Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14685

1 Monday, 24 February 2003

2 [Open session]

3 --- Upon commencing at 9.05 a.m.

4 [The accused entered court]

5 JUDGE AGIUS: [B/C/S translation on channel 4]

6 THE REGISTRAR: [B/C/S translation on channel 4]

7 JUDGE AGIUS: I see on the transcript, this is just unacceptable.

8 I mean it's -- could you please put on the record that the Registrar

9 did -- her microphone was switched on. And I see that there is no record

10 of her calling the case.

11 Neither have I. I don't even have a translation. Can you hear

12 the interpretation? No, I can't hear any interpretation and I'm on

13 channel 4. I'm still not okay. It's plugged in. I can't hear a thing.

14 Let's see with another set of ear phones.

15 I can't hear a thing. At least I mean they are hearing me

16 complaining that I am not hearing anything. They should speak and say

17 something. At least and if everyone else is hearing, why shouldn't I hear

18 as well?

19 THE INTERPRETER: Your Honour can you hear the English booth?

20 JUDGE AGIUS: Yes, I can hear some English words being spoken at

21 last, yes. And now can I ask why there is no record of the Registrar

22 calling the case, please?

23 THE REGISTRAR: Your Honour, I just was informed by the

24 translation booth that there was a mix-up with the channel so that should

25 be the reason that there was no record.

Page 14686

1 JUDGE AGIUS: All right. Could you call the case, again, Madam

2 Registrar, please? Thank you.

3 THE REGISTRAR: Good morning, Your Honours. Case number

4 IT-99-36-T, the Prosecutor versus Radoslav Brdjanin.

5 JUDGE AGIUS: I thank you. Mr. Brdjanin, can you here me in a

6 language that you can understand? I hope you can hear.

7 THE ACCUSED: [Interpretation] Good morning, Your Honour, yes, I

8 hear and I understand.

9 JUDGE AGIUS: I thank you, Mr. Brdjanin and good morning to you.

10 Appearances for the Prosecution.

11 MS. RICHTEROVA: Good morning, Anna Richterova for the Prosecution

12 assisted by Hasan Younis case manager.

13 JUDGE AGIUS: I thank you madam and good morning to you both.

14 Appearances for Radoslav Brdjanin.

15 MR. ACKERMAN: Good morning, Your Honours I'm John Ackerman and

16 I'm here with Mr. Brian Roberts.

17 JUDGE AGIUS: I thank you and good morning to you both. So I

18 understand that there are some minor points that you would like to raise

19 before we bring in the witness.

20 MS. RICHTEROVA: Exactly. There is really a minor point. I

21 discussed the protective measures with the witness 7.266, we requested

22 closed session. I discussed this issue with the witness and she agrees to

23 open session if she is -- if she was granted facial distortion and

24 pseudonym. She is not concerned of people where she lives but in

25 connection with her work, she travelled all over the places and she would

Page 14687

1 appreciate if her -- she wasn't recognised.

2 JUDGE AGIUS: All right, Mr. Ackerman?

3 MR. ACKERMAN: I have no objection to that at all, Your Honour.

4 JUDGE AGIUS: Okay. So we were about to hand down our decision in

5 any case so we just handed it down. I don't know what -- this witness

6 will testify with protective measures that she -- that you have indicated,

7 Madam Richterova, that is facial distortion and --

8 MS. RICHTEROVA: Pseudonym.

9 JUDGE AGIUS: And pseudonym. If at any time obviously if you

10 require to go into private session, then we would go into private session

11 as and if necessary but no closed session as far as we are concerned.

12 MS. RICHTEROVA: Thank you, Your Honour. The second thing was we

13 requested closed session for the Witness 7.157.

14 JUDGE AGIUS: Is that BT89?

15 MS. RICHTEROVA: It is BT89.

16 JUDGE AGIUS: BT89 is going to be closed session.

17 MS. RICHTEROVA: It is a female witness.

18 JUDGE AGIUS: Yes. Our decision is as follows. It will be handed

19 down in writing but basically this is what we are deciding, that both as

20 regards BT88 and as regards BT89, they will be referred to by these

21 respective pseudonyms at all times in the course of the testimony, or

22 whenever referred to in the course of the proceedings, whether during the

23 hearing or in documents, including the transcript of the proceedings. The

24 testimony of Witness BT89, which is the one after the next, shall be held

25 in closed session. All hearings to consider the issue of protective

Page 14688

1 measures of the Witness BT89 shall be held in closed session, and edited

2 record and transcripts of the said sessions shall be released to the

3 public after review by the Prosecution in consultation with the VWS. The

4 name addresses and whereabouts of BT89 shall be sealed and not included in

5 any of the public records of the Tribunal. And the usual other details of

6 such decisions, including that the testimony of BT89 shall be sealed and

7 shall not be released to the public or media in any form.

8 So in the meantime we can proceed with BT88. It's BT88, yes you

9 have to draw down until she comes in and then --

10 MS. RICHTEROVA: I have one small issue. I already discussed it

11 with Mr. Ackerman. We would like to swap the Witness 7.156 with the

12 Witness 7.157 so it means that after Witness 7.266, which will testify in

13 open session today, tomorrow we would call the Witness 7.157.

14 JUDGE AGIUS: All right. If you have no problems with that,

15 Mr. Ackerman, we can proceed that way.

16 MR. ACKERMAN: Your Honour I have no problems as long as we don't

17 start with 7.157 today since I only learned about this this morning,

18 although Ms. Richterova made efforts to reach me by e-mail and fax

19 yesterday my system was broken down and not working and she wasn't able to

20 do so.

21 JUDGE AGIUS: Mine too.

22 MR. ACKERMAN: Unfortunately I didn't learn about it until this

23 morning so I didn't have any materials here at all so we could start that

24 witness in the morning. I hunch we will finish maybe a few minutes early

25 today then.

Page 14689

1 JUDGE AGIUS: I don't know. I have no idea. I don't know how

2 long you anticipate your in chief to last.

3 MS. RICHTEROVA: I expect two hours but Your Honours know that you

4 can expect one and the reality is different.

5 JUDGE AGIUS: What I meant to say actually or the reason why I

6 mention this is that I feel -- I don't know whether you would agree with

7 me, but I feel Mr. Ackerman's complaint is fully justified if he was not

8 prepared to start with the evidence of 7.157 today he should not be put in

9 that position.

10 MS. RICHTEROVA: Of course we just discussed it and he agreed with

11 tomorrow and I already informed VW about this.

12 Just for the record, Ann Sutherland joined the Prosecution team.

13 JUDGE AGIUS: Thank you. Good morning to you.

14 [The witness entered court]

15 JUDGE AGIUS: Good morning to you, madam. I take it you can

16 follow what I'm saying in a language that you can understand.

17 THE WITNESS: [Interpretation] Yes.

18 JUDGE AGIUS: So good morning once more. You are about to give

19 evidence. I will explain to you later on under which conditions, in the

20 meantime, before you start your evidence, it is required by our rules that

21 you enter a solemn declaration equivalent to an oath, that you will be

22 telling us the truth, and the whole truth in the course of your

23 testimony. The text of the solemn declaration is contained in a piece of

24 paper which Madam usher is going to hand to you now. Please read that

25 solemn declaration aloud and that will be your undertaking with this

Page 14690

1 Tribunal that you will be speaking the truth.

2 THE WITNESS: [Interpretation] I solemnly declare that I will speak

3 the truth, the whole truth, and nothing but the truth.

4 WITNESS: WITNESS BT88

5 [Witness answered through interpreter]

6 JUDGE AGIUS: I thank you. You may sit down.

7 I take it that this is the first time that you are giving evidence

8 before this Tribunal, and therefore I will explain to you very briefly

9 what's going to happen. You are first going to be asked a set of

10 questions by the Prosecution, today being led by Madam Richterova. I

11 suppose that you know her already. You have met her already. She will

12 then be followed by Mr. Ackerman -- have you been following, have you

13 been hearing what I was saying or did you have difficulties? She will

14 then, Madam Richterova, she will then be followed by Mr. John Ackerman,

15 who is the lead counsel for Radoslav Brdjanin who is the accused in this

16 case. He will be cross-examining you.

17 Now, you asked for and we have granted you some what we call some

18 protective measures, and basically they are two. The first one is that no

19 one will refer to you by your name here but we will be referring to you by

20 a pseudonym, by a nom de plume. You are just being -- going to be

21 referred to by a number, and a couple of letters. You are BT88. BT88.

22 And that's how you will go into the records of this case, and any

23 documents that are handed down and out to the public will not bear your

24 name but your pseudonym only. That's number 1.

25 Number 2 is that although others will be able to hear and follow

Page 14691

1 your testimony, no one will be able to see your face, and that's because

2 we have granted you visual, facial distortion, image distortion. In other

3 words if you look at your monitor right in front of you, if it is on video

4 mode, and that's what others will see you like. That's how you appear to

5 others. In other words, your image is completely distorted and no one

6 should be able to see your face anywhere outside this court.

7 Having explained that, I will now invite Madam Richterova to start

8 with her examination-in-chief. One bit of advice. Please answer the

9 question, the whole question, and nothing but the question. Don't go

10 round in circles, don't give us long stories. We are only interested in

11 the answer that is specific to the question or questions that are put to

12 you in sequence. So try to answer those questions. Otherwise you will be

13 here for days and no one will enjoy that.

14 So Madam Richterova, she is in your hands.

15 Examined by Ms. Richterova:

16 Q. Good morning, Witness. I would like the usher to show you a piece

17 of paper. Just read the name for yourself and confirm whether yes or not

18 it is your name.

19 A. Yes.

20 MS. RICHTEROVA: This would be Prosecution Exhibit under seal

21 P1689 -- I'm sorry, 1686.

22 Can we go to private session just for some preliminary questions.

23 JUDGE AGIUS: Yes, let's go to private session for a while. Madam

24 when we go to private session, then members of the public won't even --

25 won't be able to hear what you're saying. The reason is that you'll be

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Page 14693

1 giving some details about yourself that would otherwise identify you if

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24 [Open session]

25 JUDGE AGIUS: Yes. Let's go into private session again, please,

Page 14696

1 for a second.

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18 [Open session]

19 JUDGE AGIUS: We are in open session now. Please proceed.

20 MS. RICHTEROVA:

21 Q. I would like to show you one document, and it is -- it has already

22 been exhibited. It's P242. I will give you my version. It is a decision

23 dated 12 of June, 1992. It says Serbian Republic of Bosnia and

24 Herzegovina, Autonomous Region of Krajina, Crisis Staff Banja Luka, and it

25 is decision to found an agency for population movement and exchange of

Page 14697

1 material wealth for the Autonomous Region of Krajina, and it is signed for

2 president Radoslav Brdjanin. Was this the official title of the agency

3 you started working for?

4 A. Yes.

5 Q. Leave it with the witness so we will need it a little bit later.

6 How did you learn about this company? How did you start working

7 for this company?

8 JUDGE AGIUS: First of all, the agency.

9 MS. RICHTEROVA:

10 Q. Agency, I'm sorry.

11 A. Do you want me to answer?

12 JUDGE AGIUS: Yes, please.

13 THE WITNESS: [Interpretation] A group of refugees, because

14 refugees were arriving in Banja Luka on a daily basis, so from the group

15 of refugees that had virtually besieged the municipality building at the

16 Crisis Staff, there were people who asked for an organisation to be set up

17 upon their arrival in Banja Luka. So it was upon their request that such

18 an agency was established. Since it was wartime, of course, we did not

19 have adequate means or office equipment. My office happened to have

20 adequate equipment so my husband, together with a lawyer who insisted that

21 such an agency should be set up, offered the equipment that we owned for

22 the use of this agency, and this is how I happened to become an employee

23 of this agency.

24 MS. RICHTEROVA:

25 Q. What was the name of the lawyer?

Page 14698

1 A. Djoko Popovic.

2 Q. Did you know where he worked at that time?

3 A. I know that he was a lawyer by profession and that he had fled

4 from Travnik.

5 Q. Do you know whether he had any contacts with municipality, with

6 the municipal assembly or some other authorities?

7 A. I'm sure he did, because all refugees would gather in front of the

8 town hall every day.

9 Q. So did he, when you said that the refugees gathered in front of

10 the town hall, did he work for the town hall or what did you know about

11 him?

12 A. My husband knew him from before the war, and when I say that

13 refugees gathered in front of the town hall it was because there was no

14 official institution where they could be registered and look for

15 accommodation. At that time, they were still sleeping in school

16 buildings, kindergartens, and that was the reason why they were coming to

17 the municipality building at the time.

18 Q. And once again, just answer me yes or no, do you know whether this

19 Mr. Popovic worked for the municipality or not?

20 A. No, I don't know. I don't know whether he worked for them.

21 Q. You can see the date on this document as 12 of June.

22 A. Yes.

23 Q. Did the agency start working immediately in June or when did it

24 start working?

25 A. No, not immediately in June. Sometime in August, but there were

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Page 14700

1 preparations going on during that period of time. They were moving

2 offices, the equipment.

3 Q. So the date June, did you know in June about the existence of this

4 agency?

5 A. It did not exist in June yet.

6 Q. So when were these discussions about setting up the agency? When

7 did it start?

