us several times. He brought

15 our stuff from the house, the stuff we needed.

16 Q. What was the purpose for Dusko Tadic returning to Kozarac after

17 you had moved into this place?

18 A. He went back in order to work.

19 Q. Was the coffee bar in Kozarac still open at this time, as far as

20 you knew?

21 A. Yes.

22 Q. Were you able to work in Banja Luka?

23 A. No.

24 Q. Do you recollect the date when Kozarac was attacked and the

25 conflict in Kozarac started?

26 A. Yes.

27 Q. What was that date?

28 A. 24th May.

Page 6762

1 Q. In that period from when you had moved into the house and until

2 24th May, how often would you say Dusko had been back to that

3 house in Banja Luka where you were staying with the rest of the

4 family?

5 A. Between 7th and 23rd May he came on several occasions and on

6 23rd May, it was a Saturday, he joined us in that house.

7 Q. What time of the day then on 23rd May did he join you in the

8 house?

9 A. I think between somewhere 5.00 and 6 o'clock in the afternoon,

10 that is, 17 and 1800 hours.

11 Q. Do you know where he had come from before he had been to see you

12 in Banja Luka?

13 A. Yes.

14 Q. Where was that?

15 A. Then he came from Prijedor.

16 Q. Do you know how he travelled from Prijedor to Banja Luka?

17 A. Yes.

18 Q. How was that?

19 A. From Kozarac he went with Trivo Reljic by car. This is our

20 neighbour.

21 Q. Where did that take him when he went with Trivo Reljic by car

22 from Kozarac?

23 A. To Prijedor.

24 Q. How did he travel from Prijedor to Kozarac?

25 THE PRESIDING JUDGE: Prijedor to Banja Luka?

26 MR. KAY: Sorry, your Honour.

27 A. Trivo went to his house in Svodno and my husband went for Banja

28 Luka.

Page 6763

1 Q. How? Do you know how?

2 A. By train.

3 Q. Did he have his own vehicle or any other form of transport for

4 himself at this time?

5 A. No.

6 Q. When he arrived then on 23rd May at this place in Koste Jarica,

7 had you and the children and your mother-in-law settled into the

8 house by this time?

9 A. Yes, we lived there.

10 Q. But what was the state of the accommodation like for you as a

11 family?

12 A. That was mostly temporary accommodation.

13 Q. You said that your husband had returned from Kozarac several

14 times and had brought things from the family home. Did you have

15 much of your own possessions with you there in Banja Luka?

16 A. No.

17 Q. On 23rd May then when your husband arrived from Prijedor by

18 train, what did you do that evening when he arrived?

19 A. On that evening we went to visit our friends.

20 Q. What friends are they?

21 A. [redacted]

22 MR. KAY: Your Honour, I have just set a redaction mark. You saw

23 them that evening. How far away did they live from where you

24 were in Koste Jarica?

25 A. It is on the other side of Banja Luka, some four or five

26 kilometres away.

27 Q. How did you get to that house where you went that evening?

28 A. On foot.

Page 6764

1 Q. Why did you go there to that house to see those people?

2 A. Because they were our friends and we also wanted to share our

3 feelings about fleeing our house.

4 Q. From what you could tell of the mood of your husband when he

5 came to Banja Luka on this evening of 23rd May, what was the

6 state of affairs in Kozarac by that day?

7 A. It was very tense and desperate.

8 Q. Were you aware of the ultimatum that had been given by the

9 Prijedor authorities to the people of Kozarac?

10 A. Yes.

11 Q. And the ultimatum concerning the delivery up of arms by the

12 people within that town?

13 A. Yes.

14 Q. Did you know if by that time of your husband coming on 23rd May

15 whether they had complied with that ultimatum from Prijedor by

16 that time?

17 A. No.

18 Q. For how long did you stay at the house of that couple that you

19 had walked to in Banja Luka?

20 A. We stayed until Sunday afternoon.

21 Q. Had they been old friends of yours?

22 A. Yes.

23 Q. Did you both know them well?

24 A. Yes.

25 JUDGE STEPHEN: I am sorry. I have lost track of the days of the

26 week.

27 MR. KAY: The 24th May is a Saturday, your Honour -- Sunday.

28 JUDGE STEPHEN: It is a Sunday.

Page 6765

1 MR. KAY: Is a Sunday.

2 JUDGE STEPHEN: Thank you.

3 THE PRESIDING JUDGE: Is there any objection to the redaction?

4 MR. KEEGAN: No, your Honour.

5 THE PRESIDING JUDGE: OK. It will be granted.

6 MR. KAY: I am much obliged. [To the witness]: So had you and the

7 family stayed overnight with that couple?

8 A. Yes.

9 Q. Then on next day -- you told us that you left in the

10 afternoon -- where did you go after that?

11 A. You mean on Sunday 24th or on Monday 25th?

12 Q. No, you have told us that you arrived at the house of your

13 friends on the evening of 23rd May, which is a Saturday, and

14 that you stayed there until the afternoon of the next day which

15 would be Sunday, 24th May. When you left their house, did you

16 go back to that place in Koste Jarica where you had been staying

17 previously?

18 A. Yes.

19 Q. For how long then did you remain living in that house?

20 A. We lived there up until 27th June.

21 Q. On 27th June where did you go to live from that date?

22 A. We moved into a flat in Pecani.

23 Q. Is that in Prijedor?

24 A. Yes.

25 Q. I now want to talk to you about that period of time then from

26 23rd May until 27th June when you are living in Koste Jarica in

27 Banja Luka. During that time did you get a job in Banja Luka?

28 A. No.

Page 6766

1 Q. Did your husband have a job in Banja Luka?

2 A. No.

3 Q. Did he remain living with you in Banja Luka until you moved to

4 Pecani on 27th June?

5 A. No, he left before us for Prijedor.

6 Q. Can you recollect when that was that he left for Prijedor?

7 A. On 15th June.

8 Q. Then in that period from 23rd May until 15th June, was he living

9 with you in Banja Luka or was he living elsewhere?

10 A. With us in Banja Luka.

11 Q. By "living" I mean staying the night and you all being based

12 there as a family?

13 A. Yes.

14 Q. How did you and he and the rest of the family spend your time in

15 Banja Luka during this period until 15th June?

16 A. In that period we were mostly visiting our friends in Banja

17 Luka.

18 Q. Did either of you have much money at this time?

19 A. No.

20 Q. Did you have many friends in Banja Luka?

21 A. Yes, real friends.

22 Q. You referred to Dusko Tadic's brother Ljubo. Was he in Banja

23 Luka as well at this time?

24 A. Yes, yes, he lived nearby.

25 Q. Were there any times that your husband Dusko left Banja Luka to

26 travel elsewhere during this period between 23rd May and 15th

27 June?

28 A. Yes.

Page 6767

1 Q. Do you know where he travelled to?

2 A. Yes.

3 Q. Can you tell us then where did he go?

4 A. He went to Kozarac to see the state of our family house, the

5 first time round.

6 Q. Do you know when that was, when he, as you have said it, the

7 first time round went to Kozarac to look at the state of the

8 family home?

9 A. That was some seven or eight days after the conflict in

10 Kozarac. I do not know the exact date.

11 Q. Was that the only time, as far as you know, that he visited

12 Kozarac during this period or were there other times when he

13 visited Kozarac?

14 A. That was the first time, that was the first time. Then he also

15 went there another time.

16 Q. Can you remember when that other time was?

17 A. No, I do not remember the date, but it was a couple of days

18 after the first time.

19 Q. I am going to ask you some questions now about that first time

20 when he went to Kozarac. Did he go on his own or with anyone?

21 A. With his brother Ljubomir Tadic.

22 Q. Was he away for the day or for any longer period?

23 A. One day, he was away for one day.

24 Q. What time did they leave Banja Luka or what time did you last

25 see him on that day?

26 A. In the morning.

27 Q. You recollect the particular time in the morning or is it just a

28 general .....

Page 6768

1 A. No.

2 Q. Do you know how they travelled to Kozarac?

3 A. Yes, I think that they went by a car. I am not sure.

4 Q. Was that any car owned by your husband or would that have been

5 someone else's vehicle?

6 A. No, my husband did not have a car.

7 Q. So if they travelled by another car, whose car would that have

8 been?

9 A. I do not know. It might have been Ljubo's car.

10 Q. What time did they return from Kozarac?

11 A. I think that they came back in the afternoon. I do not know

12 exactly when, but they returned quickly.

13 Q. How did they get back to Banja Luka from Kozarac?

14 A. By car most probably. I do not know. I cannot remember.

15 Q. Did you actually see them return to Banja Luka?

16 A. Yes, they came to our house.

17 Q. Did they have anything with them when they returned on this

18 first visit?

19 A. I do not know what you are thinking of.

20 Q. Did they have anything with them? You said they went to look at

21 the family home -- no?

22 A. No, they did not bring anything on that first occasion.

23 Q. On the second occasion which was a few days later, was your

24 husband away for one day or for a longer period?

25 A. For two days on the second occasion.

26 Q. Again, do you know if he went with anyone or did he travel

27 alone?

28 A. With his brother Ljubomir Tadic.

Page 6769

1 Q. Do you know when they left Banja Luka on this second occasion?

2 A. I do not know the exact date. It was a couple of days after

3 that first time.

4 Q. But do you know what time of day that was?

5 A. They also left in the morning, and they came back the following

6 day in the afternoon.

7 Q. Do you know how they travelled to Kozarac on this occasion?

8 A. I do not know exactly how they left, but I know that they

9 returned in a lorry.

10 Q. Whose lorry was that?

11 A. That lorry belonged to a guy from Omarska.

12 Q. Can you recollect his name?

13 A. No.

14 Q. Why did they return in a lorry?

15 A. Because they brought the stuff from our family home, from the

16 cafe.

17 Q. What sort of stuff did they bring from the home?

18 A. They brought all the linen from the house and then they also

19 brought the interior part, I mean, the thing that was --

20 everything that was inside the cafe.

21 Q. What do you mean by that, "the interior part"?

22 A. That means things that are inside the ceiling, like in a form of

23 a net and then parts of the bar, then the glasses and all the

24 things that are needed in a cafe, like, for example, coffee

25 cups.

26 Q. What happened to those things that they had brought from the

27 cafe?

28 A. They put them in that house where we lived, that is where we

Page 6770

1 left them.

2 Q. Did they remain in that house where you lived?

3 A. We only went to fetch those things after a year.

4 Q. Did they then remain there in the building in Koste Jarica?

5 A. Yes.

6 Q. What sort of lorry was this that they returned in?

7 A. I do not know what type of a lorry that was.

8 Q. You have referred to a driver as a man from Omarska and the

9 brother of Dusko Tadic, Dusko Tadic himself, was there anyone

10 else with them?

11 A. No, just the three of them.

12 Q. So in that period then from 23rd May to 15th June, were those

13 the only two visits to Kozarac that you were aware of or were

14 there others?

15 A. No, no, only two visits.

16 Q. Were there any other places that you were aware of that your

17 husband travelled to during this period of some three weeks?

18 A. Yes.

19 Q. Where was that?

20 A. In that period he visited Trnopolje on one occasion.

21 Q. Did he go to Trnopolje on his own or with anyone?

22 A. He did not go on his own.

23 Q. Who did he go with?

24 A. With Jovo Samardzija.

25 Q. Can you tell us either by the date or in relation to the period

26 after the arrival on 23rd May when this was?

27 A. I can tell you more or less, but I do not remember the exact

28 date, somewhere between 10th and 15th June.

Page 6771

1 Q. Was this before or after the second visit that had happened to

2 Kozarac?

3 A. After the first visit to Kozarac, I think.

4 Q. Why did he go to Trnopolje with this man, Jovo Samardzija?

5 A. Jovo went to try to seek his sister, to find his sister, in the

6 collection centre in Trnopolje.

7 Q. What ethnic group is Jovo Samardzija?

8 A. He is a Serb.

9 Q. Did you know him before you came to stay in Banja Luka?

10 A. Yes.

11 Q. For how long had you known him?

12 A. Since I got married to my husband.

13 Q. Was he a friend of the Tadic family?

14 A. Yes, he was a friend of my husband's father. They were in the

15 war together.

16 Q. The sister of Jovo Samardzija, were you told or were you aware

17 of how she came to be in Trnopolje?

18 A. We knew that all the entire population had been evacuated to

19 Trnopolje.

20 Q. Where did she live?

21 A. In Kamicani.

22 Q. Did you know the sister yourself?

23 A. Yes.

24 Q. Do you know how Jovo Samardzija came to learn that his sister

25 was in Trnopolje?

26 A. No, I do not know how he came to know it. He was just going to

27 see whether she was there because he did not know where she was.

28 Q. Do you know why it was that your husband Dusko travelled to

Page 6772

1 Trnopolje with him?

2 A. Because Jovo asked him to and we insisted he go with him because

3 Jovo is an old man and he could not go on his own, and he did

4 not have anyone who was next of kin to go with him.

