110617ED

Page 14820

1 that we have received all of this new material, and it has an impact on

2 our being able to continue.

3 Thank you.

4 JUDGE KWON: Very well. It's well noted. Thank you,

5 Mr. Robinson.

6 Let's bring in the witness.

7 [The witness takes the stand]

8 WITNESS: DOROTHEA HANSON [Resumed]

9 JUDGE KWON: Good morning, Ms. Hanson.

10 Very well, Mr. Karadzic.

11 THE ACCUSED: Thank you, Excellency.

12 [Interpretation] Good morning, Your Excellencies. Good morning

13 to everyone.

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

15 MR. KARADZIC: [Interpretation]

16 Q. Good morning, Ms. Hanson.

17 A. Good morning.

18 Q. May I draw your attention to the paragraph 57 in your report,

19 where you say:

20 [In English] "Of all the various forces within the crisis staffs

21 dealt -- which the crisis staffs dealt, it is in military matters that we

22 see the greatest variety of patterns. One pattern does not describe the

23 whole range of relations between the crisis staffs and the military

24 forces."

25 [Interpretation] Is that right?

Page 14821

1 A. It's not paragraph 57.

2 Q. [In English] 67.

3 A. Yes, that's what I say.

4 Q. [Interpretation] Further down in paragraph 73, you say:

5 [In English] "Tensions could arise, however, in those places

6 where municipal SDS leaders felt that the JNA was not sufficiently

7 supporting their cause, and the JNA Command was suspicious of the

8 military pretensions of the crisis staffs."

9 [Interpretation] Right?

10 A. Yes, that's what it says there.

11 Q. 74:

12 [In English] "Some crisis staffs took a different tack: rather

13 than co-operate with the existing military structure, they were involved

14 in arming of local Serbs and the formation of Serb units ..."

15 [Interpretation] And so on.

16 Is that right?

17 A. Yes, that's what it says.

18 Q. Can you provide documents showing that crisis staffs formed any

19 units outside the VRS?

20 A. I wasn't referring to the VRS. I was referring to the time

21 before the VRS was formed.

22 Q. Do you mean the Territorial Defence and Civilian Protection;

23 correct?

24 A. I mean, it was formed outside of the JNA or the existing

25 Territorial Defence structures, some of these Serb units.

Page 14822

1 Q. Do you know that according to the law, Territorial Defence and

2 Civilian Protection belong to the municipality, regardless of the JNA?

3 Have you seen -- did you see on Thursday the Law on All People's Defence?

4 It is obviously within the jurisdiction of the municipality; correct?

5 A. Yes, on Wednesday we saw the Law on All People's Defence. It is

6 within the jurisdiction of the municipal authorities. But this sort of

7 thing, I do have several documents that show that the SDS was forming

8 units outside of the municipal TO or the JNA.

9 Q. We'll come back to that, but we should bear in mind the law that

10 you did not take into account.

11 Let us look at paragraph 79:

12 [In English] "Some cries staffs did, indeed, explicitly distance

13 themselves from direct military command."

14 [Interpretation] And you give some examples. And in

15 paragraph 81.

16 [In English] "Other crisis staffs were also prepared to interpret

17 the government and party instructions in a manner that gave them command

18 authority."

19 [Interpretation] And then in 90:

20 [In English] "As the Kotor Varos Crisis Staff put it, 'The Crisis

21 Staff reviewed the work of the SJB. The Crisis Staff concluded that it

22 does not have the right to interfere with the professional work of the

23 police and army.'"

24 And then --

25 JUDGE KWON: What paragraph was it?

Page 14823

1 THE ACCUSED: [Interpretation] 90.

2 MR. KARADZIC: [Interpretation]

3 Q. And 91:

4 [In English] "Other crisis staffs were much more assertive in

5 their authority over the Serb police forces."

6 [Interpretation] Is that right?

7 A. Yes.

8 Q. Thus, in some municipalities it is one way, and in other

9 municipalities it is another way, so things vary from municipality to

10 municipality; correct? Both with regard to the army, and with regard to

11 the police, and to the Territorial Defence and the JNA; correct?

12 A. I say that within discussion -- discussing the army, that is, the

13 JNA, TO, VRS, there's a spectrum with considerable variation upon it. I

14 say that with regards to the police, there's a more consistent pattern

15 because, for one thing, the commander of the police was always a part of

16 the Crisis Staff. So there are distinctions, as I see, between

17 Kotor Varos -- the statement from Kotor Varos and what we see in some

18 other places about the extent of their interference in the execution of

19 the police tasks, but I see the relationship as much closer and

20 consistent with the police than with the other armed forces.

21 Q. Thank you. How many municipalities have you reviewed?

22 A. I reviewed the documents that we have in our -- in evidence. For

23 some municipalities, we have a great deal of documentary evidence. For

24 others, we have only a very scanty collection. Some, we have none at

25 all. So I would have to count through. You can see in my footnotes I

Page 14824

1 bolded the name of each municipality for ease, and I -- just sort of

2 going through the footnotes, we could go through and count. But I really

3 couldn't say, off the top of my head, how many municipalities I had

4 actually documents from.

5 Q. May I then assist you, perhaps? Is that 10, 15 municipalities?

6 A. No, more than that.

7 Q. Is it 20? Let's begin with the west, Novi Grad. You took that

8 into consideration; right?

9 A. Do you mean the former Bosanski Novi or Sarajevo Novi Grad? I

10 did both.

11 Q. Bosanski Novi. Bosanski Novi, Prijedor - I'll

12 enumerate - Sanski Most, Kljuc, Banja Luka? Did you take Banja Luka into

13 account?

14 A. There are a few documents of a Banja Luka municipal Crisis Staff.

15 I didn't have many of those. It was hard to distinguish between the ARK

16 Crisis Staff and the Banja Luka municipal authorities. But I do have

17 something from the Banja Luka War Presidency, so, yes.

18 Q. Thank you. Krupa, Petrovac -- Bosanska Krupa, Petrovac,

19 Sanski Most. In the middle municipalities, that's Bosanski Brod, Brcko,

20 Bijeljina --

21 A. Brcko and Bijeljina, I had documents. Bosanski Brod, I'm not

22 sure I did. Only one or two, if I found anything.

23 Q. Good. Do you know how many municipalities there were in

24 Republika Srpska?

25 A. In Republika Srpska, no, I don't. As I said, there were about

Page 14825

1 100 and -- between 100 and 110 municipalities in the Republic of

2 Bosnia-Herzegovina. I don't know how many -- presumably fewer in

3 Republika Srpska.

4 Q. Do you accept that with the newly-established municipalities --

5 entire municipalities that were not divided and the newly-established

6 municipalities, Republika Srpska had 61 or 62 municipalities, but there

7 were 55 major large municipalities; correct?

8 A. That seems quite possible, but I have no basis for -- I never

9 counted them in that way, so I have no basis for agreeing or disagreeing.

10 It seems likely.

11 Q. So you perhaps took into account one-third or perhaps one half of

12 all municipalities and studied them, and within that framework, you were

13 not able to establish a pattern. Why didn't you take into account the

14 other municipalities? If it is about state policy of persecuting a

15 minority population coming from the central level, from a powerful leader

16 or an authoritarian regime, as your predecessor called them, if it's

17 state policy, it is applied in the entire republic, whereas you did not

18 manage to find and determine a pattern even in this limited number of

19 municipalities. Why did you not review all the municipalities to tell us

20 what those central authorities did?

21 A. As I said, I am limited by the evidence in the possession of the

22 OTP. I reviewed the evidence available to me as thoroughly as possible.

23 There were many municipalities where evidence was never collected. I

24 have noted throughout my report that I'm limited to the evidence

25 available to me.

Page 14826

1 Q. Thank you. Are you trying to say the Prosecution did not take

2 into account the entire territory of Republika Srpska, that it did not

3 investigate what happened in Srbac, for instance? Have you heard of that

4 municipality, Srbac?

5 A. Yes, I've heard of Srbac.

6 Q. Do you know that in that municipality, some Muslims remained to

7 live together with us, they were in the army, they were well respected,

8 and there was not a single problem? Did you investigate -- did you

9 research why?

10 A. I am aware that some Muslims remained in Srbac. I am not -- I

11 have no basis to say how well respected they were or that there was not a

12 single problem. I did not -- I was unable to investigate Srbac because

13 there was no evidence available to me on Srbac. I didn't have access to

14 the Crisis Staff minutes, or decisions, or the Municipal Gazette of

15 Srbac.

16 Q. Thank you. Are you saying that they did not give evidence to

17 you, or was there no evidence? Did the OTP ever investigate things and

18 see -- in Srbac in order to find whether the Serbs there were guilty of

19 any sins? I'm asking you about Srbac, but I'm not limiting myself to

20 that. They made your selection for you, and you, in your turn, were even

21 more selective and you narrowed down your research to some documents

22 which do not portray a very clear picture, they do not reflect what you

23 purport to say in your report; right?

24 A. There are many questions that you've asked. Do you want me to

25 take them in order or just answer the last one?

Page 14827

1 JUDGE KWON: It's in your hands, Ms. Hanson.

2 THE WITNESS: All right.

3 "They" did not -- who are "they"? I have complete access to all

4 the evidence in the possession of the OTP. Their evidence is limited to

5 where they investigated and collected evidence or what evidence they have

6 received from other sources. Nobody limited my access to anything. I

7 had access to everything there is here. I did not go out into the field

8 and collect evidence of non-investigated -- uninvestigated

9 municipalities. I believe they did not investigate Srbac because they

10 did not hear of crimes committed there. The OTP's mandate is to

11 investigate crimes, not to investigate the entire history of every

12 municipality in the Republika Srpska.

13 That there were some places where crimes did not occur does not

14 alter the crimes that did occur.

15 Q. Ms. Hanson, you are trying to establish a link between the

16 central authorities and the chaotic events that happened during the civil

17 war. Why didn't you list any of the municipalities where crimes did not

18 happen, and why didn't you say, then, these people did not listen to what

19 Karadzic was saying or Karadzic did not instigate any crimes there?

20 You're talking about central authorities. The president of a republic is

21 on trial here, and the OTP is trying to prove that what was happening

22 during the case of a civil war was something that the central authorities

23 were behind. Why didn't you take into account so many municipalities

24 where nothing of the sort happened?

25 A. I do not say -- I do not say that Karadzic instigated crimes

Page 14828

1 here. I say that crisis staffs considered themselves part of the Bosnian

2 Serb state system and took orders and instructions from the central

3 organs from the republican level. And I do, indeed, cite in my footnotes

4 some municipalities where, as far as I know, crimes have never been

5 charged, simply because they provided evidence of the links, not of links

6 that had to do with crimes, but simply links. For example,

7 Bosanska Dubica, Bosanska Gradiska, I had their municipal gazettes. I

8 don't know how those came into the possession of the OTP, but they were

9 there, I looked at them and I saw that they received Djeric's

10 instructions, formed crisis staffs, recognised the republican authority.

11 I also see that those crisis staffs, in municipalities where there was a

12 large-scale moving out of population, that they did it with such a

13 similar pattern that it's hard to believe it was spontaneous that they

14 all formed these agencies, that they all met and said, Let's move out our

15 Muslims; not all of them, but the seven municipalities. But I see enough

16 co-ordination between municipalities on the issue of moving out and I see

17 instructions and communications on various topics from the republican

18 level to the municipality that I concluded that there was -- that the

19 crisis staffs operated as part of a state system and that there appears

20 to be, among the municipalities, a co-ordinated policy of moving out the

21 population.

22 JUDGE KWON: Ms. Hanson, let me put it this way: You stated that

23 there was some places where crimes did not occur, does not alter the

24 crimes that did occur. Would it be, by any chance, possible that they

25 have an impact upon whether they are of a systematic and widespread

Page 14829

1 nature?

2 THE WITNESS: Well, certainly if the majority of municipalities

3 were peaceful and a minority were not, that would influence how

4 widespread and systematic.

5 JUDGE KWON: Thank you.

6 Mr. Karadzic, please continue.

7 MR. KARADZIC: [Interpretation] Thank you.

8 Q. Ms. Hanson, before the Judge's question, you tried to speculate

9 as to what may have influenced things and how. Why speculate, if you

10 have Prime Minister Djeric's instruction before you? In his instructions

11 on the work of the crisis staffs, did Prime Minister Djeric aid, abet, or

12 instigate or order crimes, or was the situation just the opposite?

13 A. In his instructions, Djeric does not aid, abet, or instigate or

14 order crimes.

15 Q. Did he provide instructions against crimes, against violations of

16 the humanitarian law and so on and so forth? You established that his

17 instructions were implemented -- or, rather, first received and then

18 implemented by the crisis staffs; right?

19 A. His instructions do provide instructions against crimes --

20 against violations of humanitarian law. I do establish that his

21 instructions were received and implemented in the municipalities. The

22 extent of implementation -- the extent of implementation of every single

23 article, no, I don't go through that, but I do show that they were

24 received as an indication of the role of the crisis staffs in the state

25 system, and I see crisis staffs operating according to these

Page 14830

1 instructions.

2 Q. Thank you. In your paragraph 45, you say:

3 [In English] "The municipal crisis staffs co-ordinated the Serb

4 military, political and administrative forces involved in seizing and

5 maintaining control on the ground."

6 [Interpretation] Let's leave "seizing and maintaining control"

7 aside in the municipalities which were growing. Why didn't you stick to

8 your own statement that they co-ordinated the existing structures of

9 power? Why did you turn them into some sort of authorities beyond the

10 existing authorities?

11 A. I'm sorry, it's not in paragraph 45.

12 Q. [In English] 145.

13 A. 145, okay.

14 Q. 145:

15 "The municipal crisis staffs co-ordinated the Serb military ..."

16 [Interpretation] You adhere by your statement that the crisis

17 staffs co-ordinated Serbian military, political and administrative

18 powers?

19 A. Yes. I stand by that.

20 Q. Did you establish that not even in the limited number of

21 municipalities, you could not find the pattern? Some of the

22 municipalities that you studied did not even have a crisis staff, and

23 there are so many municipalities that you did not even take into account.

24 You say, in your paragraph 67, that there was no pattern?

25 A. In paragraph 67, I'm referring explicitly to the question of

Page 14831

1 relations with the military, and I say that the minimum that we see

2 everywhere is co-ordination with the military, support of the military

3 effort. That is the common denominator. That is not in contradiction

4 with paragraph 145, which says they co-ordinated the military, political

5 and administrative forces. I think that's not -- I think that those are

6 compatible.

7 Obviously, if I was tasked to look at Bosnian Serb municipal

8 crisis staffs, I looked at the crisis staffs. I didn't look at the

9 municipalities where there were not crisis staffs formed, because that

10 was not my tasking. I do note that there are some municipalities that

11 did not form crisis staffs before March, when, in the Assembly, you

12 called for Serb municipalities to form crisis staffs. I note that most

13 of the crisis staffs formed in December are in the Serb minority

14 municipalities. Again, all I can say is I'm limited to the evidence

15 available and to my tasking.

16 Q. Ms. Hanson, I have to ask you once again. Do you make a

17 distinction between the crisis staffs of the party which were suggested

18 in December and the crisis staffs of the municipalities which I referred

19 to on the 27th of March, 1992?

20 A. No, I do not, because I saw that you did not in your speeches in

21 1994 and 1995 that you did not. You refer explicitly back to A and B as

22 the basis of the municipal authorities. I see in Kljuc and Sanski Most

23 an emphasis on the continuity. I see in many documents of these crisis

24 staffs, their use of the SDS, even as interchangeable with the Serbian

25 municipality, the use of the stamps interchangeably. I see continuity

Page 14832

1 between the A and B crisis staffs and December crisis staffs and those

2 operating as municipal authorities in the spring.

