1 Friday, 4 March 2005

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.17 a.m.

5 JUDGE ORIE: Madam Registrar, would you please call the case.

6 THE REGISTRAR: Case number IT-00-39-T, the Prosecutor versus

7 Momcilo Krajisnik.

8 JUDGE ORIE: Thank you.

9 MR. STEWART: Your Honour, I've expressed my apologies privately.

10 I wonder if I could simply say that I am sorry that I was the cause of the

11 lateness in court this morning.

12 JUDGE ORIE: Yes. Thank you very much, Mr. Stewart.

13 Ms. Hanson, first of all, I'd like to remind you that you're still

14 bound by the solemn declaration you've given at the beginning of your

15 testimony, and I was informed that you had, perhaps, an answer to one or

16 two of our questions.

17 Perhaps, Mr. Hannis, we should give we should give Ms. Hanson an

18 opportunity to give those answers.

19 WITNESS: DOROTHEA HANSON [Resumed]

20 THE WITNESS: Yes, thank you, Your Honour. You had inquired about

21 document P0008404 through P0008410. It's a report on the list of motor

22 vehicles at the logistics base in Cirkin Polje. That document had been

23 brought to my attention by Ewen Brown, who had written a report on the

24 military. Mr. Brown is no longer at the Tribunal, but I consulted his

25 report to see if he had more information about this document.

1 And what I see is he actually uses the next document -- a related

2 document which appears right next to it in the evidence, P0008411 through

3 P0008420, which is a related document, similarly from the logistics base

4 of the Crisis Staff in Cirkin Polje, dated the 16th of September, 1992. I

5 have a copy, and a copy of the translation, if it's of interest to you. I

6 noted it had been disclosed in this case on the 14th of December last

7 year.

8 JUDGE ORIE: Yes. Do you have a copy for the Defence as well?

9 THE WITNESS: I have two copies. One has been highlighted. I was

10 just going to read the highlighted portion. I'm sorry. I don't have

11 three copies.

12 JUDGE ORIE: Perhaps we -- if one of the copies could be put on

13 the ELMO, and then the other copy be given to Mr. Stewart, and then

14 perhaps you could read, Ms. Hanson, the portion you thought relevant. I'm

15 afraid I forgot what the tab number was of the Cirkin Polje, and it might

16 be that -- because the long numbers, I can't memorise.

17 MR. HANNIS: I believe it's 178, Your Honour.

18 JUDGE ORIE: 178. And it certainly will be in the binder that's

19 on my desk downstairs. Yes, it starts with 179. Perhaps you can read it

20 and we'll check it later on the basis of the material.

21 THE WITNESS: Yes. As I said, this was dated on the 16th of

22 September, and it discusses in the first paragraph the setting up of the

23 logistics base, and in the second paragraph, the fact that it distributed

24 meals to army and police and prisoners in Omarska, Keraterm, and refugees

25 in Trnopolje. And it says that a report about the distribution of food

1 had been given to the Crisis Staff, the police, public security station,

2 and a copy of the report kept for the base's files.

3 This report also makes reference on the last page that --

4 JUDGE ORIE: Reporting, therefore, was mainly at the local level.

5 THE WITNESS: Yes. Simply, there's a reference on the last page

6 that they attach the list of motor vehicles from the logistics base of

7 Cirkin Polje, dated the 17th of June, 1992. And since these two documents

8 were found together, they appear next to each other in the evidence

9 record, they both indicate that they were found in the municipal building

10 in Prijedor. I take it that they were presented together. They were

11 found among materials of the Prijedor executive committee, dating from

12 October 1992, and the minutes from that session indicate that they

13 discussed the work of the logistics base in Cirkin Polje. So I take it

14 these material -- it would be logical that these materials were together

15 because they were being examined at the time by the executive committee.

16 JUDGE ORIE: Yes. Therefore, we have no indication that this

17 material went higher up in the hierarchy than the Prijedor level.

18 THE WITNESS: No indication of that in these documents.

19 JUDGE ORIE: Thank you.

20 Then I wonder whether, Mr. Hannis, whether it's necessary to

21 include this document in evidence. It rather confirms that it was

22 reporting on the municipality level rather than ...

23 MR. HANNIS: I'm willing to stipulate that with Mr. Stewart, or we

24 can have this marked as an additional exhibit, whichever the Court

25 prefers.

1 JUDGE ORIE: At this moment at least, the Chamber ...

2 [Trial Chamber confers]

3 JUDGE ORIE: No, there's no specific wish of the Chamber to

4 receive that additional document in evidence.

5 MR. HANNIS: Thank you, Your Honour.

6 JUDGE ORIE: Please proceed.

7 Examined by Mr. Hannis: [Continued]

8 Q. Ms. Hanson, when we left off yesterday we were talking about the

9 treatment or the status of the non-Serbs in the municipalities vis-a-vis

10 the Crisis Staffs. I'm ready now to have you take a look at presentation

11 tab 203, which is master tab number 312, and we'll follow the same

12 procedure we've been doing of putting the B/C/S up in Sanction and the

13 English on the ELMO. And if you would direct us to the excerpt you wanted

14 to discuss. This is from the Sipovo municipality Crisis Staff meeting on

15 the 2nd of June.

16 A. Yes. I believe it's page 3 in the translation. I'm just going to

17 find it in the original. Yes, it's at the top of 02194122 in the B/C/S,

18 the very top line, and on page 3 in the English, indicating that the

19 Crisis Staff is discussing whether Muslims will live here in Sipovo, and

20 that they should -- whether the Crisis Staff should take a stand with

21 regard to Muslims. So it was, once again, an issue. One of the topics of

22 discussion, for Crisis Staffs was the status of non-Serbs.

23 Q. Thank you. Next I'd like to show you presentation tab 204, master

24 tab 311, from the Pale municipality.

25 A. This is an order of the Crisis Staff of Pale, dated the 7th of

1 May, 1992, ordering the -- that the following telephone numbers be

2 disconnected. All of these names on this list appear to be Muslim names.

3 And the last item, or last remark on the top of the second page, that 10

4 of those 15 numbers are to be given to Serbian Television Pale. It's a

5 small detail, but it indicates the kind of business with which Crisis

6 Staffs were occupied and the kind of measures they could take against

7 Muslims.

8 Q. Thank you.

9 MR. HANNIS: And, Your Honour, I would like to recall to you that

10 our crime-base witness from Pale testified about this document, and one of

11 the names on that list was his neighbour. Next, we're going to skip tabs

12 205 and 206, Your Honours and counsel. These are referred to in footnotes

13 in Ms. Hanson's report. And I want to go to tab 207, master tab 322.

14 Q. This is a document from the Vogosca Crisis Staff.

15 A. Yes. This is the conclusions of the Vogosca Crisis Staff, dated

16 the 17th of May, 1992. Under item 5, you would note that they are laying

17 off specifically Muslim and Croat staff from the hospital. This is also

18 an interesting document for a few other themes I've mentioned, if I could

19 briefly point out.

20 Item number 1, it's saying that they are -- the Crisis Staff will

21 issue an order for taking over the army barracks which are being placed

22 under the command of the Crisis Staff of the Serbian Assembly of Vogosca,

23 which is under the sole command of the Serb Republic of BiH. If you'll

24 note the date, the 17th of May, following the establishment of the VRS,

25 they're now asserting their control -- authority over the army barracks,

1 and it gives an indication of hierarchy. The barracks are under the

2 command of the Crisis Staff, which is under the command of the Serb

3 Republic.

4 Also, item 2, discussing the cleansing, ciscenje.

5 JUDGE HANOTEAU: Excuse me. In that 207, what does it mean that

6 number 2, "for the 'cleansing' of Svrake and other territories, one more

7 man is to be secured, apart from Mr. Borovcanin." What's the meaning of

8 it, please?

9 THE WITNESS: Well, the word cleansing, ciscenje, has a variety of

10 meanings, and it's not sufficiently clear from this sentence alone whether

11 they mean the military term of clearing the terrain after a battle or

12 mopping up the last resistance or the way we see it used in many other

13 cases as -- also known as ethnic cleansing. I would note in this case

14 that Svrake was a predominantly Muslim settlement, over 80 per cent

15 Muslim. And I see that, in fact, the revised translation didn't get into

16 my binder, so perhaps if we put up Mr. Hannis's translation, a little bit

17 of the confusion is removed because -- no, it didn't get revised. I'm

18 sorry, the --

19 JUDGE ORIE: On the computer -- under the computer evidence

20 button, you'll find the original.

21 THE WITNESS: Yes. I have the original here. I would just note

22 that the second sentence refers to the cleansing not of Svrake as it

23 appears in the translation but Semizovac, and if the interpreters can

24 confirm that's a reference to Semizovac not Svrake. So the first

25 sentence, they're talking about cleansing Svrake, getting one more person

1 for that. The second sentence, they're saying when to cleanse Semizovac

2 in the case of firing, any shooting.

3 What precisely they mean here by cleansing, this document alone

4 doesn't give an indication of what kind of cleansing.

5 MR. STEWART: Your Honour, may I observe, it's extremely helpful -

6 I don't suggest it's not helpful for Ms. Hanson to give an explanation and

7 go as far as she can - I can also observe that actually Ms. Hanson's use

8 of mopping up is entirely consistent with the discussion we had some weeks

9 ago on that precise phrase. So I am certainly not quarrelling with Ms.

10 Hanson about that. But clearly, Your Honour, if we do get to points where

11 it does become important to resolve meanings of words and translations, we

12 have to go beyond this particular witness whose expertise lies in other

13 areas.

14 JUDGE ORIE: Yes, I do understand that. But whenever a word

15 appears that comes even close to cleaning, cleansing, mopping, whatever,

16 the Chamber will be immediately alert on the proper meaning of those

17 words. I'm not saying that I'm waking up at night and considering all

18 these different sensations, but it comes close to that.

19 MR. STEWART: We do, Your Honour. But thank you for that

20 observation, Your Honour. We appreciate that.

21 MR. HANNIS:

22 Q. In that regard, I know in this case, cleansing is actually in

23 quotation marks in the original, no?

24 A. Yes, and that is unusual. Again, on the basis of one sentence, I

25 can't speculate as to why it is. But it's unusual to see it in quotation

1 marks.

2 Q. Any other comment on this document?

3 A. No.

4 Q. Next, I think, in your report you talked about how Crisis Staffs

5 exercise some control over the freedom of movement within the

6 municipalities. Tabs 208 and 209, Your Honours, I want to skip over.

7 They're referred to in the footnotes in her report, and go to tab 210,

8 which is master tab 326, and ask you to comment on this one, Ms. Hanson.

9 A. Yes. This is a decision of the Crisis Staff of Ilidza

10 municipality, dated the 19th of May, 1992, signed by Nedeljko Prstojevic

11 as commander of the Crisis Staff, prohibiting the moving out of Croats and

12 Muslims from Butmir, Sokolovic Kolonija, and Hrasnica, and stating that no

13 passage is allowed from the direction of Sarajevo without a special

14 written approval of the Crisis Staff. In this connection, you might

15 remember the intercepted conversation dated the 23rd of May, between

16 Prstojevic and Gagovic, saying that he had set such a policy that no one

17 can come out from Sarajevo.

18 If you'll note that this -- in the distribution of this, it says,

19 number 1, all Crisis Staffs. I would note here what I have noted in my

20 report, that in some municipalities, there was also -- there were also

21 Crisis Staffs at the lower -- the next lower level, the local community

22 level. And we have seen such in Ilidza. I would take this to mean that

23 all of the local level Crisis Staffs, the local community Crisis Staffs,

24 not all Crisis Staffs in Bosnia, because it doesn't seem logical there.

25 That's my interpretation of that particular notation.

1 Q. Thank you.

2 MR. HANNIS: Next, Your Honours --

3 Q. Well, Ms. Hanson, in addition to controlling freedom of movement,

4 in your report, I think you next discuss how the Crisis Staffs established

5 a local judicial system and appointed Serbs to judgeships and

6 prosecutorships and removed non-Serbs.

7 A. Yes. We saw mention of that in Rajko Dukic's speech in the

8 Assembly in July 1992, and we have many documents that indicate that power

9 of the Crisis Staffs.

10 MR. HANNIS: And the next two, Your Honours, tab 211 and 212, I'll

11 will skip over. They're in her report, in the footnotes. But I would

12 like to go to tab 213 in the presentation, which is master tab number 423.

13 Q. This is from Doboj. I'd ask you to comment on this one for us,

14 please.

15 A. Yes. It's perhaps a little clearer in the original, because it's

16 all on one page, but this is a letter from the president of the Serbian

17 municipality of Doboj, also signed by the president of the Autonomous

18 Region of Krajina, dated the 24th of June, 1992, addressed to the Ministry

19 of Justice of the Serbian Republic. I would note that this document was

20 found in the archives of the Ministry of Justice. And the notations on it

21 show -- there's a handwritten notation saying it's implemented, done, yes.

22 It's a recommendation for the appointment of public prosecutors in

23 Doboj, and if I could see that -- yes. It's proposing the leaving --

24 dismissal of three public prosecutors. Their names, I note -- the first

25 two names are Muslim and the third name Ante, son of Stipe, would be

1 typically a Croatian name.

2 Q. And --

3 A. Sorry, the handwritten notations there also say they've been

4 relieved. So it's an indication that the non-Serbs were dismissed and --

5 I'm sorry, that the proposal -- that it was proposed that non-Serbs be

6 dismissed and Serbs appointed.

7 Q. Following on from that, I'd like to show you presentation tab 214.

8 JUDGE HANOTEAU: I'm sorry, a question.

9 MR. HANNIS: Sorry, Your Honour.

10 JUDGE HANOTEAU: [Interpretation] I have a question. Before these

11 events, before this took place, how were prosecutors appointed? Were

12 municipalities -- did municipalities intervene in the appointment of

13 prosecutors? Do we have any information about that? Does that mean that

14 this is a completely new practice that has nothing to do with what was

15 done in the past, with the rules that applied in the past in the republic?

16 Thank you very much, witness.

17 MR. STEWART: Your Honour, may I draw attention to the fact that

18 in the -- I'm looking at tab 213, that the English translation, where it

19 says that -- bottom of page 2, "handwritten and double-underlined

20 relieved," indicates that the word "relieved" is in translation is

21 handwritten and double-underlined. What it doesn't indicate, but it's

22 very clear on the original B/C/S version, is that those three names are

23 crossed out, Midhat Demirovic.

24 THE WITNESS: Pardon me. Yes, I am not familiar with the earlier

25 proceedings, but in general, what I know of the relationship between the

1 authorities of the municipal assembly and those of a higher level, I think

2 it would be much -- a similar practice that the municipal proposes the

3 candidates and the ministry approves or not, generally, approving. But I

4 can't say that with complete confidence. I understand -- I am not

5 claiming here that this is a new power, but rather I am looking at how the

6 Crisis Staff used that power. That's the focus of my --

7 MR. STEWART: Your Honour, the witness appears to be treating my

8 observation as a question. It was purely an observation, and it seems in

9 relation also to one or two other items on this document, that a little

10 bit of care is needed to make sure that the particular items in the

11 translation -- it is seen how they match the items in the original.

12 JUDGE ORIE: Mr. Hannis, would it be possible to have an English

13 translation? Because there's no problem with the translation, as such, as

14 far as I understand, but that all other handwriting, crossing out, is

15 reflected in the English translation and -- well, I understood Ms.

16 Hanson's answer to be that since Judge Hanoteau first put a question,

17 which was not directly related to your observation, rather rightly, that

18 she first answered the question of Judge Hanoteau, and I think we dealt

19 with the other matter by now.

20 MR. STEWART: That may be what happened. I see that now, Your

21 Honour. I just thought that somebody might have made a comment in

22 response to my comment. Anyway, never mind.

23 JUDGE ORIE: Yes. Let's proceed.

24 MR. HANNIS: Thank you.

25 Q. Then following on that decision, I wanted to show you presentation

1 tab 214, master tab 423, which appears to relate.