8 A. Sometime in July.

9 MS. RICHTEROVA: I would like to show the witness Exhibit P241.

10 Q. Before it is shown to you do you know the name of a person who was

11 in charge of this agency?

12 A. Yes.

13 Q. What was his name?

14 A. Milos Bojinovic.

15 Q. So this is decision issued by Crisis Staff Banja Luka, signed

16 Radoslav Brdjanin, decision to appoint professor Milos -- and it is either

17 Vojinovic or Bojinovic --

18 MR. ACKERMAN: Excuse me, Your Honour.

19 JUDGE AGIUS: Yes, Mr. Ackerman?

20 MR. ACKERMAN: I think it's not signed by Mr. Brdjanin, I think

21 it's signed for him. I think it's a "za" document.

22 JUDGE AGIUS: Yes, Madam Richterova, I think he is right.

23 MS. RICHTEROVA: Yes, you're right.

24 JUDGE AGIUS: Thank you, Mr. Ackerman.

25 MS. RICHTEROVA:

Page 14701

1 Q. Can you read the original document and can you tell us what is the

2 correct name, according to you, from this document?

3 A. Milos Bojinovic [Realtime transcript read in error "Vojinovic"].

4 Q. And again, he was appointed on 12th of June?

5 A. Yes, according to this document.

6 Q. And do you remember when you met Mr. Bojinovic for the first time?

7 A. I don't know the exact time but it must have been sometime in late

8 July or early August.

9 JUDGE AGIUS: Yes, Mr. Ackerman?

10 MR. ACKERMAN: Excuse me Your Honour there is confusion in the

11 transcript. She was asked what this person's name is and she said it was

12 Milos Vojinovic and the next question is about a person named Bojinovic.

13 JUDGE AGIUS: Yes.

14 MR. ACKERMAN: I'm satisfied it's the same person but the

15 transcript doesn't necessarily reflect that.

16 JUDGE AGIUS: Unfortunately in this part of the world, or rather

17 from the southern part of Europe, the B and the V is very often mistaken.

18 So it is the same -- I know it's the same person but obviously just for

19 the record we just confirm it. Thank you.

20 MS. RICHTEROVA:

21 Q. Can you tell us where the premises of this agency were located?

22 A. In the Mejdan local community.

23 Q. Who lived in Mejdan community? What was the ethnicity structure

24 of population in Mejdan?

25 A. Mixed.

Page 14702

1 Q. Were there some -- some nationalities which would prevail?

2 A. Slightly perhaps. I live in Mejdan.

3 Q. And when you said slightly, so which ethnicity would be just

4 slightly prevailed?

5 A. Muslim.

6 Q. Can you tell us, in brief, the initial activities of this agency?

7 What were your tasks?

8 A. The idea was that there should be an agency where Serb refugees

9 could register themselves upon arrival in town. Themselves and members of

10 the families that they had left behind. The records were meant to include

11 also their occupation, their qualifications, what property they had come

12 with, what property they had left behind, and similar information. So

13 that we know who came in town and how many people, how many new people,

14 there were living in town. So that was the idea behind this agency,

15 initially.

16 Q. When you said that you registered not only names, places, where

17 they came from, but also qualification, do you know whether the

18 municipality was able to find jobs for these people based on this

19 information?

20 A. It was very difficult because at the time nothing was working.

21 Q. But to your knowledge, was it the case or not?

22 A. I'm sorry, I don't understand your question.

23 Q. My question was: Because you also registered the people according

24 to their qualification, so my question was whether it was possible for the

25 municipality to find relevant job for these people?

Page 14703

1 A. No. Because companies were not working. There were no jobs that

2 they could take. And the reason why we recorded their qualifications and

3 professions was because they -- most of them did not bring with them their

4 personal documents, their certificates.

5 Q. Did you collect any fee for this type of service?

6 A. No.

7 Q. So how did the agency make its money?

8 A. It was the very beginning, we did not need money at the beginning.

9 Q. So you say it was the beginning. So what happened then, after

10 this initial activities?

11 A. The Red Cross, that kept records for non-Serb population, who

12 wanted to leave Banja Luka, brought us these things for us to continue

13 doing them.

14 Q. And do you know when this happened?

15 A. I told you I don't remember the exact dates but it was sometime in

16 August.

17 Q. And how long approximately again, how long did this first initial

18 activity of registering refugees last?

19 A. We continued registering them but until the beginning of the

20 second part of our work, maybe some 15 days, for about 15 days.

21 Q. And then all of a sudden, you hand -- you were given activities

22 from the Red Cross. Who informed you about the change of your work?

23 A. Representatives of the Red Cross brought us lists that they had

24 drawn up, and told us that from now on, we would be in charge of that.

25 Q. And how did the non-Serb population learn about the fact that you

Page 14704

1 took over from the Red Cross?

2 A. Sorry, I didn't understand your question.

3 Q. How the non-Serb people learn that it is you, this agency, who

4 will be dealing with registration -- with their registration?

5 A. They were told at the Red Cross that they would no longer be in

6 charge of that but that the agency, that is located in Mejdan, would take

7 over.

8 Q. So what -- you said that the Red Cross one day brought you these

9 lists of people and you took -- you took over. What were you are told

10 your new task is?

11 A. That we would be in charge of compiling lists, securing transport,

12 going to the separation line with Croatia to take affidavits that people

13 needed when going to Croatia, and similar type of work.

14 Q. What was the purpose of these lists? What were you doing? What

15 was your task?

16 A. Those were the lists that we had to draw up depending on what

17 transport we had available. For example, if we had only one bus, then we

18 would have to draw up a list of people who can be boarded on that bus. If

19 we had two buses then we would make lists accordingly. Those were the

20 lists of non-Serb population which -- who had valid documentations, that

21 was required, for them to be put on the lists, so that they could travel.

22 Q. So the purpose of your agency, from this moment, was to prepare a

23 list of non-Serb population who wanted to leave Banja Luka, is it

24 correct?

25 A. Yes, in addition to the work that we had already started with Serb

Page 14705

1 refugees.

2 Q. And can you take us through the registration procedure? How did

3 it start? What one needed if he or she wanted to leave Banja Luka?

4 A. They needed a certificate issued by the local SUP to the effect

5 that they were changing place of residence. They had to have a

6 confirmation letter from a third country, because Croatia did not allow

7 transits if they did not have such letters, because they were afraid that

8 they would remain in Croatia. A certificate issued by the bank to the

9 effect that they had no outstanding debts or loans, and also a receipt

10 certifying that they had paid the required amount of money for the

11 transport.

12 Q. I will start with this changing place of residence. What did it

13 mean? Did it mean that they exchange apartments or they just cancel their

14 residence in Banja Luka?

15 A. No, not the exchange of apartment. They would just cancel their

16 residence in Banja Luka, because even before the war, whenever someone

17 wanted to change place of residence, he or she was required to come to the

18 SUP and sign a piece of paper stating that he was leaving his place of

19 residence and going some place else so that when he gets to his new place

20 of residence, he can get adequate certificate.

21 Q. So they receive a confirmation, they abandon it, their apartment,

22 they cancel the residence?

23 A. Yes, the residence. Not that they abandoned their apartments but

24 that they had cancelled their residence with the SUP.

25 Q. What happened to that apartment, if they cancelled the residence

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Page 14707

1 with the SUP?

2 A. They would lock them and leave them, but usually they didn't leave

3 at the same time. Usually a member of the family would stay behind when

4 they -- and some left together and would then leave their apartments or

5 houses empty.

6 Q. Then you mention confirmation letter from a third country. You

7 organised these buses to move non-Serbs out of Banja Luka. Where did you

8 go? Where these people go by these buses? What was their destination?

9 A. To take them to the separation line with Croatia. The place where

10 they were taken was called Dragalic.

11 Q. And were they taken to some other places or just to Croatia or to

12 the borders with Croatia?

13 A. Only to the border.

14 Q. And were they also taken to some places within Bosnia and

15 Herzegovina?

16 A. Yes, a group went to Travnik.

17 Q. And then you mentioned this pay slip. So how much these people

18 had to pay for registration to be transferred from Banja Luka?

19 A. Not for registration but for the ticket, the travel ticket. I

20 don't exactly remember how much it was, between 30 and 50 German marks but

21 I really cannot remember the exact amount.

22 Q. Did you use buses which would belong to this agency, or did you

23 hire private buses?

24 A. No. The agency didn't own buses. They hired buses.

25 Q. You just stated that the agency took something between 30 and 50

Page 14708

1 marks, which would be the price of the ticket. How much did you pay to

2 these private companies, these transport companies?

3 A. I cannot recall the amount.

4 Q. Did they receive the -- also the price of the ticket?

5 THE INTERPRETER: I didn't hear the witness.

6 MS. RICHTEROVA: She didn't understand.

7 JUDGE AGIUS: Could you please repeat the question and could you

8 please repeat your answer? The reason is that the interpreters did not

9 hear what you answered.

10 MS. RICHTEROVA:

11 Q. My question was: You stated, "We received from 30 to 50 marks for

12 a ticket." Did you also give the same money to these transport companies?

13 It means one person, let's say 30 deutschmark, because it was the price of

14 a ticket?

15 A. No, not the whole sum. It really depended on the price that we

16 agreed upon with the transport company.

17 Q. So I'm again returning back to my previous question. How did the

18 agency make its money, if you do not ask for any registration fee and you

19 are asking only for the money which are relevant to the price of one

20 ticket?

21 A. We always tried to negotiate a lower price, and we financed

22 ourselves from the remainder of the money.

23 Q. Now I would like to show you a document which we received from the

24 Defence, and our marking is Y001-8261.

25 A. I've read it.

Page 14709

1 Q. This is a document issued Serb Republic of Autonomous Region

2 Krajina-Banja Luka. Your agency -- agency for help in moving of

3 population and exchange of material property. And it is authorisation for

4 these three people and please don't put it on ELMO. To go -- to carry out

5 negotiations with the representatives from the Republic of Croatia

6 regarding the matters concerning moving of population and exchange of

7 material property, and it was signed by Milos Bojinovic. And the date is

8 10 of August.

9 And you mentioned before that to collect these authorisations or

10 affidavits from Croatia was part of your job, the date for this

11 authorisation was 10 of August. Does it mean that you already started

12 working on this project already at the beginning of August?

13 A. I said I couldn't remember the exact date. It was sometime in

14 August but I really cannot recall the date. Do you want me to explain

15 this document?

16 Q. Yes. I would like you to explain just briefly. Did you go and

17 why did you go to Croatia?

18 A. We didn't go to Croatia. We went to the separation line, and we

19 went there to fetch the affidavits, the guarantees that were required for

20 those people who were travelling from Banja Luka. The letters that were

21 part of the obligatory bunch of documents.

22 Q. If someone wanted to leave Banja Luka but not to Croatia and you

23 mentioned that people were leaving also for Travnik, if someone wanted to

24 leave for Travnik, did he or she need some kind of authorisation as well,

25 some kind of guarantee?

Page 14710

1 A. We started doing Travnik when Croatia prohibited transit over its

2 territory for refugees, and as people of non-Serb ethnicity were

3 constantly pressing us, insisting that they wanted to leave, then we

4 started using Travnik as a route, because no letters of guarantee were

5 required there.

6 Q. You stated that you took over from the Red Cross. Was there any

7 preparation phase before you started dealing with this particular task?

8 A. No.

9 Q. You said that these people had to pay or had to bring you this pay

10 slip. Where did they pay this money?

11 A. At the post office or at the bank.

12 Q. Did you have any special account?

13 A. Yes. The agency had the giro account.

14 Q. And did you have this account right from the beginning or after

15 you started with this activity?

16 A. From the beginning, ever since the agency was registered with the

17 court, under our law, no company or agency may be registered if it doesn't

18 have a giro account in a bank through which payments will be made.

19 Q. And one more question about the buses and these companies you used

20 to transfer the non-Serb people from Banja Luka: Do you happen to

21 remember any of these companies?

22 A. To begin with, we worked with private entrepreneurs who owned

23 buses. I can't remember their names but there were two men who had a bus

24 each, and because petrol was very expensive they charged a lot. Then we

25 looked for someone whose services would be cheaper, and there was

Page 14711

1 something called, I think it was Autoprevoz Knezevo or something like

2 that, a transport company we discovered.

3 Q. And tell me, one day, these people started coming to your company,

4 they tried to be registered. How many people a day approximately were in

5 front of your agency, were coming to your agency?

6 A. Serbs and non-Serbs?

7 Q. Now I am asking about non-Serbs.

8 A. Many, very many, a great many. The queues were very long. They

9 were there from morning until evening almost, standing there in front of

10 the agency waiting.

11 Q. And when you say many, many people, are we -- and when we are

12 talking about many, many people, are we talking about hundreds?

13 Approximately tell us.

14 A. A 100 or 200.

15 Q. And was it every day?

16 A. Yes.

17 Q. Also over weekends or just five working days?

18 A. Only five working days.

19 Q. And how did you make the final selection?

20 A. You mean those who were to leave? Well, people would queue up and

21 those whose turn it was, we didn't make any selection, we just listed

22 people as they came in, provided of course that they had all the required

23 documents and that the documents were in order.