3 JUDGE KWON: Ms. Hanson, did you note the transcript?

4 THE WITNESS: Yes. My apologies to the interpreters.

5 THE ACCUSED: [Interpretation] Could the Court please produce P12;

6 English 2, Serbian 1.

7 MR. KARADZIC: [Interpretation].

8 Q. Let us see what, on the 14th February, the day after the

9 beginning of the Conference on Bosnia, I said about the same things that

10 you are talking about.

11 The document number is P12. We need number 2 in English.

12 I'm going to read for you from the second paragraph in the

13 Serbian language:

14 "We hope that the deputies are stepping up their activity in the

15 municipalities, because as we concluded the last time, representatives is

16 authority for a party and parties are a service to elected people, to the

17 people and to people, elected by the people to carry out -- to carry out

18 the political will of the people."

19 JUDGE KWON: Slow down. Slow down.

20 THE INTERPRETER: [Previous translation continues]... passages in

21 English. Thank you.

22 MR. KARADZIC: [Interpretation] "To carry out the political will

23 of the people."

24 So:

25 Party officials are not authority to us. Authority for us are,

Page 14833

1 first of all, the representatives, then representatives in municipal

2 assemblies and others.

3 Q. Why did you neglect the fact that a party is not power, but only

4 a service to the people who elected them?

5 A. I do not think I neglected that. In my report, I note that in

6 the period January to March, while the SDS deputies were creating the

7 organs and institutions of the Bosnian Serb state, the emphasis was on

8 the role of the Assembly deputies as the link back to the municipalities.

9 As we know, they were to be on the crisis staffs. And you said that they

10 must go and sit next to the president of the municipal assemblies because

11 the president -- the municipal president is the one who actually takes

12 action on the ground, but the Assembly deputies are to make sure that

13 their actions are in line with SDS policy.

14 I do emphasise the authority of the deputies there. The deputies

15 are part of the crisis staffs. So are the municipal officials part of

16 the crisis staffs. So I don't think that I neglected that.

17 THE ACCUSED: [Microphone not activated]

18 JUDGE KWON: Mr. Karadzic, microphone.

19 THE ACCUSED: [Interpretation] I apologise.

20 Let's look at D034, and let's see what I referred to on the 27th

21 of March, when I asked the municipalities to form their crisis staffs.

22 MR. KARADZIC: [Interpretation]

23 Q. In the previous document, you see that power consists of

24 representatives, deputies, and other elected people, whereas the party

25 and the crisis staffs only helped them, they act as their service. The

Page 14834

1 deputies and representatives who were elected by the people constitute

2 the real power. Am I right in saying that?

3 A. The deputies made up the Bosnian Serb republican-level assembly

4 which, as I said, set up the organs of the Bosnian Serb state. But to

5 say that they are the only power, that ignores the entire municipal

6 structure, also ignores the Government of the Republic of

7 Bosnia-Herzegovina. So, no, I can't agree that only SDS deputies to the

8 Bosnian Serb Assembly are the only power.

9 Q. Well, I have mentioned everybody; deputies in the municipalities

10 and others, secretaries, and so on and so forth. What I was trying to

11 emphasise is that a party people were not the power, but just a service.

12 But it's very difficult for you to understand that, Ms. Hanson, I

13 believe.

14 We have not got the right document. It has to be 65 ter 1000.

15 Maybe it will be easier to get the right document in this way. D304,

16 304.

17 There's something wrong with my articulation, obviously.

18 Serbian, 33; English, 20, please.

19 MR. KARADZIC: [Interpretation]

20 Q. I will be reading for you:

21 [In English] "When you returned ..."

22 [Interpretation] In English, it's in the middle of the page. I'm

23 going to read now:

24 "When you returned to your municipalities, especially the

25 newly-formed municipalities, I ask you to do what you are required and

Page 14835

1 entitled to do under the law. The moment you arrive in your

2 municipalities, you must urgently establish crisis staffs. You must try

3 to organise the people so that they can defend themselves."

4 And so on and so forth.

5 Do you note here that I am referring to the law here? Why didn't

6 you check what law was I referring to in here?

7 A. I see that you are referring to the law. As I said, I have

8 checked the laws and did not find any reference to crisis staffs.

9 Q. However, Madam, did you find a law pursuant to which a

10 municipality is entitled to carry out measures in emergencies? Why

11 didn't you ask yourself, What law did Karadzic have in mind here?

12 A. As I indicate in my section on the legislative origins, I thought

13 the law you were referring to was regarding municipal presidencies or all

14 people's defence committees. The question, though, is how much --

15 whether the law allowed for, for example, the formation of Serbian

16 municipalities, and how much the law -- the letter of the law was your

17 main motivation here.

18 I see you appealed to the law. I didn't inquire into the

19 legality, under the existing legal system, of each step, because I do not

20 say that the formation of crisis staffs, themselves, was a crime. I take

21 no stand on that. I describe the process of how they were formed, but

22 whether they were legal or not I see as not as important as what they

23 did.

24 JUDGE BAIRD: Ms. Hanson, I don't quite follow that. I don't.

25 Please help me.

Page 14836

1 THE WITNESS: It may be that crisis staffs were, indeed, provided

2 for under the legislation of the Republic of Bosnia-Herzegovina, but it

3 doesn't follow that if they -- which I haven't seen, as I emphasised, I

4 haven't seen that. But the relationship between the laws of the Republic

5 of Bosnia-Herzegovina and the actions of the crisis staffs set up in

6 self-declared Serbian municipalities, even if there is a legal basis for

7 them - we certainly see there's a legal basis for municipal

8 presidency - that doesn't change whether the actions they took that

9 contributed to the crimes occurring -- it doesn't mean that their actions

10 were legal, even if they had a legal basis. You can have a

11 legally-elected president who commits -- and I'm not -- that was just an

12 example, I'm not referring to Dr. Karadzic in this case, but of any

13 country -- who commits crimes, but even if he's legally elected, he can

14 still commit a crime.

15 JUDGE BAIRD: Thank you.

16 THE ACCUSED: [Interpretation] Thank you.

17 Well, let's look at how all that looked like in Bosanski Novi,

18 which is a municipality that you mentioned.

19 Could the Court please produce --

20 THE INTERPRETER: Could the accused please repeat the number.

21 JUDGE KWON: Could you repeat the number, Mr. Karadzic?

22 THE ACCUSED: [Interpretation] 65 ter 6733.

23 MR. KARADZIC: [Interpretation]

24 Q. Please pay attention to this document. This is a report on the

25 work of the Crisis Staff of the Municipality of Bosanski Novi. Look at

Page 14837

1 the second paragraph, where it says:

2 "The other significant issues and questions which were not easy

3 to answer at the time was, for example --"

4 It has to be the following page in English.

5 And where it says:

6 "On the 20th of April, a part of Novska Battalion," still the

7 JNA, "that was stationed in Jasenovac, under the command of

8 Veljko Risojevic, came to Bosanski Novi and raised Serbian flag at

9 certain spots in the town, forcibly and under the threat of arms."

10 And now I'm just giving you my interpretation. You can see that

11 the Crisis Staff opposed that.

12 And then it says:

13 "On the 4th of May, concrete talks started with the

14 representatives of the SDA with regard to the current political

15 situation."

16 The war had been going on for a month already, and they were

17 still talking to the SDA; right?

18 A. Yes, it says they're talking to the SDA.

19 THE ACCUSED: [Interpretation] We need the second page in Serbian,

20 the third in English. I believe that you have already moved on to that.

21 MR. KARADZIC: [Interpretation]

22 Q. And then it says:

23 "A curfew was introduced between 10.00 in the evening and 5.00 in

24 the morning, and all the unlawfully-armed individuals and paramilitaries

25 were invited to immediately, and not later than 11 May 1992, surrender

Page 14838

1 their weapons either to the Municipal TO Staff or to the SJB. After that

2 dead-line, searches," it says here --

3 People were not being disarmed along the ethnic --

4 JUDGE KWON: I don't think the interpreters are following at this

5 time.

6 THE INTERPRETER: It's very difficult to find the passage,

7 Your Honour.

8 JUDGE KWON: Of course.

9 Could you check the transcript and start again from the part they

10 missed?

11 MR. KARADZIC: [Interpretation]

12 Q. "The curfew between 22 and 05 hours was introduced, and all the

13 unlawfully-armed individuals and paramilitaries were invited to

14 immediately, and no later than 11 May 1992, surrender their weapons

15 either to the Municipal TO Staff or to the SJB. After this dead-line has

16 passed, the searches will be carried out, with the application of force."

17 Ms. Hanson, are they issuing this appeal to just one ethnic

18 community? What was the basis for the surrender of weapons? Was it the

19 ethnic background of those who held them or was it the fact that they had

20 been unlawfully obtained?

21 A. In this text, they do not mention any ethnic criteria. In

22 practice, I believe, in many municipalities, that was not the case in

23 practice, but the terminology used in this public report does not give

24 any ethnic criteria, simply the question of how the arms were -- whether

25 they were illegally armed or not.

Page 14839

1 Q. Well, let us stick to the subject, Ms. Hanson. Now we're not

2 talking about other municipalities. We're talking about these

3 municipalities. And you have seen that the Crisis Staff opposed the Serb

4 from the JNA who hoisted a Serbian flag over the municipality, and you

5 see that it's not only the Muslims who are invited to surrender the

6 weapons, but all of those who possess them illegally. Have we agreed

7 about that?

8 A. Yes, that's what it says here.

9 THE ACCUSED: [Interpretation] Thank you.

10 Can we see page 4 in English about negotiations. I'm retelling

11 it. Every time when representatives of the SDA -- it's midway through

12 the paragraph:

13 "In the implementation of the government's decision on disarming,

14 every time the SDA representatives demonstrated their readiness to make

15 it a success. However, it turned out that they either had little

16 influence on the Muslim people or they were working on a double track,

17 saying one thing at the negotiations, then saying something completely

18 different to their supporters and members."

19 Can we see page 5 in English.

20 You will see in this paragraph: "On the 11th of May ..."

21 That's how it begins. No, it's the same page. Oh, sorry. The

22 beginning is on page 4.

23 There was some shoot-out by the military police, and the

24 Crisis Staff criticises that:

25 "Pursuant to an order by the Crisis Staff issued around 1800

Page 14840

1 hours on the 11th of May, a cease-fire was ordered."

2 Next page in English.

3 And it says:

4 "On the 12th of May, the commander of the TO Municipal Staff

5 presented the current situation and said that TO Staff did not issue any

6 order to open fire at Bosanski Novi, except for Blagaj, where warning

7 shots were fired when the military police was attacked."

8 It was his assessment that he is unable to control the entire

9 territory of the municipalities because certain groups are distancing

10 themselves from the chain of command and not obeying orders, and are

11 acting on their own initiative.

12 "Such large numbers of armed people should be placed under

13 control."

14 JUDGE KWON: Just a second.

15 Yes, Ms. Sutherland.

16 MS. SUTHERLAND: Does Mr. Karadzic have a question for

17 Ms. Hanson? He's just reading text into the record.

18 JUDGE KWON: I take it he's going to ask a question very soon.

19 Yes.

20 THE ACCUSED: [Interpretation] Yes, yes, let me just finish this

21 paragraph, and then I'll come up with a question:

22 "Simultaneously, other armed groups are appearing that hold

23 themselves out to be regular units, army or police. But in reality, they

24 are under nobody's control and they are looting.

25 "After this analysis of the situation, the Crisis Staff distanced

Page 14841

1 itself from the activities by all such illegal groups and paramilitary

2 formations."

3 That was the conclusion dated 13 May 1992.

4 MR. KARADZIC: [Interpretation]

5 Q. Did you observe, Ms. Hanson, and did you put it in your report

6 that there had been groups under nobody's control, and that the

7 Crisis Staff disowned and said that they need to be placed under control?

8 A. No, I did not put that in my report.

9 Q. Thank you. Do you know that the war in Croatia had only just

10 finished, if at all, and that all over that territory there were many

11 people milling around, carrying their weapons from that war, because

12 Bosanski Novi is just on the border with Croatia? Perhaps the

13 Trial Chamber doesn't know that.

14 A. I know that many troops were withdrawn from Croatia into Bosnia

15 at this time. Many units withdrew and were relocated in Bosnia. But

16 people milling around, carrying weapons, I find that difficult to address

17 directly. But, yes, we see that in several municipalities, that the

18 return of troops, largely Serb, from Croatia raised tensions in many

19 municipalities.

20 Q. Was the local Muslim population armed, and did the Muslims also

21 have their own uncontrolled elements or were they under somebody's

22 control?

23 A. This document indicates that the Muslims did have arms. It

24 doesn't give an indication of what kind or how many, nor does it give an

25 indication of whether they were under somebody's control. As I said, the

Page 14842

1 troops that were returning were largely Serb and had been armed by the

2 JNA, came back as JNA units. Most Muslims did not respond to the call-up

3 for the war in Croatia, so they were not getting arms from the JNA. I

4 have no basis to answer whether they were uncontrolled or under

5 somebody's control.

6 THE ACCUSED: [Interpretation] Thank you.

7 Can we see English page 6 and Serbian 4.

8 MR. KARADZIC: [Interpretation]

9 Q. It says nicely here all these organs were ordered, and that's at

10 the beginning of page 4 in Serbian, and the beginning of the paragraph is

11 after the analysis of that situation. These organs were ordered and

12 authorised to disable the work of such illegal persons and remove them

13 from the territory of the municipality.

14 Further below, it says:

15 "With the involvement of the military police and the

16 Banja Luka Corps, to assess the situation and search the terrain,

17 including incidents in Urije town."

18 And then it enumerates other places along the Japra River Valley

19 where order needs to be restored. And then it says:

20 "The assignments given by the Crisis Staff have not been

21 implemented. Field reports say that TO armed forces are not under the

22 control and subordination of the TO Municipal Staff Command."

23 End of that paragraph:

24 "TO forces must be placed under strict control of the superior

25 command, and all instances ..."

Page 14843

1 That's actually page 7 in English.

2 "... and all instances of violation of discipline and misconduct

3 shall be severely punished."

4 And below that:

5 "The Government of the Serbian Republic of Bosnia and Herzegovina

6 belatedly sent instructions to all municipalities."

7 In our municipality, it was received on the 20th of May. It was

8 sent on the 26th of April, but arrived on the 20th of May; correct?

9 A. Yes, that's what this report says.

10 THE ACCUSED: [Interpretation] Thank you.

11 Can we see Serbian page 5 --

12 THE INTERPRETER: Thank you for indicating where the passage is

13 in English.

14 MR. KARADZIC: [Interpretation]

15 Q. ... all these are officials, members of the municipal government,

16 deputy president, commander of the Territorial Defence.

17 And then number 9:

18 "Milan Radulovic, in charge of war crimes and damage."

19 Do you know the Crisis Staff appointed a special officer for war

20 crimes?

21 A. I see that here. I note that municipalities were charged to

22 investigate war crimes against Serbs. There's no indication here of the

23 ethnic -- of any ethnic criteria for the war crimes, perpetrators or

24 victims.

25 Q. And where did you find it, that investigations were made only

Page 14844

1 into crimes against Serbs? Are you perhaps confusing the Documentation

2 and Investigation Centre in the Federal Bosnia and Herzegovina with the

3 regular police work in investigating all crimes?

4 A. No, I'm thinking of the instructions from the member of the

5 Presidency, Biljana Plavsic, to investigate and document war crimes

6 against Serbs.