5 Q. You have said that Jovo is an old man -- about what age?

6 A. I think he must be between 75 and 80 years of age.

7 Q. Is he now a strong man in good health or otherwise?

8 A. No, no, he is a very weak man. He looks -- he does not look

9 good. Since I have known him he has been that way.

10 Q. Do you know how the two of them travelled to Trnopolje?

11 A. Yes.

12 Q. How was that?

13 A. By train.

14 Q. Is that from Banja Luka railway station to the Kozarac station

15 which is in Trnopolje?

16 A. Yes.

17 Q. Can you recollect what time of day it was that they left Banja

18 Luka?

19 A. I think -- I am not sure, but I think they left by train around

20 12 o'clock and they must have come back at around 3 o'clock.

21 Q. When they returned at 3 o'clock, did they have the sister of

22 Jovo with them?

23 A. No.

24 Q. Was it apparent that they had not found her there?

25 A. They did not find her there.

26 Q. Do you know what happened to this lady?

27 A. Yes.

28 Q. What was that?

Page 6773

1 A. She left with a convoy to go to Zenica.

2 Q. Do you know when that was?

3 A. No.

4 Q. During this period between May 23rd and 15th June, did your

5 husband have any weapons and by that I mean guns?

6 A. Yes.

7 Q. What sort of weapons were they?

8 A. He had a gun.

9 Q. By "gun" do you mean a hand gun, a pistol?

10 A. A regular, small hand gun, I think 765. There is a difference

11 between guns.

12 Q. Did he have any other gun with him at this time?

13 A. No, at that time, no. I think of the time, as of 23rd May, the

14 first time he went back to Kozarac he brought a rifle.

15 Q. The rifle that he brought back from Kozarac during this first

16 visit, had you seen that rifle before?

17 A. Yes.

18 Q. Do you know where he got it from?

19 A. Yes.

20 Q. Can you tell us?

21 A. Yes, he got that rifle from Kusota and I do not know what his

22 name is.

23 Q. Does Kusota live in the Kozarac area?

24 A. Yes.

25 Q. Whereabouts?

26 A. In Balte.

27 Q. What sort of rifle was that?

28 A. An automatic rifle.

Page 6774

1 Q. When had he got this rifle from Kusota?

2 A. I do not know exactly. By the end of 1991, perhaps in November,

3 December, thereabouts.

4 Q. Kusota, was he a soldier, was he mobilized at that time?

5 A. Yes.

6 Q. The hand gun that you referred to, the 765, do you know when

7 your husband obtained that?

8 A. Yes, before the war, much before the war, 1980 something.

9 I cannot remember the year.

10 Q. What was the reason for him getting the rifle from Kusota?

11 A. Kusota deserted on the Slavonia front and then he brought back

12 that rifle and gave it to my husband.

13 Q. What did your ----

14 A. Sorry, for the reason that he was taking it away from the

15 barracks -- giving it back to the barracks.

16 Q. What did your husband do with the rifle, where did he keep it?

17 A. In the loft.

18 Q. When he returned after that first visit to Kozarac with the

19 rifle, do you know where the rifle had been previously?

20 A. Yes, it was in the loft of our house, it was hidden away.

21 Q. Where was that rifle kept when you lived in this place in Koste

22 Jarica in Banja Luka?

23 A. When we were living at that house when Dule brought it the first

24 time it was in the house, in our house.

25 Q. Do you know if it had any bullets with it?

26 A. Yes.

27 Q. Can you help us with how many there were?

28 A. I think about two loads.

Page 6775

1 Q. When he went to Kozarac the second time, did he take that rifle

2 with him?

3 A. Yes.

4 Q. When he went to Trnopolje with Jovo Samardzija, did he take that

5 rifle with him?

6 A. Yes.

7 Q. What sort of clothes was your husband wearing at this time

8 between 23rd May and 15th June?

9 A. At that time he had a summer camouflage uniform.

10 Q. When you say "summer camouflage uniform", what do you mean, can

11 you describe it for us, what the colours were?

12 A. Let us say it was a uniform that looked like a sports outfit,

13 like a jump suit. You put it on on top of your civilian

14 clothes, and the part down was really wide, it was like a beige,

15 yellow and brown with spots, and the wider part on top of it, it

16 was very light cloth.

17 Q. When you were seeing your friends in Banja Luka, is that the

18 clothing that he wore?

19 A. No.

20 Q. What sort of clothes did he wear then?

21 A. Regular clothes, casual clothes that he used to wear normally.

22 Q. Is that civilian clothes?

23 A. Yes.

24 Q. On these visits to Kozarac and the visit to Trnopolje, did he

25 wear that camouflage uniform that you have described?

26 A. Yes.

27 Q. What was the reason for wearing that uniform?

28 A. Because one could not move about without a uniform and without

Page 6776

1 weapons.

2 Q. Were most people dressed in military style clothing at this time

3 in that area?

4 A. Yes.

5 Q. Was your husband mobilized for the military or any other forces

6 during this period of 23rd May to 15th June 1992?

7 A. No.

8 Q. Do you know when your husband was mobilized, if he was

9 mobilized, later?

10 A. Yes, he was mobilized as a part of the Reserve Staff of the

11 Traffic Police.

12 Q. When was that?

13 A. 16th June.

14 Q. How did it come about that he was mobilized into the Traffic

15 Police on 16th June?

16 A. Do you mean the reason why he was mobilized?

17 Q. Yes.

18 A. Well, as we were living in Banja Luka, none of us had a job and

19 my mother-in-law was not receiving her pension, we had no means

20 to support ourselves there. Then we agreed that we would go

21 back to Prijedor, and to ask his brother, Radovan Vukic, to

22 intervene with the Police Force in Prijedor, so that Dule would

23 be accepted as a member of the Traffic Police. The only reason

24 for that was our situation, because the Police Force was the

25 only job where you would actually receive wages.

26 Q. Before then, that date of 16th June, how did it come about that

27 he had not been mobilized?

28 A. It came about because he was not registered with the Ministry,

Page 6777

1 when he stopped working in Rudi Cajavec he failed to report as

2 unemployed at the Ministry, the Labour Ministry.

3 Q. You described someone as being his brother as Radovan Vukic, is

4 that right?

5 A. Yes. Not his brother, his cousin actually.

6 Q. What was his connection with the Police Force?

7 A. Well, he was a member of the Police Force.

8 Q. Was he contacted by your husband?

9 A. Yes.

10 Q. Were you aware of any discussions between them over how your

11 husband was to join the police?

12 A. Yes.

13 Q. What were they?

14 A. Well, we met with Radovan Vukic in Banja Luka and then we asked

15 him whether there was a possibility for Dule to join the Police

16 Force, if he could do anything, and then he said for him to come

17 and then we did go. Radovan talked to his superior and he

18 accepted him.

19 Q. You said your husband went to Prijedor on 15th June. Did you go

20 to Prijedor with him on that day?

21 A. No.

22 Q. Do you know what time he left Banja Luka on that day?

23 A. Yes, in the morning.

24 Q. Do you know how he travelled to Prijedor?

25 A. Yes.

26 Q. How was that?

27 A. By train.

28 Q. When did you next see your husband after he had gone to

Page 6778

1 Prijedor?

2 A. The following day, in the evening of the following day, on 16th.

3 Q. How was he dressed on that day of the evening of 16th June?

4 A. Dark blue trousers, dark blue blouse and a light blue shirt.

5 Q. Was that a uniform?

6 A. Yes.

7 Q. What uniform was it for?

8 A. It was a police uniform.

9 Q. You saw him in Banja Luka then on the evening of the next day.

10 Did he stay the night in Banja Luka on 16th June?

11 A. Yes.

12 Q. Where did he go next?

13 A. On the day after, on 17th, we left for Prijedor together.

14 Q. What time did you leave for Prijedor?

15 A. Early in the morning, 6 o'clock I think. I think our train left

16 at 6 o'clock.

17 Q. What was the purpose for the both of you going to Prijedor?

18 A. I was meant to report at the hospital for work.

19 Q. Why was that? Why were you meant to report to the hospital?

20 A. Because as of 23rd May when the state of war was declared we

21 were obliged to report for work.

22 Q. Was it your intention then to go and work at the Prijedor

23 hospital?

24 A. Yes.

25 Q. Did you make the arrangements there so that you could return to

26 work there?

27 A. Yes, I reported there, but at that stage I was not needed.

28 Q. When were you needed for work in the hospital at Prijedor?

Page 6779

1 A. In August 1992, that is when I started.

2 Q. Travelling to Prijedor in the early hours of 17th June, did you

3 remain in Prijedor that day or did you return to Banja Luka?

4 A. On that day I spent the night and then the day after I went back

5 to Banja Luka.

6 Q. Where did you spend the night in Prijedor?

7 A. With [redacted]

8 Q. Whereabouts did they live?

9 A. In [redacted]

10 Q. What sort of age are these people?

11 A. Between 65 and 70 years of age.

12 Q. Is [redacted] in good health?

13 A. Do you mean at that time or just now?

14 Q. Now.

15 A. No, not now. He is ill now.

16 Q. What about his wife?

17 A. She is all right. She is ill as well but better than him.

18 Q. Were they family friends of yours and Dusko or friends of either

19 of your family?

20 A. Well, we knew each other and they are the [redacted]

21 [redacted].

22 Q. What nationality -- what ethnic background is [redacted]?

23 A. [redacted]

24 Q. You told us that having spent the night there you returned to

25 Banja Luka the next day. Did your husband Dusko spend that

26 night with you?

27 A. Yes.

28 Q. At what time did you return to Banja Luka?

Page 6780

1 A. I do not know exactly when I came back, but during the day,

2 sometime during the day.

3 Q. Do you know where your husband was working at this time?

4 A. Yes.

5 Q. Where was that?

6 A. At Orlovci point.

7 Q. You told us earlier that you came to live in Prijedor on 27th

8 June. Did you visit Prijedor on any more occasions between this

9 date and 27th June?

10 A. On 23rd June I came to Prijedor again.

11 Q. Why was that?

12 A. Because I needed to clear up the flat into which we were

13 supposed to move.

14 Q. On this occasion, on 23rd June when you returned to Prijedor,

15 had your husband obtained a new flat in Prijedor?

16 A. Yes, he was given a flat by the Crisis Command.

17 Q. Was it then just the one visit by you in this period before you

18 moved to Prijedor on 27th June?

19 A. No, two. On the first occasion I came to Prijedor to report for

20 work, and the second time I came again on 23rd to have a look at

21 the apartment into which we were supposed to move, actually to

22 clean it up and to pack away the stuff that we were supposed to

23 mail to the previous owner. Then on the third occasion I came

24 on the 27th when I brought my mother-in-law and my children

25 along.

26 MR. KAY: Your Honour, I have been passed a note. We need a

27 redaction on page 4888, lines 3, 8, 19 and 20 for protected

28 persons.

Page 6781

1 MR. KEEGAN: We have no objection, your Honour. It appears it is

2 also on line 2.

3 MR. KAY: Thank you.

4 THE PRESIDING JUDGE: Very good. That request will be granted for

5 redaction.

6 MR. KAY: I am much obliged.

7 Q. During this period before you moved to Prijedor then on 27th

8 June, did your husband visit you and the family in Banja Luka?

9 A. Could you repeat that question, please? I was not

10 concentrating.

11 Q. Yes. During this period after you first of all go to Prijedor

12 with him on 17th June and until you moved to live there on 27th

13 June, did your husband ever return to Banja Luka to visit you

14 and the family?

15 A. Yes, he came on that first occasion when he took me to Prijedor

16 and then the second time. Basically, on 23rd when I went to

17 Prijedor I did not go on my own; I went with him.

18 Q. So can you tell us then when he returned to Banja Luka?

19 A. On that second occasion I cannot remember exactly, but it must

20 have been on 22nd in the evening and then we got there on 23rd

21 in the morning by train. I cannot remember exactly.

22 Q. When you got there on 23rd had the flat in Pecani that you

23 described already been allocated to you?

24 A. Yes.

25 Q. I would like you now to look at a photograph, D67. If this

26 could be put on the overhead monitor. (Handed). Do you

27 recognise that photograph there, madam? What it is a photograph

28 of?

Page 6782

1 A. Yes. Yes, that is the building where we were staying.

2 Q. Can you indicate with that pointer for us which flat in that

3 building you occupied?

4 A. Yes. [The witness indicated]. On the third floor, this is the

5 living room and that was the balcony.

6 Q. We can see two windows on the third floor, one on the left and

7 one on the right. Is the window on the right part of that flat?

8 A. No, not on the right. Just this window to the left.

9 Q. Thank you. Do you know who had lived in that apartment before

10 you moved there?

11 A. Yes.

12 Q. Who was that?

13 A. It was Hasan Talundzic.

14 Q. Who is he?

15 A. He used to work for the Police Force in Prijedor, a newly

16 elected head of the Police Force. Once his party came to power.

