Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14605

 1                           Tuesday, 14 June 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.01 a.m.

 6             JUDGE KWON:  Good morning, everyone.

 7             Good morning, Ms. Hanson.

 8             THE WITNESS: [Interpretation] Good morning.

 9             JUDGE KWON:  Mr. Karadzic, please continue.

10                           WITNESS:  DOROTHEA HANSON [Resumed]

11             THE ACCUSED: [Interpretation] Thank you.

12                           Cross-examination by Mr. Karadzic: [Continued]

13             MR. KARADZIC: [Interpretation]

14        Q.   Good morning, Witness.  Good morning to all of you.  Good

15     morning, Ms. Hanson.

16        A.   Good morning.

17        Q.   We left off on Thursday with the document that pertains to Foca.

18     Now, my question to you was whether you overlooked -- or why did you

19     overlook the very essence, the gist of this document, where the

20     authorities are preventing the departure, and a demand is made to

21     actually put a stop to the expulsions and not to expel people, as you

22     claimed?

23        A.   Is it possible for me to see a copy of that document, because my

24     recollection of it is the opposite, that they are discussing how to

25     organise the departure of Muslims.

Page 14606

 1             JUDGE KWON:  Yes, Ms. Sutherland.

 2             MS. SUTHERLAND:  Your Honour, for the record, that's

 3     Exhibit P2642.

 4             THE ACCUSED: [Interpretation] Will we see this document in

 5     e-court?

 6             THE WITNESS: [Interpretation] I read paragraph 1 as saying that

 7     they will allow people to depart.  And paragraph 3, they're organising

 8     that.  Paragraph 4 calls on the police and civilian authorities to

 9     organise transportation.  And paragraph 5 is to make a list of property

10     that will remain when the people leave.  So I see this as an example of a

11     war commission, in this case, acting to organise the departure of Muslims

12     after consulting with the commissioner sent from the government level.

13             I agree that the second paragraph -- third paragraph says that

14     they have, until now, been preventing both Serbs and Muslims from

15     leaving, but the gist of this decision I see as how to organise the

16     departure of those who want to leave, as the letter expresses it.

17        Q.   With all due respect, Ms. Hanson, I will have a problem with the

18     way you understand documents, not with documents, themselves.  This is a

19     clear suggestion that there was a ban, so these people wanted to go.  And

20     now you say that things should be organised for those who wish to go.

21     This is not expulsion.  This is about making it possible for people,

22     Serbs and Muslims alike, to leave and to join their families, and you

23     misrepresented that in your report.  You painted it in a completely

24     different light; is that so?

25        A.   In my report, I cite this document as an example of

Page 14607

 1     communications with the government commissioner.  However, I certainly

 2     see here that they are putting it in terms of organising the departure of

 3     those who wish to leave.  I note that in my report, that one of the

 4     criteria that is set in many -- by many crisis staffs for the departure

 5     of the non-Serbs is that they sign a paper stating they're leaving

 6     voluntarily.

 7             I think the overall evidence of the events throughout the

 8     municipalities indicate why people would say such a thing, and it is not

 9     a truly spontaneous desire to move to a different place.  In some cases,

10     they wish to avoid war operations, perhaps.  But in other cases, they

11     were forced into such a situation that departure was seen as the only

12     option.  In Bosanska Krupa, for example, the Crisis Staff wrote, and

13     those are the words of Gojko Klickovic, member of the Main Staff, that

14     two options were suggested to the Muslims; to organise their own

15     departure or to have it effected by military means.  He then --

16        Q.   Ms. Hanson, we'll get to that.  Now we're in Foca.  We're dealing

17     with Foca now.  And in some municipalities, this is not allowed.  Do you

18     know, by the way, that Mr. Klickovic, against whom you testified before

19     the court in Bosnia and Herzegovina, that he was acquitted because he did

20     not harm Serbs at all, and that this Court is not in favour of Bosnian

21     Serbs at all?  So in this case, you cannot say that they were forced in

22     some municipalities.  We have to determine in what municipalities, under

23     what circumstances.  And I asked you whether you knew that Mr. Klickovic,

24     before a Court which is very much anti-Serb, that he was acquitted.

25             JUDGE KWON:  Yes, Ms. Sutherland.

Page 14608

 1             Microphone.

 2             MS. SUTHERLAND:  I don't think that question is appropriate for

 3     the witness.

 4             JUDGE KWON:  The question is whether she knew that a certain

 5     individual was acquitted.  I think she mentioned his name in her answer

 6     previously.

 7             Please proceed.

 8             THE WITNESS:  I did bring up his name.  I knew he was acquitted,

 9     but I can't agree with the entire statement, that the Court is anti-Serb.

10     So how can I answer a question that I agree with half of, but not the

11     other half.

12             JUDGE KWON:  Yes, Mr. Karadzic.

13             MR. KARADZIC: [Interpretation] Thank you.

14        Q.   Could you please confirm for the Trial Chamber whether

15     Gojko Klickovic was the president of the Crisis Staff in the municipality

16     of Bosanska Krupa that you mentioned?  And you mentioned a document that

17     he drafted.  Is that the Gojko Klickovic we're talking about, the same

18     person?

19        A.   Yes.

20        Q.   Thank you.  In paragraph 147 of your report, you present some

21     conclusions that pose a great challenge for the Defence, and they are the

22     foundation of the charge in the indictment that the Bosnian Serb

23     leadership did not have any institutional authority over crisis staffs,

24     as members of the Presidency and Government, but that they did

25     everything, they assisted and so on.  And then you say:

Page 14609

 1             "As the president of the Presidency of Kotor Varos, a

 2     municipality that witnessed some of the worst violence quoted ..."

 3             [In English] "Indeed as the president of the War Presidency of

 4     Kotor Varos Municipality, Kotor Varos, a municipality that witnessed some

 5     of the worst violence, put it as far as the action concerning the

 6     hand-over of arms and moving people out of the municipality is concerned,

 7     the action and all activities in general were carried out on the order of

 8     the Government and Presidency of the Republika Srpska."

 9             [No interpretation]

10             MS. SUTHERLAND:  I'm sorry to interrupt again, Your Honour.

11             JUDGE KWON:  That should be "not only," that did not have only

12     the institutional authority of a crisis staff, but they did everything.

13             Just a second.

14             Yes.  Please proceed, Ms. Hanson.

15             THE WITNESS:  Is it possible for me to have a copy of my report

16     when he cites paragraphs?

17             JUDGE KWON:  By all means.  The last paragraph, I take it.

18             MS. SUTHERLAND:  Mr. Registrar, that's Exhibit P2589, and a hard

19     copy of the report is coming down to the courtroom as we speak.

20             THE ACCUSED: [Interpretation] I would like her to get a hard

21     copy, because we're wasting time.

22             While we're waiting for you to get it -- okay, yes.  I would

23     really like the witness to be given a hard copy, because we can't waste

24     time waiting for each and every paragraph to be called up on the screen.

25     I think that the witness can then look at the hard copy and everybody

Page 14610

 1     else can check their own copies.

 2             JUDGE KWON:  A hard copy is coming.

 3             Yes.

 4             THE ACCUSED: [Interpretation] Can we please look at 65 ter

 5     document 532.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Since, Ms. Hanson, you list Kotor Varos as an example of

 8     wrong-doing, now I would like us to look at Kotor Varos and to verify

 9     what actually happened there and what your conclusions should have been,

10     and then we will deal with other municipalities.

11             Please look at this document.  This is a session of the

12     Crisis Staff of Kotor Varos, 25th of June; that is the date.  And now

13     look at the first paragraph:

14             "In combat activities in the course of the day, the members of

15     the Crisis Staff were informed about them by Colonel Peulic, and he also

16     informed the crisis staff of a telegram from the corps commander relating

17     to the security for the arrival of Banja Luka Bishop Komarica for a

18     religious service in Kotor Varos to be held on Saturday, and that

19     measures must be taken to make this possible.  With regard to the

20     development of events in our area, he ordered that anyone that can carry

21     a rifle must be mobilised.  The town command must be formed ..."

22             And so on.

23             Do you know that Bishop Komarica is the local religious leader of

24     Roman Catholic Church and that he is an ethnic Croat?

25             JUDGE KWON:  Are we looking at the correct document,

Page 14611

 1     Mr. Karadzic?

 2             THE WITNESS:  Yes.

 3             THE ACCUSED: [Interpretation] I believe so.  That's the first

 4     paragraph.

 5             JUDGE KWON:  Thank you.

 6             THE WITNESS:  Yes, I am aware that Bishop Komarica is the

 7     Catholic bishop and a Croat.

 8             MR. KARADZIC: [Interpretation] Thank you.

 9        Q.   Now look at the end of this paragraph, where it says that

10     Dr. Gajanik informed the Crisis Staff about the condition of the wounded,

11     and he says that they have a total of 10 people dead and 31 wounded.

12             Do you know that throughout this area, there was fighting going

13     on in Kotor Varos?

14        A.   Yes, I'm aware that there was armed conflict.

15        Q.   Do you know that Bishop Komarica is coming to visit Croats for

16     their religious holiday, not Serbs?

17        A.   I don't know which religious holiday, but he is coming, yes,

18     presumably to minister to Croats or Catholics, yes.

19        Q.   And that's at the end of the third month of war.  This

20     municipality makes it possible for a bishop of a minority population to

21     come and visit, provides security, and orders that additional forces be

22     mobilised in order to ensure his safety during his visit.  Did you have

23     this document when you were making your report, and did you take it into

24     account?  Yes or no?

25        A.   Your question is too complicated to give a yes or no.  I don't

Page 14612

 1     see that the additional forces mobilised is expressly to ensure his

 2     safety.

 3             Yes, I reviewed all the minutes of the Crisis Staff -- meetings

 4     of the Crisis Staff of Kotor Varos, so I would have seen this one as

 5     well.

 6        Q.   So you did not take it into account; is that so?

 7        A.   I reviewed it.  I did not put it in my report.  I did not enter

 8     into issues of religious services or -- this bishop is in Banja Luka,

 9     which is already part of the Serb-held territory.  He's moving between

10     two Serb-held areas.  I didn't go into detail into that sort of -- a

11     visit like that.  I did not -- I read it.  I did not include it in my

12     report.  I don't know what you mean, did I take it into account.

13        Q.   Ms. Hanson, it's the third month of the war, it's at the end.

14     The Croat minority in Kotor Varos is still there.  They have their

15     religious services.  The Catholic bishop comes to visit them, and the

16     authorities are trying to make sure that everything goes as it should.

17     And you are insinuating that they are -- they have expelled everyone.

18     You can see clearly here that additional forces are mobilised in order to

19     secure Komarica's visit, but you said that you did not take this document

20     into account.

21             I would like to tender it into evidence.

22             JUDGE KWON:  Did you ask a question?  Do you like to comment,

23     Ms. Hanson?

24             THE WITNESS:  The quotation which he started this section with,

25     paragraph 147, as you can see from the footnote, refers to -- is dated

Page 14613

 1     from October, not June.  We see later, in Kotor Varos, more organised

 2     departures in July and August.  Of course, there were some non-Serbs

 3     left, especially in Banja Luka, in 1992.  I don't claim that they got rid

 4     of -- they moved out everybody, but they -- this body, the Crisis Staff,

 5     is formed to defend Serb interests in territory that contains non-Serbs

 6     as well, and a pattern I see throughout is that that brings an inherent

 7     conflict when power is wielded in the name of one people in territory

 8     that contains Serbs, Croats and Muslims.  So this is proof that there are

 9     still Croats in Kotor Varos.  I agree that their bishop is coming to

10     visit them.  But it does not negate the later minutes of the crisis

11     staffs and War Presidency that say, We've got to figure out why not

12     everyone wants to leave, we've got to organise their departure.

13             JUDGE KWON:  We'll admit this one.

14             THE REGISTRAR:  As Exhibit D1294, Your Honours.

15             THE ACCUSED: [Interpretation] We will get to that, Ms. Hanson.

16             Can we please look at 65 ter 276.

17             MR. KARADZIC: [Interpretation]

18        Q.   This is two days later, the 27th of June, the meeting of the same

19     body again.  And in item 1, it says that Lieutenant-Colonel Peulic

20     informed the staff about combat operations, and it says:

21             "Mane T.," probably Mane Tepic, "reported on the situation in the

22     units securing the town, stressing that during the night, the situation

23     in the units was stable, and the enemy was seen setting fire to Serbian

24     houses in Kotor."

25             And in item 2, at the end, it says:

Page 14614

 1             "The Crisis Staff was made aware of the requests of the Red Cross

 2     and the request of Naim Hadziselimovic for permission to exchange his

 3     house, which was given on the condition that he brings the proper

 4     documents as proof of the exchange."

 5             Do you know that at that time, Serb houses were being set on fire

 6     in Kotor Varos, itself, that there are enemy units present there, and

 7     that Naim is a Muslim who is seeking permission to exchange his property?

 8        A.   We can see all that from the document, I agree.

 9             THE ACCUSED: [Interpretation] Thank you.

10             I would like to tender it into evidence.

11             JUDGE KWON:  Yes.

12             THE REGISTRAR:  Exhibit D1295, Your Honours.

13             THE ACCUSED: [Interpretation] Can we please look at 65 ter 290.

14             MR. KARADZIC: [Interpretation]

15        Q.   Now, this is the 29th of June, two days later, another meeting of

16     the Crisis Staff.  A shortage of oil is mentioned here, shortage of a

17     number of items, and it says:

18             "At about 2300 hours yesterday, a group went into action in the

19     Rujik area, on which occasion one soldier was killed and another

20     seriously wounded."

21             And:

22             "Kotoriste must be cleaned again because in the course of the day

23     because there are a lot of people there."

24             And then in the last paragraph:

25             "Due to the frequent occurrence of flat break-ins, an order was

Page 14615

 1     issued to the tenants' councils in blocks of flats to organise guard duty

 2     in their building and to check persons entering and leaving them.  The

 3     tenants' councils shall be responsible for every unauthorised entry into

 4     flats."

 5             Are you aware of this, that this was organised, and do you know

 6     that this was done in accordance with the law?

 7        A.   Are you referring to the last paragraph of the tenants' councils?

 8        Q.   Yes.

 9        A.   I see that here.  I have no basis to say whether it was or was

10     not in accordance with the law, but I see that it is written here.

11             THE ACCUSED: [Interpretation] Thank you.

12             I would like to tender it into evidence.

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit D1296, Your Honours.

15             THE ACCUSED: [Interpretation] Can we please look at 65 ter 300.

16             MR. KARADZIC: [Interpretation]

17        Q.   This is another session of the War Presidency.  The date is the

18     15th of July, so it's no longer the Crisis Staff, it's the

19     War Presidency.  And we can see everything from this document.

20             Look at item 3:

21             "Under this item, the work of the Red Cross was discussed; i.e.,

22     the possibility of a visit from a representative of the

23     International Red Cross.  It was decided that the Red Cross should become

24     more active in this field of work by visiting prisoners, passing messages

25     from their families to them, and preparing for a visit from an

Page 14616

 1     International Red Cross representative."

 2             Are you aware of the fact that the International Red Cross was

 3     active there?

 4        A.   I'm aware, in general terms, of the International Red Cross

 5     seeking access to many detention centres.  The story in Kotor Varos,

 6     itself, I'm not familiar with.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             I would like to tender this into evidence.

 9             JUDGE KWON:  Yes.

10             THE REGISTRAR:  Exhibit D1297.

11             THE ACCUSED: [Interpretation] I would like us to look at

12     65 ter 458, please.

13             MR. KARADZIC: [Interpretation]

14        Q.   The date is the 8th of August.  This is the 51st session, which

15     means that they had a session practically every day.  And in item 3, it

16     says:

17             "The Presidency considered the Executive Committee's proposal to

18     grant permission for the operation of a private company, Bosna Kompanija

19     in Siprage ..."

20             And other matters.  So they gave their approval for the operation

21     of this company, Bosna Kompanija.  And it says:

22             "Savo reported on the unsanitary conditions in the prison."