7 Q. We'll find that very soon. Ms. Hanson, do you accept that the

8 Serbian police was not able to investigate crimes in territories

9 controlled by the Muslim army?

10 A. Yes.

11 Q. Do you know that a documentation centre was established for that

12 purpose, headed by a literary man, not a lawyer, Miroslav Toholj, to

13 document and investigate what the police was unable to?

14 A. I've heard of the Documentation Centre, I've heard of

15 Miroslav Toholj. What that centre was charged with and whether it was

16 what the police were unable to do, I have no basis to answer that

17 question. I don't know about that.

18 THE ACCUSED: [Interpretation] Could we see 1D3585 briefly.

19 MR. KARADZIC: [Interpretation]

20 Q. Ms. Hanson, we are expected, and you are expected, and everyone

21 who is dealing with this legal case is expected to precisely determine

22 this: The Documentation Centre for investigating crimes in other

23 territories is not the same as investigating on your own territory;

24 right?

25 A. I'm sorry, I don't know enough about the Documentation Centre to

Page 14845

1 answer that question.

2 Q. Well, the centre, headed by Toholj, was a documentation centre,

3 not an investigation centre; correct?

4 A. I'm sorry, I don't know enough about the centre to answer

5 questions about it.

6 Q. Thank you. Look at paragraph 2 here. Do you agree that these

7 are instructions from the Ministry of the Interior, the Serbian Republic

8 of Bosnia and Herzegovina, sent to centres in Banja Luka, Bijeljina,

9 Doboj, Sarajevo, Trebinje? Paragraph 2 reads:

10 "A questionnaire will be completed at security services centres

11 for all persons, regardless of ethnicity (Muslims, Croats, Serb,

12 et cetera) against whom criminal reports are filed because of reasonable

13 suspicion that they are responsible for crimes."

14 This is an instruction on the documentation and investigation of

15 war crimes, as we can see in paragraph 1. And in paragraph 2, it says:

16 "Without discrimination." Have you read this? Why do you keep

17 maintaining the Serbs investigated only crimes against Serbs?

18 A. This is not in my report because it's not about crisis staffs. I

19 do not state in my report, as far as I can recall, that -- I don't enter

20 into the question of police investigations into war crimes or crimes.

21 That wasn't in -- I didn't find that in the scope of my report.

22 Q. But, Madam, you invoke wrongly Biljana Plavsic, who asked that

23 this be documented, and here the police is required to investigate,

24 regardless of faith and nationality. You are misstating facts in an

25 attempt to support the theory about Serbian culpability.

Page 14846

1 A. I have no theory about Serbian culpability. There are

2 individuals charged. The nation is not charged. I talk about the

3 Bosnian Serb leadership, and I don't like being accused of just -- of

4 blaming all Serbs.

5 Yes, I agree, this document says "to investigate all the crimes,

6 regardless of nationality." I do believe that there is a document from

7 Biljana Plavsic. I didn't include it in my report because it wasn't

8 addressed specifically to crisis staffs. Perhaps it will come up

9 somewhere -- some other time in the course of the trial. I wasn't

10 talking about this document when I mentioned the one from Plavsic.

11 THE ACCUSED: [Interpretation] Thank you.

12 Can this document be admitted?

13 I don't have time to ask you whether this minister was part of

14 the Bosnian Serb leadership.

15 MR. KARADZIC: [Interpretation]

16 Q. Was this minister part of the Bosnian Serb leadership,

17 Mr. Mico Stanisic?

18 A. Yes.

19 THE ACCUSED: [Interpretation] Thank you.

20 Can this be admitted?

21 JUDGE KWON: I take it the previous Bosanski Novi document has

22 been already admitted.

23 THE ACCUSED: [Interpretation] We'll come back to it.

24 JUDGE KWON: It was P2632, if I'm correct.

25 And we'll admit this as a Defence exhibit.

Page 14847

1 THE REGISTRAR: It will be D1360, Your Honours.

2 MR. KARADZIC: [Interpretation]

3 Q. If this document has been admitted, let me ask you, Madam: Are

4 you aware of this document, and do you agree that in here the

5 Crisis Staff - Serbian page 6, English 9 - says that its orders have not

6 been honoured and that complete chaos occurred? It straddles pages 8 and

7 9 in English and pages 5 and 6 in Serbian.

8 Can we get back that previous document, 65 ter --

9 THE INTERPRETER: The interpreter didn't get the number.

10 JUDGE KWON: 6733.

11 THE ACCUSED: [Interpretation] P2632, the previous one about

12 Bosanski Novi; Serbian page 5, English 8. Serbian 5, English 8.

13 MR. KARADZIC: [Interpretation]

14 Q. This deals with the problems in the Japra River Valley, the

15 sectoral TO Staff for Agic, Rujinka and Krsalj, Muslim-populated places,

16 turned a deaf ear to the endeavours of the official policies and organs

17 of the authorities and started to deal with things on their own.

18 Then a conflict started and expulsion of Muslim civilians from

19 one village to another village. And:

20 "The Crisis Staff reacted vigorously and issued an order to the

21 Municipal TO Staff that they should immediately place all their members

22 and units under their control ..."

23 So it says here the order was not followed. And on pages 6,

24 English 9, it says:

25 "Complete chaos has begun to reign."

Page 14848

1 Ms. Hanson, in your footnote 162, you characterise these events

2 in Bosanski Novi as ethnic cleansing, led by the Crisis Staff, whereas

3 you have evidence that the Crisis Staff is warning against chaos and

4 issuing orders completely contrary to what you describe. It's

5 paragraph 99, I believe, and footnote 169 in your report. That's what

6 you say:

7 [In English] "Examples of crisis staffs actually setting forced

8 deportation as a policy include:"

9 [Interpretation] And you say "Bosanski Novi" among them, Blagaj,

10 the Japra River Valley.

11 So you ascribe this chaos, you blame it on a deliberate process

12 controlled by the Crisis Staff?

13 A. The letter from the president of the Crisis Staff, Radomir Pasic,

14 to the population of the Japra Valley says, If you don't move out, we

15 can't guarantee your safety, which caused a lot of people to move out,

16 thinking that the authority -- the municipal authorities refused to

17 guarantee their safety, or were unable to guarantee their safety,

18 perhaps. But I think if you consider the people being held in the

19 stadium at this time, the discussions with UNPROFOR and others to help

20 the Muslims of Novi, that you have to understand a report like this,

21 which was written to be adopted by the Municipal Assembly when the

22 Crisis Staff finished its work, involves a lot of passing the blame on.

23 A lot of these reports sort of say, Crimes happened, but it wasn't us,

24 things were out of our control. They may be true, they may not. It's

25 part -- it's part of the whole context and setting here. Yes, Pasic

Page 14849

1 says, It was out of our control. He says that here. He threatened the

2 Muslims that if they didn't leave, he couldn't guarantee their safety.

3 Whether this was forced or voluntary depends on your view of the context,

4 and I do not entirely trust the language of reports like this when they

5 are endeavouring to cast blame elsewhere. I see this kind of language in

6 a lot of the -- when I rely on documents written by the crisis staffs,

7 themselves, I focus on what they say they did. The whys can be less

8 credible.

9 Q. With all due respect, Ms. Hanson, your task was to present all

10 the facts to the Trial Chamber, and then the Trial Chamber can decide

11 whether they are credible or not. Is that right?

12 A. All facts? No. The Trial Chamber will be hearing, I believe --

13 I don't know -- I don't even remember what's charged in Bosanski Novi

14 because I'm not familiar with the current state of the indictment, but I

15 imagine the Trial Chamber will also be hearing from other people about

16 events in Bosanski Novi. My job was to present documents, not the whole

17 story that is unavailable in the documents of the crisis staffs or

18 contemporary records at the time. I am not supposed to be presenting

19 material outside of the documents.

20 Q. Madam, we are going around and around. Despite what you say,

21 that you are supposed to present documents, you have not presented

22 documents. You did not take into account the chaos of war and the

23 efforts of the Crisis Staff in Bosanski Novi to restore order and peace.

24 You characterised it in a certain way. You made a judgement that the

25 Crisis Staff in Bosanski Novi controlled the situation and led the

Page 14850

1 expulsions of Bosnian Muslims. And with a selective way, you treat

2 documents. What you are doing is you are being very selective and you

3 are deciding for yourself which ones to believe and which not.

4 A. Part of my job, as an analyst, is not to believe every document

5 on its face value. I do cite this document. I read it. But noting that

6 the Crisis Staff did have the forces and the ability to secure a convoy

7 of people to leave the municipality, but they didn't seem to have the

8 ability to protect those people within the municipality, I did not

9 believe all of the justifications they cite in this report.

10 Previously, in my first report, all the documents on which I

11 relied were also given to the Court, and I'm very glad to have as many

12 documents as possible made available to the Court. The process changed

13 because there were a lot of documents. The more documents the Court can

14 see, the better they can draw their own conclusions. But I also note

15 that this report starts out, right at the beginning, discussing how the

16 Crisis Staff was formed on the instructions of the Main Board of the SDS.

17 So I rely more on what they say they did than their motivations for it.

18 When I rely only on documents written by crisis staffs, there's a

19 lot of, let's say, blaming others, protecting themselves. These are

20 documents issued for the whole municipality to be discussed at the

21 Municipal Assembly. I don't think crisis staffs usually say, We did all

22 this. They don't list everything they do, and they're not always honest

23 about what they -- why they did it.

24 I hope the Court will hear more evidence of events in

25 Bosanski Novi in which they'll be able to put this document in context.

Page 14851

1 Q. Are you trying to say that crisis staffs are misinforming their

2 own leadership?

3 A. When they're submitting their reports to the municipal

4 assemblies, I think they -- or in their own minutes, I think they choose

5 words to make themselves look as good as possible.

6 THE ACCUSED: [Interpretation] Excellencies, I note the time. Can

7 I be given at least another half an hour, because there is a clear gap

8 between my needs and with what I have been able to achieve. And if you

9 given me another half an hour, I may be able to just fill in some of that

10 gap. If I'm able to finish before that half an hour expires, I'll try to

11 do that.

12 [Trial Chamber confers]

13 JUDGE KWON: Given that you haven't wasted time today, and that

14 as long as you remain on relevant issues, we'll grant that.

15 We'll have a break for half an hour.

16 --- Recess taken at 10.31 a.m.

17 --- On resuming at 11.00 a.m.

18 JUDGE KWON: Yes, Mr. Karadzic.

19 THE ACCUSED: [Interpretation] Thank you.

20 65 ter 5915 is the next document I would like to call up. It

21 should have a translation. This is a Prosecutor's number.

22 MR. KARADZIC: [Interpretation]

23 Q. However, you speak Serbian, and Croatian as well. Do you agree

24 that the president of the Republic of Croatia, President Tudjman, issued

25 a decision on crisis staffs on the 27th of August, 1991? And in here, in

Page 14852

1 Article 1, he says --

2 THE INTERPRETER: The interpreters note that the accused is

3 reading too fast and we don't have a translation on the screen.

4 JUDGE KWON: You are simply reading too fast, without any

5 translated material. Could you slow down and repeat.

6 THE ACCUSED: [Interpretation] "Decision on Crisis Staffs," which

7 was issued on the 27th of August, 1991:

8 "The Government of the Republic of Croatia, in keeping with its

9 constitutional obligations and authorities, is duty-bound to ensure a

10 co-ordinated action of executive and administrative bodies of the state

11 authorities in the republic, as well as economic and social activities,

12 in conditions when the independence of the republic is threatened or in

13 the state of war, as well as the logistics support and all the other

14 assistance to the commands and units of the armed forces. For that

15 purpose, the Government of the Republic of Croatia forms the Crisis Staff

16 of the Republic of Croatia, as well as the crisis staffs as co-ordinating

17 bodies."

18 MR. KARADZIC: [Interpretation]

19 Q. Do you agree that this is what it says in this article?

20 A. Yes.

21 Q. Let me not read the rest of it. Do you agree that the second

22 paragraph of Article 2 says that in terms of their position -- or,

23 rather, by virtue of their position, government members and ministers are

24 also members of the Crisis Staff?

25 And the last sentence says:

Page 14853

1 "The Government of the Republic of Croatia can appoint up to

2 three other members of the Crisis Staff who are not its members already

3 by virtue of their position."

4 Right?

5 A. Yes, that's what it says.

6 Q. Thank you. Does it say in Article 3:

7 "In the municipalities in which the local bodies of authorities

8 regularly perform their duties and are loyal to the Republic of Croatia,

9 the president of the Municipal Crisis Staff is also the president of the

10 Executive Council of the municipality, and its members are the heads of

11 municipal administrative bodies."

12 And so on and so forth.

13 Do you agree that he cannot form crisis staffs in the

14 municipalities which are not loyal to the republic, but only in the

15 republics which are obedient, which are loyal to the republican

16 authorities? Right?

17 A. Correct, I agree.

18 Q. Article 4 says:

19 "In order to co-ordinate the work and activities of the municipal

20 crisis staffs, the Government of the Republic of Croatia can form a

21 crisis staff that will cover a territory of several municipalities or it

22 can appoint its own commissioner that will be in charge of several

23 municipalities."

24 Do you agree that they also have an institution -- or, rather,

25 that they have the institution of a commissioner who helps municipalities

Page 14854

1 in an attempt to co-ordinate their activities?

2 A. Yes.

3 Q. Municipalities, themselves, can also appoint commissioners for

4 local communes or settlements, and so on and so forth; right? Do you

5 agree that a crisis staff is just a form through which the existing

6 authorities function, rather than an entirely new body?

7 A. I'm not familiar enough with the Croatian legislation to really

8 draw that. I see here it refers to that the Executive Committee of the

9 Assembly can form a crisis staff or name a -- oh, the commissioner is

10 just to the local levels. That is so different from the model that I've

11 seen in the Bosnian Serb municipalities that I'm really reluctant to draw

12 any conclusions without having studied the Croatian legislation better.

13 Q. Please read Article 5, where it says:

14 "When this decision comes into force, the decision on the setting

15 up and activities of the Crisis Staff in the Republic of Croatia,

16 number 822/91 of 29 July 1999, will become null and void, as well as all

17 the decisions --"

18 THE INTERPRETER: The text has just disappeared from the screen,

19 and the accused was reading too fast.

20 JUDGE KWON: Mr. Karadzic, we can all read this document later

21 on, when it's translated. What is your question on this document?

22 MR. KARADZIC: [Interpretation]

23 Q. My question is this: Ms. Hanson, when we look at your footnote,

24 and when we see that you say that the crisis staffs existed elsewhere,

25 can we now finally underline the fact that those crisis staffs, indeed,

Page 14855

1 existed and that they existed much before the Serbian crisis staffs were

2 ever set up?

3 A. The date of this was August. Yes, had I realised in my writing

4 how much other crisis staffs -- non-Serb crisis staffs would matter to

5 the readers of my report on Bosnian Serb crisis staffs, I would have

6 expanded that section to make it clear that we hear of crisis staffs in

7 Croatia in 1991. We see crisis staffs on the Bosnian Croat and

8 Bosnian Government side as well. I readily can see I did not pay

9 attention to it -- much attention to that in my report on Bosnian Serb

10 municipal crisis staffs.

11 Q. Thank you. With all due respect, Ms. Hanson, the crisis staffs

12 that were formed by the Muslim side in January 1991, only a month after

13 our elections, were not the staffs of the Bosnian government. They were,

14 rather, the staffs of the Muslim community. The Crisis Staff of the

15 Bosnian Presidency was formed in mid-September 1991. In any case, all of

16 them had crisis staffs much before the first Serbian crisis staffs were

17 set up; is that correct?