24 Q. So you received the required documents, you registered the -- a

25 person. So what happened after that?

Page 14712

1 A. Then we would draw up the list that we had to hand over to the SUP

2 to be checked, we had to inform them. And then we looked for buses and

3 then people travelled.

4 Q. And you said that you had to hand over these lists to the SUP.

5 What was the reason behind this?

6 A. Yes. And the reason that the SUP gave was that there were many

7 people who had been indicted or sentenced, people who had stolen something

8 or broken the law, and such people were not allowed to go. They could not

9 evade the law. They had to be held responsible for what they had done.

10 Q. Do you know whether anyone was taken off the list?

11 A. Throughout the time I worked in the agency on one occasion, one

12 man was taken off the list.

13 Q. And did you learn why he was taken off the list?

14 A. Yes. He was one of seven people who had been members of the SDA

15 and founded a young Muslim organisation. They called the Muslim people to

16 arm themselves and to rebel.

17 Q. And how many convoys did you organise per week or per month?

18 A. Throughout the time I worked there, perhaps six.

19 Q. Did you organise --

20 A. Or maybe seven times we did this.

21 Q. Did you organise convoys, or did you manage to organise convoys,

22 every week?

23 A. No, no, no.

24 Q. So how often?

25 A. Maybe once or twice a month.

Page 14713

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Page 14714

1 Q. And again, -- and again, how many buses form such a convoy?

2 A. Well, it varied, depending on how many we could get. Sometimes

3 there was one, sometimes three.

4 Q. And if you say not every week, so approximately how often you

5 managed to organise these convoys?

6 A. Once or twice a month.

7 Q. And again, I will ask for how long did you organise these convoys,

8 or better say, for how long did you work for this agency and organise the

9 convoys?

10 A. I worked in the agency until the end of December, 1992. The

11 organisation of the convoys did not depend on us but also on the other

12 side. Sometimes we would secure transport, prepare people, and then one

13 of the negotiators would go to Dragalic to say a convoy was to arrive on

14 the next day and Croatia refused to accept the people. Then we would have

15 to postpone the convoy and wait until Croatia was ready to receive them.

16 Sometimes we would wait 15 days, a month, two, it all depended.

17 Q. I will show you one more document -- or I will show you two

18 documents. If this Exhibit P288 and the other one is payroll, it's a

19 Defence document, with our markings Y001-8263.

20 This document P288, it's from the radio, unfortunately we do not

21 have the interview itself, but it says that our reporter, Dragan Stegic

22 talked about the passport in the agency with its president, Milos

23 Bojinovic. And the date of this interview was 23rd of July, 1992. I know

24 that you said that you do not remember now when exactly you started

25 working for this agency, but if you look at this document dated 23rd of

Page 14715

1 July, and Milos Bojinovic was supposed to talk about the work of the

2 agency, to your knowledge, is it possible that the agency worked already

3 in July?

4 A. No, no. It didn't work in July. In July we were carrying out

5 preparations but would you please give me sometime to read this? I

6 haven't read it.

7 Q. Yes, please. This document doesn't say anything about the content

8 of the interview. It just says that the interview was conducted with

9 Milos Bojinovic and the date.

10 The other document is payroll from July. So did you work already

11 for the agency in July? You stated that there was some preparation phase.

12 Was it possible that it was in July?

13 A. That was when we were carrying out preparations, and as for this

14 payroll, it could have been drawn up retroactively in order for us to be

15 paid for the work we did at the time, because in the first few months, we

16 didn't have any money. I said that the agency financed itself.

17 Q. The amount of money was around 20.000 dinars. Is it correct you

18 were paid in dinars?

19 A. Yes. Our currency at that time was the dinar.

20 Q. And if the witness could be shown document Y001-8259, which is a

21 payroll from December? And can you see your name on this payroll?

22 A. Yes.

23 Q. And the money paid are around 70.000 dinars, so the --

24 A. Yes.

25 Q. -- Agency was earning money to pay you?

Page 14716

1 A. Yes, yes.

2 Q. And you said that the agency was earning money just from the

3 payment of the tickets for the bus?

4 A. Yes, and the taxes they paid at the time, we started carrying out

5 exchanges of flats, and people both Serbs and non-Serbs would pay a tax of

6 I think five marks.

7 Q. When did your agency start dealing with this activity? I mean the

8 exchange of apartments. When did you start?

9 A. I told you I have a very poor memory for dates but it could have

10 been in August or September. I really couldn't pinpoint the exact date.

11 Q. You worked, as we heard, approximately for four or five months,

12 July you mentioned the preparation phase, August we have this

13 authorisation, so you already started dealing with Croatian part.

14 September, October, November, December. So within these five months, was

15 it right from the beginning? Was it in the middle? Or was it at the end

16 of the time, you worked for this company, for this agency?

17 A. You mean the exchange of apartments?

18 Q. The exchange of apartments.

19 A. Well, let's say sometime in the middle of the time I worked there.

20 Q. And who came with this idea?

21 A. To me?

22 (Redacted)

23 (Redacted)

24 (Redacted)

25 (Redacted)

Page 14717

1 (Redacted)

2 (Redacted)

3 (Redacted)

4 (Redacted)

5 (Redacted)

6 Madam, while we are in open session, try to avoid either

7 mentioning names or giving details which could identify you. We are

8 trying to protect you. At the same time you're trying to reveal your

9 identity without obviously realising that so we are taking care of that.

10 We are going to redact that from the public transcript or transcript which

11 would be available to the public.

12 Yes, Madam Richterova, please proceed.

13 MS. RICHTEROVA:

14 Q. So it was more or less your idea based on your experience with

15 other people who managed to exchange such apartment, is it correct?

16 A. Yes.

17 Q. And how was the agency involved in this exchange of apartments?

18 A. Legal advice we had form -- or rather there was a form that could

19 be bought in shops, in book shops, for the buying and selling of real

20 estate and people would come and fill this in and bring it to us and then

21 we would give them advice and then the contracts would be validated by the

22 authorities on both sides, because for a contract to be valid, it would

23 have to have the seal of both governments on both sides.

24 Q. So you provided the legal advice. Did you ask Mr. Bojinovic

25 whether it is possible to provide this type of service?

Page 14718

1 A. Yes, yes.

2 Q. And he agreed?

3 A. Yes, yes.

4 Q. And how much did you charge for this type of service?

5 A. As I said, I think five marks.

6 Q. And did you receive this money in cash or again was it put on the

7 account?

8 A. No, no, not in cash. It was all through the account.

9 Q. And again, approximately how many people utilised this service?

10 A. I think quite a few, but when I left all the documentation stayed

11 there. So I couldn't tell you now but I think that these contracts on the

12 exchange of property, they all remained in the agency when I left it.

13 Q. And are you able to tell us at least approximately whether it was

14 more than ten, more than 100, more than 200?

15 A. More, more than 100. Much more than a hundred, I think.

16 Q. If you say much more than 100, was it more than 1.000?

17 A. No, no, no.

18 Q. And before we will have a break can we go to a private session for

19 a moment?

20 JUDGE AGIUS: Yes. Let's go to private session for a while

21 please.

22 [Private session]

23 (Redacted)

24 (Redacted)

25 (Redacted)

Page 14719

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Page 14721

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7 (Redacted)

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9 (Redacted)

10 (Redacted)

11 (Redacted)

12 (Redacted)

13 (Redacted)

14 (Redacted)

15 (Redacted)

16 (Redacted)

17 [Open session]

18 THE WITNESS: [Interpretation] No. I said that the agency was not

19 opened to carry out the moving out of non-Serbs, but to help the Serbs

20 coming into Banja Luka every day who had no where to register and no one

21 to look after them. They slept in schools, kindergartens, sports halls,

22 even in the streets, and then it happened that the Red Cross transferred

23 the lists but we didn't distinguish between ethnicity -- ethnicities. We

24 didn't draw any distinctions. We helped every one who wanted to leave. I

25 think mostly they wanted to leave because they were afraid of the large

Page 14722

1 number of Serbs coming in. Banja Luka was the only place where there was

2 no war going on.

3 MS. RICHTEROVA: We will discuss this after the break.

4 JUDGE AGIUS: Yes. We will have a break until 11.00. Thank you.

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

6 --- On resuming at 11.04 a.m.

7 JUDGE AGIUS: [Microphone not activated] Yes, Mr. Brdjanin is

8 back. So Madam Richterova, you may proceed.

9 THE INTERPRETER: Microphone, Your Honour, please.

10 JUDGE AGIUS: Thank you. Sorry about that. Madam Richterova, you

11 may proceed.

12 MS. RICHTEROVA: Thank you.

13 Q. Witness, were you ever present when people were leaving Banja Luka

14 and it was still organised by the Red Cross?

15 A. Yes.

16 Q. How many times were you present, approximately?

17 A. Several times, when my school friends and colleagues were leaving,

18 those who were of non-Serb ethnicity.

19 Q. And again approximately how many buses did you see leaving during

20 the occasions when you were present there?

21 A. I'm not able to tell you the exact number but on those several

22 occasions when I went, there would be two buses.

23 Q. So each time, just to clarify it, each time you were there, there

24 was approximately two buses?

25 A. Yes.

Page 14723

1 Q. And do you know how often Red Cross organised these convoys?

2 A. No.

3 Q. And you said several times you were present several times. What

4 was -- what were the gaps between these departures?

5 A. I don't know exactly, maybe every 10 or 20 days. I mean, I

6 was -- I wasn't present when buses were leaving at all times. Only when I

7 went there to greet my friends.

8 Q. And did you know what buses the Red Cross was using? Were they

9 private -- excuse me, were they buses from private companies or from

10 municipality or do you know it?

11 A. No, no.

12 Q. And when you took over from the Red Cross, compiling these lists,

13 did you took over also buses or the companies which were -- which were

14 providing this service for the Red Cross?

15 A. Two privately owned buses were offered to us by their owners.

16 They told us they had previously worked for the Red Cross.

17 Q. And my question was: Did Red Cross maybe gave you a list of

18 companies which they were using for transport?

19 A. No, no.

20 Q. And again, to clarify how many people left Banja Luka via your

21 agency, you stated you worked for this agency approximately from August

22 until December, which is five months, and you stated that the agency

23 organised probably only six convoys while you were working there, is it

24 correct?

25 A. Yes.

Page 14724

1 Q. So --

2 A. Approximately six. Again, I don't know the exact number.

3 Q. And you stated that you -- when you organised only these

4 approximately six convoys, that you had two or three buses, which would

5 mean that you transferred or you provided your service only to

6 approximately 300 -- from 300 to 400 people, is it correct, or were there

7 more people who left Banja Luka?

8 A. Well, there are often 40 seats on a bus, so there is -- it's 18

9 times 4, something over 100 --

10 JUDGE AGIUS: Yes. The interpreters -- the last words that we

11 heard was something over 100, but we get the impression that the

12 interpretation was interrupted. Madam, could I ask to you repeat your

13 answer? They said -- you said, well, there are often 40 seats on a bus,

14 so there is -- it's 18 times 4, something over a hundred. Did you say

15 anything else beyond that or was that the end of your testimony, of your

16 answer?

17 THE WITNESS: [Interpretation] Something over a hundred, yes.

18 JUDGE AGIUS: All right.

19 MS. RICHTEROVA:

20 Q. So you want to say that in one convoy, there were approximately

21 100 people?

22 A. Yes.

23 Q. And you --

24 JUDGE AGIUS: Perhaps at this point, madam, before I decide to

25 intervene in a much stronger manner, the witness could tell us how much

Page 14725

1 she reckons her agency or the agency she worked for, how many people

2 they -- she -- that that agency moved out of the area it was responsible

3 for, how many that Caritas and how many did Merhamet, because she

4 mentioned both, and how many did the Red Cross, because the numbers must

5 tally. Otherwise, someone is not telling us the truth and if I catch

6 anyone not telling us the truth, there will be fire works in this room.

7 MS. RICHTEROVA:

8 Q. Witness, within these five months, you were compiling these lists,

9 you were giving these lists to police for clearance. Approximately within

10 these five months, how many people left Banja Luka via your agency? Was

11 it more than 100? Was it more than 500? Was it more than 1.000? Was it

12 less?

13 A. Via our agency, the number would be 1.000, between 600 and 1.000,

14 during the time when I worked there.

15 Q. And your agency was financed just from the incomes you received

16 from these people who were buying tickets to leave Banja Luka?

17 A. Yes, and the people who had paid the tax for the exchange of their

18 apartments and houses.

19 Q. Now I will --

20 JUDGE AGIUS: Yes, perhaps she could work out a little bit of

21 arithmetic here, a little bit of mathematics because at the rate that she

22 mentioned earlier, that these persons were paying, which would be -- she

23 should put us in a position whereby we can see whether the figures at

24 least that are shown on the pay slips or the pay statements for December

25 in particular, whether they tally or not. Yes, Mr. Ackerman?

Page 14726

1 MR. ACKERMAN: Your Honour, the problem is we don't know how marks

2 and dinars relate in December of 1992 because the pay slips show dinars

3 and the people were paying marks.

4 JUDGE AGIUS: Yes, in marks.

5 MR. ACKERMAN: I think 20.000 dinars was I think less than 100

6 marks.

