1 Monday, 5 December 2005

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.07 a.m.

5 JUDGE ORIE: Good morning to everyone. Mr. Registrar, would you

6 please call the case.

7 THE REGISTRAR: Good morning, Your Honours. This is case number

8 IT-00-39-T, the Prosecutor versus Momcilo Krajisnik. Thank you.

9 JUDGE ORIE: Thank you, Mr. Registrar.

10 Mr. Stewart, is the Defence ready to call its next witness?

11 MR. STEWART: Yes, Your Honour. And this -- there are no

12 protective measures sought for this witness, and it's Mrs. Slobodanka

13 Hrvacanin.

14 JUDGE ORIE: Yes. Then, Madam Usher, would you please escort

15 Mrs. Hrvacanin to the courtroom.

16 MR. STEWART: Your Honour, may I just say as the witness is coming

17 in, just to use the time, that there are occasions, I'm sure Your Honour

18 will appreciate, where there are things which a witness, either on the

19 Prosecution or the Defence side, is in some way bursting to tell the Court

20 and will tell the Court anyway. It may not be rigorously, ruthlessly

21 relevant. I just hope Your Honour will understand if sometimes for a

22 relatively short passage such material is elicited in evidence even

23 perhaps ruthless, rigorous efficiency about what was strictly relevant

24 might exclude it. But, Your Honour, I'm talking about really quite minor

25 things on which I could lead as quickly as I could.

1 JUDGE ORIE: I take it we'll hear from Mr. Tieger once leading

2 becomes a problem for him.

3 [The witness entered court]

4 JUDGE ORIE: Good morning, Mrs. Hrvacanin. Before you give

5 evidence in this court, the Rules of Procedure and Evidence require you to

6 make a solemn declaration that you'll speak the truth, the whole truth,

7 and nothing but truth. May I invite you to make that declaration of which

8 the text is now handed out to you by Madam Usher.

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

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

11 JUDGE ORIE: Thank you, Mrs. Hrvacanin. Please be seated.

12 THE WITNESS: [Interpretation] Thank you.

13 WITNESS: SLOBODANKA HRVACANIN

14 [Witness answered through interpreter]

15 JUDGE ORIE: You'll first be examined by Mr. Stewart, who is

16 counsel for the Defence.

17 Mr. Stewart, you may proceed.

18 MR. STEWART: Thank you, Your Honour.

19 Examined by Mr. Stewart:

20 Q. Good morning, Mrs. Hrvacanin. Mrs. Hrvacanin, I'm going to put a

21 number of facts to you fairly quickly to do with your own personal history

22 and other basic matters. I'm going to invite you from time to time when I

23 do that just to tell the Trial Chamber whether you agree or whether there

24 are any corrections that you want to make.

25 Now, you were born on the 31st of January, 1946 in Belgrade. You

1 graduated from high school in Gradiska, which is about 58 kilometres from

2 Banja Luka on the Sava River, and Croatia is just on the other side of the

3 river. You gained a diploma in dentistry from university in Belgrade.

4 Your father was a volunteer in the Serbian army in the First World War,

5 fought on the Salonika front. He was a Thessalonika freedom fighter. In

6 World War II he was for a time in the Stari Gradiska concentration camp.

7 At one point he was taken out to be shot but narrowly escaped by virtue of

8 somebody who recognised him being able to save him, and he was sent on the

9 way to Germany. The convoy on the way to Germany was stopped in Zagreb

10 and eventually he, with a number of others, made his way to Slovenia.

11 Your mother was arrested in retaliation, sent to a camp in Germany, and

12 because of your father's background as a freedom fighter his -- he found

13 difficulty getting a job -- or you found difficulty as well at times. He

14 found difficulty getting a job in what was then a communist state and went

15 abroad at times to look for work.

16 Now, is all that, as an important family background for you,

17 Mrs. Hrvacanin, is all that I've just described accurate?

18 A. Yes, it is accurate.

19 Q. And you were married in 1970, and when you were first married you

20 lived and worked in Zenica, and you have one son who was born in 1972; is

21 that correct?

22 A. Yes.

23 Q. Your husband, who is still alive, your husband was, during the

24 communist era in former Yugoslavia a Communist party member, but you

25 yourself were always and have always been strongly anti-communist; is that

1 correct?

2 A. Yes.

3 Q. But in fact your husband's support of the Communist Party, which

4 you always vigorously disagreed with, did at least help you to be able to

5 finish your studies; is that correct?

6 A. Yes.

7 Q. And you eventually gained a doctorate in Novi Sad, and you now

8 work as the head of the dentistry department at the medical school in

9 Banja Luka and as an oral surgeon in the health centre in Banja Luka; is

10 that correct?

11 A. I'm an oral surgeon in Banja Luka in the health clinic, and I am

12 dean of dentistry at the medical faculty in Banja Luka and a professor

13 there.

14 Q. And is it correct that you have -- you have watched, from time to

15 time, excerpts of this trial on television? On main television programmes

16 there are from time to time summaries and reports of this trial of

17 Mr. Krajisnik, and you have from time to time watched those?

18 A. Yes.

19 Q. Have you at any time watched the internet transmissions of this

20 trial?

21 A. No.

22 Q. Now, in Zenica municipality -- well, to just jump ahead for the

23 moment: You stayed and lived in Zenica municipality, didn't you, until

24 the end of February 1992?

25 A. Yes.

1 Q. Now, in Zenica municipality in -- at the time of the multi-party

2 elections in November 1990, what was the ethnic mix in Zenica municipality

3 as you remember it? What proportions of the different nationalities?

4 A. As far as I remember, in -- most of it belonged -- 60 per cent was

5 the Muslim population, 15 was the Croatian, and 50 per cent [as

6 interpreted] the Serb population. The rest belonged to Yugoslavs.

7 Q. And in the November 1990 elections --

8 MR. TIEGER: I'm sorry, there appears to be a transcript error

9 that counsel may wish to correct with the witness in terms of the

10 percentages.

11 MR. STEWART:

12 Q. Yes. It appears in the transcript as 50 per cent Serbs. That may

13 be just a mishearing. You said 60 per cent were Muslim, 15 per cent

14 Croats, and then the percentage that you would put on Serbs is what?

15 A. The same as the Croats; 15 per cent. We were a national minority

16 there.

17 MR. STEWART: Thank you for that, Mr. Tieger.

18 Q. Then in the November 1990 elections, do you remember what the

19 proportions of votes were that were obtained by the main parties?

20 A. Most of the votes were won by the Party of Democratic Action, the

21 SDP, and the Serbian Democratic Party and the HDZ got an equal number of

22 votes. Then there was the party for Yugoslavia, the Yugoslav Party, the

23 Green Party, and a few other minor parties. I don't know what percentage

24 they secured.

25 Q. I should have made it clear that my question related to Zenica.

1 Your answer clearly did relate to Zenica.

2 What was the -- can you put a percentage on the votes in the

3 Zenica municipality that was obtained by the Serbian Democratic Party?

4 A. We won 10 per cent of the votes. Of the 15 per cent of the

5 inhabitants we had, we had nine deputies in the Municipal Assembly.

6 Q. Now, did you attend a large meeting on the 12th of July, 1990, at

7 the Bascarsija hall in Sarajevo which was a founding convention of the

8 SDS?

9 A. Yes.

10 Q. About how many people do you remember being there?

11 A. Well, there were 2 to 3.000 people there. It's a large hall. I

12 don't know the exact number, but it was chock-a-block full. People were

13 standing in the hallway as well.

14 Q. Was Dr. Karadzic, Radovan Karadzic present?

15 A. Yes.

16 Q. Was Mr. Izetbegovic present?

17 A. Yes.

18 Q. And what was the temperature of the meeting? Was it -- was it a

19 good-natured meeting? Was it an argumentative meeting? What sort of a

20 meeting was it?

21 A. Well, it was a founding Assembly meeting. The atmosphere was very

22 nice. The SDS was the third national party which was being established

23 out of the SDA party and the HDZ party, and there was a general atmosphere

24 of friendship that prevailed. There were no insults being hurled. All

25 the speakers expressed their happiness that the Serbian Democratic Party

1 was being founded. And when I say that, I'm not referring to people from

2 the Serb ethnic group but from other ethnic groups who were present there.

3 Q. Had you previously been active in politics yourself before that

4 meeting on the 12th of July, 1990?

5 A. No.

6 Q. After that meeting, did you go to see Mr. -- Dr. Radovan Karadzic

7 in Sarajevo?

8 A. Yes.

9 Q. And did you go with anybody else?

10 A. Yes.

11 Q. Who was that?

12 A. I went with people from Zenica. I went with Bosko Jevtic and some

13 other people whose names I don't remember because, after all, it's been 15

14 years since then. We went to see how we were going to found the Serbian

15 Democratic Party in Zenica.

16 Q. Who was Bosko Jevtic?

17 A. Bosko Jevtic was a member of the initiative board for the founding

18 of the Serbian Democratic Party in Zenica. He was a technician working in

19 the ironworks of Zenica.

20 Q. Did he have some personal connection with you?

21 A. Yes. I am the kuma, or godmother, to his children.

22 Q. Was there then a meeting in Zenica that followed your visit to

23 Sarajevo to see Dr. Karadzic?

24 A. On that first occasion I didn't have chance to meet Dr. Karadzic,

25 but did I have a chance of meeting his associates, and that was the late

1 Danilo Veselinovic, Mr. Velibor Ostojic, Mr. Joja Tintor. Then we came on

2 the second time and it was Mr. Radovan Karadzic. We had a talk and

3 discussed how to form the Serbian Democratic Party in Zenica. He wasn't

4 overjoyed with the idea, and he said that there were very few Serbs living

5 in Central Bosnia. I don't know what he meant by "very few Serbs," or

6 insignificant number if you know that there were 100.000 or maybe more

7 Serbs living in that part of Bosnia, but then he said, "Well, all right.

8 Do something, then," and we were given the basic instructions and

9 guidelines as to how to establish the party.

10 We joined up and started organising the whole affair, and in

11 August the party was formed --

12 Q. Can I just ask you to pause there, please, Mrs. Hrvacanin. You

13 said that you were given the basic instructions and guidelines as to how

14 to establish the party. Could you give the Trial Chamber some idea of the

15 nature of such instructions and guidelines.

16 A. Well, the party already had a statute. It couldn't have

17 registered in the court of Bosnia and Herzegovina without the statute. So

18 we had a statute, and from the statute we were able to see all the

19 conditions met for the party to be established, that is to say what organs

20 it should have. We expanded our initiative board of like-minded people,

21 anti-communists who had spent their entire life during the communist era

22 living under conditions of mistreatment and abuse, and we rallied around

23 and tried to form this Serbian Democratic Party. And we had a solemn

24 session similar to the one that was held in Sarajevo. There were many

25 Serbs, a large number of Serbs, certainly over 800, perhaps more, in the

1 hall, and the hall was a cinema that was called the 29th of November

2 Cinema Hall in Zenica. It has a large hall.

3 Q. Mrs. Hrvacanin, may I ask you to pause there. You -- you started

4 off --

5 JUDGE ORIE: Mr. Stewart, may I just ask one brief question to

6 clarify the matter.

7 You mentioned the name of Joja Tintor. Is that the same person as

8 Jovan Tintor?

9 THE WITNESS: [Interpretation] Yes, that's right.

10 JUDGE ORIE: Please proceed.

11 MR. STEWART: Thank you, Your Honour.

12 Q. Mrs. Hrvacanin, I was just going to say that you started off the

13 first ten minutes or so with very short answers. Your answers are

14 becoming a bit longer. If you could please tend towards the short side

15 and then I will put more questions to you.

16 A. I apologise. Yes. Thank you, I will.

17 Q. No apology needed, Mrs. Hrvacanin. The -- were you given -- I've

18 asked you about instructions and guidelines given. Were you given any

19 policy directions on those visits to Sarajevo?

20 A. No.

21 Q. Did you meet Mr. Krajisnik on those visits to Sarajevo?

22 A. No.

23 Q. Did you at the time know who Mr. Krajisnik was?

24 A. No.

25 Q. Coming to the meeting that you were describing, then, that took

1 place on the 28th of August, 1990. That's right, isn't it?

2 A. Yes.

3 Q. And Dr. Karadzic was present at that meeting, was he?

4 A. Yes.

5 Q. And Mr. Ostojic?

6 A. Yes.

7 Q. Was Mr. Krajisnik present?

8 A. No.

9 Q. Was the president of the Zenica SDA also present?

10 A. Yes.

11 Q. And the president of the Zenica municipality, was he present?

12 A. Yes.

13 Q. Was he a Muslim?

14 A. No. Mr. Kolar is a Croat. Bogdan Kolar is his name.

15 Q. And did you, on or shortly after that meeting on the 28th of

16 August, take on the office of president of the SDS for the municipality of

17 Zenica?

18 A. At that meeting I was elected president of the SDS of Zenica.

19 Q. Was that the first political post that you had ever held?

20 A. Yes.

21 Q. Was there any -- was there any unpleasant consequence for you

22 personally of your becoming the SDS municipality president?

23 A. Yes, very unpleasant.

24 Q. And what was that?

25 A. It was very unpleasant for me. After one of our meetings, the

1 police collected me up off the street and took me to the premises which

2 the State Security Service used. I thought that it was a friendly

3 invitation as they told me when they took me over on the street to have a

4 cup of coffee. However, later on it turned out to be something quite

5 different.

6 I was there verbally and physically abused. Perhaps the whole

7 session would have lasted much longer had a good friend of mine not turned

8 up, and he succeeded in extracting me from the clutches of the people who

9 wanted to beat me. On that particular occasion I was just slapped twice.

10 Q. That good friend of yours, was he a policeman?

11 A. He worked in the crime police. He was a crime inspector, but he

12 did not work in the state security.

13 Q. Now, you said that they took you over on the street to have cup of

14 coffee. So they took you to the police station, did they?

15 A. Yes. I was a doctor, and people would come to me from the police

16 force as patients, and at first I just couldn't believe that anything bad

17 would happen to me. That's what I always tend to think. I always tend to

18 think the best of people, and I never have any fear that something bad

19 will happen.

20 Q. How many of -- were they policemen, all these people who took you

21 to the police station?

22 A. They worked for the State Security Service. They're not called

23 policemen. They're inspectors of the DB, state security. They don't wear

24 uniforms. They wear the kind of clothes that all of us ordinary civilians

25 wear.

1 Q. How many of them were there?

2 A. Four.

3 Q. And when you got to the police station, was there a discussion or

4 some form of conversation or questioning? What happened?

5 A. First I had the cup of coffee that I was invited to. Then one of

6 them told me to get up. I did get up. Then the cross-examination

7 started: What is it that we Serbs wanted? Do we want to write in the

8 Cyrillic alphabet? I said, "Well, the Cyrillic alphabet is our alphabet.

9 What do you want?" "There's no place for you here. Go to Serbia and live

10 there." I asked them whether that was some kind of a joke or whether they

11 were serious when they said that. They said, "You don't even know what

12 kind of situation you're in."