23             Do you know which ethnicity is in the majority in Siprage?

24        A.   No, I do not.

25             THE ACCUSED: [Interpretation] Siprage has a Muslim majority, and

Page 14617

 1     we will have to look at it in the end, show that.

 2             It says here:

 3             "Savo reported on the unsanitary conditions in the prison."

 4             That's the translation that we have of this document and it says

 5     Savo presented the problem of unsanitary conditions in the prison, which

 6     means that it was a problem which was being solved.  So the translation

 7     is wrong.

 8             And as regards the various places, Siprage, as you will see, is a

 9     Muslim village.  It has a marked Muslim majority in Kotor Varos.

10             So I would like to tender this document into evidence.

11             JUDGE KWON:  Instead of making a statement, why don't you read

12     the last sentence on item 4 so that we can hear the correct

13     interpretation.

14             And I ask Ms. Hanson to read out that sentence, starting out with

15     "Savo."

16        A.   [Interpretation] "Savo raised the problem of unsanitary

17     conditions in the prison."

18             JUDGE KWON:  Thank you.

19             Yes, this will be admitted.

20             THE REGISTRAR:  Exhibit D1298, Your Honours.

21             THE ACCUSED: [Interpretation] 65 ter 295, please.

22             MR. KARADZIC: [Interpretation]

23        Q.   This is a session, the 57th session, on the 21st of August, 1992.

24     In fact, it's the 59th meeting.  We see the agenda, and the second

25     paragraph:

Page 14618

 1             "Pursuant to the information reported, President Djekanovic

 2     pointed out matters and problems that needed to be solved to prevent

 3     pressures and provocations by certain members of the Special Forces unit

 4     directed against Muslim and Croat families in order to compel them to

 5     leave should be stopped; that the question of what to do with several

 6     families from Gornji Cepak who cannot stay there, but are still in Cepak,

 7     should be dealt with, and that the killing of the Orsulic couple should

 8     be investigated."

 9             Item 4 in English, we need the next page.

10             The translation says "should be," and the proper translation

11     should be "would be" or "to be."

12             Item 4:

13             "Under this item of the agenda, the case of Mirso Alen Avdic was

14     considered, and the recommendation that he be issued documents to travel

15     abroad and visit his father.  Problems were discussed and security

16     arranged for a convoy of people wishing to leave the area, scheduled for

17     next Sunday."

18             My first question:  Do you see that in this paragraph 2, there is

19     talk about pressures and problems created by certain individuals, and the

20     authorities require action to be taken?

21        A.   It's not individuals; it's a unit.  Oh, individuals from a unit

22     of special units.  Yes, they are describing that there have been

23     unacceptable pressures put on Muslims and Croats to move out, and that

24     should be stopped.

25        Q.   Furthermore, do you agree, concerning item 4, that this

Page 14619

 1     Mirso Alen Avdic is a Muslim, and his departure to a destination abroad

 2     is being approved?

 3        A.   The name certainly suggests a Muslim, and, yes, his departure is

 4     being approved by the War Presidency.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             May this be received?

 7             JUDGE KWON:  Yes.

 8             THE REGISTRAR:  As Exhibit D1299, Your Honours.

 9             THE ACCUSED: [Interpretation] 65 ter 436, please.

10             MR. KARADZIC: [Interpretation]

11        Q.   This is the 12th session of the War Presidency.  The Crisis Staff

12     is long gone.  It's the 13th of July, 1992.

13             Look at item 1:

14             "Mane Tepic ..."

15             [In English] "Mane Tepic informed members of the War Presidency

16     about yesterday's events on the ground.  At the president's proposal

17     concerning the initiative and wishes of a group of Vecici inhabitants who

18     want to move out, it was concluded that efforts should be made to make it

19     possible."

20             [Interpretation] Did you know that Vecici had a large Muslim

21     concentration and a large armed group that was constantly involved in

22     combat?

23        A.   I did not know the specifics of the population or events in

24     Vecici, but I'm not surprised, reading this, to learn that it's non-Serbs

25     who want to move out.  I said that I see many documents in which the

Page 14620

 1     War Presidency is assisting the moving out of people who say they want to

 2     move out.  I don't see them anywhere saying, Let's try and make these

 3     people want to stay, let's change conditions that would change the mind

 4     of all our population and make them want to stay in their home territory.

 5     That's what I don't see in any crisis staff or War Presidency minutes, of

 6     wanting to find out why they want to leave and changing that.  On the

 7     contrary, I find in Kotor Varos, itself, a document saying some people

 8     who were supposed to leave haven't and the reasons for that should be

 9     looked at.  And it's given as an example of a poorly-organised departure.

10     So I agree, this is an example of --

11        Q.   Madam, Ms. Hanson, we'll come to that, we'll come to that.  I

12     don't need your moral position on this.  This is a criminal case.

13             You knew that Vecici had a large Muslim concentration and a very

14     strong armed group that was constantly involved in fighting; did you know

15     that or not?

16             JUDGE KWON:  Before you answer, Ms. Hanson:  Yes, Ms. Sutherland.

17             MS. SUTHERLAND:  Your Honour, I don't think it's proper for the

18     accused to say, I don't need your moral position on this, this is a

19     criminal case, when Ms. Hanson is simply answering the question.

20             JUDGE KWON:  Yes, I agree.

21             Yes, Ms. Hanson, could you answer the question.

22             THE WITNESS:  Your Honour, I believe I already did further up

23     that I didn't know the specifics of the population or events in Vecici.

24             THE ACCUSED: [Interpretation] Can this be admitted?

25             JUDGE KWON:  Yes.

Page 14621

 1             THE REGISTRAR:  Exhibit D1300, Your Honours.

 2             THE ACCUSED: [Interpretation] 65 ter 274, please.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Ms. Hanson, with all due respect, let us stick to questions.

 5     There are many documents concerning this municipality which you singled

 6     out as representative.  We'll go through everything.  Everything will

 7     fall into its proper place.  Please stick to questions.

 8             This is the 15th session of the War Presidency, held on 14 July.

 9     Item 2, one paragraph before last:

10             "Regarding the pronounced problem of providing accommodation for

11     families from Kotor whose houses had been burnt down by extremists, a

12     temporary solution needs to be found and the Presidency informed."

13             We saw, in 65 ter 276, that Serb houses were ablaze, were being

14     burnt in Kotor Varos, itself, that extremists were all over the place.

15     Did you see that in the previous document, 276?

16        A.   I didn't see that extremists were all over the place, but we saw

17     it said that some Serb houses in Kotor were being burnt.

18        Q.   Thank you.  Item 3:

19             "Under this item, the meeting reviewed the issue of houses

20     remaining vacant after evacuation, and in some recent cases, people have

21     moved into them.  It was decided that the competent commission should

22     seal all such houses and submit a list to the Public Security Station."

23             Did you know that municipal authorities, in the middle of this

24     chaos, still found the time to look after property, vacant property?

25        A.   What I see is crisis staffs, war presidencies, taking over this

Page 14622

 1     vacant property and reassigning it, reusing it in some cases.  Here, it

 2     seems to be preventing people who have moved in on their own, but that

 3     the authorities are trying to assert control over that property.  That's

 4     what I -- how I read item 3.

 5        Q.   Ms. Hanson, please, let's discuss only Kotor Varos now, because

 6     you cited it in your last paragraph of the report as representative.

 7     Let's concentrate on that.

 8             THE ACCUSED: [Interpretation] Can this document be received?

 9             JUDGE KWON:  Have we not?  We'll admit it.

10             THE REGISTRAR:  As Exhibit D1301, Your Honours.

11             THE ACCUSED: [Interpretation] 65 ter 550, please.  65 ter 550.

12             MR. KARADZIC: [Interpretation]

13        Q.   This is a session of 18 June.  The Crisis Staff is still there,

14     and it says, towards the end of the second paragraph:

15             "Goran Krsic informed the Crisis Staff that there were two

16     requests to return into abandoned apartments."

17             Next page in English.

18             "Goran Krsic informed the Crisis Staff that there were two

19     requests to return into sealed apartments."

20             Two Muslim names are quoted:

21             "Huseinovic was given permission to move back into his flat, but

22     not Ibricic, since he was not the tenancy right holder.  The Crisis Staff

23     was informed of the activities of the Municipal Civilian Protection

24     Staff."

25             These two persons, Huseinovic and Ibricic, were they Muslims, to

Page 14623

 1     the best of your knowledge?

 2        A.   The names are certainly Muslim, so the assumption is they

 3     identified themselves as Muslims, yes.

 4        Q.   Did you register that on the 18th of June, Muslims were returning

 5     to their apartments in Kotor Varos?

 6        A.   I did not put this in my report, if that's what you mean by

 7     "registering."

 8        Q.   Did you, as an unbiased expert, have the obligation to include

 9     exculpatory elements into your report?

10        A.   "Exculpatory" I take to mean that crimes did not occur or that

11     someone else, other than the accused, would be responsible for the

12     crimes.  For a crisis staff to allow a citizen to return to his apartment

13     does not strike me as, in itself, exculpatory.  It's what I would expect

14     a municipal government to do.

15             I note that item 2 in here is quite consistent with what I say

16     about the people -- non-Serbs can move out if they give up their

17     apartment.  That's what we see in item 2.  I don't see the fact that one

18     Muslim is allowed to enter his own apartment as exculpatory.

19        Q.   Ms. Hanson, you are accusing this Crisis Staff that, under the

20     leadership of the Presidency and Government of Republika Srpska, it was

21     persecuting Muslims consistently.  This is evidence that it was not so.

22     Chaos reigned in the town.  There was fighting and shooting everywhere

23     around, and still, under those circumstances, this War Presidency acted

24     as a responsible government.  You did not stress that.  On the contrary,

25     you left us with the impression, in paragraph 147, that it was quite the

Page 14624

 1     contrary.

 2             Can we see the next page in Serbian.

 3             JUDGE KWON:  You are making statements without asking a question.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Madam, did you accuse this Crisis Staff, in your report, about

 6     the expulsion of Muslims?

 7        A.   I have difficulty with the word "accused."  I stated what I saw

 8     it doing.  I nowhere said that they expelled every single last non-Serb.

 9     As we saw from the document we looked at last week, they wanted to remove

10     non-Serbs to a level at which Serbian power could be assured in the

11     territories they claimed.  But as for the accusations, that's not my job.

12        Q.   But you said earlier today -- you say they did not expel

13     everyone, but show us one person whom they did expel?  Did they expel

14     this person from item 2, Mehmedovic, Rasim, who is asking permission to

15     move out on the condition that he leaves behind his apartment in

16     Kotor Varos?  Do you know what occupancy right means under our

17     legislation, that the apartment belongs to the municipality, but it is

18     being used by the person to whom it was allocated?

19        A.   I'm satisfy with the [indiscernible] occupancy right.  The

20     apartment can belong to the municipality or his place of employment.

21     And, yes, he has the right to occupy it temporarily, although -- not

22     temporarily.  He is given the right to occupy, but it is not out-and-out

23     possession.

24             THE ACCUSED: [Interpretation] Thank you.

25             Can we look --

Page 14625

 1             JUDGE KWON:  The question asked before that question was whether

 2     you can show us one person whom they did expel.

 3             THE WITNESS:  In this document, no, if that's the question

 4     relating to this document.

 5             JUDGE KWON:  Thank you.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Towards the end of paragraph 2 under item 1, you see it says:

 8             "The decision was taken that the order to gather foodstuffs be

 9     extended to the Siprage co-operative, and the distribution be done from

10     that shop, and that work obligation be introduced in Siprage,

11     Grabovica ..."

12             And another place.

13             Does this concern produce to be distributed among the population?

14        A.   I'm just reading the B/C/S because I do not see the English yet.

15        Q.   In English, it's the next page.

16        A.   I see that sentence, yes.  What was your question?

17        Q.   Is this the same place, Siprage, where Muslims were an

18     overwhelming majority?

19        A.   It mentions Siprage as the name of an economic enterprise here,

20     probably found in the settlement of Siprage, but I don't know for sure.

21     And as I say, I don't know that Siprage has an overwhelming Muslim

22     majority --

23        Q.   Do you see item 1:

24             "Agricultural cooperative Zadruga from Vrbanjci (systemisation

25     was conditionally accepted)."

Page 14626

 1             Do you know that this place, Vrbanjci, was almost purely Croat?

 2     Just yes or no?  Did you know that Vrbanjci is a purely Croat village?

 3        A.   No, I did not know.

 4        Q.   Thank you.  It says after this item 4:

 5             "The president of the Crisis Staff informed the staff that there

 6     are strong pressures and requests by individuals to leave Kotor Varos.

 7     After debate, it was agreed that those who live near the front-line and

 8     wanted to be evacuated within the municipality should be enabled to do

 9     so."

10             Do you know that it's the obligation and the right of municipal

11     authorities to evacuate people who may be jeopardised?

12        A.   Yes, I would expect municipal authority to evacuate people in

13     danger.  These are to be evacuated within the area of the municipality.

14             THE ACCUSED: [Interpretation] Thank you.

15             Can this be received?

16             JUDGE KWON:  Yes.

17             THE REGISTRAR:  Exhibit D1302, Your Honours.

18             THE ACCUSED: [Interpretation] 65 ter 367, please.

19             JUDGE BAIRD:  Ms. Hanson, as we look for that document, can you

20     assist me?  In paragraph 147:

21             "Indeed, as the president of the War Presidency of Kotor Varos, a

22     municipality that witnessed some of the worst violence ..."

23             When you say "violence," what exactly do you mean?

24             THE WITNESS:  Fighting, killings.

25             JUDGE BAIRD:  War?

Page 14627

 1             THE WITNESS:  More than that.  Not equal combat, but also

 2     civilians, non-combatants detained, put in their -- detained in horrible

 3     conditions, maltreated there, and then forced to leave because of the

 4     threat of violence or actual killings.

 5             JUDGE BAIRD:  I see.  Thank you.

 6             Yes, Mr. Karadzic.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             Then we will stick to Kotor Varos and show all documents that are

 9     available.

10             MR. KARADZIC: [Interpretation]

11        Q.   This is a session from the 15th of July, 1992.  Look at item 2,

12     the penultimate paragraph:

13             "The president of the War Presidency stressed that the Presidency

14     had already noted more than once that the situation was taking a bad turn

15     and that the Presidency was ready to do its best -- to do everything in

16     its power to change this.  He mentioned, as evidence of this bad

17     situation, that several Serbian families were spending nights in other

18     people's houses, that is to say, outside their homes, than either Muslims

19     or Croats."

20             Did you know that more Serbs were spending nights in other

21     people's houses than Muslims and Croats, and that Serbs were at a greater

22     risk than Muslims and Croats?

23        A.   I see that the War Presidency sees that as a criteria and that

24     the situation is bad.  If more Serbs are not securing their homes than

25     Muslims or Croats, that's when the Presidency feels they should change

Page 14628

 1     it.

 2             THE ACCUSED: [Interpretation] Can this document be admitted?

 3             JUDGE KWON:  Yes.

 4             THE REGISTRAR:  Exhibit D1303, Your Honours.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   And who forced these Serbs to spend nights outside their homes?

 7     Was it the Serbs?

 8        A.   It doesn't say.

 9        Q.   Well, you conclude.  You make conclusions.  You are very creative

10     in your conclusions.  If Croats and Muslims feel safer in their homes

11     than Serbs, then who is perpetrating crimes there?

12        A.   I would take this to be general combat activities.  There's

13     certainly not enough to say that Muslim or Croat forces are targeting

14     Serbs here.  We don't know.  It's ...

15             We see in the previous paragraph that 70 per cent of all soldiers

16     who have been killed have lost their lives outside combat, so there's

17     some violence going on, but there's no indication here of it being -- of

18     Muslims or Croats directing fire or arms at Serb families.  "Fire" in the

19     sense of shooting, not setting on fire.