17 Q. How did you learn that he owned that flat?

18 A. Well, our friends told us.

19 Q. By "friends" who were they?

20 A. Well, for example, our friend Nada Vlacina had told us that he

21 had been living there, and on the basis of property that we

22 found in the flat we knew it was him, but we did not know him

23 personally. Radovan Vukic told us the same thing that Hasan

24 Talundzic used to live in that flat.

25 Q. So when you moved to live there was there anyone living in that

26 apartment?

27 A. No.

28 Q. Was that apartment fully furnished when you moved to live there?

Page 6783

1 A. Yes.

2 Q. What happened to the furniture within that apartment?

3 A. Well, that apartment was looked after by his wife's sister who

4 had another apartment, and then the two of us agreed on the

5 phone, she told me what she wanted from that apartment and then

6 the first few days I was packing stuff away, etc., the

7 children's clothes, valuables and so on.

8 Q. Why could you not live in the Tadic family home in Kozarac at

9 this time?

10 A. At that stage it was not possible to either live or go back or

11 even travel through Kozarac.

12 Q. Do you know why that was?

13 A. Because there were war operations going on there.

14 Q. Did the wife's sister of the previous owner collect those items

15 from the flat or were they delivered to her?

16 A. It was delivered to her.

17 Q. Whereabouts was that?

18 A. I do not understand, what was where?

19 Q. Where were they delivered to?

20 A. To her apartment.

21 Q. When did that happen?

22 A. A few days after we moved in, after 27th June, because all that

23 was standing there packed and we had to wait to find some means

24 of transport. So when all of us were already in the apartment

25 after 27th.

26 Q. The property that you had had in Banja Luka that had come from

27 your family home, did you ever take that from Banja Luka and

28 bring it to Prijedor?

Page 6784

1 A. Yes.

2 Q. When did that happen?

3 A. It was later on in the summer, after a few months.

4 MR. KAY: Your Honour, that is actually a convenient moment.

5 THE PRESIDING JUDGE: We will stand in recess until 2.30.

6 (1.00 p.m.)

7 (Luncheon Adjournment)






















Page 6785

1 (2.30 p.m.)

2 MIRA TADIC, recalled.

3 Examined by MR. KAY, continued.

4 THE PRESIDING JUDGE: Mr. Kay, you may continue.

5 MR. KAY: Thank you, your Honour. Mrs. Tadic, for how long did you

6 live in Prijedor having moved there on 27th June 1992?

7 A. From 27th June 1992 until the end of July 1993.

8 Q. Did you move to Prijedor with the same members of your family

9 that you moved to Banja Luka with, being your children and your

10 mother-in-law?

11 A. With my children, with my mother-in-law and with my husband.

12 Q. What work was your husband doing in Prijedor when you first

13 moved there?

14 A. He was a traffic policeman.

15 Q. For how long did he work in that job?

16 A. Up until the month of August '92, more or less.

17 Q. Did you know any of his work colleagues with whom he worked?

18 A. Yes, I met them then.

19 Q. Who were they?

20 A. His colleagues were Miroslav Brdar and Miroslav Cvijic.

21 Q. Did you know either of them before that time?

22 A. No.

23 Q. You said your husband worked in the reserve traffic police until

24 August 1992. Where did he go to work after that?

25 A. Then he did not work in the traffic police but in the normal

26 police.

27 Q. Do you know when he started his duties in the normal police?

28 A. I do not know exactly. I think it was in August, somewhere

Page 6786

1 towards the end of August.

2 Q. Do you know whereabouts it was that he was working with the

3 normal police?

4 A. Yes.

5 Q. Where?

6 A. First, he worked -- he secured the bridge by the new Hotel

7 Prijedor, then for a while at the railway station, he secured

8 the railway station, and then he secured the SUP building in the

9 centre of the town and then he worked at the police station in

10 Kozarac.

11 Q. You said that he secured the bridge near the hotel. Is that the

12 bridge over the River Sana?

13 A. Yes.

14 Q. Can you recollect when it was that he went to work for the

15 Kozarac police?

16 A. I think in September, yes. I do not recall the exact date.

17 Q. Can you tell us anything about his routine, first of all, when

18 he worked for the traffic police in Prijedor, how regularly did

19 he work for them?

20 A. Well, he worked very often. I really never could figure that

21 out, whether he worked in the first, second or the third shift,

22 but he was at work very often.

23 Q. Did he have a similar shift system when he went to work for the

24 normal police in Prijedor?

25 A. Yes, I think so.

26 Q. How would you describe your husband's character during this

27 period from June until August 1992?

28 A. Sorry, I did not understand.

Page 6787

1 Q. How was your husband behaving during this period of June until

2 August 1992?

3 A. He behaved normally, as he had behaved previously.

4 Q. When he was off duty were you with him? How did he spend his

5 time, can you tell us?

6 A. We spent the time either at home or with our friends.

7 Q. Did you have many friends in Prijedor?

8 A. Yes.

9 Q. When he was working in Prijedor and you were living with him

10 from 23rd June 1992, did he spend periods away from home? Other

11 than when he was working, did he spend periods away?

12 A. No.

13 Q. When he was off duty, do you know where he spent his time

14 mainly?

15 A. Yes.

16 Q. Where was that?

17 A. Well, for example, with our friends, Vlacina family, or the

18 Sobot family or Vukic, at my sister's. That is mostly where he

19 went.

20 Q. When he was off duty did you spend time with him?

21 A. Yes, up until the moment when I started working.

22 Q. You told us earlier that that was in August that you started

23 working at the hospital in Prijedor. Can you recollect what

24 date that was?

25 A. On 2nd August.

26 Q. Again were you working as a general nurse in the Prijedor

27 hospital?

28 A. Yes, I worked at the ambulance services, first aid.

Page 6788

1 Q. Were you working every day or was it only occasionally?

2 A. Not every day; I worked in shifts.

3 Q. Was that a regular shift or did that shift vary?

4 A. That was a regular shift.

5 Q. Which shift were you on?

6 A. For example, I worked one day, then would be free on the

7 following day. Then I would work overnight and then I would be

8 free for two days.

9 Q. So did that mean that sometimes you worked on the weekends and

10 sometimes you worked during the week?

11 A. Yes.

12 Q. But this was a regular job?

13 A. Yes.

14 Q. For how long did you work at the Prijedor hospital?

15 A. For a year.

16 Q. So was that until you left Prijedor?

17 A. Yes.

18 Q. You said that the reason for your husband taking this work for

19 the reserve traffic police was so that you could receive some

20 form of income. Was he paid?

21 A. Yes.

22 Q. So you received an income during this period, is that right?

23 A. Yes.

24 Q. During this period between June until September 1992, did your

25 husband become involved in any political activity?

26 A. Yes.

27 Q. What activity was that?

28 A. That was an activity for the revival of the authority and of the

Page 6789

1 town of Kozarac itself.

2 Q. How did he become involved with this revival of the town of

3 Kozarac?

4 A. During that period of time, Serb refugees started to arrive in

5 the Kozarac area, and that is why he took part into the revival

6 of Kozarac.

7 Q. What period are we talking about?

8 A. It is August and September 1992.

9 Q. Did you yourself become involved in any political activity?

10 A. No.

11 Q. You had previously been a member of the SDS?

12 A. Yes.

13 Q. Did you in any way contribute to the activities of that

14 political party?

15 A. No.

16 Q. We know from evidence in this Court that your husband became the

17 President of the SDS in the middle of August 1992. Did you have

18 any part in relation to his election or appointment to that

19 position?

20 A. No.

21 Q. Were you present at any meeting when that happened?

22 A. No.

23 Q. We have also heard that your husband became the Secretary of the

24 Local Commune in Kozarac. Were you aware that he held that

25 position?

26 A. Yes.

27 Q. What exactly did he do in that position as Secretary to the

28 Local Commune?

Page 6790

1 A. He worked on the revival of the town, that is, settling of the

2 population, also going around to see abandoned houses. He

3 worked at the Red Cross as well. Those were his tasks.

4 Q. Do you know when he started this work as Secretary of the Local

5 Commune?

6 A. I do not know the exact date, but I think it was in October '92.

7 Q. Do you know who else he was involved with in Kozarac working to

8 revive the town after these refugees came into the area?

9 A. Yes.

10 Q. Can you name some of those people?

11 A. Who worked with my husband? Those people who worked with my

12 husband in the Kozarac area were Bosko Dragicevic, Branka

13 Jasikovic and the other people were refugees and I do not know

14 their names.

15 Q. Did you visit Kozarac in June/July/August or September?

16 A. I visited Kozarac only in August, later then as well in

17 September and in October and so on.

18 Q. How often did you visit Kozarac in August?

19 A. In August, just once.

20 Q. Did you go back to the family home?

21 A. Yes.

22 Q. What was the state of the home at that time?

23 A. Devastated. Nothing was in there except for some photographs.

24 Q. What was the state of the town like?

25 A. The same, like a phantom town.

26 Q. On this occasion in August when you visited the town, did you

27 undertake any help on behalf of anybody?

28 A. I do not understand what type of help do you mean. Do you mean,

Page 6791

1 how did I go to visit?

2 Q. No. Did you yourself help anybody or do anything for any of

3 your friends when you visited Kozarac on this occasion in

4 August?

5 A. On that occasion there was nobody there, nobody, as far as the

6 population is concerned.

7 Q. The refugees that you spoke of, did you see any of them in the

8 Kozarac town at that time in the middle of August?

9 A. No.

10 Q. In September 1992, how many times did you visit the town then?

11 A. I do not know exactly how many times. On that second occasion

12 I did meet refugees -- it was in the month of September -- and

13 they had, I do not know how to describe this, they were having a

14 meeting and basically they had cocktails, and that is when they

15 met, and that was when the Local Commune was first set up.

16 Q. Whereabouts did this meeting take place?

17 A. At the primary school in Kozarac.

18 Q. You have referred to the Jakupovic family when you gave

19 evidence. Did you ever meet them in Prijedor whilst you were

20 living there?

21 A. Yes, we did visit each other.

22 Q. Can you remember when you visited each other, perhaps how often

23 that was?

24 A. Well, I do not remember -- I cannot remember exactly. I believe

25 we visited them twice or thrice, and the same about them

26 visiting us -- not the whole family. The ones that came to

27 visit us were his wife and daughter and I, my husband and our

28 daughter went to visit them.

Page 6792

1 Q. The name of the wife of Adil Jakupovic is what?

2 A. Nasiha Jakupovic.

3 Q. Did she ask for your help in any way?

4 A. Yes.

5 Q. What did she ask?

6 A. She asked me to look for some documents in the family house in

7 Kozarac when we went there, some travel documents.

8 Q. By "travel documents" what do you mean?

9 A. What I mean is passport and an ID.

10 Q. When did she ask this of you?

11 A. I do not know, around that time. It must have been in August,

12 but I cannot remember exactly.

13 Q. So, did you look for these documents in their former house in

14 Kozarac?

15 A. Yes, we did look for them, Dule and myself.

16 Q. What was the state of their house when you visited it?

17 A. The house had not been destroyed but it was in disarray.

18 Everything was thrown everywhere.

19 Q. What did you find there?

20 A. We found Adil Jakupovic's driving licence, a few family photos

21 and a doll which I took and gave to their daughter.

22 Q. Did you find the travel documents that they had asked for?

23 A. No, it was not possible.

24 Q. Were you asked to look in a particular place for those

25 documents?

26 A. No, I cannot remember.

27 Q. Some years later when the German police arrested your husband in

28 Germany, in Munich, they found a copy of an expired driving

Page 6793

1 licence belonging to Adil Jakupovic amongst his papers. Did you

2 know he still had that document?

3 A. Yes.

4 Q. Do you know why he still had that document?

5 A. Probably he had not managed to give it to Adil or maybe Adil had

6 no use for it. I do not know.

7 Q. You referred to finding photographs there. Did you ever give

8 those to the Jakupovic family?

9 A. Yes.

10 Q. They were living in Prijedor at this time in the summer of 1992?

11 A. Yes.

12 Q. Is that right?

13 A. Yes.

14 Q. Then they moved to Trnopolje. Were you aware that they had

15 moved to Trnopolje?

16 A. Yes.

17 Q. Can you recollect when that was?

18 A. I think it must have been September '92, September or October.

19 Q. When your husband was made Secretary of the Local Commune, was

20 he also working for the police in Kozarac?

21 A. Yes, for a time.

22 Q. Can you recollect when he stopped working for the police?

23 A. I believe mid October '92, he stopped working for the police and

24 all he did was act as Secretary of the Local Commune.

25 Q. At this stage you were also working as a nurse in Prijedor.

26 Were you being paid for your employment?

27 A. Yes.

28 Q. When your husband was working as the Secretary to the Local

Page 6794

1 Commune, do you know if he was being paid?

2 A. Yes.

3 Q. How was he paid?

4 A. How do you mean?

5 Q. Do you know who paid him? Was there ----

6 A. The municipal authorities.

7 Q. Is that the municipal authorities in Prijedor?

8 A. Yes.

9 Q. Although you were living in Prijedor, did you stay for any

10 period of time during 1992 in Kozarac?