18 A. No. I've listened to an intercept from, I believe, June 1991, in

19 which you say there is an SDS crisis staff already. It's not in my

20 report because it wasn't a municipal one, but I have heard mention of a

21 Serbian SDS crisis staff from the summer of 1991.

22 Q. In that conversation, I'm trying to calm down somebody who was

23 putting pressure on me to form a crisis staff. Did a crisis staff exist

24 at the time I indicated in my question?

25 A. In your question, what -- I'm sorry, what time do you -- do you

Page 14856

1 refer to, what time-period?

2 Q. Throughout 1991. Did it exist in the summer of 1991? Did the

3 Crisis Staff exist at the time that I indicated?

4 A. As I say, I've only your word for it in that intercept. That's

5 the only indication I have of a republic-level SDS crisis staff in the

6 summer of 1991. I have no other documents regarding that one.

7 Q. Well, very well. Do you know that people on the ground in

8 municipalities formed crisis staffs whenever they felt that there was a

9 crisis coming, even before the instructions were issued in 1991?

10 A. As I say in my report, I have seen or heard references to ad-hoc

11 crisis staffs formed even before -- well, before the war, I've seen

12 references, I know, to a crisis staff for the reception of refugees in

13 Bosanski Petrovac, I believe, in the summer of 1991, refugees coming from

14 Croatia. So I have heard the term used, but not as a municipal

15 government organ; simply a co-ordinating body to deal with a specific

16 issue or local crisis.

17 JUDGE KWON: Ms. Sutherland, do we have a 65 ter or the exhibit

18 number of the intercept she has referred to?

19 MS. SUTHERLAND: I was just trying to work out which one it was

20 myself, Your Honour.

21 JUDGE KWON: Thank you.

22 MS. SUTHERLAND: If Ms. Hanson can tell me the speakers, if she's

23 able.

24 THE WITNESS: The other speaker's name is Zoran -- I'm afraid

25 that's all it is, Zoran. I believe it's June 1991.

Page 14857

1 If I may explain, Your Honours, I listened to intercepts in which

2 the word "crisis staff" appeared, so I don't know if they're on the

3 exhibit list or not. I was doing my own researches.

4 JUDGE KWON: Thank you.

5 Yes, Mr. Karadzic.

6 THE ACCUSED: [Interpretation] Can the previous document be

7 admitted?

8 JUDGE KWON: Yes. It will be marked for identification, pending

9 translation.

10 THE REGISTRAR: As MFI D1361, Your Honours.

11 THE ACCUSED: [Interpretation] Could the Court produce 65 ter 594,

12 only in English, because the Serbian version is a handwritten document.

13 Page 11, please.

14 As for the previous question, the instructions were issued in

15 December 1992; page 43, line 23. The instructions were issued in

16 December 1991. The month was not recorded the first time 'round.

17 MR. KARADZIC: [Interpretation]

18 Q. Let's look at bullet point 3, where it says:

19 [In English] "From the second session of the Municipal Board of

20 SDS Bratunac, held on the 25th of October, 1991."

21 [Interpretation] Can we go to the following page.

22 Bullet point 3:

23 [In English] "Appointment of the Crisis Staff of Bratunac

24 municipality for implementation of measures for protection of the Serbian

25 people."

Page 14858

1 [Interpretation] Do you agree with me that those people of

2 Bratunac acted of their own will and that they formed a crisis staff

3 independently, even before the instructions were issued in December 1991?

4 A. This is obviously before the 19 December instructions. But if we

5 can look at item 1, it follows information from the Main Board of the

6 SDS.

7 If we can go back to the previous page.

8 "Information on the standpoints of the Main Board of the SDS BiH

9 and the standpoints and conclusions of the newly-elected Serbian Assembly

10 of the BiH."

11 In my report, I tie this Crisis Staff to the declaration of a

12 state of emergency in the party which Mr. Karadzic gave on the 18th, I

13 believe, October. And if this is the same one -- could I just go to the

14 top of this document? What's the date of it? It's the -- yeah, because

15 I also -- I cite a document from the 19th of October in which Deronjic

16 informs the leaders of the SDS Municipal Board of Bratunac of the

17 policies and instructions from the expanded session of the SDS Main Board

18 held the night before in Sarajevo:

19 "The membership of the municipal crisis staff was proposed

20 immediately." And the Bratunac crisis staff then met on the 26th of

21 October. So, actually, the day after this party emergency was declared,

22 Deronjic comes back to Bratunac and says, We got instructions from the

23 SDS leadership, and therefore a crisis staff should be formed. I tie

24 that to the state of party emergency.

25 I agree it is formed before the 19 December instructions, but I

Page 14859

1 would not say that it's completely on their own initiative. The explicit

2 references to instructions and information from the party centre make me

3 think it was not completely an initiative. They may have jumped the gun,

4 perhaps, already hearing of this term "crisis staff," forming a crisis

5 staff, given that the party is declared to be in a state of emergency,

6 but I think that they were -- that they were seeing themselves as

7 following the party line at that time.

8 I also see, in Bosanski Petrovac at this same time in late

9 October, the SDS Municipal Board proposes forming a crisis staff, which

10 the Municipal Assembly, being still a multi-ethnic body, rejects. So

11 I think there may have been talk of a crisis staff or the declaration on

12 the state of emergency may have led people to use this term "crisis

13 staff." I see no written instructions at this time from the party centre

14 about a crisis staff.

15 THE ACCUSED: [Interpretation] Thank you.

16 This document has been admitted.

17 Could the Court please produce 1D3594.

18 MR. KARADZIC: [Interpretation]

19 Q. I would ask you to help me go quickly through the following few

20 documents. There is not much left for us to look at.

21 JUDGE KWON: Yes, the previous document was Exhibit P2597.

22 MR. KARADZIC: [Interpretation] Thank you.

23 Q. Do you agree with me that this was issued on the 16th of January,

24 1992, and that these are decisions of the Presidency of the HDZ of

25 Bosnia and Herzegovina?

Page 14860

1 And we can go immediately to the second page, both in English and

2 in Croatian. I don't want to say "Serbian."

3 I would like to draw your attention and everybody's attention to

4 bullet point 7 and 8, where it says:

5 "Crisis staffs of the HDZ of BH at all levels ..."

6 And so on and so forth.

7 Were you familiar with this document? This was signed by the

8 president of the HDZ of Bosnia and Herzegovina, Stjepan Kljuic, a member

9 of the Joint Presidency of Bosnia and Herzegovina; right?

10 A. Right, it was signed by Kljuic, who was a member of the

11 Joint Presidency. I was not familiar with this document at the time I

12 wrote my report. It was brought to my attention since then, but I don't

13 feel it changes my conclusions on Bosnian Serb municipal crisis staffs.

14 Q. Did you come across a document which indicates that

15 Plavsic/Koljevic did the same, that they managed the area as members of

16 the Joint Presidency?

17 A. I'm sorry, I don't know what you mean by "managed the area," but

18 I have not seen an equivalent document like this from Plavsic or

19 Koljevic.

20 THE ACCUSED: [Interpretation] Thank you.

21 Can this be admitted? This is precisely what I meant. You

22 understood me well. It was a good equivalent of what I had in mind.

23 JUDGE KWON: Yes, that will be admitted.

24 THE REGISTRAR: As Exhibit D1362, Your Honours.

25 JUDGE KWON: You have five minutes, Mr. Karadzic.

Page 14861

1 We dealt with Croatian crisis staff yesterday, which was noted in

2 her footnote 5. Please proceed.

3 MR. KARADZIC: [Interpretation] Thank you.

4 Q. Then I have to skip over so many things, and I have to ask you

5 this: You are appearing today as an expert witness, or, rather, you have

6 testified here as an expert witness; right?

7 A. Yes.

8 Q. Are you still affiliated with the OTP, are you still a staff

9 member there?

10 A. Yes.

11 Q. Thank you. What is your capacity as a staff member in the OTP?

12 You are a researcher, you're not an investigator; right? You are a

13 research officer; that's what you told us?

14 A. Yes, the name of my post is "research officer."

15 Q. When your testimony is finished today, you are going back to your

16 work to be a research officer; right?

17 A. Well, I hope I get a short break, but, yes, on Monday I'll start.

18 Q. Thank you. And you're going to try to help the OTP to reinforce

19 their case against me; right?

20 A. I'm going to try to help the OTP to better their case, which

21 includes a better understanding, if necessary, of all sides of the

22 issues. But, yes, I will go back to working to help the OTP.

23 Q. You have also stated that you did the same in the Krajisnik case.

24 Before you provided evidence, you were a research officer, and you had

25 collected documents that supported the Prosecution case. And then you

Page 14862

1 were transformed into an independent expert witness, and you remained

2 that for the duration of your testimony. And after that, you were again

3 transformed or you went back to being a research officer and an associate

4 of the OTP. Right? You said that on page 14721, from line 1 onwards.

5 I can look for that.

6 A. If you feel the need. But I agree with that statement, so I'm

7 not challenging you to find it in the transcript.

8 Q. Thank you. Ms. Hanson, do you find it difficult to turn from a

9 research officer, and an associate of the OTP, into an impartial expert

10 witness? How difficult is it to go back and forth between these roles?

11 A. It requires some intellectual rigour to separate -- to separate

12 the roles, but I -- my report -- my work is based on the documents, and I

13 have faith that the documents show what I'm saying. And I do try and

14 keep out other sources when I testify, when I write my report.

15 Q. If I put it to you, Ms. Hanson, that Mr. Krajisnik was found

16 guilty of only one charge in the indictment, and that is persecution of

17 the Muslim population, and that the decision was based mainly on your

18 findings, on the results of your research, and at the same time if I tell

19 you that he is a totally innocent person, how will that make you feel?

20 JUDGE KWON: No, an improper comment.

21 I take it you concluded your cross-examination, Mr. Karadzic.

22 THE ACCUSED: [Interpretation] That was not a comment. I asked

23 Ms. Hanson whether she feels responsible for the fact that an innocent

24 man was convicted based on such a selective approach to work.

25 Okay, I'll withdraw the question.

Page 14863

1 JUDGE MORRISON: Dr. Karadzic, it's a blatant comment, thinly

2 disguised as a question. We both know it's improper.

3 JUDGE KWON: And not helpful at all.

4 Yes, Ms. Sutherland.

5 MS. SUTHERLAND: Thank you, Your Honour.

6 Your Honour, a moment ago you asked for the 65 ter number for the

7 intercept that Ms. Hanson was referring to. If I could call up

8 65 ter 30073, please.

9 Re-examination by Ms. Sutherland:

10 Q. Ms. Hanson, this is an intercept between Mr. Karadzic and a man

11 called Zoran on the 29th of June, 1991. Is this the intercept that you

12 were referring to?

13 A. Yes, it is. On the second page, Karadzic says:

14 "We have a crisis staff."

15 MS. SUTHERLAND: I tender that document, Your Honour, to mark it

16 for identification.

17 JUDGE KWON: Yes.

18 THE WITNESS: He also connects it to a secret. He says, We have

19 a crisis staff, but we can't tell them about secrets over the phone.

20 THE REGISTRAR: It will be MFI P2713.

21 MS. SUTHERLAND: While we're on the subject of intercepts, I have

22 another one from June 1991.

23 If I could have Exhibit 65 ter 30035, please.

24 Q. Ms. Hanson, this is an intercept of a conversation between

25 Dobrica Cosic and Radovan Karadzic on the 8th of June, 1991. Have you

Page 14864

1 reviewed this intercept?

2 A. I believe so, but it's not -- I'm not recognising it right now.

3 It's still just -- the first pages are just the usual chitchat.

4 MS. SUTHERLAND: If we could go to page 12 of the English and

5 page 8 of the B/C/S. I'm sorry, page 8 of the English. In the bottom

6 right-hand corner, it says "8th of --" thank you.

7 Q. Just at the top of the page, do you recall reviewing this

8 intercept, now that you see that text?

9 A. Yes.

10 Q. And what's the significance of that in June of 1991?

11 A. That Krupa and Sanski Most are already planning to establish a

12 Serbian municipality.

13 MS. SUTHERLAND: Your Honour, I tender that and ask that it be

14 marked for identification.

15 JUDGE KWON: Yes.

16 THE REGISTRAR: As MFI P2714, Your Honours.

17 MS. SUTHERLAND:

18 Q. Ms. Hanson, at page 33/34 of today's transcript, Mr. Karadzic

19 took you to Exhibit D1360, which was the Mico Stanisic document. Do you

20 remember that?

21 A. Yes.

22 Q. And you said that you had seen documents which referred to only

23 investigating crimes against the Serbian population?

24 A. Yes, I remember that.

25 MS. SUTHERLAND: If I could have 65 ter 09342 on the screen,

Page 14865

1 please.

2 Q. This is a strictly-confidential dispatch from the minister,

3 Mico Stanisic, to the CSBs Banja Luka, Bijeljina, Doboj, Sarajevo and

4 Trebinje. Is this a document that you may have reviewed?

5 A. I think I've seen this one, yes.

6 Q. And it states in the first paragraph -- and it's dated, sorry,

7 the 16th of May, 1992:

8 "In view of the tasks resulting from the order by the minister of

9 the interior, Strictly Confidential number," and gives the number, "and

10 for the purpose of monitoring combat operations and regular activities of

11 the organs of the interior, and in order to collect documentation on the

12 crimes against the Serbian population (for prosecution and to accurately

13 inform the local and international public), fax reports must be submitted

14 daily to the Ministry of the Interior of the Serbian Republic of Bosnia

15 and Herzegovina."

16 Did you -- do you recall seeing other similar documents to this?

17 A. Yes. I believe I've seen something from Plavsic with similar

18 instructions to collect documentation on crimes against the Serbian

19 population.

20 MS. SUTHERLAND: Your Honour, I tender this document.

21 JUDGE KWON: I take it we have a full translation of this one.

22 MS. SUTHERLAND: Yes, Your Honour.

23 JUDGE KWON: Very well. We'll admit it.

24 THE REGISTRAR: As Exhibit P2715.

25 MS. SUTHERLAND:

Page 14866

1 Q. Ms. Hanson, Mr. Karadzic took you to -- on Wednesday, at the end

2 of the session, to Exhibit D01356, which is a report by the

3 SDS Municipal Board in Prijedor. Do you recall seeing that document? It

4 was the report written in December 1992.

5 A. Yes, of the SDS Municipal Board. Yes, I remember that.

6 Q. And during -- looking at that report, he was making the point

7 that there was no communication between the Prijedor SDS and the

8 republic-level SDS. And then he, at transcript page 14788, said:

9 "Well, we looked a moment ago at a diary that we looked at."

10 I'm sorry, the diary was D01356, the Prijedor Municipal Board

11 report was D01357.

12 In any event, he said:

13 "Well, the diary we looked at a little while ago, if we had time,

14 we would point your attention to where it says that they had not had

15 contact for 45 days with the representatives from Prijedor."

16 THE COURT REPORTER: Slow down, please.

17 MS. SUTHERLAND: I apologise.

18 Q. Do you remember that?

19 A. Yes, I remember him referring to a 45-day break in

20 communications, with no reference to -- without bringing up a document.

21 MS. SUTHERLAND: Your Honour --

22 JUDGE KWON: Could you check whether the transcript reflects all

23 of what you asked to the witness?

24 MS. SUTHERLAND: Yes, I would just repeat what I was saying.

25 That Mr. Karadzic said, at page 14788:

Page 14867

1 "Well, in the diary that we just looked at a little while ago, if

2 we had time, we would point your attention to where it says that they had

3 not had contact for 45 days with the representatives from Prijedor."