2 A. Yes. It relates -- it is the decision on appointing the public

3 prosecutors in Doboj, signed by Radovan Karadzic as president of the

4 Presidency. And it is the -- the three names, Serbian names, proposed in

5 the previous document. So we had the handwritten annotation that that

6 decision had been -- that proposal had been done, and this is the -- an

7 official decision indicating that it had been acted on.

8 Q. Thank you. Next, I want to go to presentation tab 215, and the

9 master tab number is 424. This is from Banja Luka, and deals with the

10 same issue. Can you tell us what this one shows?

11 A. Yes. This is an interesting document because it shows the process

12 of the proposal of -- and confirmation of appointments of some judicial

13 offices, in this case, in Banja Luka. The first page is the cover letter

14 from the public prosecutors' office in Banja Luka to the War Presidency of

15 the Banja Luka municipal assembly, stating that the War Presidency must

16 give its approval for the appointment of the deputy public prosecutor. So

17 they are forwarding to the War Presidency for its approval a list of

18 candidates for the office of public prosecutors.

19 If we look at the list on the following pages, following three

20 pages in the translation - in the B/C/S, it's two pages, 03234587 through

21 03234588 - if we can see the originals -- in the originals, it's quite

22 striking that it's noted in the translation that all the names are circled

23 except the last name - I'm just looking at the original to confirm it -

24 which is a Muslim name. We can tell who is a Muslim and Serb because that

25 is noted for each name, and it is underlined in handwriting. So there are

1 handwritten annotations circling the numbers and underlining

2 nationalities. The only name that is crossed out is the last Muslim name.

3 Q. Do you have any information for the Court where this particular

4 document was obtained from?

5 A. Yes. This document was found in the archives of the Ministry of

6 Justice, so it indicates that this was forwarded from the public

7 prosecutors' office to the War Presidency, and got from the War Presidency

8 of Banja Luka municipality to the Ministry of Justice.

9 Q. And did you see another document later on actually reflecting what

10 might have been taken in connection with these proposals?

11 A. Yes.

12 Q. Let me hand you a document, which is tab number 216, master tab

13 425, and you to comment on that.

14 JUDGE ORIE: Before we do so, may I ask for a clarification on the

15 previous answer. Ms. Hanson, you said only the last name was --

16 THE WITNESS: Well, there are two lists, Your Honour.

17 JUDGE ORIE: Yes.

18 THE WITNESS: The first is the shorter list of candidates for

19 public prosecutors.

20 JUDGE ORIE: Yes.

21 THE WITNESS: And the second list, which we'll get to in a moment,

22 is for judges.

23 JUDGE ORIE: Yes. I went too fast.

24 THE WITNESS: Well, we're jumping ahead to the next document

25 because it relates only to the first list.

1 MR. HANNIS:

2 Q. Which candidates were those, judges or prosecutors?

3 A. Prosecutors. So the first list of prosecutors, the next document

4 that you see, it's the decision on appointing deputy public prosecutors in

5 Banja Luka, signed by Momcilo Krajisnik as president of the Assembly,

6 dated the 11th of August. And that list -- the appointments here

7 correspond to the Serb names on that list of proposed candidates, and the

8 Muslim name is not appointed, which had been X-ed out on the list.

9 Q. Can you refer us to the B/C/S ERN?

10 A. Of the decision? I'm sorry. Of the decision?

11 Q. Yes.

12 A. I'm sorry. It is 03234584 through 03234585.

13 Q. And the last name that was on the list in the previous document

14 among prosecutor candidates was the Muslim name?

15 A. Yes.

16 Q. And that person was not appointed?

17 A. Correct.

18 Q. Thank you. Next, I would like to --

19 JUDGE HANOTEAU: [Interpretation] May I ask a question, a very

20 brief question?

21 I'm somewhat confused, I'm somewhat lost, with these lists, and I

22 would like to get an explanation. I'm still with tab 215. We have a

23 first list of names under our eyes here, and this first list of names has

24 11 names. You told us that the last name was a Muslim name, that this

25 name was a Muslim name. That's the eleventh name; is that correct?

1 THE WITNESS: Yes.

2 JUDGE HANOTEAU: [Interpretation] But the following list, what does

3 it represent? We have the second list. We can see that there are 50

4 names on this second list. Some numbers are circled and other numbers are

5 crossed out, or there's a cross over them. You explained this to us, but

6 I didn't really quite understand. Thank you, ma'am.

7 THE WITNESS: Yes. Perhaps, if I can show the original, because

8 it's not in Cyrillic, it might be quite clear. The second list, the

9 longer list, is candidates for judge, so it's separate -- it's not -- it's

10 a separate list from the first list. For the first list, we have the

11 decision on appointments; for this one, we do not. But if you look at the

12 original, for each name, the nationality is underlined, and each name that

13 is underlined is Serb there in the original, Srpkinja or Srbinje is

14 circled. Each name that is not a Serb nationality is crossed out. On the

15 first page of the list, that's 03234589, you can see the first crossed-out

16 name, the nationality Hrvatica, means Croatian. Numbers 8 and 9 -- okay,

17 number 8 is Srpkinja, is a Serb, but I would note that her father is

18 identified as Avdo and the last name is Fazlic -- sorry, her married name

19 is Fazlic. The Avdo would be a typically Muslim name. She identifies

20 herself as Serb, and her name is crossed out. But Fazlic also is more

21 usually a Muslim last name, although that is harder to judge. That is one

22 of the exceptions of a Serb being crossed out. The next name that's

23 crossed out is, in fact, Muslim. The next page, the name that's crossed

24 out, number 14, is Croat. Number 19, crossed out, Yugoslav; 20, Yugoslav,

25 crossed out; 24, Slovene, crossed out; 25, Muslim, crossed out; 26,

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1 Muslim, crossed out; 29, Yugoslav, crossed, and so on.

2 There are a few Serb names that are crossed out, but there is an

3 explanation following this list that refugees cannot be employed, and the

4 indication is that these are -- the indication from where they worked

5 before, that they are not from Banja Luka, and it is my opinion that it's

6 likely that they were refugees and therefore names were crossed out as not

7 suitable. But it is notable that nobody identified as a Muslim or Croat

8 has their name circled. Somebody marked up this list, it's clear, and

9 identified the nationality by underlining, in addition to naming it when

10 they drew up the list.

11 JUDGE HANOTEAU: [Interpretation] Thank you very much, witness.

12 MR. HANNIS: Thank you.

13 Q. Ms. Hanson, I now wanted to move on to another topic. In your

14 report, at paragraph 61, you talk about how Crisis Staffs carried out a

15 policy and procedures for the removal or forcible departure of non-Serbs.

16 I'd like you to take a look at tab 217 in the presentation, that's master

17 tab 141. This is a Crisis Staff decision from the 30th of May, 1992, from

18 Sanski Most. It's a document we've seen before on another topic, but

19 could you tell us how it pertains to this?

20 A. Yes. Under item 2, at the bottom of the first page in

21 translation, the second paragraph on the second page of the B/C/S,

22 00471744, notes that the Crisis Staff needs to find a long-term solution

23 for Muslims and Croats who are not loyal to the constitution and laws of

24 the Serbian Republic of BiH, which means that all those who've not taken

25 up arms and want to change their municipality are to be allowed to move

1 away.

2 The Crisis Staff also notes that they should make contact with the

3 leadership of the Autonomous Region of Krajina regarding implementation on

4 the idea of resettlement of the population.

5 Q. Thank you. Next, I would like to show you presentation tab 218,

6 master tab 426. This is from Bosanski Novi Crisis Staff.

7 A. Yes. This is an announcement of the Crisis Staff of Bosanski

8 Novi, dated the 8th of June, addressed to the citizens of Blagaj and the

9 Japra valley, saying that in regard to the war operations and a decision

10 -- information from the Red Cross of Bosanski Novi about the departure of

11 Muslims -- the problem of the departure of Muslims, the Crisis Staff here

12 advises the citizens that they are prepared to provide peaceful and secure

13 departure of the Muslim population from that area. "With a view to your

14 security, it is necessary to form a departure column immediately. If

15 these proposals are rejected, the Crisis Staff will no longer be able to

16 guarantee security for Muslims in this area."

17 Q. Thank you.

18 MR. HANNIS: Your Honours, we would recall you to the testimony of

19 a couple of crime-base witnesses from Bosanski Novi about how they came to

20 be moved out of that area.

21 Q. Next, Ms. Hanson, I would ask you to look at presentation tab 219,

22 master tab 295. This is from, I think, a document that we looked at other

23 portions of before, and I think the excerpt you want to talk about here is

24 on page 10 of the English translation. Can you direct Mr. Krajisnik to

25 the appropriate place in the B/C/S?

1 A. In the B/C/S, it's on page 12 of the document, B0032538, the last

2 full paragraph from the bottom of that page. It notes that 3.500 Muslims

3 from the Japra valley came to an agreement with the Crisis Staff of the

4 municipality of Bosanski Novi, and on the 9th of June, left the

5 municipality in the direction of Doboj. The previous document was dated

6 the 8th of June. "This resettlement was done by rail in a train composed

7 of 22 wagons. The SJB has no precise data because these citizens did not

8 officially unregister their residents in accordance with the law."

9 I take that is a confirmation related to the previous document.

10 Q. Thank you. Let's go on to another municipality. Presentation tab

11 220, master tab 427. This is from the Gacko municipality.

12 A. Yes. It's a proclamation of the War Presidency of Gacko, dated

13 the 31st of July, 1992, a proclamation to the Muslim people in Bileca,

14 telling them to come down out of -- where they had sought refuge in the

15 mountains, saying -- I take attention to item 3 on the list, bottom of the

16 first page of the translation; in the B/C/S, on the second page, 02096314,

17 item 3 on the first -- on the top of the page.

18 "After leaving the mountains, you will immediately be put on

19 buses. The women, children and the elderly will be taken where they wish

20 to go, while the men fit for military service will be taken to the

21 garrison prison in Bileca."

22 And item 5 on the next page in the translation: "The possible

23 destinations are Stolac, Mostar, and Macedonia. There are no other

24 possibilities due to the present circumstances."

25 So although they say that they may go -- be sent where they wish

1 to go, in fact their only choices are in either territory held by the

2 Bosnian and Croat forces -- Muslim and Croat forces in Bosnia or

3 Macedonia, another country altogether. And the men, of course, will be

4 sent to the prison.

5 Q. Thank you. I now want to show you tab 221, master tab number 13.

6 This is from the Prnjavor municipality.

7 A. Yes. This is a decision of the Crisis Staff, dated the 22nd of

8 June, 1992, "a decision on the organised moving out of refugees disloyal

9 to the authorities of the Serbian Republic of Bosnia and Herzegovina."

10 Under Article 1, it says: "All refugees who are disloyal to the

11 authorities, as well as refugees whose relatives are members of enemy

12 formations, are obliged to leave Prnjavor in an organised fashion." And

13 it tasks the police station, the public security station, to implement

14 this decision.

15 Q. Thank you. Now let me show you tab 222, master tab number 221.

16 This is from the Bosanska Krupa municipality, although in connection with

17 that I see there's a different name on the front of that report.

18 A. Yes. Krupa na Uni, Krupa on the Una river, just as we saw that

19 Bosanski Petrovac dropped the "Bosanski", similarly here, Krupa is

20 dropping the Bosnian identification and calling itself simply the Krupa on

21 the Una.

22 Q. This is a long document.

23 A. It's on page 5 in the translation, the last two paragraphs on that

24 page, and I will look for the -- there it is. The B/C/S is page 4 of the

25 B/C/S, that is, 00552818. It mentions that -- in discussing the work of

1 the Crisis Staff, they discuss the Crisis Staff's involvement in the

2 removal of Muslims. In the beginning of the third paragraph on page --

3 I'm sorry, in the middle of the third paragraph:

4 "The War Presidency of the Serbian municipality offered the

5 Muslims two options. They could organise themselves and, with our

6 guarantees and full protection, move out to the destination of their

7 transfer, or this would be done by military means."

8 In the next -- beginning of the next paragraph, they explain that:

9 "The reason for adopting this decision on the temporary transfer was the

10 physical safety of the Muslim people and the historically proved and

11 confirmed nobility and kindness of Serbs who do not have a propensity for

12 crimes and genocide."

13 Q. Let me ask you for a comment regarding --

14 MR. STEWART: Your Honour, in relation to that, of course it's

15 necessary to avoid reading out all sorts of superfluous context, but from

16 the English translation, what Ms. Hanson read out here in open court

17 started in the middle of a sentence, and really, in this particular case,

18 I do suggest that the whole sentence should have been read out and should

19 now be read out.

20 JUDGE ORIE: Please indicate where you'd like Ms. Hanson to start.

21 MR. STEWART: The words "the weak response" in the translation,

22 which is almost halfway down that penultimate paragraph on page 5.

23 MR. HANNIS:

24 Q. Did you find that, Ms. Hanson?

25 A. You wish me to read that?

1 JUDGE ORIE: Yes, please.

2 A. "The weak response or total disregard of Muslims to the call for

3 surrender of arms, and Alija's threat that Krupa must become green

4 whatever the cost, forced the War Presidency of the Serbian municipality

5 to offer the Muslims two options: They could organise themselves and,

6 with our guarantees and full protection, move out to the destination of

7 their transfer; or this would be done by military means."

8 MR. STEWART: Thank you, Your Honour.

9 MR. HANNIS:

10 Q. Before we leave that one, the second statement you read to us made

11 a reference to the temporary nature of the removal. Can you comment on

12 that what regard to what Miroslav Vjestica from Krupa had to say in the

13 municipality?

14 A. He said to the Bosnian Serb Assembly on the 12th of May that he --

15 having heard the happy news of where the borders will be set, he does not

16 think that there will be a place for Muslims to return to.

17 Q. Thank you. Next, I would like to show you presentation tab 223,

18 master tab number 342. This is also from Bosanska Krupa.

19 A. Yes. This is an order of the War Presidency of Bosanska Krupa,

20 dated the 22nd of May, 1992, an order to evacuate the remaining Muslim

21 population from the territory of Bosanska Krupa, and, again, tasking the

22 public security station and the military police to implement this order on

23 evacuation. And the evacuation should be directed towards Cazin Krajina.

24 Cazin Krajina was an area of Bosnia held by -- not claimed by the Serbs,

25 so Bosnian Muslim territory.

1 I would note here, it says "the remaining population," those

2 who've not yet left are to leave.

3 Q. Thank you.

4 MR. HANNIS: Next, Your Honours, at presentation tab 224, master

5 tab 429.

6 Q. This is an intercept, an intercepted telephone conversation from

7 the 12th of May, 1992. And can you tell us who the speakers are and where

8 we're beginning on both the English and B/C/S versions of the hard copy?

9 A. The speaker -- one speaker is identified as Nedeljko Prstojevic,

10 as we've seen, commander of the Ilidza Crisis Staff. The others are an

11 unidentified Milenko and then an unidentified Novakovic. I don't have any

12 information on who they might be. The excerpt starts in the seventh box

13 -- oh, no, I'm sorry, I don't -- the sixth -- fifth box from the bottom,

14 Prstojevic saying, "Why did Mika phone me?" I'll find it in the B/C/S.

15 It's at the top -- towards the top of the second page, 04013854, the sixth

16 box from the top.

17 Q. Thank you.

18 MR. HANNIS: I would note for the interpreters, as I recall, I

19 think this is a pretty rapid conversation, and it's about two pages.

20 We're ready to play it.

21 [Intercept played]

22 THE INTERPRETER: [Voiceover]

23 "Nedeljko PRSTOJEVIC: Why did Mika phone me?

24 Milenko: Milenko ... phoned you to check with you ... these

25 people in Kotorac.

1 Nedeljko PRSTOJEVIC: Yes.

2 Milenko: What should we do with them?

3 Nedeljko PRSTOJEVIC: Did you arrest them? What did you do.

4 Milenko: People are down there on ... Just a second, one second

5 ... (Milenko is telling people in the room to be quiet) Yes?