13 I turned to one of them whom I knew, I didn't know the rest of

14 them, and I said, "What are you doing?" At that moment I was slapped in

15 the face. I was hit in the ribs too. He hit me with his elbow. And it

16 was only then that I realised where I was.

17 When I as a woman was being beaten, what happened to men?

18 Q. Was there any questioning or comment made on that occasion by

19 these men on the policies of the SDS?

20 A. They said that all missions regarding the SDS had to be finished

21 and that it would be best for me to leave the SDS if I wished myself and

22 my family well. They said that they were vigilantly following everything

23 that we Serbs were doing and they said that we were a national minority

24 there; Muslims were majority. And one of the men who I already mentioned

25 and who I said I knew from before, I think his last name was Vukovic, I

1 cannot say whether he's a Serb or a Croat because I really don't know

2 whether he is one or the other.

3 Q. But he was one or the other and not a Muslim; is that correct?

4 A. Mr. Vukovic, I don't know what he was. But the remaining three

5 men were Muslims.

6 Q. Was there any suggestion made to you that any SDS policy on any

7 issue should be abandoned?

8 A. No. Generally speaking, they were saying that the SDS had no

9 business there.

10 Q. Was there any reference made by anybody to Chetniks?

11 A. Oh, yes. I've already said that they abused me verbally. I am

12 sorry, I do apologise to the Court, because I'm going to use a swear word.

13 They cursed my Chetnik mother, and they said that we Chetniks had no

14 business there.

15 I don't think I'm a Chetnik. I'm a nationalist, a sound

16 nationalist, no greater nationalist than a French person or a Dutch person

17 or a Spanish person. I love my own people. I'm a Serb, and I shall

18 always remain one, but I respect all other peoples, all other nations, all

19 other religions, because as a Christian I cannot live any other kind of

20 life.

21 I did not think that I was there to answer questions as a Serb,

22 but I am a Serb.

23 Q. Was there any mention by anybody in that discussion of the idea of

24 Greater Serbia?

25 A. That was said often. A Greater Serbia was often mentioned. I

1 think that we just wanted to be equal to the other two peoples, the

2 Muslims and the Croats, and the other peoples living there. In Zenica

3 there are over 30 different ethnic groups. There are Czechs, Germans and

4 others who came to the town where the steelworks were being built. So I

5 don't see why anybody would have that kind of idea in that area. We

6 wanted to live in Yugoslavia, and we wanted to be within

7 Bosnia-Herzegovina, our state, at that time a republic.

8 Q. Did you mention to these men that you had personally any support

9 for the idea of a Greater Serbia?

10 A. No. Why would I support the idea of a Greater Serbia when I lived

11 in that town, when I lived in that republic? I was born in Belgrade. My

12 mother is a Belgrader too. But I was born towards the end of the Second

13 World War. My father suffered terribly in the Second World War and he

14 didn't want to go on living in Gradiska where he was born because, as a

15 Serb, he was mistreated by the communist regime. He wanted us, his

16 children, and I'm the ninth child of my father, to have a safe and happy

17 future. However, I'm sorry that I have to say this, I'm 60 years old but

18 I'm not happy today either. Can a person like me be happy, who was

19 expelled from the town of Zenica on account of the fact that she's a Serb,

20 whose property was not restituted? My husband cannot get his pension, and

21 I cannot be happy for as long as such issues are at stake.

22 Q. Mrs. Hrvacanin, we -- the incident that you've just described took

23 place, we know, between your election as the SDS Zenica president and the

24 multi-party elections in November 1990, so just concentrating on that

25 period for the moment, from the end of August until the multi-party

1 elections in November 1990, did you experience any other unpleasant

2 consequences of your -- or what you understood as consequences of your

3 election as SDS president in Zenica?

4 A. This is the Balkans. It is very hard for a woman in the Balkans

5 to be a public figure and to be involved in cultural affairs. Women, like

6 in the Ottoman Empire, are supposed to stay at home, take care of their

7 families and husbands, their children. This was a great burden for me

8 because I was mistreated every day. I had these telephone calls at work,

9 at my workplace. They cursed my Chetnik mother. They were saying that I

10 should move out. They threatened me over the telephone. They threatened

11 to kill me.

12 When I walked through town until then I was a well-respected

13 figure through my profession, but then I had thousands of embarrassing

14 situations. They would mock me and shout "SDS, you will wear a fez."

15 That's what they shouted after me.

16 In many places, in the marketplace where I went shopping for my

17 family, they would call out my name from several different directions in

18 order to frighten me so that I'd leave the marketplace. When I'd get

19 home, the telephone would ring and the question would be, "Are you still

20 there? Move out. We're going to kill you. We're going to kill your son.

21 We're going to kill your husband. You've got to leave." And this went on

22 for months.

23 Often in my mailbox I would find threats, threatening letters.

24 They tried to explain to me that my name was ugly and that my last name

25 was nice, because Hrvacanin probably made them think of Croats; Hrvat.

1 They said, "It would be best for you to get out of here."

2 Under the door I would find little notes saying, "There's a

3 grenade in your apartment. We're going to kill you. What are you waiting

4 for? Why are you not leaving?"

5 All of that led to my decision in February 1992 that I leave the

6 town that I lived in, that I leave it forever. I lived in that town. I

7 never made a mistake there. I looked at all of my patients as patients.

8 Ethnicity or religion or race did not matter at all. I was what I was

9 because, after all, I took the oath of Hippocrates and all people are

10 equal to me.

11 Q. Mrs. Hrvacanin, you -- you've described a number of types of

12 incident, and you referred very often to "they." "They would call out my

13 name. They would mock me." Who do you mean by "they"?

14 A. Muslims.

15 Q. Did incidents of this type that you've just described over the

16 last few minutes begin before the multi-party elections?

17 A. Excuse me. May I put a question? I don't understand. Are you

18 referring to the parliamentary multi-party elections or the party

19 elections?

20 Q. You're quite right, Mrs. Hrvacanin. I was referring to the

21 November 1990 multi-party elections throughout Bosnia and Herzegovina for

22 the, among other things, the Bosnia and Herzegovina Assembly. So I'm

23 talking about -- the time I'm talking about, I think it was the 24th or

24 25th, the time I'm talking about is the end of November 1990, and the

25 question was whether incidents, those telephone calls and those sorts of

1 incidents, did they start before those elections?

2 A. Before the parliamentary elections, yes. Not before the party

3 elections. While the party was being founded, it seemed that the SDA and

4 the HDZ wanted to topple communism first and foremost and that that is

5 what would happen, that the communists would no longer be in power and

6 that non-communists would get into power.

7 Q. Was there, in that period before the parliamentary multi-party

8 elections, were there any actions or was there any behaviour in your

9 locality on the part of Croats that you found objectionable?

10 A. Yes. As for Croats, there was an increasingly visible coalition

11 between the Muslims and the Croats. Their pre-election rallies were

12 terrifying. They had flags there, and of course it didn't really suit any

13 Serb to see that. They were very vociferous at these rallies, so all of

14 this instilled anxiety among the Serb population of Central Bosnia,

15 especially when the SDA had their Congress in the Holiday Inn hotel. I

16 think it went on for three days.

17 At this Congress Mr. Brozovic, who is a Croat from Croatia, was a

18 guest, and he said that the eternal dream of the Croats to establish a

19 border on the Drina River would finally come true. That --

20 JUDGE ORIE: May I just intervene for a better understanding of

21 your testimony. You were talking about Croats, that they had flags and

22 that it didn't really suit any Serb to see that. You continued,

23 "They were very vociferous at these rallies, so all of this instilled

24 anxiety among the Serb population of Central Bosnia, especially when the

25 SDA had their Congress in the Holiday Inn hotel." You switched from the

1 Croats to the Muslims, and then immediately continued with Mr. Brozovic

2 who was, as a Croat, a guest. Did you mean to say the SDA Congress or

3 were you referring to the HDZ?

4 THE WITNESS: [Interpretation] No, Your Honour. Mr. Brozovic

5 attended the SDA Congress. That was the SDA Congress, not the HDZ

6 Congress.

7 JUDGE ORIE: Yes, thank you.

8 MR. STEWART:

9 Q. And Mr. Brozovic was a Croat.

10 A. Yes.

11 Q. You referred to flags. The transcript may not have it a hundred

12 per cent at the moment, but in some way actions and in relation to flags

13 were not acceptable to Serbs. What was it that you were talking about

14 there, what actions connected with flags?

15 A. For example, the SDA flag and the Croat flag, the chessboard flag,

16 were tied together. And then there were Saudi Arabian flags at these

17 rallies too in Velika Kladusa. There was a lot of kind of this folklore,

18 so to speak, which does not belong to our country, which was then called

19 Yugoslavia and the Republic of Bosnia-Herzegovina.

20 Serbs did no such thing. They were not tying up flags that way.

21 We came to rallies, too, but without flags and without baiting others.

22 In the local media, the television, radio, and the daily press,

23 there were many statements to the effect that Muslims were the flowers of

24 Croatdom. I as an intellectual did not mind not being anybody's flower,

25 but the messages I was receiving were that I would not fare very well. I

1 came to that conclusion myself without anybody even telling me.

2 Q. Does the phrase -- what did the phrase "The flower of Croatdom" or

3 "The flower of Croats," did that have any resonance for you?

4 A. Yes.

5 Q. What was that?

6 A. I'll try to explain that. As a woman, I am very fond of flowers.

7 I like giving flowers as a present. I like having flowers in my home, I

8 like having flowers in my garden. People who do not like flowers and who

9 do not know what it's like to take care of flowers do not know what beauty

10 is.

11 When you pay that kind of compliment to someone, then it means

12 that that person means the world to you. Knowing history, knowing what

13 happened in the Second World War, and having been fortunate enough to live

14 with a father who spent the First World War and the Second World War the

15 way he did, I didn't like that because I realised that there was something

16 going on and that this coalition would probably do something bad, which

17 later proved to be true in the future.

18 Q. May I just pause there for a moment. The phrase "The flower of

19 the -- of Croatdom," did it have any specifically political or historical

20 resonance?

21 A. Yes. The Croats and the Muslims were allies in the Second World

22 War.

23 Q. Was there any phrase used in the Second World War in any way

24 related to that?

25 A. I don't know. I was born after the Second World War. I was born

1 in 1946. But I know that Muslims were part of Ustasha units and that they

2 cooperated closely with the Croats. You yourself said that my father was

3 from Gradiska, and the concentration camp of Stara Gradiska was right

4 there and all the people of Gradiska know that history.

5 Q. Mrs. Hrvacanin, leaving the incident you described at the -- when

6 you were taken to the police station or the state security station, but

7 did you take any action yourself as a result of that incident?

8 A. Yes. I went to Sarajevo to say that to Mr. Karadzic and to the

9 political council of the party that held its meetings in Sarajevo on

10 Mondays. I was worried for myself, and I was worried about other people

11 who were top intellectuals. I was worried that something could happen to

12 them.

13 Mr. Karadzic did not consult me but made this public at a press

14 conference. I think that it was held on the second day, on Tuesday. Of

15 course, the state security of the SUP of Zenica responded by saying that

16 they had not brought me into custody and had not beaten me. They don't

17 have any written record. However, I must say that communists never had

18 any written records for people they brought into police custody and beat

19 up. No police records are required for that. But I had a record on my

20 face, on my eye, and in my soul, and I still feel this trauma.

21 Q. Was there, before the parliamentary elections in late November

22 1990, an incident affecting your apartment in Zenica?

23 A. Yes.

24 Q. First of all, can you -- can you date that incident?

25 A. Yes, I can tell you when that happened. I think it was the 8th of

1 August. I have a document to that effect.

2 Q. Do you mean August?

3 A. Well, I'm just not sure now. I've become a little upset telling

4 the story I've been telling. But on the document it says -- I can show

5 you the document if His Honour the Judge will permit me to do so.

6 Q. Just a moment, Mrs. Hrvacanin.

7 MR. STEWART: Your Honour, we do have the document and over the

8 break we will arrange necessary copies. I can proceed without the

9 document, but, Your Honour, I can tell you it relates to 8th of November,

10 1990. It's very clear on the document.

11 JUDGE ORIE: I leave it in your hands, Mr. Stewart, whether it's

12 -- and also I don't know whether this is a contested matter, yes or no.

13 If not, then even without the document we could accept the testimony of

14 the witness as such.

15 We should take care that -- we should take care that -- I do

16 understand that this is much of background information on what happened

17 elsewhere in Bosnia and Herzegovina. At the same time, it goes into such

18 detail that now and then the question came into my mind whether you were

19 presenting the Prosecution's case in a case to be started against Croats

20 and Muslims rather than whether you are presenting the Defence case, in

21 view of the charges against Mr. Krajisnik. So therefore the level of

22 detail and the balance, I leave it up to you, Mr. Stewart.

23 MR. STEWART: Your Honour, what I can do, for example, in relation

24 to -- to this incident, I could more ruthlessly lead on the matter, Your

25 Honour, and get to it quite quickly, and then if Mr. Tieger, or indeed

1 Your Honours, had any problems with what I was leading, then of course you

2 could say so at any time.

3 JUDGE ORIE: Yes, of course, we will. I hope that you got the

4 other part of my message.

5 MR. STEWART: Of course, Your Honour, and I know that my job is to

6 defend Mr. Krajisnik, Your Honour.

7 JUDGE ORIE: And charges against him rather than --

8 MR. STEWART: Indeed Your Honour, I'm well aware of that.

9 JUDGE ORIE: Yes, please proceed.

10 MR. STEWART: I shall follow that as my guiding principle, Your

11 Honour.

12 Q. The -- is this right, Mrs. Hrvacanin, that on the 8th of November

13 one of the nurses where you work recognised a man who was inquiring about

14 your whereabouts as a Ministry of Interior employee and that later that

15 day your son told you on the telephone that your apartment had been broken

16 into and ransacked, with things strewn about, and that had in fact

17 happened? When you got home, you discovered that there was a terrible

18 mess of your apartment, with belongings and clothing strewn about, that

19 very little was stolen, just a little bit of foreign currency. Is that

20 right?

21 A. Yes. Absolutely.

22 Q. And you did report the incident to the police straight away;

23 correct?

24 A. Yes.

25 Q. And inspectors came to the apartment, took fingerprints, were

1 there for several hours, but after that you never received any further

2 response to your complaint?

3 A. That's right. The inspectors did come and so did the

4 investigating judge. They made a note of it all and kept a record of it.

5 They didn't give me an answer, nor did they when I filed a criminal report

6 against the police of the Zenica district.

7 Q. The -- in -- around April of 1991, is it correct that you were

8 elected to a further SDS position which was the president of the region of

9 Central Bosnia?

10 A. Yes.

11 Q. And if I can just torment the interpreters for a moment, if I read

12 off - and everybody else - a list of municipalities, can you confirm that

13 these are the municipalities which comprised that region: Zenica itself,

14 Kupres, Bugojno, Donji Vakuf, Travnik, Vitez, Zavidovici, Zepce, Magla,

15 Kakanj, Busovaca, and is it Novi Travnik/Pucarevo? Were those all

16 comprised in the region of which you were elected SDS president?