20             THE ACCUSED: [Interpretation] Thank you.  Your conclusions are

21     very valuable to me.  We'll leave them for later.

22             Can we see 65 ter 314.

23             MR. KARADZIC: [Interpretation]

24        Q.   This is a session from 18 July.  Item 1:

25             "The decision was made that due to shortage of manpower in the

Page 14629

 1     active-duty police force, the reserve police force should be built up.

 2     In that way, the lack of active-duty policemen --"

 3             Next page in English, please:

 4             "In that way, the shortage of active-duty police officers would

 5     be offset by the increased reserve police forces, while the size of the

 6     reserve force should be decreased by manning active-duty police.

 7     Regarding requests by families whose houses had burnt down to be given

 8     accommodation, it was decided that they should all submit a request to

 9     the municipal Civilian Protection Staff, which staff will address their

10     accommodation."

11             Do you see that this refers to all families, regardless of faith

12     and ethnic background, and that there was not enough housing?

13        A.   I agree that in this reference here, they do not specify any

14     ethnic background of the families.

15        Q.   Thank you.  Could you please look at the continuation of this

16     document, where it says that a decision was made to carry out the harvest

17     on all plots where owners are absent, and that all the crops should be

18     taken in by the co-operative, with proper records being kept.  So did you

19     notice here that care is taken of the property belonging to owners that

20     are absent, and that records are kept of all the crops harvested from

21     their plots of land?

22        A.   It is certainly here that they will harvest all available crops.

23     The precise record-keeping doesn't mean that's going to be -- the owners

24     are going to be reimbursed or anything.  But, naturally, there the

25     War Presidency is trying to, you know, take care of the resources of the

Page 14630

 1     municipality, including food.  That doesn't surprise me.

 2        Q.   And if proper records are being kept, well, does it say here that

 3     they will not be paid?  Why are they keeping records, if not for that

 4     purpose?

 5        A.   Perhaps to avoid black market -- you know, diversion of the

 6     resources out of the control of the municipality.

 7        Q.   Yes, yes.  And do you see item 3, where it says:

 8             "At the request of Spasen Topic --"

 9             "Next page in English language:

10             "So regarding Spasen Topic's request for authorisation to go to

11     Belgrade in order to sort out his pension, the War Presidency decided to

12     authorise Topic -- Topic's departure to Belgrade."

13             To you knowledge, would this Spasen Topic be a Serb, based on his

14     name?

15        A.   The name would suggest Serb to me, yes.

16        Q.   Does that mean that Serbs needed authorisation to leave the

17     territory of the municipality?

18        A.   Yes, of course, if he's of military age.  Does it suggest -- when

19     it says he would be engaged in an adequate position in the brigade, it's

20     very clear that the municipal authorities were very sure to keep men

21     of -- Serbs of military age engaged and would not let them go abroad

22     without permission.

23        Q.   But this is a retired person, he is retired, because -- well, do

24     you see these things that you are saying anywhere in this document, and

25     don't you see that this is a retired person?

Page 14631

 1        A.   A retired person who, upon his return, is to be engaged in the

 2     brigade.  You can retire at an age where you're still fit for military

 3     duty.

 4             THE ACCUSED: [Interpretation] Can this document be received,

 5     please?

 6             JUDGE KWON:  Yes.

 7             THE REGISTRAR:  Exhibit D1304, Your Honours.

 8             THE ACCUSED: [Interpretation] Can we please look at 65 ter 402.

 9             MR. KARADZIC: [Interpretation]

10        Q.   This is a session of the War Presidency of the 23rd of July,

11     1992.  Please look at item 2, the penultimate paragraph:

12             "The Commission for Abandoned Flats and Houses was given the task

13     of checking if all abandoned flats and houses had been sealed ..."

14             Next page in the English language, please.

15             So:

16             "... if all abandoned flats --"

17             My apologies.  Can we please go back to the previous page in the

18     English language.  So that would be item 2.

19             So:

20             "... if all abandoned flats and houses had been sealed and if

21     there had been instances of people moving in."

22             And now we can go on to the next page in the English language.

23             And we can see from this that the commander asked for permission

24     for a fighter in his unit, Ostoja Popovic, to be authorised to travel to

25     Italy on business, and it says here:

Page 14632

 1             "No decision was taken in respect of this request."

 2             So were you aware of the fact that abandoned flats and houses

 3     were sealed, that the municipal authorities were taking good care of the

 4     abandoned property?

 5        A.   We see that they're sealed.  We also see them receiving

 6     applications for people to get some shelter, those whose houses have been

 7     destroyed.  The level of care taken of them can't be judged, but here the

 8     municipality is sealing and controlling those houses.  Yes, I see that.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Can this be received, please?

11             JUDGE KWON:  Yes.

12             THE REGISTRAR:  Exhibit D1305, Your Honours.

13             THE ACCUSED: [Interpretation] I would like us to look at

14     65 ter 273.

15             MR. KARADZIC: [Interpretation]

16        Q.   This is the session of the 24th of July, again the same

17     War Presidency.  It says down there that Ljubo Gavric is to compile and

18     forward to the Presidency a detailed report on the resettlement of the

19     population, including the following data: the number of convoys moved out

20     so far; the number of persons who have moved out and the structure of the

21     people who moved out; who carried out the transportation, in which

22     conditions; a financial report with updated information on receipts and

23     expenditures and other relevant information."

24             Do you agree with me that this is the Presidency of Kotor Varos

25     and that it should provide this information to the presidency of the

Page 14633

 1     municipality?

 2        A.   I'm sorry, I don't understand the last question.  Perhaps there

 3     was a problem with the translation, this is the presidency -- that it

 4     should provide the information to the presidency.

 5        Q.   It says here that Mr. Ljuboje Gavric should compile and forward

 6     to the Presidency the report.  What Presidency?

 7        A.   The War Presidency of Kotor Varos, I assume.

 8        Q.   Thank you.  And the last item in the Serbian version - we can go

 9     on to the next page in the English version:

10             "Goran Krsic is to be relieved of all tasks related to the

11     harvest to devote his attention to making an inventory of abandoned

12     houses, apartments and other property and their conservation."

13             Now I would like us to go to the next page in the Serbian

14     version:

15             "... that special care be taken of protecting the property in the

16     houses from which entire families had moved out, and that daily reports

17     should be submitted to the War Presidency on all activities regarding the

18     sealing of such property.

19             "Regarding the problems regarding property exchanges, we must

20     prepare decisions enabling tax-free property exchanges and a decision

21     preventing fictitious exchanging and profiteering."

22             Were you aware of the fact that the municipal authorities in

23     Kotor Varos were trying to protect the abandoned property and to deal

24     with the issue of exchanges of property with appropriate regulations in

25     order to prevent looting and profiteering?

Page 14634

 1        A.   The property exchanges commissions or agencies we see set up all

 2     over the --

 3        Q.   Please, Madam, we're now talking about Kotor Varos.  Please,

 4     Kotor Varos.  You listed this municipality as an example, a

 5     representative example.

 6        A.   This is also a municipality where people could bring only 300

 7     Deutschmarks with them when they left, so they left behind quite a bit of

 8     property, I imagine.  And, yes, here the War Presidency is sealing and

 9     holding that property, and setting up or dealing with the property -- the

10     problems of property exchanges.

11             THE ACCUSED: [Interpretation] Thank you.

12             Can this document please be admitted?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit D1306, Your Honours.

15             THE ACCUSED: [Interpretation] Can we please look at 65 ter 17271.

16             MR. KARADZIC: [Interpretation]

17        Q.   Was there any law regulating the possession of cash in

18     Yugoslavia, foreign currency in cash or is it something that the

19     authorities in Kotor Varos thought up?

20        A.   They got it from the ARK, the regulation of not taking out more

21     than 300 marks.

22             As for the legal situation in the former Yugoslavia, I'm not

23     familiar with it.  But Deutschmarks were generally used as the default

24     currency because the dinar was going into inflation in the war situation.

25     People didn't know which dinar to use, so Deutschmark was essentially

Page 14635

 1     the -- was another currency in use.

 2             I know that the instructions on 300 Deutschmarks came from the

 3     ARK, and Kotor Varos received and implemented it.

 4        Q.   Let's look at this document.  The date is the 31st of July, 1992,

 5     and it says that the public security stations in the Banja Luka centre

 6     area.  It's addressed to all of the police stations in that area:

 7             "Recently, under the auspices of the Red Cross, the Caritas and

 8     the Bureau for Resettlement of the Population, people are moving out to

 9     Croatia, Slovenia and other countries in Western Europe, a large number

10     of people of the Croat and Muslim ethnicity, and it has come to our

11     attention that those people are taking out of the Autonomous Region of

12     Krajina large quantities of foreign currency in order to be able to take

13     unified positions.  We hereby issue the following instructions to be

14     complied with when convoys are leaving the area:"

15             So natural persons leaving the area of Autonomous Region of

16     Krajina can take with them a maximum of 300 German marks or the

17     equivalent amount in other currency.  And taking into consideration the

18     vagueness of the term "leaving," the SFRY Law on Foreign Exchange was

19     consulted.  The law adopted by the Serb Republic of Bosnia-Herzegovina

20     until the new law was passed.  Article 80 of the law states:

21             "Citizens can take abroad only the foreign currency withdrawn

22     from their foreign currency accounts."

23             Please, can we move on to the next page in the English language.

24             "... foreign currency savings deposits, as well as foreign

25     currency bought from authorised banks in keeping with the regulations."

Page 14636

 1             It is also stated in the quote that:

 2             "The limit of the amount of foreign currency that might be taken

 3     abroad is determined by Federal Executive board.  Consequently, the

 4     decision of the ARK Crisis Staff, published in the ARK Official Gazette

 5     number 2 from the 5th of June, 1992, is not in contrast to the valid law

 6     on Foreign Currency.  Therefore, the following actions are to be taken

 7     while inspecting the above-mentioned natural persons:"

 8             And let us move on:

 9             "Each natural person leaving the ARK, trying to take with them a

10     larger amount of foreign currency than allowed by the appropriate

11     provisions, shall be seized, with the appropriate receipt being issued to

12     them.  This money shall be deposited in the safe of the Public Security

13     Station, and natural persons in possession of appropriate authorisations

14     from the authorised banks in the ARK, in accordance with appropriate law,

15     may take with them amounts greater than 300 German marks."

16             THE INTERPRETER:  Mr. Karadzic is kindly asked to read more

17     slowly.

18             THE ACCUSED: [Interpretation] It doesn't say in the transcript

19     "temporarily seized ."

20             MR. KARADZIC: [Interpretation]

21        Q.   And in paragraph 100 of your report, you say the Crisis Staff --

22     I will read in English:

23             [In English] "... the Crisis Staff oversaw the removal of

24     non-Serbs from the municipalities by establishing committees for

25     emigration, travel agencies and the exchange agencies."

Page 14637

 1             [Interpretation] And in 101, you say:

 2             [In English] "... a maximum sum of money, usually 300

 3     Deutschmarks that deportees could take with them."

 4             [Interpretation] So are you giving the full information to the

 5     Trial Chamber regarding the rights that people had to take foreign

 6     currency with them?

 7        A.   This document you provide confirms my assertion.  It gives more

 8     detail, but it confirms that the ARK decided it and it was implemented.

 9        Q.   Ms. Hanson, did you inform the Trial Chamber in your report that

10     this sphere was regulated by the federal law, adopted by

11     Republika Srpska, and that the 300 German marks limit pertained only to

12     the money that had not been withdrawn in accordance with the regulations

13     from one's bank account or purchased in a bank or a foreign exchange

14     office, that the excess amounts were seized temporarily, and that if you

15     were in a position of appropriate authorisations, you could take more

16     money with you?

17        A.   I'm sorry, I don't see the part where you said that it was -- the

18     300 was only over and above what people had taken out of their ...

19             I guess you mean the fourth item:

20             "Natural persons with valid certificates from authorised banks

21     are allowed to take out more than 300 marks."

22             Is that what you mean by the "over and above"?  But the federal

23     law you cite makes no mention of this 300 as a limit.

24             And as for it being a temporary confiscation, I don't see any

25     convincing evidence that these crisis staffs intended people to move out

Page 14638

 1     temporarily and made any effort to return them when the situation was

 2     more peaceful.  It was not -- this removal was not simply for the

 3     duration of the war.  It was to change the make-up of the municipalities.

 4     So to say it's a temporary confiscation of funds is not exactly honest

 5     here, because the intention was that these people leave forever.  But

 6     I --

 7        Q.   Madam, Ms. Hanson, it's not up to you to decide that, it's the

 8     Trial Chamber's job, and you're trying to take it upon yourself to do it.

 9             So this document that provides the legal basis for the seizure of

10     foreign exchange currency above a certain limit, did you include this in

11     your report?  Did you specify that this was in line with the federal law

12     and that seizure of this unlawful foreign currency is only temporary?

13     Did you put this in your report or not?  And leave the adjudication to

14     the Trial Chamber.

15        A.   It's not, as I see, simply a matter of adjudication.  It's the

16     Kotor Varos Crisis Staff or War Presidency later saying, We will decide

17     who can return and who cannot.  So that's the basis on which I talk about

18     Kotor Varos saying they didn't expect everyone to come back.

19             As for -- Obviously, no, I did not include this document or any

20     reference to federal laws on currency controls in my report.

21        Q.   Well, you mentioned foreign currency, because in paragraph 101 of

22     your report, you say that restrictions were in place and that foreign

23     currency was confiscated.  So how can you say that you never mentioned

24     it?

25        A.   That must be a mistake in translation.  I said I make no

Page 14639

 1     reference to federal regulations on currency controls.

 2             THE ACCUSED: [Interpretation] Can this document be admitted,

 3     please?

 4             JUDGE KWON:  Yes.

 5             THE REGISTRAR:  Exhibit D1307, Your Honours.

 6             JUDGE KWON:  We are sitting on a regular schedule today, until

 7     1.45.  It's time to take a break now.

 8             THE ACCUSED: [Interpretation] I would like the Trial Chamber to

 9     consider this issue:  I would like to remind you that Donia and Treanor

10     have not been examined.  I would like to ask you to give me enough time

11     to examine this witness, because these are the fundamentals on which the

12     indictment is based.  And this is Prosecution examination, and they took

13     twice as much time as they had previously indicated, and I would like to

14     get twice as much time as I was initially allocated, which is still below

15     what I had asked initially.

16             JUDGE KWON:  You still have a long way to go.

17             We'll have a break for 20 minutes and resume at quarter to 11.00.

18                           --- Recess taken at 10.22 a.m.

19                           --- On resuming at 10.47 a.m.

20             MR. ROBINSON:  Excuse me, Mr. President.

21             While we --

22             JUDGE KWON:  Yes, Mr. Robinson.

23             MR. ROBINSON:  While we're getting settled, if I can just take a

24     minute to withdraw our fourth motion for binding order against the

25     Government of Bosnia which was filed on the 7th of June.  And since then,

Page 14640

 1     we've received the materials that we had asked for.  Thank you.

 2             JUDGE KWON:  Thank you.  We had expected that.  Thank you.

 3             Yes, Mr. Karadzic, please continue.

 4             MR. KARADZIC: [Interpretation] Thank you.

 5        Q.   Ms. Hanson, in paragraph 100 of your report, you say -- well,

 6     we've read it already.  You say:

 7             [In English] "The Crisis Staffs oversaw the removal of non-Serbs

 8     from the municipalities by establishing 'committees for emigration,'

 9     'travel agencies' and 'exchange agencies'."

10             [Interpretation] Let us now address this through 65 ter 1067.

11             Here, at the top, it says:

12             "Decisions of the Crisis Staff shall be binding for all the

13     crisis staffs in the municipalities."

14             This is the Official Gazette of the ARK and the decisions of the

15     ARK Crisis Staff, signed by Radoslav Brdjanin.  It says here:

16             "These decisions of the Crisis Staff shall be submitted to the

17     Assembly of the Autonomous Region of Krajina for their verification as

18     soon as it is able to convene."