7 JUDGE AGIUS: I don't know. That's why I'm asking the witness to

8 clarify that.

9 MS. RICHTEROVA:

10 Q. Witness, you heard the question which was asked by the Judge. Was

11 it -- was the income from these tickets and the fee for legal advice

12 sufficient to provide salary for 11 people working in the agency?

13 A. Yes, but that income -- or rather those salaries were not very

14 high.

15 Q. Did you by any chance remember what was the exchange rate between

16 dinar and deutschmark at that time?

17 A. No. I -- not exactly.

18 JUDGE AGIUS: Did anyone bother to pay you in dinars at the time?

19 THE WITNESS: [Interpretation] No.

20 JUDGE AGIUS: So she didn't have to bother about the exchange

21 rate, Madam Richterova.

22 MS. RICHTEROVA:

23 Q. And again, last question regarding this subject: Do you know

24 approximately how many people left with Caritas and Merhamet? Did you

25 cooperate with these humanitarian organisations?

Page 14727

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Page 14728

1 A. No, no. We didn't cooperate with them, and I don't know how many

2 people left.

3 Q. As I said before, I will change the subject.

4 At the beginning, I showed you the document, decision to found an

5 agency for population movement, and it was stamped by Radoslav Brdjanin or

6 I'm sorry, it was --

7 JUDGE AGIUS: For.

8 MS. RICHTEROVA:

9 Q. It was stamped for Radoslav Brdjanin. Did you know Radoslav

10 Brdjanin in 1992?

11 A. Only from the media. He was one of the people who were in power

12 at the time and we all knew him, but I personally didn't know him.

13 Q. And did you know what was his position at the time?

14 A. No, not exactly. I know that he was one of the leaders but I

15 don't know what kind of position he held.

16 Q. And I show you this document that it was issued by Crisis Staff.

17 Did you know whether or not Mr. Brdjanin was a member of the Crisis Staff?

18 A. No, I didn't.

19 Q. You didn't learn via media what was his position?

20 A. At the time, there were often power shortages, and we couldn't

21 follow the media all the time. I know that he was a member of the top

22 leadership, that he was in local government but I was not aware of the

23 function he performed.

24 Q. Did you see him talking on television, on -- did you hear him on

25 radio or did you see any rallies in which he would participate?

Page 14729

1 JUDGE AGIUS: Yes, Mr. Ackerman?

2 MR. ACKERMAN: Your Honour, I object unless there is a time frame

3 set, if she is going to talk about 1995 or 75.

4 JUDGE AGIUS: Yes, you're correct. Please put a time frame to

5 your question.

6 MS. RICHTEROVA: I apologise.

7 Q. I'm talking about year 1991 and 1992.

8 A. No. Not in 1992, because Banja Luka was in total dark practically

9 speaking and very rarely could one listen to the media, but people

10 sometimes tried to improvise broadcasting. I had heard Radoslav Brdjanin

11 speaking on rallies at the time when these divisions between a local

12 authorities occurred.

13 Q. And when was it? Again approximately. Which year, which period

14 of time?

15 A. I think it was in 1991. I don't know exactly when the political

16 parties were established along ethnic lines.

17 Q. You said approximately in 1991?

18 JUDGE AGIUS: Was it in the beginning, towards the end of 1991?

19 Because 1991 is like any other year, it's 12 months, and 12 months is

20 quite a long time.

21 THE WITNESS: [Interpretation] I don't know exactly when the

22 national parties won in Bosnia and Herzegovina but I know that both SDA

23 and SDS held daily rallies at the square [as interpreted].

24 MS. RICHTEROVA:

25 Q. What do you remember hearing?

Page 14730

1 JUDGE AGIUS: Hearing from?

2 MS. RICHTEROVA:

3 Q. From Mr. Brdjanin.

4 A. I personally didn't attend those pre-electoral rallies so I didn't

5 hear anything directly from Mr. Brdjanin.

6 JUDGE AGIUS: Yes, Mr. Ackerman?

7 MR. ACKERMAN: Your Honour, the answer at page 39, line 21, also

8 included HDZ, which didn't make it into the transcript.

9 JUDGE AGIUS: Yes, okay. Do you agree to that, Madam? Did you

10 also mention HDZ apart from SDA and SDS, having daily rallies at the

11 square?

12 THE WITNESS: [Interpretation] Yes.

13 JUDGE AGIUS: Okay.

14 MS. RICHTEROVA:

15 Q. So you didn't attend these rallies. What did you hear from

16 others?

17 A. At that time, all three parties, both gave and requested support

18 from their people, SDS, SDA and HDZ. They talked more or less in the same

19 context, all of them.

20 Q. And did you watch TV in 1991? Did you see any political

21 leaders --

22 A. Yes.

23 Q. -- On television in 1991?

24 A. Yes.

25 Q. And did you see Mr. Brdjanin on television in 1991?

Page 14731

1 A. Yes. Mr. Brdjanin was a representative of the Serb people, so of

2 course he was on TV.

3 Q. I understand that it is 10, 11 years ago, but do you remember

4 anything what was said by Mr. Brdjanin?

5 A. No.

6 Q. Do you remember hearing any other representatives of the SDS

7 speaking?

8 A. No. I mean I did hear something but I don't think I'm able to

9 repeat any of those words.

10 Q. And do you remember hearing any representatives of the SDA?

11 A. The same, the answer is the same. I did hear, but I couldn't

12 repeat what they said.

13 Q. And what about in 1992? Were you able to watch television in the

14 first half of the year 1992?

15 A. Maybe sometime at the beginning of that year, up until the month

16 of March, but we didn't have electricity every day.

17 Q. You didn't have electricity from the beginning of the year?

18 A. Yes, approximately from that time.

19 Q. And at the time when you had electricity, were you able to see any

20 politicians on TV or listen to them on the radio?

21 A. I didn't have time to watch politicians. It was more important

22 for me to switch on the washing machine and take care of the laundry.

23 Q. So you cannot tell us what was your impression about Mr. Brdjanin?

24 Was he popular in Banja Luka?

25 A. Just what I know from the people who came to the agency, the Serbs

Page 14732

1 who visited the agency. Apparently Mr. Brdjanin was very well liked

2 amongst the people, because according to their stories, he was the only

3 man who wanted and endeavoured to help them ease their troubles. This is

4 at least what the Serbs who came to the agency told us. They praised him

5 a lot.

6 Q. So he was popular with the Serb population?

7 A. Yes.

8 Q. Did you hear any comments on Mr. Brdjanin from the non-Serb

9 population?

10 A. No.

11 Q. Back to the agency. To your knowledge, what was the reason for

12 non-Serbs leaving Banja Luka?

13 A. I think that the main reason for non-Serbs leaving Banja Luka was

14 the fear from the influx of the Serb population in Banja Luka.

15 Q. How would you describe the atmosphere in Banja Luka from, let's

16 say, March until the end of 1992?

17 A. How shall I describe it to you? It was terrible. There were a

18 lot of refugees around. The whole town was in chaos. The electricity was

19 often cut off. We didn't have enough food, enough medicine, enough

20 water. People kept coming in on a daily basis, people came in, other

21 people left, it was total chaos.

22 Q. And when you say people were coming, which nationality are you

23 referring to, to be more specific?

24 A. To Serbs.

25 Q. And the people who were leaving?

Page 14733

1 A. Non-Serbs.

2 Q. You said it was chaotic, no electricity. What about jobs? Could

3 people work?

4 A. 90 per cent of the companies were not working.

5 Q. Do you know whether there were some dismissals from work?

6 A. There were some, but on the other hand, there was no need to

7 dismiss anyone, because, as I said, 90 per cent of the companies were not

8 working at the time.

9 Q. If someone was dismissed, to your knowledge, what was the reason

10 for dismissal?

11 A. Well, I think it was because many people went to the front line,

12 because they were mobilised, there was no water or electricity, as a

13 result of that, many companies were not operational, so that was the main

14 reason, I think.

15 Q. What mobilisation had to do with dismissals or better say with my

16 question what was the reason for dismissals?

17 A. At the beginning of the war, all three ethnic groups received

18 call-up notes, not only Serbs, but members of all three groups, and of

19 course, if someone responded to the call-up, they couldn't work, but what

20 happened was that if all the Serbs went to the front line, responding to

21 the call-up, then you couldn't have only the non-Serbs working, and the

22 Serbs fighting the non-Serbs, on the confrontation lines.

23 Q. And to your knowledge, are you aware of any non-Serb directors of

24 firms which would be dismissed?

25 A. No, but I can tell you that my sister's husband, who was not a

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Page 14735

1 Serb, responded to the call-up, and he remained the managing director of

2 his company until the end of the war.

3 Q. To your knowledge, were there any checkpoints in Banja Luka?

4 A. There were no checkpoints in Banja Luka. There were only

5 checkpoints at the points of entry and exit from the town, but there were

6 no checkpoints within the town itself.

7 Q. Was any checkpoint in your neighbourhood, in Mejdan?

8 A. Certainly not.

9 Q. To your knowledge, were there any searches, searches of houses or

10 searches on people, in the period of March until December, 1992?

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

12 Q. When people were leaving Banja Luka, were they allowed to take

13 everything with them or were there some limits what they are allowed to

14 take with them?

15 A. There were no limits. They could even organise transport of their

16 furniture to other areas.

17 Q. And what about money? Were they allowed to take unlimited amount

18 of money?

19 A. No. I never had any document limiting the amount of money. I

20 know we were told they couldn't take weapons or military booklets. That's

21 what they couldn't take. Also, cameras and video cameras.

22 Q. I would like to show the witness a document. I showed you this

23 document yesterday. It's P227, and you can use my copy, because it's one

24 page from Official Gazettes. And it was a decision issued on 3rd June,

25 1992 and under Article 3, it says, "Natural persons leaving the Autonomous

Page 14736

1 Region of Krajina may take out a maximum of 300 deutschmarks or

2 corresponding amount in other currencies which may not exceed this limit."

3 A. I have never seen this document before. This document was never

4 delivered to us in the agency, nor did anyone tell us that that's how

5 things should be. People may have known this, they may have read this,

6 but nobody ever asked us how much money they were allowed to take, nor did

7 we have this information.

8 Q. When they -- when people were boarding the buses, were they

9 searched?

10 A. Yes. They were searched. Their belongings were searched so that

11 we would see they were not taking things that were prohibited, that is

12 weapons, their military identity booklet, a camera or a video camera or a

13 video cassette.

14 Q. And to your knowledge, were these people searched during the

15 transport, either to Croatia or to Travnik? Were they searched on the

16 way?

17 A. No, no. I don't know.

18 Q. You never received any information from people who left and

19 returned?

20 A. No.

21 Q. And were these buses escorted?

22 A. Yes. The police did.

23 Q. And back to the situation in Banja Luka in 1992, are you aware of

24 the group of people called red Kombi?

25 A. No.

Page 14737

1 Q. You have never heard about this group?

2 A. Yes. I heard about them but I never saw that van.

3 Q. And what did you heard about them?

4 A. Just that there was this van, they were calling the red van, which

5 was allegedly driving non-Serbs out of Banja Luka. I never saw this, and

6 I never heard from any of my non-Serb friends that they had had any

7 contacts with the red Kombi or the red van.

8 Q. Did you heard that they would be abusing someone on the street?

9 A. No.

10 Q. And did you heard about a group called SOS?

11 A. When I had my first interview, I really didn't know what this SOS

12 meant. Then later it was explained for me that it stood for Serbian

13 defence forces, and that this was the regular army, because of course the

14 JNA had ceased to exist so that the Serb army of the Krajina was called

15 that. They were the Serbian defence forces. Because the JNA was no

16 longer there. So that's what the army was called.

17 JUDGE AGIUS: One moment, Madam Richterova, because you moved on

18 from the red Kombi to something else, and I want to have this clarified,

19 probably the -- you were asked very directly whether you had ever heard

20 any allegations of abuses of citizens in Banja Luka by or related to the

21 existence of this red Kombi or the people who used to be in this red

22 Kombi. Did you ever hear anyone talk about this red Kombi being used by

23 whoever used to run it, abuse citizens in Banja Luka? Or was it just

24 another charitable institution carrying out a charitable work of helping

25 people out of Banja Luka and to somewhere else? What, according to you,

Page 14738

1 from what you heard at the time, what did this red Kombi stand for?

2 Charitable service? Or abuse of citizens?

3 THE WITNESS: [Interpretation] No. I've just said I never saw this

4 van. I don't know if it was really red. Someone would have recognised

5 it. I heard of its existence but I never saw it.

6 JUDGE AGIUS: I will read to you a transcript of the questions

7 that were put to you and your answers during your interview with Mr. Dupas

8 and Madam Korner. Mr. Dupas told you, "We have spoken to several

9 witnesses who described this notorious red Kombi that was driving --

10 driven around Banja Luka in the year 1992 and harassing the non-Serb

11 population. Do you have any information about that?" And you answered:

12 "I also heard that. I also knew about that from stories." And then Mr.

13 Dupas told you, "What were the stories that were going around?" And you

14 said, "All the citizens of Banja Luka knew that, that there was this Kombi

15 that was abusing people in the city." When you say people, he said, Mr.

16 Dupas, you're talking about non-Serbs? And you said, "Also the Serbs who

17 wanted to protect the non-Serbs."