17 A. Yes.

18 Q. And that's 12 municipalities. Is it correct that, at least in

19 theory, Gornji Vakuf was also included but there were no Serbs there?

20 A. A small number.

21 Q. And Zenica had, is this right, for some considerable time been

22 effectively the centre of that particular region?

23 A. Zenica was the centre of the region according to the state set-up

24 as well. Not only the one that the SDS had but previously as well.

25 Q. On your appointment, or election, rather, as the president of the

1 Zenica municipality - and I'm talking about the municipality now - did you

2 become a member of the SDS Main Board?

3 A. Yes. In the first mandate.

4 Q. Well, that was your first mandate, and then, just jumping ahead

5 for the moment in time, then, when did your second mandate begin?

6 A. In 1991, on the 12th. St. Peter's Day, the 12th of July.

7 Q. Did you -- under whichever mandate, did you remain a member of the

8 Main Board of the SDS right through from the end of August 1990 until late

9 into at least 1992?

10 A. The term of office was four years; until 1995.

11 Q. So you -- until well after the end of 1992 you were continuously a

12 member of the SDS Main Board after your initial membership. That's

13 correct, isn't it?

14 A. Yes.

15 Q. In Zenica itself after the multi-party elections, were you

16 involved in leading for the SDS in power-sharing discussions at the

17 municipality level?

18 A. Yes.

19 Q. And they were tripartite discussions, were they; the SDS, the SDA,

20 and the HDZ?

21 A. Yes.

22 Q. And for the SDS there was you as the SDS president and nine local

23 deputies who were Serbs, is that right, in the negotiations, power-sharing

24 discussions?

25 A. Yes. That is correct. Each party gave a certain number of

1 negotiators; the SDA, the HDZ, and the SDS. So that we were engaged in

2 certain agreements that you would think were fine at the beginning.

3 Q. Who led for the SDA in those discussions?

4 A. At the head of the SDA delegation was the president of the

5 municipality, Ibrahim Alispahic, who was elected president of the

6 municipality. Well, maybe I've got the surname wrong. I apologise if I

7 do, but I know that his first name was Ibrahim.

8 Q. And for the --

9 A. He was the number one man.

10 Q. And for the HDZ, was it a Mr. Zakic?

11 A. Sakic.

12 Q. I beg your part.

13 A. Sakic. That's right, yes.

14 Q. And those negotiations took about three months altogether, did

15 they?

16 A. Yes.

17 Q. But one way or another you were able - is this correct - to obtain

18 for the SDS rather more -- a rather higher percentage of the posts than

19 was strictly proportionate to your votes in the election?

20 A. That's right, yes.

21 Q. Did you obtain for the SDS around 30 per cent of the posts

22 available?

23 A. Yes.

24 Q. What was the secret of your success in obtaining that higher

25 percentage? How did it -- how did you achieve that?

1 A. I negotiated with Mr. Ibrahim. Probably my patience and his

2 patience was great. He wanted to help. He wasn't one of the extremist

3 extremes of the SDA, and that was shown later on, and he was replaced as

4 the president of the municipality and another man put in his place,

5 because in fact he had given us more space than he ought to have done.

6 Q. And is this right, if I put a number of positions to you, that you

7 were able to obtain for the Serbs, for the SDS, the following posts:

8 Vice-president of the Municipal Assembly, vice-president of the Municipal

9 Executive Committee, the headship of four of the 12 municipal departments,

10 the position of secretary for public transport within the police, and also

11 that there were no significant changes among directorships and managerial

12 -- senior managerial positions in local companies? Is that description

13 and list accurate?

14 A. Everything that you have said is correct except for the SUP. Not

15 the head of transport but the head of the public security service.

16 Q. And the chief of police and chief of state security, under the

17 power-sharing arrangements, were both Muslims; is that correct?

18 A. Yes. [In English] Yes.

19 Q. And is it right that at no time did you form a Serb Assembly in

20 either Zenica municipality or in the central region of Bosnia?

21 A. [Interpretation] That's correct.

22 Q. Were you involved yourself in any power-sharing discussions in any

23 other municipalities apart from Zenica?

24 A. Only in Zepce.

25 Q. And why did -- why were you involved in those discussions in

1 Zepce?

2 A. The president of the SDS of Zepce asked me because only five and a

3 half or 6 per cent Serbs lived there. It's a municipality with an equal

4 number of Muslim inhabitants and Croat inhabitants, and he wanted me to

5 become involved in that respect and I did. I tried to hold consultations

6 and help in that way with respect to the power sharing.

7 Q. Did you become aware, in April and May 1991, of any imminent

8 changes in relation to JNA presence in Zenica?

9 A. Yes. The garrison from Zenica was supposed to move out, and that

10 led to another reason for nervousness and fear among the Serb people.

11 Q. Taking it just in stages, Mrs. Hrvacanin. Did you find out that

12 -- in advance that the -- the men in the JNA garrison in Zenica were going

13 to be moved to Cacak in central Serbia?

14 A. Yes.

15 Q. In fact, you found out from one of your patients?

16 A. That's right. The pilots who from Pleso, Croatia, came as

17 logistics to the SUP of Zenica, I think there were three or four pilots.

18 One was a patient of mine. I operated on him. He said this since they

19 used the hangars for the helicopters and they were helicopters with which

20 -- or, rather, which were supposed to be placed at the disposal of the

21 medical centre because the Zeljezara mine was there and if there were any

22 emergencies and natural disasters, they were to be deployed, and then he

23 said to me, "Do you know that they're going to -- the army is going to

24 pull out of here?" And I was astounded. I said, "No. That is the first

25 time I hear of it."

1 Q. Mrs. Hrvacanin, again I'm going to put to you a brief summary and

2 ask if you can confirm it: That you learnt that the JNA from Zenica were

3 going to move to Cacak. You went with a number of your Zenica SDS

4 colleagues to raise this concern with one of your colleagues, a

5 Mr. Ostojic. Not Velibor Ostojic, a local Mr. Ostojic who was in the

6 nature of the local minister of defence under the power-sharing

7 arrangements. Is that right so far?

8 A. That is right. His name is Branko Ostojic, and he was the chief

9 of the department for the army. I don't know what the exact name was, I

10 didn't do any military service, of course. It was the National Defence

11 Department, or sector. I think that's what its name was. But we went to

12 see him and asked him whether that was true. And he was a lawyer by

13 profession, he was a civilian, but he worked --

14 Q. Mrs. Hrvacanin, I'm going to put the next bit to you and see if

15 you agree with this. He did look into the matter. He told you that on

16 the JNA pulling out of Slovenia, that a garrison from Ljubljana would move

17 to Zenica, and that did happen about two months later, under the command

18 of a colonel who later became a general, Tomislav Sipcic. Is that all

19 correct?

20 A. That is correct, but the army didn't pull out. It was forced out

21 of Slovenia.

22 Q. The -- did the arrival of the JNA from Slovenia, did that have any

23 effect on the feelings of the local Serb community in Zenica?

24 A. Yes. With the arrival of the JNA, the Serbs once again breathed a

25 sigh of relief because they thought that everything would be all right,

1 because our defender was there, our saviour was there, and everything

2 would be well.

3 Q. As you came to -- to observe it as best you could, were you

4 yourself satisfied and happy about the number of JNA soldiers who arrived

5 in Zenica from Slovenia?

6 A. As they had no logistics, that is to say they didn't have doctors,

7 dentists, I was called to the garrison to offer medical assistance to some

8 of the officers and people working there in need of medical care. What I

9 saw made me very frightened. Nothing was properly in order. Nothing was

10 in its proper place. It was all untidy, and it appeared to me as if that

11 garrison was going to move away in the near future, and that instilled

12 fear and unrest in me as well.

13 Q. Did you visit the garrison in Zenica after Colonel Sipcic had

14 arrived on Army Day, 22nd of December, 1991?

15 A. Yes. The more prominent people from political life and from the

16 authorities always for the 22nd of December, Army Day, were invited to

17 attend a traditional luncheon of beans in the garrison.

18 Q. Mrs. Hrvacanin, there was -- it doesn't matter whether there still

19 is, but there was at that time, wasn't there, a substantial steel mill in

20 Zenica?

21 A. There was a steel mill in Zenica, yes, and there was the Simmons

22 Martin Steelworks as well. Ironworks and steelworks. I worked there.

23 Q. And did the steelworks have its own territorial -- have its own

24 arms? Weapons I'm --

25 A. The steelworks had its territorial arms because -- territorial

1 weapons because they stretched over a piece of land which was 15

2 kilometres. It's an enormous area. They had their own security system,

3 and they had 17 entrance gates for their employees. It was a giant,

4 employing 23.000 workers. It's heavy metallurgy.

5 Q. Did you learn at any time in late 1991 or early 1992 of any

6 acquisition of arms by the Zenica steel mill?

7 A. I -- it is the ironworks of Zenica, or the term being used is

8 steel mill. Well, in 1991, we had no salaries or, rather, not regular

9 salaries. And when we did receive something, we would receive coupons

10 which would allow us to buy food and items of personal hygiene and

11 household goods.

12 I asked one of the directors of the internal bank, Mr. Martin

13 Janjevic, "When are we going to receive our salaries?" and he said, "We

14 have a lot of expenditure at the present. The ironworks had ordered

15 automatic rifles and when we pay for those automatic rifles, that's when

16 you'll receive your salaries." I wondered what we would need automatic

17 rifles for. I wasn't a man. I wasn't a soldier. And that was rather

18 strange.

19 Q. When did you first learn about this order of automatic rifles?

20 A. Secondhand. I heard that things like that were being bandied

21 about town, and I heard it for the first time from this gentleman, that it

22 would be procured and paid for. And the media published that afterwards

23 as well.

24 Q. [Previous translation continues] ... Mrs. Hrvacanin, I was asking

25 you when you first learned about that order.

1 A. I'm sorry, yes. I think it was the beginning -- or, rather, the

2 end of the summer and beginning of the autumn.

3 Q. Of 1991?

4 A. 1991.

5 Q. In the middle of 1991, in the summertime, around June or July

6 1991, did you notice any -- anything unusual or any change among the

7 people that you saw in your part of the city; Jalija, is it?

8 A. Yes.

9 Q. What did you see?

10 A. Well, I saw people cleaning, who were engaged in cleaning the

11 town, keeping it clean. And I saw in my neighbourhood six or seven people

12 there, which wasn't normal, because there was either one or none at all to

13 cater to that part of the town, just the garbagemen following the garbage

14 truck. And they were located there. And when I passed by I would usually

15 say, "Hello. Good morning. How are you?" That's what my parents taught

16 me to say. And I saw, judging by the way they spoke, that they didn't

17 speak our language very well. And then I became interested in finding out

18 who these people were, and I was told that they were people who had come

19 in from Kosovo and who the new utilities director had employed to keep the

20 town clean and that there were a number of them.

21 Later on, my knowledge was gained from people who, when I'd left

22 Zenica -- that is to say I learnt secondhand from others that these were

23 the cadres of the green -- future Green Berets, and the Patriotic League.

24 Q. Had -- had any men arrived at any point in 1991 that you were

25 aware of from Sandzak?

1 A. From Sandzak I don't know about that. I'm not aware of that. In

2 Sarajevo there were a number of people from Sandzak. Since I was doing my

3 oral surgery specialisation course there in Sarajevo and I saw that there

4 were lots of people from Sandzak coming in. But there was something else

5 that I noticed, actually, and it was this: In the drugstore where I make

6 my purchases, which is close to my flat, I saw foreigners buying there,

7 and they were paying in dollars. I had previously said that we ourselves

8 were not receiving salaries. It was an Upi market store and we had

9 coupons for that particular store and that's how I was able to buy my

10 goods.

11 I asked the woman working at the cashier's who these people were,

12 and she said --

13 Q. Excuse me. May I just interrupt you? You referred to foreigners.

14 Can you be more specific?

15 A. Well, I think they were Arabs.

16 Q. And you said you asked the woman who these -- the cashier -- the

17 cashier in the supermarket who these people were, and then I interrupted

18 you with that question.

19 A. Yes. The cashier said that they were foreign students, because

20 Zenica at that time had technical faculties, such as the faculty of

21 metallurgy, the faculty of electrical engineering, the faculty of law, and

22 so on, and that they had come in as students to study there. I found that

23 a little strange, because it was the end of November, beginning of

24 December. I was a student myself, and I know that studies usually begin

25 in October, not in --

1 Q. [Previous translation continues] ... did you -- were you able

2 subsequently to find out whether they were students or not?

3 A. Yes.

4 Q. And what did you discover?

5 A. My patient was Professor Sulejman Drljevic from the faculty. It

6 was a faculty within the frameworks of our ironworks at Zenica, and I

7 asked him what foreign students they had received just now, and he said,

8 "We haven't got any foreign students, Mrs. Hrvacanin, or not as far as I

9 know." And I asked him, "Are you aware of the fact that in town people

10 like that -- there are people like that in town?" And he said, "Well, I

11 did hear something about that." And although he was a Muslim, he was a

12 cosmopolitan, he was a man who didn't mind what religion you were or what

13 ethnic group you belonged to, just like me, and he said, "Perhaps they're

14 Mujahedin," and that was the first time I heard of the word Mujahedin.

15 Q. Did you, as president of the Zenica SDS, hold a regular press

16 conference at this time every Wednesday?

17 A. Yes.

18 Q. And did you raise this matter at a press conference?

19 A. Yes. I declared that and made that public at a press conference

20 and said that foreigners had arrived in Zenica, Mujahedin, because rumours

21 were already going round that a Patriotic League had been established.

22 Q. After you raised the matter at the press conference, did you

23 become aware of any change connected with these foreigners that you had

24 identified as Arabs?

25 A. Well, after a certain amount of time they disappeared from our

1 area. Perhaps I and a few other Serbs lived in that neighbourhood which

2 was otherwise an exclusively Muslim neighbourhood, so that they were

3 dislocated and moved to a neighbouring village which is called Sarici,

4 near Nemila, and that is a place which is about 15 kilometres away from

5 Zenica and the village is 30 kilometres away from Zenica, up in the

6 mountains.

7 MR. STEWART: Your Honour, I'm looking at the clock. I wonder if

8 that would be a convenient point for Your Honours to break.

9 JUDGE ORIE: It's a convenient time for a break. We will have a

10 break until five minutes to eleven.

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

12 --- On resuming at 11.02 a.m.

13 JUDGE ORIE: Please proceed, Mr. Stewart.

14 MR. STEWART: Thank you, Your Honour.

15 Q. Mrs. Hrvacanin --

16 MR. STEWART: Your Honours, I'm handing to the witness what's -- a

17 document that's been seen before in this court. May I ask for it to go

18 onto the ELMO. It's very familiar, Your Honour. It's the item that's

19 numbered 93. We'd chosen that as the particular example.

20 JUDGE ORIE: Yes. May it be put on the ELMO. My guess would not

21 being wrong if I was thinking about the 19th of December.