19             Item 6:

20             "An agency shall be established immediately that will work on the

21     problem of population resettlement."

22             Is that what you meant?  Were you referring to agencies of this

23     kind when you said that we oversaw the -- or, rather, that the crisis

24     staffs oversaw the removal of non-Serbs?

25        A.   What I see in a great many municipalities is an institution

Page 14641

 1     named, variously, Property -- exchange Agency, or Agency for Movement of

 2     Population, or so on.  It is established at the ARK level, but also at

 3     the municipal level, and these agencies were often named by the crisis

 4     staffs and war presidencies as the institutions through which the moving

 5     out of the population was to be organised, including the signing over of

 6     property.  So I don't mean simply this ARK one.  I also see them in many

 7     individual municipalities.

 8             THE ACCUSED: [Interpretation] We will get back to this issue of

 9     property being signed over.  This is what you're reading into this, but

10     this was not done, this was not implemented.  You don't know that, but

11     this was not implemented.

12             Can this please be received?

13             JUDGE KWON:  What did we see in this document, Mr. Karadzic?

14     What answer did we hear from the witness?

15             THE ACCUSED: [Interpretation] Well, in this -- well, it was an

16     evasive answer.  The answer was supposed to be -- did you mean agencies

17     described in Article 6 here:

18             "An agency shall be established that will work on the problem of

19     population resettlement"?

20             That was the question.

21             JUDGE KWON:  Can you answer the question, Ms. Hanson?

22             THE WITNESS:  Yes, I see agencies like that formed in many

23     municipalities.

24             JUDGE KWON:  Thank you.

25             That will be admitted.

Page 14642

 1             THE REGISTRAR:  As Exhibit D1308, Your Honours.

 2             THE ACCUSED: [Interpretation] Can we now look at 65 ter 795

 3     [Realtime transcript read in error "785"]?  The previous one was dated

 4     the 26th of May, and this one.

 5             The transcript says "785."  It should be "795."  We see the right

 6     document, but the transcript is incorrect.  It says "785."  It should

 7     read "795."

 8             MR. KARADZIC: [Interpretation]

 9        Q.   It says here that this is actually six days before the document

10     speaking about the formation of the agency.  The date is the 20th of May.

11     "Conclusions":

12             "First of all, there is no reason for the population of any

13     ethnic background to move out of the territory of the Autonomous Region

14     of Krajina."

15             Were you aware of the fact that this was the position taken by

16     the Crisis Staff of the Autonomous Region of Krajina?

17        A.   No, and I'm aware we've had many trials -- we've had trials on

18     the Crisis Staff in Autonomous Region of Krajina precisely on the

19     question of the removal of the population -- non-Serb population.

20        Q.   But do you see that the decision on the establishment of the

21     agency was actually taken one week after the position was adopted?  Does

22     this not tell you that this was something that was inevitable, and that

23     even after this conclusion, requests were made by people who wanted to

24     move out?

25        A.   What is this something that was inevitable; the creation of

Page 14643

 1     agencies?  I'm just not clear on your question.  What was inevitable?

 2        Q.   I'm asking you, Madam, whether you know that the initial position

 3     taken by the Crisis Staff of the Autonomous Region of Krajina was that

 4     there was no reason for people to move out, and yet a week later they had

 5     to establish an agency that would regulate that process.

 6        A.   I don't know that they had to establish an agency.  They chose

 7     to.  As for whether their -- what their public announcement was, that

 8     there was no reason for people to move out, as I said, we know and we've

 9     established for the trial that they did intend people to move out.

10        Q.   Did you include this position by this Crisis Staff in your

11     report?

12        A.   No, I did not.

13             THE ACCUSED: [Interpretation] Thank you.

14             Can this be received, please?

15             JUDGE KWON:  Yes.

16             THE REGISTRAR:  Exhibit D1309, Your Honours.

17             THE ACCUSED: [Interpretation] Now I would like us to look at

18     65 ter 398.  We are going back to Kotor Varos, the striking example -- a

19     municipality that is a striking example, representative of everything,

20     according to your report.

21             MR. KARADZIC: [Interpretation]

22        Q.   This is a bulletin published by the War Presidency of the

23     Municipality of Kotor Varos.  The date is the 24th of July, 1992.

24             And we can move on to page 2 both in the Serbian and in the

25     English versions.

Page 14644

 1             The third paragraph says:

 2             "The extremists from Vecici constantly harass the people of

 3     neighbouring villages, so that the people of the hamlet of Vasiljevici

 4     left the village and found shelter with their relatives in Vrbanjci.

 5             "The extremists from Bilice have, over the past few days, opened

 6     fire on Plana.  A few days ago, they treacherously killed Ranko Vucanovic

 7     while he was mowing a field, after which they set fire to the houses and

 8     cattle-sheds belonging to Djordje Djuric and Slavko Zaric.  Extremists

 9     from Vecici co-operate with the fundamentalists from Ravne and Kotor, who

10     set fire to the house of livestock breeder Andjelko Popovic in Zubovici.

11     Extremists spread fear among the people in the rest of Serbian villages

12     as well, forcing them to seek safety in other villages."

13             And then it goes on to say:

14             "The frequent attacks by extremists on Serbian settlements

15     indicate that there is a need to take more vigorous action in mopping up

16     the municipality's terrain and disarming the extremists in order to bring

17     back peace to the entire area."

18             Were you aware of the fact that in late July, there was this

19     terror campaign against Serb villages in the municipality of Kotor Varos,

20     and is this something that you've taken into consideration and included

21     in your report?

22        A.   I've read this bulletin.  I see many references to extremists and

23     fundamentalists as the enemy -- the Serbs describe the enemy as

24     extremists and fundamentalists.  So I've read this bulletin, so I

25     certainly saw this passage.  No, I did not include it in my report.

Page 14645

 1             THE ACCUSED: [Interpretation] Thank you.  Next page, please, in

 2     both English and Serbian.

 3        Q.   It says here in the third paragraph:

 4             "The War Presidency analysed information regarding appropriation

 5     of abandoned property from houses and other buildings, and, in order to

 6     prevent such conduct by individuals, ordered strengthened checks of entry

 7     and exit at all check-points in order to detect and put on record

 8     individuals who are taking advantage of the war situation in order to try

 9     to profit from it.  In contacts with the army command, their attention

10     was drawn to this, that they should do everything possible to preserve

11     and protect all property and prevent its unnecessary wanton destruction."

12             Did you know that the War Presidency was taking such efforts, and

13     did you include this in your report?

14        A.   I would note an error there in the translation.  It's not

15     "preserve and protect," it's "preserve and use all property."  The

16     written text is correct, but the simultaneous translation was wrong.

17             So, in fact, the army commands are being told to do everything

18     possible to preserve and use all property.  I was aware of the efforts to

19     control property, put it to the use of the municipality.  I did not

20     include this specific reference in my report.

21             THE ACCUSED: [Interpretation] Thank you.

22             Page 4, please, in Serbian and in English.

23             MR. KARADZIC: [Interpretation]

24        Q.   "List of deserted houses and flats.

25             "One development that should be noted is the abandoning of flats

Page 14646

 1     by extremists and other Muslims and Croats ..."

 2             Do you see, Ms. Hanson, that a distinction is being made between

 3     extremists and other Muslims and Croats?  You said a moment ago that we

 4     called our enemy "fundamentalists."  Do you see that a distinction here

 5     is made between citizens and extremists?

 6        A.   Here, the distinction is made, yes.

 7        Q.   Thank you.

 8             "So that as of today, some socially-owned flats have been

 9     abandoned, and some family houses, socially-owned flats, are those that

10     people used temporarily because they have occupancy rights."

11             Correct?

12        A.   Correct.

13        Q.   Thank you.

14             "In view of the fact that Croatian and Muslim families are being

15     resettled, those who wanted, it is to be expected that we will have a

16     large abandoned" --

17             THE INTERPRETER:  Mr. Karadzic is kindly asked to read more

18     slowly and give us a reference.

19             JUDGE KWON:  Interpreters were not able to catch up with you.

20     Could you repeat, and read slow, and reference as well?

21             THE ACCUSED: [Interpretation] It's the last paragraph:

22             "The list of deserted houses and flats ..."

23             "The War Presidency and Municipal Secretariat for Urban Planning

24     and Construction have done what was in their power; that is to say, they

25     have registered and sealed flats and houses, with people on duty in

Page 14647

 1     blocks of flats ..."

 2             Et cetera.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Isn't this protection of this property?

 5        A.   Yes.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             Can we see the next page.  The English page can remain briefly,

 8     but we need the next page in Serbian.

 9             MR. KARADZIC: [Interpretation]

10        Q.   "However, some flats have been broken into, and the Public

11     Security Station in Kotor Varos has received an express order from the

12     War Presidency to take all perpetrators of such acts into custody, and we

13     must persevere in this task, so that we expect unselfish assistance from

14     citizens and relevant CZ officials in discovering and reporting

15     perpetrators of these and similar acts.

16             "The owners of the abandoned flats grant temporary use of these

17     flats, through the Municipal Civil Protection Staff, to the workers whose

18     houses or flats had been destroyed in war."

19             Do you see that this is temporary use?

20        A.   Yes, here they say "temporary use."

21             THE ACCUSED: [Interpretation] Thank you.

22             Can we now see page 6 -- page 5 first in English and page 6 in

23     Serbian.

24             MR. KARADZIC: [Interpretation]

25        Q.   "Resettling the population."  It says:

Page 14648

 1             "The pernicious policy of Muslim and Croatian extremists is

 2     increasingly losing supporters even among other Muslims and Croats.  The

 3     population, which they had led astray and then let down, is increasingly

 4     and openly turning their backs on them.  Many reasonable people,

 5     including a group of Muslim intellectuals, realising the full absurdity

 6     of resisting the Serbian Army and new authorities ..."

 7             You can all read for yourselves.

 8             Next page, please.

 9             It says:

10             "The population, misled by empty promises, is seeking help from

11     the Serbian municipality ..."

12             And then it says:

13             "A considerable number of Muslims and Croats --"

14             THE INTERPRETER:  Could Mr. Karadzic please read more slowly,

15     please.

16             JUDGE KWON:  Mr. Karadzic, could you repeat.  Again, the

17     interpreters were not able to catch up with your speed.

18             THE ACCUSED: [Interpretation] I don't have to read every word.

19     We have the translation.

20             MR. KARADZIC: [Interpretation]

21        Q.   This paragraph explains that a considerable number of Croats and

22     Muslims are feeling the uncertainty and want to move to other parts of

23     Bosnia-Herzegovina or to join their families abroad.  I will read:

24             "The War Presidency and other relevant organs, showing great

25     understanding for these unfortunate people, and acting in accordance with

Page 14649

 1     the existing laws and regulations of the Serbian Republic of BH, the

 2     region and municipality, has begun resettling the population in an

 3     organised manner.  This activity is proceeding in accordance with the

 4     wishes expressed by these population groups.  To this end, transportation

 5     and appropriate protection have been provided ..."

 6             And it says further down that:

 7             "Three convoys have so far been organised and escorted."

 8             Do you see that this is about securing and escorting convoys and

 9     meeting the requests of those people?

10        A.   Yes.  I cite this in my report, I believe.  The municipality is

11     organising the transport.  They're acting in accordance with the laws of

12     the Serbian BH in the region, and they're moving out the population in

13     accordance with their understanding of the population's wishes.  They are

14     not trying to create conditions of security for the people in the

15     municipality.  They're not trying to move them to another part of the

16     municipality which is safe.  They're moving them out.

17        Q.   And how did you come to that conclusion?  From where does that

18     follow?  Isn't it clear from this that citizens are requesting this, it's

19     their wish?  It's not that the municipality's interpreting or

20     misinterpreting their wishes.  Where will we see an end to your

21     insinuations?

22        A.   I have a general understanding of the events throughout Bosnia,

23     and I believe the Court will hear or has heard witnesses who say that

24     they were not leaving entirely voluntarily.  I do not -- I haven't

25     followed the trial of this, I don't know what the witnesses have said,

Page 14650

 1     but I know from other trials that the general atmosphere there was such

 2     that people said they wanted to leave because the other -- the only other

 3     option they felt was death or detention; was unbearable circumstances.  I

 4     do not see the municipality here trying to simply move them to another

 5     part of the municipality.  We saw that with people on the front-line, we

 6     saw in an earlier document, being moved within the municipality to a

 7     safer place.  Here, they don't seem to be offered that.

 8             They are saying they want to leave, according to the

 9     War Presidency.  That's why I say that conclusion, that it's the

10     War Presidency saying these people want to leave.  I do not always --

11     cannot take that simply on face value, given the events in this and other

12     municipalities.  And, moreover, we see Kotor Varos later making sure that

13     people who left do not come back.

14        Q.   Did you make your report based on documentation or based on

15     rumours and the testimony of other witnesses in other trials?  What was

16     the subject of your work?  What was the material you used?

17        A.   I did not base -- I did not use any rumours, nor any witness

18     testimony in my report.  It was on documentation, based on documentation.

19             THE ACCUSED: [Interpretation] Then let's stick to the

20     documentation on which your report is based.

21             Can this document be admitted?

22             JUDGE KWON:  Yes.

23             THE REGISTRAR:  Exhibit D1310, Your Honours.

24             THE ACCUSED: [Interpretation] 65 ter 397, please.

25             MR. KARADZIC: [Interpretation]

Page 14651

 1        Q.   This is a session from the 26th of July of the same

 2     War Presidency.  Let's look at the last bullet point in item 2, where it

 3     says that:

 4             "For today's meeting of the War Presidency, reports should be

 5     prepared on the resettlement of population ..."

 6             The next page in English.

 7             "... resettlement of population, the harvest, humanitarian aid,

 8     the operation to seal flats and houses, and protection of abandoned

 9     property, the dead and the wounded, and reports on the take-over of goods

10     from shops."

11             Did you have this document in mind, and do you see what the

12     War Presidency is doing?

13        A.   The War Presidency is seeking reports on the resettlement of

14     population and other important things in the municipality, such as

15     goods -- resources, the harvest, and goods, and protection of -- the

16     sealing of property.

17        Q.   And the protection of property; right?

18        A.   Yes.

19             THE ACCUSED: [Interpretation] Thank you.

20             Can this be admitted?

21             JUDGE KWON:  Yes.

22             THE REGISTRAR:  Exhibit D1311, Your Honours.

23             THE ACCUSED: [Interpretation] 65 ter 246, please.

24             MR. KARADZIC: [Interpretation]

25        Q.   This is a session of the same Presidency, 28th of July, 1992.

Page 14652

 1     Look at item 2:

 2             "As part of this item, members of the War Presidency reported on

 3     their activities for the past day.  In relation to the report of the

 4     chief of the SJB on confiscating the money of individuals who are moving

 5     out, it was established that this was being done without anyone's orders;

 6     that is, in an unauthorised manner, and this can have a negative effect

 7     on the operation and the reputation of all of us ..."

 8             Et cetera.  And then an order was given to Vrbanjci Agricultural

 9     Co-operative to open up a shop in Vrbanjci.

10             Vrbanjci is not a Serb village, is it?

11        A.   I don't know about Vrbanjci.

12        Q.   Do you see the last paragraph in item 2?  The Executive Board --

13     the Executive Committee will begin to work.  It is their judgement that

14     the Executive Committee can start operating like in normal times?

15        A.   Yes, I see that paragraph.

16             THE ACCUSED: [Interpretation] Can this be admitted?

17             JUDGE KWON:  All you asked about this document is about Vrbanjci;

18     was that it?

19             THE WITNESS:  I would have a further comment on the first

20     paragraph, if I may.

21             JUDGE KWON:  Yes, please.

22             THE WITNESS:  That he notes, yes, that the money -- that money

23     has been confiscated from individuals moving out, apparently without

24     authorisation, but the money that is so confiscated will be used to help

25     families of soldiers killed and other essential costs of the

Page 14653

 1     municipality.  It is not being held temporarily and securely for those

 2     who will return.  The money taken from people moving out is to be used by

 3     the municipality.