11 A. Only to visit.

12 Q. So you did not stay for a weekend or stay overnight in any

13 building there?

14 A. Not in Kozarac, no, but I did occasionally spend a weekend with

15 my parents in the country.

16 Q. By that do you mean in Vidovici?

17 A. Yes.

18 Q. How often would that have been that you would have stayed the

19 weekend at Vidovici? I am talking now about 1992.

20 A. Not too often, on occasion of some important holidays --

21 29th November, for example.

22 Q. When your husband moved to work for the police in Kozarac and to

23 work at the Local Commune, did he still live at the family home

24 in Prijedor?

25 A. Yes.

26 Q. Were there occasions when he ever stayed overnight and stayed

27 behind in Kozarac?

28 A. Yes, if he was on call for the police.

Page 6795

1 Q. Did he have any vehicle of his own or means of transport during

2 this part of the year, from September until the end of 1992?

3 A. No.

4 Q. How did he travel backwards and forwards from Prijedor to

5 Kozarac?

6 A. Well, mostly in the morning he would travel by bus and during

7 the day he would manage either hitchhiking or sometimes the

8 Commander of the police force would go to Prijedor as well, so

9 that is how he travelled.

10 Q. What was the reason for you ceasing, to end, your stay in that

11 flat in Prijedor in 1993?

12 A. In 1993 we received a written decision that we had to move out.

13 Q. Is that move out from the apartment?

14 A. Yes.

15 Q. Do you know why you received that written decision to move out

16 from the apartment?

17 A. That notice to move out we received because my husband had not

18 been a member of the army and that is why he could not keep it.

19 Q. Was your husband ever mobilized in the army in 1993?

20 A. Yes.

21 Q. When was that?

22 A. In March 1993 he was forcefully mobilized twice.

23 Q. For what length of time?

24 A. The first time for a few days and then he came back and the

25 second time it was a fortnight.

26 Q. Do you know where he went on that first time of his

27 mobilization?

28 A. Yes, somewhere on the Gradacac battlefield.

Page 6796

1 Q. For the second mobilization of a fortnight?

2 A. The same.

3 Q. Had the military authorities been trying to mobilize your

4 husband before these two occasions?

5 A. No.

6 Q. You said that you lost your flat in Prijedor because he had not

7 been mobilized in the army.

8 A. Yes.

9 Q. So how did that come about, can you explain it to us?

10 A. Well, let us say soldiers who had been with the army between

11 1991 and 1992 and were taking part in the war had the right to

12 stay where they were, and they were not being kicked out of

13 their apartments.

14 Q. Perhaps if we just look at a document that is in evidence before

15 the Court, Exhibit 373A and B. If you put the English

16 translation on the monitor, but put the documents in Serbo-Croat

17 to the witness? Perhaps it can be taken back a bit so we can

18 get a little bit more on the screen? Thank you. This is a

19 document from the Prijedor municipality?

20 THE PRESIDING JUDGE: I may be the only person who cannot read it.

21 Can you bring it up just a little bit, if you want us to read

22 it?

23 MR. KAY: Yes. (To the witness): This is a document from the

24 Prijedor municipality dated 1st June 1993. It is a request from

25 the iron ore mine of Ljubija from Prijedor for the eviction of

26 Dusan Tadic, members of his household and belongings from the

27 flat in Pecani estate, B2, with various articles quoted. Do you

28 recollect this document being received by your husband?

Page 6797

1 A. Yes, I do remember.

2 Q. It states that the eviction shall be executed on 21st June 1993

3 at 11 o'clock in the morning -- that is in paragraph (2) -- and

4 who is going to ----

5 A. Yes, I know.

6 Q. --- empty the flat. Can you tell us what happened then? Were

7 you forcibly evicted by the authorities on a date?

8 A. Prior to that date, when my husband was in war in the month of

9 March, I myself received -- was served a similar notice and then

10 I asked the municipal authorities to postpone this until that

11 date indicated here, and then they met our wishes in that

12 respect. But on that day, on 21st June, we did not empty the

13 apartment. I think we vacated the premises two days later. We

14 were not evicted forcibly, but we reached an agreement with the

15 previous owner to allow us two extra days in which to move out.

16 Q. By the "previous owner" do you mean the Ljubija iron ore mine?

17 A. I do apologise. What did I say? Maybe I should have said the

18 future owner. No, he came with a decision allocating him that

19 apartment. He was a war invalid and that is whom I meant. We

20 agreed with him.

21 Q. So when you were eventually evicted from the flat and you left

22 some two days later, where did you go?

23 A. We went to one room flat above the Jugobanka premises in

24 Prijedor.

25 Q. How did you obtain that accommodation?

26 A. I got it from a colleague who used to work at the hospital.

27 Q. So was that accommodation linked with the hospital of Prijedor

28 because of your job?

Page 6798

1 A. No.

2 Q. Was it a private arrangement with the colleague?

3 A. Yes.

4 Q. For how long did you stay in this other flat in Prijedor?

5 A. Until the end of July 1993.

6 Q. Was your husband still working at the commune in Kozarac at this

7 stage?

8 A. Yes.

9 Q. How were your husband's relations as Secretary of the Commune

10 with the main municipality in Prijedor, the town hall there?

11 A. With the town hall there, well, he entertained good relations,

12 but there were strained relations between the army and the

13 police force.

14 Q. Why was that?

15 A. Well, first of all, due to his arrest, because officially he was

16 obliged to work as Secretary of the Local Commune and, according

17 to some rules that existed, the army was not supposed to arrest

18 him and send him to the battlefield.

19 Q. Did his work as Secretary of the Local Commune count as a form

20 of work obligation that people were also required to do?

21 A. Yes, that was work obligation.

22 Q. You referred to him being arrested and that the military were

23 not supposed do that. Why was he arrested?

24 A. Well, on a daily basis there were conflicts between the civilian

25 and the military authorities because they each did things their

26 own way, so that is why.

27 Q. Why did the army arrest him?

28 A. Well, there was this conflict relating to the allocation of the

Page 6799

1 premises we were allocated in Prijedor.

2 Q. Is that that flat in Pecani?

3 A. No, no, the other premises, the cafe, business premises,

4 I meant. That is what we received when we came to Prijedor.

5 Q. What did you receive as business premises?

6 A. A cafe bar called OK in Edvard Kardelj Street. I believe that

7 was the name of street.

8 Q. Had your husband applied to open a cafe at those premises?

9 A. Yes.

10 Q. Did he ever open a cafe in those premises?

11 A. No.

12 Q. So was he granted the licence to open a cafe there but it never

13 happened?

14 A. Yes.

15 Q. Can you tell us why it did not happen?

16 A. Well, the Mayor at that time, Jakov Maric, did not allow it

17 because he himself was interested in the same premises.

18 Q. Did he ever take those premises for himself?

19 A. Yes.

20 Q. At what period are we talking about here when your husband

21 applied for the cafe licence?

22 A. Immediately upon arrival to Prijedor. We are referring to the

23 month of June '92. I cannot remember the exact date, but it was

24 in July, that is, upon our arrival to Prijedor.

25 Q. What was the reason for that? Why did he apply to open a cafe?

26 A. The reason was that we used to have a cafe in Kozarac, and in

27 instead of that area, those premises, we wanted to rent another

28 place where to open a cafe in order to have something to live

Page 6800

1 on.

2 Q. So was it planned then in those early days in Prijedor that that

3 would be a future business?

4 A. Yes.

5 Q. You told us that you stayed in this later apartment for a month

6 in July 1993. Where did you go after that?

7 A. Yes. Afterwards I left for Munich.

8 Q. Where was your husband when you left for Munich?

9 A. He stayed on a few days in Prijedor after I left.

10 Q. Why did you leave to go to Munich?

11 A. For economic reasons.

12 Q. Where did you go and stay in Munich?

13 A. I went to my sister-in-law's, Sofija Tadic.

14 Q. You said your husband came a few days later. Did he join you

15 there in Munich?

16 A. No, after a few days he fled to Belgrade.

17 Q. Why did he flee to Belgrade?

18 A. Because he was going to be arrested by the military police and

19 he was receiving threats. Major Jakov Maric issued threats to

20 his life.

21 Q. Why was he going to be arrested by the military police?

22 A. Because of that business with the cafe.

23 Q. So how could the military police have arrested him because of

24 the cafe? Can you explain that to us?

25 A. I explained that to you. Major Jakov Maric was a Major in the

26 military police, and he wanted to have those -- that cafe which

27 we had -- which we had the right to have.

28 Q. Did he flee Munich or Prijedor because he was going to be

Page 6801

1 arrested by the military police?

2 A. He fled from Prijedor to Belgrade and for those reasons.

3 JUDGE STEPHEN: I wonder if you could clarify the confusion between

4 "mayor" and "major"?

5 MR. KAY: Yes. [To the witness]: We had a translation that it was

6 "Mayor Maric" and you have just referred to "Major Maric" of

7 the military police. That is maybe why I was asking you this

8 question again. Perhaps if you can explain then who Maric was

9 so that we have that in our minds?

10 A. There was a Major Jakov Maric. He was in the army. He was an

11 officer in the army. Major is an army rank. That has nothing

12 to do with the civilian authorities. At that time in Prijedor

13 we had the civilian and military authorities and also the third

14 authorities which were the police authorities.

15 Q. What the reason for your husband leaving Prijedor?

16 A. He was fleeing the military and the police authorities.

17 Q. He went from Prijedor to where?

18 A. From Prijedor he went to Banja Luka, to his brother's, Ljubomir

19 Tadic.

20 Q. You mentioned in your evidence earlier that you were in Munich.

21 Did he join you in Munich?

22 A. Yes, he joined me in October 1993.

23 Q. So, for how long were the two of you apart at this time?

24 A. We were apart in August, September, up until 23rd or 25th

25 October when he arrived to Munich.

26 Q. From Banja Luka did he go via Belgrade to Munich?

27 A. Yes.

28 Q. When he arrived in Munich did he stay with you there?

Page 6802

1 A. Yes.

2 Q. In Munich did he live with you in the house of your

3 sister-in-law or did you live elsewhere?

4 A. No, before he arrived I moved at his -- in his brother Mladen's

5 house.

6 Q. Is that where he joined you in Mladen's house?

7 A. Yes.

8 Q. Your husband was arrested in February 1994 in Munich. In

9 between October and February 1994, did he have any work in

10 Munich?

11 A. No, he worked in his brother's cafe.

12 Q. Had the two of you planned to settle in Munich?

13 A. Yes.

14 Q. Did you apply to live in any other country?

15 A. No, we did not apply, but we actually thought about it.

16 Q. Where did you think of going to?

17 A. We were discussing going to, sort of, a third country like

18 Australia or Canada -- somewhere where it would be better to

19 live.

20 Q. Why did you want to live elsewhere other than in Munich?

21 A. We wanted to live in Munich, but we thought that somewhere else

22 it would be better for us, like, for example, in Canada or

23 Australia.

24 Q. Why was that?

25 A. For financial reasons.

26 Q. Were you present at Mladen's house on the day that your husband

27 was arrested in Munich in February 1994?

28 A. Yes, I was in the flat. My husband was arrested in the street.

Page 6803

1 MR. KAY: Thank you. That is all I ask.

2 THE PRESIDING JUDGE: Cross-examination, Mr. Keegan?

3 Cross-examined by MR. KEEGAN

4 MR. KEEGAN: Thank you, your Honour.

5 Q. Mrs. Tadic, you said that your father's name was Radovan?

6 A. Yes.

7 Q. Did he have a nickname?

8 A. Yes.

9 Q. What was that?

10 A. Baja.

11 Q. What was his date of birth?

12 A. He was born in 1936, I do not know when exactly -- I am sorry,

13 I have just remembered, on 2nd August 1936.

14 Q. How many brothers and sisters do you have?

15 A. One brother and two sisters.

16 Q. One of your sisters name is Jelena Gajic?

17 A. Yes.

18 Q. Does she currently live in Prijedor?

19 A. Yes.

20 Q. Your brother's name, Marko?

21 A. No, Mirko.

22 Q. Did he have a nickname?

23 A. No.

24 Q. During the summer of 1992 was he a guard or a part of the

25 perimeter security at the Omarska camp?

26 A. No.

27 Q. Do you know a man named Dragoje Vidovic nicknamed "Tepo"?

28 A. Yes.

Page 6804

1 Q. How was he related to you?

2 A. He is my cousin.

3 Q. What was his father's name?

4 A. Borislav Vidovic.

5 Q. Have you had conversations with or exchanged correspondence with

6 your husband, your ex-husband, since he has been here in jail in

7 The Hague?

8 A. Yes.

9 Q. Did you have conversations with him or exchange correspondence

10 when he was in jail in Germany?