6 Nedeljko PRSTOJEVIC: Hello?

7 Milenko: Yes?

8 Nedeljko PRSTOJEVIC: And where are those people? Have they been

9 arrested?

10 Milenko: No.

11 Nedeljko PRSTOJEVIC: What then?

12 Milenko: ... Down there on the road, all of them. Men are

13 separated from women.

14 Nedeljko PRSTOJEVIC: Ha ...

15 Milenko: Just a second, just a second.

16 Nedeljko PRSTOJEVIC: ... Up there... right?

17 Milenko: He says men ... I've just received the word: Men are in

18 the Kula prison, and women went in the direction of Butmir.

19 Nedeljko PRSTOJEVIC: Put Tepavcevic on.

20 Milenko: Here, here's Novakovic. He will talk with you. It's

21 Prstojevic, stop fooling around.

22 NOVAKOVIC: Hello?

23 Nedeljko PRSTOJEVIC: Hello?

24 NOVAKOVIC: Hi, Nedja.

25 Nedeljko PRSTOJEVIC: Hi.

1 NOVAKOVIC: How are you?

2 Nedeljko PRSTOJEVIC: I'm fine. Have you been cleaning Kotorac

3 today?

4 NOVAKOVIC: They have. I don't know the exact details, because I

5 was engaged otherwise.

6 Nedeljko PRSTOJEVIC: Yes.

7 NOVAKOVIC: Well, if you want we will call you later, well, while

8 ...

9 Nedeljko PRSTOJEVIC: That's ok, but tell me, please, I beg of

10 you, why did you take women to Butmir?

11 NOVAKOVIC: They said women were not in Butmir but ...

12 Nedeljko PRSTOJEVIC: But?

13 NOVAKOVIC: Well, in Butmir, yes. Not to KP Dom, but to Butmir.

14 That's where they're going.

15 Nedeljko PRSTOJEVIC: They cannot go to Butmir, we'll mop up

16 Butmir in time as well.

17 NOVAKOVIC: Aha.

18 Nedeljko PRSTOJEVIC: Butmir will be mopped up, Sokolovic will be

19 mopped up, Hrasnica will be mopped up.

20 NOVAKOVIC: Well, I don't know where to take them?

21 Nedeljko PRSTOJEVIC: They will all ... There is Bascarsija.

22 Please take all of them to Bascarsija, on foot.

23 NOVAKOVIC: Aha, aha.

24 Nedeljko PRSTOJEVIC: Women.

25 NOVAKOVIC: OK, now I'll ...

1 Nedeljko PRSTOJEVIC: And men to prison.

2 NOVAKOVIC: OK. I'll check with them now and then I'll let you

3 know.

4 Nedeljko PRSTOJEVIC: Yes. Tell them, those who convert to

5 Orthodox religion on the spot, they can stay, women and children.

6 NOVAKOVIC: Aha. OK. OK, now I'll ...

7 Nedeljko PRSTOJEVIC: Do it, please, but don't make mistakes ...

8 You've done an excellent job, but it means that Butmir will be mopped up

9 in time. Tell that to the people there.

10 NOVAKOVIC: Yes, yes. OK.

11 Nedeljko PRSTOJEVIC: There you go. Cheers.

12 NOVAKOVIC: OK."

13 MR. HANNIS:

14 Q. Ms. Hanson, do you have any comment on that?

15 A. Well, first of all, the word that is translated as mopped up here

16 is cistiti, or cistite. And in terms of what he means, mopping up, his

17 emphasis that women who convert to Orthodox religion can stay, men will go

18 to prison; otherwise, the women go to Bascarsija, that is, the centre of

19 Sarajevo, which was held by the Bosnian Muslims at this time, indicates

20 that it's not just about military operations to my mind; that those who

21 convert to the Orthodox religion can stay, is a striking statement. And

22 that he's planning to -- he has intention to cleanse, clear, mop up,

23 certain neighbourhoods and therefore does not want more Muslims sent

24 there, I think, is indicative of an -- his planning for future operations

25 in those regions, those areas, neighbourhoods.

1 Q. And did you see some -- we've talked about a few examples of where

2 the Muslims were being removed from individual municipalities. Did you

3 see some examples where there was coordination between more than one

4 municipality in this process?

5 A. Yes, I did.

6 Q. Let me show you tab 225 in the presentation, master tab 343, and

7 ask you what that is.

8 A. This document is called "Conclusions Adopted at a Subregional

9 Meeting of Political Representatives of the Municipalities of Bihac,

10 Bosanski Petrovac, Srpska Krupa" is how Krupa is described here, "Sanski

11 Most, Prijedor, Bosanski Novi, and Kljuc," and sent to a Crisis Staff of

12 the autonomous region of Banja Luka, the leadership of the Serbian

13 Republic of Bosnia-Herzegovina in Sarajevo, and the 1st Krajina Corps.

14 It's dated the 7th of June, 1992.

15 I would note in this context, particularly item 6, which is on the

16 second page of the translation and also of the B/C/S.

17 "That all seven municipalities here agree that Muslims and Croats

18 should move out of our municipalities until a level is reached where

19 Serbian authority can be maintained and implemented on its own territory

20 in each of these municipalities."

21 The paragraph goes on to note that if the ARK leadership fails to

22 solve this issue, "our seven municipalities will take all Muslims and

23 Croats under military escort from our municipalities to the centre of

24 Banja Luka."

25 Q. Thank you. Next, I want to go on to another paragraph in your

1 report, paragraph 62. You talk about how Crisis Staffs oversaw the

2 removal of non-Serbs by establishing variously named committees or

3 agencies, for example, Committee for Immigration, Travel Agency, Exchange

4 Agency.

5 Let me show you tab 226 in the presentation, master tab 325. This

6 is from Kotor Varos. Tell us about this one, please.

7 A. This is minutes of the War Presidency of Kotor Varos, dated the

8 14th of July, 1992. On the first page in both the English and B/C/S,

9 under item 2, the War Presidency says that: "Activities relating to

10 moving out the population failed to meet expectations. This task must be

11 dealt with in a much more organised fashion. An agency has to be

12 established to handle these matters."

13 I've seen agencies, as you mentioned, various kinds of agencies,

14 some dealing with the exchange of property of those leaving and others

15 with larger issues of how to move out -- move the population.

16 MR. HANNIS: Your Honours, we'll skip the next tab, 227. It's

17 referred to in a footnote in her report, and go to presentation tab 228,

18 master tab 350.

19 Q. This is a document from Sanski Most on the 2nd of July, 1992. Did

20 the Crisis Staffs set any criteria before people would be allowed to

21 depart?

22 A. Yes. I saw several decisions on the criteria for moving out.

23 This is one such decision from Sanski Most, dated the 2nd of July, 1992.

24 Under Article 1, it notes that families and people may leave voluntarily

25 from Sanski Most if they give a statement to the appropriate municipal

1 organ that they are permanently leaving, and that they are leaving their

2 real property to Sanski Most municipality.

3 Q. Now, you mentioned -- did you see similar requirements in some of

4 the other municipalities for being allowed to depart, in particular an

5 indication that the departure was permanent?

6 A. Several such decisions specify the arrangements for the real

7 estate and the permanency of that -- the disposing of the real estate.

8 Q. Let me take you next to tab 229 in the presentation, master tab

9 344. This is from Petrovac.

10 A. Yes. It's an information or statement based on the decision of

11 the War Presidency, dated 31st of July, 1992, and the statement is

12 regarding the conditions by which Muslims may move away voluntarily from

13 the municipality. And they may do so if they either exchange -- sign a

14 contract on the exchange of their property or leave their property to the

15 state. Notable here, at the bottom -- the last sentence of the first

16 item, that "property may be given to close relatives from mixed

17 marriages." So Muslims may leave but they -- the implication here is that

18 only those from mixed marriages can leave their property to

19 relatives. Others have to either exchange it or give it to the state.

20 Q. Thank you. Let me show you next presentation tab 230, master tab

21 354 --

22 JUDGE HANOTEAU: [Interpretation] May I just ask a question? Did

23 you find some examples, Witness, where there was an exchange of real

24 estate? You seem to suggest to us that people would accept to sell and to

25 receive another building in exchange, or another apartment in exchange.

1 Do you have examples showing that this in fact took place?

2 THE WITNESS: I do not recall seeing such examples; however, I

3 would -- in that respect, I'm always dependent upon the evidence we have,

4 and such agreements might be kept by people -- the people involved. And

5 because we have records of -- from the municipal side, such agreements may

6 not have entered the municipal record. But in terms of the documents I

7 examined for this, I do not recall seeing such agreements, but I do see

8 many indications of agencies being set up for this exchange, of the

9 municipal authorities apparently creating the possibility for that.

10 MR. HANNIS: And Your Honour --

11 JUDGE HANOTEAU: [Interpretation] Thank you, madam.

12 MR. HANNIS: -- if I may indicate, I believe in the trial so far, I

13 think both from one or two viva voce witnesses and some of the 92 bis

14 materials, we have had some of our crime-base witnesses speak to this

15 particular issue. I can't point you to a specific point, Your Honour, but

16 there is some evidence on that that may be of assistance to you.

17 JUDGE ORIE: If my recollection is right, it was one of the Pale

18 witnesses.

19 MR. HANNIS: I think he did talk about an exchange of property and

20 what he got when he got to Sarajevo. Thank you, Your Honour.

21 Q. Next, I think you have before you the presentation tab 230 --

22 A. Yes, minutes of the War Presidency of Kotor Varos, dated the 29th

23 of July, 1992. Here, I would draw your attention to item number 7, that

24 the War Presidency says that people "moving away should be informed that

25 they are allowed to take with them no more than 300 Deutschemarks."

1 Q. Thank you. Next, with regard to this process, I want to ask you

2 about tab number 231 in the presentation, master tab 355. This is from

3 Bosanska Krupa.

4 A. Yes. This is instructions on the evacuation of refugees -- of the

5 inhabitants and refugees from the local community of Arapusa. It's signed

6 by a representative from Arapusa from the refugee committee and from the

7 command of the battalion, dated the 1st of May, 1992.

8 At the beginning of the instructions, they refer to the order of

9 the war staff of the Serb municipality of Bosanska Krupa, dated the 29th

10 of April, 1992, by which the evacuation of the inhabitants and refugees

11 from Bosanska Krupa is ordered. And it's showing that on the basis of

12 that order, the local community has organised -- prepared a plan of

13 evacuation. Arapusa, I would point out, was a predominantly Muslim

14 settlement.

15 Q. Thank you.

16 MR. HANNIS: Your Honours, the next one, I think, we'll skip, 232.

17 This is in Ms. Hanson's report in a footnote and pertains to payment of

18 transportation for refugees from Zvornik.

19 Q. 233 in the presentation, master tab 300. Ms. Hanson, this is from

20 Sanski Most municipality.

21 A. Yes. The conclusions of the Crisis Staff of Sanski Most, dated

22 the 23rd of June, 1992. Here, I would draw your attention to what is

23 listed as item (h) on the first page; in the B/C/S, I'm just checking

24 where it -- oh, yes, it's (g) in the B/C/S. No, I'm sorry, I'm confused

25 here. I'm sorry, it's at the bottom of the first page in the B/C/S, under

1

2

3

4

5

6

7

8

9

10

11

12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

1 letter (e). The Cyrillic -- it's not -- anyway, I'm sorry, I'm confused.

2 The sentence I want to read is that: "Nedeljko Rasula and Mladen

3 Lukic are given the task of travelling to Prijedor to negotiate quantities

4 of fuel for the use of Sanski Most municipality and at the same time to

5 ask about the possibilities of the passage of a convoy of people who would

6 like to travel by rail into Central Bosnia."

7 Central Bosnia, at this time, I take that to be a reference to

8 territory held by the Bosnian Muslim forces. And so we see that the

9 Crisis Staff is talking to other municipalities about arranging passage --

10 arranging convoys.

11 Q. Thank you.

12 MR. HANNIS: Your Honour, that takes us to the end of binder

13 number 5. We're just -- I don't know if you want to take a break at the

14 normal 10.30 time; in light of our late start, if you want to continue on.

15 JUDGE ORIE: We have to take two breaks anyhow, so whether this

16 would be a better moment or after the -- you've introduced your new

17 subject. I'll leave it up to you. But somewhere within the next seven to

18 eight minutes.

19 MR. HANNIS: Let me just ask her a question to follow up on the

20 topics we've just been talking about, and then I'll ask if we can take a

21 break.

22 Q. Ms. Hanson, that just concludes our discussion of how the Crisis

23 Staffs were involved in the removal of non-Serbs. In some of the

24 documents we saw, and some that you referred to in your report, the

25 municipality authorities and in some of the higher level authorities, they

1 seemed to indicate that they're simply trying to help the non-Serbs who

2 want to leave the area. Do you have any comment on that?

3 A. We do see that. However, I have not seen references to Crisis

4 Staffs discussing the possibility of moving those people to another safe

5 part of the Serbian municipality or to another safe area of the Bosnian

6 Serb territory. But the idea of safety seems to refer to moving them out

7 of Serb territory altogether.

8 Q. And did you see in some of the documents you reviewed for this

9 where there were discussions, for example, in the municipality, in the

10 Crisis Staff meetings, where local Muslims or other non-Serbs were

11 requesting to be allowed to stay?

12 A. I'm sorry, could you repeat the question?

13 Q. Did you see any examples in the documents where the local Muslims

14 were requesting to be allowed to stay, even though there were wartime

15 conditions and a lot of anti-non-Serb bias?

16 A. No, I don't recall seeing any such requests of Muslims who wanted

17 to say.

18 Q. As for the removal, whether it was temporary or permanent, did you

19 see any evidence to suggest that it was not temporary?

20 A. Yes, we saw -- as we see, the decisions regarding property

21 indicate that it's permanent. We do see -- we looked at briefly in the

22 Krupa War Presidency, they say it was for their temporary removal, but we

23 also have the comments of a member of that War Presidency that he does not

24 expect the Muslims to return. We also see War Presidencies and Crisis

25 Staffs deciding who can return and cannot, and taking -- making efforts to

1 return Serbs but not making the same efforts to return non-Serbs.

2 MR. HANNIS: Your Honour, I'm about to go into another area. Can

3 we take a break at this point?

4 JUDGE ORIE: Then we'll have a break. We had a late start --

5 we'll resume at 10.55, five minutes to 11.00.

6 --- Recess taken at 10.30 a.m.

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

8 JUDGE ORIE: The fact that the Chamber returned late gives no

9 right to the parties. It's always because there are a lot of things to do

10 during the breaks which sometimes take even more time than expected.

11 Please proceed, Mr. Hannis.

12 MR. HANNIS: Thank you, Your Honour.

13 Q. Now, Ms. Hanson, we just finished talking about the removal of

14 non-Serbs from the municipality, and discussed the issue about whether

15 that was meant to be temporary or permanent. In your report, at paragraph

16 63, you talked about how the Crisis Staff oversaw the collection and

17 redistribution of the property that had been left behind when the

18 non-Serbs left or were forced to leave, and, in many cases, signed over

19 their property.

20 Binder tab 234 is a document we looked at before, which is from a

21 Presidency decision, and I'll skip over that one, Your Honours, and go to

22 235, which is master tab 357, and, Ms. Hanson, ask you to direct us to the

23 page in that document you want to talk about and what point it illustrates

24 regarding ...

25 A. Yes. This is also a document we have seen before, the accounts of

1 the Serbian municipality of Ilijas. But in this context, I would just

2 turn you to the last page of the translation, the B/C/S page 02252626,

3 where, after the summary, there are some remarks. And the first remark

4 notes that some of the income came from goods taken by the Crisis Staff's

5 order, from the shop of Mirsad Tokac -- I'm sorry, it does not say that it

6 was part of the income. I was misunderstanding from the first page. But

7 it says that goods were taken by order of the Crisis Staff from the man's

8 shop to the Trgopromet company. So it's -- the name of the shop owner,

9 Mirsad, is a typically Muslim name.

10 Q. And was there an estimated value of the property that was taken?

11 A. Yes. 1.500.000 dinars, which is about -- I had the figure in my

12 notes, I'm sorry, I don't have it with me.