18 THE WITNESS: [Interpretation] Well, as I said, just now, I only

19 heard people talking about this Kombi but I never saw it myself.

20 JUDGE AGIUS: But you heard people talk about this red Kombi

21 positively or negatively?

22 THE WITNESS: [Interpretation] Yes.

23 JUDGE AGIUS: What's "da."

24 THE WITNESS: [Interpretation] Negatively.

25 JUDGE AGIUS: So we got it at last. It's like being in a

Page 14739

1 dentist's clinic now, having to extract one tooth after the other.

2 Yes, Madam Richterova?

3 MS. RICHTEROVA:

4 Q. What was the role of the SOS in Banja Luka?

5 A. I've just told you I didn't know.

6 Q. You said -- you said that people -- there were Serbs coming to

7 Banja Luka, there were convoys of Serbs coming to Banja Luka. Where were

8 they accommodated?

9 A. In the Borik sports hall, the Mejdan sports hall, the Mejdan

10 kindergarten and the primary school.

11 Q. And was there any period of time when these people move into the

12 houses which were abandoned by people, by non-Serb people who left Banja

13 Luka?

14 A. Yes, yes.

15 Q. So when was it approximately?

16 A. I have no idea when. Throughout this time, people searched for

17 empty houses and when they found one, they entered it and settled down in

18 it.

19 Q. And again, I will return to the politicians in Banja Luka, and I

20 would like to ask you if you remember, during the 1991, stating anything

21 negative from the Serb politicians towards non-Serb population in Banja

22 Luka?

23 A. I was never active in politics. I was never interested in

24 politics. I never attended the rallies. I didn't hear what any of them

25 said, because I wasn't there.

Page 14740

1 Q. But you were able to watch television, or at least read

2 newspapers. Neither from these medias you learned anything which we could

3 call negative attitude towards non-Serb population?

4 A. At all these rallies all the leaders depending on the part they

5 represented talked within their own context. Some people said let's start

6 from the Serbs, that the Serbs had to organise themselves, to protect

7 themselves that the Muslims were arming. And then the next day the SDA

8 would turn up on the Krajina square and the SDA leaders would then say

9 that they had knowledge that the Serbs were armed, that they had to

10 organise themselves, that they had to protect themselves. On the third

11 day, the HDZ would turn up and say the same things.

12 Q. I will leave this unless Your Honour will read the witness her

13 testimony given in Banja Luka on the page 36.

14 JUDGE AGIUS: No. The witness is in your hands, Ms. -- Madam

15 Richterova. We won't intervene unless it is really something --

16 MS. RICHTEROVA:

17 Q. Do you recall stating to the questions, can you remember exact

18 words what was his attitude and this question was referring to

19 Mr. Brdjanin, as expressed in his speeches towards the non-Serbs in Banja

20 Luka? Do you recall this question and the answer to this question?

21 A. Yes, I remember being asked this question and I think I replied

22 that -- oh, I don't know exactly what I replied.

23 Q. You replied, "Well, how could I tell you that? Of course it

24 wasn't positive but you know how could I tell you this when I had no

25 contact with this person? I never met him personally."

Page 14741

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Page 14742

1 You said it wasn't positive. Now you say that you have never

2 heard anything. Can you explain to us this inconsistent reply?

3 A. Well, I think it's not inconsistent. When I said negative, it's

4 what I just explained. All three ethnic parties said the same sort of

5 thing, and of course the things Mr. Brdjanin said at pre-electoral rallies

6 was negative for the non-Serbs. By the same token the other parties that

7 spoke at pre-electoral rallies on behalf of the SDA and the HDZ, what they

8 said was negative for the Serbian people. That's what I meant when I said

9 negative.

10 JUDGE AGIUS: Perhaps she could also tell us what the position

11 was, whether it changed in the post electoral -- and that's after the

12 formation of the Autonomous Region of Krajina. We probably are more

13 interested to hear about what happened during that phase rather than in

14 the post election or pre-election phase of the events.

15 MS. RICHTEROVA:

16 Q. I will repeat the question: You discuss this phase, 1991, when

17 there were these rallies of all three parties, but what was the situation

18 after the election and after the takeover? And I'm referring to the year

19 1992. What was his position or what was the SDS position to other nations

20 living in the Autonomous Region of Krajina?

21 A. After the elections, the war broke out.

22 Q. And when the war broke out, does it mean that there were no longer

23 any speeches?

24 A. There were speeches but we were not able to listen to them

25 regularly because we had no electricity.

Page 14743

1 Q. So how would you describe the reason why people were leaving? Was

2 it just because -- because of the -- cause in Banja Luka or what else made

3 them to leave?

4 A. I think they were leaving for the same reasons that the Serbs were

5 arriving in Banja Luka. People feared retaliation. As the Serbs came to

6 Banja Luka, at the same time, the non-Serbs left for other places. They

7 were afraid to stay, but I can't say that any of the politicians made the

8 people move. On any side. I know what people said in the agency. Every

9 non-Serb who was on good terms with me and whom I asked why he was

10 leaving, each and every one of them said I am leaving because I am afraid

11 some of the Serbs who have arrived who have been driven out of their towns

12 will drive me out or kill me. And I want to protect my children and so

13 on. I never heard anyone while working at the agency and I really want to

14 tell you the real truth now, I never heard anyone say that someone in

15 authority was forcing them to leave. At least the people who had contacts

16 with me and who have now returned to Banja Luka and we are in contact

17 again now.

18 Q. Do you recall answering to the question, again it was the very

19 similar questions whether any of these comments could make people to leave

20 the city, it's page 38, and you said, "Definitely, surely not positive

21 since they decided to leave the city." And when Mr. Dupas asked you, do

22 you think that some of the things he said, and the discussion was about

23 Mr. Brdjanin, he said inspired people to leave? And your answer was --

24 was "Yes."

25 So this wasn't true, what you said?

Page 14744

1 A. No, no. That's not how I understood it. I said today that I was

2 very confused when I had my first interview. Not for a moment did I

3 understand that I was to testify here either for or against Mr. Brdjanin.

4 JUDGE AGIUS: You're not testifying for or against anyone here.

5 You're testifying towards the truth. We are in -- we have a common

6 enterprise here. We are searching for the truth. So please do not look

7 at your testimony as being a testimony for or against someone. You have a

8 responsibility here to tell us the truth. And the question that was asked

9 of you by Mr. Dupas in the interview couldn't have confused your mind,

10 because it was a very simple and clear question. He was referring to the

11 interventions of Mr. Brdjanin that you had spoken about earlier on in the

12 course of the interview, and he told you, Mr. Dupas, well, let's talk

13 about some of the things he did, he did speak about. What do you think

14 was the impact of the things that he was saying on the Serb -- on the

15 non-Serb population? And you said, "Definitely, surely not positive,

16 since they decided to leave the city." And Mr. Dupas told you, do you

17 think that some of the things that he said -- do you think that some of

18 the things that he said inspired people to leave? And you said, "Yes."

19 And then what's most important of all, Mr. Dupas told you, did people

20 actually tell you that? And you said, "No." So you made up this

21 conclusion yourself. You reached this conclusion yourself. Not other

22 people telling you that they had been inspired by Mr. Brdjanin to leave.

23 This is the conclusion that you arrived at. Why did you arrive at that

24 conclusion?

25 THE WITNESS: [Interpretation] I don't know. That's not the way I

Page 14745

1 understood it.

2 JUDGE AGIUS: Yes. All right. I think that's enough from me.

3 [Trial Chamber confers]

4 JUDGE AGIUS: And actually, Judge Janu is drawing my attention to

5 another part of your testimony soon after that you had just confirmed to

6 Mr. Dupas that this was your own conclusion that you had arrived at. And

7 then you said, "My personal stance was such that when I looked at him, and

8 while listening to his speeches and the way he, when he, when he was, his

9 appearance, and I was thinking what an idiot you are, I mean I've been

10 living with these people for 50 years or 30 years, I don't know, and

11 you're trying to, you know, to create a conflict between us, you know, so

12 that that was my personal stance, the members of the HDZ and the -- or the

13 SDA were no better. They all said the same thing. I experienced this for

14 me, this was a very, very difficult experience because it was a

15 psychological burden on me."

16 So please, do tell us the truth.

17 THE WITNESS: [Interpretation] I am telling the truth. And I was

18 referring to all three sides, because there was an ethnic war going on

19 there.

20 MS. RICHTEROVA:

21 Q. So you were referring to all three parties, but just non-Serb

22 population was leaving from Banja Luka?

23 A. But the Serb population was coming to Banja Luka.

24 Q. But non-Serb population was leaving Banja Luka because they were

25 afraid of their lives? And we are talking about political parties in

Page 14746

1 Banja Luka. So it wasn't Serb who would leave the Banja Luka because they

2 would be afraid.

3 A. The Serbs were not leaving Banja Luka. They were arriving in

4 Banja Luka.

5 MS. RICHTEROVA: I don't have further questions.

6 JUDGE AGIUS: All right. Thank you, Madam Richterova.

7 Mr. Ackerman?

8 Mr. Ackerman will be putting some questions to you, please.

9 Cross-examined by Mr. Ackerman:

10 Q. Good morning, madam, how are you this morning?

11 A. Pretty good, thank you.

12 (Redacted)

13 (Redacted)

14 (Redacted)

15 (Redacted)

16 (Redacted)

17 (Redacted)

18 (Redacted)

19 (Redacted)

20 MR. ACKERMAN: Private session, please.

21 JUDGE AGIUS: All right. We go into private session.

22 [Private session]

23 (Redacted)

24 (Redacted)

25 (Redacted)

Page 14747

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Page 14749

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Page 14751

1 (Redacted)

2 (Redacted)

3 [Open session]

4 MR. ACKERMAN:

5 Q. I'm a bit confused, ma'am, because when you spoke with the

6 Prosecutor in Banja Luka, about this agency, you indicated at that time

7 that you did not believe that the agency got involved with assisting

8 non-Serb persons to leave Banja Luka until October of 1992. I think what

9 you said, it didn't begin doing that kind of work until it had become

10 officially registered, which actually happened in October. Is that your

11 recollection or were you confused at that time? Did it start a bit

12 earlier? What's the best you can tell us regarding that now?

13 A. No. In my work booklet, the copy of which I provided to the

14 Office of the Prosecutor, it says, in accordance with our law, the work

15 experience is mentioned there, in order not to have any interruptions, any

16 breaks in service, when my company ceased working, I paid adequate

17 contributions into the fund and I wanted to link my work experience in the

18 company with my work in the agency, and hence the stamp, which was a bit

19 confusing perhaps in the beginning. I must say that I was confused when I

20 was summoned to the interview and I needed sometime to refresh my memory.

21 So when I stopped working in December, I started paying appropriate

22 contribution in the pension fund so that I could have entire pension when

23 (Redacted)

24 (Redacted)

25 (Redacted)

Page 14752

1 (Redacted)

2 MR. ACKERMAN: I think must --

3 JUDGE AGIUS: One moment, Mr. Ackerman, we need to redact the --

4 in line 22, and in line 24, the two names that appear there. I need not

5 mention them here because then I would have to redact what I am saying

6 too. Page 58, lines 22 and 24. Yes, go ahead, Mr. Ackerman.

7 MR. ACKERMAN:

8 Q. The part I was actually confused about, ma'am, was when the agency

9 began assisting non-Serbs who were wanting to leave the Banja Luka area

10 and you had said during this interview in Banja Luka that you believed

11 that was October of 1992 but then today you told us that it could have

12 been as early as August of 1992, and I'm just wondering, giving this your

13 best recollection, which of those you think it was.

14 A. I think it was August. I was a bit confused by the stamp for

15 October in that work booklet and that's why I mentioned October.

16 Q. That's fine. Thank you.

17 Now, you told us about the fares that people were paying, they

18 were paying somewhere between 30 and 50 deutschmarks for their bus fares,

19 you told us, is that correct?

20 A. Yes.

21 Q. I want you --

22 A. I don't remember the exact price.

23 Q. Yeah. I would like the Registrar to give you three documents.

24 They are the three Y001 documents, 8259, 8261, 8263. I'd like you to

25 have all those available to look at for a moment.

Page 14753

1 The first one I'd like you to look at, ma'am, is a document I

2 think it's 8262, 8263, it's a payroll for July of 1992. Do you find

3 that?

4 A. Yes.

5 Q. And that document contains your name and shows that you were paid

6 a net amount of 20.000 dinars, correct?

7 A. Yes.

8 Q. Can you -- first thing I want to ask you is: Can you give us any

9 kind of an approximation as to about how many deutschmarks 20.000 dinars

10 would have been in July of 1992?

11 A. I really cannot recall what the rate was, but I think it was less

12 than 100 deutschmarks.

13 Q. If you look at the bottom of that document, because one of the

14 concerns is why is this July of 1992, when the company didn't start until

15 later, if you look at the bottom, you'll notice, don't you, that the

16 document is actually dated 30 September, 1992. You see that?

17 A. Yes.

18 Q. Is it possible that the date, July, 1992, was a mistake on this

19 document? And that it actually should have been an August or September

20 date?