4 Your Honour, if --

5 JUDGE KWON: Yes, let's proceed.

6 MS. SUTHERLAND: If I could have 65 ter 23157.

7 Your Honour, this is the conversation that Mr. Karadzic was

8 referring to -- not a conversation, a notation in the diary, and he had

9 previously said that it was his handwriting. And this is at page 14783.

10 When the handwritten document came up on the screen, he said:

11 "This is a session of the Cabinet on the 14th of September, 1992,

12 in Bijeljina."

13 We can see that on page 1.

14 Can we see the next page in Serbian:

15 "This is obviously my handwriting and my diary."

16 And there was only a limited number of the diary -- pages of the

17 diary in evidence, and I seek to use the remaining -- the entire diary

18 now as Exhibit 65 ter 23157.

19 And if we could please go to the ERN, which is R066-3937.

20 And this is a note of -- a notation on the 19th of October, 1992,

21 and I think it says there -- and I'm sorry, Your Honour, we don't have a

22 translation at the moment. It's been put in for urgent translation.

23 Q. There's a meeting of the Presidency and the Main Staff of the RS;

24 is that right?

25 A. Of the VRS. Yes, the Main Staff of VRS and the Presidency.

Page 14868

1 Q. And then it says there's a report from Geneva?

2 A. Yes.

3 Q. And then on the next page, does it say "Presidency with Prijedor"

4 underlined?

5 A. Yes.

6 Q. And then:

7 "The first 45 days of the war, there was no connection with us"?

8 A. Mm-hmm, yes, that's what it says.

9 Q. "Problems of the functioning of government and the relations

10 between party and government"?

11 A. Yes, that's what it says.

12 Q. "Assembly session to be held"?

13 A. Mm-hmm.

14 Q. "Political goals in the army can be interpreted only by SDS

15 members"?

16 A. Yes, that's what it says.

17 Q. And according to Mr. Karadzic, it's -- he understands the war to

18 be beginning at the beginning of April; is that right?

19 A. Yes. From the way he's been counting the months of the war,

20 that's my conclusion.

21 MS. SUTHERLAND: Thank you.

22 I seek to tender this document, Your Honour, MFI, marked for

23 identification, and to have a translation.

24 JUDGE KWON: Yes, Mr. Karadzic.

25 THE ACCUSED: [Interpretation] First of all, let us be precise.

Page 14869

1 The war in Prijedor began in end May, not in April. And, second,

2 am I writing here what I am saying or what I'm being told? How can

3 anyone ascribe to me words which other people tell me?

4 JUDGE KWON: If necessary, the Chamber can give you another go,

5 but it's not for you to intervene with the examination of the

6 Prosecution.

7 MS. SUTHERLAND: Your Honour, if I can just make a point.

8 Mr. Karadzic can't have his cake and eat it too. He either has

9 been putting to this witness throughout her testimony that the war

10 started -- for example, if we have a document at the end of -- end of

11 June, he'll be saying, Well, this is three months into the war, and this

12 is what's happening in Kotor Varos, when, in fact, everyone knows that

13 the war broke out in Kotor Varos on the 11th of June. So he can't, for

14 one minute, be saying three months into the war, in relation to

15 Kotor Varos, and then, in relation to Prijedor, well, it's at the end of

16 May, so now we've got to count 45 days from the end of May.

17 JUDGE KWON: It may depend.

18 In any event, what's the number under which we admitted part of

19 this diary?

20 MS. SUTHERLAND: That was Exhibit D01356, and that was the

21 decision of the Cabinet on the 14th of September, 1992, Your Honour.

22 But this document -- this handwritten diary is a lot longer and

23 covers a lot more period in 1992, and so I thought it was better that we

24 had a new exhibit number.

25 JUDGE KWON: Yes, we'll mark for this --

Page 14870

1 THE ACCUSED: [Interpretation] And may I ask Madam Sutherland to

2 show to the Trial Chamber the entire page, everything that is written on

3 it?

4 JUDGE KWON: We mark this for identification, pending

5 translation.

6 THE REGISTRAR: As MFI P2716, Your Honours.

7 JUDGE KWON: Yes. Please proceed, Ms. Sutherland.

8 MS. SUTHERLAND:

9 Q. Ms. Hanson, I want to just quickly, very quickly take you back to

10 the excerpts on the 26th of April, 1992.

11 In your evidence-in-chief, I called up Exhibit D407 because that

12 was the document that we had exhibited in the case, and that was at

13 transcript page 14529. However, in -- during your cross-examination,

14 Mr. Karadzic also brought up Exhibit D407, and that was at transcript

15 page 14774 to 14775. And at that point, you said this is a Latin script

16 and you were using the Cyrillic version; is that right? Do you recall

17 that?

18 A. Yes, I recall that.

19 MS. SUTHERLAND: If I could have, first of all, quickly on the

20 screen Exhibit D407.

21 Q. And that was the document that you were taken to by both myself

22 and Mr. Karadzic?

23 A. Yes, it is.

24 MS. SUTHERLAND: And if I can now have on the screen Exhibit --

25 sorry, 65 ter 00783.

Page 14871

1 Q. And this is actually the document -- or is this the document that

2 you were referring to --

3 A. Yes.

4 Q. -- and cited in your report?

5 A. Yes, I believe I used this version in my report, and certainly

6 the one to which I'm more familiar. But I have seen the Latin script,

7 but this is the one I usually use.

8 MS. SUTHERLAND: Your Honour, I would seek to tender this

9 document, 65 ter 00783.

10 JUDGE KWON: Yes.

11 THE REGISTRAR: Exhibit P2717, Your Honours.

12 MS. SUTHERLAND: And if we can just go to the second page of the

13 B/C/S and English.

14 Q. And we can see there that it's got a signature block and a date

15 of the 26th of April?

16 A. Yes.

17 Q. Ms. Hanson, you were also asked in cross-examination about the

18 Agency for Resettlement, and that's at transcript page 14640 to 14642.

19 Mr. Karadzic took you to Exhibit D01308, which is the ARK Crisis Staff

20 decision, signed by Brdjanin, of the 26th of May, 1992, where he said, at

21 item 6:

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

23 problem of population resettlement."

24 Mr. Karadzic said:

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

Page 14872

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

2 oversaw the removal of non-Serbs?"

3 And you answered:

4 "What I see in a great many municipalities is an institution

5 named variously Property Exchange Agency or Agency for Movement of

6 Population, and so on."

7 And then you go on a little. And then Mr. Karadzic said:

8 "This is what you're reading into this, but this was not done,

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

10 implemented."

11 Do you recall that?

12 A. Yes, I do.

13 MS. SUTHERLAND: Could I have 65 ter 05485 on the screen, please.

14 Q. This is a decision dated the 12th of June, 1992, of the

15 ARK Crisis Staff to found an agency for population movement and exchange

16 of material wealth for the Autonomous Region of Krajina. Is that the

17 document that you were referring to?

18 A. Well, I was referring to such agencies at the municipal level as

19 well as this one at the regional level, but, yes, I knew that the -- the

20 item in the ARK conclusions had been implemented, and this is the

21 evidence that I was thinking of, of its implementation.

22 MS. SUTHERLAND: I seek to tender this document.

23 JUDGE KWON: Yes.

24 THE REGISTRAR: Exhibit P2718, Your Honours.

25 MS. SUTHERLAND: If I could have 65 ter 05484 on the screen,

Page 14873

1 please.

2 Q. Again, this is a decision of the ARK Crisis Staff, dated the 12th

3 of June, 1992, a decision to appoint Professor Milos Bojinovic from

4 Glamoc as chief of the Agency for Population Movement and Exchange for

5 Material Wealth for the ARK. Were you aware of this decision?

6 A. I knew that someone had been appointed. I didn't remember the

7 name. I don't know if I've seen this exact appointment, but I do know

8 that the agency was set up and personnel were named to it, yes.

9 MS. SUTHERLAND: I'd seek to tender this document, Your Honour.

10 JUDGE KWON: Yes.

11 THE REGISTRAR: Exhibit P2719, Your Honours.

12 MS. SUTHERLAND:

13 Q. Ms. Hanson, I'm now going to show you a number of documents

14 related to this agency.

15 If I could have one moment, Your Honour. Sorry, Your Honour,

16 I've got a lot of paper on my table.

17 While we're waiting for the list to print: Ms. Hanson, on

18 another matter, Mr. Karadzic asked you this morning how many

19 municipalities you had looked at in relation to the documentation for

20 your report, and he named off maybe a dozen municipalities and then asked

21 you, How many municipalities were there, 55 or 60 rather large

22 municipalities, and then said that you probably only included a third or

23 something of that region in your report. Do you recall that?

24 THE ACCUSED: [Interpretation] Can we have the reference for that,

25 please?

Page 14874

1 JUDGE KWON: It's today's transcript.

2 MS. SUTHERLAND: Page --

3 JUDGE KWON: 13.

4 MS. SUTHERLAND: -- 13. Thank you, Your Honour. I had it on

5 page 12 and 13, but --

6 THE WITNESS: I do recall the exchange.

7 MS. SUTHERLAND:

8 Q. Would you agree with me that it was -- it's probably more in the

9 vicinity of 60 municipalities that are listed in your report?

10 A. I am quite prepared to believe that. I haven't, as I said, made

11 a list of that, but I know it was a lot more than 20.

12 MS. SUTHERLAND: Thank you.

13 Now I have my piece of paper back in relation to the

14 Autonomous Region Agency for Population Movement.

15 If I could have 65 ter 23145, please.

16 THE ACCUSED: [Interpretation] Did I receive a wrong

17 interpretation or translation? Madam Sutherland said "the displacement

18 of population," and in our language, when this is translated the way it

19 was translated to me, it has a totally different connotation.

20 MS. SUTHERLAND: I said the Agency for Population Movement.

21 Q. Ms. Hanson, you can see on the screen here a payroll for

22 July 1992, and listing a number of persons. One is Milos Bojinovic, who

23 we've just seen from the previous two documents was a director of the --

24 appointed director of the agency or as the chief?

25 A. Yes.

Page 14875

1 Q. What does this document signify to you?

2 A. It signifies to me that Milos Bojinovic was actively working in

3 July 1992.

4 Q. And do we see -- can you make out the stamp at all?

5 A. If it could be enlarged. I'm afraid I can't see it that well.

6 JUDGE KWON: We can enlarge further. We can collapse the English

7 part.

8 THE WITNESS: I see the words "for resettlement" or "movement,"

9 and the "Autonomous Region of Krajina, Banja Luka." I can't -- yes, "The

10 Serbian Republic of BiH, Autonomous Region of Krajina," something,

11 "movement," or "resettlement."

12 MS. SUTHERLAND: There's a better stamp on the next document.

13 Your Honour, I tender that document.

14 JUDGE KWON: It will be admitted.

15 THE REGISTRAR: Exhibit P2720.

16 MS. SUTHERLAND: If I can have 65 ter 23146 on the screen.

17 My apologies, I will slow down. 65 ter 23146.

18 Q. The English on the screen is a payroll for December 1992, and it

19 is signed by the director, and it has a stamp.

20 And if we could just quickly blow that stamp up.

21 A. Yes, it's the Agency for Movement of ARK in Banja Luka, so this

22 would suggest to me that the agency was active and its members were

23 working in December 1992.

24 MS. SUTHERLAND: I tender that document, Your Honour.

25 JUDGE KWON: Yes.

Page 14876

1 THE REGISTRAR: Exhibit P2721, Your Honours.

2 MS. SUTHERLAND: If I could have 65 ter 23147 on the screen,

3 please.

4 Q. This is an authorisation dated the 10th of August, 1992, signed

5 by Director Milos Bojinovic, and it's entitled "An Agency for Helping in

6 moving of Population and Exchange of Material Property." And it's

7 authorising Ms. Perka Bandic, Mr. Milan Segrt, Mr. Slobodan Bandic, and

8 they're authorised by the government of the ARK and the management of the

9 agency that they can carry out negotiations with the representatives from

10 the Republic of Croatia regarding the matters concerning moving of

11 population and exchange of material property.

12 What does this document signify to you?

13 A. It signifies to me that the agency was established, was

14 operating, was actively involved in the movement of -- organising the

15 movement of population out of Bosnia altogether, since they're dealing

16 with representatives from Croatia.

17 MS. SUTHERLAND: I tender that document, Your Honour.

18 JUDGE KWON: Yes.

19 THE REGISTRAR: Exhibit P2722, Your Honours.

20 MS. SUTHERLAND: If I could have 65 ter 23148.

21 Q. And, again, this is a certificate signed by the director,

22 Milos Bojinovic, in relation to an exchange of apartments in Zagreb with

23 one in Banja Luka?

24 A. Yes, that's what it appears.

25 Q. And it's dated the 26th of October, 1992. So did this signify

Page 14877

1 that this agency is working at that point?

2 A. Yes.

3 MS. SUTHERLAND: I tender that document, Your Honour.

4 JUDGE KWON: Yes.

5 THE REGISTRAR: Exhibit P2723, Your Honours.

6 MS. SUTHERLAND: If I could have 65 ter 23150.

7 Q. This a document dated the 29th of August, 1992, from the Agency

8 for Aiding relocation of Inhabitants and Exchange of Material Assets, and

9 it's a contract on co-operation. It's signed by Perka Bandic and a

10 company in Zagreb. And we saw a moment ago Perka Bandic having

11 authorisation to deal with Zagreb.

12 What does this document signify?

13 A. That it's organising a convoy of -- from Zagreb -- from

14 Banja Luka to Zagreb, four buses, each taking about sixty people. So it

15 indicates the agency is actively involved in organising the relocation of

16 inhabitants.

17 MS. SUTHERLAND: Your Honour, I have another five documents

18 relating to the agency. I don't want to waste a lot of time -- not

19 "waste a lot of time," but valuable time going through these documents,

20 and I wonder whether we could simply call them up, and then I could

21 tender them either as a bundle or individually.

22 JUDGE KWON: Mr. Robinson.

23 MR. ROBINSON: Well, Mr. President, we didn't have enough time

24 for our own examination, even with a lot of extensions, particularly a

25 lot of documents. Our own documents we had for this region we chose not

Page 14878

1 to use because of lack of time. So I think if they want to admit a

2 document, it ought to be presented to the witness, and there might to be

3 some thought for allowing Dr. Karadzic some time for re-examination also.

4 MS. SUTHERLAND: If I could have 65 ter 23 -- sorry.

5 [Trial Chamber confers]

6 JUDGE KWON: We think that Mr. Robinson's comment is fair enough,

7 so let's deal with them.

8 MS. SUTHERLAND: 65 ter 23149.

9 Q. This is a notice in relation to a convoy to Travnik on the 6th of

10 October, 1992. What does this document tell you?

11 A. That it's arranging a convoy to Travnik, which was then

12 Bosnian-held territory, and that each passenger must pay 14.000 dinars to

13 cover the costs of their ticket. So it tells me the agency is actively

14 involved in relocating people.

15 MS. SUTHERLAND: If I could have -- I tender that document.

16 JUDGE KWON: Exhibit P2724.

17 MS. SUTHERLAND: If I could have --

18 THE REGISTRAR: Exhibit P2725, Your Honour.

19 JUDGE KWON: Yes, thank you.

20 MS. SUTHERLAND: If I could have 65 ter 23154. I'm sorry -- yes,

21 23154.

22 Q. And this is from the same agency, dated the 1st of October, 1992,

23 signed by the director, Milos Bojinovic, to the CSB Banja Luka. What

24 does this document signify?