13 Q. I think you had indicated it was somewhere in the neighbourhood of

14 $4.600 at the time.

15 A. Yes, just as an indication.

16 MR. HANNIS: Your Honours, I'd like to skip the next presentation

17 236, it's a document in the footnotes to her report, and go to tab 237,

18 which is master tab number 430.

19 JUDGE HANOTEAU: [Interpretation] Mr. Hannis, I have a question for

20 the witness, if you don't mind.

21 MR. HANNIS: Certainly, Your Honour.

22 JUDGE HANOTEAU: [Interpretation] In document 235, I do not

23 understand "for incomes." What was the status of the Snaga shop or

24 supermarket manager, Ozren Hotel? Maybe this is rather naive question,

25 but had these shops being requisitioned? Did they belong to someone?

1 Were these shops then operated directly by the municipality of the

2 commune? Can you give us some information about this. It's not the

3 Crisis Staff who was directly operating or managing these establishments.

4 Did they appoint someone to operate these establishments? Can you provide

5 us some more information about this, please?

6 THE WITNESS: I have no further information on these institutions

7 in Ilijas. Ilijas is not a municipality for which we have very detailed

8 reports, so I don't know whether this came as a tax on -- a sales tax, tax

9 on income from these businesses, or whether these were businesses whose

10 profits went directly to the municipality. I have no further information.

11 JUDGE HANOTEAU: [Interpretation] Thank you. But, in other cases

12 you've studied, was it customary for municipalities to directly manage, to

13 directly operate goods or properties that, in the past, belonged to

14 individuals? Do you have any other examples?

15 THE WITNESS: I have no examples of that, to my knowledge, to my

16 recollection.

17 JUDGE HANOTEAU: [Interpretation] Thank you, Witness.

18 MR. HANNIS: Your Honour, I would note that in our upcoming

19 witness schedule, I think we have two or three witnesses from Ilijas who

20 will testify in a couple of weeks, so we may be able to address that issue

21 at that time. Thank you.

22 Q. Ms. Hanson --

23 MR. STEWART: Subject to the ruling on the application for an

24 adjournment, Mr. Hannis means, Your Honour.

25 MR. HANNIS: Certainly.

1 JUDGE ORIE: That's only for the weeks to come. But I take it

2 that's somewhere in the presentation of the Prosecution case, and that's

3 how I understood Mr. Hannis's remark. The timing is, I fully agree,

4 totally in the hands of the Chamber.

5 Please proceed.

6 MR. HANNIS: Thank you.

7 Q. Ms. Hanson, I'd like to go next to presentation tab 237, which is

8 master tab 430. This is a document from Prnjavor.

9 A. Yes. The decision of the Crisis Staff, dated the 23rd of June,

10 1992, on -- instructing those who have -- citizens of the municipality who

11 have left to report to the municipal secretariat for economy, urban

12 planning and finance, by the 10th of July. If they fail to report, their

13 property "shall be declared the property of the state and placed at the

14 disposal of the municipality of Prnjavor." I would note in this context

15 that it's not a long time period from the date of the decision to the date

16 by which they lose their right to the property.

17 Q. And is there any indication in that document that the proceeds

18 from that property would be held in trust in the event that the owners

19 were to return after the conflict died down?

20 A. No. It says it would be declared the property of the state and at

21 the disposal of the municipality.

22 Q. Let me show you next presentation tab 238, master tab 364. This

23 is a document from Kotor Varos, on the 28th of July, 1992.

24 A. From the minutes of the War Presidency. Under item 2 on the

25 middle of the first page of the translation: "In relation to the report

1 of the chief of the public security station on confiscating the money of

2 individuals who are moving out, it was established that this was being

3 done without anyone's order, i.e., in an unauthorised manner," and so it

4 was decided that the money confiscated in this manner -- I'll finish the

5 sentence. I was trying to summarise, not trying to leave out anything

6 significant. "... this can have a negative effect on the operation and

7 the reputation of all of us. It was decided that the money confiscated in

8 this matter will be used to help the families of soldiers killed and other

9 essential costs of the Municipality."

10 Q. Thank you. In your report, at paragraph 64, you indicate that

11 that is a sign that the removal was meant to be permanent rather than

12 temporary, that some Crisis Staffs took measures to ensure non-Serbs would

13 not return.

14 Let me show you presentation tab 239, master tab 367, in that

15 regard.

16 A. This is a document on a conclusion of the war staff of Kalinovik,

17 discussing a decision made on the 17th of May. It doesn't quite have the

18 form of a regular conclusion, but it is signed and stamped. It's just

19 that the date isn't in the usual place.

20 Notable here, the second paragraph. The conclusion is regarding

21 men of military age, of Muslim nationality, that they were to report to

22 the secretariat for national defence between the 20th and the 25th of May;

23 if they fail to report at this time, they shall be proclaimed opponents of

24 the SOS, banned from returning to the municipality, and their property

25 shall be confiscated.

1 Q. I think you have two more documents related to this point.

2 Presentation tab 240, master tab 368, this is from Kotor Varos Crisis

3 Staff or War Presidency, on the 11th of November, 1992.

4 A. At the end of item 2, the last paragraph of item 2, the War

5 Presidency wants to form a commission to make a selection of which -- to

6 allow some refugees to return to their homes, but not others.

7 Q. Does it mention any criteria which will be used for that purpose?

8 A. It doesn't specify that here, but it's the War Presidency,

9 apparently, who's setting up the commission.

10 Q. Finally, on this issue, let me show you presentation tab 241,

11 master tab 366. This is from the Ilidza municipality.

12 A. It's titled "A Programme for the Return of Serbs from SR

13 Yugoslavia," dated the 21st of June, 1992. Under item 4, at the bottom of

14 page 1, this plan notes that -- if I could just see the ...

15 It seems that the revised translation has not gotten into the

16 binders. Could I read the B/C/S and have the interpreters translate the

17 relevant passage?

18 Q. Please do.

19 A. Okay. I'm getting confused with these. Okay.

20 [Interpretation] "From the Serbian municipality of Ilidza, not

21 only the Muslim and Croatian population moved out or ran away, but also

22 our own Serbian population. In order to have the Serbian population

23 return, we kindly ask the government of the Serbian Bosnia-Herzegovina to

24 adopt the following stances: 1, to take every possible step for the

25 return of the displaced persons, refugeed Serbs."

1 [In English] The emphasis in the original is that not only Muslims

2 and Croats left Ilidza, but also "our Serbs," and the emphasis is on

3 returning the Serbs from Yugoslavia. So the intention here of this

4 municipality appears to be to make -- take efforts to return the Serbs,

5 but not all who left.

6 Q. And no mention of non-Serbs?

7 A. No mention of returning non-Serbs.

8 Q. Now, Ms. Hanson, that concludes the documents we wanted to show in

9 the presentation related to your report. We talked in the beginning that

10 you had prepared some case studies for three separate municipalities to

11 sort of reflect the overall points you've been making.

12 Before we move to that, was there anything you wanted to say to,

13 sort of, sum up what we've talked about so far, before we do that, or do

14 you want to go to the case study of Kljuc?

15 A. I would direct the Court to my report. My written conclusions are

16 perhaps more eloquent than I can say now.

17 Q. Thank you.

18 MR. HANNIS: And, Your Honours, those are contained in paragraphs

19 65 through 69 of her report.

20 Q. With that, then, Your Honours, I would like to talk about some of

21 the case studies.

22 First of all, would you tell us, briefly, how you chose those

23 municipalities, and why you chose them, and what you intend to show with

24 these case studies?

25 A. I wanted to show what a good collection of Crisis Staff documents

1 can tell us about the day-to-day operations of Crisis Staffs, and how they

2 illustrate the themes which I've discussed. So I selected municipalities

3 for which we have good, consistent documentary evidence, none of it, of

4 course, perfect, 100 per cent complete. And many municipalities do not

5 have such extensive collections. But that was one criterion.

6 I also -- to show the extent of the pattern, I wanted a

7 geographical distribution, so, according to those criteria, the best

8 examples were Kljuc, Trnovo, and Bratunac.

9 MR. STEWART: Your Honour, could I just observe that -- I've just

10 noticed that when there was a reference a few moments ago to paragraph 65

11 through 69 of Ms. Hanson's report, the numbering doesn't seem to fit. Of

12 course, this is evidence in chief and I get to cross-examine, but I don't

13 think the actual paragraph numbering fits what it was probably intended to

14 say as a wrap-up of that bit of the evidence.

15 JUDGE ORIE: I also notice that somewhere in this range we jump to

16 the conclusions, for example, if I'm --

17 MR. STEWART: But 69 doesn't fit either, because 69 is the second

18 paragraph of the section dealing with conclusions, so I don't think it can

19 have been intended to be 65 to 69.

20 JUDGE ORIE: Ms. Hanson.

21 THE WITNESS: I don't have my report with me.

22 MR. HANNIS: I'm sorry, Your Honour, I misspoke. I was looking at

23 an earlier version. I think I should have said paragraphs 68 through 72.

24 JUDGE ORIE: Yes, that's the conclusions, then. So Mr. Hannis was

25 referring to your conclusions.

1 MR. HANNIS: Thank you. I thank Mr. Stewart.

2 JUDGE ORIE: May I, before you do so, Ms. Hanson, I do understand

3 that there are municipalities where there is more documentation as to

4 others. You used the words "pattern," which is, of course -- well, I

5 would say, to establish a pattern is not always an easy matter. May I

6 take it that, if -- from any of the less-documented municipalities, if

7 there is documentation which would go against your conclusion of what

8 would be your conclusion on the well-documented municipalities, you will

9 draw our attention to that when dealing with the matter.

10 THE WITNESS: Yes, of course, Your Honour.

11 JUDGE ORIE: Because we're talking about three municipalities.

12 There were many municipalities, and, of course, if you say they are

13 well-documented and this would allow us to establish, I would say, what

14 would be a pattern in these three municipalities, and might be a pattern

15 for the other municipalities as well on the condition that there are not

16 contradictory elements in those documents pertaining to the other

17 municipalities. Of course, I'm not asking for every detail. But if in

18 one of the other municipalities, although less documented, if you find

19 one, two, or three clear indications that it was different there, we would

20 like to be informed about that.

21 THE WITNESS: To clarify my comments, when presenting these case

22 studies, I'm not claiming that everything that happened in these

23 municipalities happened elsewhere. I'm not taking them to stand for other

24 municipalities. When I referred to a pattern, I meant the themes that I

25 discuss in my report. When I discuss a theme, such as the military role

1 or the question of detention centres, on one topic, I take from many

2 municipalities, and so we've been jumping around with a lot of documents.

3 What I wanted to do with the case studies was turn that study upside down

4 and say, Here's one municipality; what, of the topics I've discussed, can

5 we see there?

6 So I'm saying here's what happened in Kljuc. I'm not trying to

7 say that what happened in Kljuc happened in the same way in other

8 municipalities, but rather, the themes that I've discussed, we can see all

9 in one -- or a fairly finite set of documents.

10 JUDGE ORIE: That's clear. And you pointed in your report already

11 to sometimes a pattern not being very clear, such as on the military

12 matters, where you clearly indicated that it was different, depending on

13 presence of the JNA, different on whether orders were given or received.

14 So that's just for our understanding, that we know what you're talking

15 about if you talk about a pattern.

16 THE WITNESS: Yes.

17 JUDGE ORIE: Yes, thank you.

18 MR. HANNIS: Thank you, Your Honour.

19 Q. To follow up on that, Ms. Hanson, I think you've made that point

20 in your report, but we've also talked about this before, that you see wide

21 variation with regard to many of the themes in the various municipalities;

22 correct?

23 A. Yes.

24 Q. And you've talked about some of the factors that influence that.

25 Could you go through two or three of those for us again? I know one we

1 talked about: Location.

2 A. Location.

3 Q. And how did that affect?

4 A. Well, how closely the municipality was located to areas of

5 conflict, or how heavy the conflict was in that area; how close to the

6 border of the Serbian territory as opposed to being in the centre; the --

7 Q. You talked about timing.

8 A. The timing, as we saw, is -- what obtained in April is not

9 necessarily the same situation as obtained in June. My report, as I note,

10 is concentrated on that time period mostly, in terms of the most

11 interesting events at that time.

12 Q. And I think you mentioned before personalities.

13 A. The personalities involved. Some personalities just had more

14 interest in moving and shaking on the ground; some personalities had

15 closer contacts to the centre because of personal ties and political --

16 long-standing political ties. So that can also be a factor.

17 Also, the makeup of the population. We talk about variant A or

18 variant B, but, of course, some were much more heavily Serb, with very few

19 non-Serbs. Some had a closer balance of population. So those were all

20 factors.

21 I have to point out also, from my end, one variation is the amount

22 of evidence available to me, and I cannot know what we don't have. I

23 cannot know how much another municipality might have had documents that

24 were not made -- never got to the Tribunal, so that can also influence my

25 appearance of the pattern.

1 JUDGE ORIE: No one asks you to take into consideration material

2 you do not have. Only the fact that you have little information on

3 certain municipalities should make you more cautious in drawing any

4 conclusions.

5 Well, I think the context of your case studies is thus established

6 in such a way that we'd like to listen to it.

7 MR. HANNIS: Thank you, Your Honour.

8 Q. Now, with regard to Kljuc, before I show you the first document,

9 can you tell us briefly, what was the universe of documents from which you

10 were able to draw on in respect of that municipality?

11 A. We have a lot of minutes, handwritten I might note, of the SDS of

12 Kljuc, as well as a book of minutes of the Crisis Staff of Kljuc. That

13 book of minutes starts on the 27th of May, but prior to that we have other

14 -- and subsequent to that, because I believe it ends at the end of June,

15 we have other decisions of the Crisis Staff and War Presidency, and we

16 have a handwritten diary of a member of the Crisis Staff and War

17 Presidency. Kljuc is a municipality with quite good documentation

18 overall, which is, as I said, one of the criterion for selection.

19 Q. Let me begin by handing you presentation tab 242, which is master

20 tab 41, from the 23rd of December, 1991.

21 A. This is the minutes of the meeting of the executive board of the

22 SDS on the 23rd of December, 1991. We have seen this document briefly in

23 the discussion of the implementation of the 19 December instructions. But

24 just to take it a little more to see what the municipality was doing in

25 reaction and how -- to these instructions, and how they discussed them.

1 Kljuc was -- had a very close balance of Serbs and Muslims. The

2 Serbs were a slight majority, just over 49 per cent, while the Muslims

3 were, I believe, just over 47. So it was A, in terms of Serb majority,

4 but a close balance.

5 As we've seen before, under agenda item 1, briefing on the

6 materials arrived from the Serbian Assembly. Veljko Kondic informed the

7 meeting of the instructions for the organisation and activities of the

8 Serbian people in BiH. "All organs will be required to act in accordance

9 with the instructions. Whoever is not ready to fulfil its duties should

10 say so immediately, and it will not be held against him."

11 JUDGE ORIE: Ms. Hanson, we all are speaking more quickly when we

12 read than when we have to invent the words at the very moment.