21 A. It could have been a mistake, but it's also possible that at the

22 time we did not have enough money so we didn't pay the salaries until

23 September when they were paid retroactively. These are the two

24 possibilities.

25 Q. All right.

Page 14754

1 MR. ACKERMAN: Your Honour, I don't know if the Prosecution

2 intends to make this document an exhibit.

3 MS. RICHTEROVA: Yes, I apologise. I forgot to tender all these

4 three documents.

5 JUDGE AGIUS: Yes, you will both do that at the end of the

6 witness's testimony, okay?

7 MR. ACKERMAN: It's going to be very confusing for someone trying

8 to find out in the transcript what it is we are talking about, because for

9 instance the document I have doesn't have any of these Y numbers that the

10 Prosecution has put on them. And I don't know if the document --

11 JUDGE AGIUS: So Mr. Ackerman is right here. Perhaps you can tell

12 us straight away, Madam Richterova, this last document that we are talking

13 about, the payroll for July, with Y001-8263, and then BD0657E, what

14 exhibit number you intend giving it?

15 MS. RICHTEROVA: It would be P1687. And it would be under seal.

16 JUDGE AGIUS: Yes. So be it.

17 And the other one, the December?

18 MS. RICHTEROVA: The payroll for December, Y001-8259, would be

19 1688.

20 JUDGE AGIUS: And also under seal?

21 MS. RICHTEROVA: Under seal.

22 And the Y001-8261 would be 1689.

23 JUDGE AGIUS: And also under seal?

24 MS. RICHTEROVA: Under seal.

25 JUDGE AGIUS: All right.

Page 14755

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Page 14756

1 MR. ACKERMAN: Thank you.

2 Q. Now, ma'am, while we are looking at those documents, the other one

3 that you've not looked at yet is now called P1689, you'll find I think on

4 that document the number BD0656. And that is a document called an

5 authorisation. It has to do with authorising certain persons to travel to

6 Croatia, and although that document contains a heading, "Autonomous Region

7 of Krajina, Banja Luka" it's actually signed, is it not, by Milos

8 Bojinovic, the director of the agency?

9 A. Yes.

10 Q. Okay. These fares that people were paying, this 30 to 50

11 deutschmark fares that people were paying for their bus fares, would you

12 say these were normal bus fares for -- that people would be required to

13 pay for the kind of transportation they were receiving or were they kind

14 of outrageously high numbers?

15 A. Not outrageously high numbers. It is true that we paid a lot of

16 money for the transport. The oil was four German marks at the time so I

17 don't think that the price was too high. But I wasn't the one who

18 established the price, and I don't remember exactly what it was, between

19 30 and 50 German marks.

20 Q. You talked to a lot of these people. Did any of them complain

21 that the bus fares were way too high or anything like that?

22 A. No.

23 Q. And these people, to the extent that you spoke with them and

24 understood what they were doing, these were people who were wanting to

25 leave Banja Luka, weren't they?

Page 14757

1 A. Yes.

2 Q. They were trying very hard to get their names on the lists of

3 those that were permitted to leave?

4 A. Yes.

5 Q. And I think you have told us that there were several reasons that

6 they wanted to leave, primary among them was their fear of retaliation

7 from the Serbs who were coming in to the city from other places, correct?

8 A. Yes.

9 Q. And these Serbs who were coming into the city from other places,

10 from other parts of Bosnia and from Croatia, were people that -- that had

11 been basically thrown out of their homes and made to become refugees and

12 came to Banja Luka as a safe place; is that correct?

13 A. That's what they told us when they came to the agency.

14 Q. And they came there with an attitude, they came there angry, for

15 what had happened to them, didn't they?

16 A. Yes.

17 Q. And so the fear of the non-Serb population of Banja Luka regarding

18 the possibility of retaliation, was not an unwarranted fear, was it?

19 A. Yes.

20 Q. The other reasons that people were wanting to leave was Banja Luka

21 was a place that had very little food and that had no electricity much of

22 the time?

23 A. Yes.

24 Q. This whole business of people going to the SUP to cancel their

25 residence, that was the law of former Yugoslavia, wasn't it? If you were

Page 14758

1 going to move from one place to another, you had to go to the SUP and tell

2 them you were moving, cancel your residence in the place, in that place,

3 so you could take up residence in a new place? You had to do that,

4 everybody, right?

5 A. Yes.

6 Q. And that went on way before there was any multiple parties or war

7 or anything of this -- these things?

8 A. Yes, yes. Before the war as well.

9 Q. Were any of the non-Serb people who travelled through the

10 assistance of your agency ever required to sign over any of their property

11 to the government before they could leave?

12 A. No.

13 Q. And you've told us that all the people who wanted to leave, a

14 condition of their being able to leave, was that if they were going to a

15 third country, if they were going to some place like Germany or Spain or

16 France, that they had to have a letter of guarantee from these places

17 saying that they would be permitted to enter these countries once they

18 arrived there, correct?

19 A. Yes. It applied also to those who wanted to go to Croatia. They

20 also had to have a letter of guarantee.

21 Q. Yes. Now, when you went to -- when you went to the border with

22 Croatia to exchange documents, these guarantees, wasn't that a two-way

23 exchange? Didn't you also furnish guarantees to the Croatian government

24 regarding Serbian people who were coming to Banja Luka? Or was it just a

25 one-way thing?

Page 14759

1 A. No, no. We only received letters of guarantee for non-Serb

2 population who wanted to leave Banja Luka.

3 Q. Now, when these people would be accepted, put on the list, and

4 come and get on the bus, from your observations, nobody took from them any

5 jewellery or any valuables or anything like that? Nobody stole these

6 things from their luggage, to your knowledge, correct?

7 A. No, no. No convoy left without passengers having been escorted by

8 the members of their families who for whatever reasons were still there,

9 were not leaving yet because they had not sold all their furniture or were

10 still waiting for the letter of guarantee or were not able to collect all

11 the necessary documents. They were there to say goodbye to their mothers

12 and friends, and it was all happening there and we could see it.

13 Q. So just to get a sort of mental picture of the scene, it begins

14 with a list being posted on your office of the people who had been

15 authorised for the next transport? Then there is a date and a time, the

16 buses are there, the people come with all of their belongings that they

17 want to bring with them, correct?

18 A. Correct.

19 Q. And with them are relatives and friends there to see them off, and

20 kiss them goodbye and things of that nature?

21 A. A day or two before that, we were required to put those lists on a

22 board so that the people could find their names, together with the date of

23 departure. The buses would usually depart early in the morning, around

24 7.00 or 8.00 and the people would come to the agency with their luggage,

25 board the buses, say goodbye to their friends and relatives and leave.

Page 14760

1 Q. And you're there, you're observing what's going on at this time?

2 A. Yes.

3 Q. [Previous translation continues] ... these other non-Serb people

4 are there observing what's going on there at the time, who are not going

5 on the transport?

6 A. Yes.

7 Q. And the only searches that took place that you observed or that

8 you knew about were searches for prohibited items like weapons, cameras,

9 military identifications, things of that nature?

10 A. Yes.

11 Q. And as you told the Prosecutor during your interview in Banja

12 Luka, you can say with full responsibility that everything was done

13 correctly, can't you?

14 A. Yes.

15 Q. Mr. Brdjanin never appeared at your agency, did he?

16 A. No.

17 Q. And you don't personally know him, do you?

18 A. No.

19 Q. At the time you had heard of him? Right?

20 A. Yes.

21 Q. And you saw him on television in 1991?

22 A. Yes.

23 Q. But today, you can't remember any specific thing that you heard

24 him say on television, can you?

25 A. No.

Page 14761

1 Q. Do you recall, as you told the Prosecutor during your interview in

2 Banja Luka, that you also heard SDA leaders on television at the same time

3 urging Muslims to arm themselves against the Serbs. Do you remember

4 hearing speeches like that?

5 A. Yes.

6 Q. And if you know, these speeches that you heard, made by

7 Mr. Brdjanin or by these SDA leaders or even maybe some HDZ people, these

8 speeches all occurred in 1991, early 1992, before there was ever any

9 Crisis Staff in existence in Banja Luka, didn't they?

10 THE INTERPRETER: We didn't hear the answer.

11 JUDGE AGIUS: She said "da."

12 MR. ACKERMAN:

13 Q. You answered yes to that last question, didn't you, ma'am?

14 A. Yes.

15 MR. ACKERMAN: This might be a good time, Your Honour.

16 JUDGE AGIUS: Yes. I was going to suggest to you to look at the

17 clock. How much longer do you think -- do you envisage you will take,

18 Mr. Ackerman?

19 MR. ACKERMAN: It looks to me like 20 minutes, Your Honour.

20 JUDGE AGIUS: 20 minutes. Okay. So -- no, because we definitely

21 have to stop at half past 1.00 because there is a 65 ter meeting in

22 another case that I have to be present at. You have re-examination?

23 MS. RICHTEROVA: No, but, Your Honour, the witness asked me that

24 she definitely needs to leave The Hague.

25 JUDGE AGIUS: Yes, I'm trying to make sure that she will be able

Page 14762

1 to leave, in fact. Can we shorten the break to 15 minutes?

2 MR. ACKERMAN: Your Honour I'm quite certain I won't be more than

3 20 minutes.

4 JUDGE AGIUS: But if there is re-examination plus some questions

5 from the bench, is it okay with you, 15 minutes? All right?

6 THE WITNESS: [Interpretation] If we need more time, we can go on

7 without a break, I'm doing fine.

8 MS. RICHTEROVA: It's for the interpreters.

9 JUDGE AGIUS: 15 minutes' break, 15 minutes' break. Thank you.

10 --- Recess taken at 12.30 p.m.

11 --- On resuming at 12.49 p.m.

12 JUDGE AGIUS: Yes, Mr. Ackerman?

13 MR. ACKERMAN:

14 Q. Ma'am, could you tell us who you remember as being the political

15 leaders in Banja Luka during 1992? What names do you remember?

16 A. All three ethnic groups?

17 Q. No, let's --

18 JUDGE AGIUS: Or what was left of them.

19 MR. ACKERMAN:

20 Q. Yes. The political leaders that you can remember, what were their

21 names?

22 JUDGE AGIUS: 1992, we want to know, not 1991.

23 THE WITNESS: [Interpretation] Mr. Brdjanin, Mr. Kupresanin,

24 Mr. Radic, Mr. Lutovic. He was the President of the SDA, I think. I

25 can't remember many of them. There was Mr. Krzic, I think that's what his

Page 14763

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Page 14764

1 name was. But I can't recall any other names now.

2 MR. ACKERMAN:

3 Q. You mentioned Mr. Kupresanin. Do you have any recollection of

4 what position he held?

5 A. No.

6 Q. What about Mr. Radic?

7 A. Mr. Radic was the mayor of the municipality, I think.

8 Q. You had mentioned during your direct examination that during the

9 time when the Red Cross was handling these transfers of people who were

10 leaving Banja Luka, that you had many school friends and colleagues who

11 left during that time, correct?

12 A. Yes.

13 Q. And these were people who you talked to, people who you said

14 goodbye to, people who you knew at that time?

15 A. Yes.

16 Q. To your knowledge, were these people leaving voluntarily? Were

17 they people who were leaving because they wanted to leave or did they tell

18 you they were being forced to leave?

19 A. No. No one told me that they had been forced to leave.

20 Q. Do you ever recall at any time hearing Mr. Brdjanin make any

21 speeches against war profiteers and against paramilitary organisations, or

22 either one?

23 A. Would you repeat your question, please?

24 Q. Do you recall at any time hearing Mr. Brdjanin make any speeches

25 where he was being critical, war he was against war profiteers or

Page 14765

1 paramilitary organisations? Do you recall him saying anything like that

2 in any of his speeches?

3 A. I almost never heard any speech of Mr. Brdjanin's.

4 Q. So the answer is you never heard him saying anything like what I

5 just suggested? And I take it that you also never heard him saying that

6 everything had to be done according to the law?

7 A. No.

8 Q. Did you ever hear from any of your non-Serb friends, either at the

9 time or since they have returned to Banja Luka, that Mr. Brdjanin had

10 actually helped them in some way?

11 A. No. I really have to tell you quite truthfully, none of them ever

12 mentioned Mr. Brdjanin to me.

13 MR. ACKERMAN: Okay. Let's go to private session for just a

14 moment, please?

15 JUDGE AGIUS: Yes, let's go into private session for a while.

16 Thank you.

17 [Private session]

18 (Redacted)

19 (Redacted)

20 (Redacted)

21 (Redacted)

22 (Redacted)

23 (Redacted)

24 (Redacted)

25 (Redacted)

Page 14766

1 (Redacted)

2 (Redacted)

3 (Redacted)

4 (Redacted)

5 (Redacted)

6 (Redacted)

7 [Open session]

8 JUDGE AGIUS: We are in open session now, Mr. Ackerman.

9 MR. ACKERMAN:

10 Q. I think during your interview with the Prosecutor, you were

11 talking about how people were afraid of retaliation and this needs to be

12 in private session again, Your Honour?