22 MR. STEWART: Your Honour would be really getting in the right

23 region.

24 Q. Mrs. Hrvacanin, are you able to see a document? I don't know

25 whether it would be more convenient for another copy to be available.

1 A. I can see the document but only --

2 Q. [Previous translation continues] ... just -- if you need --

3 A. Yes.

4 Q. -- to see the actual document at any point, Mrs. Hrvacanin, as

5 opposed to seeing it on the screen, please don't hesitate to say.

6 Now, Mrs. Hrvacanin, had you ever seen this document or a document

7 like it before you arrived in The Hague in the last few days?

8 A. No.

9 Q. Had you, before you arrived in The Hague -- and you arrived in The

10 Hague last Thursday night, didn't you? You arrived Thursday evening in

11 The Hague. That's right, isn't it?

12 A. Yes.

13 Q. Had you ever heard of a document known as Variants A and B?

14 A. No.

15 Q. Were you in Sarajevo at any time in late December 1991?

16 A. Yes.

17 Q. And can you say -- and I'm talking about the second half of

18 December 1991 now. Are you able to say on what dates you were in

19 Sarajevo?

20 A. I think it was the 19th, 20th, and the 21st when I was in

21 Sarajevo.

22 Q. And for what purpose were you in Sarajevo?

23 A. I think that the Assembly was in session that day, the Serb

24 Assembly. I wanted to attend that Assembly in the Assembly building. I

25 think that some important items were on the agenda. I found them

1 important; what the coat of arms would be and what the anthem would be in

2 the republic -- or, rather, this was on the agenda of the Serb Assembly.

3 Q. Now, can we just get a couple of things clear, Mrs. Hrvacanin.

4 You were not at any time a deputy in the Serb Assembly, were you?

5 A. No.

6 Q. On that -- that visit to Sarajevo, did you attend any meeting of

7 the SDS Main Board?

8 A. You mean the 19th?

9 Q. Yes, the visit that you've just referred to.

10 A. It wasn't only the Main Board. This was a bigger meeting.

11 Q. Mrs. Hrvacanin, if we can try and stick as specifically as

12 possible to my questions. On that visit to Sarajevo, did you attend a

13 meeting of the Main Board?

14 A. I don't know about the Main Board having a meeting on the 19th. I

15 was at the Assembly.

16 Q. It was open, was it, to you, although not a deputy in the Serb

17 Assembly, to attend Assembly meetings?

18 A. That's right. Mr. Krajisnik, who was president of the Assembly,

19 allowed people who wished to attend to attend; people from politics,

20 ministers, representatives of municipalities that did not have their own

21 MPs. He allowed them to attend the Assembly session.

22 Q. When you say "allowed," was it a -- in the nature of a courtesy

23 that Mr. Krajisnik should give permission or was there any question of

24 anybody being refused attendance at the Assembly meetings?

25 A. I think that Mr. Krajisnik is a democrat, and he never refused

1 anyone. At least, I'm not aware of him not allowing someone to attend

2 Assembly meetings. He never refused my requests, but I've never heard of

3 him refusing anybody's requests.

4 Q. So were there at that Assembly meeting -- was there quite a number

5 of people present who were not actually deputies in the Assembly?

6 A. Yes.

7 Q. And, first of all, in what building did the Assembly meeting take

8 place?

9 A. The session took place in the so-called Blue Hall of the

10 municipality building. It was the Assembly of the B and H.

11 Q. You said the -- the Blue Hall of the municipality building. Is

12 that a correct description of the building, the municipality building?

13 A. Assembly building, yes, Assembly building.

14 Q. And did that meeting take place in the morning or the afternoon?

15 A. From around 10.00 onwards. Until lunch, I think.

16 Q. And then the meeting ceased or broke for lunch, did it?

17 A. That's right.

18 Q. At a normal sort of time, around the middle of the day?

19 A. Yes.

20 Q. Did the meeting subsequently resume in the Blue Hall on that same

21 day?

22 A. No.

23 Q. Did you leave the Assembly building for lunch?

24 A. Yes.

25 Q. And where did you go?

1 A. The Holiday Inn.

2 Q. And you personally went to the Holiday Inn. Was that a general

3 move? Did all or a large number of the people at the meeting in the Blue

4 Hall go over to the Holiday Inn?

5 MR. TIEGER: Your Honour, this is -- I was waiting, but this is

6 clearly an area where I would ask counsel to refrain from leading

7 questions to the extent possible. A couple of the previous questions have

8 gone in that direction, so I --

9 JUDGE ORIE: Yes. You'd rather have the non-leading questions in

10 this portion of the examination-in-chief.

11 MR. TIEGER: That's right.

12 JUDGE ORIE: Mr. Stewart.

13 MR. STEWART: I have no problem with that. I'm obviously being

14 asked to be ultra-strict, and I will be.

15 JUDGE ORIE: Yes.

16 MR. STEWART:

17 Q. When you -- did you -- did you arrive at the Holiday Inn and have

18 lunch there yourself?

19 A. Yes.

20 Q. Did you lunch alone?

21 A. No. Everybody had lunch there.

22 Q. Did anybody who had -- as far as you knew, did anybody who had

23 been at the meeting in the blue room remain in the Assembly building when

24 you went over for lunch to the Holiday Inn?

25 A. No. I'm not aware of that.

1 Q. Was there any -- any sort of meeting that you were involved in at

2 the Holiday Inn before you had lunch?

3 A. Yes.

4 Q. What was that?

5 A. It was an expanded meeting. The members of the Main Board were

6 there, members of parliament were there, then some ministers were there,

7 and the representatives of some municipalities that did not have MPs of

8 their own.

9 Q. Mrs. Hrvacanin, may I just be -- be specific about this. I asked

10 you about before lunch. The expanded meeting, leaving aside for the

11 moment any details of that meeting, but the expanded meeting that you

12 referred to, that began before lunch, did it?

13 A. Yes. I think it was before lunch.

14 Q. Did it conclude before lunch?

15 A. Yes.

16 Q. How long did it last?

17 A. Perhaps two hours, perhaps less. I could not say exactly, but it

18 wasn't long.

19 Q. How far is it from the Assembly building to the Holiday Inn?

20 A. I don't know the exact distance, but I can tell you how much time

21 it takes to get there: Five minutes.

22 Q. Five minutes by what? What means of movement or transport?

23 A. By foot.

24 Q. Did you walk over?

25 A. Yes.

1 Q. Do you remember anything particularly about the day in question

2 when you walked over from one building to the other?

3 A. Well, I saw some people in the street wearing green berets, and I

4 asked some people, "What is this? Is this some new kind of police in

5 Sarajevo?" And nobody knew how to answer that question.

6 Q. Do you remember anything about the day itself, what sort of a day

7 it was?

8 A. It was pretty cold. It was windy.

9 Q. When you described the meeting as an expanded meeting, where

10 exactly did it take place?

11 A. The meeting took place in the Congress hall of the Holiday Inn.

12 Q. What sort of size room is that? Is it -- is it bigger than this

13 courtroom?

14 A. A bit. Just a little bit bigger. Perhaps it's just a bit longer,

15 and narrower on the other hand.

16 MR. STEWART: I don't know whether we need to record the

17 measurements of this courtroom, Your Honour. We're in the very large

18 courtroom III this morning.

19 JUDGE ORIE: We are, Mr. Stewart.

20 MR. STEWART:

21 Q. Was it -- was the expanded meeting a -- whoever was there, was it

22 officially a meeting of some specific organ of the SDS?

23 A. No. It was a spontaneous meeting, because there were things going

24 on and the deputies had a discussion. I think that this was the time when

25 the platform on the independence of Bosnia and Herzegovina was being

1 prepared. I think that at the same time Mr. Silajdzic attended some

2 Congress of Islamic countries where he presented certain views that caused

3 concern among the Serbs.

4 Q. How many people were at the expanded meeting?

5 A. I think over 200.

6 Q. And could you -- you gave some -- some description of who were

7 there. You said members of the Main Board, members of parliament,

8 ministers, representatives of some municipalities. Any other categories

9 of person who were present at that meeting?

10 A. Well, perhaps drivers of some ministers and technical staff that

11 was there to provide their services if necessary, if somebody needed a

12 telephone or whatever. There was no one else.

13 Q. In what capacity did you regard yourself as attending that

14 expanded meeting?

15 A. Well, I was there as a member of the Main Board.

16 Q. Are you able to say how many municipality presidents were present

17 at the meeting?

18 A. A few, a small number. These were municipalities that did not

19 have MPs of their own.

20 Q. How -- how familiar were you with the municipality presidents for

21 the SDS throughout Bosnia? That's to say did you -- what proportion of

22 them did you know personally?

23 A. I knew some well and others I knew only by sight and with some I

24 was actually friends.

25 Q. Would you -- would you be able to say whether there was any

1 particular category of municipality which was better represented at the

2 meeting than others?

3 A. No. No one was represented in particular.

4 Q. Who presided over that meeting?

5 A. The president, Mr. Radovan Karadzic.

6 Q. And can you remember who else of the senior figures in the SDS

7 were present?

8 A. Mr. Velibor Ostojic was present, Mr. Rajko Dukic, Mrs. Plavsic,

9 Mr. Koljevic.

10 Q. Was Mr. Krajisnik there?

11 A. Yes, Mr. Krajisnik was present, too, but he was not chairing the

12 meeting.

13 Q. From -- can you describe where Dr. Karadzic stood and what sort of

14 furniture he was working with when he presided over the meeting?

15 A. Mr. Karadzic was sitting there. It was like the Honourable Judges

16 are sitting today. So that was the group of people who were chairing the

17 meeting. And opposite them were the members of the Main Board, the

18 Executive Board, the MPs, and the other guests on chairs, and there was a

19 rostrum on the other side where the lady tells us that the session is

20 adjourned.

21 Q. Was Mr. Karadzic -- did he have other senior figures of the SDS

22 seated close to him?

23 A. Yes. I've mentioned it was Mr. Dukic, and Mr. Ostojic,

24 Mr. Koljevic, and Mrs. Plavsic.

25 Q. And they sat with him at some sort of table, did they?

1 A. They were chairing the meeting. They were sitting at the

2 chairman's table.

3 Q. Was Mr. Krajisnik sitting at the chairman's table?

4 A. No. He sat where the rest of us sat, in the first row.

5 Q. Did you know Mr. Miroslav Deronjic at that time?

6 A. Just by sight as a member of the Main Board from Bratunac.

7 Q. Was he at the meeting?

8 A. I don't think so.

9 Q. Did you know Mr. Radomir Neskovic at that time?

10 A. Yes. He's a founder of the Serb Democratic Party. He was

11 present.

12 Q. Did you -- did you know Mr. Neskovic more or less well than you

13 knew Mr. Deronjic?

14 A. Yes. I knew Mr. Neskovic better. As a matter of fact, he was a

15 guest in my house. When he needed something, I was always there to help

16 him; money, cigarettes, spending the night, things like that.

17 Q. And is it correct you still have a personal relationship with

18 Mr. Neskovic?

19 A. Yes. He lives in Banja Luka. We see each other. We talk.

20 Q. Does he still come to your home at times?

21 A. No. We see each other at a hotel.

22 Q. What was -- can you remember what was the topic, if there was one,

23 of discussion at that expanded meeting?

24 A. I've said that the entire political situation was very heated. I

25 know that Muslims were making certain decisions, and after that it was

1 inevitable for the Serb MPs to leave the Assembly. They left the

2 Assembly, and they formed an Assembly of their own. It was this

3 declaration that was being discussed. People were worried. By the very

4 recognition of the independence of Bosnia-Herzegovina, would the Serbs be

5 in a position to be out-voted all the time, and what would the position of

6 the Serb population be in Bosnia-Herzegovina?

7 Q. Are you -- do you know of any other similar size meeting that took

8 place in the Holiday Inn in December 1991 relating to the SDS?

9 A. No.

10 Q. Is it possible that such a meeting was held without your having

11 known about it?

12 A. I think that that would not be possible. Knowing myself, I think

13 that they could not hide something like that from me.

14 Q. Broadly speaking, Mrs. Hrvacanin, what sort of contacts and

15 relations did you have in December 1991 with active SDS members around

16 Bosnia and Herzegovina?

17 A. Well, at that time the SDS Assembly was being prepared. Sorry,

18 were you asking about 1991?

19 Q. Yes. I was asking specifically about December 1991.

20 A. Specifically I did not have any particular duties. It's not that

21 I had to do something for the SDS somewhere in Bosnia-Herzegovina.

22 Q. Mrs. Hrvacanin, there are, for example, people who just keep

23 themselves to themselves. They get on with their job, they come to the

24 meeting, they go home, they don't talk to anybody, they don't socialise.

25 There are people like that. Are you that sort of person?

1 A. I'm having some trouble with my headsets. I didn't hear your

2 question at all.

3 JUDGE ORIE: I think if you put the ...

4 THE WITNESS: [Interpretation] Thank you. It's too wide. It

5 doesn't cover my ears.

6 Your Honour, could that question be repeated? I wasn't able to

7 hear it.

8 MR. STEWART: I'll just read it off the transcript, Your Honour,

9 shall I, and then it will come exactly the same.

10 JUDGE ORIE: Please do so.

11 MR. STEWART:

12 Q. Mrs. Hrvacanin, there are, for example, people who just keep

13 themselves to themselves. They get on with their job, they come to a

14 meeting, they go home, they don't talk to anybody, they don't socialise.

15 There are people like that. Are you that sort of person?

16 A. No. I like socialising and talking to people, because you learn a

17 lot talking to people.

18 Q. Mr. Deronjic told this Court, specifically this Trial Chamber,

19 that at a meeting that took place around these dates in December 1991 a

20 document of the nature of the documents that you have been shown a few

21 minutes ago was made available to participants in that meeting. Casting

22 your mind back as best you can, could Mr. Deronjic be right about that?

23 A. I said I wasn't sure whether Mr. Deronjic was at that meeting at

24 all. And the meeting that I attended no document was passed around, or a

25 document with that type of heading that I can see on the monitor, on the

1 screen.

2 Q. Mr. Neskovic described a meeting.

3 MR. STEWART: This, Your Honour, is at page 16647 of the

4 transcript on Monday, the 18th of July. Your Honour, we have prepared a

5 copy of batches of transcripts for anybody that needs them.

6 JUDGE ORIE: It has already been distributed among the Judges. I

7 don't know whether there's anyone else who is in need of it.

8 MR. STEWART: That's the position, Your Honour. We have copies

9 for anybody who needs one. All they need to do is speak and they can have

10 one. Otherwise I'll just continue.

11 Q. At page 16647, Mr. Neskovic was shown basically the same document,

12 dated 19 December, even if it wasn't exactly the same copy. He said he

13 was familiar with it, and then he went on to describe a meeting at the

14 Holiday Inn. He said: "... so I think it wasn't a meeting of a body but

15 a kind of -- almost a parliamentary meeting, which would be a meeting to

16 which all members of the Main Board, the Executive Committee, all MPs and

17 all municipal officials, members of the government, the political

18 committee, secretaries and everybody would be invited to. It's a huge

19 meeting. In the Serb culture, you would tend to convene such a meeting on

20 solemn occasions. Anyway, that was the make-up of the meeting. So there

21 was the Main Board with 45 members. It wasn't a separate meeting for the

22 Main Board ..."

23 Now, just stopping there, Mrs. Hrvacanin, so far would that

24 description of a meeting given by Mr. Neskovic fit the meeting that you

25 attended that you have just described?