13 THE WITNESS: Yes, my apologies.

14 A. I would note, then, further down on that page, which is in the

15 B/C/S -- because these are handwritten Cyrillic, finding the B/C/S will

16 always take me a moment longer. It's on page 00914529, in the middle of

17 the page. The composition of the Crisis Staff is consistent with the 19

18 December instructions. It includes the deputy in the Assembly. The

19 deputy from Kljuc was Rajko Kalabic, and we'll see that he speaks at this

20 meeting. I would also note that Ljuban Bajic is named as secretary of the

21 Crisis Staff. I note that because his diary is one of our exhibits. All

22 the appointments that they named to the Crisis Staff are consistent with

23 the 19 December instructions. And at the top of page 2 in the

24 translation, still on the same page in the B/C/S, Rajko Kalabic informed

25 those present on the issues considered in the second part of the Serbian

1

2

3

4

5

6

7

8

9

10

11

12 Blank page inserted to ensure pagination corresponds between the French and

13 English transcripts.

14

15

16

17

18

19

20

21

22

23

24

25

1 Assembly proceedings. There was a session of the Serbian Assembly on the

2 21st of December. So we see the channel of communication, the way -- as

3 described in the Assembly sessions before, that the deputies convey

4 information to the municipality. We see Kalabic doing that.

5 On the same page in the translation, and the next page in the

6 B/C/S, 00914530 -- oh, I'm sorry. I'm trying to avoid the highlighted

7 section. Pardon me.

8 One member asks that the meeting be informed about the second

9 stage, and Kalabic said: "The first stage is the preparation for the

10 second stage so there is no need to introduce the second stage," another

11 reference consistent with the 19 December instructions.

12 JUDGE ORIE: May I ask one question. If you say that "Rajko

13 Kalabic informed those present on the issues considered in the second part

14 of the Serbian Assembly proceedings" what is that exactly, the second

15 part?

16 THE WITNESS: The original says -- yes, the second part. I'm just

17 seeing where it says the "pauza". It says, if I read the B/C/S just to

18 see if the order of words makes anything more clear. This is on 00914529.

19 [Interpretation] "The second part of the Serbian Assembly, after

20 the break, the presidents were informed by Kalabic Rajko."

21 [In English] As to what they mean -- whether it means simply the

22 part after the break -- whether the break was in the Assembly session that

23 he's reporting on or in the -- this meeting here, it's not entirely clear.

24 But I'm not familiar enough with the proceedings of that Assembly session

25 to say that it was divided in two, or anything like that.

1 JUDGE ORIE: Yes.

2 MR. HANNIS: Thank you.

3 Q. Anything else on that document before I show you the next one?

4 A. No, that's all.

5 Q. Next, we'll have a look at presentation tab 243, master tab 148,

6 which is a report on the work of the Crisis Staff in Kljuc.

7 A. Yes, report -- we see such reports in a few municipalities. We

8 just talked about the Krupa one already. These are generally -- the ones

9 I've seen appear to be at the first meeting of the municipal assembly

10 after the war operations, when the Crisis Staff is now supposed to -- or

11 War Presidency, supposed to cease operations and the municipal assembly

12 take over. There seems to have been, in several cases, a report given on

13 what they had done in the interim, and this appears to be such a one.

14 It's dated the 29th of July, so it covers the period from the 15th of May

15 to the 29th of July.

16 I'll just give the usher all of the pages, I'm sorry.

17 It notes on the first page that the Crisis Staff was established

18 in the SDS on the 23rd of December, as we saw in that minute. That, "In

19 mid-May, it was expanded and transformed into the Crisis Staff of the

20 municipal assembly." Again, to replace the municipal assembly, this is

21 the pattern I've described in my report, noting that, as it moves from the

22 SDS organ to the municipal organ, it does add some new members,

23 representative of its wider role as the municipal authority.

24 It says: "It was the supreme organ of authority with all the

25 prerogatives of the Assembly. It adopted all decisions and conclusions

1 falling within the jurisdiction of the Assembly."

2 It then became the War Presidency on the 31st of May, and it's --

3 okay. Yes, on page 3 in the translation, still on the first page of the

4 report, in the B/C/S, 00349533, just a note on how it worked, that it

5 based its activities on collective work; that sessions were held in the

6 beginning every day and generally twice a week.

7 On the next page of the B/C/S, the first paragraph, an important

8 reference to cooperation with the army; that representatives regularly

9 participated in the sessions; maintained good cooperation and coordination

10 with the Crisis Staff. "All major questions related to the army and

11 police were resolved within the Crisis Staff of the municipal assembly,"

12 and notes "This is a period of very successful cooperation between the

13 Crisis Staff and military organs in crushing armed resistance by Muslim

14 extremists." So an example of the cooperation I talked about.

15 The last paragraph on the same page in the B/C/S, 00349534, page 4

16 in the translation, the report notes: "Certain negative trends which were

17 not compatible with the dignity of the Serbian people; certain

18 paramilitary groups and individuals appeared who engaged in looting,

19 torching, and attacks mostly in settlements, villages, inhabited by

20 Muslims after hostilities had ceased and the terrain had been mopped up,

21 and in breaking and moving into empty apartments."

22 The word for mopping up is "ciscenje terena." I take "ciscenje

23 terena" to be specifically the mopping up of the terrain.

24 The next page in the B/C/S, 00349535, just again describing how it

25 worked; that it discussed and analysed military, security and political

1 situation, and adopted orders, decisions, and conclusions.

2 Page 5 in the translation, same page in the B/C/S, third

3 paragraph, mention of -- dealing with personnel issues in the judiciary,

4 public prosecutor's office, and other -- the administrative organs, public

5 and socially-owned enterprises. "Questions related to the organised

6 moving out of Muslims and the question of the status of Muslim citizens

7 were often dealt with, and conclusions were adopted on these issues at

8 Crisis Staff sessions." So all the various topics that I have discussed

9 in my report. It's nice when they write a report for me and summarise

10 their work.

11 Last paragraph on the translation, first paragraph on 00349536,

12 talks about the role of the Crisis Staff and War Presidency in

13 establishing and equipping the 17th Infantry Brigade. So a summary of

14 their work indicates that the way they -- in which they worked, and the

15 topics they dealt with.

16 Q. Thank you. The next tab, 24 --

17 MR. HANNIS: Yes, Your Honour.

18 JUDGE HANOTEAU: [Interpretation] May I ask a question? Why was

19 such a report drawn up? Was it for archive purposes or was -- why was

20 this report drawn up? Was it meant to be sent to higher-ups in the

21 hierarchy? Do we know anything about this? Because if I understand you

22 correctly, you found these type of reports in other municipal assemblies.

23 THE WITNESS: My understanding of this report is that it would be

24 written for the municipal assembly. When it would first meet, the

25 municipality -- it did not meet during this time period. The Crisis

1 Staff/War Presidency took over all responsibilities and competencies of

2 the municipal assembly. When the municipal assembly could meet again, it

3 would confirm the decisions that had been passed in its name, confirmed or

4 not, although the records I've seen, they confirm generally everything.

5 Sometimes they asked for clarification. And I take this to be such a

6 report presented to the municipal assembly, because we also see a list of

7 all the decisions taken by the Crisis Staff and War Presidency, and the

8 municipal assembly would then consider them all. That's my understanding

9 of this report.

10 JUDGE HANOTEAU: [Interpretation] Thank you, Witness.

11 MR. HANNIS: Next tab, 244, Your Honour, we'll skip. It's some

12 discussion about a shortage of weapons and training.

13 Q. Tab 245, Ms. Hanson, I'd like to show you, master tab 283. This

14 is a document from the military, dated the 4th of May, 1992.

15 A. Yes, from the command of the 3rd Partizan Division to the

16 commander of the 5th Corps, a regular combat report.

17 Q. And does it have some reference to the Kljuc Crisis Staff?

18 A. Yes, it does, and to the themes I had mentioned of some of the

19 military issues. On the first page -- well, actually, I don't believe

20 that's my highlighting.

21 Q. The one you wanted to talk about appears on the second page.

22 A. Yes, second page, 6, state of morale. That's on the second page

23 of the B/C/S, 00954740, at the bottom third of the page 6.

24 Under the question of morale, this report notes that: "Serbian

25 extremism is increasingly present in Kljuc induced by the official organs

1 of authority since the president of the municipality is asking to have his

2 own army which he would use as he sees fit."

3 The president of the municipality was Jovo Banjac, member of the

4 Crisis Staff. I'm sorry, I'm getting confused with the names. We'll see

5 in the other documents the president of the municipality and the president

6 of the Crisis Staff.

7 Q. Veljko Kondic?

8 A. Yes, thank you. A few too many names, Your Honour.

9 Q. Could you tell us his name again?

10 A. Veljko Kondic.

11 Q. All right. Do you see in the documentation anything about that

12 event that was being discussed, or how the JNA reacted to it?

13 A. Of this particular thing, not -- not this event in Kljuc. I'm

14 not ...

15 Q. Okay, thank you. Let me now talk about the police, which was

16 another topic we've discussed before with regard to the Crisis Staffs, and

17 I'll hand you presentation tab 246, master tab 183, from the 7th of May.

18 A. Yes. An announcement of the Kljuc municipal Crisis Staff on the

19 formation of the Serbian public security station in Kljuc. This is, of

20 course, consistent with the 19 December instructions on taking over the

21 police station. This says that the police now wear the Serbian flag and

22 patch on which the word "police" is written in Cyrillic. The Serbian flag

23 is displayed on the municipal building. The Kljuc municipality will be

24 incorporated in the Autonomous Region of Krajina and the Serbian Republic

25 of Bosnia-Herzegovina, and "therefore, the municipality is automatically

1 required to administer laws and decisions adopted by the Assembly of the

2 Serbian Republic of BH and the Assembly of the ARK." It notes, again,

3 further down, that all decisions is -- and work is carried out in

4 accordance with those organs.

5 And on the second page, which is on the second page of the B/C/S,

6 00914750, the underlined section in the centre: "All the citizens are

7 guaranteed all civil rights and freedoms, regardless of their religious or

8 ethnic background, provided that they respect the authorities."

9 So the authority -- the Crisis Staff is setting itself up as the

10 authority and demanding respect and guaranteeing rights in return.

11 Q. Thank you. Let me go next to presentation tab 247, master tab

12 202. This is from a Crisis Staff meeting on the 13th and 14th of May,

13 1992.

14 A. Yes. Here, I take you to agenda item 2, the adoption of positions

15 in connection with the decisions of the Serbian Assembly of BH. As you'll

16 recall, there was a session on the 12th of May of the Serbian Assembly.

17 On the second page, under item 2, we see that Jovo Banjac,

18 president of the Crisis Staff, and Rajko Kalabic, deputy of the Assembly,

19 discuss the security situation "in connection with the decisions and

20 reports of the session of the Serbian Republic of BH Assembly." And the

21 Crisis Staff adopted a report in connection with the decisions of that

22 Assembly. So more indications of the communications from the Assembly to

23 the municipality, and the municipal support for the Assembly decisions.

24 Q. All right. In addition to these minutes of that meeting, did you

25 have some other document referring to what took place in regard to that

1 discussion?

2 A. Yes. As I mentioned, we have a copy of the diary of the secretary

3 of the Crisis Staff, which also has minutes of this meeting.

4 Q. Let me refer you, then, to tab 248 in the presentation, master

5 binder number 13. And in the original, this is a handwritten document, so

6 could you refer us to which portions you're referring to.

7 A. The first reference is the B/C/S 01399464, and it -- agenda for a

8 meeting of the Crisis Staff on the 14th of May. The items, "the

9 separation of the Serbian ethnic community from ..." it is a handwritten

10 document so some parts are illegible. "Creation of our territory and a

11 transversal - the corridor; borders on the Una and Neretva; division of

12 Sarajevo; access to the sea." Those are all consistent with the strategic

13 objectives. Here it is notable that they do not have reference to the

14 Drina, which was one of the strategic objectives. But I would point out

15 that Kljuc is quite far from the Drina.

16 But this indicates that the strategic objectives, as discussed at

17 the 12th of May session, were conveyed to the municipal level. Other

18 items here are also consistent with the 12th of May session that the --

19 the establishment of the VRS, the army under the command of the

20 Presidency, also anthem, borders and taxes, those are all mentioned in the

21 12th of May session.

22 Q. Next --

23 A. Also, from this diary, another meeting of the Crisis Staff.

24 Q. Yes. If you want to refer to that while we have the diary there.

25 A. This is on the B/C/S 01399467 and the following page. A note

1 under -- that's not the right page for you. It's 19 and 20. Page 19 in

2 the translation, on item 2 in the agenda, "political and security

3 situation - Telexes." On the next page, in a moment, we'll see what the

4 telexes might have been about. I'd draw your attention to a list of the

5 make-up of the Crisis Staff. President is Jovo Banjac and Veljko Kondic

6 is the deputy president. Also, a lieutenant colonel, Milojevic is listed,

7 as is the assembly deputy, Rajko Kalabic.

8 On the next page, 01399468 in the translation -- in the B/C/S,

9 indication of communications from higher levels. Veljko Kondic read out

10 the telexes from the Bosnian Krajina, and R. Karadzic. Then they

11 discussed mobilisation, including mobilising all Muslims to report. Then

12 I note that the telexes would be photocopied and copies sent to the

13 police, the TO, president of the assembly, an indication of the orders

14 being passed from -- received from Karadzic and from, apparently, the ARK

15 level and then distributed -- passed further on to the municipality for

16 implementation.

17 Q. Anything else from that before we go on?

18 A. No, that's all from that document.

19 Q. Thank you.

20 MR. HANNIS: Your Honours, I intended to skip the next tabs, 249

21 and, 250, and 251, and go to tab 252, which is master tab 79.

22 Q. This is an excerpt from the book of minutes of the Kljuc municipal

23 assembly Crisis Staff. Ms. Hanson, I think we had particularly taken note

24 of items 1 through 3, 10 through 13, and 18 and 19, on these pages.

25 A. I would just like to point out that, for some reason, the pages of

1 this book of minutes were stamped out of order, so the ERNs of the

2 original will jump around. But if you look at the -- if you read each

3 page carefully, they can be put together in the order that they are.

4 There might be a little confusion because of that, and because, of course,

5 the translation sometimes takes less -- is more -- translation covers many

6 pages just because it's more neatly written.

7 But this is beginning on 00573857. Under item 2, we see -- sorry,

8 item 1, a reference to the Crisis Staff of the ARK, affirming the

9 legitimacy of the ARK Crisis Staff. Two, judicial appointments, again

10 proposing judges and prosecutor. Item 3, replacing all non-Serbian

11 personnel in various posts "where independent decision-making is possible

12 and the protection of properties ..." So dismissal of non-Serbs.

13 Under -- at the next page of the translation, at the bottom of the

14 next page in the B/C/S, 00573858, a nice explication -- the Crisis Staff

15 is explicating the relationship between the military and the civilian.

16 "The military authorities will follow the orders of the civilian

17 authorities. The civilian authorities will not interfere with the way

18 they are followed."

19 Then under item 11, which is on the next page, in the B/C/S,

20 00573859. "Establishment of an agency for the reception/removal of

21 refugees from one region to another." Number 12, "Prohibit the return of

22 families that have departed if those families did so without appropriate

23 reasons." Also mobilisation, a discussion. Number 18, which is on the

24 next page in the B/C/S, 00573860: "The municipal Crisis Staff adopted the

25 decision on the organisation of departure from the area of the

1 municipality. The departure of individuals from the municipality will be

2 organised by the municipal secretariat of national defence."

3 Then the last -- well, I didn't even get it on there. Yes, I'm

4 sorry. Under -- it's a moment where the B/C/S does not follow

5 immediately, but I believe it is 00573874. I'll confirm that in a moment.

6 The Crisis Staff is appointing battalion command personnel, and so on, so

7 more indication of the Crisis Staff appointing military personnel.

8 Q. Okay.

9 JUDGE ORIE: Do we have that page in the --

10 THE WITNESS: Yes, I'm sorry, it's --

11 JUDGE ORIE: -- B/C/S?

12 THE WITNESS: Yes. It's the next tab, actually, because it is --

13 it's 00573882. It's where -- the interruption jumps from 60 to 82.