 4             JUDGE KWON:  This will be admitted.

 5             THE REGISTRAR:  As Exhibit D1312, Your Honours.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   When will they return, Ms. Hanson?  When will they return?  That

 8     money is being used temporarily, because the municipality has the legal

 9     right to use all the material resources.  Instead of keeping it in their

10     treasury, they are using it for humanitarian purposes; correct?

11        A.   Instead of keeping it in the treasury, they're using it, yes.

12     And they say essential costs of the municipality, not necessarily

13     humanitarian ones.  But it's interesting that they claim it was done

14     without anybody's order, in an unauthorised manner, and yet the

15     municipality is able to take that money.  They clearly have it.  So the

16     question is:  Who's been doing the confiscating and how the

17     War Presidency, in this case, can actually use the money?  If it's been

18     individuals out of control, how can the War Presidency hold that money?

19             THE ACCUSED: [Interpretation] Well, we'll see.

20             65 ter 264, please, 264.

21             MR. KARADZIC: [Interpretation]

22        Q.   Here is what is being said the next day on the issue I'm asking

23     you about.  Item 1, bullet point 3:

24             "The problem of unprofessional work of the police was discussed,

25     as well as cases of theft and robbery committed by members of the police,

Page 14654

 1     who are imposing themselves as a force and authority unto itself.

 2             "It was concluded that more efforts should be invested in

 3     preventing and apprehending individuals involved in criminal activities."

 4             And point 6:

 5             "The service in charge of resettlement is required to set up

 6     records in local communes of people who wish to move away and to announce

 7     its arrival in any local commune three days in advance."

 8             Do you see that already on the next day, they reviewed the issue

 9     of unauthorised conduct by certain members of the police force?

10        A.   Yes, that's what the minutes show, although they don't expressly

11     connect it to the question of money taken from those leaving.  But they

12     do see the police operating unauthorised.  I do tie this into what we see

13     in general.  By late July, the crisis staffs -- the police are

14     increasingly saying that they have their own authority, their own chains

15     of command, and the War Presidency's authority over police is resented by

16     the police structures.  So we see, perhaps, another side of the coin

17     here, that the War Presidency is resenting the police setting themselves

18     up as a force and authority unto itself.

19             But, yes, they're discussing police committing robberies.  They

20     don't connect it to the question of money taken from those leaving, and

21     they are getting more detailed and more organised in their resettlement

22     service in item 6.

23        Q.   Doesn't it mean anything to you that this information about

24     unauthorised confiscation of money was given just the day before, and

25     already that this date that we are looking at, it's being discussed, this

Page 14655

 1     unauthorised conduct by police officers?

 2        A.   They could well be related.  I'm not denying.  They could well be

 3     related.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             Can this be admitted?

 6             JUDGE KWON:  Yes.

 7             THE REGISTRAR:  Exhibit D1313, Your Honours.

 8             THE ACCUSED: [Interpretation] 65 ter 321, please.

 9             MR. KARADZIC: [Interpretation]

10        Q.   This is a session of the War Presidency of the 31st of July,

11     1992.  We see the agenda, the analysis of the conclusions of the

12     Executive Committee, which is already in operation, and then further down

13     it says:

14             "In order to prevent robberies in houses that are abandoned,

15     warehouses need to be established to collect all the goods, that is,

16     movable property, that is at risk of being looted.

17             "The competent committee for sealing apartments and houses is to

18     carry out a check on the persons who have moved into apartments or houses

19     without authorisation and supply the Public Security Station with this

20     list.

21             "In the police station at Siprage, appropriate measures should be

22     taken to prevent unauthorised behaviour by the police."

23             Do you remember that Siprage is a majority Muslim place, and here

24     the War Presidency is demanding that the police act in accordance with

25     the law?

Page 14656

 1        A.   I said that I do not know the population of Siprage, but here,

 2     yes, I see that the War Presidency is ordering the police to act in

 3     accordance with the law.

 4        Q.   To stop unauthorised conduct by the police.  Isn't that an appeal

 5     to lawful behaviour, a demand for lawful behaviour?

 6        A.   Yes.

 7        Q.   Thank you.  And this previous paragraph, to protect property, it

 8     relates to the protection of abandoned property?

 9        A.   Yes, it relates to the protection of abandoned property.

10             THE ACCUSED: [Interpretation] Thank you.

11             Can this be received?

12             JUDGE KWON:  Yes.  D1313 -- D1314.  My apologies.

13             THE ACCUSED: [Interpretation] 65 ter 527, please.

14             The Prosecution attached -- or, rather, put together two

15     different sets of minutes, but we don't mind.

16             On page 1, it says in item 2 that some two members of special

17     units were arrested; that security should be organised for convoys.

18     Convoys are not organised, but security for them is organised.

19             Can we see the next page.

20             The next page says:

21             "The president, N. Djekanovic, informed the Presidency of the

22     visit of the representative of the ICRC and the conversation the night

23     before about the operation of civilian authorities and overcoming some

24     problems that yielded no result."

25             In English, we should have left the previous page on.  I'm sorry.

Page 14657

 1     The previous page in English:  "President Nedeljko Djekanovic."

 2             And then it says:

 3             "Zdravko Pejic informed the War Presidency about the

 4     instructions, that is, the order issued by President Karadzic in

 5     connection with resolving the issue of Vecici, and his demand that the

 6     civilian population be protected as much as possible."

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Did you include this in your report?

 9        A.   No, I didn't.

10        Q.   Can you explain why?

11        A.   Because I was looking at the overall course of events in

12     Kotor Varos and elsewhere, and the pattern I see was the moving out.  I

13     do see individual references to humanitarian law, the abiding by the --

14     I've seen other telegrams from Karadzic for other areas about protecting

15     the civilian population.  I've seen this.  I probably forwarded it to the

16     trial team as an example of Rule 68.  It is certainly -- indicates -- it

17     goes both ways.  It indicates communication between Karadzic and the

18     War Presidency, and it certainly says here that he's demanding the

19     civilian population be protected as much as possible.

20        Q.   But in your paragraph 147, you say that in -- Kotor Varos has

21     seen some of the worst violations, and that this was done on the orders

22     of the Government and Presidency of Republika Srpska.  So was it not

23     important to include this?  Under Rule 68, the Prosecution is under an

24     obligation to disclose exculpatory evidence to the accused, but an

25     unbiased expert is duty-bound to include and cover everything; is it not

Page 14658

 1     so?

 2        A.   I cannot possibly include and cover everything.  I do not tie --

 3     when I said that about the worst violence, I was thinking of the

 4     detention centres and the earlier killings and mass expulsions in

 5     Kotor Varos.  The Vecici incident in the fall of 1992 was clearly done

 6     with a lot of communication with the regional and republican level, also

 7     with the Red Cross.  There was a lot of discussion that was -- a lot of

 8     communication over that particular issue, which wound up with the

 9     civilian population being moved out, not protected and kept in its -- in

10     place.  The protection here that we see does not apparently extend to

11     keeping the population there.  They were moved out eventually.  That is a

12     specific incident, Vecici, which is later than most of the pattern.

13        Q.   And is this a pattern where the Serb authorities forcibly removed

14     the civilians from Vecici?  Is that the model, is that the pattern?

15        A.   My understanding of Vecici, although I am not familiar with the

16     exact crime base, is that it was surrounded by Serbian forces and, in the

17     end, they were -- the non-Serbs were allowed to move out rather than the

18     civilians being detained.  That's my understanding, but I do not claim to

19     know the entire history of events in Vecici.  I do know that this is an

20     example when the War Presidency was in close contact with the republican

21     level over the events.  I know that some killings followed in early

22     November, and I can't honestly remember whether they were the men of this

23     village or another place in a school.  But I do not see the

24     War Presidency here, or the republican level, intervening to calm the

25     situation down to the extent that the people were allowed to stay in

Page 14659

 1     their homes.

 2        Q.   Well, indeed.  We'll see now how they were detained and how those

 3     civilians were treated.

 4             Let me just remind you on the next page in the English version,

 5     that activities be taken and that an agreement be reached for a setting

 6     up bus service from Siprage to Banja Luka -- from Maslovare and Siprage

 7     to Banja Luka.  So does it not show to you that the authorities are

 8     trying to set up public transportation lines with Siprage?

 9             It's the third bullet in the English version, that:

10             "Activities and agreement begin for starting two bus lines from

11     Maslovare to Siprage to Banja Luka."

12             Siprage is a Muslim village.

13        A.   I don't know how many Muslims were in Siprage at this point in

14     October 1992.  Yes, the authorities are setting up transport lines.

15             THE ACCUSED: [Interpretation] Thank you.

16             I would like to tender this.

17             JUDGE KWON:  Yes.  Exhibit D1315.

18             THE ACCUSED: [Interpretation] Can we please look at 65 ter 268.

19     268.

20             The date is the 28th of August, a session of the War Presidency.

21     Let's look at item 2.  It's about the activities of the enemy in the

22     Bilice area - it's a Croatian village - and provocations on the line

23     facing Bastina, another Croatian village.  It says the question was asked

24     about issuing a pass to Captain Serdar, who travelled to the

25     Federal Republic of Yugoslavia --

Page 14660

 1             THE INTERPRETER:  Mr. Karadzic is asked to give us a reference

 2     and to speak more slowly.  Thank you.

 3             JUDGE KWON:  Just a minute.  It's in the middle of item 2.

 4             Could you repeat your question?

 5             THE ACCUSED: [Interpretation] Yes.

 6             Item 2:

 7             "President Djekanovic again informed those present about the

 8     issuing of passes, that this is in the exclusive responsibility of the

 9     Defence Office and not the War Presidency, and that they should check to

10     see who issued the pass.  Chief Tepic reported that he visited the branch

11     station in Siprage and had a meeting with the police, and attended a

12     meeting of civil authorities and leading figures of the local commune.

13     He insisted on an announcement of the names of police officers who have

14     been engaged in unauthorised dealings."

15             And a little bit further down:

16             "A report from the meeting in Siprage was submitted by the

17     chairman of the Executive Committee, Mr. Komljenovic."

18             And further down, it says:

19             "One ambulance should be acquired for the Siprage Local Commune."

20             And again further down:

21             "Organise a joint meeting with influential people from among the

22     Muslims."

23             Next:

24             "Civilian authorities and directors of private and socially-owned

25     enterprises in the Siprage Local Commune must try to overcome mutual

Page 14661

 1     disagreements and address open problems more effectively."

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Is this not what you contested, in other words, an effort to make

 4     the residents of Siprage feel safe and live more safely?

 5        A.   Once again, I have no personal knowledge of the make-up of the

 6     population of Siprage, nor the ethnic background of the police officers

 7     there.  So, yes, if Siprage is a Muslim settlement and there are still a

 8     substantial number of Muslims there, yes, this would be an example of a

 9     municipality taking care of all its citizens and trying to make them feel

10     secure.

11             THE ACCUSED: [Interpretation] Thank you.

12             Can this be admitted, please?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit D1316, Your Honours.

15             THE ACCUSED: [Interpretation] Thank you.

16             Can we please look at 65 ter 447.

17             MR. KARADZIC: [Interpretation]

18        Q.   This is the session of the 17th of September; again, the

19     War Presidency.  And in item 2, it says:

20             "The battalion commander, Slobodan Z.," Slobodan Zupljanin,

21     "briefed the War Presidency on the situation on the ground yesterday and

22     last night.  He said that there had not been any significant operations

23     yesterday, but an all-out attack on Vrbanjci took place in the morning.

24     A village was also attacked and set alight, and the people who happened

25     to be there were most probably killed."

Page 14662

 1             So in the second half of September, people are being killed in

 2     the villages around Kotor Varos.  In the municipality of Kotor Varos, the

 3     villages are torched, and people living there, who happened to be there,

 4     were probably killed?

 5        A.   You inform me that Vrbanjci was not a Serb settlement, so

 6     there's -- I can't recall now whether you said it was Muslim or Croat.

 7     So, yes, apparently there are still some non-Serbs there, and there's

 8     continued fighting.  It doesn't specify which other village was attacked

 9     and set alight and who was killed.  So there are still some non-Serbs at

10     this -- in Kotor Varos.  I never said that they expelled everyone.  In

11     fact, I make it clear that -- I made it clear in my testimony now that

12     Vecici was an incident in October, so it was not all finished then.

13        Q.   Vrbanjci is inhabited by a substantial number of Serbs, and it is

14     obvious that they came under an attack.  So this might be a reference to

15     them, that they might have been killed there, but we will look into that

16     later.  We will have a demography -- demographic composition of those

17     places, and you should have taken that into account.  You should know

18     that, given the type of report that you wrote.

19             Can we look at the next page.

20        A.   I don't see that it was Serbs that were attacked.  It doesn't say

21     who did the attack and who were the victims.

22        Q.   Well, if the commander of the Serb Army says that they came under

23     an attack in Vrbanjci, well, he probably is not going to report that he

24     attacked his own forces.

25             JUDGE KWON:  Let us proceed.  It's not for us to speculate.

Page 14663

 1             THE ACCUSED: [Interpretation] Can we look at the next page in the

 2     Serbian language.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Do you agree that here, in item 4, it says that some Serbs submit

 5     requests for permission to go to Belgrade to study, and a man is asking

 6     for the permission to go back to work, and the War Presidency did not

 7     give them their approval?  And these are Serbs, Milenko Naric and

 8     Jelenko Tepic, is that not so?

 9        A.   Well, apparently the request comes from the recruiting office, so

10     I would presume a student and somebody working would be military capable,

11     and, therefore, they're not being excused from the military offices --

12     from their military duties.

13             THE ACCUSED: [Interpretation] Thank you.

14             Can this be admitted, please?

15             JUDGE KWON:  Yes.

16             THE REGISTRAR:  Exhibit D1317, Your Honours.

17             THE ACCUSED: [Interpretation] Now I would like us to look at

18     65 ter 446.

19             MR. KARADZIC: [Interpretation]

20        Q.   This is the session that took place on the next day, the 18th of

21     September.  And in item 2, it says:

22             "The battalion commander, Slobodan Zupljanin, briefed the

23     War Presidency on the situation in the field yesterday and overnight.  He

24     stated that during the morning, the village of Serdari was attacked and

25     burned, and it has been established that on that occasion, the remains of

Page 14664

 1     16 bodies were found.  It is not known what happened to two people.  A

 2     woman and a man were taken away, and one soldier was wounded.  He noted

 3     that the village was not protected by the troops and that the bodies have

 4     been gathered and burial has been agreed, most probably in a mass grave.

 5     In order to prevent such things from happening again, he proposes that

 6     the village of Dolina be evacuated."

 7             Do you see here that the village of Serdari had come under

 8     attack - we can check in the census and see that it's a Serb

 9     village - that 16 people were killed, and that the village had not been

10     secured, it was not guarded by anyone, by the military?

11        A.   Yes, I see that they describe the attack on Serdari, which is a

12     Serb village.

13        Q.   Would you say that the War Presidency has control over the

14     municipality and the developments on this territory or that this is not

15     the case, that it does not have control?

16        A.   It does not have full control.  There's been a military attack on

17     a village, so it does not control the entire territory, no.

18             THE ACCUSED: [Interpretation] Thank you.

19             Can this be admitted, please?

20             JUDGE KWON:  Yes.

21             THE REGISTRAR:  Exhibit D1318, Your Honours.

22             THE ACCUSED: [Interpretation] Can we please look at 65 ter 473.

23             MR. KARADZIC: [Interpretation]

24        Q.   This is the session of the 18th of August, 1992.  And in item 2,

25     it says that:

Page 14665

 1             "Mane Tepic reported about the death of five soldiers and the

 2     wounding of one soldier in the Plana village area, and another soldier

 3     was wounded in the Ripiste area by extremists.  President Djekanovic

 4     proposed that the civilians, who are loyal and who are not mounting

 5     resistance, should be allowed to remain in their homes."

