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19 [Open session]

20 JUDGE SCHOMBURG: Please be seated. You may have heard that in

21 order to avoid that the witness has to come a second time to The Hague, we

22 have additional time. But this shouldn't be an invitation to be as long

23 as we all have been with the last witness. I think we should all speak

24 aloud mea culpa related to the last witness. I think we, all of us, could

25 have been shorter.

1 So let's try -- what is your real estimate the time you would

2 need.

3 MR. OSTOJIC: Approximately an hour and a half to two hours, Your

4 Honours.

5 JUDGE SCHOMBURG: Then let's try to do it in one session, and then

6 the cross the same period in time. And in case we all show the necessary

7 self-restraint, then it will be in good time.

8 I want to let you know that next week on Wednesday, exceptionally

9 we sit in the morning instead of the afternoon. There was a change

10 necessary because of an extraordinary bureau meeting which is now

11 unfortunately rescheduled for Thursday. This means that on Thursday, we

12 have to start a little bit later. As regards all the other changes in the

13 schedule in the future, I'll let you know as soon as possible. Only that

14 you know for those of you who want to leave The Hague, everybody should

15 know that we hear this case the 7th of February. But in exchange, the day

16 between UN holiday and the day between court recess will be a day without

17 any hearing. So this means from Wednesday to Friday, no hearing that

18 week. But you'll get it in writing as soon as possible.

19 Without further ado, may I ask the usher to bring in the witness.

20 May I hear any change as regards protective measures.

21 MR. OSTOJIC: No, there is no change in connection with that

22 issue, Your Honour, but I would like to make an oral application of a

23 different kind if I may.

24 JUDGE SCHOMBURG: Please.

25 MR. OSTOJIC: As the Court has reviewed our proffer, we would like

1 to add to our proffer an issue that Mrs. Kovacevic will be discussing, and

2 that is her employment. As I do with most witness cover their employment

3 history. She will share with us information and data she has received in

4 connection with refugees who were coming to the Prijedor municipality from

5 1991 through 1995. We would ask that be allowed to be inquired of, and we

6 also brought the documentation in CD form, and we would like for her to

7 explain, at least in part, some of that documentation the headings, et

8 cetera. And I think subsequent to that it should be self-explanatory for

9 all of us to read. Because there are listings of names, addresses, et

10 cetera.

11 JUDGE SCHOMBURG: Any objections?

12 MR. KOUMJIAN: Your Honour, after reviewing that material, we may

13 ask for additional time to review it and cross-examine the witness. What

14 we had until this moment is a three-sentence summary of this witness's

15 testimony. And to have -- a moment before she testifies have it be

16 disclosed that there's going to be a CD admitted into evidence with her

17 testimony, which I understand is not part of the Defence exhibit list, we

18 think we are entitled if -- depending on what it is, to additional time

19 before we complete our cross-examination.

20 JUDGE SCHOMBURG: We are also taken by surprise. The witness has

21 testified beforehand in this Tribunal?

22 MR. OSTOJIC: Not to my knowledge, Your Honour, she has not.

23 JUDGE SCHOMBURG: So the content of this CD will be in concreto

24 what?

25 MR. OSTOJIC: The CD will help establish, we think, and rebut

1 certain allegations made in the fourth amended complaint, specifically

2 relating to the population in the Prijedor municipality and the events

3 pre-, during, and post-April through September of 1992. We believe that

4 it addresses specifically issues of various witnesses offered by the OTP,

5 specifically Mr. Robert Donia, Dr. Ewa Tabeau, and several of the lay

6 witnesses who testified about various exodus and movement of people within

7 that region at that time. We also believe that it specifically goes to

8 count 7 and 8 of the fourth amended indictment, which we think can help

9 establish certain factors and assist the Court.

10 JUDGE SCHOMBURG: May I ask why it was not possible to present

11 this CD beforehand?

12 MR. OSTOJIC: Yes. The explanation is we recently received the CD

13 Your Honour. And immediately upon receiving the CD, we had to examine it

14 as well, unlike -- and respectfully, unlike the OTP witnesses, we do not

15 have an opportunity to meet with our witnesses years and months in

16 advance. We are literally meeting our witnesses for the first time when

17 they arrive at The Hague. And she brought this CD with her. And it was

18 at that time, after we reviewed it, that we thought it was be prudent to

19 produce that CD. We think it's important. We certainly think it's most

20 relevant --

21 JUDGE SCHOMBURG: Okay. The picture becomes more clear. If it's

22 a CD she brought with her, we have had this in the past that a witness

23 brings some evidence. Let's wait and see what and not discuss in the fork

24 when we don't know what it's all about.

25 Let's start hearing the witness.

1 MR. OSTOJIC: We have the CD here if the Court would like us to

2 distribute it and to mark it for the Court. I think we previous --

3 JUDGE SCHOMBURG: We can play it with our LiveNote laptops?

4 MR. OSTOJIC: We have coordinated with the video technicians that

5 we can at least, by way of a sample, go over a couple of pages so the

6 Court can understand various columns that were within the CD. If

7 necessary and if the Court wishes, you can ask her if there's any

8 questions that may immediately come to mind any further. But I think it's

9 really just a listing of individuals with their address, the place where

10 they were from, where they left to, and the year in which they

11 approximately came or specifically to the Prijedor Municipality and when

12 it was reported, their status.

13 JUDGE SCHOMBURG: So this CD will be provisionally marked as D43,

14 because D43, unfortunately, was omitted in the past. So let's wait and

15 see. But Mr. Koumjian.

16 MR. KOUMJIAN: If I could just give a brief comment, I'm moving to

17 exclude this, and I never think that if something is relevant, that the

18 Prosecution is going to make a motion to exclude it. It's a question of

19 preparation. And I would just, and perhaps we can finish with this today,

20 but if I could just comment on counsel's remark about the difference in

21 resources and the ability to meet with witnesses. In fact, the Defence

22 has investigators as the Prosecution does. They have the advantage that

23 their investigators live in Prijedor, unlike ours.

24 JUDGE SCHOMBURG: I think we shouldn't discuss this in depth. I

25 know the advantages and disadvantages of Defence counsel. Normally, the

1 Defence knows better what has happened in the past and is closer to the

2 truth because there's a good relationship to the client. And on the other

3 hand, we shouldn't discuss in-depth all the capacities the OTP has. This

4 is not a matter we should discuss here and today and are wasting time by

5 doing so.

6 Therefore, I would kindly ask the usher really now to escort the

7 witness into the courtroom. Thank you.

8 Please distribute the provisionally marked exhibit.

9 [The witness entered court]

10 JUDGE SCHOMBURG: Good afternoon. Can you hear me in a language

11 you understand?

12 THE WITNESS: [Interpretation] Yes, I can.

13 JUDGE SCHOMBURG: Would you please be so kind and give us your

14 solemn declaration.

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

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

17 JUDGE SCHOMBURG: Thank you. Please be seated.

18 WITNESS: LJUBICA KOVACEVIC

19 [Witness answered through interpreter]

20 JUDGE SCHOMBURG: Mr. Ostojic, the witness is yours.

21 MR. OSTOJIC: Thank you.

22 Examined by Mr. Ostojic:

23 Q. Good afternoon, Mrs. Kovacevic.

24 A. Good afternoon, Mr. Ostojic.

25 Q. Just so the record is clear, my name is John Ostojic, along with

1 Branko Lukic and Danilo Cirkovic; we represent Dr. Milomir Stakic. I'm

2 going to be asking you a series of questions here today. As we previously

3 discussed, I'll be asking them in English. And I would ask you to please

4 wait, although you may anticipate some of my questions, to wait until you

5 fully hear my question before you give us an answer. Fair enough?

6 A. Okay.

7 Q. For the record, can you please state your full name and spell your

8 last name.

9 A. Ljubica K-o-v-a-c-e-v-i-c.

10 Q. Can you please share with us your current marital status. If

11 you're a widow, or are you currently married?

12 A. I'm a widow.

13 Q. Can you please tell us if you have any children.

14 A. Yes, I have a son.

15 Q. Can you please tell us the name of your late husband.

16 A. My late husband's name was Milan Kovacevic.

17 Q. Forgive me for asking, but what is your ethnic background?

18 A. I'm a Serb.

19 Q. In the spring and summer of 1992, where did you reside?

20 A. In the spring and summer of 1992, I lived in Prijedor.

21 Q. Is that within -- that's the city of Prijedor which is within the

22 Prijedor Municipality. Correct?

23 A. Correct. In the town of Prijedor, in the municipality of

24 Prijedor.

25 Q. And with whom did you reside there in the spring and summer of

1 1992?

2 A. I lived with my husband and my son.

3 Q. Did you live in a home, a house, or an apartment?

4 A. We lived in an apartment in a neighbourhood called Raskovac.

5 Q. Can you, to the best of your recollection, share with us the

6 specific address and apartment number where you resided in the spring and

7 summer of 1992.

8 A. I remember because I still live there. It is Zarko Zgonjanin

9 Street, number 23.

10 Q. In that apartment complex, can you tell us the ethnic background

11 of your neighbours, again, for the spring and summer of 1992.

12 A. Until then, I didn't realise what their ethnic background was, but

13 I now see that it is important, so I made an effort to find out. I just

14 greeted them. I knew their names. There were Croats, there were Serbs.

15 But I don't make a distinction between Croats and Serbs by their names

16 because I am not a native of Bosnia and Herzegovina.

17 Q. Mrs. Kovacevic, forgive me for --

18 THE INTERPRETER: Your microphone, please.

19 MR. OSTOJIC:

20 Q. Forgive me for having to ask this question again, it's just for

21 purposes of correction, with the Court's permission. It's my

22 understanding that you also mentioned that Muslims were living within that

23 apartment complex in which you resided in 1992. Correct?

24 A. Yes, that's correct.

25 Q. It just didn't appear on the transcript, and that's why I'm just

1 asking you so that we're clear on that issue. Within your apartment

2 complex, people resided there of all different ethnic backgrounds,

3 Muslims, Croatians, and Serbs. Correct?

4 A. Yes. Yes, correct.

5 Q. Let me move to your educational background if I may, can you share

6 with us the highest level of education that you attained.

7 A. I have an associate degree. I am a defectologist.

8 Q. Can you tell us, when did you graduate or when did you obtain your

9 degree.

10 A. In 1973, actually I started working in 1973, but I believe that I

11 graduated in 1972.

12 Q. Where did you obtain your degree, from what university or college?

13 A. In Belgrade. It was a university for the education of teachers

14 working with students with special needs.

15 Q. Share with us, if you will, your employment history commencing in

16 1973. Where were you first employed, and then tell us the years in which

17 you were employed there?

18 A. It was in Maglaj, a small town in Bosnia-Herzegovina. So that is

19 when I worked in a primary school. And I worked with retarded children.

20 I had two classes, and I worked as a special-needs teacher, teacher

21 teaching children with special needs.

22 Q. And for what period of time did you work there? From when to

23 when?

24 A. I worked there from 1973 to 1976. And then Mico and Ljubimir and

25 I went to Kljuc, and from there, we went to Germany.

1 Q. Just so that we're clear, when you say "Mico," you mean Milan

2 Kovacevic. Correct?

3 A. Yes, yes.

4 Q. When you say "Ljubimir," you're referring to your son. Correct?

5 A. Yes. We were a family.

6 Q. Can you give me the reason why is it you and your family went to

7 Germany in 1976?

8 A. We lived in Kljuc. Kljuc is a small place. And I always wanted

9 to go back to Serbia. And Germany was the way to go back to Germany.

10 Mico had to complete his residency in order to be able to find work

11 Belgrade. So he went to Germany to complete his residency.

12 THE INTERPRETER: Interpreters' correction: "Germany was the way

13 to go back to Serbia."

14 MR. OSTOJIC: Thank you.

15 Q. Share with us the period of time that you and your family resided

16 in Germany. How many years were you there?

17 A. From 1978 to 1983, I returned one year earlier because my son

18 started school. And according to the agreement that was valid between

19 Serbia and Germany at that time, my son should have started school in

20 Germany, and then my husband would have had to come back. I didn't want

21 my son to stop his education at one point, so I returned before he started

22 school.

23 Q. Did you become gainfully employed subsequent to your return to

24 Yugoslavia in 1983?

25 A. Yes, but not immediately. I started working in Cirkin Polje in

1 the institution for mentally retarded children and adolescents.

2 Q. Share with us the time frame in which you were at Cirkin Polje

3 working with the mentally retarded children and adolescents. From what

4 period of time to what?

5 A. I don't recall the dates, but it was between 1983 and 1992. And

6 in September of that year, I left for Belgrade.

7 Q. So is it fair to say that you actually were employed at that

8 medical institution dealing with mentally retarded children and

9 adolescents during the period of April through September 1992. Correct?

10 A. That is correct.

11 Q. Share with us, if you will, the composition of the ethnic

12 background of those children and adolescents that you were helping and

13 caring for from April through September 1992.