14 Because that page also contains the 28th of May announcement, it's

15 entered, I guess, as a separate --

16 JUDGE ORIE: My question was -- oh, yes, the previous one was 81,

17 last two digits of the ERN number, and that --

18 THE WITNESS: No.

19 JUDGE ORIE: The previous one we saw?

20 THE WITNESS: Of the B/C/S?

21 JUDGE ORIE: Yes.

22 THE WITNESS: 00573860.

23 JUDGE ORIE: And the second one?

24 THE WITNESS: 00573882.

25 JUDGE ORIE: Yes. Please proceed.

1 THE WITNESS: That's all for this session, as I say. That page

2 also includes the next session, but that's another tab.

3 MR. HANNIS:

4 Q. I wanted to skip a couple of tabs, 253 and 254, and take you to

5 tab 255 in the presentation, which is master tab 82. And this refers to

6 the meeting of the 29th of May.

7 A. This is in the B/C/S 00573883 and 3884. First sentence, just to

8 note that the Crisis Staff is in continuous session. That same paragraph,

9 at the end: "The transport of the Muslim members of Territorial Defence

10 to Stari Gradiska has been secured."

11 And under item 3, which is on the second page of the B/C/S,

12 discussing the mopping up of two areas of town - in the original it's

13 simply "ciscenje" - to be carried out by the police. So the Crisis Staff

14 ordering the police to carry out the ciscenje.

15 Q. Next, presentation tab 256, master tab 83, and I believe it begins

16 on the bottom of that first page. It's a meeting from the 30th of May,

17 1992. I'll get to you comment on some items on the second page in the

18 English.

19 A. This begins in the B/C/S 00573885. I'd note that the unit

20 commander was at the session of the Crisis Staff, and his decision to

21 block the villages of Ramici, Plamenice, Vukova Sela, Krasulje and Kaliska

22 was accepted, with the obligation of calling for the unconditional

23 surrender and surrender of arms. And then, if no resistance is given, the

24 mopping up of the area can be carried out. It is "ciscenje terene."

25 Item 2, which goes onto the next page of the B/C/S, 00573886, that

1 the police carry out the mopping up - again, "ciscenje terene" is mopping

2 up - and according to the plans as set, and to carry out the return of

3 weapons. So there's a plan for the ciscenje terene, mopping up of some

4 towns -- areas of the -- towns, yes.

5 MR. HANNIS: Your Honours, let me skip the next tab, presentation

6 tab 257, and go to presentation 258, master tab 85, for a meeting on the

7 2nd of June.

8 A. This is, in the B/C/S, 00573890. Notable here under item 1, that

9 the brigade commander reports to the Crisis Staff. And then under (b),

10 the chief of police reports to the Crisis Staff on the operations of the

11 police in mopping up the area, on processing those arrested, and on the

12 security of the town. It is "ciscenje terene," mopping of the area.

13 Q. Thank you. Next, presentation tab 259, master tab 86. This is a

14 meeting on the following day, the 3rd of June, and in particular, items

15 number 4 and 7.

16 A. This is, in the B/C/S, 00573891, and on to the next page. Item 4,

17 "the question of the removal of the population." And item 7, the problem

18 or the "issue of prisoners."

19 I would point out that the discussion of those agenda items is

20 missing from the pages of the book. We did not seem to receive them.

21 Some pages are out of order, but the pages that correspond to those agenda

22 items are not there.

23 Q. Yes. To the first four items --

24 A. The first four items, yes.

25 Q. Was there a discussion of item number 7 regarding prisoners?

1 A. Yes. And that is the next page, as stamped 00573892. On the

2 issue of prisoners, the chief of police indicated to the Crisis Staff the

3 problem of prisoners, the greatest problem being their accommodation.

4 Q. Thank you.

5 JUDGE ORIE: I have some difficulties in following this. You said

6 the discussion on item number 2 regarding prisoners was at ERN number,

7 last two digits, 92. I couldn't find them that quickly, because under tab

8 258, it stops at 891. Should I look at the next one? But then I have

9 difficulty --

10 THE WITNESS: Well, 3891 appears twice. One, for the first half

11 of the page, referring to the previous session, that's the previous tab --

12 JUDGE ORIE: Yes.

13 THE WITNESS: -- but the tab, the document we're looking at now,

14 it's the same page, 3891, in reference to the session of the 3rd of June.

15 JUDGE ORIE: Yes, that's, in the translation, page number 10 at

16 the bottom.

17 THE WITNESS: Yes.

18 JUDGE ORIE: And where, now, do we see the -- agenda item 7

19 discussed?

20 THE WITNESS: Yes. At 00573892.

21 JUDGE ORIE: I'm -- I take it that there is a numbered translation

22 as well. Would that be on page --

23 THE WITNESS: Page 11 of the translation.

24 JUDGE ORIE: And under what tab do I find that?

25 MR. HANNIS: I think the B/C/S for that page 92 was actually

1 behind tab 259.

2 JUDGE ORIE: Okay. So we move to the next tab.

3 THE WITNESS: I've been in 259.

4 JUDGE ORIE: Yes, I've found it. Perhaps I failed to follow you.

5 THE WITNESS: I had difficulty myself putting the translation

6 together with each session. It's very difficult.

7 JUDGE ORIE: You said "I couldn't find them that quickly because,

8 under tab 258 --" Then you said, "Should I look at the next one," but

9 then you had a difficulty -- no, that was me, myself. Well, I'm there,

10 that's the most important.

11 MR. HANNIS: Thank you. And to everyone's relief, I hope, we'll

12 skip tabs 260 through 263, because mostly those are just to reflect

13 reports from the police, the army, and the TO, and go to tab 264 in the

14 presentation, which is master tab 91.

15 Q. If you could talk about a meeting on June the 6th and June the

16 9th.

17 A. Yes. The B/C/S is 00573870. The top of the page, which is from

18 the 6th of June session, on page 14 in the translation, the third item:

19 "The status and employment of Muslim citizens should be resolved on the

20 regional level across the board." Then skipping the next item. "The

21 matter of the organised removal of the Muslim population should be

22 resolved." And lastly, skipping another sentence, the last sentence:

23 "Nothing should be done to the Muslim population in areas where it is not

24 necessary." And still on the same page in both the translation and the

25 B/C/S, the 9th of June session, noting a report on the condition of

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1 prisoners as number -- as item number 1.

2 Q. Okay, thank you. Anything else from that one?

3 A. Yes. On page 15 on to 16 in the translation, and I'm just

4 checking the B/C/S, 00573871 on the B/C/S, about three-quarters of the way

5 down, "the question of the employment of Muslims" seems to be referring to

6 the earlier decision on managerial posts and important posts concerning

7 property and information.

8 Agenda item 4, in the B/C/S 00573872, discussing the status and

9 the inclusion of Muslims and Croats in the health authorities, and the

10 need to take a specific stand on this issue.

11 Q. Okay.

12 JUDGE ORIE: May I ask one question?

13 THE WITNESS: Mm-hm.

14 JUDGE ORIE: This Chamber has understood the case of the

15 Prosecution to be that many of the actions undertaken were actions to make

16 certain municipalities and areas purely Serb. You just highlighted a line

17 which says, "nothing should be done to the Muslim population in areas

18 where it is not necessary." Does that mean that these were areas which

19 were not aimed at becoming purely Serb in this municipality, or is this

20 contradicting, to that extent, the Prosecution's case that the aim in many

21 areas was to make it purely Serb? I tried to understand how, in this

22 decision -- it seems to say, if you don't need it, let the Muslim

23 population, let them -- well, if not be in peace, at least be.

24 THE WITNESS: There are several factors which might --

25 JUDGE ORIE: If you say it's beyond your expertise, then please

1 tell us.

2 THE WITNESS: Well, I can't know exactly what they mean here in

3 Kljuc and what areas they refer to. But it is notable in -- from these

4 minutes that there are discussions of disarming of Muslims and some

5 resistance to disarming. We don't know where -- what areas they say it

6 isn't necessary. But that might be one of the criteria, because that is a

7 common theme. Another would be -- I'm thinking of, here, also the

8 document we looked at not long ago where the representatives of several

9 municipalities, including Kljuc, said that Muslim population or non-Serb

10 population should be moved out to a level at which Serbian authority can

11 be maintained. And some areas might be more Muslim-settled and less Serb,

12 but there -- in all these municipalities, no settlement was ever entirely,

13 or practically no settlement was entirely Serb or entirely one nation --

14 one ethnic group.

15 JUDGE ORIE: Yes. You've heard the question.

16 MR. HANNIS: Yes.

17 JUDGE ORIE: And I take it that -- well, being aware that it leads

18 to -- it was a question that arose, that to the extent you intend to

19 present any further evidence on that, we'll hear that, if it comes to

20 that.

21 MR. HANNIS: Yes, Your Honour. And I know this is not time to

22 make argument; we'll address that much later.

23 JUDGE ORIE: No.

24 MR. HANNIS:

25 Q. Let me move on, then, to tab 266, which is master tab 29 -- is

1 master tab 93. This is a meeting of the 16th of June, and I'd like you to

2 mention or discuss items 1, 3, and 7 in that meeting.

3 A. Yes. This is, on the B/C/S, 00573873, and the next page. Agenda

4 item 1, appointing the brigade commander, saying it should be resolved by,

5 pardon me, the 18th of June, noting this is still into June -- yes, sorry.

6 I apologise, I seem to be in the wrong tab. I gave the wrong B/C/S, my

7 apologies. Or did I? This is, by far, the worst set of documents for the

8 case studies. It will get easier. I don't want to see that; it doesn't

9 help.

10 Q. I know the date of the meeting is on the preceding English page,

11 but the substance is on that first page you have.

12 A. I see, I see. Yes. I don't seem to have the B/C/S pages in front

13 of me, so I can't give the ERN.

14 Q. Items 3 and 7, at any rate, are on 00573861.

15 A. Thank you.

16 Q. I don't know if item 1 would be on the immediately preceding page.

17 A. Yes, 74. This is where the confusion arises. Yes, item 1 is on

18 00573874, on appointing the brigade commander, and item 3 is --

19 Q. Item 3 and 7 appear to be on 00573861.

20 A. Yes, thank you. It is a confusion. "The Crisis Staff shall

21 remain the highest authority and will cooperate fully with the military

22 command and the Kljuc SJB."

23 Item 7 on the same page, that "a work group should review the

24 situation regarding managerial posts held by Muslims, and to propose new

25 personnel solutions."

1 Q. Thank you. Now we'll skip some tabs 267 through 271, and go to

2 presentation tab 272, master tab 99. Those tabs we skipped are footnotes

3 in your report.

4 JUDGE ORIE: Just drawing the attention to the fact that it might

5 be a bit confusing now for Mr. Krajisnik, because the issue under agenda

6 item 1 about the appointment of the brigade commander does not appear in

7 the original under the same tab number, 266, but does appear under -- the

8 original, under tab 265.

9 MR. HANNIS: The preceding tab, that's right, Your Honour.

10 JUDGE ORIE: Yes. Whereas it does not appear in the translation

11 under tab 265, as far as I can see.

12 MR. HANNIS: No, it's not. It's --

13 JUDGE ORIE: So it's a bit confusing, and I'd like you to

14 specifically tell us not only what ERN number the original can be found,

15 but also so under what tab number, so that Mr. Krajisnik is able to find

16 it. But, of course, the Chamber prefers to have the translation under the

17 same tab number as the original is.

18 MR. HANNIS: We do too, Your Honour. This is the last one in

19 connection with that last handwritten document, and hopefully it will go

20 smoother after this one.

21 THE WITNESS: It will.

22 MR. HANNIS:

23 Q. In this one, Ms. Hanson, I wanted you to refer to the meeting of

24 the 26th -- the 10th of July.

25 A. The 10th of July, that's 00573879, noting the adoption of the

1 decision on the establishment of a War Presidency. So we see the Crisis

2 Staff becoming a War Presidency in July.

3 Q. And on that same page, I believe in both the B/C/S and English --

4 JUDGE ORIE: Which tab are we at this moment?

5 MR. HANNIS: This is tab 272, Your Honour.

6 JUDGE ORIE: 272.

7 MR. HANNIS: Yes. We skipped several.

8 JUDGE ORIE: We skipped, yes.

9 MR. HANNIS: 267 through 271.

10 JUDGE ORIE: 10th of July, I've got that. Yes, and I see that all

11 is in the original under the same tab, at least the 10th of July. Please

12 proceed.

13 MR. HANNIS:

14 Q. And right above that, on the English page, and I believe also in

15 the B/C/S, in discussing matters in the previous meeting --

16 A. Yes, the previous meeting. "The question of the status of Muslim

17 citizens and further work employment." The municipal Crisis Staff refers

18 this decision to what they term the Banja Luka regional Crisis Staff, a

19 reference, I take it, to ARK, the ARK Crisis Staff.

20 Q. Thank you. Let's finish with that one, then, and I'll take you to

21 presentation tab 273, master tab 152. And can you tell us what this is?

22 A. Yes. This is, in B/C/S, 00575222, a review of decisions,

23 conclusions, rulings, and orders issued by the Crisis Staff and War

24 Presidency -- War Presidency. In the translation it says "the Crisis

25 Staff of the War Presidency," but if we just put the B/C/S on the screen,

1 you can see it's just a hyphen, if that's helpful.

2 Q. Okay. And I see you highlighted some particular items on that

3 list. Can you tell us about those, please?

4 A. I pointed out the hyphen just to show that it's seen as a --

5 essentially the same body. Yes, there's some interesting decisions here.

6 I take this document to be connected to the report that we saw. In other

7 municipalities, we have seen this kind of list submitted to the municipal

8 assembly for their review and confirmation. There's no indication on this

9 document that that was its purpose, but it's consistent with that.

10 If we look at decisions 12, 13, 14, 16, and 17, they are decisions

11 on judicial dismissals and appointments; 18, establishing a War

12 Presidency; 21, financing the army, paying a sum to the army; 23, a

13 committee for the receipt of war and other booty; 26, which is on the next

14 page, in the B/C/S, 00575223, a decision on members of the War Presidency

15 to -- allowing them to carry weapons and wear uniforms, which I think is

16 indicative of their -- the military role in which they -- that they gave

17 themselves, or they saw themselves as having. On the next page in the

18 translation, 29, reinforcing the infantry brigade. Then the last -- from

19 31 onward, decisions on municipal appointments and dismissals, or in this

20 case just dismissals; decision on positions that can only be filled by

21 workers of Serbian nationality; and the last item, "committee for the

22 collection of data relating to the population exodus from the territory of

23 Kljuc municipality."

24 Q. Thank you.

25 MR. HANNIS: Your Honours, I'm going to skip several tabs, 274 and

1 275, relating to freedom of movement, and they are footnoted documents to

2 the report. 276 to 280 regard dismissal from municipal employment.

3 Q. And I would like to go to 281, which is master tab 131. This is

4 from -- a decision from the 10th of July, I believe, or the 13th. I'm not

5 sure.

6 A. Well, the session was held on the 10th, and the date on the

7 published decision is the 13th. This is the B/C/S 00575284. Notable in

8 the preamble, that they take this decision to form the War Presidency, on

9 the basis of Article 2 of the decision on the formation of War

10 Presidencies in municipalities during imminent threat of war or state of

11 war. I take that to be a reference to the Presidency decision of 31 May.

12 As we saw, according to the 10th of June decision, that 31 May

13 decision was superseded by the later decision. But you can see that on

14 the ground, the municipalities -- this municipality, at least, still took

15 its decision to form a War Presidency on the basis of that Presidency

16 decision. Clearly, the War Presidency is replacing the Crisis Staff; it

17 says it's formed instead of the Crisis Staff. The makeup is almost

18 identical to the Crisis Staff, as listed in the 18 May entry of Bajic's

19 diary. Certainly, the essential members, the same Jovo Banjac, president;

20 Veljko Kondic, deputy president. Item 7, Rajko Kalabic, the Assembly

21 deputy is a member; 8 and 9, the head of the police station and the

22 secretary of the SDS; and lastly, number 12, the commander of the brigade.