1 A. Partially. Not all the presidents of the municipalities were

2 there, and they couldn't have fitted into that hall.

3 Q. Did you -- when you say presidents of municipalities, of course

4 you mean SDS presidents of municipalities. That's correct, isn't it?

5 A. No, no. I mean the presidents of the municipalities in the

6 executive powers, the executive authorities, not presidents of the SDS.

7 You had the Main Board, the Executive Board, you had the ministers, you

8 had certain presidents of the municipalities, and popular deputies,

9 national deputies.

10 Q. I just want to try and clear up one thing, Mrs. Hrvacanin. When

11 we're talking about presidents of municipalities, we're not talking about

12 Muslims or Croats here, are we? We're talking about Serb presidents of

13 the SDS in their own municipalities; is that correct?

14 A. Well, no, it wasn't the representatives of the SDS. There was the

15 Main Board there, and I just happened to have been a member who was

16 president of the SDS and a member of the Main Board as well, but that

17 wasn't usual. I don't know that there was anybody else who was president

18 of the SDS who was in the Main Board except President Karadzic, who was

19 the presiding officer of the Main Board.

20 MR. STEWART: Your Honour, I think we're at cross-purposes but I'm

21 going to proceed.

22 Q. The -- you mentioned a difference. Otherwise, does the

23 description of a meeting given by Mr. Neskovic as I've just read it out to

24 you, does it match the meeting that you attended as you've described?

25 A. Roughly speaking, yes.

1 Q. And what Mr. Neskovic then went on to say - and this is the foot

2 of page 16647 - he said: "As far as I can remember, this document -" and

3 he's talking, for practical purposes, about the one that you were shown

4 about ten or 15 minutes ago - "this document is something that Karadzic

5 brought into the meeting room, and it had already been completed, printed

6 out. It was in a package, as it were, and in this present form, and he

7 simply put it on the table where the working Presidency was."

8 Do you remember anything like that, Mrs. Hrvacanin?

9 A. No. Mr. Karadzic was usually late to meetings. He never carried

10 any documents with him, nor were any documents or material of that kind

11 present in that Congress hall.

12 Q. And then Mr. Neskovic said: "And I was sitting in the fifth or

13 sixth row ..." Do you have any comment on that?

14 A. He would never have sat in the fifth or sixth row. He would

15 always sit in the front row, the first row, because he was in the

16 Executive Board of the party.

17 JUDGE ORIE: Mr. Tieger.

18 MR. TIEGER: Yes, Your Honour. I had previously raised concerns

19 about leading questions. It seems to me that a standard and conventional

20 approach would be to ask the witness for her observations and

21 recollections of an event.

22 JUDGE ORIE: Who was seated where and --

23 MR. TIEGER: Right. This is taking the form of precisely the

24 concern I voiced earlier and I would object to this particular use of

25 prior testimony.

1 JUDGE ORIE: Mr. Stewart, Mr. Tieger invites you not to put your

2 questions leading more or less on the basis of the testimony of

3 Mr. Neskovic but, rather, ask the witness what she observed at the time.

4 MR. STEWART: Well, of course, Your Honour. I indicated that I

5 will respond to any such request and of course I will do that.

6 JUDGE ORIE: Please proceed.

7 MR. STEWART:

8 Q. At the meeting that you attended, first of all, how was the --

9 you've described briefly, but how was the room laid out by way of seating,

10 rows of chairs, or whatever? What was the layout? Please describe.

11 A. The hall had a rostrum for the presiding people, and then in a

12 semi -- the chairs were placed in a semicircle, and when you entered the

13 hall, on the right-hand side were chairs in a semicircle. I think there

14 were about ten to 15 rows of chairs on both sides. Some people always

15 liked siting in the front row, although by rights they shouldn't have sat

16 there, but all this was televised so they liked to see themselves on

17 television and would sit in the front row.

18 Mr. Neskovic sat in the front row, I was sitting to the side, and

19 I was able to see exactly where who was sitting. He was present. There

20 was no material, no documents, and no documents were handed out in that

21 hall. Had they been, I would certainly have been given a copy myself.

22 It was a spontaneous meeting and certain positions were taken --

23 but actually the positions were not taken. It didn't come to that because

24 the people were hungry, so the meeting lasted for a very brief period. I

25 said between one and two hours, perhaps a little shorter.

1 Q. Was this particular meeting televised?

2 A. Well, the media would come and cover it. I don't know if it was

3 televised, whether a television crew was there or not, but usually they

4 followed all our meetings. So that one, too, probably was, although I

5 can't actually say for sure.

6 Q. Did anybody bring any significant -- Mrs. Hrvacanin, I'm going to

7 assume that everybody had bits of paper or many people had bits of paper

8 for a meeting, but did anybody bring any significant quantities of

9 documents into the meeting?

10 A. No. I didn't see anything like that, nor did anybody bring

11 anything like that in because that would have been noticeable.

12 Q. At any point in the meeting did anybody from the body of the

13 audience go up to the top table?

14 A. No. No. While the meeting was going on, nobody went up to the

15 top table nor did they do so after the meeting. They all went off to

16 lunch.

17 Q. Was there any point in the meeting at which anybody went through

18 or called out names in sequence?

19 A. No. I don't know why their names would be called out.

20 Q. Well, I'm going to put specifically to you now, Mrs. Hrvacanin,

21 what has been said.

22 JUDGE ORIE: Before you do so, Mr. Stewart, Judge Hanoteau would

23 like to ask a question to the witness.

24 JUDGE HANOTEAU: [Interpretation] Yes. Madam Hrvacanin, you said

25 several times that it was a spontaneous meeting. Could you say exactly

1 what you mean by "spontaneous."

2 THE WITNESS: [Interpretation] That was the usual term that we use

3 when something wasn't planned or foreseen in advance. That's why I called

4 it spontaneous, that it came up of its own accord. And that's how that

5 particular meeting came about. Somebody made the suggestion while we were

6 in the Assembly that it would be a good idea to discuss matters in another

7 place, to discuss some vital political issues, such as the declaration,

8 for example, on the recognition of Bosnia-Herzegovina, because it was a

9 premises shared by the Muslims, Croats, and Serbs, and each club had his

10 own -- its own premises to avoid being listened into. And as the Serbs

11 tend to speak loudly, we said, "Let's go somewhere else which is safer and

12 more secure." And we thought that a hotel is always the least secure

13 place. At least, I think so.

14 JUDGE HANOTEAU: [Interpretation] So all those who participated to

15 that meeting in the Holiday Inn were already in the Assembly prior to

16 that.

17 THE WITNESS: [Interpretation] Yes. Most of them. With the

18 exception of Mr. Karadzic. I think he came later. He wasn't at the

19 Assembly.

20 JUDGE HANOTEAU: [Interpretation] So it means that Mr. Karadzic was

21 told that the decision had been made and was asked to come into the

22 meeting?

23 THE WITNESS: [Interpretation] Probably, but I don't know about

24 that.

25 JUDGE HANOTEAU: [Interpretation] So --

1 THE WITNESS: [Interpretation] I'm not getting the interpretation.

2 JUDGE HANOTEAU: [Interpretation] My question is the following:

3 Was Mr. Karadzic at the Assembly in the morning? Was he attending?

4 THE WITNESS: [Interpretation] I didn't see him.

5 JUDGE HANOTEAU: [Interpretation] So you're saying that he arrived

6 at the Holiday Inn. He was coming from the outside. What did you feel

7 that -- you know, what did you -- how did you feel about where he was

8 coming from?

9 A. Well, I can't say exactly where somebody had come from, in this

10 case Mr. Karadzic, but I can only assume that he was just taken up with

11 other business elsewhere and then joined in at somebody's invitation. But

12 Mrs. Plavsic was certainly there, and so was Mr. Koljevic.

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

14 JUDGE ORIE: Just a clarification. The transcript reads that,

15 where you said that Serbs tend to speak loudly, that you said, "Let's go

16 somewhere else which is safer and more secure. We thought that the hotel

17 was the least secure place, at least I think so."

18 Now, you moved from your Assembly meeting to a hotel because you

19 wanted to keep it private, and at the same time you say a hotel was the

20 least safe place. How should I interpret that?

21 THE WITNESS: [Interpretation] We first of all went to the hotel to

22 have lunch, and then what happened was, as I explained it, that

23 spontaneous meeting.

24 JUDGE ORIE: Did you say that that suggestion was made at the

25 Assembly meeting, but let me just check your testimony in this respect.

1 You said -- I have to find it. "Somebody made the suggestion while we

2 were in the Assembly that it would be a good idea to discuss matters in

3 another place."

4 So where you now say that you went to the --

5 THE WITNESS: [Interpretation] That's right.

6 JUDGE ORIE: [Previous translation continues] ... and that in the

7 hotel, as you said, "We all went to the hotel to have lunch and then what

8 happened, as I explained, that spontaneous meeting," whereas your

9 testimony earlier said that someone in the Assembly said to have another

10 meeting. So I still have some difficulties in reconciling the various

11 answers you gave, one of them being that you wanted to go to a safer place

12 and that a hotel was the least safe place.

13 When I asked you how I should interpret that, you told this

14 Chamber that actually you went to the hotel and then the idea of a

15 spontaneous meeting came up, but in one of your earlier answers you said

16 that it was during the Assembly meeting that someone suggested to go to

17 another place. So now there are three answers to be reconciled. Could

18 you help me out.

19 THE WITNESS: [Interpretation] With your permission, what is

20 correct is this: It is correct that in the Assembly it was stated that a

21 position should be taken with respect to the declaration on

22 Bosnia-Herzegovina's independence, not only the deputies but the members

23 of the Main Board, the Executive Board, and that that is something that

24 should be done.

25 Now, since you're not clear on what I said, I said I think, I

1 didn't say that this was the general view, somebody made a general

2 assessment to the effect that it was safer in the hotel and that it should

3 take place there rather than in the Assembly, but I was not of that

4 opinion. I have my own opinion and my own position. So I said that that

5 was my opinion. I didn't say that that's what other people thought. If I

6 came across that way, I don't know, but I hope I'm being clear now.

7 JUDGE ORIE: You used the words, "We said let's go somewhere else

8 which is safer and more secure," and then the text is not quite clear,

9 although the word "we" clearly appears. "We thought that the hotel was

10 the least secure place."

11 So but one thing now is for certain, if I understand you well,

12 that the decision to discuss the matter somewhere else was taken at the

13 Assembly meeting. It was suggested, at least, at the Assembly meeting to

14 discuss the matter somewhere else.

15 A. Yes.

16 MR. STEWART: Your Honour, may I remark, Your Honour?

17 JUDGE ORIE: Yes.

18 MR. STEWART: When Your Honour put to the witness, Your Honour

19 said the text is not quite clear, the "we" clearly appears.

20 JUDGE ORIE: Well, one "we" is not entirely clear to me.

21 MR. STEWART: Well, Your Honour, it's just that what the witness

22 actually said was, "We thought that the hotel was the least secure place.

23 At least, I think so." And, Your Honour, a sentence which is presented in

24 those terms I would suggest needs to be treated with some care, Your

25 Honour, when questions are put to the witness, because the -- well, I'd --

1 JUDGE ORIE: I --

2 MR. STEWART: The word "I" is important there, Your Honour.

3 JUDGE ORIE: I was quoting from page 51. At the end it says so,

4 "At least, I think so."

5 MR. STEWART: My suggestion is only, Your Honour, that a quote is

6 better as a quote rather than a paraphrase, that's all, Your Honour.

7 JUDGE ORIE: It makes it even more mysterious because your

8 testimony was, when you said, "We thought that the hotel was the least

9 secure place. At least, I think so," I now do understand that -- so what

10 you actually said at page 51 is that you disagreed with the hotel being a

11 safer place.

12 THE WITNESS: [Interpretation] Nobody asked me whether I agreed or

13 didn't agree. Since I saw the Green Berets on the way, then I came to

14 that democratic opinion myself, that it wasn't safe there. I myself came

15 to that decision, but I didn't tell anybody that. I'm telling you that

16 now.

17 JUDGE ORIE: Yes. But your fear, as you explained to us, was

18 being overheard, not being attacked by Green Berets, was it?

19 THE WITNESS: [Interpretation] Both.

20 JUDGE ORIE: But your answer that only in the hotel where you went

21 for lunch that you spontaneously decided to have a meeting, you withdraw

22 that in view of your last answers?

23 THE WITNESS: [Interpretation] I apologise, but I'm not sure I

24 followed you.

25 JUDGE ORIE: Earlier when I asked you to help me interpreting or

1 to reconcile some answers you gave, one of your answers was that you went

2 to the hotel for lunch, and it was then that you -- that it was suggested

3 to have a meeting, but now you tell us that it was already at the Assembly

4 meeting that this was suggested and decided. So therefore the answer that

5 it was spontaneously suggested once you had gone to the hotel for lunch,

6 is that answer withdrawn --

7 MR. STEWART: Your Honour, might I simply ask for the reference

8 there to that point? I'm not following that. I'd be grateful to know the

9 reference to that point.

10 JUDGE ORIE: Yes. I was referring to page 52, where the witness

11 said -- I asked her: "Now you moved from the Assembly meeting to a hotel

12 because you wanted to keep it private, and at the same time you say a

13 hotel was the least safe place. How should I interpret that?" And then

14 the witness said: "We first of all went to the hotel to have lunch and

15 then what happened was, as I explained it, that spontaneous meeting." So

16 there she puts going to the hotel prior to what she calls a spontaneous

17 meeting. And in view of the specific question I put to her, I understood

18 that answer to be that the spontaneous idea came up when they went or had

19 gone to the hotel to have lunch.

20 MR. STEWART: Your Honour, might I respectfully suggest that

21 that's reading into the answer rather more than it will bear?

22 JUDGE ORIE: That's on the record, Mr. Stewart. Please proceed.

23 MR. STEWART:

24 Q. Mrs. Hrvacanin, was there -- was there some specific concern about

25 security expressed by anybody at the Assembly meeting, the one that you

1 describe as being in the blue room?

2 A. Yes. During the discussion everybody expressed great concern for

3 the overall political situation that prevailed in Bosnia-Herzegovina, and

4 from those discussions - but that wasn't the conclusion, that wasn't a

5 conclusion - that there should be an expanded meeting, but that wasn't the

6 conclusion of the Assembly. It was just something that became apparent on

7 the basis of the discussions being held. And when we went to the hotel,

8 this came about spontaneously.

9 Q. Mrs. Hrvacanin, was there -- was there anything said at the

10 Assembly meeting about specific ways in which that meeting might not be

11 secure?