14 A. It was a welfare institution, a health-care institution, and an

15 educational institution. As far as the ethnic background of the children

16 is concerned, while we worked at that institution, we did not segregate

17 children by their ethnic background. This information is not accessible

18 to me. There was a nongovernmental institution from Finland who has that

19 information, and I may have learned that at one point. But I don't

20 remember. Even -- although I knew that this may be important today, I

21 couldn't obtain that information.

22 Q. Did you care and treat for those mentally retarded children and

23 adolescents the same regardless of what their ethnic background would have

24 been?

25 A. Of course. When you work in an institution like that, and if you

1 see a child that is not capable of caring for themselves, then it doesn't

2 occur to you what their ethnic background may be. I would have to think

3 long and hard in order to find out what their ethnic background was. We

4 treated everybody the same, and the only distinction we made between the

5 children was whether they were severely handicapped or not, whether they

6 were epileptic or not, whether they are included in the system of

7 education, whether they are under the system of work occupation, whether

8 they needed the attention of a third person and the full care of that

9 third person. These were the only criteria we applied when we made a

10 distinction amongst those kids; nothing else.

11 Q. Did anyone, ma'am, at any time instruct or order you to treat any

12 of the children that you were caring for and treating any differently than

13 you had throughout your entire career while at Cirkin Polje, from 1978 to

14 1983?

15 A. What do you mean, anybody? Nobody, never.

16 Q. Continuing with your -- just to correct the record, on page 68,

17 line 6, I limited the time period from 1979 through 1983. Looking at my

18 notes, that was the time, I believe you testified, you were in Germany.

19 Subsequent to that, you worked at Cirkin Polje all the way through

20 September of 1992. Correct?

21 A. When I returned from Germany, now you have confused me. I

22 returned from Germany in 1983. Then I started working, and I worked until

23 the end of September 1992 in the institution for the handicapped children

24 and adolescents.

25 Q. And I apologise for causing any confusion. With the Court's

1 permission, I'd like to re-ask that question with the correct date.

2 Specifically up through and including 1992, did anyone, ma'am, at any time

3 instruct or order you to treat any of the children you cared and treated,

4 adolescents or children, while at Cirkin Polje up to and including

5 September of 1992?

6 A. No, never, nobody.

7 Q. Following September of 1992, did you once again become gainfully

8 employed?

9 A. After I left for Belgrade, in September of 1992, I returned in the

10 summer of 1993. I didn't work until the year 1994, then I got employed in

11 the centre for welfare and -- social welfare. And there I worked in the

12 administration for the registration of refugees.

13 Q. And how long did you work with the centre for welfare and social

14 services where you were the administrator for the registration of

15 refugees?

16 A. I worked there from 1994 to 2000 when I was invited to go back to

17 Cirkin Polje and work there, because they had a shortage of staff, of

18 trained personnel. That's why I was invited to come back. I stayed there

19 for six months, just to see whether I was still able to do that. Because

20 it is a very difficult job. And then I felt I really couldn't do it. And

21 after six months, I returned to the centre for welfare and social

22 services.

23 Q. Am I correct that you are still employed by the centre for welfare

24 and social services?

25 A. Yes, that's correct. I still do.

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1 Q. What is your job title?

2 A. Currently, the centre for social welfare, I work on the

3 accommodation of persons with special needs. We are talking about all

4 kinds of handicaps. We are talking about blind children, deaf children,

5 mentally handicapped children, children with physical handicaps. That's

6 my job. I put them up in different institutions, and family care, too.

7 Q. Can you tell me when you arrived here at The Hague. Two days

8 ago? Four days ago? When? Or was it yesterday?

9 A. I think it was yesterday.

10 Q. You arrived yesterday morning, and we had an opportunity to meet

11 for the first time last night. Correct?

12 A. That's correct, yes.

13 Q. And with you, you brought a CD from the centre for welfare and

14 social services which contains data of the registration, names, and

15 identification numbers among other things of people, men and women, who

16 were refugees during the period of 1991 through 1995. Correct?

17 A. That's correct, yes.

18 Q. With the Court's permission, I would like to direct the

19 audiotechnician booth to place the CD that we provided them so that we

20 could have the witness answer some questions.

21 JUDGE SCHOMBURG: May I ask, you tendered an entire CD-ROM. On

22 this CD Rom are four files. One consists of 31.594 rows, and the others

23 are more limited. Do you tender all the four files or only the one?

24 MR. OSTOJIC: We are tendering all four, Your Honour.

25 And if I can have the Court's permission to have the usher to

1 assist the witness to transfer the screen on a video text so that she

2 could follow along.

3 JUDGE SCHOMBURG: And you are starting now with the first file.

4 Correct? If we can please name the file that we know.

5 MR. OSTOJIC: On the top left-hand corner, there's a connotation

6 that is referred to as Izglav, I-z-g-l-a-v. And that is page 1, starting

7 with the left-hand portion of the document with the numerical 1 appearing

8 below.

9 JUDGE SCHOMBURG: This is the 1 ending with row 31.594. Right?

10 MR. OSTOJIC: I'm being assisted with this. We think that if we

11 turn the videotape on the computer evidence section of your screen, as

12 opposed to the video evidence, the Court may be able to see a better

13 picture of it.

14 JUDGE SCHOMBURG: I have it right now on my laptop. There is a

15 file called Izglav, Izglint, Izmov, Izin. We start with Izglav.

16 MR. OSTOJIC: Correct, Your Honour.

17 JUDGE SCHOMBURG: Thank you.

18 MR. OSTOJIC: Just so the Court is aware and I'm informed, the

19 document that we have which is Izglav is the main document of our

20 exhibit. The following three disks are actually the manner in which it

21 would assist anyone reviewing this CD in order to understand the various

22 connotations within that first CD. The first one Izglav is the main CD

23 here.

24 JUDGE SCHOMBURG: May I ask, "Izglav" stands for? Abbreviation

25 for what word?

1 MR. OSTOJIC: "Glavne izbjelgice", which is mainly -- or main

2 refugees or refugees mainly.

3 THE WITNESS: [Interpretation] I can't see anything on the screen.

4 What is this?

5 MR. OSTOJIC:

6 Q. Mrs. Kovacevic, you're looking at a screen of one of the CDs that

7 was given to me, which lists out the various refugees that came and

8 travelled from various parts and portions of former Yugoslavia to the

9 Prijedor municipality.

10 A. All right.

11 Q. Do you understand how the columns are broken down at all? And can

12 you explain the various columns to us.

13 MR. KOUMJIAN: Excuse me, Your Honour, I have an objection because

14 I'm working at a severe disadvantage since I just learned about this and

15 it's not translated. But I'm not sure that this witness is testifying in

16 any way from personal knowledge or what -- who it is that authored or what

17 the circumstances are in which this data was gathered. So we are

18 presenting completely -- information data of completely unknown sources.

19 I would like -- if the Court is going to allow further questioning, I

20 would like first to be able to voir dire her about her knowledge of

21 these -- this information.

22 JUDGE SCHOMBURG: I think the document and the source should be

23 identified first. Correct.

24 MR. OSTOJIC:

25 Q. Ms. Kovacevic, while you were employed in the centre for welfare

1 and social services, is there within that centre binders of books which

2 maintain registration data for refugees that came within the Prijedor

3 Municipality from 1991 through 1994 or 1995?

4 MR. KOUMJIAN: Your Honour, I would ask counsel on this specific

5 point not to be leading the witness.

6 JUDGE SCHOMBURG: I would do the same and also ask --

7 THE INTERPRETER: Microphone, Your Honour, please.

8 JUDGE SCHOMBURG: Sorry. And also ask the witness the latest

9 update -- is it true that the latest update of the document we have before

10 us is the one from the 16th of February, 1976, or what is the source?

11 When was this file produced? And by whom? And what were the underlying

12 sources?

13 THE WITNESS: [Interpretation] If I may.

14 MR. OSTOJIC:

15 Q. Yes, with the Court's permission.

16 A. When I first started working in the centre for social welfare in

17 1994, I worked on the records. That's recording the refugees and people

18 being declared as refugees who came as refugees from all the different

19 parts of the former Yugoslavia. So it could have been from the

20 federation, which means the Muslim or Croat-controlled parts of Bosnia,

21 from Croatia, or from Slovenia for that matter. While I worked there,

22 that's my unit, I was some kind of head of that unit. Over 22.000

23 refugees were registered and declared as refugees. And I took part in

24 collecting these registrations.

25 What I can see here on the screen, this is probably a PC version

1 of the file. I didn't really use a PC, but I did record refugees when

2 they arrived in Prijedor. It was their obligation, as soon as they could,

3 to go to the centre for refugees and then to the centre for welfare and

4 social services so that they can be registered as refugees. And then in

5 the SUP, they would get some kind of a substitute ID, which was some sort

6 of a replacement for their passport or their original ID. And this was

7 their new personal document, the one they should be using in their new

8 place of residence.

9 MR. OSTOJIC: May I proceed, Your Honour?

10 MR. KOUMJIAN: Well, I do have an objection to the relevance of a

11 list of refugees since 1994 in the municipality of Prijedor. I don't see

12 how the names and data regarding refugees who came to Prijedor after the

13 indictment period is relevant to any of the allegations regarding ethnic

14 cleansing during the indictment period.

15 JUDGE SCHOMBURG: Submission by the Defence.

16 MR. OSTOJIC: If we ever get an opportunity to review the

17 document, we'll see that within the document the data clearly contains

18 refugees that came within the period immediately prior to the indictment,

19 specifically, prior to April 30th of 1992. I think other testimony

20 substantiated that from various witnesses, including the witnesses that

21 the OTP called.

22 So I think it is important, and necessary, when viewing this case

23 in its totality to determine what effect in the Prijedor Municipality

24 refugees that came from other areas, including Croatia and Slovenia, what

25 effect, if any, they may have had on the Prijedor Municipality during the

1 critical time as outlined in the indictment April through September of

2 1992.

3 JUDGE SCHOMBURG: May I ask to which column do you refer, K or L?

4 Datum Prijave or Datum Obrade?

5 MR. OSTOJIC: Datum Prijave is when they initially came in and

6 registered, so it would, in our submission, logical that if they are

7 registering as a refugee, that in fact at the latest point would be the

8 date that the registration shows. But as I hope Ms. Kovacevic will

9 testify, it came prior to that time, as she herself experienced in one

10 other area. So that's the date that they formally registered with the

11 centre, but it's our view, based upon what we hope the witness will

12 testify to, that people came months prior to that and merely registered

13 themselves during the period of time as reflected within the data.

14 We were hoping, as the Defence always does, to give the Court the

15 complete set of the document as it was given to us without redacting it.

16 If the OTP feels that the 1994 refugees in that area should not be counted

17 in the 32 or 22.000 refugees that were in the Prijedor Municipality during

18 that time period, we will make that amendment, and we'll strike those from

19 the record. However, this is an original CD that we got, so we left it to

20 the Court in its original form.

21 JUDGE SCHOMBURG: After first review, we can see that the data in

22 column K are in most cases somewhere in between 1991 and 1993. So I think

23 we have to decide later on the probative value of this document. But I

24 think we shouldn't waste too much time. Please introduce what the

25 different columns mean, and then we will draw the necessary conclusions.

1 MR. OSTOJIC: Thank you, Your Honour.

2 Q. Mrs. Kovacevic, thank you for your patience. If you can just tell

3 us and read for us the columns as they appear, and tell us what the column

4 itself below it, what appears before the designated title of the column.

5 A. The first column is personal code. That was the code under which

6 a person was registered. And members's code. I'm really not sure what

7 this means. And family, 1, 2, 3, members, Rodic, first and last name,

8 sex, date of birth, place of birth, municipality in which the person was

9 born. Republic. And then 014 --

10 JUDGE SCHOMBURG: [Previous interpretation continues]... Mention

11 also in which column we are in the moment. So, for example --

12 THE WITNESS: [Interpretation] All right, all right.

13 JUDGE SCHOMBURG: -- Column A, the number of registration, and B

14 and so on.

15 MR. OSTOJIC:

16 Q. Mrs. Kovacevic, I'll try to ask the question if you don't mind,

17 although it will not be leading, but just so that we could all follow it.

18 You explained the first column furthest to the left. You explained,

19 although let's have it again, what the second column is from the left.

20 What is that column for, which is designated as column B?

21 A. Column B, this is processed by a computer, this list. What I did,

22 my job was to have a conversation with the refugee first, take the

23 refugee's personal information, enter this personal information into a

24 form that was used. But we did all of this by hand. The image I can see

25 here, well right now I can't on the screen because it's lost. It's a

1 computerised image, and believe me, this is the first time I see it. I

2 never used a computer in my work. I was a specially trained -- I was a

3 trained teacher for children with special needs.

4 Q. Ms. Kovacevic, within that column B, you list three specific or --

5 or you identified previously three --

6 A. I assume that column B shows 01, 02, 03. I take that to mean

7 three family members, although it says three members, then family.

8 Perhaps it Rodic, Rodic, Rodic. We have three members here of that

9 family. The form that I would fill -- would be filled separately for

10 every member of the family. Now, how it was processed by a computer,

11 using the computer, I don't know. But I assume this to be showing the

12 same data.