25 A. They're requesting the police to escort a convoy going from

Page 14879

1 Banja Luka to Vlasic. So the agency is actively involved in organising

2 the movement of population.

3 MS. SUTHERLAND: I tender that document.

4 JUDGE KWON: Yes.

5 THE REGISTRAR: P2726, Your Honours.

6 MS. SUTHERLAND: 65 ter 23152, please.

7 Q. This is a document dated the 13th of November, 1992, again from

8 Milos Bojinovic to the CSB. And is it also requesting an escort from the

9 CSB to assist the convoy?

10 A. Yes. It's very similar to the previous document. It shows that

11 it's a regular -- that this is what the agency is doing, creating

12 convoys, organising their security.

13 Q. And the route is Banja Luka --

14 A. -- Galica-Vlasic.

15 MS. SUTHERLAND: I tender that document, Your Honour.

16 JUDGE KWON: Yes, Exhibit P2727.

17 MS. SUTHERLAND: Could I have 65 ter 23156.

18 Q. This is a document dated the 12th of November, 1992. It's signed

19 by the director of the agency to the Secretariat for National Defence,

20 Banja Luka, requesting a war schedule for four individuals. What's the

21 significance of this document?

22 A. First of all, it describes the employees at the agency, which

23 tells us the agency is working, and that their work in the agency is to

24 be considered as war assignment, and, therefore, that they should not be

25 drafted, but that this assignment is helping the war effort is how I

Page 14880

1 understand that "ratni" [indiscernible].

2 MS. SUTHERLAND: And, finally, if I could have 65 ter number --

3 JUDGE KWON: We'll admit it as Exhibit P2728.

4 MS. SUTHERLAND: My apologies, Your Honour.

5 If I could have 65 ter 23155.

6 Q. And this is a document dated the 25th of November, from the

7 agency, in relation to services provided by it. And if you could just

8 briefly tell the Court what that -- what those services are.

9 A. They're organising bus travel, they're organising the moving of

10 furniture, they're organising convoys of private vehicles, and exchanging

11 apartments, making contracts, acting as a middleman between those who are

12 exchanging apartments and other assets.

13 MS. SUTHERLAND: I tender that document, Your Honour.

14 JUDGE KWON: Yes.

15 THE REGISTRAR: Exhibit P2729, Your Honours.

16 MS. SUTHERLAND:

17 Q. Ms. Hanson, also at footnote 172 of your report, relating to

18 paragraph 100, you cite five municipalities where committees for

19 immigration, travel agencies and exchange officers were established by

20 crisis staffs, and you list Bosanski Petrovac, Kljuc, Kotor Varos,

21 Sanski Most and Zvornik.

22 Your Honour, as these are footnoted in Ms. Hanson's report, I

23 would seek to tender the three that are not yet in evidence. The first

24 one, Petrovac, is Exhibit D01343, and the Kljuc one is Exhibit P02606,

25 but I would seek to tender the one from Kotor Varos, 65 ter 4203 and

Page 14881

1 00344, and from Sanski Most, the two documents, 65 ter 001 -- I'm sorry,

2 01097 and 05121, and from Zvornik, 65 ter 11256.

3 JUDGE KWON: Could you give the numbers of the first two about

4 the Bosanski Petrovac?

5 MS. SUTHERLAND: Petrovac was D01343.

6 JUDGE KWON: Is it different from that is noted in her footnote?

7 MS. SUTHERLAND: No, it's the same, 65 ter 01114. That's the

8 exhibit.

9 JUDGE KWON: And what is your tendering now?

10 MS. SUTHERLAND: I don't seek to tender that because it's already

11 Exhibit D01343.

12 JUDGE KWON: Yes.

13 MS. SUTHERLAND: And the next one from Kljuc, that's

14 65 ter 00853. That's already Exhibit P02606.

15 JUDGE KWON: Now I understand it.

16 Mr. Robinson.

17 MR. ROBINSON: Yes, Mr. President.

18 I'm sorry to ask that you take up the time, but I believe that

19 you've already indicated that these documents should not be the subject

20 of -- that you prefer to hear oral evidence. This is almost an oral

21 Bar Table motion, as I understand it, and I don't think it's appropriate.

22 [Trial Chamber confers]

23 JUDGE KWON: Fair enough.

24 Ms. Sutherland, as you noticed, it has been our practice, if the

25 Prosecution finds it necessary to tender the document through a witness,

Page 14882

1 you better put it to the witness. It's up to you, whether or not to put

2 them to the witness.

3 MS. SUTHERLAND: Thank you, Your Honour.

4 If I could have --

5 JUDGE KWON: Microphone.

6 MS. SUTHERLAND: Sorry. Thank you, Your Honour.

7 If, then, I could have 65 ter 04203.

8 Q. Ms. Hanson, this is an excerpt from the 14th session of the

9 War Presidency of Kotor Varos of the 14th of July, 1992. Could you

10 briefly tell the Court --

11 A. I --

12 Q. -- about this document?

13 A. Well, I cite the second bullet point under item 2:

14 "Activities relating to moving out the population failed to meet

15 expectations. This task must be dealt with in a much more organised

16 fashion. An agency has to be established to handle these matters."

17 I cite this as an example of an agency and, in general, of the

18 War Presidency involving itself in the organisation of the moving of

19 population -- the moving out of population.

20 MS. SUTHERLAND: I tender that document, Your Honour.

21 JUDGE KWON: Yes.

22 THE REGISTRAR: Exhibit P2730, Your Honours.

23 MS. SUTHERLAND: If I could have 65 ter 00344.

24 Q. These are the minutes of the 37th session of the War Presidency

25 of Kotor Varos, dated the 27th of July, 1992?

Page 14883

1 A. At the bottom of page 1 in English, the War Presidency has

2 received a report on population resettlement and wants a detailed work

3 plan of the Population Resettlement Service, so it suggests to me that an

4 agency has been established and it's reporting to the War Presidency.

5 MS. SUTHERLAND: I tender that document.

6 JUDGE KWON: Yes.

7 THE REGISTRAR: Exhibit P2731, Your Honours.

8 MS. SUTHERLAND: If I could have 65 ter 01097.

9 Q. This is from Sanski Most. It's the conclusions of the

10 Sanski Most Crisis Staff, dated the 23rd of June, 1992. Could you please

11 point out the relevant passage in this conclusion?

12 A. Well, it's citing, in fact, that ARK decision -- ARK conclusions

13 that we saw, discussing that, among other things, the army has to be in

14 the line with the SDS. But particularly item G, excuse me, at the bottom

15 of the page -- the English page, that they are faxing -- all

16 municipalities are to appoint a representative on the matters of

17 relocation and exchange of population and prisoners, and they should be

18 faxing these appointments to Vojo Kupresanin, member of the ARK and of

19 the SDS Main Board. And Sanski Most here appoints Vlado Vrkes to that

20 duty. As we recall from a previous document, Vrkes was the one appointed

21 to implement the policies and ideas of the SDS. They've also established

22 a camp at Sitnica. I think I've used this decision for several things

23 but the relevant here is appointing -- implementing the ARK conclusion on

24 agencies for resettlement.

25 MS. SUTHERLAND: I tender that document, Your Honour.

Page 14884

1 JUDGE KWON: Yes.

2 THE WITNESS: And also, I'm sorry, item 4, the bottom of the

3 second page of English, the commission, itself, is formed.

4 THE REGISTRAR: Exhibit P2732, Your Honours.

5 MS. SUTHERLAND: If I could have 65 ter 05121.

6 Q. And this is minutes of a meeting of the War Staff in Sanski Most

7 of the 21st of July, 1992?

8 A. Item 1 is a report of the commission for the movement of

9 population, or the Population Resettlement Commission here in the

10 English.

11 MS. SUTHERLAND: I tender that document.

12 JUDGE KWON: Yes.

13 THE REGISTRAR: Exhibit P2733, Your Honours.

14 MS. SUTHERLAND: And 65 ter 011 -- oh, sorry, 11256.

15 Q. And this is a decision on the establishment of the Agency for

16 Exchange of Real Estate Property, dated the 11th of May, 1992?

17 A. In Zvornik, yes.

18 MS. SUTHERLAND: Yes.

19 I tender that document, Your Honour.

20 JUDGE KWON: Yes.

21 THE REGISTRAR: Exhibit P2734.

22 THE ACCUSED: [Interpretation] Is there a question arising from

23 this document?

24 MS. SUTHERLAND:

25 Q. Was an agency for exchange of real estate property set up in

Page 14885

1 Zvornik?

2 A. Yes, it was.

3 JUDGE KWON: Yes, I take it to be the case.

4 Please proceed.

5 MS. SUTHERLAND: Thank you, Your Honour.

6 Q. Footnote 173 of your report cites to the Bosanski Petrovac

7 document re. the War Commission, and this document was put to you by

8 Mr. Karadzic at transcript page 14749 to 14750. It's dated the -- it's

9 65 ter -- it does have an exhibit number, but the 65 ter number is 1115.

10 THE REGISTRAR: Exhibit D1344.

11 MS. SUTHERLAND: Thank you, Mr. Registrar.

12 Q. And he was saying to you that:

13 "You were treating this document as if ethnic cleansing is the

14 intention of the Serbian authorities to cleanse Muslims from Petrovac;

15 correct?"

16 And you said:

17 "I don't use the word 'ethnic cleansing' or even 'cleansing,' but

18 I say that their solution to -- that -- I say that their solution to

19 Muslims wanting safety was to move the Muslims out. And that was one of

20 the things that crisis staffs did, or war commissions in this case, was

21 organise the departure of Muslims, and this is an example of it."

22 And then Mr. Karadzic said:

23 "Why didn't they just drive them out immediately?"

24 And you said:

25 "As I said repeatedly, Petrovac was a Bosnian Serb majority, and

Page 14897

1 drafted in Croatia about the population of Bosnia-Herzegovina, and was

2 there a census made at the time? In which way is this document relevant

3 to us? This is April 1995. A different state is making assessments

4 about the ethnic --

5 JUDGE KWON: Just refrain from making comment at this moment.

6 And when she tenders the document, you have an opportunity to object to

7 the admission of the document. Let's hear from what the witness can say

8 about this document.

9 Yes, Ms. Sutherland.

10 MS. SUTHERLAND:

11 Q. So we have on the screen in front of us the ethnicity map for the

12 municipality of Petrovac, which is -- the source document is the 1991

13 census. And this document has been produced in Croatia in 1995, based on

14 the 1991 census data. And we can see, for the municipality of Petrovac,

15 that it has a total population of 15.621, of which 11.694 are Serb

16 ethnicity, 3.288 are Muslim.

17 Given the population of the Muslims, is it right that having seen

18 the previous document, that by the end of September 1992, basically, the

19 majority -- nearly all of the Muslim population had left the

20 municipality?

21 MR. ROBINSON: Objection. Leading.

22 JUDGE KWON: So what is your question, Ms. Sutherland?

23 MS. SUTHERLAND:

24 Q. Given what we can see on the screen here, and given the previous

25 document, is it --

Page 14898

1 JUDGE KWON: The first question to be put is whether she agrees

2 with these statistics, if you are minded to ask that question, given the

3 population of the Muslims.

4 MS. SUTHERLAND:

5 Q. Ms. Hanson, you said earlier on in your testimony that the

6 Bosanski Petrovac municipality was -- I don't know whether you used the

7 word "Variant A municipality," but you said that it was a Serb majority.

8 Is that right?

9 A. Yes, I said it was one of the most Serb municipalities, in that

10 it was one of the municipalities with the highest percentage of Serbs.

11 And I'm familiar with this census of 1991. I'm familiar with this

12 publication as a reliable representation of the census. So, yes, I'm

13 familiar with -- these census figures appear correct to me.

14 Q. Thank you. And then, secondly, looking at the figures here, and

15 bearing in mind the last document, would it be right to say that the

16 majority of the population had left the municipality by the end of

17 September?

18 A. The majority of the Muslim population --

19 Q. Yes, sorry.

20 A. -- had left the municipality, yes. If we could look at the map,

21 to just scroll down, I had said that, I believe, the Muslims of

22 Petrovac -- of the municipality were concentrated in the town, itself,

23 and the map shows only two other significant Muslim settlements. So this

24 corresponds with my understanding of the ethnic structure of the

25 municipality.

Page 14899

1 MS. SUTHERLAND: Thank you.

2 Your Honour, I don't know whether you want just this one page.

3 I think it would be helpful for you to have the entire census data.

4 JUDGE KWON: We'll admit this page. Do you have an objection,

5 Mr. Karadzic?

6 THE ACCUSED: [Interpretation] I would not object to this page --

7 sorry, I'm waiting for the interpretation.

8 I would not object to this page if the figures are correct and if

9 the chart is correct. But I don't see where it shows that the population

10 was moved out and how Croatia established that.

11 JUDGE KWON: It may all go for -- go to the issue of weight which

12 is to be assessed later on.

13 We'll admit this page.

14 MS. SUTHERLAND: Yes, Your Honour.

15 The actual figures are on the ERN page 0048-1977 to 0048-1978.

16 It has the municipality total and then it has the breakdown of every

17 village in the municipality.

18 If we could quickly go to 0048-1977.

19 Your Honour, you can see it's got the figures for several

20 different years. And then over on the following page, if you follow

21 "Bosanski Petrovac" along, I think it's number 36, and then you pick up

22 number 36 on the next page, then you see, in 1991, the figures that I

23 just called out, 15.621, consisting of 3.288 Muslims and 11.694 Serbs.

24 So that's where the figures come from for the ethnic map at the back of

25 the book.

Page 14900

1 JUDGE KWON: Very well.

2 Shall we admit those two pages?

3 MS. SUTHERLAND: Yes, Your Honour.

4 JUDGE KWON: Or three pages?

5 MS. SUTHERLAND: Yes.

6 THE ACCUSED: [Interpretation] With my objection -- or, rather,

7 with the proviso that the 1991 census is not official, it was not

8 verified before the Assembly, because we had major objections concerning

9 falsifying, which doesn't mean, necessarily, that this is an inaccurate

10 result.

11 JUDGE KWON: As I indicated, it's a matter that goes to the

12 weight.

13 We'll admit these three pages.

14 THE REGISTRAR: As Exhibit P2736, Your Honours.

15 JUDGE KWON: And I take it there are English pages corresponding

16 to these.

17 MS. SUTHERLAND: There's English pages for the heading --

18 THE ACCUSED: [Interpretation] Excuse me.

19 Can we see -- can we scroll down to see what it says about the

20 Croatian population originating from Bosnia-Herzegovina, just to see the

21 figure? Can we see the top of the page? Could we maybe zoom in?

22 MS. SUTHERLAND: Your Honour, if this is going to take time, I

23 would mark it for identification, and the accused can -- and look at this

24 volume at his leisure. And then we can come back to the document.

25 THE ACCUSED: [Interpretation] I would like to tell the

Page 14901

1 Trial Chamber that it says: "Population of Croatia originating from

2 Bosnia-Herzegovina, broken down by settlements." How is this relevant,

3 and what does this mean? "Croatian population originally from BH."

4 JUDGE KWON: We admitted this page to support the page we saw in

5 relation to the map.

6 We'll proceed.

7 MS. SUTHERLAND: And, Your Honour, we were also looking at the

8 figures on the left-hand side of the screen, not the right-hand side of

9 the screen, on that particular page, 0048-1978.