12 A. No, no one said that.

13 Q. What type of security was the concern? Was it physical security?

14 I'm talking about the Assembly meeting in the blue room now.

15 A. During communism, all anti-communists had their conversations

16 bugged, and this probably left an impression on all the MPs and everybody

17 else who was present there that somebody might be listening in. I don't

18 see any other reason why this couldn't be held there except for the fact

19 that it was lunch break anyway, so we could go and have lunch and clarify

20 these matters along the way, things that were not clear, that is.

21 Q. Did anybody at the Assembly meeting make any reference to bugging?

22 A. No. It was just the deputies who were saying that. "We're being

23 bugged," et cetera. The SDA hall was nearby, and they thought, well, it's

24 better for to go somewhere else and talk somewhere else.

25 Q. When you say the SDA hall was nearby, was it --

1 A. Sorry; the club of SDA deputies.

2 Q. Was nearby you said. Is that just -- I'll just clarify. You're

3 saying the club of SDA deputies was nearby. Is that what you're saying,

4 first?

5 A. Yes, that's what I meant, because it's all in the same area; one

6 hall, the other hall, the third hall. You see, it would not be very easy

7 for me to give you the exact layout now.

8 Q. Was it -- was it in the same or a different building?

9 A. The same building.

10 Q. Was -- had -- when you held the Assembly meeting in the blue room,

11 was it -- was it already known and arranged that you would be going to the

12 Holiday Inn for lunch?

13 A. No. It was already known that we would go to the Holiday Inn to

14 have lunch, but it wasn't known that we would have a meeting, because that

15 had not been arranged earlier on.

16 Q. So I am now going to put to you, unless there is some objection, a

17 passage from Mr. Neskovic's evidence at page 16648. It's line 10,

18 beginning: "Anyway, he would --"

19 MR. TIEGER: I haven't looked at the particular passage and maybe

20 -- and I appreciate the reference. Maybe it isn't necessary to do so, by

21 think I have a more general objection, and that is once -- I mean, I've

22 sought to have a process whereby the witness relates her recollection. It

23 seems to me that any comparison between that account and the accounts of

24 other witnesses is best done by the Court not by individual witnesses

25 offering their impression of --

1 JUDGE ORIE: It's, although very practical for the Court to know

2 what Mr. Stewart has in the back of his mind if he puts questions to the

3 witness which, at least in his thought, are related to the question he

4 puts to the witness, there are, however, other ways of doing that,

5 although I would not expect the witness to have learned by heart all the

6 numbers of the -- before of course there is a possibility.

7 Mr. Stewart, if you'd just put the questions to the witness. You

8 have mentioned the page by now. We have that in our mind, and if you say

9 three forwards or three backwards, then we'll know what to orient

10 ourselves on.

11 MR. STEWART: Thank you, Your Honour. May I just say that the --

12 what I'm proposing to do, and I'm not proposing to do it at inordinate

13 length, but after all, when the Prosecution present their case the Defence

14 will cross-examine -- or has cross-examined Prosecution witnesses by

15 putting its case on specific matters to Prosecution witnesses. In this

16 area, Your Honour, in this really rather important area of the case, to

17 put to a Defence witness very specifically after I have dealt with the

18 point in a non-leading way what a Prosecution witness has put is an

19 appropriate course, I suggest, and that's --

20 JUDGE ORIE: Mr. Tieger, if the subject matter is a subject matter

21 dealt with already in examination-in-chief in a non-leading way, then I

22 take it that you do not oppose against confronting the witness with

23 testimony given in this courtroom which is different from her testimony

24 and to verify whether she sticks to her memory of the occasion.

25 MR. TIEGER: May I make a general point and I think it's one I'd

1 prefer to make without the witness overhearing it. So if she doesn't

2 speak English, perhaps she could remove her --

3 JUDGE ORIE: I don't know whether this witness speaks any English.

4 From what I know is that the dentistry books are very often -- at least,

5 in many countries foreign books are used.

6 MR. STEWART: I should tell Your Honours and Mr. Tieger through

7 Your Honours the witness does have some understanding so that she's not

8 one of the witnesses in the case to whom it's simply a foreign language

9 that means nothing.

10 JUDGE ORIE: Yes. Mr. Tieger, if the matter is such that you say

11 there's a need to raise this general matter apart from what we just

12 discussed right away, we'll ask the witness to leave for a second. If you

13 say we can wait until the next break, then we'll wait.

14 MR. TIEGER: Well, the point needs to be made now. I may be

15 over-cautious in seeking to have the witness leave, but I think on such

16 matters, since this seems to be the first time we've addressed this

17 particular issue, perhaps that caution is warranted.

18 MR. STEWART: Your Honour, I would suggest that's entirely

19 reasonable, Your Honour. We've done it before and that does, from what I

20 know about the witness's English, that's fair.

21 JUDGE ORIE: If you say I'd rather have the witness to leave for a

22 second, then we'll ask Madam Usher.

23 MR. TIEGER: Thank you, Your Honour.

24 JUDGE ORIE: Mrs. Hrvacanin, there is a procedural issue that the

25 Prosecution would like to raise in your absence, so we ask you to remain

1 standby but to leave the courtroom for a moment.

2 THE WITNESS: [Interpretation] Thank you.

3 [The witness stands down]

4 JUDGE ORIE: Please, Mr. Tieger.

5 MR. TIEGER: Your Honour, my concern is simply this, and it may

6 well be one that the Defence agrees with and was built into the

7 questioning inadvertently: It is that the specific subject matter of the

8 testimony that's being raised should not be linked to particular witnesses

9 by name. That's an entirely different issue that asks or that invites the

10 witness to consider an extraneous element. If we're asking the witness to

11 opine on facts is one thing. To link it to a particular witness, and

12 surely some witnesses will have views about some previous witnesses, is,

13 in my submission, inappropriate.

14 JUDGE ORIE: Let's check whether it was inadvertently done or

15 whether the response is not --

16 MR. STEWART: No, it wasn't inadvertent Your Honour. No, it

17 wasn't. It was absolutely specific, Your Honour. Our submission is the

18 precise opposite, that it is -- it is only fair and only correct to all

19 concerned that when such a matter is put to the witness -- and clearly

20 what I -- what I'm wishing to do, Your Honour, is in fact not leave it -

21 and I hope Your Honours won't misunderstand this - but not simply leave it

22 for Your Honours to put this evidence alongside that evidence, but on

23 these critical points to have it absolutely clear whether this witness

24 says that what has previously been said in this case is in her evidence

25 simply not right and to have it specific. And it's only fair to all

1 concerned that the witness should know who it is that said it, who they

2 are, what part they have in the party, where they're coming from, what

3 they would know, because after all, if she knows nothing except -- she

4 doesn't know, if I put something to her with no identification of a

5 witness, she doesn't know whether it's some casual remark made by some

6 witness that doesn't know anything about it or some remark made by

7 somebody with a -- in the case of Mr. Neskovic, a really quite important

8 position in the party, because after all, that's inviting the witness to

9 consider carefully, implicitly, whether she might be wrong and recognise

10 the authority of that person, and if, notwithstanding what she would know

11 about the authority of the person, she says it's not true, that is

12 relevant to the force of the evidence all round.

13 JUDGE ORIE: Mr. Tieger, before I give you an opportunity to

14 answer, I would like to add one question. If the Defence would have put

15 to the witness that a witness testified that he had been sitting on the

16 fifth or the sixth row of that meeting, wouldn't it be true that the

17 witness would have had no opportunity to comment on Mr. Neskovic never

18 sitting in the fifth or the sixth row because he wanted to be televised. I

19 mean, that would be a part of the testimony that would have been lost if

20 Mr. Stewart had not confronted the witness with that information.

21 I include that as a question and give you now an opportunity to

22 answer to the position taken by Mr. Stewart.

23 MR. TIEGER: First of all, Your Honour, I accept that there maybe

24 limited situations in which linking the testimony to a particular person

25 may be appropriate, and this may be one. Forgive me if I haven't studied

1 the Court's example well enough. As a general matter, however, I think

2 the flaw of the argument lies in precisely what my learned friend has just

3 indicated. First of all, his initial focus was on what has previously

4 been said by a witness. That should be the focus of the next witness's

5 testimony, not who said it. And he went on to focus on the extent to

6 which the witness's response and recollection might be influenced by an

7 understanding of where -- of who actually said that. And I think the

8 Court can see where that might be going. It's a matter of, when you

9 consider the factors that may be implicated by that, whether or not the

10 witness's relationship with that person, whether it's favourable or

11 unfavourable, the witness's understanding of that person's relationship to

12 Mr. Krajisnik, the witness's understanding of the general tenor of the

13 witness's testimony in this courtroom vis-a-vis Mr. Krajisnik, I think the

14 opportunity for inviting the witness's recollection and comparison to be

15 influenced by the person who said it rather than the substance of what was

16 said makes that an appropriate way to proceed.

17 [Trial Chamber confers]

18 JUDGE ORIE: Mr. Tieger, the questions put by the Defence, even

19 where it was clear to the Court that it was an exercise to verify earlier

20 testimony such as did anyone stand up are solicited -- the testimony is

21 solicited from the witness in a non-leading way, so therefore, in general

22 terms Mr. Stewart could not be blamed for just putting witnesses by their

23 name to this witness and saying, "Is that correct; yes or no?" The

24 appropriate way of doing it, in the view of this Court, would be to first

25 solicit the testimony by asking what the witness observed at that time, at

1 that occasion, without any reference to earlier testimony in this court.

2 Second step could be, if there's inconsistency with it, with the

3 testimony of this witness with evidence given earlier in this courtroom,

4 to confront the witness with that evidence without at that moment giving

5 the personal details of the witness who gave that evidence, and if the

6 inconsistency continues to exist, then, finally, Mr. Stewart is allowed to

7 put to the witness that that testimony was given by this and this witness

8 so that the witness has an opportunity, finally, to tell us that the

9 witness was therefore already at that time or was treated for bad sight,

10 whatever, so the witness is in a position to further clarify what might

11 have caused the inconsistency by having full detail of the source of that

12 evidence.

13 Then we can continue. I think it's clear to both Mr. Stewart, to

14 you and to Mr. Tieger, what the Court expects the Defence to do.

15 MR. STEWART: Well, thank you, Your Honour. That is most clear

16 and helpful.

17 JUDGE ORIE: I see that the witness not fully reflects the

18 reference to being deaf and, to say it more bluntly, being blind.

19 [The witness entered court]

20 JUDGE ORIE: Thank you. Thank you for your patience,

21 Mrs. Hrvacanin.

22 Mr. Stewart, you may proceed.

23 MR. STEWART: Just give me one moment, Your Honour I just want to

24 -- yes. Excuse me, Your Honour. I was wanting to best implement Your

25 Honour's guidelines in the light of any water that's already flowed under

1 the bridge, that was all.

2 Q. Mrs. Hrvacanin, this Court has heard a quite detailed description

3 on another occasion during this trial of names being called out at an

4 expanded meeting in the Holiday Inn, a meeting it was said presided over

5 by Dr. Karadzic. Names being called out, individuals would respond then

6 to their names by going up to the table, taking a copy of that Variant A

7 and B document under apparent request or instructions to read it, that

8 they were asked to give the document back. Did anything like that happen,

9 anything at all like that happen at the expanded meeting that you have

10 mentioned in your evidence?

11 A. There was no such thing at that meeting, because if 200 people

12 were present there, if they would all take one minute, it would be 200

13 minutes, and that would require over three hours. I already told you that

14 it was a very short meeting, between an hour and a half and two. I cannot

15 say whether it was one and a half hours or one hour and 45 minutes.

16 Nobody was given any document, and nobody had their names called out, and

17 I state that with full responsibility.

18 Q. On what floor of the Holiday Inn was the meeting that you've

19 described?

20 A. I think it was on the first floor.

21 Q. Now, the description which I put to you a few moments ago which

22 had come from another source in this case was in fact given to the Court

23 by a Mr. Radomir Neskovic in the course of his evidence. Knowing that

24 there was a description by Mr. Neskovic of such a distribution at an

25 expanded meeting in the Holiday Inn in late December 1991, does that move

1 you to reconsider any answer that you have given to the Trial Chamber this

2 morning?

3 A. I stand by my answer that no such thing was handed out in the

4 Holiday Inn, nor were any names called out, nor did anybody receive that

5 kind of document. It is my very nature and also in view of my profession

6 I always like to have things spelled out exactly, so perhaps I would have

7 preferred that kind of document, but there was no such thing.

8 Q. Is it -- is it realistically possible that Mr. Neskovic,

9 Mr. Radomir Neskovic, could have attended a completely different meeting

10 from the one that you've described in December 1991 but that you would

11 have learnt nothing at all of that other meeting?

12 A. I don't think so.

13 Q. Have you ever heard anything at all about any other such meeting

14 in late December 1991 in the Holiday Inn?

15 A. No, never.

16 Q. How many times, roughly, could you say you have spoken to

17 Mr. Neskovic since December 1991?

18 A. Very often. Whenever he came to Sarajevo, or he would have some

19 party task to carry out. And since he was not financially well-off at

20 all, he would often come to see me, to have a meal, to spend the night.

21 So we would talk about the party, but he never told me any such thing.

22 Q. You were -- are you aware of anybody --

23 MR. STEWART: In the first place, Your Honour, I'm going to invite

24 the witness fairly quickly to read through or at least glance through the

25 documents, Variants A and B, to get an idea what it's about, Your Honour.

1 JUDGE ORIE: Wouldn't it be a good idea to invite the witness to

2 do that during the break and to give her a copy of it?

3 MR. STEWART: Yes. I hadn't noticed the clock, Your Honour. Yes.

4 I don't see any problem about that at all. That's --

5 JUDGE ORIE: Then we have a wide variety of copies of this

6 document. Which one would you prefer the witness to look at, the 1990 --

7 MR. STEWART: I think the one the witness has got is number 93.

8 JUDGE ORIE: Handwritten 93.

9 MR. STEWART: It says copy number -- at least, I'm looking at the

10 English --

11 JUDGE ORIE: It was the one on the ELMO.

12 MR. STEWART: -- 093. That's become our, if you like, authorised

13 working copy for the purposes of evidence, Your Honour, for convenience.

14 JUDGE ORIE: Yes.

15 MR. STEWART: So that's the one, Your Honour.

16 JUDGE ORIE: Mrs. Hrvacanin, we'd like you to have a look during

17 the break at this document and to --

18 THE WITNESS: [Interpretation] Very well.

19 JUDGE ORIE: -- familiarise yourself with the content since

20 Mr. Stewart would like to ask you questions about the substance of the

21 document.

22 MR. STEWART: Would it be helpful, Your Honour, if I indicated to

23 Your Honour that I'm not inviting Mrs. Hrvacanin to make any attempt to

24 master the fine details. I would like her to just read enough to know

25 what it's dealing with, what its purpose is, who it is addressed to, what

1 sort of thing it's -- and also, may I just mention specifically, Your

2 Honour, to have a look at what is meant by A and B, the two particular

3 different approaches.