13 May I just please explain the method we used to register the

14 refugee. The refugee would first come to us. We would talk to the

15 refugee. We would take his information. Enter it into special forms.

16 Then you would draft a decision that the person has been identified as

17 that particular person, and that the person was a refugee from whatever

18 town the person --

19 JUDGE SCHOMBURG: [Previous interpretation continues]... For a

20 better understanding of the entire document and the relevance that we can

21 really decide on the relevance, could you please be so kind and go through

22 column by column that we understand what this shall mean. You explained

23 to us column A, B. And now we are on the following, column C.

24 THE WITNESS: [Interpretation] Yes. C, that is name of person

25 registered Rodic Simo Radomir. That's father's name and last name of the

1 person being registered as a refugee.

2 MR. OSTOJIC:

3 Q. Yes. And column D.

4 A. Column D, "M" means male. Column E --

5 Q. I think it's obvious, but "M" under column D is for male. "Z" is

6 for female. Correct?

7 A. That's correct, yes.

8 Q. Column E --

9 MR. KOUMJIAN: Your Honour, if I could make a quick objection.

10 The witness indicated that she has never seen this before. Why present

11 this document through this witness who has no knowledge of its preparation

12 or the document? We don't know who prepared this or what its reliability

13 is. She has never seen it before.

14 THE WITNESS: [Interpretation] Can I just add something.

15 JUDGE SCHOMBURG: Before we decide on the relevance, please,

16 continue explaining what the meaning of the certain columns are.

17 Datum Rodjenja.

18 THE WITNESS: [Interpretation] Date of birth. Column C, date of

19 birth. Column F, place of birth. Column G, municipality where the person

20 was born. Column H, the republic in which the municipality where the

21 person was born is in.

22 JUDGE SCHOMBURG: What -- sorry to interrupt. What does it mean

23 is in? At what time?

24 THE WITNESS: [Interpretation] No, no, no. That's not what I

25 mean. Can you just put the image back as it was. A certain person was

1 born, for example, on 3rd of June, 1939. The village where the person was

2 born was Kriva Rijeka, the municipality was Bosanska Dubica. Bosanska

3 Dubica is in Bosnia and Herzegovina. That was the republic. That's what

4 these columns mean, F, G, H. It's all about the place of birth.

5 MR. OSTOJIC:

6 Q. Can you please proceed with the next column, I.

7 A. Column I and J, I'm not sure what these two mean. These might be

8 computer marks.

9 Now, let me tell you the following: I didn't use a computer. But

10 the forms we used, those forms were processed, electronically processed,

11 contained the following information: Profession, education, level of

12 education, current job, and the corresponding codes were entered. So the

13 form didn't say married, it had a special code for that, 14. So every

14 code had a special meaning. A person was a doctor, for example, single,

15 or unemployed, the level of the person's education with the corresponding

16 codes. And when forms were entered into a computer, these codes were

17 used.

18 Q. If I may, to assist the Court and the OTP, the other disks clearly

19 identify the number --

20 A. Here, have a look.

21 JUDGE SCHOMBURG: But I think we can abbreviate this procedure.

22 THE WITNESS: [Interpretation] The indicator, yes.

23 JUDGE SCHOMBURG: Isn't it true that we are discussing here people

24 living under a new address later in Prijedor and coming from a former

25 address as we can see it mostly from Zagreb, in most cases? When we go

1 further on, the column -- I can't see here on my laptop. Could we see the

2 following columns after O, P. Could you please go to this side and

3 further on.

4 THE WITNESS: [Interpretation] Yes.

5 JUDGE SCHOMBURG: Further, further, further, further. Here.

6 THE WITNESS: [Interpretation] Yes, yes. Yes, yes.

7 JUDGE SCHOMBURG: This was the previous address where the person

8 lived beforehand. Correct?

9 THE WITNESS: [Interpretation] Yes, yes, that's correct. That's

10 correct.

11 JUDGE SCHOMBURG: And then continue further, further. And then we

12 see another address.

13 THE WITNESS: [Interpretation] That's the new address where the

14 person is currently registered as living. That's inside Prijedor, after

15 reaching Prijedor from Zagreb or wherever.

16 JUDGE SCHOMBURG: So then, may I now hear from the Defence, what

17 is the relevance to know that people came from other countries -- from

18 other towns or regions to Prijedor?

19 MR. OSTOJIC: The Defence believes that it's extremely relevant

20 for two reasons, Your Honour: One, witnesses from the OTP testified that

21 there was an "atmosphere of fear" that was within the Prijedor

22 municipality. I think witnesses should be allowed to testify as to what

23 effect, if any, refugees came from a war-torn area who were kicked out and

24 moved into the Prijedor Municipality, what if any effect that had on

25 Prijedor as a municipality and on its people. Likewise, we believe that

1 some of the pressures exerted from individuals who claim or were at that

2 time identified as refugees, what if any pressure did they exert to people

3 who they considered were perpetrators of crimes against them.

4 For those two reasons, we believe that when witnesses testify

5 about atmosphere of fear and how the events in Prijedor transpired, and

6 when we discuss things such as a plan or a conspiracy of some kind in a

7 specific municipality, the Defence strongly believes that it should be

8 taken in context. And when you introduce a foreign object or people

9 outside of a municipality to a new municipality, we believe that it would

10 cause some disruption at the very least. And unfortunately, can result in

11 some graver or a graver situation.

12 JUDGE SCHOMBURG: May I ask a final question in this context, to

13 the witness: Did you also include what was the ethnicity of those people

14 coming, in this case apparently, mostly from Zagreb and then going to

15 Prijedor?

16 THE WITNESS: [Interpretation] When the information is entered, of

17 course, you ask the person about the person's ethnic background. In

18 99 per cent of the cases, the people who came were Serbs.

19 MR. OSTOJIC: We just now put on the screen one of the tapes which

20 is --

21 THE INTERPRETER: Microphone for the counsel, please.

22 MR. OSTOJIC: Thank you. We just placed on the video monitor one

23 of the tapes which has "IZIND" in the top left corner, and if I may just

24 ask the witness, although that's within the CDs that were provided to the

25 Court and the OTP.

1 Q. Can you just tell me what the screen before you, what does it

2 mean? Is that the indicator of the various ethnic backgrounds, so that

3 when you go back, you can look at the code and determine which person was

4 of which ethnic background?

5 A. Yes, yes, that's the indicator I was talking about. I didn't know

6 what it meant at first, 01 probably means that the person is a Serb. 02

7 probably Croat. And 03, Muslim. 04, others. And then you have other

8 codes and indicators following, housewife; occupation; health insurance;

9 where the person resides, with parents or in an abandoned house.

10 Then what sort of assistance or subsidies is the person receiving

11 in kind. 03, whether the person has anywhere to live in Prijedor, whether

12 the person has a place of residence in Prijedor. 04, whether the person

13 was put up in a special home. 05, whether the person received any

14 assistance in terms of clothing. And then 103, whether the person lives

15 in the person's own house. 104, whether the person is using social

16 housing. 002, level of education. A PK worker or an NK worker, and then

17 student or child and so on and so forth.

18 So these are the codes that I couldn't recognise a while ago

19 because we didn't have these specific codes on the forms that we were

20 using, because when we were using those forms we only entered the

21 information which would then be forwarded to the SUP where it would then

22 be processed on a computer.

23 JUDGE SCHOMBURG: Now we can hear the final arguments by the

24 parties on the relevance of these documents. When you have a glance on

25 the ethnicity, you will find out that 99 per cent were, in fact, Serbs. I

1 could identify 3 Croats. No Muslim. So could be the purpose of

2 discussing the immigration of Serbs to Prijedor? And it's open for both

3 parties to comment on the relevance, and then we will decide.

4 MR. KOUMJIAN: I can maybe cut it short, because I'm not

5 objecting. I don't think it hurts me. I would make a couple

6 suggestions. One, that because this is going to create huge problems if

7 we ask to translate this entire document, I think it is of marginal value

8 that only the heading be translated. And secondly, that it be marked

9 confidential because it has person's addresses.

10 MR. OSTOJIC: I only disagree with the OTP that it has any

11 marginal effect, and I also take exception that they think it doesn't

12 hurts them. It's not a question of hurt or help. It's a question of

13 getting to the truth. They knew this information as well and they could

14 have brought this information forward, as they did other information.

15 I do agree with their suggestion, however, that when this does get

16 translated, although I thought we pretty much covered all the significant

17 parts, that the translators do confine themselves to the categories and

18 the columns and the various indicators that were within the CDs. But I do

19 think that this is of extreme value to all the parties in the case.

20 MR. KOUMJIAN: I won't comment on Mr. Ostojic's comment that we

21 knew about this and could have gotten it ourselves. It arrived today.

22 JUDGE SCHOMBURG: I think...

23 [Trial Chamber deliberates]

24 MR. KOUMJIAN: May I add one comment -- actually, we join in

25 asking this to come into evidence. We think the fact that such detailed

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1 records of individuals coming into the municipality does have relevance to

2 our allegations.

3 JUDGE SCHOMBURG: I don't want to comment on this. But I think

4 following our deliberations, this document is as such admitted into

5 evidence. But it need not be commented today by the witness before us

6 because it's, in the way it's built up, self-explanatory.

7 If only the witness could tell us a little bit more on the group

8 of persons she, together with others, interviewed and that formed the

9 basis for this. And then later on, we can use the CD-ROM as such without

10 any further translation. And then it should be treated as a sealed

11 exhibit because, no doubt, there are personal data included, and I'm -- to

12 be honest, I'm surprised that we receive these documents under data

13 protection law of some countries, this would not be admissible. But we

14 have it now before us, but it has to be strictly under seal. So

15 therefore, admitted into evidence as D43 under seal. And we need no

16 translation and no further explanation save related to the source. And if

17 you then please continue with the testimony of the witness before us.

18 MR. OSTOJIC: Thank you, Your Honour.

19 Q. Thank you, Mrs. Kovacevic. If you heard the Court's comment and

20 suggestion, I think we need to know if you could tell us a little bit more

21 on the group of persons that you, together with others, interviewed, and

22 that which formed the basis for the material that we reviewed here.

23 A. I have already said that I started working with the registration

24 of refugees in 1994, and I can say that I worked there in 1994, 1995, and

25 1996. This may seem a bit odd, but it is true, and I also worked there in

1 1997. Why were the refugees registered for such a long time?

2 Firstly, a refugee who came to us in 1995, their number was so

3 huge that we couldn't register all of them. We registered a hundred every

4 day, and they waited in front of our doors for days and nights. They

5 waited their turn to get their refugee identification papers. When they

6 received their refugee identification papers, that meant everything to

7 them. It was the proof of who they were. Based on those registration

8 papers, they could obtain health care, they could go to seek medical

9 services. And based on that document, they were entitled to humanitarian

10 aid. Bearing in mind that all these peoples did not have any money or any

11 other means for life, they had to be provided for, and the refugee

12 identification paper was just the beginning of their way to deal with all

13 the other questions. It was not a small group of people. We are talking

14 about thousands upon thousands of people.

15 Between 1994 and 1997, we registered 22.000 people. We talked to

16 everybody. We took their personal data, and we tried to help them with

17 dealing with their problems in Prijedor. That was my role, mine, and the

18 role of the other three people who worked with me. So I tried to help

19 them to solve their essential problems once they reached Prijedor from

20 other places.

21 Q. I do have two more questions on the effect of refugees, if I may,

22 unless the Court feels that I should strictly move to another area.

23 JUDGE SCHOMBURG: We continue for another five minutes to the next

24 break for a quarter of an hour. But that we really can understand it, you

25 registered these 22.000, if not more, people, 99 per cent Serbs, coming to

1 Prijedor?

2 THE WITNESS: [Interpretation] Yes, that's correct.

3 JUDGE SCHOMBURG: May I ask you, why did you register primarily

4 99 per cent Serbs?

5 THE WITNESS: [Interpretation] I'm afraid I have been

6 misunderstood. We registered everybody, all the refugees who reported to

7 us during that period of time. But 99 per cent of them were Serbs. There

8 were also Muslims who fled from Croatia and settled in the federation of

9 Bosnia-Herzegovina. But the national composition of the refugees was as

10 such. There were 99 per cent of Serbs, and there were 1 per cent of other

11 ethnicities. But we registered everybody who reported to us as refugees.

12 In order to prove to us that they were refugees, they had to show

13 to us a document proving that they fled from a certain place. Either an

14 identification document or a passport, any proof that they used to live in

15 the place from which they fled. We took any such document as proof that

16 they are indeed refugees from somewhere.

17 JUDGE SCHOMBURG: And also, for a better understanding, you

18 mentioned the number of 22.000 people. If I compare with the CD-ROM

19 provided by you, it ends with 31.594. And as you indicated beforehand,

20 it's reflecting not only the number of persons, but also the families. So

21 all in all, it would be more than 31.594 persons coming to Prijedor. And

22 among them, about 99.9 Serbs. Is this correct?

23 THE WITNESS: [Interpretation] More or less that would be that.

24 But I also said that I started working in 1994. The registration of

25 refugees started even before that. And that job was done by other

1 people. Ever since I came over, about 22.000 refugees were registered.