10 JUDGE KWON: Very well. Let us proceed.

11 MS. SUTHERLAND:

12 Q. So, Ms. Hanson, Mr. Karadzic took you yesterday to a document --

13 or Wednesday to a document dated the 28th of October, 1992, from the

14 War Presidency of Bosanski Petrovac, and that was at transcript

15 pages 14753 to 14754, which stated that all Muslims were afforded all

16 rights under the Constitution and for the Public Security Station to

17 increase the patrols.

18 Given the state of affairs by the end of September, this decision

19 by the War Presidency would be affecting a small handful of people, would

20 it not?

21 A. Yes.

22 THE ACCUSED: [Interpretation] This is, again, leading and

23 inaccurate. I mean, it's leading, and we'll prove that it is incorrect.

24 JUDGE KWON: You preempted Mr. Robinson's role.

25 Yes, that was leading, yes, but --

Page 14902

1 MS. SUTHERLAND:

2 Q. In footnote 174 of your report, you cite three examples of crisis

3 staffs setting the conditions for departure. And you cite documents from

4 Bosanski Novi, Kljuc and Sanski Most. I won't take you to those

5 documents now. But the accused also raised the issue of voluntariness

6 and suggested that the non-Serbs were leaving of their own volition, and

7 then spoke to you about convoys at transcript page 14689 to 14690, and

8 talking about, you know, resettling the population in the areas where

9 they felt safe and whatnot. And you replied that as for the obligation

10 to secure the convoys, you did see lots of documents of municipal

11 authorities securing the convoys you can but not an equal attention was

12 paid to the local population in-situ, the non-Serbian population, that

13 is.

14 Do you recall now what documents that you had in mind when you

15 said that?

16 A. Well, I had in mind documents of the sort we've seen today,

17 arranging the police escort. The crisis staffs often note that they have

18 to get the city transport company -- to get the buses and the police to

19 provide the security, but I did not see them discussing, Can we use those

20 same municipal resources to persuade these people not to move, to make

21 them feel safe. That's what I was talking about, like when the

22 delegation of Muslims comes to the Petrovac War Commission, they ask, Can

23 you make us safe? And the answer is to move them out in an organised

24 fashion, the safety seems to be in -- while they're being moved, but not

25 while they're in place in the municipality, or being -- they're not --

Page 14903

1 neither are they offered another place in the municipality that might be

2 safer.

3 Q. Thank you. I now want to move to the municipality of

4 Bosanska Krupa, if I can.

5 And Mr. Karadzic took you to a document at transcript page 14769

6 to 14772, which was Exhibit D01353, and it was the document of the 1st of

7 May, 1992, from the Committee of Refugees, stating that it's a temporary

8 evacuation of residents and refugees from Arapusa and that the Command is

9 obliged to ensure the safe return of the residents to their homes. Do

10 you recall that?

11 A. Yes.

12 Q. If I could just take to you a couple of documents now, and I'll

13 ask you to comment.

14 If I could have 65 ter 19898, please. Oh, sorry, before that,

15 65 ter 06724, and this is the War Presidency order of the 28th of April,

16 1992, to evacuate the Muslim population from Podgrmec enclave, and using

17 the words "Evacuating them." And in the direction of Bunja [phoen]

18 Japra, Kamengrad and Fajtevci --

19 A. Fajtevci.

20 Q. Sorry for my pronunciation. And that's cited in footnote 170 of

21 your report; is that right?

22 A. Yes.

23 Q. And you cited this document for which reason?

24 A. Another example of organised evacuation. As I noted, the

25 president of the War Presidency, himself, said that the War Presidency

Page 14904

1 suggested two options to the Muslims; either to organise their own

2 evacuation from the area or to have that effected by military means. So

3 I cite this to support that, in fact, they did carry out these

4 evacuations, and that if the options are merely, Do it yourself or the

5 army will make you move, it can't be considered truly voluntary

6 evacuation. We also have the deputy from Krupa saying in the Assembly

7 that he hopes the Muslims will not come back.

8 MS. SUTHERLAND: Your Honour, I tender that document.

9 JUDGE KWON: Yes.

10 THE REGISTRAR: Exhibit P2737, Your Honours.

11 MS. SUTHERLAND: And could I please have 65 ter 19898.

12 Q. Ms. Hanson, this is a list entitled "List of inhabitants of

13 Arapusa deported to Sanski Most municipality," on the 1st of May, 1992,

14 at 1530 hours.

15 And if we could quickly scroll through the pages, Mr. Registrar.

16 Have you seen this document before?

17 A. I believe I have. All the names appear to be Muslim, just on a

18 quick glance. There are so many obviously family -- surnames, and the

19 first names all appear to be Muslim.

20 Q. It's a list of 390 names. Is this consistent with what you say

21 in your report in relation to the temporariness of the evacuation?

22 A. Yes, it is.

23 MS. SUTHERLAND: I tender that document, Your Honour.

24 THE ACCUSED: [Interpretation] Excuse me.

25 What is this document?

Page 14905

1 MS. SUTHERLAND: This is a list of 390 persons who were deported

2 from Arapusa municipality to Sanski Most Municipality on the

3 1st of May, 1992.

4 MR. ROBINSON: And what is the provenance of the document? Who

5 did it come from, who issued it?

6 MS. SUTHERLAND: It's been provided by a witness.

7 MR. ROBINSON: I think we need to know more than that,

8 Mr. President, before you can admit it.

9 MS. SUTHERLAND: Your Honour, we can provide that information to

10 the Defence. If we can mark it for identification at this stage.

11 THE ACCUSED: [Interpretation] I can't agree with that. Anyone

12 could have brought this. It has no authenticity at all.

13 [Trial Chamber confers]

14 JUDGE KWON: The Chamber is of the view that you have another

15 opportunity to tender this document through another witness, so we'll not

16 admit this through this witness at this time.

17 Before you proceed, I'm going to ask you, at the end of your

18 re-examination, to identify the items that you wish to tender among the

19 Appendix B list. So could you identify those --

20 [Overlapping speakers]

21 MS. SUTHERLAND: I've done that already.

22 JUDGE KWON: You already have. All right.

23 MS. SUTHERLAND: If we could have 65 ter 13197 on the screen,

24 please.

25 Q. Ms. Hanson, do you recognise this document?

Page 14906

1 A. Yes, I do. I cite it in my report.

2 MS. SUTHERLAND: And unfortunately, Your Honour, we don't have a

3 translation.

4 Q. So could you please read the text of the document? Sorry, it's

5 dated the 13th of July, 1992, and it's a War Presidency order.

6 A. [No interpretation]

7 JUDGE KWON: Ms. Hanson --

8 MS. SUTHERLAND: We're not getting a translation/interpretation.

9 JUDGE KWON: Ms. Hanson, could you repeat? We don't have the

10 translation.

11 THE WITNESS: I've taken my headphones so I don't hear the

12 B/C/S --

13 "[Interpretation] The War Presidency of the Serbian Municipality

14 of Bosanska Krupa is issuing the following order:

15 "The Public Security Station of the Serbian Municipality

16 Bosanska Krupa is hereby instructed to invite, for security reasons, for

17 an interview all persons from mixed marriages and to offer to them, if

18 they so wish, to move out of the area of the Serbian Municipality

19 Bosanska Krupa individually or together.

20 "This order enters into force immediately."

21 MS. SUTHERLAND:

22 Q. And is this consistent with a temporary evacuation?

23 A. No. It suggests that people from mixed marriages are still in

24 Krupa in July and that they are going to be -- have it suggested by the

25 police that they might want to leave, which strikes me as a method of

Page 14907

1 intimidation. Perhaps they genuinely want to leave, but if the police

2 are saying that, Because you're in a mixed marriage, you might want to

3 leave, it suggests intimidation to me.

4 MS. SUTHERLAND: Your Honour, I tender that document.

5 JUDGE KWON: Yes.

6 THE REGISTRAR: MFI 2738, Your Honours.

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

8 I'm just a little slow in my thinking about that, but I would

9 like to object to that last answer as beyond the qualifications of this

10 witness as an expert. I don't think that she's in a position to

11 determine, from a document like this, whether -- which, on its face,

12 talks about people being given the opportunity to leave, whether that's a

13 form of intimidation or not. She's just a researcher for the Office of

14 the Prosecutor. She doesn't have that kind of expertise. Although

15 things like this sometimes go to weight, I think in this case that

16 particular observation is outside of the expertise of the witness and

17 shouldn't be allowed.

18 JUDGE KWON: Thank you.

19 But as you indicated, it all goes to the weight and credibility,

20 but the witness must have heard it. Thank you for your intervention,

21 Mr. Robinson.

22 Let's proceed, Ms. Sutherland.

23 MS. SUTHERLAND:

24 Q. Ms. Hanson, yesterday you also -- Wednesday you were also

25 shown -- no, I showed that to you. I'm sorry.

Page 14908

1 Could I have 65 ter 01217.

2 And yesterday -- Wednesday, again, Mr. Karadzic was talking to

3 you about these temporary transfers. This is a report of the work on the

4 Municipal Assembly and the War Presidency from the 1st of January, 1992,

5 to the 20th of April, 1993, and this is something that you cite in your

6 report at footnote 9, 69, 115, 136 and 170.

7 In this report, do the Muslim -- I'm sorry, the municipal

8 authorities, the War Presidency, discuss the temporary or otherwise

9 evacuation of its population, the non-Serb population?

10 A. Yes. That's where I got the quotation from that I read earlier

11 about the -- being offered either to organise their own evacuation or

12 have it carried out by the army.

13 MS. SUTHERLAND: If we could scroll to -- and this is, I think,

14 at footnote 170 --

15 THE WITNESS: Yes.

16 MS. SUTHERLAND: -- which is on page 5 of the English.

17 THE WITNESS: Yes. It says that it would be a temporary

18 transfer, but certain areas were an exception and dealt with militarily.

19 However, as I mentioned before, the Assembly deputy, Miro Vjestica, did

20 say he hoped the Muslims would not return.

21 MS. SUTHERLAND: Your Honour, I tender this document.

22 THE ACCUSED: [Interpretation] May I ask Ms. Sutherland to present

23 the entire document to the Chamber, or, alternatively, ask to get more

24 time myself. Let's see, on the first page in Serbian, what happened in

25 Arapusa the day before and the reason for this decision about temporary

Page 14909

1 resettlement, because it's explicitly said that it's temporary. Equally,

2 if the document is admitted, it should be admitted in its entirety.

3 JUDGE KWON: Yes, we are admitting it in its entirety, of course.

4 MS. SUTHERLAND: Yes, Your Honour.

5 JUDGE KWON: That will be admitted.

6 THE REGISTRAR: Exhibit P2739, Your Honours.

7 MS. SUTHERLAND:

8 Q. You mentioned a moment ago that Vjestica formed his view on the

9 population?

10 A. Yes.

11 Q. Do you recall his speech he made at the Assembly session?

12 A. Yes, that's what I was referring to.

13 Q. Which Assembly decision was that?

14 A. The 12th of May, I believe.

15 MS. SUTHERLAND: If we could have 65 ter 0026 -- no, it's a P

16 number. P01379. Sorry, P00956. And if we could go to English page 20

17 to 21, and in B/C/S, the page is 16 to 18, where we can see Vjestica

18 beginning to speak on page 20 of the English and page 16 of the B/C/S.

19 And then if I can perhaps direct you to page 21 in the English

20 and 18 of the B/C/S.

21 A. The quotation I was thinking of, it's at the very bottom of the

22 screen. Oops. Yeah, it's between the two pages. That there are no more

23 Muslims left in the Serbian Municipality of Krupa, and now that they have

24 heard the president has told us --

25 THE INTERPRETER: The interpreters kindly ask for the reference

Page 14910

1 in the B/C/S text. Thank you.

2 MS. SUTHERLAND: The quote is on page 18 -- page 17, sorry.

3 JUDGE KWON: So we go back to the previous page in English as

4 well.

5 MS. SUTHERLAND: Yes, page 17.

6 THE WITNESS: It's -- for the interpreters, it's in the middle of

7 the large paragraph, so it's about one-third of the way down the page.

8 He lists various settlements, and then he says:

9 [Interpretation] "Will I have anywhere -- will they have anywhere

10 to go back to? I don't think so."

11 [In English] So at the very bottom of the English page, it says:

12 "Will they have a place to return to?"

13 And then the next page goes on:

14 "I think it is unlikely after our president has told us the happy

15 news that the right bank of the Una is the border."

16 That's a reference to one of the strategic objectives

17 establishing the Una as a border of the Republika Srpska. So he

18 explicitly ties the inability of the Muslims to return to their homes

19 as -- he explicitly ties that to the strategic objective of the border of

20 the state.

21 MS. SUTHERLAND: And while we have that Assembly session, if we

22 could go to page 17.

23 THE WITNESS: Could I also note something on that page? Well,

24 sorry, it's --

25 MS. SUTHERLAND: No, no.

Page 14911

1 THE WITNESS: You haven't asked me about it.

2 There's a reference to Bosanski Novi, that an ultimatum has been

3 issued for the Muslims to surrender their weapons, which is -- earlier,

4 Dr. Karadzic was taking me through the report of the Crisis Staff and

5 saying there was no ethnic criterion for their surrender, but, I think

6 the Muslims will soon be disarmed there too, Vitnica is saying. Or

7 that's in Sanski Most. So, Bosanski Novi, Sanski Most, it's the Muslims

8 being disarmed.

9 MS. SUTHERLAND: If we could quickly go to, while we have this

10 12th Assembly session on the screen, to Mr. Kalinic.

11 Q. Do you remember him making a speech at this Assembly?

12 Mr. Karadzic took you yesterday to a document which was signed by him in

13 English --

14 A. Yes, I recall the document.

15 Q. -- saying that people had to --

16 A. Co-operate with the International Red Cross and humanitarian

17 organisations.

18 Q. And -- yes, yes.

19 If we could go to page 17 of the English and page 14 of the

20 B/C/S.

21 Are you familiar with what he said at this Assembly session?

22 A. I know I've read it. I'm not quite sure what quotation -- or

23 what passage you're leading me to now, but I've certainly read his

24 speeches.

25 Oh, I remember this, yes, where he says:

Page 14912

1 "The enemy cannot be trusted, and until they are physically

2 militarily destroyed and crushed, which, of course, implies eliminating

3 and liquidating their key people."

4 And he does not hesitate in selecting that option.

5 Q. And the document, I think, we saw from Mr. Karadzic was dated

6 around the end of April. So this is a fortnight later. This is what

7 Mr. Kalinic has to say about the matter?

8 A. Yes, this -- that seems to follow my recollection of the

9 chronology.

10 MS. SUTHERLAND: Thank you.

11 If I could have 65 ter -- sorry, it's Exhibit P1379 on the

12 screen. This is the 34th Assembly session.

13 Q. Do you recall Mr. Vjestica speaking at this Assembly session?

14 A. I know I've reviewed his speeches. I can't recall right now what

15 he's saying, but --

16 MS. SUTHERLAND: If I could ask for page 20 of the English and

17 page 18 of the B/C/S, just so that we can see Mr. Vjestica's name at the

18 beginning of his speech.

19 And then if we could go to page 22, the last paragraph on

20 page 22, going over to page 23 in the B/C/S. And in English, the last

21 paragraph on page 24, going over into page 25.

22 Q. And it starts around about the war in Krupa started on the 21st

23 of April -- on 21 April?

24 A. Yes.

25 Q. And then he's talking about Abdic --

Page 14913

1 A. Yes, Fikret Abdic.

2 Q. -- coming to Krupa?

3 A. He describes one village as a Turkish village, by which he means

4 Muslim. He's used the derogatory term "Turk" for Muslims here.

5 Q. And then he says:

6 "And, gentlemen, since it is written in this agreement that

7 everyone will be able to go back to their own territory, that means that

8 his people will be going back to Veliki Babic, and we will have to

9 compensate everything we destroyed and burnt and 17 mosques that we

10 flattened."