 6             Are you aware of the fact that -- well, you can see here that

 7     people are being killed every day in the depth of the Serb-held

 8     territory, and President Djekanovic proposes that the civilians, who are

 9     not mounting resistance, who are not opening fire, should remain in their

10     homes?

11        A.   I'm afraid I don't see it in this document.  Do we have the wrong

12     one called up?

13             THE ACCUSED: [Interpretation] 56, that's what we need, in the

14     English version.  I think that the Serb text is okay.  No, no, it's not.

15     We need 473.

16             Thank you for your warning.  I think that we did not have the

17     correct document.  It's the 56th session.  The ERN number is 0041-5728.

18             THE INTERPRETER:  Interpreter's correction:  5738.

19             THE ACCUSED: [Interpretation] 0041-5738.  It's 471; that's the

20     65 ter.

21             MR. KARADZIC: [Interpretation]

22        Q.   The date is the 18th of August.  Yes, the 56th session.

23     Mane Tepic informed the War Presidency that five soldiers were killed and

24     one wounded in the Plana area by the extremists.  So in the depth of the

25     Serb territory.  It's not the BH Army; it's the residents of the

Page 14666

 1     Kotor Varos municipality.  Is that right?

 2        A.   What's -- I'm sorry.  Who is doing the attacking, you mean?  That

 3     is not the BH Army; it's Kotor Varos residents?  We don't know who's been

 4     doing the attacking here.

 5        Q.   I am telling you that this is rebellion, armed actions launched

 6     by the residents, or, rather, ethnic Muslim extremists, in the depth of

 7     the Serb territory, far away from the front-lines.  Yes or no?

 8        A.   I don't see that here.  It doesn't tell you.

 9        Q.   Do you know that Siprage, Plana, Vecici, all those villages are

10     in the depth of the Serb territory, that they are far away from the

11     front-lines?

12        A.   Well, as I say, Vecici was, as I understood, surrounded by

13     Serbian troops, so it becomes a front-line, itself.  If you mean it

14     doesn't -- they're not adjacent to the BH-held territory, I don't know

15     the exact layout of the municipality, so I don't know that, their

16     location.  But I don't know where Plana and Ripiste are.  If you're

17     saying they're deep in the Serb-held part of the municipality, I have no

18     basis to disagree with that.  I don't know.

19        Q.   But, Madam, Vecici became surrounded once a show-down with the

20     terrorists started, but how could they otherwise have left the village of

21     Vecici to kill people mowing their fields?  Is it terrorism if extremists

22     in the depth of your territory kill peaceful residents mowing their

23     fields and if they set on fire their houses and barns?  Is that

24     terrorism?

25             JUDGE MORRISON:  Dr. Karadzic, first and foremost, you're

Page 14667

 1     disguising giving evidence as a question.  Secondly, you're putting facts

 2     that are certainly not contained in this document.

 3             MR. KARADZIC: [Interpretation] Thank you.

 4        Q.   Did you see this report, and did you include the contents thereof

 5     in your report?

 6        A.   I read it.  I can't remember if I included it.  I think I may

 7     have read it in the context of someone should go to Teslic to arrange for

 8     the transfer of people moving to Muslim territory:

 9             "Those who are loyal and not opposing us should be allowed to

10     stay."

11             I discussed the question of the declaration of loyalty in my

12     report, but I don't recall that I included this specifically in my

13     report.

14             THE ACCUSED: [Interpretation] Thank you.

15             Can this be admitted?

16             JUDGE KWON:  Yes.

17             THE REGISTRAR:  Exhibit D1319, Your Honours.

18             THE ACCUSED: [Interpretation] Can we please look at 65 ter 358.

19             MR. KARADZIC: [Interpretation]

20        Q.   These are the minutes of the session of the War Presidency.  The

21     date is the 10th of October, 1992.  Let us look at the penultimate

22     passage, where it says:

23             "Chairman Nedeljko Djekanovic said that an expanded meeting with

24     the representatives of the Croatian villages was held two days ago, and

25     among the attendees were Vojo Kupresanin, Stojan Zupljanin, and the HDZ

Page 14668

 1     representatives from Banja Luka.  It was agreed that in the next seven

 2     days, all people possessing weapons should surrender, that the HVO should

 3     be dissolved, that the chances of accomplishing this were realistic, and

 4     that efforts would be made to do something similar with the Muslim side."

 5             Ms. Hanson, do you see that by the 10th of October, until that

 6     date, Croat and Muslim armed groups were still in existence in the depth

 7     of the territory in Kotor Varos?

 8        A.   I don't know about the depth of the territory, but, yes, I agree

 9     with the rest.

10        Q.   And you can see that a meeting was held with the parents in

11     Siprage about the beginning of the school year and the problems - could

12     we please move on to the next page in English - problems faced at the

13     beginning of the school year.  We know that Siprage is a majority Muslim

14     village.

15             And then in item 4, you can see that there was a request from the

16     Kurjak family to move out, through the agency of UNPROFOR.  And the

17     Kurjaks are a very prominent Muslim family.  And there was a request by a

18     man known as Muskula.  He wanted to be allowed to move to Ravne, but this

19     was denied.

20             So do you agree that the departure was approved on a case-by-case

21     basis?  The prominent family, Kurjak, they were allowed to leave, and

22     Muskula, who was obviously a belligerent person, was not given approval

23     to go to Ravne.  So it's not about ethnicity; it's about one's character?

24             JUDGE KWON:  Yes, Ms. Sutherland.

25             MS. SUTHERLAND:  Your Honour, I'd ask that the accused refrain

Page 14669

 1     from adding his own interpretation on what's not in the document.

 2             JUDGE KWON:  Yes.  I think Judge Morrison has given the similar

 3     advice, Mr. Karadzic.

 4             What is your question?

 5             MR. KARADZIC: [Interpretation]

 6        Q.   My question is:  Do you see that the Kurjak family was allowed to

 7     leave, and Muskula's request to leave to the village of Ravne was denied?

 8        A.   I see these two specific requests dealt with here, but we've seen

 9     that the organisation of -- the departing of convoys was not done on a

10     case-by-case basis by the War Presidency.

11        Q.   You say that the Kurjak family was not allowed to leave and that

12     Muskula was prevented from going to Ravne; is that so?

13        A.   No, I didn't say that.  I said I see these two specific requests

14     dealt with, one from the Kurjak family and one from Muskula.  I see them

15     dealt with here.  But we have seen that there are busloads and busloads

16     and busloads of people who are leaving from Kotor Varos, and the

17     War Presidency is not debating each individual case.  Here, they are

18     debating individual requests, but that's not the same thing as the

19     movement of convoys of buses.

20             JUDGE KWON:  It's time to take a break, the second break for the

21     day.

22             We'll break for half an hour and resume at 12.30.

23             THE ACCUSED: [No interpretation].

24                           --- Recess taken at 12.01 p.m.

25                           --- On resuming at 12.33 p.m.

Page 14670

 1             JUDGE KWON:  Yes, we'll admit the last document.

 2             THE REGISTRAR:  As Exhibit D1320, Your Honours.

 3             JUDGE KWON:  Please continue, Mr. Karadzic.

 4             THE ACCUSED: [Interpretation] Thank you.

 5             Could we see 65 ter 311.  311.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   This is a session of the War Presidency of 13 October 1992, and

 8     it says that:

 9             "The president of the War Presidency, Nedeljko Djekanovic,

10     stressed there were certain problems about the start of the school year,

11     especially in Siprage, that the situation is still not unsatisfactory.

12     He informed those present about the visit of the International Red Cross,

13     their involvement in supervising the procedure and method of moving

14     people out, and stated that there would be more meetings with them and

15     with representatives of the Croatian people.  He also proposed that joint

16     talks be conducted and the other members of the War Presidency should be

17     included."

18             It says there's a contract on transportation, and the license for

19     operation for some enterprises being extended.

20             Did you know that the ICRC was involved in supervising the moving

21     out of the population?

22        A.   I see here that they visited.  I don't know how involved they

23     were in the earlier months.

24             THE ACCUSED: [Interpretation] Can this be received?

25             JUDGE KWON:  Yes.

Page 14671

 1             THE REGISTRAR:  Exhibit D1321, Your Honours.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             Can we see 65 ter 527.

 4             527, 103rd session held on the 21st of October --

 5             MS. SUTHERLAND:  Your Honour, sorry.  That's Exhibit D01315.

 6             JUDGE KWON:  Yes, we saw it earlier on today.  The 21st of

 7     October.

 8             THE ACCUSED: [Interpretation] Thank you.  Then I must be

 9     confused.

10             Let's move on.  Can we see 65 ter 711.

11             [In English] I said, Thank you, Madam Sutherland, and that is not

12     in the transcript.

13             MR. KARADZIC: [Interpretation]

14        Q.   We see this meeting held on 25 October 1992, an appeal from the

15     War Presidency, addressed to all those who temporarily removed - in other

16     words, stole - machinery and other property from abandoned houses.  It

17     says that:

18             "All persons found in possession of any movable property acquired

19     without valid documentation after the above dead-line will be handed over

20     to the competent court and criminal proceedings will be conducted against

21     them."

22             Number 3:

23             "The War Presidency appeals to all citizens who have information

24     on unlawful removal of property to report this to a competent organ to

25     allow more effective action to be taken in punishing those who have not

Page 14672

 1     handed items in by 1st November 1992."

 2             Do you know that this appeal was made and there were attempts

 3     made to recover what had been stolen?

 4        A.   I've seen this appeal.  We've seen mention in the report -- in

 5     the minutes of the War Presidency on recovery of stolen property.  So,

 6     yes, I'm generally aware of it, and I see that it's in keeping with the

 7     Presidency decision back from May of 1992 that says that crisis staffs

 8     are to dispose of the property of -- abandoned property and property of

 9     those who have left.  So it's the War Presidency asserting its authority

10     over abandoned property.

11        Q.   Do you agree that this was not achieved by 25 October; otherwise,

12     this appeal need not have been made?

13        A.   Right, movable property -- some movable property appears to have

14     been stolen, not fully under the control of the War Presidency, by

15     October 1992.

16             THE ACCUSED: [Interpretation] Thank you.

17             Can this be admitted?

18             JUDGE KWON:  Yes.

19             THE REGISTRAR:  Exhibit D1322, Your Honours.

20             THE ACCUSED: [Interpretation] 65 ter 302, please.

21             302.  Serbian page 9, English page 12.

22             MR. KARADZIC: [Interpretation]

23        Q.   In the document, itself, the minutes are in the wrong order, so

24     we are restoring the proper chronology.

25             So the session took place on 25 October.  It's the same body.

Page 14673

 1             Item 2, paragraph 2:

 2             "Captain Slobodan Zupljanin pointed out that there had been no

 3     operations and that regular activities were ongoing.  Contact had been

 4     established with Vecici, and a proposal was made to send a letter on

 5     behalf of the War Presidency, offering the evacuation of their women and

 6     children to avoid their getting killed.

 7             "In connection with this proposal, all the members of the

 8     Presidency stated their individual opinions, and the conclusion was

 9     adopted to issue a last call for the release of the women and children

10     and all our prisoners, and then to deal with this issue in a military

11     manner."

12             Is this removal of the population or saving people from combat

13     operations?

14        A.   Here, it would appear to be saving people from combat operations,

15     although it's not made clear where they're going to be evacuated to and

16     whether they'll be able to return.

17        Q.   Thank you.  Look at item 5.

18             We need the next page in English.

19             Sorry, item 3, second paragraph:

20             "Concerning the return of evacuated citizens to their homes,

21     everywhere where it's possible, these people should be returned to their

22     homes.  The Executive Committee will establish a board to list abandoned

23     property and make an order inviting all citizens to return abandoned

24     property."

25             So we see here a reference to an order to return these citizens

Page 14674

 1     to their homes; is that correct?

 2        A.   Yes, it's now complete.  What I didn't see in the first part, I

 3     now see here, that they're going to plan to return them as soon as

 4     possible.

 5             THE ACCUSED: [Interpretation] Thank you.

 6             Can we see page 6 in Serbian and English page 9.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   This is from the 28th of October.  Item 2, paragraph 2:

 9             "Zdravko Pejic informed the War Presidency about the results of

10     the negotiations with the villagers of Vecici and proposed a solution.

11             "The proposed solution was adopted, to accept the evacuation of

12     the civilian population on the condition that prisoners be released, and

13     then for the remaining part to be blocked by the army and destroyed.

14             "All the members of the War Presidency supported the proposed

15     solution to the issue of the Vecici village."

16             So the civilian population is being spared; right?

17        A.   Yes, here the civilian population is being spared.  I would just

18     note a difference between the B/C/S and the English, that they talk about

19     the -- [interpretation] list of prisoners.

20             [In English] Yes, as opposed to the release of the hostages in

21     the English.  I just note I don't see "hostages" there.

22        Q.   We agree, thank you.  There are many wrong translations, but it's

23     about releasing our prisoners and their civilians in order to leave this

24     zone which is at risk?

25        A.   Yes, and then destroy the rest.

Page 14675

 1             THE ACCUSED: [Interpretation] Thank you.

 2             Can we see page 5 in Serbian, page 4 in English.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   This is 29 October.  Item 2:

 5             "The War Presidency was informed of the situation on the ground

 6     by Slobodan Zupljanin and Zdravko Pejic.  Zdravko Pejic informed the

 7     War Presidency that there was an agreement with Vecici village to

 8     evacuate women and children and the imprisoned Serbs on Sunday."

 9             That's what we discussed a moment ago, the children and --

10        A.   The documents don't seem to be correct.  They're not matching.

11             MS. SUTHERLAND:  Your Honour, the 29th of October session is on

12     page 7 of the English.

13             THE ACCUSED: [Interpretation] Seven.  Thank you, that's correct,

14     7.  Item 2.  Thank you.

15             Can we see page 3 in Serbian and page 4 in English.

16             THE WITNESS:  Once again, I would note that it says "hostages" in

17     English, but simply "prisoners" in B/C/S.

18             MR. KARADZIC: [Interpretation] Thank you.

19        Q.   You know the Serbian language.  Do you agree there is a

20     difference between "prisoners," "detainees," and "hostages"?  Those are

21     three different categories; correct?

22        A.   I'm sorry, I was listening to the English, so, I mean, certainly

23     in English there's a difference between "prisoners" and "hostages."  But

24     if you could repeat the B/C/S, I can -- I can make a judgement on the

25     B/C/S.  But I wasn't listening to you; I was listening to the

Page 14676

 1     translation.

 2        Q.   Would you perhaps listen to the Serbian now.

 3             Is there a distinction in Serbian between "captive" or

 4     "detainee," on the one hand, and "prisoner," on the other?  "Captive" is

 5     somebody who was taken captive in combat, and "prisoner" is somebody --

 6             [In English] Prisoner and captive.  Prisoner, if it should be

 7     "prisoner of war" --

 8             [Interpretation] It should be "prisoner of war" as the equivalent

 9     of "zarobljenik."  It should be specified that it's a prisoner of war,

10     not just "prisoner"?

11        A.   I raised the issue mostly in relation to the word "hostage" in

12     English, which is "talac" in B/C/S.  The nuances of "zarobljenik" and

13     "zatvorenik" in general, yes, "zatvorenik" is a prisoner, "zarobljenik"

14     is someone who has been taken and imprisoned.  So a captive is not a bad

15     translation, but I'm not a professional translator and I don't want to

16     get into the nuances of the language.  I was pointing out the hostage

17     issue, not the question of "zarobljenik" versus "zatvorenik."

18        Q.   Thank you.  I wanted to take advantage of the fact that you know

19     the Serbian language, so you can clarify it.