2 There were even more refugees than that, but in order for them to register

3 with us, they had to show us some proof of their refugee status. If they

4 didn't have any document to prove their refugee status, we couldn't

5 register them. So there were even more than that, even more than that

6 number that I've mentioned.

7 JUDGE SCHOMBURG: Thank you.

8 If you continue for about five minutes.

9 MR. OSTOJIC: Thank you, Your Honour.

10 Q. Thank you, Mrs. Kovacevic. Just quickly, I want you to focus on

11 the time period prior to April 30th of 1992 for my following couple

12 questions. Was there, ma'am -- I know you didn't work at the centre for

13 welfare and social services in 1992, but was there an influx of refugees

14 that came from other republics or other areas into Prijedor Municipality

15 prior to April of 1992 that you yourself personally observed and

16 experienced?

17 A. In 1992, I worked in Cirkin Polje. Refugees started coming to

18 Prijedor already in 1991. How did I know that? We started seeing a lot

19 more people in the streets than usually. Then I talked to people in my

20 workplace and my colleague every now and then would tell me, my brother

21 and his wife came from Zagreb with their children. The house is crowded.

22 That's how I learned that refugees started arriving from Zagreb. But not

23 only from Zagreb, but from all over Croatia. A small number also came

24 from Slovenia.

25 When I talked about the way they lived, they told me, they go to

1 the Red Cross to be registered for humanitarian aid. And then also, there

2 was also evidence to be seen in the hospitals, in the health centre,

3 because in the waiting rooms, people tend to talk amongst each other.

4 That's one part of the story.

5 Secondly, when I worked at the social welfare and services centre,

6 they would come to us for various reasons, not only for the ID papers, but

7 also when they wanted to enroll children at school, when they wanted to

8 change their address. For example, they came from Zagreb or somewhere

9 else in Croatia, and they lived with their parents. And then they found a

10 place of their own. In order to be registered at the new address, they

11 had to come to us first so that we could register the change of their

12 residence. So while I worked in that job, I spoke to the refugees, and

13 they would give me the entire history of where they came from, when they

14 came from, so I could build a picture.

15 Q. Just briefly one last question, if I may, on this issue, so that

16 we can take our break, Mrs. Kovacevic, to the best of your recollection,

17 what effect did the influx of these refugees from Slovenia or Croatia have

18 on the general municipality of Prijedor? If you noticed any, please share

19 with us that which you noticed and experienced.

20 A. Of course it had an effect on Prijedor, primarily a psychological

21 effect. Refugees were a novelty to us. The notion of somebody being a

22 refugee was new. And the situation that they flew from was also new. It

23 was a psychological burden for all people because everybody realised that

24 they could find themselves in a similar situation to have to flee the

25 place where they lived, that one could lose their job, that one could lose

1 their house, that one could lose their life. That was a psychological

2 burden that had a huge effect on me personally, because I realised that

3 war was a reality.

4 The second effect was the economic effect on the town of

5 Prijedor. The situation was difficult. Even before that, there was a

6 huge number of unemployed people. There was a high level of poverty.

7 There were a lot of beggars on the streets. That was the second type of

8 burden. These people had to be provided for. They had to be provided

9 with food, with clothes, because they came barefoot and barehanded.

10 Some people had nothing but plastic bags in their hands. Some of

11 them, in order to flee Croatia, they just had to pretend that they went to

12 do some shopping. That's why they had plastic bags in their hands. As a

13 matter of fact, they didn't go shopping. They fled their houses in order

14 to save their hides. I don't know whether the following information is

15 relevant or not, but one of the persons working with me on the

16 registration of refugees was Mrs. Ljiljana Babic who came from Zagreb and

17 who told me a lot about what was going on there. And she told a story

18 about how she fled together with her husband, how the two of them had fled

19 Zagreb.

20 Therefore, I can tell you that I was quite familiar with all of

21 these problems. I heard from the people that I worked with as well as

22 from the people that I had to see in my official capacity. It was a great

23 fortune that the situation was rather peaceful in Prijedor so that the

24 municipal government could accept these people and provide for them,

25 organise their accommodation. It was -- I'm talking about the year 1991.

1 MR. OSTOJIC: Thank you, that's all I have on this issue, with the

2 Court's permission, and I think it's a good time for a break.

3 JUDGE SCHOMBURG: It's time for a break. But at the same time,

4 the Trial Chamber takes the opportunity to ask the Defence to concentrate

5 on that what we could read on the proffer. And due to the shortage of

6 time, we would ask you to conclude your examination-in-chief within the

7 next 30 minutes after the break.

8 The trial stays adjourned until 5 minutes past 4.00.

9 --- Recess taken at 3.50 p.m.

10 --- On resuming at 4.08 p.m.

11 JUDGE SCHOMBURG: Please be seated.

12 MR. OSTOJIC: Thank you, Your Honour.

13 Q. Good afternoon once again, Mrs. Kovacevic. I'm going to proceed.

14 I apologise for the confusion that I may have caused with respect to the

15 tape. I'd like now to turn our attention and focus on a couple of

16 different areas. And with all due respect, I would like you, if you can,

17 to describe for us your late husband Milan Kovacevic. Tell us the type of

18 person and individual that he was.

19 A. My late husband, first and foremost, he was my husband, the father

20 of my son. He was a doctor. As a husband, he was the Balkan-type

21 husband. He looked after his wife, making sure she had enough to eat and

22 a roof over her head, making sure she was protected if attacked. He never

23 brought me flowers. He never gave me any special presents for the

24 Mother's Day, but I think he respected me, and I think he loved me. He

25 loved all people. He was a humanist, and people liked him. He was an

1 exceptional father, unlike me as a mother.

2 Sometimes I yelled at my son; sometimes I even hit him. He never

3 as much as raised his voice. He never complained about anything, even if

4 his son was about to fail in five different subjects in school. He never

5 said anything. And my son got some stick from me for that. And Milan

6 asked him, How many subjects are you about to fail? He said, Five, dad.

7 And he gave him a hundred German marks for each of the subjects totalling

8 to 500 altogether. And he said, You have to pass all these subjects. And

9 in a month, as a matter of fact, he did. And he told me, You're supposed

10 to be trained to deal with kids, and I'm a doctor, but obviously I'm

11 better at these things than you are. As a man, he was good in almost in

12 almost everything, and I often used to tell him, complain to him, that he

13 was a better man to other people sometimes than he was to me.

14 He did a lot of good to other people. He told me once when I had

15 a problem that his personal motto, his slogan, was help whoever you can,

16 but never do anyone any harm. You choose a man to spend the rest of your

17 life with. What do you think about them? You think about if he's a good

18 person, if he's employed or unemployed. But when I met him as a man, I

19 realised that what I really loved about him is that he had a deep feeling

20 for the common man, for the small man, and he had an instinct to protect

21 people who weren't well enough. And he had a great instinct to shield

22 people who were suffering, maybe that was because a doctor by profession.

23 Now speaking of my family or speaking of other people, unrelated

24 people even, he always had this instinct to help people, he would always

25 help people any which way he could. I keep meeting people, even today,

1 who thank me for what Mico once did for them, for his help in receiving

2 people to hospital to be treated and in treating them the right way.

3 Sometimes, he was on duty even when he wasn't required to be just because

4 someone asked him to.

5 I spent over 28 years of my life with this man. I could talk

6 about him for a very long time. He was a very honest person. That's a

7 character trait that I respected very much in him. He was not a

8 materialist. He didn't care about very small things in life. He was a

9 flexible person, too.

10 Q. Thank you. If I may, Mrs. Kovacevic, specifically over those 28

11 years, but primarily within the period of 1992, did you ever observe or

12 see whether Dr. Kovacevic ever exhibited any ill will or hatred against

13 Muslims or Croats?

14 A. During the 28 years that we spent together, not a single time.

15 Really, not a single time. I never noticed Milan distinguishing on a

16 national basis. He tried to look for the person and see if the person was

17 a good person or a bad person. We discussed people sometimes, and I used

18 to criticise people. And he would always tell me, Well, what right do you

19 have to criticise other people? That's what he always told me. And

20 that's exactly how he was himself. He refrained from judging people and

21 from criticising people. I think he had more friends where he worked,

22 colleagues, Muslims and Croats, than Serbs. He was close friends with the

23 Resic brothers. He didn't talk that much about his job at home. It was

24 just the sort of man he was. Once he was home, he stopped thinking about

25 his job.

1 He was home finally, and his job was never discussed at home. He

2 would leave his problems behind. If he did say anything, and whenever he

3 talked about, he would talk about the Resic brothers. If there was an

4 operation, usually these two brothers sometimes would have an argument

5 assisting him during the operation, and Mico was always the one to calm

6 them down and to bring peace between them. When he was the manager of the

7 hospital, there were a lot of people working there. But mostly non-Serbs,

8 I would say, accounted for the majority of the hospital's employees.

9 Q. Specifically in the time period of 1992, share with us if you will

10 whether Milan Kovacevic discussed with you the political situation in

11 Prijedor and whether he thought that a peaceful solution with all ethnic

12 groups could be reached.

13 A. As I said, Mico never discussed his work at home. He did not want

14 to give me additional burdens and worries. But I was the one who asked

15 the question. I said, Mico, what's happening? Is it possible that a

16 conflict will occur? However, I must say something before I go on. After

17 the elections, he wasn't thinking about going into politics. There were

18 certain pressures, though, and then he agreed. But he was absolutely

19 enthusiastic about the way the Serbs, Muslims, and Croats cooperated and

20 the way positions were distributed among the three different ethnic

21 groups. He said they found it easy to agree on everything because it was

22 now finally multiparty system and people expected problems to arise.

23 However, at the beginning, at the initial stage, everything was

24 running very smoothly. I was even surprised by the degree of tolerance

25 that was manifest. And everything worked smoothly. You could even feel

1 it, the way people communicated with each other. One piece of information

2 I'd like to share with you, he came to me once. He said: "Is there a

3 suit in our house?" I asked him, "What, you're getting married again?" I

4 was joking. And he said, "No, I've just been invited by Mr. Cehajic to

5 celebrate Bajram with him." So he dressed up and left for Kozarac. That

6 was back in 1991. When he came back, I asked him, "So, how was it?" And

7 he said, "Well, it was really, really fine. I had a very fine time."

8 Q. Was Milan Kovacevic a man who advocated war or peace throughout

9 the period of time that you knew him?

10 A. As a man, he never had a single quarrel with anyone. He would

11 always tell me, the only quarrels I have had in my life were with you.

12 And I would always tell him, well I'm the only person you're married to.

13 You're not married to anyone else I hope. He simply avoided conflict,

14 even verbal conflict. He would never -- he would always back down even if

15 the altercation threatened to become sharper. He would always just

16 withdraw himself, and he was -- he kept avoiding conflict with other

17 people. He was a very -- he was a person who didn't like conflict.

18 Q. Moving in the period from April 30th through approximately May

19 30th --

20 THE INTERPRETER: Correction, there was not a single person in

21 Prijedor with whom he ever entered into a conflict.

22 MR. OSTOJIC: Thank you.

23 Q. Moving to the period from the 30th of April, approximately,

24 through the 30th of May, 1992, can you tell us the nature and extent of

25 any influence that Milan Kovacevic had on the town of Prijedor during the

1 summer and spring of 1992, and specifically because of our time

2 constraints, I'm going to direct you to a conversation that you shared

3 with me which included Eso Sadikovic.

4 What influence, if any, did Dr. Kovacevic have at that time

5 period?

6 A. As I've pointed out, whatever Mico was doing, and I could see that

7 he was always making an honest effort, he really tried hard to keep the

8 relationship between Muslims and Croats, which I think were reflected more

9 among the people than at government level. He tried to keep the

10 relationship smooth. I would always ask him the same question, Mico,

11 what's going on? What's going to happen. He would always tell me, It's

12 all going to be fine. Just wait and see. We're working on it. No one

13 wants to have a war. I asked for my own sake, because if there was to be

14 a war, I thought I would just leave and go back to Serbia. However, Mico

15 was convinced that the war wouldn't happen. He was totally convinced. He

16 would always say, these people are reasonable. We're all reasonable

17 people. There must be a way for us to find a solution to reach an

18 agreement. He used to tell me all these things.

19 So I listened to him, and then whenever I socialised with other

20 people, I could see that there were divisions, that people started

21 grouping in terms of their ethnic backgrounds, even at work. He kept

22 telling me everything would be all right. But somehow I just couldn't

23 bring myself to believe it. I thought he didn't have enough insight into

24 what was happening among the common people at the time. But still, he was

25 totally convinced that on both sides, people would find a way to reach an

1 agreement and to smooth out the differences.