4 JUDGE ORIE: Yes. And perhaps also with phase 1 and phase 2.

5 MR. STEWART: Indeed, Your Honour. I'm obliged for that.

6 JUDGE ORIE: So if you would be so kind to familiarise yourself

7 with the general structure of the document and not to pay too much

8 attention to the details.

9 Then, Madam Usher, would you please escort Mrs. Hrvacanin out of

10 the courtroom. We'll have a break for -- until ten minutes to one, Mrs.

11 Hrvacanin. But the Chamber still owes the public the reasons for

12 closed-session testimony of Witness D9.

13 [The witness stands down]

14 JUDGE ORIE: And I'll give the reasons in open court.

15 On the 22nd of November, 2005, in court, the Chamber granted the

16 Defence request that Witness D9 be allowed to testify in closed session.

17 I will now deliver the reasons for the Chamber's decision in open session,

18 as required by the Rules.

19 The Defence filed its application for protective measures for

20 Witness D9 confidentially on the 17th of November, 2005. The Prosecution

21 stated in court on the 21st of November, 2005, that it did not oppose the

22 application.

23 Witness D9 expressed fear that giving evidence for Mr. Krajisnik's

24 Defence would give rise to physical danger to him, a risk of criminal

25 damage to his property, and a risk of dismissal from his employment.

1 The Chamber was satisfied that the Defence, in its written

2 submissions, established that there was a real risk to the safety and

3 welfare of the witness should it become known that he testified before the

4 Tribunal. The Chamber took particular note of the fact that the witness

5 is a public figure in Bosnia-Herzegovina and that he has received various

6 threats in relation to his place of residence. Moreover, the Chamber

7 considered that the content of the witness's testimony alone would be

8 sufficient to identify him and that protective measures less restrictive

9 than closed session would have been inadequate in this case.

10 This concludes the reasons for the Chamber's decision.

11 We will adjourn until ten minutes to one o'clock.

12 --- Recess taken at 12.30 p.m.

13 --- On resuming at 12.55 p.m.

14 JUDGE ORIE: Mr. Stewart, please proceed.

15 MR. STEWART: Thank you, Your Honour.

16 WITNESS: SLOBODANKA HRVACANIN [Resumed]

17 [Witness answered through interpreter]

18 Examined by Mr. Stewart: [Continued]

19 Q. Mrs. Hrvacanin, I take it you did have an opportunity over the

20 break to -- to read the document that you were handed earlier.

21 A. Yes.

22 Q. First of all, does your reading of that document change in any way

23 the evidence that you have given about whether you had or hadn't ever

24 previously seen such a document?

25 A. No. I hadn't seen that document.

1 Q. Now, you've appreciated, have you, in reading that document, that

2 there are two alternative sets of instructions, one designed for

3 municipalities where the Serbs were in the majority and one designed for

4 those municipalities where they were in a minority? Did you see that

5 structure of the document?

6 A. Yes.

7 Q. Zenica, from the evidence you've already given, was quite plainly

8 a municipality where you were in a distinct minority, wasn't it?

9 A. Yes.

10 Q. Did -- are you aware of anybody, including yourself, anybody

11 connected with the SDS in Zenica during 1991 or 1992 receiving any

12 instructions of the broad nature of that document in any form whatever?

13 A. I'm not aware at all of the fact that anybody in the SDS received

14 a document like that, and I for one certainly didn't.

15 Q. Did -- did Mr. Radomir Neskovic ever visit your municipality in

16 connection with his work on behalf of the SDS in 1991 or 1992?

17 A. With respect to that subject, never.

18 Q. Now, was there ever in Zenica a Serb -- ever. Mrs. Hrvacanin, I'm

19 talking about the period through from 1990 to the end of 1992. Was there

20 ever a Serb Crisis Staff in Zenica?

21 A. No, never.

22 Q. Was there ever, that you heard, any suggestion made by anybody

23 that a Serb Crisis Staff should be established in Zenica?

24 A. I'm not aware of that, no.

25 Q. You left Zenica yourself, and just confining ourselves to this

1 single point at the moment, you left Zenica at the very end of February

2 1992 to go to Banja Luka, didn't you?

3 A. Yes.

4 JUDGE ORIE: Mr. Stewart, I take it that you left your previous

5 subject; is that correct? Because then I would have one -- ask -- one

6 question to ask the witness.

7 When you were asked whether Mr. Neskovic ever visited your

8 municipality in connection with his work on behalf of the SDS in 1991 or

9 1992, you said, "With respect to that subject, never." Could you tell us

10 whether he ever visited you in respect to any other subject but in the

11 context of his work on behalf of the SDS.

12 THE WITNESS: [Interpretation] I beg your pardon. Your Honour, as

13 far as Mr. Neskovic is concerned, he did not have any duties with respect

14 to Zenica municipality in Central Bosnia. He would just come by privately

15 when he was going somewhere. I didn't know where he was going, but just

16 if he told me that he was going to such-and-such a place, then I would

17 know. But he was my private guest.

18 JUDGE ORIE: Yes. Never any political discussions with him at

19 those occasions or ...

20 THE WITNESS: [Interpretation] He was a member of the Executive

21 Board of the party, and I tried to talk about that a little bit with him,

22 but he didn't give out much information.

23 JUDGE ORIE: Yes. Please proceed, Mr. Stewart.

24 MR. STEWART: Thank you, Your Honour.

25 JUDGE ORIE: Judge Hanoteau has one question as well.

1 JUDGE HANOTEAU: [Interpretation] Yes. Have I heard you right when

2 you said that it was the only Assembly meeting that you attended at the

3 time in December 1991? You didn't attend another session of the Assembly?

4 MR. STEWART: Your Honour, could I say straight away, Your Honour,

5 with respect, I'm not distinctly aware the witness ever did say that.

6 JUDGE HANOTEAU: [Interpretation] She didn't say that. She didn't

7 say that. I just wanted to make that very clear. I wasn't really sure.

8 I'd like to know how many Assembly sessions she attended, please. Could

9 she answer that.

10 THE WITNESS: [Interpretation] Almost all of them.

11 JUDGE HANOTEAU: [Interpretation] Thank you. Everything's clear

12 now. Thank you very much.

13 MR. STEWART:

14 Q. After you left Zenica for Banja Luka, did you, over the succeeding

15 period, March, April, May 1992, did you speak to former colleagues and

16 friends from time to time who were still in Zenica?

17 A. Yes. My deputy, Radovan Glogovac, the vice-president of the

18 party, I talked to him frequently on the phone when I left Zenica, for

19 security reasons, to save my own life. So as far as I know, something

20 like that was not organised. Not a single SDS Crisis Staff in Zenica

21 existed.

22 Q. Do you have any knowledge whether a Muslim Crisis Staff was ever

23 set up in Zenica during that period 1990 to 1992?

24 A. While I was still in Zenica, rumours were going around that the

25 Muslims did have a Crisis Staff in Zenica and for the whole region. So

1 it's only hearsay, second -- secondary information. I didn't attend

2 meetings of this kind, but I did hear from my patients and prominent Serbs

3 that something like that was in fact in existence.

4 Q. Do you have any knowledge of whether there was a Croat Crisis

5 Staff during that period in Zenica?

6 A. No.

7 Q. When you -- when you did leave Zenica in late February 1992, was

8 there any specific matter which caused you to leave at that date?

9 A. Yes. They threatened to kill me, to liquidate my entire family.

10 And my husband said that the best thing would be for me to leave. And he

11 joined me very soon afterwards as well, within the space of two months.

12 Q. First of all, what -- you say they, "They threatened to kill me."

13 What was the form of such a threat? Was it by telephone, in person, in

14 writing? In what way was that threat made to you?

15 A. They threatened me personally in the work organisation that I was

16 employed in. They also threatened me over the phone and sending written

17 messages. So they used all sorts of ways.

18 In the local media they tried to mock me by presenting certain

19 articles of untruths to make it appear as if I were mad. And I couldn't

20 take those psychological and physical forms of abuse and I had to leave.

21 Q. Who are "they"? Again you refer to "they" as threatening you.

22 Who are you talking about?

23 A. The Muslims.

24 JUDGE ORIE: Mr. Stewart, could you please seek further

25 information where the witness says about physical abuse, whether that's

1 anything in addition to what she told us before.

2 MR. STEWART: Yes, of course, Your Honour.

3 Q. Mrs. Hrvacanin, you did tell Their Honours earlier about the

4 incident when you were taken to the police or the state security station,

5 and you specifically told Their Honours about one or two forms of physical

6 assault, your face being slapped and being jabbed in the back. Did you

7 subsequently -- those events were back in 1990. Did you subsequently

8 suffer any direct physical abuse before you left Zenica in February 1992?

9 A. Yes. In the building I lived in, which was predominantly

10 inhabited by Muslims and some Croats, there was another Serb family in

11 addition to my own. They waited for me in the stairwell and beat me up.

12 So I no longer dared go alone. I always had to have an escort with me,

13 whether my husband or one of my friends to accompany me, because it was

14 highly uncertain for me to enter a lift on my own. A Muslim stepped into

15 the lift with me once and stopped the lift halfway between two floors. He

16 didn't do anything to me, but he frightened me. I was very frightened,

17 and he said, "If you continue that way, then this will take a different

18 form." So that at work I was mistreated because they told me every day

19 that that was a Muslim country, that we Serbs would have to live there

20 pursuant to Mr. Alija Izetbegovic's declaration. He wrote the

21 declaration. They talked about the non-Serb population, non-Christian

22 population, how they would behave. They called me up on the telephone and

23 said that they would buy me a cockade, which is the symbol of the Kingdom

24 of Yugoslavia.

25 JUDGE ORIE: Let me stop you there because you were specifically

1 asked about any further physical abuse where you describe further threats.

2 You said in the building you lived in, which was predominantly

3 inhabited by Muslims and some Croats, there was another Serb family in

4 addition to my own, and then you said, "They waited for me in the

5 stairwell and beat me up." May I take it that was not the Serb family but

6 others living --

7 THE WITNESS: [Interpretation] The Muslims waited for me. No, not

8 the other.

9 JUDGE ORIE: That's clear. Thank you.

10 THE WITNESS: [Interpretation] I apologise.

11 JUDGE ORIE: Please proceed.

12 MR. STEWART: Thank you, Your Honour.

13 Q. Well, I'm not seeking enormous detail, Mrs. Hrvacanin, but the

14 phrase that comes across in English as "beat me up," however it's coming

15 back to you in your own language, could you just very briefly indicate to

16 Their Honours what you mean.

17 A. Well, when somebody hits me physically, whether in the head or the

18 leg, or tries to break my arm, that, for me, is a form of beating. Any

19 kind of physical violence is a fight, as far as I'm concerned.

20 Q. In the building that you lived in, then, you said predominantly

21 inhabited by Muslims and some Croats. How many -- roughly how many

22 families lived in that building?

23 A. There were 51 flats. It was a high-rise building.

24 Q. Did you -- threats you've described. Did you receive any friendly

25 warnings as opposed to hostile threats about what might happen to you and

1 your family?

2 A. That's right. That's true. From the Muslims who were not the

3 extremist extreme and not members of the SDA party at the time.

4 Q. And what was the nature of such warning?

5 A. Well, that I should stop delving in politics, that I should leave

6 the SDS, and that probably the assumption was that then I wouldn't have

7 any problems. But always in an indirect -- indirectly, and I would have

8 to read between the lines, there was always this caution and warning that

9 in fact I should leave Zenica along with my family.

10 Q. Now, your husband stayed in Zenica after you until April 1992; is

11 that correct?

12 A. Correct.

13 Q. And did your son stay with him during that period?

14 A. My son stayed with him until April, and he came in April. My

15 husband came on the 28th of April, just before the holidays, the 1st of

16 May holidays that were observed in Yugoslavia at the time, and

17 communication lines, the train lines and bus lines from Sarajevo to Banja

18 Luka were interrupted, so my husband never returned to Zenica.

19 Q. When you moved to Banja Luka, did you get a job straight away

20 there?

21 A. That's right. There was a competition for an oral surgeon, and I

22 applied and began working in the health centre as an oral surgeon, because

23 there was a place that was free. And according to job systemisation, they

24 needed four oral surgeons for the region. One of my colleagues was from

25 Belgrade, he worked there, but he left for reasons unknown to me, and so

1 there was a vacancy.

2 Q. When you -- when you arrived in Banja Luka, you moved into an

3 apartment there, did you?

4 A. That's right. From the Municipal Assembly I was given a flat that

5 was envisaged for cadres, and nobody had lived in it for ten years before

6 the war. It was unoccupied.

7 Q. Did you become actively involved in SDS politics in Banja Luka

8 from your arrival there end of February 1992 over the next few months up

9 to July 1992?

10 A. Yes, I did become involved in the work of the SDS in Banja Luka.

11 Q. And what was the nature and extent of your involvement in that

12 work?

13 A. Well, as a member of the Main Board I attended all the meetings of

14 the Municipal Board of the SDS in Banja Luka, and I was given the task of

15 setting up a humanitarian society called Dobrotvor, which had already been

16 established but was forbidden by the communists. It was actually founded

17 in 1919 and ceased working in 1945, but it was reinstituted in Sarajevo in

18 1991 and registered as such, as a charity organisation, and that's the

19 assignment I was given.

20 Q. And who gave you that assignment?

21 A. That assignment I received from the political council of the

22 party. I was appointed the social coordinator for social policy, social

23 welfare and policy, because they considered that, judging by my

24 profession, I would be best suited for that job.

25 Q. Did Mrs. Plavsic have any -- Biljana Plavsic have any association

1 with that political council?

2 A. Yes. She was a member of the political council, Mrs. Plavsic was.

3 Q. Did you have any particular connection yourself with Mrs. Plavsic

4 at that time?

5 A. Yes. I was friends with Mrs. Plavsic at that time.

6 Q. And for how long had you been friends with Mrs. Plavsic?

7 A. Well, since 1990. Up until her appointment as president of the

8 Republika Srpska. And for a time after that when Mrs. Plavsic proposed

9 that I join her party and be the president of the SNSD. I declined. I

10 wasn't able to accept, and we parted ways, politically speaking. Not --

11 as friends, though. But we didn't visit each other after that.

12 Q. So you've just -- you reminded Their Honours you were still a

13 member of the Main Board of the SDS, you attended the Municipal Assembly

14 meetings, as you've described, you had your humanitarian work that you've

15 just described. Did you have any further involvement in politics in Banja

16 Luka in the early months of your residence and work there?

17 A. No. Well, they didn't accept me with open arms regardless of the

18 fact that I was a Serb. I had a lot of problems with Mr. Radoslav

19 Brdjanin, for example.

20 Q. You anticipated my next question, Mrs. Hrvacanin, which I will put

21 in these terms, then: Did you -- did you meet specific resistance to your

22 becoming more involved in SDS politics when you were in Banja Luka?