13 JUDGE AGIUS: Let's go to private session, Mr. Ackerman.

14 [Private session]

15 (Redacted)

16 (Redacted)

17 (Redacted)

18 (Redacted)

19 (Redacted)

20 (Redacted)

21 (Redacted)

22 (Redacted)

23 (Redacted)

24 [Open session]

25 JUDGE AGIUS: Thank you, we are in open session, Mr. Ackerman.

Page 14767

1 MR. ACKERMAN:

2 Q. You said with regard to that period in 1995, that it was a time

3 when many, many non-Serbs left the town. Is that correct?

4 A. Yes.

5 Q. The way you explained it was because -- let me give your full

6 answer. "People were afraid of retaliation, just like Serbs were afraid

7 of retaliation in Sarajevo, so were the Muslims afraid of retaliation

8 here. I will now tell you a story of a friend of mine who was a good

9 acquaintance of mine," and I won't say her name and I'll skip over that

10 part, "she left Banja Luka in 1995, when Krajina fell. When all those

11 people came to Banja Luka, this was the time when many, many non-Serbs

12 left town." And when you say when all those people came to Banja Luka,

13 you're referring, are you not, to a large number of Serb refugees who

14 arrived in 1995?

15 A. Yes.

16 Q. You went on to say, "Because when those people came, they

17 naturally kicked the Muslims out, they chased them out from here without

18 anyone's asking them to do so. And she told me, I want to leave here for

19 one and only reason because I don't want a Serb who had been expelled from

20 Glamoc or God knows where else from to come here to my door and to kick me

21 out of my apartment because he was kicked out of his over there, and I

22 don't want to start hating my Serbian friends because of it."

23 Correct?

24 A. Yes.

25 Q. In 1992, you described conditions in Banja Luka as being horrible

Page 14768

1 for all nationalities. You said there were periods of 45 days without

2 electricity, and that there was a curfew that applied to everyone,

3 correct?

4 A. Yes.

5 Q. So if someone were to describe Banja Luka in 1992 as a ghetto for

6 non-Serbs, I take it you would not agree with that but that it was

7 difficult for everyone just the same?

8 A. Yes.

9 Q. In your interview with the Prosecutor, you said that there were no

10 barricades set up in Banja Luka in April, 1992, by anyone, including an

11 organisation they referred to called SOS. And that's correct, isn't it?

12 A. That's correct. There were no barricades in the town.

13 Could the interpreter speak up? I don't hear very well, please.

14 JUDGE AGIUS: Yes. Usher, could you please move the microphones

15 nearer to the speaker, to the witness?

16 MR. ACKERMAN: I think it's that she is not hearing, not that they

17 are not hearing her.

18 JUDGE AGIUS: Oh, she's not hearing?

19 MR. ACKERMAN: She's not hearing well, I think that's correct.

20 THE WITNESS: [Interpretation] Yes, yes, that's correct, I don't

21 hear very well, could it just be a little louder please.

22 JUDGE AGIUS: Then could you adjust the volume on her -- is it

23 better now?

24 THE WITNESS: [Interpretation] Excellent.

25 JUDGE AGIUS: Okay. Thank you.

Page 14769

1 MR. ACKERMAN: All right.

2 Q. And you said during that interview that one of the reasons you

3 knew that there were no barricades in April of 1992 or during that time

4 was that you yourself were able to move around freely and to have coffee

5 with your non-Serb friends, that you went to visit them and they came to

6 visit you.

7 A. We could all move about, regardless of our ethnicity because there

8 were really no barricades in the town itself. There were checkpoints at

9 the exit and entry points but within the town, everybody moved around

10 freely, both Serbs and non-Serbs.

11 MR. ACKERMAN: Can we go to private session again, Your Honour?

12 JUDGE AGIUS: Yes, let's go to private session for a while,

13 please.

14 [Private session]

15 (Redacted)

16 (Redacted)

17 (Redacted)

18 (Redacted)

19 (Redacted)

20 (Redacted)

21 (Redacted)

22 (Redacted)

23 (Redacted)

24 (Redacted)

25 [Open session]

Page 14770

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Page 14771

1 JUDGE AGIUS: We are in open session, Mr. Ackerman.

2 MR. ACKERMAN:

3 Q. Of the transports, the buses that were taking non-Serb people out

4 of Banja Luka, to your knowledge, the army was not involved in any of

5 these convoys, was it?

6 A. No, only the civilian police.

7 Q. At the agency, there were, in addition to the non-Serb people who

8 were showing up trying to get permission to leave, and get on the lists,

9 at the same time there were Serb refugees who were showing up at the

10 agency also, weren't there?

11 A. Yes.

12 Q. And you said that there were even some confrontations that went on

13 at your agency between the Serbs who had been kicked out of the places

14 where they lived, and those non-Serbs who were trying to leave Banja Luka,

15 correct?

16 A. To a lesser extent. Because we had the police who were in charge

17 of law and order, so fights rarely broke out. There were only verbal

18 abuses.

19 Q. And the police were there trying to reduce the tensions between

20 these people? To prevent any outbreaks of serious matters? In other

21 words, they were trying to reduce and calm tensions, not to create

22 tensions, weren't they?

23 A. The police was there so that any conflict could -- would be

24 avoided.

25 Q. I'd like you to look, please, at the document P238. I believe

Page 14772

1 that's the number. Yeah.

2 Ma'am, at the bottom of that document, there is some handwriting.

3 I'm wondering if you can read that, if you can read what it says in that

4 handwriting there. Because the translation we have has left out some of

5 that. Maybe you can read it better than our translators could. Do you

6 see what I'm referring to?

7 A. No. I don't think I can read this.

8 Q. I think the first line, according to the translation I have, says

9 the conclusion under 2 is binding on the secretary for OU. Would you have

10 any idea what OU stands for?

11 A. No.

12 Q. Is your copy good enough so that you can see that it is signed za

13 and then there is a signature there, that it does not have the signature

14 of Mr. Brdjanin?

15 A. I don't know what the signature of Mr. Brdjanin looks like, but I

16 do see the word "za".

17 Q. Okay. In your interview with the Prosecutor, on page 45 --

18 JUDGE AGIUS: Yes, Mr. Ackerman, where is the za that you are

19 specifically referring to on this handwritten part of the document? Is it

20 the za at the left of the initials OU or is it some other za, elsewhere,

21 that you're seeing elsewhere?

22 MR. ACKERMAN: Your Honour, if you look at that first line, and

23 count three words in from the right, you'll see OU, you'll see za, and

24 then you'll see another word. Right underneath that word, you can see a

25 za.

Page 14773

1 JUDGE AGIUS: All right. Okay.

2 MR. ACKERMAN: It's very faint.

3 JUDGE AGIUS: Okay. All right. Thank you. Yes, go ahead,

4 please.

5 MR. ACKERMAN:

6 Q. On page 45 of your interview with the Prosecutor, you were asked

7 the following question by Ms. Korner: "What do you feel about the work

8 that you did for that agency?" And your answer was this: "I think I

9 helped a great many people. Many of them called me and they likened" - I

10 think it should be likened - "and they likened me to Mother Teresa." It's

11 true, isn't it, that a number of people were very grateful to you for your

12 help in helping them leave that situation they found themselves in in

13 Banja Luka?

14 A. Yes.

15 Q. And even today, many of the non-Serb people who you helped leave

16 Banja Luka are grateful to you, aren't they?

17 A. Yes.

18 Q. Some of them have returned and you've talked to them since their

19 return, haven't you?

20 A. Yes.

21 Q. Now, just so this whole issue is very clear, this -- this

22 situation that caused the creation of this agency all started with Serb

23 refugees coming to Banja Luka who had been forcibly expelled from their

24 homes in Croatia and elsewhere in Bosnia, didn't it?

25 A. Yes.

Page 14774

1 Q. It was only then, when these Serb refugees started coming there in

2 large numbers and becoming a retaliation threat to the non-Serb population

3 in Banja Luka, that that non-Serb population started wanting to leave

4 there?

5 A. Yes.

6 Q. And they did so willingly and voluntarily because they wanted to

7 leave a place where they were afraid, where they did not have work, where

8 food was scarce, and where there was often no electricity, correct?

9 A. What people do you have in mind? What population are you

10 referring to?

11 Q. I'm talking about the non-Serb people. They decided to leave

12 Banja Luka, a place where they were afraid --

13 A. Yes, yes.

14 Q. Did not have work, where food was scarce and where there was no

15 electricity?

16 A. Yes.

17 Q. And you helped them to do that, and for that they were and are

18 grateful?

19 A. Yes.

20 Q. And in fact, the fears they had about this retaliation, about

21 Serbs coming there angry and starting to kick people out of their homes

22 actually started happening in 1995 when the Krajina fell, didn't it?

23 A. Yes. Both in 1992 and 1995, in these two years, many people,

24 Serbs, came to Banja Luka.

25 MR. ACKERMAN: Ma'am, that's all I have. Thank you very much.

Page 14775

1 JUDGE AGIUS: Thank you, Mr. Ackerman. Is there re-examination?

2 MS. RICHTEROVA: Just very short re-examination.

3 JUDGE AGIUS: Yes, go ahead.

4 Re-examined by Ms. Richterova:

5 Q. You mentioned this non-Serb who remained as director of one

6 company because he responds -- responded to the mobilisation. Do you

7 remember this question and your answer?

8 JUDGE AGIUS: Yes, let's go into private session a bit, Madam

9 Richterova.

10 [Private session]

11 (Redacted)

12 (Redacted)

13 (Redacted)

14 (Redacted)

15 (Redacted)

16 (Redacted)

17 (Redacted)

18 (Redacted)

19 (Redacted)

20 (Redacted)

21 (Redacted)

22 (Redacted)

23 (Redacted)

24 (Redacted)

25 (Redacted)

Page 14776

1 (Redacted)

2 (Redacted)

3 (Redacted)

4 (Redacted)

5 (Redacted)

6 (Redacted)

7 (Redacted)

8 (Redacted)

9 (Redacted)

10 (Redacted)

11 (Redacted)

12 (Redacted)

13 [Open session]

14 JUDGE AGIUS: Yes, repeat your question, please, Madam

15 Richterova.

16 MS. RICHTEROVA:

17 Q. It was your answer to Mr. Ackerman's question and you said they

18 wanted, non-Serbs, to leave because there was not enough food, there was

19 no electricity. Was there no food and no electricity just for non-Serbs

20 or for all Banja Luka population?

21 A. The entire population.

22 Q. And you also stated that no one told you that they were forced to

23 leave, that they were leaving voluntarily, they were leaving voluntarily

24 because they were afraid?

25 A. Yes.

Page 14777

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Page 14778

1 Q. All these people were your -- I'm sorry, not all -- but you stated

2 that many of them were your friends and they were leaving the place where

3 they lived for many, many years. Did you hear from them any specific

4 reason why they were leaving, what made them to leave?

5 JUDGE AGIUS: Yes, Mr. Ackerman?

6 MR. ACKERMAN: Your Honour I think this is beyond appropriate

7 redirect. She asked the same question in her direct examination.

8 JUDGE AGIUS: I think Mr. Ackerman is correct, and his objection

9 is being sustained. You did actually ask the question during your

10 examination-in-chief, and he asked the same question. So -- and we have

11 had a reply and answer from the witness. So move to the --

12 MS. RICHTEROVA: I do not have any further questions.

13 JUDGE AGIUS: Thank you. Judge Janu do you have any questions?

14 Questioned by the Court:

15 JUDGE JANU: Madam, can you clarify for the Chamber why did you

16 leave the agency for movement of the population? What were your reasons?

17 A. I've already said that. I lost five members of my family, and I

18 was psychologically unstable. I went through a terrible crisis, and of

19 course, many of my friends had left Banja Luka, many of my relatives had

20 arrived in Banja Luka, but they had not been accommodated anywhere and all

21 this was a cause of great stress, so I left the agency for health reasons.

22 JUDGE JANU: So from December, you didn't work at all? You were

23 just at home and you were not feeling well? Is that the truth? Or you

24 changed for another job?

25 A. No. I didn't take another job.

Page 14779

1 JUDGE JANU: And your husband, your husband left the agency as

2 well with you or he stayed and worked there, carry on working there?

3 A. My husband left before I did because he had been mobilised.

4 JUDGE JANU: Can you please describe your working day in the -- in

5 the agency, especially what you were doing when being there, your husband,

6 what was your husband doing, and the president of the agency?

7 A. My working day was like this: I would arrive there, receive the

8 people who came, make lists.

9 JUDGE JANU: 9.00 or 8.00 or we are only talking about the working

10 days?

11 A. 8.00, we started at 8.00, we started at 8.00, from 8.00 to 3.00.

12 We received people coming in, of both ethnic groups, and two girls and I

13 drew up lists. One day we would make a list or I would make a list of

14 non-Serbs. The next day of Serbs. Depending on what was given to me on a

15 particular morning to do.

16 JUDGE JANU: And the president was every morning assigning people

17 to certain work or was it day by day the same routine?

18 A. Yes. Sometimes he assigned specific tasks to us. If there was a

19 crowd at one desk, he would ask one of us to go and help out there. If

20 there were fewer people --

21 JUDGE JANU: So how many desks there were operating

22 simultaneously, receiving people, checking on the papers?

23 A. There were three girls receiving people, two working. There was

24 legal advice, where there was a girl receiving people, and then taking

25 them to the lawyer for consultations. There was another person who took

Page 14780

1 care of the financial side. My husband was a driver because our car was

2 put at the disposal of that agency, and he went with Mr. -- what's his

3 name, to take those lists.