2 I remember we were on our way back from the village, and we were

3 standing outside the village after the takeover. Eso Sadikovic arrived,

4 and Mico was very fond of this man, because they were alike. They were

5 people who had a lot of things in common. So Sadikovic came up to Mico

6 and said, I'll try to quote him: "You know, those idiots of mine over

7 there in that village, those fools - I'm not from that area, so I didn't

8 remember the name of the village - they are creating problems again. They

9 set up a barricade. Let's just go there and talk to these people for

10 God's sake."

11 Mico, without saying a single word, joined Eso. They drove there

12 in a jeep. They stayed there for a long time. It was almost midnight,

13 and Mico still hadn't come back. I was already scared, because I did hear

14 a number of things about Eso, a number of things were being said about

15 him. I wasn't sure, but I had seen him before with other Muslims who

16 insisted on ethnic divisions at the time. And with Mico, the sort of

17 person that Mico believed Eso Sadikovic to be was not exactly how he

18 struck me. But I said okay, if Mico had faith in him, then it must be all

19 right. And just before midnight, he came back home. And I said, What did

20 you do there? And he said, Well, we sat down with those people, we talked

21 to them. We had brandy together, and that's how the whole thing ended.

22 So this was still a period when Mico could keep certain things under

23 control.

24 Q. Eso Sadikovic was of what ethnic background?

25 A. I think he was a Muslim.

1 Q. Staying with the theme of influence, did there come at any time a

2 request from you, ma'am, to your husband to provide any type of security

3 within the apartment complex in which you lived? And if so, what, if any,

4 influence did Milan Kovacevic have to provide any such protection or

5 security?

6 A. As I've said before, in our building, we had both Croats and

7 Muslims, families, people who lived there, and Serbs, too. That was after

8 the takeover. Military-aged Serbs at that time were probably somewhere on

9 the front line. I didn't know where exactly. But they weren't in their

10 flats. So the only people left in the building were elderly people and

11 children, as well as Muslims who were not members of any army. They were

12 not organised in the military way.

13 I always felt an outsider there. I wasn't from the area, so I

14 didn't even know which villages were Muslim villages and I didn't have any

15 idea about that. They told me that Draskovic was a Muslim village, so I

16 pleaded with Mico because I was afraid. Mico was a politician, he was

17 likely to be a target of someone's revolt or resentment or someone's

18 ethnic resentment. I was afraid I wouldn't let him go there. I said:

19 "Mico, please, can you just make sure one thing. I would like to have a

20 police officer pass by sort of every once in a while to just have a look

21 just to be safe." Because there was no police in that part of town. Not

22 a single police officer. So the windows of my flat faced both sides of

23 the street. So I was looking through my window and I could see that

24 outside, Muslims assembled in two groups, and I thought they would head

25 for the building.

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1 I was scared, so I asked him to arrange for a police officer to

2 just patrol the area, maybe pass by every once in a while. And he

3 replied: "I'm not the one who decides where police officers should be."

4 And I said, Well, Mico, at least you can look into the matter. You can

5 see who is in the charge. I'm not asking for a special police officer to

6 be assigned to my building, but at least I need to know that I have

7 someone to speak in case anything should happen. And he said, "No, I just

8 can't do that." And I was angry with him. I said, "What are you doing?"

9 He said, "I'm trying to keep the worms from eating you up." He said, "I'm

10 making sure you have enough to eat, you have enough to drink. But I can't

11 be around all time, and I can't arrange for someone to keep watch over you

12 the whole time."

13 Q. Just moving quickly along if I may based on the time constraints,

14 I'm going to ask you if you can, ma'am, to describe for us the

15 relationship if you know between Dr. Kovacevic and Simo Drljaca in the

16 spring and summer of 1992. Specifically, I would like to know whether you

17 formed an impression as to whether or not during that time period, spring

18 and summer of 1992, Dr. Kovacevic was a superior to and could order

19 Simo Drljaca to perform any or certain tasks. Share with us please your

20 impression by first telling us what the relationship was and whether or

21 not Dr. Kovacevic could influence any request or order to Simo Drljaca.

22 A. As I've said before, Mico didn't really talk about his work. I

23 had information, I was aware that Simo Drljaca was the head of the SUP.

24 What their personal relationship was between, I mean between the two of

25 them or professional relationship, I really don't know. I only met

1 Simo Drljaca once. And this meeting may have taken place in May or June,

2 but I really can't remember. Because there were too many things at the

3 same time. So many things happening. I really --

4 Q. Pardon me. May or June of what year, and then I would ask you

5 just to slow down a little bit so the interpreters can catch what you're

6 saying.

7 A. All right. That was in 1992. I went to our cottage, which was

8 about 10 kilometres from Prijedor. It was in the afternoon, because I

9 worked the morning shift. I left in the afternoon, and I saw Mico and

10 Simo. Mico was lying on the grass, and Simo was standing there, which

11 means that he only just got there or perhaps he had been about to leave.

12 I said hello, I greeted them, and that was my first meeting with

13 Simo Drljaca. I did see him occasionally out in the street, but that was

14 when we were actually introduced. We said hi, we had a chat. And then

15 Mico stood up and offered to brew some coffee for us. I said no matter,

16 Well, no matter. I'll make some coffee and you just stay here and talk to

17 Simo.

18 At that moment, I used this meeting with Simo to ask him several

19 questions about events in Prijedor that really bothered me. At that time,

20 I'm talking about June, this was after the events in Kozarac, I noticed

21 that people did nothing else but just carry other people's things about

22 the town. They were loading other things on to cars and lorries. They

23 were driving other people's cars. And I asked Simo Drljaca:

24 "Mr. Drljaca, will you do anything to put a stop to all this crime?" And

25 he said: "That will be difficult." And then Mico came back with coffee,

1 and he said in passing: "Can you imagine what happened the other day? I

2 received word from Kozarac that a convoy of tractors and lorries was

3 headed our way. And I sent a patrol out to intercept them. They opened

4 fire. What could I do? I told my policemen to withdraw, to go back."

5 And I told him, "Well, this is not a solution. If you had managed to

6 catch a single Serb who was stealing other people's things and hanged him

7 right here outside for everyone to see him, I don't think it would occur

8 to anyone again to do anything like that." And then he told me, "Well,

9 soon, there will be more Serbs in Keraterm, if they keep on going like

10 this, than Muslims. They will soon outnumber the Muslims there in

11 Keraterm."

12 At that moment, I realised that even he wasn't really able to put

13 a stop to this. I thought that was just down to people's particular

14 behaviour. That was in connection with that particular meeting we had. I

15 never saw Simo again. But the impression I got then, and it stayed with

16 me later, I thought it was important.

17 First and foremost, Simo was considered a brave man. He was good

18 looking. He was tall. But one thing I couldn't help noticing, Mico

19 didn't really like him at all. And I asked Mico, "Why don't you like him?

20 Because he better looking and taller than you?" And Mico was really

21 angry. He had to reply to begin with. He said: "This Simo, this Simo you

22 like so much, he once pulled a gun at me." Why and under what

23 circumstances exactly Mico never told me. But I did notice that he wasn't

24 particularly fond of him.

25 Q. If I may, again, I'm not sure if I can just have a few more

1 minutes to proceed. Thank you. I'm going to move to another area,

2 although we can discuss and I'm sure we'll have an opportunity to share

3 some other views in connection with your impressions of individuals.

4 Can you tell in respect to Dr. Milomir Stakic, do you know him?

5 A. Stakic?

6 Q. Yes.

7 A. Yes, I know Dr. Milomir Stakic.

8 Q. Can you share with us, ma'am, when is the first time that you

9 personally met with Dr. Milomir Stakic or when you were first introduced

10 to him?

11 A. The first time I saw Dr. Stakic was at the funeral of my husband's

12 mother. That was in September of 1992.

13 Q. Can you tell us if at any time, from April through September of

14 1992, whether or not Dr. Stakic ever had attended any meetings at your

15 home with Dr. Kovacevic that you're aware of?

16 A. Maybe I didn't tell you, but I will. Mico did not like anybody

17 coming to our house. Very few people were allowed to our house. There

18 were usually people from his early childhood. His business associates

19 rarely came. When he worked as a doctor, and one of his fellow doctors

20 came, because they needed to ask him something, he wouldn't let them in.

21 He would rather put something on and go out to meet with that person.

22 Throughout all that time, I don't think that Dr. Stakic was ever

23 in our house.

24 Q. Share with us, if you will, Dr. Kovacevic's view or thoughts and

25 impressions of Dr. Stakic, if Dr. Kovacevic ever shared them with you, and

1 tell us, if you will, what he thought of him.

2 A. Mico was a man of few words, and his actions spoke louder than his

3 words. But I know that he liked Dr. Stakic. He referred to him as a kid

4 or "curle." "Curle" is an expression that stands for a young, gullible,

5 honest, a person of integrity, or something like that. A person who needs

6 to learn. I knew that he liked Dr. Stakic. He liked to hang out with

7 him. He liked to go to his house in the countryside. Mico did not have

8 parents, but they would go to his parents' house. And Mico also liked to

9 go to Dr. Stakic's house.

10 Dr. Stakic had two children, and my husband liked young children.

11 And I believe that Dr. Stakic's company was pleasant for Mico. And if

12 Mico socialised with somebody, that meant that he respected him for his

13 human qualities. And if my husband respected somebody, that meant that

14 that person was educated, that he could talk to him. At home, Mico did

15 not discuss politics at all. We could talk about a lot of things, but

16 never politics.

17 Q. Just for the record, I'm having some assistance. I don't think

18 the word humanitarian was translated. But I think the witness said

19 "humanista" to the extent that it may be of any assistance.

20 Finally if I may with the time period, can you share or tell me

21 specifically and concretely whether Dr. Kovacevic ever exhibited any

22 discriminatory intent against Muslims who were living with him in the

23 Prijedor municipality or Croatians who likewise were living and working

24 with him in the Prijedor Municipality, at any time but also including the

25 spring and summer of 1992.

1 A. Not only did he not express any such intents, but he made

2 everything possible to avoid conflict. I felt sorry at times for him. We

3 lived in Germany. We knew the meaning of true democracy. And he really

4 couldn't understand how it was possible that two normal people living in

5 the 20th century couldn't agree on things in a peaceful way. He would

6 always say: "We will reach an agreement." He told me: "I have problems

7 with Mujadzic, but I don't know. He may be getting instructions from God

8 knows where. Cehajic and I get on well. We will agree, and we agree on

9 something." And on the following day, he changes his mind. And I believe

10 that he is under the influence of Mujadzic. I'm sorry that I don't have

11 the time, and the circumstances are such, to show you how much effort he

12 invested in order to avoid the conflict and the final outcome of the

13 situation.

14 I remember when the Serbs took over, he was very unhappy. He was

15 a very unhappy man. He was so unhappy that it hadn't happened in the way

16 it was agreed. He was not a stupid man, you know. He knew that a moment

17 would come when tensions would be hard to control. And Mico would often

18 tell me: "You may try as hard as you want to up on the top, but people

19 are frustrated. There's a huge division among people in the situation of

20 the economic crisis. People are hungry." And then all the images that

21 were conveyed to us from Croatia. Whatever happened in Croatia, the

22 refugees from Croatia created such a tension and such a division among

23 people that I, as a Serb from Serbia, had huge problems.

24 Being from Serbia is even worse than being a Serb from Bosnia. In

25 the eyes of Muslims, it is even worse. That is something that I have -- I

1 forgot to tell you. I had a neighbour who lived one floor above me. He

2 was Muslim. And he came to me and told me that it would be best for me if

3 I didn't live there with my son because there's another Muslim who has an

4 order to evacuate, to kill us, to strangle us with a piece of wire.

5 That's why I asked my husband to arrange for a policeman to patrol down

6 the street every now and then. And then when he told me that he couldn't

7 do that, I realised that he was really not in the position to do that, and

8 then we left to -- for Urije to live there.

9 MR. OSTOJIC: Thank you. Just a couple more, if I may.

10 THE WITNESS: [Interpretation] That is just a story that I have

11 just remembered, an anecdote.

12 MR. OSTOJIC:

13 Q. Thank you, I would just like to ask you, Mrs. Kovacevic, if you

14 were able to during the time of the spring and summer of 1992 to observe

15 whether or not Dr. Kovacevic could influence, control, direct, or order

16 the army or military men to perform certain tasks in the Prijedor

17 municipality? Was he able to do that or not?

18 A. I really don't know. I'm a layperson as far as politics and -- or

19 political organisations are concerned. However, the military and the

20 police never were influenced or could be influenced by the civilian

21 authorities. To my mind, the army is something that did not belong to

22 everyday life. We, as laypersons, did not know anything about its

23 functioning and its organisation. So the military is something that was

24 always separated from the civilian authorities.

25 The police, during the socialist times and later on, as far as I

1 know, and as far as I could see in terms of what Mico could order the

2 army -- I don't know whether the president of the state could issue any

3 orders to the army, but Mico certainly couldn't. The police also had its

4 own organisation. And the president of the municipality couldn't issue

5 orders to the policemen in the street, let alone to a higher-ranking

6 police officer.

7 I was present when a policeman stopped Mico on the street and

8 asked him for his driving license and traffic license. Mico, mind you,

9 had not done anything to deserve that. He was just pulled over, and the

10 policeman asked him for his ID and for his driving license. If Mico had

11 been any authority in the eyes of the police, then I'm sure that he

12 wouldn't have been stopped for no reason at all. So my answer is I don't

13 think so. Not only that I don't think so, I'm absolutely convinced that

14 he couldn't influence either the military or the police.