20             Please look at this document.  It's the 1st of November, 1992.

21     Item 1:

22             "President Nedeljko Djekanovic made an introductory statement

23     about the problem of the evacuation of civilians from Vecici, with a view

24     to reaching agreement on this issue, as well as about the problems that

25     have arisen as a consequence of the corps command's prohibition against

Page 14677

 1     allowing civilians out of Vecici before all had laid down their arms.  He

 2     informed the War Presidency about Karadzic's position that civilians

 3     should be allowed to move out from Vecici, as well as that conditions

 4     should be provided for that.  He also informed the Presidency of a

 5     written document which he had signed at the corps command, at the request

 6     of General Talic, in which Talic distanced himself from the issue of

 7     releasing civilians from Vecici.  He urged that it was up to the

 8     War Presidency to decide whether it would allow the evacuation of

 9     civilians while assuming all responsibility for any subsequent

10     consequences, despite General Talic's reservation ..."

11             So you see that Karadzic takes one position and the commander of

12     the 1st Krajina Corps, General Talic, takes a different position, and now

13     the War Presidency is supposed to decide about it; is that correct?

14             My question, "Is that correct," was not interpreted.

15        A.   Well, we see that Talic is distancing himself.  He's not taking a

16     position.  Karadzic takes one position.  Talic is not taking a position,

17     which is perhaps taking another position.  And it's up to the

18     War Presidency to decide whether to allow to evacuate civilians.  But

19     they're clearly consulting with higher levels, want to get direction from

20     higher levels on it.

21        Q.   Thank you.  Do you see that they have to decide and they are

22     aware that they would be the ones bearing the consequences?

23        A.   Well, they're trying to make sure that they are -- that the --

24     that Karadzic is aware that they're getting direction from the higher

25     level.  They're trying to settle this difference between Karadzic and

Page 14678

 1     Talic, so they're not -- I don't see them as trying to act completely

 2     independently.  They're eager for direction, but they know that they have

 3     to take the actions on the ground.

 4        Q.   Remember paragraph 47 of your report -- sorry, 147, where this

 5     president of the War Presidency says evacuation was carried out with the

 6     consent of the Government and the Presidency of Republika Srpska.  Don't

 7     you see he's afraid of those consequences, and he invokes Karadzic's

 8     position to allow this?

 9        A.   I don't see that in the quotation.  You mean that in this

10     document here that I see, he's afraid of the consequences, or in the

11     quotation I use in my paragraph, do I see that he's afraid of the

12     consequences?  I see that he's eager for it -- to show that it was not

13     just the War Presidency acting on its own initiative, without any contact

14     with the republican level.  This specific incident did get a lot more

15     specific attention from the army command and from the president, as we

16     can see, than a lot of earlier moments.  I cannot see any other incident

17     that is so -- where the specifics are really checked at every level.  I

18     see later in this document here that it says -- the army major says:

19             "If Karadzic had his own solution to the problem, he should issue

20     an order which we would then execute."

21             So the army is similarly acknowledging Karadzic's authority here.

22     Everyone is trying to make sure that they're in agreement on what is to

23     be done, but it is the War Presidency that is taking the specific action

24     on the ground.

25             THE ACCUSED: [Interpretation] Thank you.

Page 14679

 1             Can we see page 1 in Serbian and in English.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   You will see that it's not exactly as you think.

 4             Page 1.

 5             The 2nd of November - that's the next day -

 6     "President Djekanovic" - that's item 2, paragraph 3:

 7             "President Djekanovic said that the state of chaos reigning in

 8     the city was mostly a consequence of the fact that the authorities were

 9     not functioning, and proposed that the Executive Board take the earliest

10     possible measures and prepare a proposal for clamping down on illicit

11     activities and restoring law and order."

12             Item 3:

13             "As part of this item of the agenda, discussing the problem of

14     appropriation of abandoned property, the failure to implement ..."

15             Et cetera, et cetera.

16             Do you agree this refers to the 2nd of November, 1992, and that

17     chaos still reigns in town?

18        A.   Well, it seems to be specifically in the town, with the problem

19     of soldiers getting drunk.  But, yes, they want to restore law and order

20     in the town, but the lieutenant-colonel remarks that the situation in the

21     field was calm, so it doesn't seem to be chaos everywhere.  It's a

22     problem of drunken soldiers and breakdown of law and order in the town.

23             THE ACCUSED: [Interpretation] Can we now see page 2 in both

24     versions to see how this interim session continued.  This was an interim

25     session of the War Presidency.

Page 14680

 1             We need the previous page in English.  This can't be the right

 2     one.

 3             MS. SUTHERLAND:  It's the next page, page 3 in English.

 4             THE ACCUSED: [Interpretation] Oh, sorry, it's the next page.

 5     Page 3 in English, so how the session continued.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   The extraordinary session of the War Presidency continued with

 8     Colonel Bogo Bogojevic informing all those present that he had received

 9     explicit orders from General Mladic that no one was allowed to leave

10     Vecici until the unconditional surrender of weapons was completed.

11             "President Djekanovic concluded there were differences between

12     Karadzic's position and Mladic's position and his order with respect to

13     this problem.

14             "Major Trivic declared the position of the corps command that

15     nobody was allowed to leave Vecici until the unconditional surrender of

16     arms was completed, and proposed that this be said to them once again so

17     that they might give thought to the idea of unconditional surrender.  He

18     also remarked that President Djekanovic, when talking to Karadzic, should

19     not tell him that his instructions were not being heeded, but to try and

20     convince him that the only right way to solve the issue of Vecici was

21     unconditional surrender, and asked Djekanovic to help --"

22             THE INTERPRETER:  Could Mr. Karadzic please slow down.  We are

23     not catching the question because we are still --

24             JUDGE KWON:  Your speed is too high so that the interpreters

25     couldn't catch up with it.  Repeat your last part of your question.

Page 14681

 1     I think you read out the last paragraph of the document.  We could all

 2     read it.  So what is your question, Mr. Karadzic?

 3             THE ACCUSED: [Interpretation] I do apologise to the interpreters,

 4     but I am under a great deal of pressure.  I don't have enough time to

 5     examine this witness.  And since I am reading, they can read the

 6     translation on the screen.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   So my question to you, Ms. Hanson, is:  Do you see that Karadzic

 9     wants the civilians to be allowed to go, but the military considers that

10     this would not be a favourable condition and that they advocate a

11     position whereby the Muslim soldiers should surrender their arms or

12     surrender themselves, and that the War Presidency is, in fact, trying to

13     make me accept this, but without letting me know that my instruction has

14     not been implemented?

15        A.   I agree with your first part of your question, that Karadzic

16     wants the civilians to be allowed to go, but the military wants

17     unconditional surrender.  It's the military suggesting to Djekanovic not

18     to tell Karadzic the whole truth, but whether Djekanovic did or didn't

19     follow that military advice, we don't know.  So that's the military's

20     advice to Djekanovic there.  But certainly there's a disagreement here

21     between the military and Karadzic, and the president of the Kotor Varos

22     War Presidency is talking to Karadzic about the issues.

23        Q.   Let me ask you this:  Is it clear from this that the civilians

24     want to leave, and that it was envisaged that the civilians could leave,

25     that the Muslim side has accepted that the civilians should leave, but

Page 14682

 1     that the Serb side wants the soldiers to leave alongside or at least to

 2     surrender their weapons or, indeed, themselves?

 3        A.   I'm sorry, but from this I don't see it's clear what the Muslims,

 4     in fact, want.  And the Serb side is divided.  By "Serb side," the

 5     War Presidency, and Karadzic seem to want one thing, and the military

 6     another.  So I see the Serb side is divided, but we don't know here what

 7     it is that the Muslims, themselves, want.

 8        Q.   Well, did we not see from the previous documents that

 9     negotiations had been held with the Muslims from Vecici, and that they

10     accepted the solution whereby the civilians and our prisoners of war

11     should be evacuated on Sunday?

12        A.   Yes, we saw that in an -- that's what the War Presidency wrote in

13     an earlier document.  I thought you were referring to this particular

14     document.

15             THE ACCUSED: [Interpretation] Thank you.

16             Can this be admitted, please?

17             JUDGE KWON:  Yes.

18             THE REGISTRAR:  Exhibit D1323, Your Honours.

19             THE ACCUSED: [Interpretation] All the minutes that are contained

20     in the Prosecution Exhibit 65 ter 302.

21             Can we please have 65 ter 705.

22             MR. KARADZIC: [Interpretation]

23        Q.   Here on the next day, the 3rd of November, we have another

24     session.  Item 2, it says:

25             "Captain Zupljanin informed the War Presidency of a report that

Page 14683

 1     the soldiers from Vecici have abandoned the village.  The population has

 2     also left the village and is in Hadzirica Potok."

 3             Item 3:

 4             "President Nedeljko Djekanovic informed the War Presidency about

 5     the communication from the Command of the 1st Banja Luka Corps and a list

 6     of persons who wished to returned to Kotor.

 7             "He wants to get a decision on the return of money to persons

 8     from Zabrdje who registered to move out but have not departed."

 9             As you know, Zabrdje is a Croatian village.  Now, does this

10     document, in fact, say those who registered as wanting to move out, and

11     they paid for it, and now, since they did not move out, they need to have

12     that money refunded?

13        A.   I don't know that Zabrdje is a Croatian village.  I have no basis

14     for knowing that.  And Djekanovic is saying the War Presidency should

15     decide whether to return the money.  It's not clear that they will, but

16     it seems to be the phrasing.  But they have to decide about whether to

17     return the money.

18        Q.   But he wants a decision to be made.  That is his demand.  The

19     president of the War Presidency is demanding that the decision be made on

20     the refund of that money to those people.  Does that sound like forcible

21     evacuation of those people from Zabrdje, given that they obviously could

22     decide on their own whether they wanted to move out or not?

23        A.   We don't know why they haven't moved out, and I assume, from the

24     phrasing, that his decision will be positive.  So if he's saying, We will

25     return the money, it seems to be, yeah, not persecution to return the

Page 14684

 1     money taken, but we don't know why they haven't departed.  In fact, we

 2     earlier saw the Crisis Staff or War Presidency saying, Some people

 3     haven't left and we have to find out why.  So we don't know here, nor do

 4     we know that people on the list will be allowed to return to Kotor.  But,

 5     yes, it seems to be here that they are not being forced to move out,

 6     these people, from this place.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             Can this be admitted?

 9             JUDGE KWON:  Yes.

10             THE REGISTRAR:  Exhibit D1324, Your Honours.

11             THE ACCUSED: [Interpretation] 65 ter 720, please.

12             MR. KARADZIC: [Interpretation]

13        Q.   This is dated the 7th of November, another session of the same

14     War Presidency.  Item 2:

15             "Lieutenant-Colonel Novakovic briefed the War Presidency on the

16     situation in the field yesterday and stated that the situation was quiet

17     and that the terrain is being combed daily, and features used by the

18     enemy are being discovered.  He also informed the War Presidency that

19     yesterday troops went into Vecici and captured three members of the

20     Green Berets."

21             Did you have this document at your disposal?

22        A.   Yes.

23             THE ACCUSED: [Interpretation] Thank you.

24             Can this be admitted?

25             JUDGE KWON:  Yes.

Page 14685

 1             THE REGISTRAR:  D1325, Your Honours.

 2             THE ACCUSED: [Interpretation] 65 ter 333, please.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   This is dated the 12th of November.  Item 2 or paragraph 2:

 5             "Colonel Novakovic stressed that the situation was peaceful,

 6     except for the fact that there was some shooting from the village of

 7     Dulici on Kalamande, that there is a great deal of fear there and people

 8     are demanding evacuation.  He proposed that somebody go out into the

 9     field and see how to deal with this."

10             Kalamande is a Serb village and Dulici is a Croatian village; is

11     that not so?

12        A.   I note that the English was not correct.  It's a different

13     session up in the English.  And I have absolutely no basis for saying the

14     ethnic make-up of Dulici and Kalamande.

15             THE ACCUSED: [Interpretation] Well, in the English version we

16     need 123, page 123, not 22, as it is now on the screen.

17             MR. KARADZIC: [Interpretation]

18        Q.   But you speak Serbian, and do you agree -- next page in the

19     English version.  Yes, 123, that's the one.

20             Well, is this a correct translation, that the situation was calm,

21     except that there was shooting from the area around the village of Dulici

22     towards Kalamande?

23        A.   Yes.

24             THE ACCUSED: [Interpretation] Thank you.

25             Can we go back to page -- or, rather, to the 122nd session, both

Page 14686

 1     in English and in Serbian.  That's the previous one.  The English is

 2     good.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   It says here, item 2:

 5             "President Djekanovic reported to the War Presidency on the

 6     results of the meeting with General Talic which was held yesterday in

 7     Doboj.  In connection with certain issues, the general suggested the

 8     following: that all irresponsible and undisciplined soldiers and

 9     mercenaries be detained and sent to the front-line near Orasje."

10             And further down:

11             "In the area of Siprage, there should be no activities that could

12     possibly aggravate the situation."

13             And then:

14             "In addition to the much-needed Serbian conscripts, the work

15     obligation should be imposed on retired people and a certain percentage

16     of other nationalities."

17             Do you know that the right to assign work obligation is defined

18     by an appropriate law?

19        A.   I'm not familiar with the specific law, but I know that it was a

20     legal concept, yes.  The work obligation is to make people stay in their

21     employment or to give them employment -- make them work at times of

22     emergencies, in general, yeah.

23        Q.   In the document, itself, do you agree that the word "mercenary"

24     was used instead of "loose cannon," which was the Serbian word used by

25     General Talic?  Item 2, first bullet point.

Page 14687

 1        A.   The Serbian is "slobodni strelci," "free shooters."  I don't know

 2     if that has a specific military meaning.

 3        Q.   "Slobodni strelci" means "uncontrolled elements," those who act

 4     as they see fit.  Well, do you know that this would be in the spirit of

 5     the Serbian language, that "loose cannon" would be a much better

 6     translation, somebody who is out of control and who's acting of their own

 7     free will?

 8        A.   I don't know.  I'm not familiar with the phrase, so I don't know

 9     its connotations.

10        Q.   Do you see that in the area of Siprage, General Talic suggested

11     that nothing should be done that could aggravate the situation and raise

12     the tensions there?

13        A.   Yes, I see that.

14        Q.   The last page, the last paragraph:

15             "The issues of bus lines in Kotor Varos and Maslovare and Siprage

16     area, and the power supply, were discussed."

17             Do you see that these authorities are dealing with the Muslim

18     population living in Siprage in a highly-responsible manner?

19        A.   I'm sorry, I don't see it in this -- oh, at the very end.  Yes,

20     now I see it.

21             Once again, all I know say is I don't know the make-up of Siprage

22     or Maslovare at this time, but I see that they are working on typical

23     municipal affairs, such as bus lines and electrical energy.

24             THE ACCUSED: [Interpretation] Well, if there is enough time, we

25     will present the census data to see who lived in what village.

Page 14688

 1             Can this please be admitted?

 2             JUDGE KWON:  Yes.

 3             THE REGISTRAR:  Exhibit D1326, Your Honours.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Ms. Hanson, I've spent two and a half sessions to try to prove

 6     that your position -- your conclusion in paragraph 147, that Kotor Varos

 7     is the municipality that witnessed some of the worst violations, is not

 8     correct.  Do you have any other document that would run contrary to the

 9     documents that I presented which all show that there were responsible

10     authorities operating there?  Do you have anything that would support

11     your position?

12        A.   I have documents where the Crisis Staff sets up the sawmill

13     detention centre.  The minutes of the Crisis Staff/War Presidency,

14     themselves, do not describe what went on, nor do they describe in detail

15     why busloads and busloads and busloads of people were shipped out, why

16     they wanted to leave.  So the documents of Kotor Varos War Presidency,

17     itself, do not describe the wider situation on the ground, the kind of

18     fighting, the kind of acts that were going on that drove people to leave.

19     So the "worst violations" phrase, I agree, is not -- is not supported by

20     the documents there.  It was just from a general understanding of events

21     in Bosnia.  What I am emphasizing is here that the departure of

22     hundreds -- thousands of people was organised by the municipal

23     authorities, that they regarded themselves as acting in accordance with

24     the laws and the instructions of their republic, that they contacted the

25     republic level where necessary.  For this one issue of Vecici, there was

Page 14689

 1     a lot of attention and lot of communication with the republican level.