11 A. No, while he was in jail in Germany I only received one letter

12 from him. I only received one letter.

13 Q. So you did receive a letter and that was in February 1994 from

14 your husband?

15 A. No, in February 1994 he was arrested, and I received the letter

16 only in September '94 for the first time.

17 Q. Do you recall in that letter where he stated to you: "We have

18 been divorced from 1985 and have only been seeing each other

19 once in a while. Remember that we spent each night together

20 from 15 to 20 June 1992. I worked for the traffic police in

21 Prijedor. I hope that you will be able to testify". Do you

22 recall that?

23 A. No, I do not recall that, really I do not.

24 MR. KEEGAN: Can we have this marked as the next Exhibit, please,

25 Prosecution Exhibit 354?

26 MR. KAY: Is there a copy for the Defence, please?

27 MR. KEEGAN: Yes, it was previously provided in your other materials

28 which you received early in the case.

Page 6805

1 MR. WLADIMIROFF: I cannot remember that.

2 THE WITNESS: Do I have to read everything or ----

3 MR. KEEGAN: No, you do not.

4 THE WITNESS: --- just to find that?

5 MR. KEEGAN: No, you do not.

6 MR. KAY: I wonder if the Prosecution could provide us with a

7 translation, your Honour? I have it in Serbo-Croat here.

8 MR. KEEGAN: Certainly. Here is also a copy for the Judges.

9 (Handed). The page you want to turn to is the one marked 104 at

10 the top of the page, Mrs. Tadic.

11 A. I have not received this letter. I have never received this

12 letter. That is not the letter I thought -- I meant.

13 MR. KAY: Your Honour, this is the first time we have seen this

14 letter. It is a document that, if it had been before my eyes,

15 I would have recollected. There is no doubt about that and

16 Mr. Wladimiroff even more so. I wonder if the Prosecution could

17 advise us where it was found and ----

18 MR. KEEGAN: Certainly, in the materials seized by the Germany

19 authorities and you received it in the materials that you

20 received from them.


22 MR. KEEGAN: Binder 4 of the German materials.

23 THE PRESIDING JUDGE: We can argue back and forth. Let us see. This

24 is not something that you have offered previously in the

25 materials?

26 MR. KEEGAN: No, your Honour, it is not.

27 THE PRESIDING JUDGE: Do you have the binder 4 with you here?

28 MR. WLADIMIROFF: It might be a misunderstanding, your Honour. What

Page 6806

1 we had is the material from the German lawyer. We got also

2 binders and also binder No. 4. This was not in the binder we

3 got from the German lawyer. So, the Prosecution expect us to

4 have it in our binder, but they did not give it to us.


6 MR. KEEGAN: It was our understanding in June of last year you

7 advised us you had binders 1 through 10 of the German materials.

8 MR. WLADIMIROFF: That is right, but I had no reason to believe that

9 there was something else that, apparently, was not in the binder

10 that I got. So you assumed that I had a complete binder and I

11 assumed I had a complete binder, but apparently there was more

12 in the binder than we got because we did not get it from the

13 Prosecution. It was not disclosed to us.

14 THE PRESIDING JUDGE: It was supposed to be in a binder, but you say

15 it was not in the binder and this came from the German

16 authorities. I have no way ----

17 MR. WLADIMIROFF: Not from the authorities, your Honour.

18 THE PRESIDING JUDGE: I mean from the German lawyer, excuse me. I do

19 not know how to resolve it since I have never seen what was in

20 the binder.

21 MR. KEEGAN: Your Honour, we asked them, we also showed them the

22 additional binders that they had not received here.

23 THE PRESIDING JUDGE: Let us see if the witness can identify it. Let

24 us get past that first and then we will see where we are.

25 MR. KEEGAN: Mrs. Tadic, if you would look through that whole letter,

26 please, and particularly to the end of the letter.

27 A. Yes. Let me just see whether there is just -- this is just one

28 letter or several letters. I have never received this letter

Page 6807

1 and the one that I received in September had only two pages, and

2 it basically spoke about the state of health of my husband, and

3 the prison and about discussions with his lawyers, and it is a

4 the first time that I see this letter.

5 Q. Your daughter Valentina, did she receive a letter in April '94?

6 A. No, nobody received a letter. This letter, if that should be

7 that letter -----

8 THE PRESIDING JUDGE: Is there an objection?

9 MR. KAY: Yes, your Honour. The witness has said quite clearly she

10 has not received this letter. Its provenance within these

11 proceedings is rather unusual, to say the least. Mr. Reid, you

12 will remember, the investigator ----

13 THE PRESIDING JUDGE: Excuse me. Mrs. Tadic -----

14 THE WITNESS: This letter was stolen from the car ----

15 THE PRESIDING JUDGE: Wait a moment. I do not think your lawyer

16 would like you to continue.

17 A. I am sorry.

18 Q. Do you speak English -- or Mr. Kay, rather, the lawyer for

19 Mr. Tadic -- do you speak English, Mrs. Tadic?




23 THE PRESIDING JUDGE: Would you take your earphones off, please, so

24 that we can discuss this among counsel. Take your earphones

25 off. OK. Go ahead, Mr. Kay.

26 MR. KAY: Your Honour, this is a letter which provenance is unusual,

27 to say the least. It was not adduced by Mr. Reid, the

28 Prosecution investigator, you may recollect, who gave evidence

Page 6808

1 at the end of the Prosecution case, producing a number of

2 documents that were seized by the German police in the premises

3 of Mr. Tadic in Munich.

4 It now is produced in cross-examination of a Defence

5 witness by a witness who has said she has never seen it. In

6 those circumstances, the Prosecution cannot use this document

7 against her because she has said she has not seen it. She has

8 not written it herself. That is not being put to her. In those

9 circumstances, this cross-examination in this form should not

10 continue.


12 MR. KEEGAN: Of course, your Honour, we are not bound to accept her

13 first refusal of the letter, but entitled to explore that.

14 Secondly, the questions had ceased as to the issue of the

15 letter, in any event, and we will move on.


17 MR. KEEGAN: We would be happy to ----

18 Q. Mrs. Tadic --

19 THE PRESIDING JUDGE: So, Mr. Keegan, you are saying that you could

20 ask more questions about the letter, but you do not wish to ask

21 more questions about the letter. You will move on to another

22 subject. Is that what I understand?

23 MR. KEEGAN: About the content of the letter, your Honour. I was

24 going to ask the witness ----

25 THE WITNESS: Do I need to put my earphones on?

26 THE PRESIDING JUDGE: Yes, please.

27 MR. KEEGAN: Mrs. Tadic, I asked you to look at that letter all the

28 way through. Do you recognise the handwriting of that letter?

Page 6809

1 A. Yes, that is my husband's handwriting.

2 MR. KEEGAN: Your Honour, we would offer that letter at this time.

3 THE PRESIDING JUDGE: Mr. Kay? Would you take off your earphones

4 again, please, Mrs. Tadic? Thank you.

5 MR. KAY: It is the use of the letter that is the important issue.

6 This witness cannot comment on the content. It has been

7 authenticated by her as being in her husband's handwriting,

8 although she has only looked at a copy and she is not an expert

9 in handwriting, so far as I know -- I have not asked her the

10 question. One, therefore, does not know quite what weight to

11 put upon that particular answer.

12 As far as the document is concerned, if she says she

13 has not seen it, then that is the end of the matter, as far as

14 she is concerned.


16 MR. KEEGAN: Just one moment.

17 MR. KAY: I notice -- I am sorry, your Honour.

18 THE PRESIDING JUDGE: Go ahead, Mr. Keegan.

19 MR. KEEGAN: Yes, your Honour. In fact, the witness has

20 authenticated the letter recognising her husband's handwriting.

21 We are satisfied that she would be this efficient to recognise

22 the handwriting of her own husband, ex-husband. In addition,

23 Mr. Kay's point might be valid if I was going to continue to ask

24 questions about the contents of the letter. However, we are not

25 going to continue asking questions about the contents of the

26 letter. We shall be offering the letter at this point as it is

27 relevant to her testimony.

28 JUDGE STEPHEN: What do you mean, you are offering the letter? Are

Page 6810

1 you tendering it?

2 MR. KEEGAN: Yes, your Honour.

3 JUDGE STEPHEN: As what? How can you tender it through this

4 witness?

5 MR. KEEGAN: Because it has been authenticated (1) and, therefore, it

6 meets the standards for admissibility on that level. In

7 addition, the information contained in the letter does address

8 issues raised by this witness in her testimony and we believe

9 that it is relevant for the Court's consideration of the weight

10 of her testimony.


12 MR. KAY: We still do not know its provenance. I am looking at the

13 document now and I see that it is dated Wednesday, February 16th

14 1992, Munich. I also see in the opening sentence: "I have

15 already written a letter to you but I was not able to send it".

16 In relation to this witness, this may well be an item of

17 correspondence that was like the previous letter that was not

18 sent. As the opening sentence indicates, that had happened

19 previously.

20 So at this stage, although the witness has identified

21 the handwriting, I think the Prosecution need to do a little bit

22 more to introduce it in evidence and at some stage in the

23 proceedings give evidence of its provenance.

24 THE PRESIDING JUDGE: By "provenance" you mean what?

25 MR. KAY: Where it came from, where it was found. There has been no

26 evidence of that at all. We do not know where it came. The

27 appropriate stage would be perhaps with -- well, they have

28 closed their case anyway. So it would not be rebuttal

Page 6811

1 evidence. So, in those circumstances, at this stage it is

2 inappropriate to ----


4 MR. KAY: Exactly, your Honour.


6 MR. KEEGAN: Your Honour, first of all, again the letter has been

7 authenticated by this witness. I think the date, obviously, the

8 translation is what was written, but obviously the location and

9 the timing clearly would give an indication that the '92 should

10 be '94. Other than that, we think that it obviously is

11 relevant. This witness has denied receiving it. However, the

12 contents of the letter themselves are relevant to the issue of

13 the testimony.

14 THE PRESIDING JUDGE: It is certainly relevant for impeachment

15 purposes. The request is whether you have laid the proper

16 foundation. That is the problem. The witness identifies the

17 handwriting, but she has never received the letter. So, I guess

18 you are offering it as an admission of some sort, but what? You

19 tell me.

20 MR. KEEGAN: Your Honour, at this point we would mark it as 354 for

21 identification.


23 MR. KEEGAN: We will simply proffer it again through another witness.

24 THE PRESIDING JUDGE: OK. Very good. I thought you were trying to

25 get it in now. Fine. It has been marked for identification

26 purposes. The witness has identified the handwriting and we

27 will move on to another topic or are you going to continue?

28 MR. KEEGAN: Yes.

Page 6812


2 MR. KEEGAN: You indicated, Mrs. Tadic, that you went to work in

3 Libya in 1986 and returned in late 1986, is that correct?

4 A. Yes.

5 Q. You said that Dusko Tadic had followed you later in 1986. When

6 did he arrive in Libya?

7 A. Somewhere in mid summer, June/July. I do not know exactly.

8 Q. When did you all return in late 86, what month, do you recall?

9 A. We did not return together. I returned first and he returned a

10 month after I returned.

11 Q. OK. When did you return and when did he return, the months, if

12 you recall?

13 A. I returned on 25th November 1996 and he returned around 20th

14 December 1996.

15 Q. You said prior to him going to Libya he had a karate school

16 -- yes, I am sorry. Your answer was translated as "1996".

17 I believe you meant to say "1986", is that correct?

18 A. '86, I am sorry.

19 Q. Did Dusko Tadic also go to classes or teach classes in the town

20 of Prijedor itself at the Mladost sports hall?

21 A. No.

22 Q. You said that when he returned from Libya he did not get

23 involved in the karate school in Kozarac again?

24 A. No.

25 Q. Did he still partly own that school or had it all been turned

26 over to Emir Karabasic?

27 A. Well, officially he was registered as the coach of that school,

28 but when he went to Libya the trainings were not carried out

Page 6813

1 regularly, so basically it died out.

2 Q. You said when you were building your cafe in Kozarac that you

3 received a lot of help from your neighbours in Kozarac and that

4 the building of the cafe was financed through a combination of

5 money from Dusko Tadic's brother and by loans from neighbours.

6 Those were, in fact, some substantial loans from Muslim

7 neighbours, were they not?

8 THE PRESIDING JUDGE: Answer, please, Mrs. Tadic. Is that "yes" or

9 "no"? Yes?


11 MR. KEEGAN: You said that you and your husband joined the SDS

12 together and that it was in part because of the threatening

13 letter that you had received?

14 A. Yes.

15 Q. You said that you had received no political books or documents

16 regarding the philosophy or the policies of the SDS before or

17 after joining it?

18 A. No, I do not think they had any books.

19 Q. Well, then in what way did you think that joining the SDS was

20 going to assist you, if you did not know what it stood for?

21 A. We knew the programme of the SDS, and it was enough for us to

22 know that that Party wanted us to stay in Yugoslavia which was

23 our homeland, and that was enough for us in order to join it.