15 Q. Thank you very much, Mrs. Kovacevic. I'm going to turn the floor

16 over, although the Defence would like to address the Court outside of the

17 witness's presence in connection with other related materials before we

18 close today. But thank you very much on behalf of Dr. Stakic and the

19 entire Defence team.

20 JUDGE SCHOMBURG: Let's wait and see how long the

21 cross-examination will take us. Maybe we will then have the possibility

22 to ask the one or other question. But let's don't waste any time.

23 Mandatorily, because the translators, the translating team working

24 now, has a well-deserved weekend as of 5.00, we have to make a break at

25 5.00 sharp.

1 MR. KOUMJIAN: Good afternoon, Mrs. Kovacevic.

2 Cross-examined by Mr. Koumjian:

3 Q. In the interests of time, I'm going to go directly to questions.

4 A. Good afternoon.

5 Q. You told -- you described your husband. Am I correct that your

6 husband, Dr. Kovacevic, had many friends among Muslims, particularly his

7 colleagues in the medical profession - you mentioned a few of those

8 names - he was well known, he was a socialable person, he was liked -- he

9 was outgoing, he liked to be out, and he knew many people?

10 A. Yes, yes.

11 Q. Can you tell us how many of your friends and your husband's

12 friends of Muslim and Croat ethnicity were killed in 1992?

13 A. I really don't know. I had some girlfriends, and they are alive,

14 as well as their husbands. And as for Mico's friends, I know that

15 Eso Sadikovic was killed, Raskovac -- no, one of them died of natural

16 causes. One of them is still living. Dr. Iglic still works in Prijedor.

17 He worked throughout the war, and he was the head of the medical service

18 throughout the war. Dr. Miljus who was a Croat was the head of a service

19 while he was there. Dr. Petrov as well. He is still in Prijedor. All of

20 our friends save for Eso Sadikovic are still alive.

21 When you say "friend," I don't know what you mean. But one person

22 can have up to three or four friends, and others are just acquaintances.

23 And I'm talking about real friends, about the people who were our true

24 friends.

25 Q. Did you think the fact that these people were Dr. Kovacevic's true

1 friends influenced the fact that they survived the conflict? In other

2 words, did he save them?

3 A. These were his true friends. If he could have saved them, he

4 would have. A little while ago, I told you that he would say, "help

5 people whenever you can help them. If you can't help them, at least don't

6 do them any disservices." I'm sure that he didn't do any disservices to

7 any of his friends. If he could in any way help them, I'm sure he did.

8 And it is a fact that save for Eso Sadikovic, everybody else is alive.

9 Q. In fact, your husband used to tell people that Dr. Eso Sadikovic

10 was the only person he could joke with. They both had that irreverent

11 sense of humor, and they both were very outgoing persons. Correct?

12 A. Yes, that's true.

13 Q. Did your husband tell you who ordered Eso Sadikovic to be killed?

14 A. No, he never talked about unpleasant things. I could only tell by

15 the expression on his face that he was thinking about something

16 unpleasant. But he never talked about those things.

17 Q. Did you ever ask him who was responsible for the killing of so

18 many persons in Prijedor in the camps, and particularly his fellow

19 colleagues, medical doctors?

20 A. I never asked him that, to be honest. I never asked him who was

21 responsible, because I lived in Prijedor at the time. I don't know

22 whether you have managed to get the picture of the situation in Prijedor.

23 I can tell you that I, as a Serb, could be killed by anybody. I found

24 myself in a situation where two guys held me at a gunpoint, and they

25 wanted to confiscate my car. If my friend hadn't happened to pass by, and

1 if I hadn't given them my car, they would have killed me, I'm sure.

2 Q. Ma'am, I'm sorry I have very limited time because we want you to

3 be able to go home. So if you could just limit yourself to answering the

4 specific question that I ask.

5 A. All right, then.

6 Q. Did you ever ask your husband or did he ever talk about -- I'll

7 withdraw the question and start again.

8 Did your husband ever express any regret for the fact that so many

9 persons that you knew, that he knew, were killed in the camps, that large

10 areas of Prijedor such as Kozarac and Stari Grad were destroyed, and

11 thousands of people of non-Serb ethnicity were killed during the time that

12 he was on the Crisis Staff and president of the Executive Board of

13 Prijedor? Did he ever express any regrets about that?

14 A. What do you mean by "expressing regrets?" He suffered

15 tremendously for everything that happened -- that was happening in

16 Prijedor. So much so that he never smiled. When he was at home, he never

17 smiled. Once he came home, he told me: "This is a madhouse. We are

18 lunatics. We are crazy people. But he didn't mean only Serbs, but

19 everybody, that everybody had gone totally crazy and nobody could control

20 people. And he thought that the lowest of -- the lowest human feelings

21 surfaced, and he suffered tremendously because of that.

22 Q. Did he tell you who he felt was responsible for the killing of so

23 many persons?

24 A. No, no, never. Never. He never told me who was responsible. He

25 himself found everything absolutely impossible to understand. He realised

1 that the things have gone beyond anybody's control, and that everybody did

2 everything they wanted to do. Not only his control, but that people could

3 not control their own actions, that people were no longer normal. That's

4 my opinion.

5 Q. Your husband knew Dr. Minka Cehajic and her husband, the former

6 president, Muhamed Cehajic. Isn't that correct?

7 A. Yes.

8 Q. Did your husband ever tell you who ordered the killing of Dr. --

9 Professor Muhamed Cehajic?

10 A. No, I'm not even sure that he knew that. I don't think he did.

11 Q. Did he ever tell you who was responsible for what happened to

12 Professor Cehajic?

13 A. No, never.

14 Q. Your husband resigned his position in January of 1993 as president

15 of the Executive Board. Correct?

16 A. Correct.

17 Q. He resigned together with Dr. Stakic? They resigned together.

18 A. Yes, that's correct.

19 Q. Did your husband tell you why he left -- he and Dr. Stakic left

20 their positions, the top civilian positions, in Prijedor?

21 A. I told you that in September 1992, left for Belgrade. My son was

22 then at the fourth grade of school. That happened while I was away. And

23 I think that my husband resigned, that it was only on the 30th of April

24 that he was allowed to resign.

25 Q. Of 1993?

1 A. No, it was in 1992.

2 Q. Let's try to clear this up quickly before the break. Your

3 husband, I'm talking about his position as president of the Executive

4 Board, which he assumed following the takeover on the 30th of April,

5 1992. Correct? And he resigned in January 1993. Is that correct?

6 A. That is correct. But you misunderstood me. Yes, he did resign in

7 January 1993, but if he hadn't been scared for his life and for the life

8 of his family, he would have resigned in 1992 when he saw that the things

9 that he fought for, and that was peace, democracy, and a multiparty state,

10 that these things didn't happen. If he had been in the position to resign

11 then, he would have resigned back then.

12 Q. One final question before the break: Did your husband participate

13 in a carefully planned takeover of Prijedor on the 30th of April in

14 cooperation with the army and the police? Would you agree with that, that

15 your husband participated in a carefully prepared takeover of power on the

16 30th of April?

17 A. I wouldn't agree because I don't know whether he participated in

18 the carefully prepared takeover. I don't know whether he participated. I

19 don't know whether the takeover was carefully prepared, for that matter.

20 JUDGE SCHOMBURG: The trial stays adjourned until 5.30. And I

21 wish a good weekend to all those having the ability to leave now. Thank

22 you.

23 --- Recess taken at 5.01 p.m.

24 --- On resuming at 5.34 p.m.

25 JUDGE SCHOMBURG: Please be seated. And Mr. Koumjian, please

1 proceed.

2 MR. KOUMJIAN:

3 Q. Ma'am, I'd like to now play a tape of a radio programme and ask

4 you if you recognise the voice of the second speaker. So if you just

5 listen to the tape, and I will stop it after the first sentence of the

6 second speaker and ask you if recognise his voice.

7 MR. OSTOJIC: Before we do that, Your Honour, can we please have

8 an exhibit number and a date, or what tape this is so that the Defence can

9 follow if appropriate.

10 MR. KOUMJIAN: I apologise to the Court and to the Defence. The

11 exhibit is Exhibit 91. That's the -- 91A is the English transcript; B is

12 the B/C/S; -1 is the tape.

13 Do Your Honours have copies? I think we have copies of the

14 transcript.

15 JUDGE SCHOMBURG: I don't think we need at the moment. It's in

16 English as well?

17 MR. KOUMJIAN: Yes. We have copies available if you would like.

18 So if we can just begin. The tape is set to begin, just for Your

19 Honours and for the Defence, at page 11, that's ERN number 00633728, the

20 last paragraph that begins with "Reporter: This is Prijedor radio."

21 Does the Defence need a copy, because we have extra copies?

22 MR. OSTOJIC: Thank you.

23 MR. KOUMJIAN: Okay. We will now play the tape.

24 [Audiotape played]

25 [Please refer to Exhibit S91 for transcript]

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1 MR. KOUMJIAN: Stop.

2 Q. I don't know, ma'am, if you heard enough of the second speaker to

3 identify the voice. Was that your husband, Dr. Kovacevic's voice?

4 I'm sorry, but you have to answer out loud.

5 A. Yes. Yes.

6 Q. Okay. Thank you.

7 MR. KOUMJIAN: If we can now continue to play the tape.

8 [Audiotape played]

9 [Please refer to Exhibit S91 for transcript]

10 MR. KOUMJIAN: Stop, please.

11 Q. In interests of time, I'm not going to play the rest of the

12 interview.

13 Madam, would you disagree with your -- or do you have any

14 information that your husband was not correct when he said, "it was all

15 very well prepared," regarding the takeover?

16 A. Do I have any comments? Is that what you're asking me? Could you

17 repeat that question, please. You have to understand that the voice that

18 I heard has stirred me a bit -- not the text, the voice. It has affected

19 me.

20 Q. We understand that. If you need a break -- you tell us whether

21 you can go on now or not.

22 A. No, no. I can continue. Just repeat the question, please.

23 Q. Your husband states very clearly in the interview that the

24 takeover of power was well prepared. Do you have any information that

25 would contradict him regarding that?

1 A. If that's what he said, if he said that it had been well prepared,

2 then he had good reason to say so. I'm afraid that he didn't say that in

3 order to satisfy a certain opinion in the surroundings according to which

4 that went smoothly. Knowing my husband, knowing that he was -- I could

5 say superficial in everything, he was only exhaustive in medicine, and

6 that is what he had dedicated himself to. I personally know that he did

7 say this. But on that evening, I personally know that he fled not to the

8 summer house but to the orchard. I don't know whether they found him

9 there. And he then appeared after everything. I can claim this for a

10 fact.

11 I don't know when the interview took place, but the reasons for

12 which he stated this could be as follows: This all came to an end without

13 me. This was all concluded without me. But he simply didn't manage to

14 get out of that situation. But that it was well prepared -- well, I don't

15 think he was a person who was capable of preparing it well. He was

16 involved in medicine. And at one point he said, I deal with medicine.

17 These are matters that he really did not understand. Other people perhaps

18 prepared this, and then it seemed as if a team had prepared it. And he

19 took the credit for it.

20 Q. Well, let's go a little bit along your comments. Let me follow up

21 a little bit on those. Your husband, was he the type of man to seek power

22 and attempt to impose his will upon other people?

23 A. That's not correct. Not at all. If necessary, I can explain.

24 Q. Let me ask a follow-up question regarding that, and if you need to

25 explain, please do so. Was he the type of person to exercise power and

1 influence over others above him?

2 A. No, he wasn't. He never liked power -- or rather, it's not that

3 he didn't like power, but it was something that he was not familiar with.

4 And the reason for which he behaved in such a way -- well, I participated

5 in his resistance to entering -- to joining the party first of all. And

6 then when the elections were held for the executive committee, the

7 elections for the executive committee for functions in the municipality,

8 he was convinced that he shouldn't accept this. I was surprised when he

9 came at 2.00 and said "I had to accept this. I did accept it. But you

10 should know, and this was through the will of the Muslim votes. This was

11 by -- through the Muslim votes." There weren't enough Serbs, so the

12 Muslims voted for him. And he said: "It was due to the Muslim votes." I

13 can understand the reasons for which he did that. I've already said that

14 we were in Germany. At that time, Yugoslavia was a socialist state;

15 Germany was a democratic state.

16 That's the first democracy that I encountered and in which the

17 ordinary man is taken care of. In socialist Yugoslavia, that was an

18 alienated state. The state was alienated from the people and the people

19 from the state. The reason for which Mico decided to go into power, to

20 assume power, was probably because part of the -- his experience of

21 democracy in Germany as a foreigner and as one who didn't know the

22 language, he wanted to transfer this experience to Yugoslavia, to apply --

23 to take advantage of his experience in Germany in Yugoslavia. That was

24 probably the reason.

25 But as far as power is concerned, well, you know, in Prijedor,

1 Mico assumes power, or rather he goes into his office. He would spend two

2 hours there, and then he would have say I have had enough of this. I'm

3 not interested in this any more. He didn't even know where he should sign

4 a certain document, but he would call his secretary and say,

5 "Don't give me anything that I shouldn't sign." He wouldn't even read the

6 text.