23 Q. Thank you. Let me show you next presentation tab 28 --

24 MR. HANNIS: Your Honour, I'm going to skip 282, which is the

25 decision she mentioned before regarding War Presidency members carrying

1 weapons and uniforms -- and wearing uniforms.

2 Q. Tab 283 in the presentation is master tab 313, from the 21st of

3 July. Can you tell us about that one?

4 A. The B/C/S, 00914877, a decision that only Serbs can hold positions

5 -- managerial positions or positions where the inflow of information is

6 important, and all places of importance for protecting socially-owned

7 property and the functioning of economic entities. Then they specify,

8 sort of, "all socially-owned enterprises, shareholding companies, state

9 institutions, public enterprises, and the police station."

10 Item 3, similarly, Serbs who are not loyal to the Serb Republic --

11 Serbian Republic, cannot fill those positions either.

12 Q. Thank you.

13 MR. HANNIS: Your Honour, might this be a good time for the next

14 break?

15 JUDGE ORIE: Yes, it is. We will adjourn for 20 minutes. We will

16 resume at 10 minutes to 1.00.

17 --- Recess taken at 12.30 p.m.

18 --- On resuming at 12.58 p.m.

19 MR. STEWART: Your Honour, Mr. Krajisnik has some query, which I'm

20 not able to understand, just about a specific -- apparently about a

21 specific piece of material. I'm not quite sure who the query is addressed

22 to. I wonder, with Your Honours' indulgence, if he can just put it and

23 then we'll know who the query is addressed to.

24 JUDGE ORIE: Yes.

25 MR. STEWART: That's very kind. Thank you, Your Honour.

1 JUDGE ORIE: Especially in the absence of Ms. Cmeric, I'll be a

2 bit more flexible. Please ask what you're going to ask. Would it be a

3 question for the witness or for us or ...

4 THE ACCUSED: [Interpretation] No. I just asked this lady to find

5 me a file. It's an electronic piece of evidence. I gave her a number but

6 I'm afraid we didn't understand each other well, me not speaking English.

7 I have the number.

8 [Trial Chamber and registrar confer]

9 JUDGE ORIE: Sometimes, Mr. Krajisnik, communication is not that

10 easy. I think Ms. Philpott understood that you were looking for that

11 document, and she passed the request to the OTP case manager, and as soon

12 as it has been found and printed, you will receive the copy.

13 MR. STEWART: Thank you, Your Honour. I did understand it was a

14 practical matter, and I'm grateful for that.

15 JUDGE ORIE: There is another matter before I allow you to resume

16 your examination-in-chief, Mr. Hannis.

17 I indicated before that the Chamber would try to give a decision,

18 an oral decision, in a couple of days on the motion for adjournment.

19 Since the Chamber could not decide the matter before, I would say, the

20 e-mail exchange of the parties was finished, before we knew about the

21 result of that, meanwhile, the Chamber worked hard on a draft decision in

22 writing, because the matter was important enough to have it in writing. I

23 can inform the parties that our decision will be filed this afternoon, in

24 writing. It's now undergoing the final checks on formalities, but the

25 decision is there, and in the decision, the motion is denied. But that's

1 what's going to be filed this afternoon so that the parties are aware of

2 it.

3 Then, Mr. Hannis, please proceed.

4 MR. HANNIS: Thank you, Your Honour. I think we left off with tab

5 283. I intend to skip tabs 284 through 288. They all pertain to

6 dismissals of Muslims from employment, I believe, in the municipality, and

7 they're referred to in the report. I would note that 287 refers to Asim

8 Egeric and 288 refers to Omer Filipovic, who were gentlemen we heard about

9 during testimony about Kljuc municipality earlier in the case, and Mr.

10 Filipovic who died in Manjaca.

11 Q. Tab 289 is the next one I'd like to go to, Ms. Hanson, it's master

12 tab 349. It's a decision of the War Presidency, dated the 30th of July, I

13 believe.

14 A. Yes. The decision of the War Presidency on the criteria required

15 in order to move out of Kljuc municipality. We saw one earlier from

16 Sanski Most. And just to show it has similar criteria, under article 1,

17 that "families and persons who issue a statement ... declaring that they

18 are moving permanently from the territory shall be permitted to leave,"

19 again, the exchange of real estate or placing properties, at the disposal

20 of the municipalities permitted, under Article 2, but the sale of property

21 is not allowed.

22 Q. Thank you. In relation to that, can I show you tab 290 in the

23 presentation, master tab 351.

24 A. This is a record dated the 31st of July, a statement by Camil

25 Kuburas, that he is leaving Kljuc permanently and voluntarily. At the

1 bottom of the translation, and on to the second page of the translation,

2 he says that he "has been informed of the order of the War Presidency of

3 Kljuc on the criteria for the possibility of permanent departure of 30

4 July," and he states that he is leaving Kljuc voluntarily and permanently.

5 And he registers the house that he has in Kljuc.

6 Q. Thank you. That concludes our case study on Kljuc. Now, if we

7 could turn to Trnovo --

8 JUDGE ORIE: Could I ask one question?

9 MR. HANNIS: Yes.

10 JUDGE ORIE: I did see under tab 289 that the conditions for

11 leaving included the possibility to take all movable property, although

12 they needed to have an inventory of those -- of that movable property. It

13 doesn't say anything about 300 Deutschemarks. But I had to check first

14 whether this was before or after, but I couldn't find it that quickly.

15 THE WITNESS: The 300 Deutschemarks that I noted before was from

16 Kotor Varos, and at the moment I don't recall that we had seen that amount

17 specified in Kljuc. If we --

18 MR. HANNIS: Your Honour, I'm looking for that tab number.

19 JUDGE ORIE: Yes. I just wanted to consult it, but I've not found

20 it.

21 THE WITNESS: But it would be -- this document would be after

22 anything we saw from Kljuc, because it's dated the 31st of July.

23 MR. HANNIS: It's tab 230, Your Honour, and it was from Kotor

24 Varos.

25 JUDGE ORIE: Yes. Please proceed. Please proceed. I'll find it

1 again.

2 MR. HANNIS: All right, thank you.

3 Q. Then, turning to Trnovo, I'd like to hand you presentation tab

4 291, which is master tab number 10. This is from a meeting on the 25th of

5 December, 1991.

6 A. Minutes of the meeting of the Trnovo SDS municipal board on the

7 25th of December. We have seen this document at the beginning of the

8 presentation on the receipt and implementation of the 19 December

9 instructions, and just now looking at Trnovo as a whole to see -- they did

10 receive these instructions by the 25th of December. It appears because

11 agenda item 1 is directives referring to organising Serbian people in

12 crisis situations, and the meeting sets up a duty roster, sets up a Crisis

13 Staff. And here we know Glisa Simanic is suggested as a coordinator.

14 He's a character we will see in these minutes, and you'll recall the

15 intercepted conversation between Glisa Simanic and General Ratko Mladic.

16 Q. Thank you. And following on that, two days later, presentation

17 tab 292, master tab number 44, another meeting in Trnovo.

18 A. Minutes of the meeting of the Trnovo SDS municipal board on the

19 27th of December. In the B/C/S, 02280490, the lower half of the page. It

20 notes that: "On the basis of the instructions for organisation of the

21 Serbian people," they name the members of the secretariat as members of

22 the Crisis Staff, along with officials in the municipal assembly, saying

23 that the Assembly will appoint a Crisis Staff and Radivoje Draskovic, who

24 was president of the SDS Trnovo, is nominated for the post of president,

25 and Glisa Simanic was appointed coordinator for crisis situations. This

1 is the document we pointed out last time. The translation reads, although

2 it's Simanic.

3 Q. I would like to 293, which is master tab 451. This is to indicate

4 that their actions are being taken based on the variant A and variant B

5 instructions.

6 A. Yes. This is a decision of the Crisis Staff of the 5th of July,

7 1992. I would just like to explain something on this document, that --

8 the heading says "Serbian Municipality of Ilidza Crisis Staff," but the

9 preamble shows it as the Crisis Staff of Trnovo. At this point, Trnovo

10 seems to have -- the Serbian part of Trnovo has attached itself, become

11 part -- fallen under the Serbian municipality of Ilidza, but it is still,

12 as you see -- the commander of the Trnovo Crisis Staff is Radivoje

13 Draskovic, signing this decision.

14 What's interesting here is that it's a minor decision forming a

15 commission for haying of fields, although you'll note under Article 2,

16 it's the haying of Muslim fields and other available hayfields.

17 More interesting here is the preamble that this Crisis Staff

18 decision is taken on the basis of the instructions on the organisation and

19 work of the organs of the Serbian people in BH in extraordinary

20 circumstances, that is, the 19 December instructions. So the Crisis

21 Staff, in July 1992, is still citing the 19 December instructions as the

22 basis for its actions.

23 Q. Thank you. Next, I'd like to show you presentation tab 295,

24 master tab 448.

25 MR. HANNIS: I've skipped 294, Your Honours. It's in her report.

1 A. This is the minutes of a meeting of the Trnovo SDS municipal

2 board, held on 12 February 1992. On the first page of both the

3 translation and the B/C/S, 02280494, one member complains that the weapons

4 of the Serbian people had been distributed in an unsystematic way, that

5 they had been distributed to people who were not members of the SDS, and

6 that individuals had sold weapons to the Muslims. The fact that even

7 people beyond the SDS were getting weapons is an interesting complaint, to

8 me.

9 On the question of weapons, on the bottom of the page, same page

10 in the translation, and the top of the next page in the B/C/S, 02280495,

11 Draskovic says that "a task force has been formed to provide strictly

12 confidential information about the distribution of weapons of which the

13 members of the SDS municipal board will be informed."

14 Q. Thank you.

15 MR. HANNIS: Your Honours, that's the last item in binder number

16 6. We'd like to hand around the last binder, number 7.

17 Q. And, Ms. Hanson, I'd like to hand you -- do you have binder 7?

18 A. Yes, I do.

19 Q. I'd like to begin -- I'd like to begin with presentation tab 296,

20 master tab number 226.

21 A. Minutes of a meeting of the Trnovo municipal board, on the 7th of

22 March, noting, in the centre of the page of both the original and the

23 B/C/S, that: "It has been decided to form armed units as follows: A

24 section, platoon, detachment, company, which will be ready for defence at

25 all times."

1 Q. Thank you. And next is presentation tab 297, which is master tab

2 459.

3 A. Yes. This is two days later, a meeting of the Crisis Staff. This

4 is the first -- earliest session of the Crisis Staff for which we have

5 minutes, connected, perhaps, to the fact that two days earlier the SDS

6 said it was decided to form armed units. The first meeting of the Crisis

7 Staff discusses what has been done regarding the organisation of the

8 command personnel. At the bottom of the page - this is all on the first

9 page of the translation and also the first page of the B/C/S - that the

10 Crisis Staff is permanently in session.

11 Q. 298 in the presentation is master tab number 450.

12 A. Another meeting of the Crisis Staff on the 20th of March -- March

13 1992. In the centre of the page, "the transformation of the municipality

14 and the local communes is to be carried out." "A decision must be carried

15 out."

16 And then number 2, "activities concerning the defence and the

17 formation of units. Battalion staff according to military principles ..."

18 And then we note again Simanic briefing the Crisis Staff on the formation

19 of units there. He notes that units have been formed in certain

20 settlements.

21 Q. Presentation 299, master tab 441, from the 24th of March, 1992.

22 A. This is a meeting of the SDS municipal board on the 24th of March,

23 noting, in the lower part of the first page of the translation, and, in

24 the B/C/S, at the top of page 02280273, Radivoje Draskovic tells the

25 municipal board that "R. Karadzic ordered the second degree of alert,

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1 organisation of duty shifts, guards, keep control of Serbian territory,

2 take the present situation seriously." Those who received weapons "should

3 use them for the defence of the Serbian people."

4 I would note that on this day, the 24th of March, in the Assembly,

5 we had Karadzic's speech saying that soon there will be the single method

6 applied for taking over, and that they will -- he expects them to receive

7 instructions later from the -- at the Deputy's Club. So secondary degree

8 of alert is, of course, consistent with the 19 December instructions.

9 Also, on this page, "Glisa Simanic informed those present on the

10 organisation of the Serbian command personnel." And on the second page of

11 the translation, and 02280274 in the B/C/S, some conclusions of the

12 municipal board that "Muslims should not till Serbian land, land should

13 not be sold, and taxes from farming should go into a specific account of

14 the SDS." So the SDS is diverting tax revenue into their own account.

15 Q. Thank you. Next, on the issue of coordination --

16 MR. STEWART: Excuse me, Your Honour, I wonder in this case -

17 because sometimes it's possible - where we've got illegibility in the

18 translation at the bottom of the first page, it could be that Ms. Hanson

19 is able to help us with something which has been illegible so far.

20 THE WITNESS: It's very difficult handwriting. I can take a look

21 at that page -- at that line, if that is helpful.

22 MR. HANNIS:

23 Q. Can you tell us which B/C/S we're looking at?

24 A. 02280273, fifth line up.

25 JUDGE ORIE: Could we ask you, Ms. Hanson, if you would be

1 provided with a copy of this page, that you look at it over the weekend,

2 and if you decipher it, that you, at the beginning of cross-examination,

3 could report it to Mr. Stewart.

4 MR. HANNIS: Thank you, Your Honour.

5 MR. STEWART: Thank you, Your Honour.

6 MR. HANNIS:

7 Q. All right. May we then go to presentation tab 300, master tab

8 212. And on the issue of coordination between Crisis Staffs, the JNA and

9 the government, can you talk to us about this 29 April 1992 meeting.

10 A. Yes. This is a meeting of the Crisis Staff on the 29th of April,

11 indicating -- in which Radivoje Draskovic reports on an agreement reached

12 with representatives of the JNA. On the B/C/S, this is 02276137,

13 Draskovic's speech in the centre of the page, bottom of the -- page 1 of

14 the translation, Draskovic says: "We have agreed with the JNA

15 representatives and they will get involved in the cleaning up of the

16 municipality, ciscenje. We have to get crews for APCs and tanks. This is

17 good for psychological effect. Work on psychological and propaganda

18 activities. We went to the government and the Serbian Ministry of

19 Interior. They gave us about 30 insignia for the police, and they agreed

20 to send a request for money, communications, equipment for the police."

21 On the top of the second page of the translation, which is on page

22 02276138 in the B/C/S, he says: "In discussion with the Prime Minister,

23 we have agreed to take whatever we can in a polite way." So contacts with

24 the government, arranging for getting support, and contacts with the JNA,

25 getting crews for APCs and tanks.

1 Q. Thank you. Next, I'd like to show you presentation tab 301,

2 master tab 462, dealing with the issue of support from the Republika

3 Srpska government. This is a document dated the 30th of April, I believe.

4 A. Yes, the 30th of April, a letter to the prime minister. A

5 mistranslation, again, of -- translation, Djeric. It should be Djeric,

6 not Ceric. But it notes: "In accordance with the agreement made in Pale

7 on the 28th of April, please provide us resources," and the resources

8 include 3 million dinars. So confirmation of what was in the minutes, an

9 indication of an agreement with the government and support from the

10 government.

11 Q. Do you have any information about what the agreement reached in

12 Pale on the 28th of April refers to?

13 A. The previous document, the minutes of the meeting, refer to going

14 to Pale and talking about getting resources, and doing it in the nicest

15 possible way. And this is a letter requesting it. I would take that to

16 be related.

17 MR. HANNIS: Next, tab 302, Your Honour, we'll skip it. It's just

18 establishing the use of a building for the Serbian police force in Trnovo.

19 Q. Tab 303, which is master tab number 447.

20 A. Minutes of a meeting of the Crisis Staff on the 30th of April. On

21 page, in the B/C/S, 02276142, the municipal board and Crisis Staff are

22 handing their premises over to the Serbian police station, so an

23 indication of the role of the municipal board and Crisis Staff in

24 informing the Serbian police.