24 Q. Why do you think that the SDS wanted Serbs to stay in

25 Yugoslavia?

26 A. Because they wanted it.

27 Q. You said that your husband was picked to run the plebiscite and

28 you were picked as one of the delegates because you had free

Page 6814

1 time. Were you not at that time working at the hospital in

2 Kozarac?

3 A. Yes, when I said that we had free time and my husband had free

4 time -- my husband had free time and I helped him.

5 Q. Was not your husband busy running the cafe?

6 A. He was the head of the cafe and he had people who worked for

7 him, employees.

8 Q. You also had two young daughters at home?

9 A. One was already a bit older and the other one was small. Both

10 of them were not small.

11 Q. So the other Serbs that lived in Kozarac had more obligations

12 than you two?

13 A. Well, the others were older; they were not as young as we were.

14 Q. The plebiscite had different coloured ballots for Serbs and for

15 non-Serbs, is that correct?

16 A. I cannot remember that really.

17 Q. Some non-Serbs did vote in the plebiscite, did they not?

18 A. Yes, but why would the ballots be of a different colour? I do

19 not understand that.

20 Q. You do not recall that the ballots were of a different colour

21 and had different phrasing on them?

22 A. No.

23 Q. You indicated that you read the Islamic declaration by Alija

24 Izetbegovic. What did you see as the main thesis or premise of

25 that work?

26 A. I do not understand. Could you please repeat?

27 Q. After you read the book, what did you take away as the main

28 premise, the main thesis, of the book?

Page 6815

1 A. Well, to my mind, the most important thesis of the book was to

2 wait, that the Muslim obtain 53 per cent so they would be more

3 numerous, that is, take power and all the people that lived

4 there should live under Islamic laws. I am not really a

5 politician. I cannot know how to explain it to you well. I am

6 sorry.

7 MR. KEEGAN: Your Honour, that would be a convenient time.

8 THE PRESIDING JUDGE: We will stand in recess for 20 minutes.

9 (4.00 p.m.)

10 (The Court adjourned for a short time)

11 (4.20 p.m.)

12 MR. KEEGAN: Your Honour, just before they bring the witness in,

13 I would like to have a brief session regarding that letter, if

14 we could?

15 THE PRESIDING JUDGE: Yes. That has been marked for identification

16 purposes as 354 for the record. OK. Go ahead, Mr. Keegan.

17 MR. KEEGAN: Yes, your Honour. I will begin while I am waiting for

18 Miss Sutherland to bring some copies -- here she is.

19 THE PRESIDING JUDGE: More copies of the letter -- you are

20 optimistic!

21 MR. KEEGAN: Your Honour, just in terms of clarifying this issue

22 about the letter, if I could have three copies for the Bench and

23 one copy for the Defence? What I am handing up to the Court,

24 your Honour, and to the Defence are a series of motions which

25 were filed and then withdrawn by the Defence, the first

26 beginning on 23rd June.

27 THE PRESIDING JUDGE: Do we want to make this an Exhibit or are they

28 a part of the record? They are a part of our record. No --

Page 6816

1 yes, they are. Tell me.

2 MR. KEEGAN: We would like to make them a part of the record, yes,

3 your Honour.

4 THE PRESIDING JUDGE: OK. Tell me what they are and then we will

5 decide whether we need to make them an exhibit.

6 MR. KEEGAN: Yes, the first one beginning on 3rd July 1995, a motion

7 to suppress the production of evidence obtained from the

8 accused. On page 3 of that motion, paragraphs 11 through 14,

9 the Defence refers to, "While in detention in Germany, the

10 accused has written private letters. Those letters were then

11 confiscated, copied" ----

12 THE PRESIDING JUDGE: Wait, let me follow you, 11 through 14? This

13 motion, I think, if I remember, was withdrawn.

14 MR. KEEGAN: It was, your Honour.

15 THE PRESIDING JUDGE: It has been a long time ago.

16 MR. KEEGAN: Yes, your Honour. My point in raising it is that as of

17 3rd July 1995, the Defence were certainly aware of the letters.

18 In fact, they were making a motion to prevent their production

19 into evidence. That motion was followed up by a second motion

20 to suppress on 4th September 1995, again referring to the

21 letters. On 28th September 1995 there was a notice of

22 withdrawal of these motions.

23 THE PRESIDING JUDGE: Help us, we have received so many. Tell us, do

24 you want us to start from the bottom up or the top down?

25 MR. KEEGAN: I think the way they are organised, it is bottom up,

26 your Honour.

27 THE PRESIDING JUDGE: OK. The first thing then we have is a request

28 for an extension of the date to file a motion.

Page 6817

1 MR. KEEGAN: Of course, yes, 3rd July 1995 is the first.

2 JUDGE STEPHEN: 23rd June.

3 MR. KEEGAN: 23rd June, yes, your Honour. I am sorry, that is

4 right. That was just the request. The actual motion was then

5 filed on 3rd July 1995.


7 MR. KEEGAN: We responded on 28th July (which we did not provide to

8 you since it is not relevant to the issue at this point) to this

9 particular issue. Then the Defence filed the second motion on

10 4th September 1995 again which we replied to. Both of those

11 motions referred to these letters from the prison.

12 The next document is 28th September 1995, the notice

13 of withdrawal. Then in response to a fax letter which I sent,

14 the last document is a response from Mr. Wladimiroff to my

15 attention. In paragraph 2 you will see that, in fact, the

16 Defence does no longer maintain the position that the German

17 material is inadmissible evidence for the reasons stated in the

18 motions. However, they did reserve the right to raise

19 additional objections.

20 So, in point of fact, just for the point of

21 clarification, we certainly had a reasonable grounds for

22 believing that the Defence was not only aware but had copies of

23 these letters.

24 JUDGE STEPHEN: The letter is mentioned by date in some of these

25 motions, is it?

26 MR. KEEGAN: I do not believe it is, your Honour, no. They simply

27 refer to letters "confiscated" and "copied" at the prison.


Page 6818

1 THE PRESIDING JUDGE: I think it also says letters seized by the

2 German authorities, but if I heard Mr. Wladimiroff correctly and

3 if I understand your position, these were - this letter, 354, was

4 in the material submitted by the German lawyer. Was it in

5 the ----

6 MR. KEEGAN: There is -----

7 THE PRESIDING JUDGE: --- folder from the authorities.

8 MR. KEEGAN: There are really two separate seized documents or

9 categories, if you will. These particular letters, and as they

10 are referred to here in the motion, were letters that were taken

11 and copied by the German authorities while he was in prison.

12 These materials are separate from those which were seized from

13 the house in Munich where he was arrested. These letters which

14 we received were in binder No. 4 of the German materials, as

15 I referred to before.

16 The Defence received binders, we received our copy of

17 binders 1 through 10 from the German authorities. The Defence

18 received their copies of binders 1 through 10 from the Defence

19 counsel in Germany who had been given his copy by the German

20 authorities.


22 MR. KEEGAN: He simply turned over his materials to the Defence

23 here. We then showed them the additional four binders which we

24 had, binders 11 to 14, the seized documents, essentially.

25 THE PRESIDING JUDGE: Was the letter included in what you showed the

26 Defence?

27 MR. KEEGAN: Your Honour, the letter was included in binder No. 4.

28 We had no reason to believe that, as they maintain, their copy

Page 6819

1 does not have these letters. They never at any time asked us

2 for a copy of these letters, despite the fact that they

3 obviously referred to them in their motion in 3rd July 1995,

4 which is why we believed they had copies.

5 THE PRESIDING JUDGE: The problem, of course, is that it just talks

6 about "letters". Then the other problem is, I do not know how

7 I can determine whether this particular letter was in the binder

8 received by Mr. Wladimiroff. He says it was not, and you say it

9 was included in the binder that you received and that you also

10 showed them the binder that you received.

11 MR. KEEGAN: Your Honour, yes. The only reason we are raising this

12 again is for a matter of clarification as to why we believed

13 they had possession of those materials, since they referred to

14 them in a motion specifically. There were only a certain number

15 of letters from the prison. They never asked us for copies

16 additionally, and so we will certainly rectify that situation.

17 We would invite them to review their binder 4 very

18 thoroughly, though, to make sure that it is not there before we

19 do that.

20 JUDGE STEPHEN: Perhaps, only as a matter of curiosity, but this was

21 a letter written after, of course, the accused's arrest?

22 MR. KEEGAN: Yes, your Honour.

23 JUDGE STEPHEN: How would it have ever been discovered -- the

24 searches were at the time of his arrest, I take it, were they,

25 and it would not be in existence at that time, and it was a

26 letter from him to his wife, how did it ----

27 MR. KEEGAN: This was a letter written while he was in prison ----


Page 6820

1 MR. KEEGAN: --- and under the German rules of detention, any

2 outgoing mail is subject to seizure ----


4 MR. KEEGAN: --- review and photocopying. That was provided to the

5 accused. He knew that. That was in the regulations. It was

6 all part of the documents which is why the Defence withdrew the

7 motion.

8 THE PRESIDING JUDGE: But Mr. Wladimiroff says this letter was not

9 among what he received, I think. Is that correct,

10 Mr. Wladimiroff? Is that still your position?

11 MR. WLADIMIROFF: As a matter of fact, your Honour, in the motion

12 itself no letter is specified, just as an issue as such ----


14 MR. WLADIMIROFF: --- it was raised. You may have seen that I made a

15 reservation when I withdrew, saying that the withdrawal does

16 not, of course, mean that the probative value of this evidence

17 may not be criticised by the Defence. Here we are. As a matter

18 of fact, the witness told you that she did not receive the

19 letter. So, apparently, it was seized by the German

20 authorities. There was no disclosure by the Prosecution to us.

21 They assumed that we got the letter. It was not established as

22 a fact. As I said, it was not specified in our motion. But

23 maybe there is a lot of fuss about nothing because we have been

24 reading the letter in the meantime. We feel the letter is very

25 exculpatory, so we would even like to have it produced.

26 THE PRESIDING JUDGE: So, all of this back and forth, you have no

27 objection to the letter, is that what you are now telling me?

28 MR. KAY: That is right, your Honour. Having had an opportunity to

Page 6821

1 read it, we view it as exculpatory. The difficulty here is

2 introducing it to this witness. It seems, from what the

3 Prosecution are telling us, that it was seized by the German

4 authorities as a communication at some stage whilst the

5 defendant was in custody and, of course, she says she has never

6 seen it. I do not know if it was seized, copied and then went

7 back into the post or whether it was just seized, period.

8 THE PRESIDING JUDGE: There are two issues, one, just as to whether

9 or not you had ever seen it. So that is really just an issue of

10 surprise. As I said earlier, I do not know how I can resolve it

11 unless I were to sit with you, you know, when you receive these

12 folders and determine what was in your folder and what was in

13 the folder of the Prosecutor. That is one issue just in terms

14 of the surprise.

15 The other has to do with the admissibility. What

16 Mr. Wladimiroff has said is that he reserved the right to raise

17 any claim as to probative value. That I do not know really

18 deals with the question of admissibility. In other words, what

19 he is saying, it is relevant, it may be admissible, but it is

20 not really probative of the facts.

21 But then the third issue, I guess, is whether it is

22 admissible through this witness. If you have no objection, do

23 you still wish to offer 354, Mr. Keegan?

24 MR. KEEGAN: Yes, your Honour.

25 THE PRESIDING JUDGE: OK. Is there an objection?

26 MR. KAY: We have no objection to 354, but it is a question of how it

27 is dealt with in evidence, because this witness has said that

28 she has never seen it and, as it is written by someone's else,

Page 6822

1 it then becomes impossible for her to deal with it if it is not

2 something that she has acted upon or seen or had any views upon

3 at that time.

4 THE PRESIDING JUDGE: So you have no objection to its admissibility,

5 but you, I gather, have some concern about whether this will be

6 used to question this witness ----

7 MR. KAY: Yes.

8 THE PRESIDING JUDGE: --- and you consider that would be

9 inappropriate since she has not received it?

10 MR. KAY: Yes.


12 MR. KEEGAN: No, your Honour, I have already indicated my questions

13 for the letter with this witness were done before it was even

14 resolved, so no. But, as to the issue, since obviously the

15 Defence knew there were letters since they described what was in

16 them and these binders are sequentially numbered, the documents,

17 so it should be fairly easy for them to determine if there is a

18 document missing, a document missing in these binders. We would

19 invite them to look carefully since there were other letters

20 that might be proffered later on.

21 THE PRESIDING JUDGE: Exactly. That is the question I have. We are

22 beyond this issue, this is admissible because there is no

23 objection, but no questioning of this witness. I am really

24 concerned as to whether this is going to arise again. I am sure

25 that we have no desire -- do you have any desire to sit with

26 counsel and compare what is in your folder with what is in your

27 folder, but we will do it, if necessary, in order to avoid a

28 future problem.