7 Q. Do you have any information as to why Dr. Stakic left the position

8 of president of the Municipal Assembly in January 1993?

9 A. I really don't have any information about that. I don't know why

10 Mico did that, and I don't know why Dr. Stakic did that either. As I

11 said, I was in Serbia. And at that time, I didn't know what was happening

12 in Prijedor. I do know that at that time, Mico was involved with the

13 hospital in Gradacac. Towards the end of 1992, he went to the

14 battlefield. He organised the hospital. I don't think he was involved in

15 politics at all. I don't know when he was replaced, but he wasn't

16 involved in politics at that time either.

17 Q. At the same time that your husband and Dr. Stakic left their

18 positions, Mr. Drljaca also resigned and left his position. Is that

19 correct? Do you know that?

20 A. Well, I really don't know about that.

21 Q. Do you know if anyone ever made an attempt to replace Mr. Drljaca

22 as a chief of police, your husband or anyone else, to have him replaced,

23 before his resignation in January of 1993?

24 A. Well, look, a minute ago I said Mico couldn't have appointed

25 Drljaca, and he couldn't have replaced him either for the same reason. I

1 know very little about that system, but even at that time in the socialist

2 system and during the multiparty elections, I did know that the chief of

3 the SUP and especially of the army, which was something completely

4 different, I knew that these people weren't appointed by municipal

5 organs. This is what you are asking me. But there must be experts who

6 could explain this better to you.

7 Q. If you do not know the answer to this, please say so, but don't

8 you know, in fact --

9 A. Well, no, I really don't.

10 Q. Let me finish the question. Thank you.

11 Don't you know that in fact the chief of police was normally

12 nominated by the local authorities, the local powers, and that his -- and

13 that nomination was simply affirmed by the Ministry of the Interior, that

14 that was the common practice in Bosnia for years?

15 MR. OSTOJIC: If I may just interject --

16 THE WITNESS: [Interpretation] I believe that --

17 JUDGE SCHOMBURG: It's better to rephrase the question. Could you

18 please --

19 MR. OSTOJIC: I don't know. By rephrasing, I may still have an

20 objection, if I may.

21 JUDGE SCHOMBURG: Please.

22 MR. OSTOJIC: The basis of the objection is the guidelines that

23 the Court has set for both parties. If counsel has those documents or

24 rules or procedure that he claims, as he does, that it's merely a

25 nomination and as he calls it affirming by the ministry, let him bring it

1 to the witness. If he doesn't --

2 JUDGE SCHOMBURG: I don't think that we need discuss this now and

3 here. The question should be rephrased because apparently, at least we

4 are not aware of these documents.

5 Please, rephrase your question whether or not the witness can tell

6 us about something.

7 MR. KOUMJIAN:

8 Q. Ma'am, would you disagree with testimony that we have heard in

9 this Court, that the practice in Bosnia was that the local authorities --

10 JUDGE SCHOMBURG: Once again, may I ask you to put the question in

11 a more neutral way, whether the witness knew about this or that. Because

12 the testimony you're referring to may be assessed by the one in this way,

13 and by another in another way. Therefore, to be on the safe side, please

14 rephrase your question.

15 MR. KOUMJIAN:

16 Q. Madam, do you know of any instance where the local Municipal

17 Assembly nominated a person to be the chief of police in Prijedor or any

18 other municipality in Bosnia, and the Ministry of the Interior did not

19 appoint the person nominated by the local Municipal Assembly?

20 A. You have made the question so complicated. But as I said, I

21 really don't know. I know a few things from how these things worked in

22 the socialist system. The police is one thing, and the municipality is

23 another thing. The army is another thing. I thought that this continued

24 in this manner, but I really don't know anything about this matter. I

25 know certain things from before.

1 Q. Thank you. Do you know, was it the case, that Mr. Drljaca was

2 forced out of office because of a split in the SDS? And the same as

3 Dr. Stakic was forced out, and Mr. Drljaca was forced out. Is that true?

4 A. I had a slight problem. Up to now, I was listening to another

5 voice, and now I can hear a female voice. And you are still speaking. So

6 it wasn't very clear to me. Something wasn't very clear to me. I wasn't

7 listening to the question. It's just the interpreter who changed. I

8 apologise.

9 Could you please repeat that. I was paying attention to what was

10 happening. So I didn't hear the question at all.

11 Q. I appreciate the fact that you're confused when a female voice is

12 interpreting me. My question, I'll try to make it clear, is; were you

13 aware, isn't it true, that Mr. Drljaca was forced out of his position as

14 chief of police in January 1993 along with Dr. Stakic following a split in

15 the SDS party?

16 A. Well, as I've already told you, and I'll repeat this again. In

17 September 1992, towards the end of September, I went to Belgrade. And I

18 stayed there until August 1993. During that period, I saw my husband,

19 Mico Kovacevic, on two occasions. He would come to Belgrade. He was at

20 the battlefield in the hospital all the time, and I really don't know what

21 was happening in Prijedor. And one other thing, I think that at the time

22 the telephones in Prijedor weren't functioning so that it was difficult to

23 communicate with Prijedor. I really don't know what was happening then.

24 Q. I believe you testified that you met Dr. Stakic on limited

25 occasions, that your husband liked to socialise with him. Did it appear

1 to you that your husband got along well with him, and they would go out

2 together?

3 A. As I said, the first time I saw Dr. Stakic was at my -- at the

4 mother of my husband's -- at my husband's mother's funeral. And then when

5 I returned to Prijedor, that was in 1993, I would see Mr. Stakic's wife

6 more often than Dr. Stakic himself. My husband, I know that he respected

7 Dr. Stakic. I know that he liked him. He considered him a friend, and

8 that means he had certain qualities that he respected.

9 Q. Isn't it the case that they socialised, and in fact, played

10 billiards together on occasions?

11 A. Yes, I never said the opposite.

12 Q. Thank you. Did they used to go -- do you know a restaurant called

13 Oskar or Kotpolje, excuse my pronunciation. Do you know such a

14 restaurant?

15 A. Pale. Yes, I do.

16 Q. Did your husband and Dr. Stakic used to go to that restaurant?

17 A. Yes.

18 Q. Did Mr. Drljaca, if you know, did he also spend time with

19 Dr. Stakic?

20 A. I don't know whether Dr. Drljaca spent time with Dr. Stakic,

21 because I wasn't in Pale when Mico and Stakic were there. All I know is

22 that when I would ask him who he was with, he would say that he was with

23 Stakic. My husband never played billiards. He only observed. And then

24 they would treat him to 10 marks for observing them, and that was my

25 pocket money.

1 Q. You said that your husband did not have a good relationship with

2 Mr. Drljaca. Do you know who in political power in Prijedor supported

3 Mr. Drljaca?

4 A. I really don't know. But it is true to say that my husband --

5 it's not that he didn't like Simo. He didn't hate people. But I think

6 that he was very disappointed. He indicated that this person wasn't

7 someone who could -- he could be together with.

8 Q. I want to move to a subject that may be painful for you, and

9 again, if you need a break or something, please, let me know.

10 Do you recall your husband being arrested in 1997?

11 A. Yes.

12 Q. Is it correct that the same day that your husband was arrested, an

13 attempt was made to arrest Mr. Drljaca, and that there was a shootout, and

14 Mr. Drljaca was killed?

15 A. I know that that happened on the same day. First, the news came

16 out that Mr. Drljaca was killed, and then I was informed that Mico had

17 been taken away.

18 Q. Did you attend the funeral of Mr. Drljaca?

19 A. No. Let me tell you. I was free to go there, but I was expecting

20 Mico to call me, so therefore I didn't go to the funeral. Regardless of

21 the relationship between Drljaca and Mico, I respected Drljaca.

22 Q. So you do not know who spoke at Mr. Drljaca's funeral. Would that

23 be correct?

24 A. No, no.

25 Q. Did you ever see your husband -- excuse me. Sorry. Did you ever

1 see Dr. Stakic, after that day where your husband was arrested and

2 Mr. Drljaca was killed, before coming to court today?

3 A. I saw him that same day, or perhaps the following day. Everything

4 that has to do with The Hague and with the prison was an unknown for me. I

5 thought that the attorneys needed to be paid, and I had no money to pay

6 them. Dr. Stakic called me to give me some confidence, first of all. And

7 then I asked him whether I would need to pay for something, and he said:

8 "I don't know. We'll stay in touch, and we'll see whether you need to pay

9 anything." And then later on, I learned that there was a different system

10 regarding that, and that if you had no money of your own, then there would

11 be an attorney appointed by a court.

12 Q. Are you okay to proceed? Are you all right to proceed?

13 A. Yes, I am. I apologise.

14 Q. There's no need to apologise.

15 At that time, the day of your husband's arrest, and when

16 Dr. Stakic called you, he was again the president of the Municipal

17 Assembly of Prijedor. Correct?

18 A. Yes, but I saw him only once, and I have already described the

19 occasion to you. You have to understand the situation. That was

20 immediately after Mico's arrest. There was probably some 50.000 people

21 treading through my house. My son and I didn't leave the house for a

22 month.

23 Q. So would it be correct then that, aside from the telephone call

24 you talked about, you had no further contact, no telephone calls or

25 visits, from Dr. Stakic?

1 A. That was not a telephone call. I went to see him in the municipal

2 building. You misunderstood me. I don't remember saying that.

3 Q. I misunderstood you, I'm sorry. I saw him in the Municipal

4 Assembly building where his office was as the president. Is that correct?

5 A. Yes, yes.

6 Q. Do you know how long Dr. Stakic stayed in Prijedor after your

7 husband's arrest?

8 A. At that time, please believe me, I paid no attention, either to

9 Dr. Stakic or to other people around me. I've already told you that for a

10 month, my son and I did not leave the house. We had different problems

11 regarding passport, regarding trip to The Hague. And simply on account of

12 all of that, I was not interested in what was going on in Prijedor.

13 Q. When you saw Dr. Stakic, did he express any concern for himself

14 after the arrest of your husband and the killing of Mr. Drljaca? Did he

15 express concern that he himself would be a target of the Tribunal?

16 A. No, I went to see him for a specific reason. I went to ask him

17 what was I to do if I needed money to pay attorneys. He was in the

18 municipal building. I came to see him when he had a break between meeting

19 various delegations. And that was perhaps a 5 to 10-minute meeting. Not

20 more than that.

21 Q. Did Dr. Stakic express any surprise or make any comments about the

22 fact that SFOR had arrested your husband and had attempted to arrest

23 Mr. Drljaca? Did he make any comments about that?

24 A. Not at all. No. He was shaken by the fact that Mico had been

25 arrested. The matter was over, and what I was interested in was how to

1 pay for Mico's defence and how to establish contact with him. We didn't

2 talk about the other matter that you mentioned.

3 Q. Ma'am, I just want to move on quickly and briefly address the

4 computer disk that you brought with you. Where did you obtain that disk

5 from?

6 A. This is how it was: I saw that things were not quite clear

7 regarding that. I said that I worked on recording the names of refugees,

8 recording their names, their personal data, which we used when they

9 obtained the refugee IDs. Upon taking that information from them, or that

10 information would be sent to the social work centre, to the lady who was

11 the database clerk. I know how to use computers, but I did not work on

12 that. This information came from the social work centre. It came from

13 the lady that was a database clerk.

14 Q. So the clerk actually gave you the CD?

15 A. Yes, yes.

16 Q. And when was it that you first asked her to make you -- did you

17 ask her to make you a copy of this information?

18 A. Yes. I don't know much about computers. They told me that they

19 had saved that information, and that whenever needed, a copy could be

20 obtained. She brought this to me, and I didn't ask her whether she kept a

21 copy for herself as well.

22 Q. And this was something that someone asked you to bring or you

23 yourself decided that -- to ask for a copy of this data?

24 A. No. Counsel asked me, when we had a conversation, where that

25 information was kept. And I told him that this data was maintained by the

1 social work centre. I believe that the refugee commissariat maintained

2 that information as well. He didn't know that prior to my current work, I

3 was involved in that as well. I told them that I used to be involved in

4 that kind of work as well. But let me tell you this: In addition to the

5 computer disk, there is a master record containing a number of

6 recordbooks, and these were the original documents.

7 Q. When was it that you had the conversation with counsel about the

8 fact that these records existed?

9 A. Some 15 to 20 days ago perhaps.

10 Q. Now, these records are quite detailed and they contain information

11 throughout the war years in Bosnia, including individuals' names, their

12 identification number, place of birth, et cetera. Is that correct?

13 A. Yes, all of it. This is how it was done. That's right.

14 Q. So can you tell us if even in wartime conditions, this information

15 was obtained -- was kept, was recorded, and was maintained? That's

16 correct?

17 A. Yes, yes. From the time when that service was established within

18 the social work centre, which was some time in 1993, the municipality had

19 to pass a decree providing that the records concerning displaced persons

20 and refugees had to be kept first in the refugee commissariat, and then in

21 the social work centre, and then it had to be transferred to SUP because

22 they were the only ones authorised to issue personal IDs or passports. We

23 passed a decision providing that SUP was the only organ authorised to do

24 that, and this decision was based on the administrative procedure, meaning

25 that we had to receive evidence concerning when the person left certain

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1 area and what was that area. We had to have some proof of that.