 2     But the minutes of the crisis staffs/war presidencies, themselves, do not

 3     detail the actions taken against Muslims and Croats and what those people

 4     were suffering that led them to seek to depart in mass numbers.

 5        Q.   Well, based on what documents did you conclude that the worst

 6     violations of rights were committed there, if that is not contained in

 7     the documents of the War Presidency?

 8        A.   As I said, that would be outside documents in my report, just my

 9     understanding of the crimes -- the events on the ground.

10        Q.   Thank you.  Ms. Hanson, we have a problem, then, with your

11     understanding.

12             JUDGE KWON:  Please proceed.  I was about to ask that, What did

13     you base your understanding on?

14             Please continue, Mr. Karadzic.  I didn't want to intervene in

15     your cross-examination.

16             THE ACCUSED: [Interpretation] You're welcome to it.  Please

17     intervene as often as you feel like it.

18             MR. KARADZIC: [Interpretation]

19        Q.   Ms. Hanson, do you know that by that time, at least three

20     agreements were reached by the warring factions in Bosnia and

21     Herzegovina, agreements allowing free resettlement of the population,

22     including the obligation on the part of the municipal authorities to

23     secure the convoys?  On the 22nd of May, in late July, in late August,

24     and the fourth one on the 30th of September and the 1st of October,

25     agreements were signed to ensure that the population could be resettled

Page 14690

 1     in the areas where they felt safe, and the municipal authorities were

 2     under an obligation to secure the convoys?

 3        A.   I am not specifically aware of those agreements, but I would --

 4     when you say "free resettlement," I don't think it applies to the kind of

 5     resettlement we're talking about here where it's free and voluntary and

 6     simply moving them to a safe location.  The point is that the movement --

 7     the mass movement of populations -- the phrase "free resettlement"

 8     implies it's entirely voluntary, and that is not what I'm talking about

 9     when I talk about forcible removal.

10             As for the obligation to secure the convoys, I do see lots of

11     documents of municipal authorities securing the convoys, but not an equal

12     attention paid to the security of the population in-situ.  The non-Serb

13     population, that is.

14             JUDGE KWON:  Ms. Hanson, I thought Mr. Karadzic would ask that

15     question.

16             In response to the last question of Mr. Karadzic as to the basis

17     for the conclusion in the last paragraph, i.e., paragraph 147, you

18     answered that:

19             "It would be outside documents in my report, just my

20     understanding of the crimes, the events on the ground."

21             Could you expand on that?

22             THE WITNESS:  Quite aside from my work on this memo, which became

23     an expert report, I and my team, we researched a lot of different topics

24     and were familiar with the findings and the investigations.  So I know

25     that we have a report on the various municipalities, our understanding of

Page 14691

 1     events in municipalities.  I have access to a lot of different documents,

 2     so it's part of my job to know, in general, the pattern.  When I look at

 3     something specifically like the issue of crisis staffs, I would cite

 4     every document that I feel relevant, but I already have a framework for

 5     understanding events.  And I think I was thinking of the detention

 6     centres and some killings that I knew of there.  Perhaps -- I mean, I

 7     don't say that it was the worst, but I know that -- I know that some --

 8     there were some very bad killings and detention centres in Kotor Varos,

 9     and that was on my mind, that it was not -- it was not a municipality

10     untouched by war.  Perhaps the phrase "some of the worst" is too

11     rhetorical.  I mean, I wouldn't want to list the municipalities, in terms

12     of which was the worst, but if I would say the top 10, I think

13     Kotor Varos would be up there.  It certainly would not be one of the most

14     peaceful municipalities.

15             I was emphasizing there the communications with the top level,

16     that the War Presidency was not acting on its own, was not considering

17     itself an independent organ, untied to the republic level, but I did not,

18     as you see, try and examine each crime base and connect each crisis staff

19     to each crime base.  I was more describing, in general, what crisis

20     staffs did.  And where I know that crimes were committed or killings

21     occurred, detention centres occurred, forcible removals occurred, I would

22     consider that some of the violence to which I refer.

23             JUDGE KWON:  When you refer to reports or documents, would those

24     include statements of witnesses or a summary of them?

25             THE WITNESS:  In general, no.  I don't have a lot to do with

Page 14692

 1     witness statements, and I don't use them as a basis of my memos.  I

 2     certainly come across them, yes, in the course of my research, but I and

 3     my team really base ourselves on the documents, not witness work.

 4             JUDGE KWON:  Back to you, Mr. Karadzic.

 5             THE ACCUSED: [Interpretation] Thank you.  Ma'am, we'll have to

 6     get back to this.

 7             Thank you, Your Excellency, for this clarification that was

 8     elicited, and it makes my job easier.  I don't have that much experience.

 9             MR. KARADZIC: [Interpretation]

10        Q.   You mentioned in your report that one of the municipalities that

11     forcibly removed non-Serbs was Bosanski Petrovac; in other words, that

12     Bosanski Petrovac was one of those municipalities.

13             I don't know if this has been interpreted.  I would kindly ask

14     you to interpret everything that I am saying.

15        A.   I did not hear a question interpreted.

16             I discussed the actions of the Petrovac Crisis Staff.  Certainly,

17     it matches the pattern of setting up agencies, having people who want to

18     leave sign a form stating that they are leaving their property to the

19     state.  So, I discuss it, yes, in the section on the removal of

20     population.

21        Q.   But in paragraph 95, you couch it in much harsher terms.  Let me

22     read:

23             [In English] "To protect the interests of the Serbs, crisis

24     staffs ensured Serb power on the ground by enabling the persecution and

25     forcible removal of non-Serbs."

Page 14693

 1             [Interpretation] And then in paragraph 96, you say:

 2             [In English] "Crisis staffs ordered the arrest of individuals and

 3     whole categories of people, such as all people of Croatian nationality in

 4     Bosanski Samac or all military-capable Muslims who could possibly harm

 5     the Serbs in Bosanski Petrovac."

 6             [Interpretation] Is that correct?

 7        A.   That's what my report says, yes.

 8        Q.   And in paragraph 100, you say:

 9             [In English] "The Crisis Staffs oversaw the removal of non-Serbs

10     from the municipalities by establishing 'committees for emigration,'

11     'travel agencies' and 'exchange agencies.'  When a delegation of Muslims

12     inquired of the War Commission in Bosanski Petrovac whether the Muslims

13     would have a guarantee of safety in the municipality, the War Commission

14     responded by forming a commission for the departure of the Muslims."

15             So those crisis staffs in Kotor Varos and in Bosanski Petrovac,

16     and in probably other municipalities, are accused by you not that they

17     enabled people to leave, if they wished, but that they forcibly drove out

18     Muslims and Croats from their municipalities, is that correct, and you

19     give selectively two or three documents, leaving out a mass of documents

20     that create or provide a completely different broader picture; is that

21     correct?

22        A.   The second half of your sentence -- your question, or your second

23     question, no, I don't agree that I leave out a mass of documents that

24     don't -- that show a different picture.  I -- the quotation I give, these

25     Muslims went to the War Commission, they said, Can you guarantee our

Page 14694

 1     safety?  And the War Commission's response was to form a commission for

 2     them to leave.  I take that as a pretty clear action, We're not going to

 3     guarantee your safety, but we will allow you to leave in an organised

 4     way, provided you leave your property to the municipality.

 5        Q.   Did they say, We won't, or, We can't because the municipality is

 6     too large?  These small distortions, Ms. Hanson, are they something an

 7     unbiased expert witness is allowed to make?

 8        A.   They didn't say, "we can't," they didn't say, "we won't."  Their

 9     answer was to form a commission for mass emigration or a commission for

10     the departure of Muslims.  That was their answer.  Because the

11     municipality is too large, I don't see that saying that at all.  If we

12     can look at the document, we can see what --

13             THE ACCUSED: [Interpretation] Can we see 65 ter 1062.  Let's move

14     to Bosanski Petrovac, although both these municipalities are now out of

15     the indictment, but you describe them in your report.

16             JUDGE KWON:  Yes, Ms. Sutherland.

17             MS. SUTHERLAND:  Your Honour, I don't know whether Mr. Karadzic

18     is going to show Ms. Hanson that document or whether he wants me to deal

19     with it in redirect.  She asked to look at the document, which was

20     65 ter 1115.

21             THE ACCUSED: [Interpretation] The time will come.  We'll come to

22     that, Madam Sutherland, and there will be also your redirect.

23             JUDGE KWON:  Very well.  Let us proceed.

24             THE ACCUSED: [No Interpretation]

25             THE INTERPRETER:  Microphone, please.

Page 14695

 1             JUDGE KWON:  Could you repeat your question with your microphone

 2     on.

 3             THE ACCUSED: [Interpretation] I haven't asked my question yet.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Here is the question:  This is a session of the Crisis Staff of

 6     24 May 1992.  Item 2:

 7             "The president read the order on general mobilisation in the

 8     Serbian Republic Bosnia-Herzegovina and made an introductory statement

 9     thereon.  Mr. Miljevic submitted a report about the coverage of military

10     conscripts by mobilisation, stressing that for the most part, all

11     military-capable citizens have already been engaged on one or another

12     basis and that mobilisation in our municipality has been carried out even

13     before this order."

14             JUDGE KWON:  Please slow down when reading out documents.  And do

15     we have the proper English page now?

16             THE ACCUSED: [Interpretation] The next page in the English.

17             MR. KARADZIC: [Interpretation]

18        Q.   So you see that everyone who could possibly be engaged has been

19     engaged already, and the representative of the 2nd Corps thinks it is now

20     pointless to talk about plans because all plans were practically

21     invalidated by the factual situation.  He stressed the need to

22     immediately implement civil order and military discipline.

23             Can we see the Serbian page 2 and English 2, because we need

24     item 3.

25             Item 3 of the order relates to the imposition of order and

Page 14696

 1     prevention of looting of military, private, and social property.

 2             Can we see item 3 in Serbian, and the next page in English,

 3     probably.

 4             Item 3 in Serbian.

 5             Military police organs of the Public Security Station are ordered

 6     to prevent looting.  This is the month of May, a month and a half into

 7     the war.  Did you take into account these efforts to prevent looting,

 8     including looting of private property?

 9             JUDGE KWON:  It should be page 3 in English and the previous page

10     in Serbian as well, I take it.

11             MR. KARADZIC: [Interpretation]

12        Q.   Point 3.  Very early on the 24th of May, an order is given to all

13     forces, both civilian and military police, to be engaged in preventing

14     looting?

15        A.   I did not include this in my report.  I see that as part of the

16     regular work of crisis staffs, but I didn't -- I didn't -- couldn't

17     possibly cover every single thing that crisis staffs dealt with.  I

18     covered the issues that I considered relevant to the needs of the trial

19     team.  I mean, I could -- as I said before, I could have done everything

20     on fuel and commodity reserves, or here the -- so looting, but it

21     doesn't -- the issues that I was looking at were more specific, those,

22     you know, of my terms of reference.  That's why I wouldn't include

23     everything that crisis staffs did or dealt with.

24             THE ACCUSED: [Interpretation] Can we see the next page in both

25     versions.

Page 14697

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Do you see item 2, where it says that ethnic Muslims, members of

 3     the Muslim community, will be engaged in companies and organisations?  In

 4     other words, it means they will not be mobilised; correct?

 5        A.   Yes.  There's no reference to them not being mobilised.  It says

 6     that the companies can request.  I mean, they will be employed if the

 7     companies that employ them request it.

 8        Q.   Thank you.  In item 3, do you see that through the mass media:

 9             "... information will be made public about the Military Court

10     starting to work, with a seat in Drvar; it shall be emphasised that all

11     persons who violate the rules, and especially those caught in the act or

12     proven to be guilty of stealing, looting, et cetera shall be severely

13     punished."

14             The last sentence:

15             "Very harsh verdicts will be meted out and implemented

16     immediately."

17             Did you include this in your report?

18        A.   No, I did not.

19             THE ACCUSED: [Interpretation] Thank you.

20             Can this be admitted?

21             JUDGE KWON:  Yes.

22             THE REGISTRAR:  Exhibit D1327, Your Honours.

23             JUDGE KWON:  Five minutes for today, Mr. Karadzic.

24             THE ACCUSED: [Interpretation] Thank you.

25             65 ter 1068, please.

Page 14698

 1             MR. KARADZIC: [Interpretation]

 2        Q.   Minutes of the 28th May.  Item 1:  Dragan Milanovic.  He was an

 3     assistant to the deputy to the Assembly of Bosnia and Herzegovina:

 4             "Dragan Milanovic informed the Crisis Staff about the results,

 5     the outcome of his talks with representatives of the citizens' forum of

 6     the SDA.  Representatives of the SDA, Safet Hidic and Mustafa Ferizovic,

 7     are spreading alarming rumours among Muslim citizens by saying that the

 8     Muslim citizens want to emigrate collectively.  However, according to

 9     Dragan Ivanic, the citizens' forum has a unanimous stand with respect to

10     Muslims being loyal citizens and supporting the authorities.  They accuse

11     Safet Hidic and Mustafa Ferizovic of illegal arming and say that the

12     citizens' forum is prepared to take part in solving the refugee problems,

13     together with other citizens, and that they are ready for the

14     mobilisation; also, that they say they will try to find out the names of

15     the people who are being trained to become members of the Green Berets."

16             JUDGE KWON:  Slow down, slow down.

17             MR. KARADZIC: [Interpretation]

18        Q.   This is almost the end of the second month of the war, in May.

19     Did you include in your report this document, which speaks of the talks

20     with the citizens' forum, normal, regular citizens who distanced

21     themselves from extremists?

22        A.   No, I did not include this.

23        Q.   Do you have an explanation why, why you did not include such a

24     striking example of the care authorities took on their own citizens?

25        A.   Well, if you compare this to the document I did include of, We

Page 14699

 1     should arrest all military-capable Muslims who could possibly harm the

 2     Serbs, I have to strike a balance.  Which is more plausible, which is it

 3     a better reflection of the situation.  Petrovac was, as I recall, one of

 4     the most thoroughly Serb municipalities, very few Muslims.  Not

 5     surprising that the Muslims who were there are eager to demonstrate their

 6     loyalty and stay, if they can, because they are outnumbered.

 7             I don't show every document where crisis staffs are not doing bad

 8     things.  The question is:  What did they do, and did they -- what was

 9     their role in the state, was the essential questions of my report.

10             So when a municipal authority is prepared to protect its own

11     people, that is, to my mind, the municipal authority doing its job,

12     regardless of the nationality of its citizens.  The problem is when the

13     municipal authority is -- says its job is to defend the interests of only

14     one ethnic group and it has other citizens in its territory.

15             THE ACCUSED: [Interpretation] We'll come to that.

16             Can this document be admitted?

17             JUDGE KWON:  Yes, it will be admitted.

18             THE REGISTRAR:  Exhibit D1328, Your Honours.

19             JUDGE KWON:  And adjourn for today.

20             Tomorrow at 9.00.

21             THE ACCUSED: [Interpretation] I'm kindly you asking for

22     additional time.  If I can get Friday too.

23             JUDGE KWON:  No.  You have about two and a half -- between two

24     and a half and three hours left.

25             THE ACCUSED: [Interpretation] I am asking for Friday too, because

Page 14700

 1     the Prosecution spent double time than they announced.

 2             JUDGE KWON:  Yes, Ms. Sutherland.

 3             MS. SUTHERLAND:  Your Honour, that's not correct.  We had 2.5

 4     hours in the schedule, and I took, I think, approximately 3.5 hours.  So

 5     it was additional time, but not double.

 6             JUDGE KWON:  Tomorrow, 9.00.

 7                           [The witness stands down]

 8                           --- Whereupon the hearing adjourned at 1.45, to be

 9                           reconvened on Wednesday, the 15th day of June,

10                           2011, at 9.00 a.m.