Page 6823

1 MR. KAY: I think it would be easier if the Prosecution are going to

2 produce them in evidence to give us the copies that they intend

3 to produce so that we can look at them overnight and review any

4 to see if we have any objection to their admissibility. It

5 seems to me that that would be a proper way and it is obviously

6 a matter easily achieved.

7 THE PRESIDING JUDGE: You do not have the folders with you that you

8 received?

9 MR. KAY: We have the folders, but we have never had an index from

10 the Prosecution of material that they have; it was always left

11 on the basis that, "Well, you have been served that by your

12 German lawyer and that is good enough for you". But whether the

13 German lawyers gave us an entire bundle, we do not know.

14 THE PRESIDING JUDGE: Maybe you can sit with each other when we

15 finish at 5.30 and make sure that the Defence has everything

16 that is in your binder.

17 MR. KEEGAN: Your Honour, as I indicated before, I am a little

18 concerned about how this is being categorised. This information

19 was given to them a long time ago. Each page, each document, is

20 sequentially numbered. It is very easy to determine if you are

21 missing a document in all of the binders. They simply need to

22 go through them and say, "We do not have these numbers" and then

23 we will provide those. But it seems to me that they were

24 clearly referred to, not only in where they came from, that is,

25 detention in Germany, but the content.

26 THE PRESIDING JUDGE: OK, but I gather there are not so many letters

27 that you cannot sit down together at 5.30 and make sure that the

28 Defence has what you think that they have.

Page 6824

1 MR. KEEGAN: We can give them a list of the dates of the letters,

2 certainly, your Honour. We can certainly do that, certainly.

3 THE PRESIDING JUDGE: Can that be done?

4 MR. KAY: It can be done. I presume that these letters are in

5 Serbo-Croat. If the Prosecution have translations that they can

6 produce to us now, that will save us sending everything out to

7 be translated in anticipation that some of the letters might be

8 used. I think it would be much easier if they just gave us the

9 letters that they intend to use in cross-examination so that we

10 can have them with the translations.

11 THE PRESIDING JUDGE: OK. Get together, please, at 5.30. Make sure

12 that the two files are the same. If you have any translations,

13 is there any problem with giving the translations ----

14 MR. KEEGAN: Of course not, your Honour.

15 THE PRESIDING JUDGE: --- to the Defence at this time? OK. Will you

16 do that? Sit down, compare your files and make sure you are

17 talking about the same information. Then we will not have to

18 worry about it, at least on that issue in terms of receipt.

19 There may be other problems.

20 MR. KAY: I am grateful to your Honour.

21 THE PRESIDING JUDGE: OK. Very good. Is there anything else before

22 Mrs. Tadic is brought in?

23 MR. KEEGAN: No, your Honour.

24 THE PRESIDING JUDGE: OK, very good. 354 is admitted. Mrs. Tadic,

25 please, should come in.

26 MRS. MIRA TADIC, recalled.

27 Cross-examined by MR. KEEGAN, continued.

28 THE PRESIDING JUDGE: Mr. Keegan, did you offer the Serbo-Croatian as

Page 6825

1 well as the English translation?

2 MR. KEEGAN: Yes, your Honour. I would like to have them A and B, as

3 is the usual custom.

4 THE PRESIDING JUDGE: OK. 354A will be the Serbo-Croatian

5 translation, 354B the English translation.

6 MR. KEEGAN: Thank you, your Honour.

7 THE PRESIDING JUDGE: Mr. Keegan, would you continue, please?

8 MR. KEEGAN: Thank you, your Honour.

9 Q. Ma'am, you referred to the threatening letter which you received

10 in 1990. There was, in fact, an investigation done with respect

11 to that letter by the police, was there not?

12 A. It was supposed to be done. It was supposed to be done.

13 THE INTERPRETER: Can you hear it?

14 MR. KEEGAN: Sorry, we did not get anything. We are not hearing you

15 either.

16 THE WITNESS: Supposedly it should have been done.

17 THE INTERPRETER: The microphone is on.

18 THE PRESIDING JUDGE: I am hearing. Can you hear me, Mr. Keegan?

19 MR. KEEGAN: I can now, I think my channel had been changed.

20 (To the witness): In fact, the investigation was done

21 and is it not true that there was no determination that that

22 letter had been sent by Muslims in Kozarac? But, in fact, did

23 not the investigation in its later stages begin focusing on the

24 fact that perhaps you and your husband had fabricated that

25 letter?

26 A. No, the investigation was not based on that but on the Muslims

27 from Kozarac.

28 Q. You indicated that there was some change in the relationship

Page 6826

1 between your husband and Emir Karabasic in 1991. What was the

2 nature of that change?

3 A. They did not see each other as frequently as they used to

4 previously.

5 Q. What type of circumstances caused that change, do you know?

6 A. Yes, the formation of national parties.

7 Q. This was after the time that you and your husband had joined the

8 SDS, correct?

9 A. No, previously. All the other parties along ethnic lines were

10 formed prior to the SDS.

11 Q. My question was the change in the relationship between Dusko

12 Tadic and Emir Karabasic occurred after you and your ex-husband

13 joined the SDS?

14 A. No, it has nothing to do with that.

15 Q. You described that there was during this same time, 1991, the

16 change in the circumstances or the environment in the town of

17 Kozarac, that the cafe was boycotted by Muslims from the centre

18 of Kozarac and that there were rumours about the cafe?

19 A. Yes, that is correct.

20 Q. Were not these people, the Muslims from the centre of Kozarac

21 and throughout the area, the same people who had been your

22 friends and your ex-husband's friends for all of your lives, the

23 same people who had lent you a significant amount of money just

24 a year prior so that you could build your cafe, and did you not,

25 in fact, still employ Muslims as waiters in your cafe?

26 A. Yes, we still employed Muslims as waiters in our cafe and we

27 continued to socialise with some Muslims from Kozarac, but not

28 with all of them as -- until that period of time.

Page 6827

1 Q. So prior to this period of time had you socialised with all of

2 the Muslims in the area?

3 A. Yes.

4 Q. During this same time, was there not a significant build-up in

5 the number of Serbian troops who were returning from the war in

6 Croatia and being established in positions particularly in the

7 hills around the Kozarac area?

8 A. There was a stepping up in the number of troops but they were

9 not positioned in town, but in Benkovac.

10 Q. So the troop formations were only in Benkovac?

11 A. Yes.

12 Q. How do you know that?

13 A. I know because I watched lorries drive by to Mrakovica.

14 Q. You watched them drive by the cafe, up the road to Mrakovica?

15 A. Yes, going to work and coming home from work, I would encounter

16 lorries.

17 Q. You stated that your overall goal was to continue to run the

18 cafe and to live in Kozarac to raise your children there. If

19 that was your goal, why did you not think of joining the SDA

20 whose stated platform was for democracy and a multi-cultural

21 Bosnia or even the HDZ? Why did you join the SDS?

22 A. I joined the SDS because their platform was to stay within

23 Yugoslavia and protect the Serb people; whereas SDA had a

24 platform which appealed only to Muslims and there was no

25 democracy in it.

26 Q. Despite the number of extremists in Kozarac, Muslim extremists,

27 as you described them, and the number of armed people, in fact,

28 the Orthodox church in Kozarac and the house of the priest which

Page 6828

1 is on the property were never destroyed or, in fact, harmed in

2 any way, is that not correct?

3 A. That is correct.

4 Q. You said that when you were leaving Kozarac you recognised Sead

5 Bahonjic as the man at the checkpoint?

6 A. Yes.

7 Q. What kind of glasses was he wearing? Were they sunglasses?

8 A. Yes.

9 Q. Was he also ----

10 A. Dark sunglasses.

11 Q. --- wearing a cap, a beret of some type?

12 A. No, no.

13 Q. What did he say when you told him that you were going to be back

14 to the police station to get authorisation to leave Kozarac?

15 A. Nothing. He said we could go.

16 Q. The house that you lived in in Banja Luka, the one that you

17 pointed out in the pictures today here in Court, to whom did you

18 pay rent for that apartment?

19 A. We were not paying rent in that house.

20 Q. You described that you arrived in Banja Luka on the Sunday

21 evening and you started getting that apartment ready, you stayed

22 with Ljubo and then started getting that apartment ready the

23 very next day on the Monday, is that correct?

24 A. Yes, we did not start preparing things on the day after. We

25 found the apartment in the evening on the day after, and then as

26 of Tuesday we started to get it ready.

27 Q. You stated that you and your ex-husband only had a personal

28 automobile during a short period of time in your marriage in the

Page 6829

1 early 80s, I guess, or mid 80s, is that correct?

2 A. Around the time between '80/'81 until '85, we sold it before we

3 went to Libya.

4 Q. During those years before the war and up until the time of the

5 war, though, many of your Muslim neighbours in Kozarac had

6 personal vehicles, did they not?

7 A. Yes.

8 Q. Including Volkswagen Golfs and even Mercedes?

9 A. Yes.

10 Q. You referred to the people that you knew in Banja Luka as "real

11 friends". What does that mean? What kind of friends are those,

12 "real friends"?

13 A. It means people we always saw and visited whenever we went to

14 Banja Luka.

15 Q. How were those different from the friends that you saw and

16 visited in Kozarac?

17 A. There was no difference. Those others were real friends as

18 well.

19 Q. When your ex-husband was going to visit Kozarac, you mentioned

20 the occasions during the time you were in Banja Luka when he

21 visited Kozarac, did he take his automatic rifle with him?

22 A. I do not know what period of time you are referring to. He is

23 not my ex-husband. He was my husband and he has remained my

24 husband.

25 Q. Are you not divorced?

26 A. Yes, but it has nothing to do with it.

27 Q. So during the time that you were staying in Banja Luka between

28 23rd May and 27th June, you mentioned there were two occasions

Page 6830

1 when your husband went to Kozarac?

2 A. Yes.

3 Q. On those occasions did he take his automatic rifle with him?

4 A. The first time he did not, but the second time he did.

5 Q. You said that on the occasion that he went to Trnopolje with

6 Jovo Samardzija, they went to find that man's sister?

7 A. Yes.

8 Q. She is married to a Muslim, correct?

9 A. No, she is not married.

10 Q. She ended up in Travnik, did you say?

11 A. I think in Zenica. That is what Jovo told me afterwards, not

12 Travnik.

13 Q. Why did she go to Zenica rather than stay?

14 A. Because she was evacuated along with the rest of the Muslim

15 population and she went in a convoy with them.

16 Q. Yes. When you were talking about Trnopolje, you indicated that

17 the entire population had been evacuated to Trnopolje. First

18 off ----

19 A. No.

20 Q. That is what you said. What did you mean by that?

21 A. A part of the population from Kozarac had been evacuated to

22 Trnopolje and the rest of them to Prijedor.

23 Q. The part that went to Trnopolje, those were Muslims and Croats?

24 A. Yes, and a few Serbs.

25 Q. You indicated that your husband had been given that automatic

26 rifle by a man named Kusota?

27 A. That is his family name. I said I did not know what his first

28 name was.

Page 6831

1 Q. Why would he give that weapon to Dusko Tadic?

2 A. To take it back to the barracks in Prijedor.

3 Q. My question is why would he give it to Dusko Tadic and not

4 someone else to take it back? Did he have some special

5 relationship with Dusko Tadic or did he know that Dusko Tadic

6 had the ability to take that back without getting in trouble?

7 A. Well, he did not know it. He must have assumed that Dule could

8 take it there and give it to someone.

9 Q. He wanted to give it away because he would get in trouble if he

10 was caught with it, correct, since he was a deserter?

11 A. Yes, because he was a deserter he was not allowed to carry

12 arms. He just simply wanted to give it back.

13 Q. But, in fact, Dusko Tadic did not turn that weapon in but kept

14 it?

15 A. Yes.

16 Q. Your apartment in Pecani that you moved into, do you know what

17 happened to Hasan Tulundzic?

18 A. I think that before the conflict in Prijedor they left to go

19 abroad. That is at least what I heard. He and his family left

20 to go abroad and stay with relatives.

21 Q. You are sure that the description about the circumstances

22 surrounding your taking over that apartment are accurate?

23 A. Yes.

24 Q. You described in great detail your husband's activities and

25 schedules while he was working with the traffic police. During

26 that time did you work with him in the traffic police?

27 A. No, I did not work with him and I did not give a detailed

28 description. I mean, I know where he worked, but what do you

Page 6832

1 mean by "detailed description"?

2 Q. Did you accompany him to his work?

3 A. No, I did not accompany him to work. I simply used to come

4 across him as he was at work.

5 Q. During the time he worked in Kozarac did you work with him in

6 the police there?

7 A. No.

8 Q. Did you accompany him to work when he was stationed in Kozarac?

9 A. No, I would visit Kozarac at that time.

10 Q. You talked about one of his positions was the bridge over the

11 Sana by the Hotel Prijedor?

12 A. Yes.

13 Q. Did you go and see him there when he was assigned to that

14 position?