11 Is that consistent with the proposal that you were shown in your

12 evidence-in-chief?

13 A. Yes, Klickovic's proposal from May 1992 to destroy settlements.

14 Q. That's the 25th of May, 1992, and it's Exhibit P02616?

15 A. Yes, and it indicates that although they have a written agreement

16 that everyone will be able to go back, they hadn't really planned on it,

17 and that's why they destroyed everything. And Dr. Karadzic right away

18 says he was always charmed by Vjestica, admires his fighting spirit, but

19 nothing is true of what he just said.

20 Q. Thank you. If we could leave that document now.

21 Mr. Karadzic took you, at transcript page 14729 to 14736, to an

22 Exhibit D01338, which was minutes of a meeting held in Bosanski Petrovac

23 on the 3rd of June, 1992. I don't want to go back to Petrovac, but he

24 suggested to you that the municipality was being put under pressure from

25 the masses, who were not getting paid to sack the non-Serb workers. And

Page 14914

1 you responded at transcript page 14736:

2 "I see that this is one member, he's saying that was the reason,

3 but I know the ARK was taking a similar position from above."

4 Do you recall that?

5 A. Yes, I do.

6 MS. SUTHERLAND: Could I have 65 ter 01095, please.

7 Q. This is a decision by Brdjanin, dated the 22nd of June, 1992,

8 that:

9 "Only personnel of Serbian ethnicity may hold executive posts,

10 posts where the information flow is possible ..."

11 Is this the decision that you were referring to?

12 A. Well, this decision seems to come after the one in Petrovac, but

13 I was certainly -- if this is what I had in mind, I see it implemented in

14 municipalities, and it may be that there were earlier versions of these

15 instructions. But certainly at the time, at this time in June, they're

16 implementing these decisions, yes.

17 Q. And if we go to the next page, we can see the document for

18 immediate delivery to the president of the Municipal Crisis Staff. And

19 then the following page, page 3, where we have the president of the

20 Prijedor Crisis Staff, Milomir Stakic, on the 23rd of June --

21 A. Receiving and forwarding this decision of ARK.

22 Q. And is that consistent with what you have in your report?

23 A. Yes. If we could go back one page, too, I would note another

24 interesting item that they -- reference to the Serbs had to vote in the

25 plebiscite to prove their loyalty. That's something else that I note in

Page 14915

1 my report, the participation in the plebiscite as an indicator of

2 loyalty, and that they must regard the SDS as the sole representative of

3 the Serbian people.

4 MS. SUTHERLAND: I tender that document.

5 JUDGE KWON: Yes.

6 THE REGISTRAR: Exhibit P2740, Your Honours.

7 MS. SUTHERLAND: Now, if we can very quickly look at

8 Exhibit P0008, which is a communication dated the 25th of June, 1992,

9 from Petrovac.

10 Q. And that's implementing the steps and decisions set out in the

11 Crisis Staff decision that we just saw; is that right?

12 A. Yes. It says employees have already been sacked, and the

13 remaining ones have now been sacked, except for one, who, when he

14 finishes his tasks, will be fired.

15 MS. SUTHERLAND: I tender that document, Your Honour. Sorry,

16 it's already an exhibit.

17 I'd like to take you to another example of crisis staffs making

18 decisions in relation to the non-Serb population, and that's 65 ter

19 05752.

20 Q. And this is a decision of the Prijedor Crisis Staff on the

21 release of imprisoned persons, dated the 2nd of June, 1992. And can you

22 just very briefly tell the Chamber the significance of this document?

23 A. I cite it in my report as an example of how the crisis staffs

24 were deciding about who would be imprisoned or released. I find

25 Article 1 quite significant, that all Serbs who have been imprisoned by

Page 14916

1 mistake are to be released, implying that there was an ethnic criterion

2 for the imprisonment.

3 MS. SUTHERLAND: I tender this document.

4 JUDGE KWON: Yes.

5 THE REGISTRAR: Exhibit P2741, Your Honours.

6 THE ACCUSED: May I ask, could we work today a little bit longer?

7 JUDGE KWON: You could have asked that later on, but let's

8 proceed.

9 MS. SUTHERLAND:

10 Q. Ms. Hanson, I now want to ask you a few questions about -- and

11 show you a few documents about the Kotor Varos municipality.

12 If I could have 65 ter 0338 on the screen, please.

13 Mr. Karadzic painted the Kotor Varos municipality as one of the

14 authorities having everything under control, so to speak, and I just want

15 to -- for you to see whether, in this document, that's really the case in

16 Kotor Varos at the end of June 1992.

17 MR. ROBINSON: Objection. Leading and comment.

18 MS. SUTHERLAND:

19 Q. Ms. Hanson, what's the significance of this document?

20 A. I believe that Dr. Karadzic brought it to my attention, showing

21 the -- that Serb houses were being burned in Kotor. I recall that he

22 described Kotor Varos as Serb territory, and described Muslim and Croat

23 enclaves as deep in the heart of Serb territory. I -- after I checked

24 what I had before on my -- in my information on Kotor Varos population, I

25 don't know if that's something I could mention or not, but to declare it

Page 14917

1 a Serb territory is a bit of a stretch. He's -- it shows -- if you could

2 direct me to which passage you want my attention. He describes the

3 police describing problems with the special unit.

4 Q. And that's Dr. Gajanin?

5 A. Yes, in general. But, yes, he was driven away from the

6 Health Centre by members of the special unit.

7 Q. And do you know whether there were any people killed at the

8 Health Centre?

9 A. I believe so, yes. I believe there was -- it was one of the

10 killing sites, yes.

11 Q. And was anything done by the authorities in Kotor Varos about the

12 special unit that came to Kotor Varos?

13 A. I believe that they requested that the ARK or CSB in Banja Luka

14 withdraw them.

15 Q. And did that happen?

16 A. I'm not familiar, I'm sorry, with the sequence of events

17 regarding the special unit.

18 Q. It says here that Djekanovic said last night that he had told

19 Dubocanin -- do you know what Dubocanin is being referred to there?

20 A. A member of the ARK crisis staff, I believe. I'm not sure.

21 Q. Is that Slobodan Dubocanin?

22 A. I believe so.

23 Q. About everything going on at the Health Centre and in the town,

24 he said that:

25 "All these questions had to cleared up and information provided

Page 14918

1 on the behaviour of the members of the special unit at the meeting with

2 S. Zupljanin, the chief of the CSB, scheduled for tomorrow?"

3 And you said that they had asked -- the crisis staff asked for

4 these special units to be removed?

5 A. I --

6 THE INTERPRETER: The speakers are kindly asked to slow down and

7 pause between question and answer.

8 THE WITNESS: My apologies.

9 Yes, that's as I recall. I've read a lot of minutes from a lot

10 of municipalities, and I can't sort out the sequence of events without

11 some reference to the documents.

12 MS. SUTHERLAND: Your Honour, I seek to tender that document.

13 JUDGE KWON: Yes.

14 MS. SUTHERLAND: Okay.

15 THE REGISTRAR: Exhibit P2742, Your Honours.

16 MS. SUTHERLAND:

17 Q. Finally, I just want to show you one document, and that --

18 Mr. Karadzic took you to quite a number of documents, Crisis Staff

19 minutes, for the period the 25th of October to the 2nd of November, and

20 then the 3rd of November, the 7th, the 10th to the 12th of November, and

21 this was all in relation to Vecici. Do you recall that?

22 A. Yes, I do.

23 Q. And you mentioned at page 14658 to 14659, he asked you about

24 Vecici, and you said your understanding of it was that it was surrounded

25 by Serbian forces and that, in the end, some killings followed in early

Page 14919

1 November, but you can't honestly remember whether they were the men of

2 this village or another place, in a school. Mr. Karadzic didn't take you

3 to the War Presidency minutes of the 6th of November, 1992.

4 And if I could have 65 ter 00292 on the screen, please.

5 What's Mr. Djekanovic up to on this day, what he's reporting?

6 A. He's going to Grabovica, monitoring the cleaning-up of the

7 terrain and the cleaning of the school. And my understanding is that

8 there was a massacre in the school, and there's the president of the

9 War Presidency making sure it's being cleaned up.

10 THE ACCUSED: [Interpretation] How do we know this? How do we

11 know this?

12 JUDGE KWON: That question was about to be asked by me.

13 How do you know that a massacre took place?

14 THE WITNESS: It's -- it's not in these pages, I know, but I just

15 know from the Krajisnik trial, the -- my -- the investigations into the

16 killings scheduled in Krajisnik of that. It's beyond the scope of my

17 report, but I don't know when I can bring in what has been established by

18 other trials or not.

19 MS. SUTHERLAND: Your Honour, if we could see 65 ter 00719 --

20 sorry, 00293.

21 Q. This is a one -- a report from the 1 KK, the 1st Krajina Corps,

22 to the Republika Srpska Army Main Staff, a regular combat report for the

23 4th of November, 1992. And they talk about their -- about 40

24 Green Berets, members were killed, and about 200 were captured. A brutal

25 massacre of the captured members of the Green Berets started because of a

Page 14920

1 wounding of four and a killing of one soldier.

2 Is this what you were referring to?

3 A. I believe so.

4 MS. SUTHERLAND: Your Honour, I would ask that document be marked

5 for identification.

6 THE ACCUSED: [Interpretation] What is the link with the school?

7 It says: "I'll undertake measures to prevent ...," but what does it have

8 to do with the school?

9 MS. SUTHERLAND: Your Honour --

10 JUDGE KWON: Why do you suggest it to be marked for

11 identification?

12 MS. SUTHERLAND: I can seek to tender it, Your Honour.

13 JUDGE BAIRD: But why did you seek it to be marked for

14 identification?

15 MS. SUTHERLAND: I'm sorry, because when I asked Ms. Hanson was

16 this what she was referring to, she said, I think so. At least that's

17 how I understood it.

18 But if I may take her to one more document, Your Honour,

19 65 ter 00722. This is another combat report from the following day,

20 where it states:

21 "The deaths of those captured from Vecici were simply the result

22 of combat activities in the clash against the VRS following the death of

23 one soldier and the wounding of several others, and it seems to be

24 downgraded now to more than 150 extremists died in combat."

25 Yes:

Page 14921

1 "In the clash against the VRS, following the death of one soldier

2 and the wounding of several others, more than 150 extremists died in

3 combat."

4 No, Your Honour, we're still not getting the link to the Grbavica

5 school. We'll have to get that through the military expert.

6 JUDGE KWON: So you seek to tender those documents at a later

7 stage or now?

8 MS. SUTHERLAND: We can either mark them for identification now

9 or we can tender them now, and the military expert will speak to them.

10 JUDGE KWON: I'm not sure whether that link has been sufficiently

11 shown at this moment. I will consult my colleagues.

12 [Trial Chamber confers]

13 JUDGE KWON: Why don't you tender them at a later stage,

14 Ms. Sutherland, yes.

15 MS. SUTHERLAND: Thank you, Your Honour.

16 Your Honour, I have no further questions.

17 JUDGE KWON: I understand, Mr. Karadzic, you wanted to ask

18 further questions. But please explain to us what questions you are going

19 to ask and why it --

20 THE ACCUSED: [Interpretation] Thank you.

21 JUDGE KWON: And tell us why it was not -- it could not have been

22 raised before, and in what context it arose from the re-examination of

23 the Prosecution.

24 THE ACCUSED: [Interpretation] This is precisely what I am going

25 to explain.

Page 14922

1 My learned friend, Madam Sutherland, has just been given a new

2 direct examination. 14641 and 14642 are the pages where she did that.

3 Actually, it is the pages on which I said, and Madam Sutherland

4 misinterpreted:

5 [In English] Hanson:

6 "Crisis staffs and war presidencies as the institutions through

7 which the moving out of the population was to be organised, including the

8 signing over of property. So I don't mean simply the ARK and so on. I

9 also see them as many individual municipalities."

10 Karadzic:

11 "We will get back to this issue of property being signed over.

12 This is what you are reading into this, but this was not done, this was

13 not implemented. You don't know that, but this was not implemented."

14 [Interpretation] There are two things at stake here. What is

15 being implied is that crisis staffs were formed up and were instrumental

16 in the forcible resettlement of the population, and that their assets and

17 property were taken away from them. And based on that, Madam Sutherland

18 had been given the chance to re-examine and introduce new elements,

19 including demographic elements that did not arise either from my

20 cross-examination, as a whole, or from these particular two pages and the

21 answers that the witness provided in cross-examination.

22 As for the agencies, they are services, and --

23 JUDGE KWON: Just a second.

24 Do you find the reference to the transcript pages of today,

25 Ms. Sutherland?

Page 14923

1 MS. SUTHERLAND: Sorry, Your Honour, I don't understand.

2 JUDGE KWON: Whether you can find the page numbers of the

3 transcript Mr. Karadzic just referred to.

4 MS. SUTHERLAND: Is that the Agency -- the Agency for

5 Resettlement?

6 JUDGE KWON: Yes, referring to his comment that that was not

7 implemented.

8 THE ACCUSED: [Interpretation] I never contested the existence of

9 the agencies. What I challenge is the implication that they implemented

10 the forcible resettlement of the population and confiscation of property.

11 And this is what was interpreted on those ten lines, and those ten lines

12 were the very base for the additional questions by the Prosecutor.

13 The document I showed after that, 1308, demonstrated that there

14 was a reason for me to ask those questions, and now we have opened an

15 entirely new page in the whole process.

16 MS. SUTHERLAND: Your Honour, the transcript pages was 14640 to

17 14642, so it would be --

18 JUDGE KWON: I meant in today's transcript. Very well.

19 MR. TIEGER: Your Honour, from today's transcript, that's at

20 page 59, if I --

21 JUDGE KWON: Thank you, yes.

22 [Trial Chamber confers]

23 JUDGE KWON: Yes, Ms. Sutherland. Microphone.

24 MS. SUTHERLAND: The way I read Wednesday's transcript,

25 Mr. Karadzic was disputing they were implementing -- or, in fact, that --

Page 14924

1 the very fact that the resettlement agencies were implemented in the ARK

2 or, in fact, anywhere in Bosnia, and that's why I took him -- Ms. Hanson

3 to all these documents --

4 JUDGE KWON: Thank you.

5 MS. SUTHERLAND: -- to show that there was a resettlement agency

6 and it was working.

7 JUDGE KWON: I'm not sure that we are going to give extra burden

8 to you, Ms. Hanson. We are minded whether we should have a more informed

9 decision on this issue. So probably you may be free of your obligation

10 to the office of the Prosecutor, but given that you are still here, could

11 you come by on Monday morning, and we'll issue a decision first thing on

12 Monday.

13 Yes, Ms. Sutherland.

14 MS. SUTHERLAND: Your Honour, Mr. Reid advises me that --

15 JUDGE KWON: So we'll deal with it on Monday, then.

16 Yes, please. I thought you were raising the items, telling us --

17 MS. SUTHERLAND: No. It was just one English translation that's

18 been up-loaded, but that doesn't matter. It can wait until Monday.

19 JUDGE KWON: All right. Thank you very much.

20 We rise for the week, and we'll resume on Monday morning at 9.00.

21 [The witness stands down]

22 --- Whereupon the hearing adjourned at 2.30 p.m.,

23 to be reconvened on Monday, the 20th day of June,

24 2011, at 9.00 a.m.