23 A. Yes. My husband is from Krajina, and father, but I was somebody

24 new as far as they were concerned, a new face in town. And in the

25 Balkans, they don't like women doing anything. I've already explained

1 that to Their Honours. So that Mr. Brdjanin forbid me to do any kind of

2 work in that autonomous region of Krajina, or, rather, in Krajina, which

3 is where I lived at the time, in Banja Luka, and he even questioned and

4 challenged this with one of his decisions, as if the Dobrotvor charity

5 society had been already opened in Banja Luka. It was the process of

6 being established but it was a charity organisation from Sarajevo.

7 JUDGE ORIE: Mr. Stewart, before we continue I'd like to ask a

8 clarification of one of the earlier answers because otherwise we move away

9 from it and it's now still fresh in our memory.

10 You said that you did not part from Mrs. Plavsic as friends,

11 though, which suggests that there was a kind of conflict. Could you tell

12 us more about that?

13 THE WITNESS: [Interpretation] No, there wasn't a conflict of any

14 kind. I just did not agree to join the SNS party, which was led by

15 Mrs. Plavsic. And I told Mrs. Plavsic that I had joined one party, that

16 is to say the Serbian Democratic Party, and that I couldn't leave one

17 party and join another and switch from party to party, that I was too

18 serious a person to do that, too advanced in age for anything like that,

19 and that that would not be something that I was ready to do. But there

20 was no conflict between myself and Mrs. Plavsic. And I said that I

21 continued being friends. I mean, I still have a good opinion of her, but

22 we parted ways politically.

23 JUDGE ORIE: Yes. Now I better understand. What you wanted to

24 say is that you were still friends, that although you parted politically

25 and -- as a matter of fact, from what I read it is not unambiguous in

1 English, from what I read, but it's now clear. Thank you. Please

2 proceed.

3 MR. STEWART:

4 Q. When was that? The year would do, I suggest, Mrs. Hrvacanin.

5 When was that suggestion from Mrs. Plavsic that you might join her party

6 and your rejection of that approach?

7 A. I think that was in 1994. Between 1994 and 1995. Please don't

8 hold it against me if I'm wrong, but I think that's the general time

9 period. Mr. Neskovic was in charge of trying to influence me and change

10 my opinion and join the party, but I was quite clear on that point; there

11 were no more parties as far as I was concerned.

12 Q. That Mr. Radomir Neskovic, is it, that you were talking about in

13 that answer?

14 A. That's right.

15 Q. The -- you've indicated very clearly Mr. Brdjanin's resistance or

16 opposition to your involvement in politics. What were -- did you know

17 what the reasons were for his adopting that attitude towards you?

18 A. Well, he always had some leadership tendencies and traits, always

19 wanted to be the number one man, and he never liked anybody threatening

20 that position, me included, if he thought that somebody could be placed

21 higher than him. So that's my free assessment of the man. That was the

22 only reason, to my mind.

23 Q. Did -- had you known Mr. Brdjanin at all before you moved from

24 Zenica to Banja Luka?

25 A. No, I didn't know him before. I would just see him when he came

1 to the Assembly in Sarajevo because he was a deputy.

2 MR. STEWART: Your Honour, may I -- well, two things: Place a

3 document in front of the witness but also distribute copies. It's not a

4 very long document, Your Honour, and I --

5 JUDGE ORIE: It's a new document.

6 MR. STEWART: I think it's new, Your Honour. We never know for

7 certain sometimes whether a document is totally new to the case, but we

8 believe it is.

9 I'm sorry, I could at the same time - I beg your pardon - there's

10 a single sheet which just at the moment, Your Honour, is a translation

11 done by my case manager of the critical paragraph. We hope that's helpful

12 for immediate working purposes. And these are photocopies of a document

13 which I'm now handing to the witness.

14 JUDGE ORIE: Mr. Registrar, would you please provisionally assign

15 a number to the document.

16 THE REGISTRAR: That would be D113, Your Honours.

17 MR. STEWART: Thank you.

18 Q. Now, first of all, Mrs. Hrvacanin, this piece of paper that I have

19 handed to you is itself a photocopy, isn't it?

20 A. That's right.

21 MR. STEWART: Your Honour, perhaps I can just indicate. It's not

22 simply one of the photocopies that the rest of us have. It's, as can be

23 seen on an inspection, it's -- it's a different colour. It is -- although

24 it's a photocopy, it's been further photocopied for our working purposes.

25 Q. First of all, Mrs. Hrvacanin -- yes. Any of the copies can go on

1 the ELMO. That's very helpful. Thank you very much indeed.

2 First of all, is the piece of paper that you've got in front of

3 you, the photocopy, as you've confirmed, is that a piece of paper that you

4 brought with you to The Hague when you arrived in the last few days?

5 A. Yes. On Thursday.

6 Q. And although it's in Serbian and it says to some extent what it

7 is, if could you just tell Their Honours what it is, please.

8 A. This is a paper that I managed to get through Mr. Kasagic at the

9 Municipal Assembly of Banja Luka because it had been read out on

10 television that I am banned from doing any kind of work in Krajina. My

11 husband comes from that area. My mother-in-law is there, and at that time

12 she was 80 years old, now she is 96 or 97. So she telephoned me and she

13 asked me whether I had heard the news, and I said no. She said, "Well,

14 you're jobless now because you're banned from doing any kind of work."

15 I tried to get hold of this document. I even went to the local TV

16 station. That is where they told me that indeed an announcer had read out

17 that I am banned from doing any kind of work in the institutions of the

18 region of Krajina and that I am banned from doing any kind of work at all

19 on behalf of the autonomous region of the Krajina. And I wasn't engaged

20 in any kind of work on their behalf anyway.

21 Also, it is stated that in the area of the autonomous region of

22 Krajina, the Dobrotvor society had not been established at all and it was

23 due to be established a month later.

24 Q. Mrs. Hrvacanin, can I just invite you, first of all, to look at

25 the signature at the end of that document and say if you recognise the

1 signature.

2 A. Let me just change my glasses.

3 MR. STEWART: Your Honours, my apologies to Mr. Krajisnik. I

4 parted with all my Serbian copies of this document and deprived my own

5 client of one. So sorry.

6 Q. Yes. Do you recognise the signature, Mrs. Hrvacanin?

7 A. I've never seen Mr. Brdjanin's signature, so I cannot say whether

8 it is his signature in actual fact. I'm not a handwriting specialist, but

9 it does say here "Radoslav Brdjanin."

10 Q. Could you just say, how did this particular photocopy, as you've

11 confirmed it is, how did you get hold of it specifically?

12 A. I think I've already said that it was given to me by Mr. Rajko

13 Kasagic, who was president of the Executive Council of the city of Banja

14 Luka. If necessary, I can go on to say that Mr. Kasagic was a man that I

15 was supposed to get married to.

16 Q. Well, you've said it anyway, Mrs. Hrvacanin, so whether it was

17 necessary or not --

18 A. Well, I am sorry. I did ask whether it was necessary for me to

19 say it, but -- maybe I even abused Mr. Kasagic because I asked him to give

20 me this document, but I did not have any bad intentions. My only

21 intention was to check out this information that was broadcast on

22 television and that it was written in the newspapers. And I have never

23 stated this publicly before. This is the first time I've said it.

24 Q. Mrs. Hrvacanin, the -- the request to Mr. Kasagic to obtain this

25 document, was that made back in 1992, or is that a request made more

1 recently?

2 A. On the same day when it was telecast, when they said on television

3 that I was banned from doing any kind of work. The following day, my

4 mother-in-law told me about this, and then I asked for this information

5 and I got this.

6 Q. So the document, the photocopy that you have, the one that you

7 brought with you to The Hague, you've had that for the last 13 years; is

8 that right?

9 A. Yes.

10 JUDGE ORIE: Yes. Mr. Stewart, do you have any further questions

11 on this document?

12 MR. STEWART: Yes, Your Honour. I was going to invite the

13 witness, if she would - it's very short - simply to read paragraph 14 so

14 we can get the interpretation.

15 JUDGE ORIE: Yes. Perhaps before doing so, it's a document that

16 contains some handwriting. Since it's a photocopy it's not clear to me

17 any more whether the handwriting is photocopied as well. Could I just

18 have a look at it for one second, and could Mr. Tieger also be given an

19 opportunity to look at it so that we know more or less.

20 [Trial Chamber confers]

21 JUDGE ORIE: I have some difficulties to fully understand what it

22 is. For example, on page 2 it seems that the front page, where it says

23 Srpska Republika Bosnia-Herzegovina, which you see in mirror writing, but

24 you don't see it only once, you see it twice, which is not yet clear to

25 me. Everything that shines through shines through on page 2 double, which

1 is -- and the handwriting.

2 Mrs. Hrvacanin, have you any idea on who did write on this

3 document, either on the front page where it seems that Dobrotvor and your

4 first name, Slobodanka, have been written down? It seems not to be very

5 informative, but on the second page there is some handwriting as well. Do

6 you know who made that handwriting?

7 THE WITNESS: [Interpretation] I wrote it, Your Honour. On this

8 same piece of paper, which was evidence of the fact that I was banned from

9 doing any kind of work, I wrote to Dr. Gvozdenovic in Sarajevo because he

10 was president of Dobrotvor. So since he authorised me to set up a

11 Dobrotvor branch in Banja Luka so I wanted him to know what I was being

12 subjected to. So I wrote this and this is my handwriting, Your Honour.

13 JUDGE ORIE: I do understand. But then, at least that seems to be

14 the conclusion, the photocopy I just looked at is there not the photocopy

15 you received at that time because it seems that your handwriting is copied

16 as well. So it would then be a copy of a copy.

17 MR. STEWART: Your Honour, perhaps I might, just for one second,

18 retrieve the copy the witness has so that I can see that.

19 THE WITNESS: [Interpretation] Yes.

20 MR. STEWART: Your Honour may wish to see it. Your Honour, I see

21 no material difference between the copy that the witness has and the

22 photocopies we're looking at in any respect here. I just wanted to check

23 that, Your Honour.

24 JUDGE ORIE: Yes. I do not see any difference either there.

25 MR. STEWART: Your Honour, I wonder whether quickly, as a lead

1 into this stuff, whether we could invite the witness to read that

2 paragraph 14.

3 JUDGE ORIE: Yes. Let's start with that. Yes.

4 MR. STEWART:

5 Q. I wonder, Mrs. Hrvacanin, could you simply read paragraph 14, only

6 that paragraph of this document, just slowly for the interpreters to be

7 able to translate it.

8 A. 14: "That Slobodanka Hrvacanin was not elected to any office in

9 the institutions of the autonomous region of Krajina. Therefore, she is

10 banned from conducting any kind of work on behalf of the autonomous region

11 of Krajina. In the area of the autonomous region of Krajina, the

12 Dobrotvor society has not been established at all.

13 Q. And then your --

14 THE INTERPRETER: Microphone, please.

15 MR. STEWART: Sorry.

16 Q. And then your note on the second page of this document. Is this

17 your handwriting, all this eight or so lines?

18 A. Yes.

19 Q. Would you just read that, please.

20 A. "Could Dr. Gvozdenovic please send a telefax as to who can

21 represent Dobrotvor in the Krajina region and send me the statute,

22 Dr. Slobodanka Hrvacanin. I'm sending this as an example of arbitrariness

23 on the part of the self-styled president of the Crisis Staff in order not

24 to have any problems and not suffer any consequences due to my

25 appointment. Dr. Slobodanka."

1 JUDGE ORIE: Perhaps, Mr. Stewart, the one line upside-down date.

2 MR. STEWART:

3 Q. Yes. Do you see, Mrs. Hrvacanin, immediately underneath the typed

4 or printed paragraph 14 there's what appears to be a -- as we look at it,

5 an upside-down single line. What does that say?

6 A. It says the "28th of January, 1968, Zenica." That is something

7 that I jotted down, and it is totally unrelated to all of these events.

8 Q. Mrs. Hrvacanin, after you moved to Banja Luka -- well, first of

9 all, before you went to Banja Luka. When you were still in Zenica, did

10 you -- how often did you miss a Main Board meeting of the SDS?

11 A. For the most part I did attend meetings of the Main Board.

12 Q. Did that continue in May -- sorry, in March 1992? Do you recall

13 whether you attended any Main Board meeting or meetings in March after

14 you'd moved to Banja Luka?

15 A. No, because it was not possible. The corridor had not been

16 established between Krajina and Semberija, and it was impossible for me to

17 go to Pale -- or, rather, to Sarajevo.

18 Q. When did it become impossible?

19 A. Just a moment. In March I attended the Congress of Serb

20 Intellectuals. I've just made a mistake. I do apologise to the Court.

21 On the 28th of March, I attended the Congress of Serb

22 Intellectuals in Sarajevo at the Holiday Inn hotel. That's my last stay

23 in Sarajevo.

24 Q. Up to that date, how frequently over the period -- well, let's

25 take the whole of 1991 and then 1992 up to that meeting you've just

1 mentioned in March 1992. Can you say how often did you go to Sarajevo?

2 A. At first the meetings were held once a week. Later, as the party

3 continued its work, people went to Sarajevo when necessary, when Main

4 Board meetings were called, and when the political council would have its

5 meetings.

6 Q. How many days a month, on average, for whatever reason, did you

7 personally go to Sarajevo during that period?

8 A. I personally went to Sarajevo often, because it is very close to

9 Zenica. I often went to the university and to the university clinic for

10 oral surgery due to professional reasons, because I continued my

11 professional work. Since the university is close to Djuro Djakovic where

12 the party was within the club of deputies of Bosnia-Herzegovina, that was

13 where it was even in Tito's day, so I went at least once a week.

14 Q. How long was the journey from your home in Zenica to Sarajevo?

15 A. A bit less than an hour.

16 Q. And did you -- you stayed overnight in Sarajevo on occasions, did

17 you?

18 A. Yes.

19 Q. And was there any particular place where you frequently stayed?

20 A. Yes. At my friend's and colleague's place. His name is Milos

21 Vukovic and he had an apartment of his own in Marsala Tito, which is a

22 street the centre of Sarajevo.

23 JUDGE ORIE: Mr. Stewart, I'm looking at the clock. If it would

24 be a suitable moment.

25 MR. STEWART: It is, Your Honour.

1 JUDGE ORIE: We will adjourn for the day. Mrs. Hrvacanin, we will

2 resume tomorrow, but not in the morning. We'll sit tomorrow in the

3 afternoon at quarter past two, and I'm looking Mr. Registrar, what

4 courtroom that would be.

5 THE REGISTRAR: That would be in Courtroom III, Your Honours.

6 JUDGE ORIE: Thank you, Mr. Registrar.

7 So we will be in the same courtroom tomorrow, quarter past two.

8 Before I adjourn, Mr. Tieger would you perhaps ask Mr. Harmon

9 about P1013. That's an interview with the BBC where we are still waiting

10 for a further indication of the time when it was published. And P1016 is

11 still waiting for a B/C/S translation.

12 Having said that, we adjourn until tomorrow, quarter past two.

13 --- Whereupon the hearing adjourned at 1.45 p.m.,

14 to be reconvened on Tuesday, the 6th day

15 of December, 2005, at 2.15 p.m.

16

17

18

19

20

21

22

23

24

25