15 A. Yes, once I went to have my hair cut in the hotel.

16 Q. Were you then familiar with the fact that that area was one of

17 the collection centres throughout the summer of 1992 for the

18 Muslims and Croats who were still being rounded up and sent to

19 the camps?

20 A. I do not understand what area you mean.

21 Q. The area next to the bridge.

22 A. No, it was not an area from which they were being rounded up.

23 Q. When your husband was assigned to Kozarac you described some of

24 his duties there. Was he also responsible for distributing aid

25 from the Red Cross?

26 A. Yes.

27 Q. During period of 1991/1992 were there joint checkpoints in the

28 Kozarac/Prijedor area, and by "joint" I mean guarded by both

Page 6833

1 Muslims and Serbs?

2 A. During 1991 there were no checkpoints. In May (sic) 1992, in

3 the area of Kozarac there were checkpoints, where I lived only

4 Muslim checkpoints, no joint checkpoints. I am sorry, I said in

5 May. Checkpoints started to exist in March and April 1992.

6 March, April, May 1992.

7 Q. Did some Serbs in the Kozarac area attempt to obtain weapons

8 from the weapons storage places to distribute to the Serb

9 population?

10 A. I do not know.

11 Q. Did some Serbs in the Kozarac area plan the assignments for the

12 Serb population that were to be put into effect if a war

13 started?

14 A. I am not aware of that.

15 Q. Did not Dusko Tadic in fact take part in those activities?

16 A. No.

17 Q. Were there members in Kozarac of the SDS who were considered

18 activists on behalf of the SDS?

19 A. I did not understand. Please could you clear it up a bit?

20 Q. Were there members of the party in Kozarac, that is the SDS, who

21 actively sought to advance the goals and policies of the SDS?

22 A. Our objective and the politics of the SDS were only to organise

23 the plebiscite, that was all the duty and all our tasks. After

24 that we had no tasks.

25 Q. What about other members of the SDS in Kozarac?

26 A. I do not know that there were any.

27 Q. Approximately two weeks before the war began in the Prijedor

28 area your husband met with the President of the SDS in Prijedor,

Page 6834

1 Simo Miskovic, and the President of the opstina, Milomir Stakic,

2 to discuss the negotiations between Kozarac officials and

3 Prijedor officials, isn't that correct?

4 A. My husband, as far as I know, was not on his own in Prijedor.

5 He was with a group of citizens of Kozarac.

6 Q. Is it not true that prior to that meeting with the group he had

7 a separate meeting with those two men I just mentioned?

8 A. I am not aware of that.

9 Q. Your husband did not tell you about such an important meeting?

10 A. About certain important meeting with a group of citizens from

11 Kozarac he told me, and he went there twice on such a meeting,

12 but I do not know that he went to any kind of a meeting on his

13 own.

14 Q. You testified in direct about the mobilization of Dusko Tadic in

15 mid-June 1992. When did you yourself speak -- you testified as

16 to why he was not mobilized, excuse me, prior to that time as

17 well -- when did you yourself speak to the Serb Ministry

18 officials about why he had not been mobilized prior to that

19 time?

20 A. I am sorry, I do not understand.

21 Q. On your direct testimony you explained why it was your husband

22 had not been mobilized prior to mid-June of 1992. When did you

23 speak with the officials regarding mobilization to determine

24 that?

25 A. I did not discuss anything with the authorities. My husband,

26 that is his cousin discussed with Dule Jankovic for him to enter

27 into the Police Force.

28 Q. You testified that you went to Prijedor on 17 June 1992 and

Page 6835

1 returned to Banja Luka on 18 June 1992. What time on the 18th

2 did you leave Prijedor to come back -- I am sorry, what time did

3 you leave Banja Luka to return to Prijedor? No, I am sorry, I

4 have not ----

5 A. On 17th in the morning.

6 Q. Right. How did you travel back to Banja Luka?

7 A. By train until Prijedor and then back to Banja Luka also by

8 train.

9 Q. That train from Prijedor to Banja Luka does not go through

10 Kozarac, is that correct?

11 A. No, it goes through Trnopolje.

12 Q. So are you saying now that you went back to Banja Luka on 17th

13 June or on 18th June?

14 A. No, I went back to Banja Luka on 18th and on 17th I arrived at

15 Prijedor. I spent the night there and went on the following day

16 back to Banja Luka. That is how I said that.

17 Q. With respect to the issue of Major Maric and the military police

18 in Prijedor, were you in Prijedor when Dusko Tadic fled from the

19 military police?

20 A. Yes, but he did not flee on one occasion but on several

21 occasions.

22 Q. Did you yourself receive any threats from the military police?

23 A. Not from the military police but from Major Maric, yes.

24 Q. How did you receive those threats? Were those by letter or by

25 phone?

26 A. By phone and later on also orally.

27 Q. How did you know Major Maric?

28 A. I did not know him. I met him later on, but at that time I did

Page 6836

1 not know him. We have only talked on the phone.

2 Q. Finally, did Dusko Tadic tell you in June 1993 that the premises

3 of the Local Commune and SDS in Kozarac had been robbed several

4 times, and that the investigation into those robberies had

5 implicated the local SDS officials themselves, including Dusko

6 Tadic?

7 A. No. I know that on several occasions the office had been

8 burgled, but that somebody robbed something, no, I do not know.

9 Q. He did not tell you that the investigations had indicated that

10 the robberies had implicated the SDS officials themselves

11 including Dusko Tadic in those robberies?

12 A. No, that is the first time I hear it now.

13 Q. You have mentioned a lot of dates in your testimony when you and

14 Dusko Tadic did certain things or were in certain places. When

15 did you begin to reconstruct these dates and events?

16 A. I am sorry, could you please repeat the question?

17 Q. When did you begin to reconstruct in your mind these dates and

18 events?

19 A. What events do you mean?

20 Q. All of the events that you testified to here in this courtroom

21 where you provided dates and, in some instances, specific times

22 for events that you and Dusko Tadic were involved in?

23 A. Some dates are concretely connected to something important and

24 of course I remember them, and the others I sort of looked to a

25 calendar and I found out according to that.

26 Q. Were you given any materials by anyone to read in connection

27 with your testimony in this trial?

28 A. No.

Page 6837

1 Q. Have you watched any of the proceedings of this trial on

2 television?

3 A. Yes.

4 Q. Have you ever been told not to watch the proceedings of this

5 trial?

6 A. No.

7 Q. Have you discussed this case with friends or relatives?

8 A. What do you mean concretely?

9 Q. Have you discussed this case, the charges involving your husband

10 and the facts about the case, have you discussed those with

11 friends or relatives?

12 A. There was nothing to discuss.

13 Q. Have you discussed this case with other Defence witnesses?

14 A. No.

15 Q. In 1992 or 1993 was there an investigation against Dusko Tadic

16 by the Prijedor police?

17 A. I do not understand.

18 Q. Were there claims being made by many people that Dusko Tadic had

19 been receiving bribes from them with respect to his duties?

20 A. There were rumours, but nothing in particular.

21 Q. Just one moment, please, your Honour. Just one final question

22 to follow up. So to your knowledge there was no official

23 investigation in 1992 or 1993 regarding Dusko Tadic?

24 A. I did not know. I knew about threats by the Commander of the

25 police, but I did not know about anything officially. There

26 were rumours that there was a case against him at the police.

27 That is what I know of.

28 Q. Where did you hear those rumours from?

Page 6838

1 A. Those rumours I heard them from Dusko's brother Ljubomir Tadic

2 and he heard about that from the brother of Dule Jankovic at the

3 market in Banja Luka.

4 MR. KEEGAN: Nothing further, your Honour.


6 MR. KAY: One matter in re-examination.

7 Re-Examined by MR. KAY.

8 Q. Which Commander of THE police was making threats against your

9 husband?

10 A. Dule Jankovic, Dusan Jankovic, he was the Police Commander in

11 Prijedor.

12 Q. When was he making threats against your husband?

13 A. I cannot recall exactly which year. Since he started to work at

14 the Local Commune in Kozarac, since then, so probably during

15 1993.

16 Q. What were those threats about?

17 A. Those were not direct threats. As I was told, Ljubomir Tadic,

18 Dule's brother, told me that Dule Jankovic is compiling a huge

19 file about Dule.

20 Q. Why was that? What was the file about?

21 A. For example, Dule, when he left the police, then he had a

22 conflict, came into conflict with the police that stayed in

23 Kozarac.

24 Q. What did this conflict concern?

25 A. About the property that remained in Kozarac.

26 Q. What was his concern about the property in Kozarac?

27 A. Because he wanted that the property in Kozarac would stay there,

28 and to revive the place so that somebody could live there in the

Page 6839

1 future.

2 Q. Were people wanting to take property from Kozarac?

3 A. Yes.

4 Q. By "property" what do you mean?

5 A. I think in particular, for, example, the sawmill, the electrical

6 mills, then the tiles on the roofs, building material, those

7 kinds of things.

8 Q. Who was it that was trying to take this property from Kozarac?

9 A. For example, people were taking those things under the

10 protection of the police. That is why Dule came into conflict

11 with the police.

12 Q. What was your husband trying to do about that to stop these

13 people connected with the police from taking the property?

14 A. Well, he wanted to prevent them doing that. He complained at

15 the Assembly. That is why all that came about. He came into

16 conflict with the police and with the military authorities

17 because of those things.

18 Q. When he complained at the Assembly, was that just on one

19 occasion or more than one occasion?

20 A. I think that was on several occasions, but once there was a real

21 Municipal Assembly meeting and that is where he came into

22 conflict with them. That was the most serious conflict.

23 Q. Was this the Assembly in Prijedor?

24 A. Yes.

25 Q. Who attended the Assembly meetings in Prijedor?

26 A. I do not know who attended the meetings. There were the

27 municipal, the military authorities and the police, the

28 representatives of those authorities.

Page 6840

1 Q. So would these have been the people who governed Prijedor at

2 this time?

3 A. Yes.

4 Q. So was Dusko Tadic making allegations at these meetings that

5 these people were protecting others who were stealing property

6 from Kozarac?

7 A. Yes.

8 Q. Do you know for how long he was in conflict with the authorities

9 in Prijedor over these matters?

10 A. During the whole time up until he left Prijedor.

11 Q. Was anyone else that you know of talking out and speaking out

12 against these authorities?

13 A. Many were complaining. The discussion with our friends was that

14 it was all right for Dule to have said that at the meeting, but

15 nothing could have been done.

16 MR. KAY: Thank you. That is all I ask.


18 MR. KEEGAN: No, your Honour.

19 THE PRESIDING JUDGE: Nothing else.

20 Examined by the Court.

21 JUDGE STEPHEN: Mrs. Tadic, just two questions. The first one, am

22 I right in thinking that Vidovici is mainly a Serb or was

23 mainly a Serb inhabited village in 1992?

24 A. Yes.

25 Q. That was where the polling place was for the plebiscite that was

26 organised which you took part in?

27 A. No, the plebiscite was not organised there. That was only

28 written like that, but the plebescite was in an office by the

Page 6841

1 church.

2 Q. In Kozarac?

3 A. Yes, in Kozarac.

4 Q. Because that document merely appoints your husband and you as

5 voting officials for polling place No. 36 in Vidovici, and

6 I wondered if that was the only polling place that you had

7 anything to do with?

8 A. Well, put it like this, that is the way it was written, but it

9 was not viable to do it that way because Vidovici is far from

10 Kozarac. So we decided for this other option up until the very

11 last moment we did not know where would be the best place to

12 organise it. So we decided to do it in the churchyard. There

13 were also posters stating that the plebescite would be held in

14 our family house, but we decided it would not be OK to do it in

15 a private home. In Vidovici there was no official building.

16 That is why we decided for the churchyard.

17 JUDGE STEPHEN: Thank you.

18 THE PRESIDING JUDGE: So was there any voting then in your house for

19 this plebiscite?

20 A. No.

21 THE PRESIDING JUDGE: Mr. Kay, additional questions?

22 MR. KAY: Nothing arises, your Honour.


24 MR. KEEGAN: No, your Honour.

25 THE PRESIDING JUDGE: Is there any objection to Mrs. Tadic being

26 permanently excused?

27 MR. KEEGAN: Yes, your Honour.

28 THE PRESIDING JUDGE: Mrs. Tadic, you are free to leave and you are

Page 6842

1 free to return home. However, you should continue to make

2 yourself available because you may be recalled as a witness in

3 this case. So keep in touch with Mr. Kay, and if Mr. Kay tells

4 you that you are to report back to the Tribunal, then you should

5 do that. Will you do that?

6 THE WITNESS: Yes, I will.

7 THE PRESIDING JUDGE: OK. Thank you. You are excused at this time.

8 We would like to talk with counsel just for one moment without

9 the sound. Mrs. Tadic, you may leave. Thank you for coming.

10 (The witness withdrew).



















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27 (5.30 p.m.)

28 (The court adjourned until the following day).