4 JUDGE JANU: And the president was at the same office with you

5 organising through the day, the daily routine work?

6 A. Yes, he had his own office. He would come and see what we were

7 doing, check on our work, contact people, just as we did. He talked to

8 people also.

9 JUDGE JANU: And you said three girls were gathering, compiling

10 those papers. You were one of those girls or you were most senior

11 officially in the office?

12 A. Yes, yes. I was one of them. I didn't have any powers greater

13 than the others. We all did everything.

14 JUDGE JANU: Did you sometimes accompany the convoy with the

15 people as an administrative body or you never accompanied a convoy to the

16 border? I mean non-Muslim people, that's clear.

17 A. Not as a representative of some sort of administrative body. I

18 did go a few times but that was only if a friend of mine was in the convoy

19 and I wanted to see them off at the border, so I did accompany convoys to

20 the border occasionally but not in an official capacity.

21 JUDGE JANU: So how many times, can you estimate? I know you

22 don't remember exactly, but how many times did you go with the convoy?

23 A. Maybe three or four times, three, I think. I can't be sure.

24 JUDGE JANU: That's okay. And in these three cases, nobody was

25 looted during the way or the convoy didn't stop for these purposes?

Page 14781

1 A. No. The convoy was never stopped. I don't know if other convoys

2 were stopped but the bus that I was on, I'm sure, wasn't stopped.

3 JUDGE JANU: That's what I want from you, just witness what you

4 really saw or heard. Do you recall when the Crisis Staff was established?

5 I don't want to know exact date but approximately, which year, and it was

6 the beginning or the middle of the year or -- you cannot help us on this?

7 A. No, no, I can't.

8 JUDGE JANU: You said that many people returned in Banja Luka.

9 Can you give us some names, especially of those who came back to you and

10 thanked you for what you have done for them during the war?

11 A. Quite a few people have come back.

12 JUDGE JANU: How many?

13 A. In percentages, I think 70, I'm sure. I think 70 per cent.

14 JUDGE JANU: 70 per cent of the number of people who left before?

15 A. Of the number of people whom I know, who are friends of mine. I

16 want to say not everybody has come back but most of them have. Those who

17 have gone to America -- but I'm talking about non-Serbs whom I consider my

18 friends, those who went to America have not come back but those who went

19 to European have almost all come back.

20 JUDGE JANU: And what is the number we are talking, we are

21 discussing, your friends? You said 70 per cent, so there you must have

22 some number on your mind.

23 A. I don't know. A lot of non-Serbs have come back to Banja Luka but

24 I could say that I had many acquaintances, not all were close friends, but

25 of about 100, 70 have come back.

Page 14782

1 JUDGE AGIUS: Give us a rough guess.

2 JUDGE JANU: A rough number, I know you can't remember exactly.

3 JUDGE AGIUS: Are we talking 100, 200, 1.000?

4 JUDGE JANU: Or 50 or 20?

5 A. You mean the total number who left and have now come back?

6 JUDGE JANU: People, your friends, people who you know. My

7 question was how many. You limit it to your friends, and you said 70 per

8 cent. So I would like to know what we are discussing, what number we are

9 discussing, and I would like to know from those, to give me the names who

10 came to you and thanked you for what you have done during the war for

11 those people, for those friends of yours.

12 A. Well, I've just said, I knew about 100 people and 70 per cent of

13 them have come back to the town. We meet every day. We run into each

14 other in the street, in the town.

15 JUDGE JANU: Okay. And so the names who came to you? I think you

16 remember at least some of the names.

17 A. Well, yes. The Osmancevic family, for instance. Eglerovic,

18 Pasalic, I won't go any further.

19 JUDGE JANU: Okay. Madam, do you know -- do you know a person --

20 I don't know if we shouldn't go to private session.

21 JUDGE AGIUS: We go into private session.

22 [Private session]

23 (Redacted)

24 (Redacted)

25 (Redacted)

Page 14783

1 (Redacted)

2 (Redacted)

3 (Redacted)

4 (Redacted)

5 (Redacted)

6 (Redacted)

7 (Redacted)

8 (Redacted)

9 (Redacted)

10 (Redacted)

11 (Redacted)

12 (Redacted)

13 (Redacted)

14 (Redacted)

15 (Redacted)

16 (Redacted)

17 (Redacted)

18 (Redacted)

19 [Open session]

20 THE WITNESS: [Interpretation] On one occasion, I did this on my

21 own free will, but I have to mention names now.

22 JUDGE JANU: You don't want to mention the names or you don't

23 remember?

24 A. I do remember. I don't want to mention them in public.

25 JUDGE JANU: M'hm.

Page 14784

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Page 14785

1 A. I want to say if we can go into private session, I will tell you.

2 JUDGE AGIUS: Yes, let's go into private session.

3 [Private session]

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20 [Open session]

21 JUDGE JANU: My last question is, I'm sorry, but I must ask this

22 question. I don't want to offend you. Did you ask for this one single

23 case when did you -- when you didn't put the person on the list? Did you

24 ask some extra money for this?

25 A. No.

Page 14786

1 JUDGE JANU: Thank you.

2 JUDGE AGIUS: Yes. Judge Taya has got a few questions for you

3 too.

4 JUDGE TAYA: I have only a few questions. All the members in the

5 agency except you were Serb refugees; is that right?

6 A. Yes.

7 JUDGE TAYA: In the summer of 1992, not only refugees but also

8 resident in Banja Luka, couldn't work because 90 per cent of business

9 didn't function at that time; is that right?

10 A. Yes.

11 JUDGE TAYA: So everybody wanted to find job; is that right?

12 A. Yes.

13 JUDGE TAYA: Why all employees except you were Serb refugees? In

14 other words, do you know the reason why other employees than you became to

15 be employed in the agency?

16 A. The other employees were refugees because it was on the initiative

17 of refugees that the agency was set up in the first place.

18 JUDGE TAYA: Yes. Mr. Milos Bojinovic was also a refugee?

19 A. Yes, he was.

20 JUDGE TAYA: Other employees from -- other employees than you, did

21 they make their employment contract with the director, Mr. Milos

22 Bojinovic?

23 A. It wasn't Mr. Bojinovic that we concluded a contract with. He was

24 an employee of the agency like the rest of us.

25 JUDGE TAYA: Then with whom you and other employees made a

Page 14787

1 contract?

2 A. Well, when we registered, when the agency was registered at the

3 court and the municipality, we were automatically registered with the

4 pension fund and the health insurance. That was the system that we had at

5 the time.

6 JUDGE TAYA: My last question is: Who fixed -- who established

7 the amount of money which should be paid by non-Serbs who are leaving?

8 A. To tell you the truth, I don't know. I can't remember exactly,

9 but I think that the director and the man in charge of the financial

10 aspect, but I really can't remember.

11 JUDGE TAYA: Thank you.

12 JUDGE AGIUS: Yes. And before you leave, I have got a very few

13 questions for you. Your husband, you've told us very little about your

14 husband, madam. You said you didn't know Mr. Brdjanin, you had never met

15 Mr. Brdjanin. Did your husband know Mr. Brdjanin?

16 A. No.

17 JUDGE AGIUS: Did your husband have any political connections?

18 A. No.

19 JUDGE AGIUS: How come it was precisely he that was approached by

20 the person you mentioned earlier on and also in your statement and not

21 somebody else, to take part, an active part, in this agency?

22 A. They happened to come across each other in town, and this man told

23 him that he was asking the authorities that a bureau be set up for

24 refugees, and that the government had approved this but they said they

25 should organise themselves and find equipment and premises on their own.

Page 14788

1 JUDGE AGIUS: But why you and your husband and not someone else?

2 What expertise, what were your qualifications that put you in better

3 stead or in good stead over others?

4 A. We didn't have any special qualifications but the man who ran into

5 my husband on the street knew that we were both out of work because our

6 company had ceased to operate. He knew that we had office space,

7 computers, and telephone lines available.

8 JUDGE AGIUS: Yes. Have you ever heard of Atlas travel agency in

9 Banja Luka?

10 A. Well, before the war, the Atlas travel agency in Banja Luka were

11 engaged in organising air travel.

12 JUDGE AGIUS: And Putnik?

13 A. Yes, yes, they did the same, before the war.

14 JUDGE AGIUS: Do you know that both these companies, both these

15 agencies, were closed down before the setting up of your agency?

16 A. Our agency wasn't at all like those two agencies. Those were

17 agencies that operated before the war. Atlas was, I think it wasn't even

18 a Bosnian agency but a Yugoslav agency, that this was only a

19 representative office or a unit of an agency that was located somewhere

20 else, I don't know where exactly. So these agencies had nothing in common

21 with --

22 JUDGE AGIUS: If I were to tell you that these two agencies were

23 forced to close down before the agency you were responsible for was

24 created, would you accept it? Are you aware that they were forced to

25 close down?

Page 14789

1 A. I believe you, but I don't know anything about their being forced.

2 JUDGE AGIUS: Respective to your offices, where did Atlas and

3 Putnik have their offices? Did they have offices in the centre of the

4 town?

5 A. Atlas was in Gospodska Street, because before the war I travelled

6 through Atlas few times and I bought air tickets there. As for Putnik I

7 don't know where that was.

8 JUDGE AGIUS: Are you in a position to know whether Atlas for

9 example could have provided their offices and equipment to -- for the same

10 purposes that you offered your offices and equipment?

11 A. Atlas was not privately owned at the time. Atlas was state-owned.

12 And if they had wanted to provide offices and equipment, they would have

13 had to seek approval from their superiors, but I really don't know, but

14 Atlas and Putnik were state owned agencies, they were not privately owned

15 agencies.

16 JUDGE AGIUS: That must have made it easier for the region or the

17 municipality to take possession of the offices, no? Why not do that once

18 they had been forced to cease operation and offer you to provide premises

19 and equipment? When they could have started -- charity begins at home and

20 would have started by taking over what was theirs in the first place?

21 A. I don't know. I really don't know, but I think that it would not

22 have been proper for someone's property to be appropriated like that.

23 JUDGE AGIUS: Did you receive a rent from the government, from the

24 state, for the use of your offices by this agency?

25 A. No. We had no contacts with the authorities or the government.

Page 14790

1 JUDGE AGIUS: So you made available the offices without any

2 co-respective, without any rent, without receiving any rent?

3 A. Yes.

4 JUDGE AGIUS: Did you ask for some kind of compensation for the

5 use of your offices plus equipment?

6 A. No. The only condition was for us to work in the agency.

7 JUDGE AGIUS: And the car, did you make the car of the -- your

8 company at the disposal, that you put it at the disposal of the agency as

9 well?

10 A. Yes.

11 JUDGE AGIUS: And the only thing that you had in return was the

12 miserable salary that you referred to before? Less than 100 marks?

13 A. Yes.

14 JUDGE AGIUS: That's all? And this is a premises and equipment

15 which, prior to these events, was sufficient for the employ of over 30

16 persons?

17 A. No, no, no. Not the premises, no, not the premises. Only the

18 equipment, not the premises.

19 JUDGE AGIUS: Were you forced in any way that you know and that

20 you could tell us about to make these premises and equipment available to

21 the state? Or was it just something that you voluntarily did?

22 A. No. It was the local commune that gave us premises, and I put the

23 equipment at the disposal voluntarily, without any force. I saw this as

24 my contribution to help the people.

25 JUDGE AGIUS: I see. Is there a beatification process in your

Page 14791

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Page 14792

1 favour, by any chance, in Banja Luka?

2 A. No.

3 JUDGE AGIUS: All right. I thank you. I have no further

4 questions, there are no further questions? Okay. I think the witness can

5 leave the courtroom. We need to draw down the curtains before she does.

6 Mr. Ackerman, are there any documents that you need to number

7 or -- no. You finished with yours.

8 Madam I still thank you for having come over to give evidence in

9 this Tribunal and only last thing I have -- I need to tell you is to wish

10 you a safe journey back home. Thank you.

11 THE WITNESS: [Interpretation] You're welcome.

12 [The witness withdrew]

13 JUDGE AGIUS: Yes, Madam Richterova?

14 MS. RICHTEROVA: I have only very quick thing and it is that we

15 haven't received any decision on our Rule 92 bis motion.

16 JUDGE AGIUS: Yes, I'm going to refer that to Mr. Ackerman because

17 Mr. Ackerman reserved his position until he was given the list of the

18 witnesses which he was given the last time he was here but we haven't

19 heard from him since then.

20 MR. ACKERMAN: Your Honour I worked on it as much as I could while

21 I was back in Texas. I think I'll have it finished today.

22 JUDGE AGIUS: I understand. All right, okay. Thank you Mr.

23 Ackerman. But we need to know because Donji Vakuf and Prnjavor are soon

24 with us. Anything else?

25 MS. RICHTEROVA: No, Your Honour.

Page 14793

1 JUDGE AGIUS: All right. Thank you. Good afternoon, and see you

2 tomorrow morning at 9.00.

3 --- Whereupon the hearing adjourned at

4 1.48 p.m., to be reconvened on Tuesday,

5 the 25th day of February, 2003, at 9.00 a.m.

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