25 Further down in the middle of the B/C/S page, at the bottom of

1 page 1 in the translation, one Crisis Staff member indicates preparations

2 for artillery activity, saying "today we will get Pero to observe the

3 terrain so that the locations are decided. From here, you cannot shell

4 Spile, but you can shell all the other villages."

5 Q. Let me next show you presentation tab 304, master tab 446, from

6 the 2nd of May.

7 A. Minutes of the Crisis Staff of the 2nd of May. Another reference

8 to military preparations. On the first page of the B/C/S, Glisa, Glisa

9 Simanic, as we know, is present, and Glisa says: "Two combat vehicles and

10 two tanks should be brought up." So the Crisis Staff is arranging for

11 getting tanks and combat vehicles.

12 Q. Presentation tab 305, master tab 105, from the 2nd of May, 1992.

13 A. This is an order of the Crisis Staff relating to freedom of

14 movement, forbidding Serbs of -- male Serbs of military age to leave the

15 territory. Interestingly enough, under point 3, the Crisis Staff says

16 that the SDS will issue permissions -- special permissions for leaving

17 temporarily, an indication, I think, of the overlap of the municipal and

18 party authorities, as well as the Crisis Staff interest in controlling

19 freedom of movement.

20 Q. Can I see on the Sanction, on the screen, that you also have the

21 seal highlighted in yellow. Did you want to comment on that?

22 A. Yes. Similarly, the Crisis Staff, which calls itself the Crisis

23 Staff of the Serbian municipality of Trnovo, uses the seal of the SDS

24 municipal board, further indication of the overlap -- of the Crisis

25 Staff's dual role as both a party organ and a government organ.

1 Q. Next, presentation tab 306, master tab 445.

2 A. Minutes of the Crisis Staff meeting of the 3rd of May. On the

3 first page of the translation and B/C/S, first speech by Radivoje, saying

4 that there's a lack of artillery crews, "they should get hold of crews for

5 cannons and mortar operators and send them to Kalinovik for target

6 practice." I would note that there was a JNA army base at Kalinovik.

7 Further down, in the middle of the English translation page 1, on

8 the B/C/S, the next page, 02276151, about a quarter of the way down the

9 page, Radivoje says again: "From tomorrow, one bus should go to Kalinovik

10 for target practice with artillery and infantry weapons," and then he

11 notes that they are moving into the building of the Ilidza Assembly and

12 starting the activities for the running of administrative --

13 administration organs. You know that they actually moved to Ilidza to

14 conduct their business, but claim to be the municipal authorities of

15 Trnovo.

16 On that -- it's a long meeting, with many interesting comments

17 made. Apparently, some personnel conflicts between individuals on the

18 Crisis Staff. But more important comments by Radivoje, at the bottom of

19 page 2 in the translation, and on page 02276153 in the B/C/S, about

20 two-thirds of the way down, Radivoje says: "We are now trying to

21 establish our authority in the municipality. We shall also appeal to the

22 Muslims, not only Serbs. The army is the product of SDS policy." On to

23 the next page of the translation: "Our goals are well known." And then a

24 comment by another member at the bottom of the page in B/C/S, and on to

25 the next page: "We have achieved now what we dreamt of a year ago.

1 Everything that was done, it was done with one objective in mind."

2 MR. STEWART: Your Honour, could we know, if the witness can help

3 on this, whether the underlining in the B/C/S was in the original or -- I

4 don't know. I suppose question number 1 is whether Ms. Hanson has seen

5 the original, whether it's in the copy, or just something about the

6 underlining.

7 THE WITNESS: I have not handled the originals of this ERN, so I

8 can't say. But the way it is produced here, it is there -- it appears to

9 be there in this original handwritten version. This ERN is, I believe,

10 the actual originals. But I can confirm that by going to the vault, sir.

11 JUDGE ORIE: Yes. Well, if you have no more information at this

12 moment, we'll have to look at that. I don't know how important the

13 underlined points are, or what it specifically would mean, but let's see.

14 Please proceed, Mr. Hannis.

15 MR. HANNIS:

16 Q. Next is tab 307 in the presentation, master tab 444, from the 7th

17 of May meeting.

18 A. The Crisis --

19 JUDGE HANOTEAU: [Interpretation] Excuse me, I have a question. I

20 would like to ask the witness how to understand what that sentence on page

21 2, which is "we shall appeal." I didn't really understand what you said

22 exactly, and I didn't follow. "We shall appeal to the Muslims." At the

23 bottom of page 2, "we are now trying to establish an authority in the

24 municipality. We shall also appeal to the Muslims, not only to the

25 Serbs."

1 THE WITNESS: Yes, "appeal" in the sense of win over. "We are

2 going to call ourselves the municipal authority, and we shall try to win

3 the Muslims over, not just the Serbs." Is that a clear enough ...

4 JUDGE HANOTEAU: [Interpretation] Thank you, witness.

5 MR. HANNIS:

6 Q. Now, do you have 307 in front of you?

7 A. Yes, 307, the bottom of the page in the translation, at the top of

8 page 02276157, an interesting indication of links to the republican level,

9 where Radivoje, as president of the Crisis Staff, says that "Djeric has

10 promised to send instructions for the organisation of the administrative

11 organs," et cetera. I would note that this is about ten days after

12 Djeric's instructions on the operations of Crisis Staffs were issued. So

13 whether it's reference to that or other instructions of which I do not

14 know, it is nonetheless indicative of look into the republican level for

15 instructions as they've set up their municipalities.

16 Q. Next, may I show you presentation tab 308, master tab 229, from

17 the 9th of May, 1992.

18 A. Here, notable are the military preparations and the relations with

19 the TO, because by now, the Crisis Staff has set up a TO command in

20 Trnovo. And we see from the minutes, some - what Subotic called minor

21 disagreements - some disagreements on actions to be taken, and Radivoje,

22 as president of the Crisis Staff, sets out at the beginning of the meeting

23 that "the command must obey and execute its tasks." Again, asserting his

24 authority -- the Crisis Staff authority over the TO command.

25 Then in his next speech, on the same page, he notes that they're

1 expecting a transport from the army and the contents should be put in

2 storage.

3 On the next page in the B/C/S, same page in the translation, Glisa

4 suggests bringing up two self- -- I'm sorry, it's Radivoje, still on the

5 same page. Radivoje, on the same page, suggests bringing up two

6 self-propelled guns. And then on the last page, the second page in the

7 B/C/S, Radivoje says that "Glisa should go to General Djordjevic today to

8 procure the two HUMVEEs," so the combat vehicles. We should constitute

9 our organs in Trnovo. So a combination of military preparations and

10 forming their own municipal organs are discussed at the Crisis Staff.

11 Q. Thank you. Next is presentation tab 309, master tab 449. It's a

12 list dated the 10th of May, 1992 of members of the Crisis Staff?

13 A. Yes.

14 Q. Can you tell us who are -- what organs those people belong to?

15 A. They are all members of the SDS municipal board.

16 Q. And what agencies were they from, if you know?

17 A. I don't.

18 Q. Were any of them military or police? If you recall at the moment.

19 A. I know from my analysis that one was a member of the police, but

20 at this moment, without my notes, I can't say which one. So I don't -- I

21 won't say which.

22 Q. Then let me show you next presentation tab 310, master tab 435,

23 from the 11th of May.

24 A. Another long session with some interesting comments, and

25 indicative of some disagreement between the TO command and the Crisis

1 Staff, because Danilo Golijanin, listed here as one of the attendees, was

2 the head of the TO command for Trnovo. He attends the Crisis Staff

3 meetings, and the head of the Crisis Staff attends the TO command

4 meetings, indicating the overlap and the communication.

5 Here at the -- on page 1 in the translation, and in the B/C/S, at

6 the bottom of page 02276170, Radivoje says: "Tomorrow, we will provide

7 the army with food from Kalinovik. The mobilisation should be carried out

8 via courier on the list and getting mobilisation papers from Ilidza," so

9 discussion about mobilisation.

10 Then in Radivoje's next speech, still on page 1 in the

11 translation, and on page 02276171, in the middle of the page: "War is

12 unavoidable in Trnovo."

13 On the next page in the translation, same page in B/C/S, the head

14 of the TO command says -- the translation -- apparently, the revised

15 translation hasn't gotten into the binders, so I will read what he says in

16 B/C/S.

17 [No interpretation].

18 THE INTERPRETER: Sorry, the channel was wrong. The translation

19 was: "I will not give the order to bomb without serious provocation."

20 JUDGE ORIE: Yes, thank you.

21 A. And then Radivoje responds, "Well, in that case, we might as well

22 just tell the SDA we're going to surrender all our weapons." I take that

23 to be sarcastic. He warns of provocations, and he says -- this is on the

24 next page in the B/C/S, 02276172, he says: "Even though everything is

25 quiet in Trnovo, we will end up living in a Muslim state." So --

1 MR. STEWART: Your Honour, excuse me, I've been trying to attract

2 Ms. Philpott's attention for a couple of minutes, but failing, which is

3 the story of my life, really, but, Your Honour, I have about two minutes'

4 worth of report back. I didn't know whether Your Honour wanted, on the

5 items from the housekeeping day, whether Your Honour wanted to deal with

6 them today. It could be first thing Monday morning. I'm entirely in Your

7 Honours' hands on that.

8 JUDGE ORIE: For several reasons, I have also a list on those

9 issues on which a report would be received in two days, which ones would

10 be dealt with by the end of the week. My problem is it would easily take

11 us a little bit of extra time, and since my next hearing starts at a

12 quarter past two, I would rather leave it until Monday.

13 MR. STEWART: I'm entirely in Your Honour's hands. No problem at

14 all.

15 JUDGE ORIE: Thank you. Whatever was said about reporting at the

16 end of this week will then be the beginning of next week.

17 MR. STEWART: We're grateful for the extension, Your Honour.

18 Thank you.

19 MR. HANNIS: Thank you, Your Honour.

20 Q. I would like to go to presentation tab 311, which is master tab

21 440. This is from a meeting of the TO command on 15 May 1992.

22 A. As I mentioned, there was overlap of personality and sharing of

23 information between the Crisis Staff and the TO command. We note that

24 Glisa Simanic is present, and that the commander of the staff informed the

25 present parties about the SDS staff conclusions, and lists the conclusions

1 and positions of the SDS Crisis Staff.

2 On the second page of the translation, in the B/C/S the next page,

3 00949423, also an indication of viewing themselves as part of the

4 Republika Srpska or the -- the Bosnian Serb state. The commander is

5 informed of the order of the SRBH on matters of discipline and

6 disobedience, and the command concludes that "any violation should be

7 reported to the official authorities of the SDS." So the TO command

8 expects the SDS to enforce the regulations of the Serbian Republic.

9 Q. Thank you.

10 MR. HANNIS: Your Honour, the next document is one that has, I

11 think, several items we want to discuss. I see it's about three minutes

12 till. I know you directed me to finish my direct today but I've run a

13 little bit short. I have about 20 documents left. I would request the

14 opportunity to finish in half an hour or 45 minutes on Monday.

15 JUDGE ORIE: I'll consider it, Mr. Hannis. On the other hand,

16 what we're doing now where we, I would say, went through the material

17 subject by subject, now we do it municipality by municipality. We went

18 through one entirely. Of course, the material, and the order in which you

19 presented it, appears in the main material as well, so by reading it in

20 its subsequent order, so the only thing that's added, then, is that it is

21 presented in a different sequence rather than that it's any new material.

22 We'll consider it, but --

23 MR. STEWART: Your Honour, may I make an observation on that?

24 It's only this, Your Honour: That, for example, certainly we can see, on

25 our side, we can see which documents are coming up. What we can't see is

1 which particular bits of the documents are being drawn attention to. We

2 have no particular wish to insist, with respect to Your Honour, that it's

3 done in this way, in open court. On the other hand, we would need to know

4 on the Defence side, very quickly then, what are those passages. So there

5 are other ways of doing that, but simply to throw that batch of documents

6 at us without that steer, that's not so readily manageable.

7 JUDGE ORIE: One of the other ways in dealing with it would be

8 that you indicate by each step -- one way of doing it would be that you

9 make one example of that and say, These are the portions we'd like to

10 highlight, to draw your specific attention to, and then we can read it and

11 then and it's there. Of course, then we miss the comments. But on the

12 other hand --

13 MR. STEWART: I'm sorry, what I had in mind is we would have no

14 problem with that, Your Honour, but could I please ask then to have that

15 by, say, 5.00 today, which is work in a different way. I'm not pressing

16 for this, Your Honour. As far as the Defence is concerned, we're in Your

17 Honours' hands. We're not pressing for this. We have no problem with

18 Mr. Hannis simply proceeding in the conventional way and completing his

19 examination-in-chief. That is, in principle, the preferable course.

20 [Trial Chamber confers]

21 MR. HANNIS: Your Honour, if I may make one last comment --

22 JUDGE ORIE: Yes, Mr. Hannis.

23 MR. HANNIS: -- in terms of appeal. Of the remaining 21 or 22

24 documents, I think eight or nine of them are new, were not footnoted to

25 her documents, so they're items we haven't seen before. In addition, we

1 did lose half an hour at the beginning of today and --

2 JUDGE ORIE: Yes, I know that, but that's, of course, a bit

3 included, because you said you would not need perhaps the last one hour

4 and a half, so altogether -- Mr. Hannis, you're invited to provide Mr.

5 Stewart with a copy of the last materials, indicating, if it's only

6 briefly, but by perhaps marking with the yellow marker, the areas you'd

7 like to draw specific attention to. At a later stage, the Chamber might

8 give you an opportunity, if there are really matters of great concern,

9 because most of what we hear now is illustration rather than anything new,

10 but if there's anything that would need very specific attention, but not

11 going through the material as we did now, then you may apply for

12 permission to do so. If you would provide Mr. Stewart with the -- well,

13 the last documents with the highlights, then the Chamber, at a later

14 stage, would like to receive at least one highlighted version as well so

15 that we can work that in our material and are well prepared for

16 cross-examination next week.

17 MR. HANNIS: Would I be permitted to address the new documents

18 that are not in her report on Monday morning?

19 JUDGE ORIE: What do you mean by new? Because I see there are two

20 kinds of documents. The one is for presentation only, but they are in the

21 original material, because there's usually -- there usually is a reference

22 to the master tab. So to that extent, they are new to the extent that we

23 have not spoken about it in court, but they're not new -- yes?

24 MR. HANNIS: I'm sorry, Your Honour, the master tabs include new

25 material.

1 JUDGE ORIE: Yes.

2 MR. HANNIS: Master tabs don't include only the footnoted

3 documents to her report. So if it says "presentation only," as I

4 understand it, those are items that were not in her report and we're not

5 familiar with, so they are brand new.

6 JUDGE ORIE: But I take it they are used as the basis for your

7 research, even if you made no specific reference to some of them.

8 THE WITNESS: Some of the documents that are "presentation only"

9 have come to my attention only after writing the report.

10 JUDGE ORIE: Yes. You may mark those documents that are, to that

11 extent, new, that they have not been taken into consideration by you when

12 you wrote your report. If you are not aware of which documents those

13 exactly are, then Ms. Hanson is permitted to provide the relevant

14 information to you so that you can make up that list.

15 MR. HANNIS: I think I can tell from our list here.

16 JUDGE ORIE: Okay.

17 MR. HANNIS: Thank you.

18 JUDGE ORIE: Then we will adjourn. I indicated until now the

19 Prosecution has taken, thus far, some 12 hours and 15 minutes,

20 approximately, in examination-in-chief.

21 Madam Registrar, next week we will sit in this same courtroom?

22 And 9.00. We will adjourn until Monday, at 9.00.

23 And, Ms. Hanson, apart from the exception I just gave to you,

24 although not needed, you will receive the same instructions as I gave you

25 before.

1 --- Whereupon the hearing adjourned at 1.50 p.m.,

2 to be reconvened on Monday, the 7th day of March,

3 2005, at 9.00 a.m.

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