2 Q. Can you tell us, then, if similar detailed records were kept about

3 the identity of persons detained in the prisoner camps of Omarska,

4 Keraterm, and Trnopolje, and the names of persons expelled from the

5 municipality of Prijedor?

6 A. I don't wish to be unpleasant, but you're asking me things about

7 which I simply don't know anything. I passed in the vicinity of Keraterm

8 prison only. I can't tell you anything about what was going on there. I

9 can only testify about things that I was involved in.

10 Q. Just speaking of Keraterm, you did hear about the shooting one

11 night, shots being heard all night long, and that many, many men were

12 killed in one night in July in Keraterm? That was common knowledge in

13 Prijedor, wasn't it?

14 A. Yes.

15 Q. Did you ever speak to Minka Cehajic about what happened to her

16 husband?

17 A. I didn't know personally Dr. Minka Cehajic, and therefore I never

18 talked to her.

19 Q. Did your husband -- forgive if I've already asked you this. But

20 did your husband ever discuss with you what happened to Dr. Cehajic?

21 A. No.

22 Q. You heard about -- is it correct you've heard about a massacre

23 that occurred in August of a convoy leaving Prijedor and passing over

24 Mount Vlasic?

25 A. I did hear about that, but much later, after the war was over.

1 Q. Did you ever learn where -- first, let me ask you. You did learn

2 at some point, didn't you, that Dr. Stakic had gone underground and fled

3 Prijedor after your husband's arrest. Is that true?

4 MR. OSTOJIC: Let me just object to the form of the question, Your

5 Honour, and I can appreciate counsel trying to probe on these issues. But

6 I certainly cannot appreciate him to give -- to put questions to any

7 witness which are pure speculation, have not been substantiated by any

8 witness, and I think truly by virtue of this witness's testimony here

9 today, that if Dr. Stakic was fleeing and running, certainly in the

10 immediate days of the arrest of Milan Kovacevic and the death of

11 Simo Drljaca would have given --

12 JUDGE SCHOMBURG: May I interrupt. Please no arguments now. It's

13 correct that the question should be rephrased.

14 MR. KOUMJIAN:

15 Q. Do you know how long Dr. Stakic stayed in Prijedor after your

16 husband's arrest?

17 A. I truly don't know that.

18 Q. What was the next thing -- after you saw him at his office, what

19 was the next thing you learned about his whereabouts?

20 A. I don't know when it was that I learned this, but I eventually

21 learned that he had left for Belgrade.

22 Q. Okay, thank you.

23 MR. KOUMJIAN: Can I have S173, please, the colour copy. If we

24 could put that on the ELMO, and the witness can look at it just so we can

25 all see it.

1 Q. Madam, is that your husband's signature that appears on the

2 left-hand side?

3 A. Yes, yes, it is.

4 MR. KOUMJIAN: If I could have the witness shown S74-1B, and

5 S74-B, there's two pages.

6 THE WITNESS: [Interpretation] Excuse me, this signature resembles

7 my husband's signature. But it should be given to experts because it

8 looks somewhat questionable to me.

9 MR. KOUMJIAN:

10 Q. Okay, thank you.

11 MR. KOUMJIAN: Actually, I withdraw that given the last answer and

12 the fact that I see a "Za" on 74-1.

13 Your Honour, at this time -- I'm sorry, if we could have that,

14 please, shown. The signature line is Stakic, and then it's "Za" for the

15 signature.

16 THE WITNESS: [Interpretation] What am I supposed to do here?

17 MR. KOUMJIAN:

18 Q. If you can just look at the signature, you see in the bottom the

19 signature, it says Dr. Milomir Stakic. And then, correct me if I am

20 wrong, but appears to say "for" and then a signature. Is that the

21 signature of Dr. Kovacevic?

22 A. You know what, I'm not saying that the previous signature wasn't

23 my husband's. As far as I can see, it looks as though a letter is

24 missing. This resembles his signature, and it probably is his.

25 Q. Ma'am, did your husband know Mrs. Plavsic?

1 A. Are you asking whether my husband knew Mrs. Plavsic? I really

2 don't know. I believe he didn't, but I can't claim. He would at least

3 boast that he was in Mrs. Plavsic's company.

4 Q. Do you know anything, and if you don't -- you have been very good

5 about telling us when you don't have information and when you do. Do you

6 know anything about the relationship between Dr. Stakic and Mrs. Plavsic

7 or Mr. Karadzic?

8 A. Wait a minute, please. You mean between Dr. Stakic and

9 Mrs. Plavsic, and Mrs. Plavsic and Karadzic? I probably misunderstood

10 you.

11 Q. I'm trying to rush myself and asking two questions at once. Let's

12 take it one at a time. Dr. Stakic and Mrs. Plavsic, do you know anything

13 about their relationship, how they got along?

14 MR. OSTOJIC: Let me just object to the form of the question --

15 THE WITNESS: [No Interpretation].

16 MR. OSTOJIC: I still would like to object to the form of the

17 question. It's inappropriate to suggest something if there's no

18 establishment that there even was a relationship and then to ask a

19 witness --

20 JUDGE SCHOMBURG: Please rephrase your question.

21 MR. KOUMJIAN:

22 Q. Do you know if Dr. Stakic knew Mrs. Plavsic? Do you know anything

23 about their relations --

24 A. No, no, really, I don't.

25 Q. Do you know who it was that put Mr. Stakic back in power at the

1 end of the war?

2 A. I really don't know that either.

3 Q. Did you hear that it was Dr. Karadzic that placed Mr. Stakic back

4 in power?

5 A. I don't know that. And I don't believe that that's how it was.

6 Q. Were you present by any chance at the Municipal Assembly or at the

7 meeting where Mr. Stakic was proposed as the new president?

8 A. I beg your pardon.

9 Q. Did you attend any political meetings where it was decided that

10 Mr. Stakic would be the new president?

11 A. No, no. I was an ordinary citizen. I don't think that people

12 could go in without being invited.

13 Q. In the interview your husband said that "we set up a staff." Do

14 you know what staff he's referring to?

15 A. I don't know.

16 Q. Have you heard of the Crisis Staff in Prijedor?

17 A. Yes, I have. I have.

18 Q. Would it be correct that following the takeover on the 30th of

19 April, the Crisis Staff assumed power?

20 A. I don't know who took over the power, but I know that the Crisis

21 Staff existed. Now, as to its tasks, I don't know anything about that.

22 Q. Your husband was a member of the Crisis Staff. Correct?

23 A. I believe he was.

24 Q. Do you know how often your husband attended meetings of the Crisis

25 Staff?

1 A. I don't know. I only know that he never liked meetings at all.

2 MR. KOUMJIAN: Thank you. I have no further questions at this

3 time.

4 JUDGE SCHOMBURG: Thank you.

5 Questioned by the Court:

6 JUDGE SCHOMBURG: Just for clarification, when you mentioned the

7 CD we received today, you told us that you received it by a data

8 processing clerk. Is it correct that this was a clerk of the social work

9 centre?

10 A. Yes, that's right. And I can give the a name if necessary. I can

11 tell you what is the name of that person.

12 JUDGE SCHOMBURG: If you would be so kind.

13 A. It is Divna. Are you following me? Her name is Divna, and she

14 is -- what is that called? She is a data processing clerk.

15 JUDGE SCHOMBURG: And in which building did you receive the CD?

16 A. In the social work centre building.

17 JUDGE SCHOMBURG: In Prijedor?

18 A. This is how it is. May I explain.

19 JUDGE SCHOMBURG: I think it's not really necessary with a view to

20 the time. But this centre is in Prijedor. Correct?

21 A. Yes, yes.

22 JUDGE SCHOMBURG: Then let me know, did you ever hear Dr. Stakic

23 on the radio?

24 A. I really don't remember. I probably did, but what do you have in

25 mind? In what period of time?

1 JUDGE SCHOMBURG: Maybe especially during the period of the

2 so-called takeover, we'll say April 30, 1992?

3 A. I don't remember whether it was during that period of time. It is

4 possible that I heard an interview of his, but I don't remember. I can't

5 claim that I never heard it, but I simply don't remember.

6 JUDGE SCHOMBURG: To the best of your recollection, what was

7 your -- what was for you the most important issue at that day of the

8 takeover? How did you learn about this? By whom did you learn about

9 this?

10 A. I learned it in the morning when I turned the radio on. It was

11 quite a shocking event for me. I think that the announcer said "radio of

12 Republika Srpska" and then the message was that citizens should remain

13 calm. And the voice of the announcer was such that it seems that it

14 reverbates in my ears even to this day.

15 JUDGE SCHOMBURG: But it was not Dr. Stakic making this

16 announcement himself. Correct?

17 A. No, no, no. That was a lady announcer.

18 JUDGE SCHOMBURG: Thank you. Did you discuss this -- you told us

19 you were shocked about this. Did you discuss this event with your

20 husband?

21 A. After that, I did not discuss. Not the event itself. What I

22 discussed was what was to happen after that. He thought: "All right,

23 perhaps this could be a good event, a good development. If the previous

24 one wasn't, perhaps this could be good." And then I thought: "Well,

25 perhaps it won't get worse." And in view of the fact what was going on

1 elsewhere in Bosnia, I was quite afraid that it could get to Prijedor as

2 well. And if you think logically, you realise that Prijedor cannot be an

3 exception. But at the same time, I believe that if intelligent people

4 were in power there, then perhaps it could be an exception. And this is

5 the belief that I held for quite a long time. Had I thought differently,

6 I would have gone to Belgrade immediately.

7 JUDGE SCHOMBURG: Did you ever see Dr. Stakic on television?

8 A. I think that immediately after the events in Kozarac, there was no

9 electricity supply. We didn't have any electricity for months. I think

10 that that was the case. I don't remember watching anything on television

11 during that period, or I didn't watch television at all. Well, yes,

12 that's true, there was no electricity after the month of May. I know this

13 because we had to throw away all the food that had been kept in the

14 freezer, and I can remember that in front of my building, as there was no

15 electricity, we would all light fires outside. And then we would all --

16 all of us from the building would cook outside. If this is important for

17 the trial, it probably is. We all used one stove, which was outside, to

18 cook, both Serbs and Muslims.

19 JUDGE SCHOMBURG: When did you for the first time learn about the

20 setting up of Keraterm, Omarska, Trnopolje?

21 A. I worked in Cirkin Polje. The road doesn't go by Keraterm, not

22 exactly. But it's a road which is parallel to it. So I was aware of its

23 existence. But as far as when it was established, I really don't know the

24 date. But I was aware of the existence of Keraterm.

25 As far as Omarska is concerned, I didn't experience Omarska in

1 such a way. I thought that -- and I don't know why. I thought that

2 people who were in Omarska were people who had been questioned in

3 Keraterm. This is how I understood the situation to be. I don't know

4 why. When it was established, I have no idea.

5 JUDGE SCHOMBURG: Did you know at that time why Keraterm and

6 Omarska were set up?

7 A. I didn't know, but as I said -- when did I talk to Simo? As I

8 have already said, it was probably in June. People were stealing, doing

9 what they were doing. And at that point, he told me that they were

10 imprisoning people. And since he also told me that they were imprisoning

11 Serbs, I took this to mean that it was a prison for people who had broken

12 the law somehow.

13 JUDGE SCHOMBURG: You said "they were imprisoning people." Who is

14 "they"?

15 A. Well, I mean the police. You know, who arrests people, that's

16 what I thought. Perhaps I'm wrong.

17 JUDGE SCHOMBURG: May I ask you a totally different question. Was

18 there any event in the family or in the life of your husband or the family

19 of your husband in the past which threatened him and which had influenced

20 all his life, maybe through World War II?

21 A. Mico and all children from Kozara suffered a lot in 1941. There

22 was one event and, Your Honour, I can't lie. I don't know how to lie.

23 The journalists falsely reported Mico having been in Jasenovac. Mico was

24 in a camp, but never in Jasenovac. He was there in a camp with his mother

25 and all inhabitants of that village, the village of Potkozarje. He was in

1 a camp and he would always say: "What kind of a people are we?" Since

2 there were three guards who were guarding 500 people. How can 500 people

3 be afraid of 3 guards? It's true that the guards were armed, but the

4 people quite simply didn't try to flee.

5 He and his mother were in that camp, but his mother was probably

6 trying to survive. The instinct for survival was putting her forward, and

7 she managed to get out of there. Mico is no longer alive, but I wouldn't

8 want things to be falsely represented. It's not true to say that he was

9 in Jasenovac. It is true to say that he was in camp, that he suffered a

10 lot -- not only Mico, but everyone, all the children suffered a lot. But

11 he wasn't in Jasenovac. And this is the truth.

12 JUDGE SCHOMBURG: He suffered from the occupation by the Germans.

13 Correct? He suffered in 1941 under the occupation by the Germans.

14 Correct?

15 A. Yes, he did. But I don't think the cause of the suffering was the

16 German occupation. He suffered because of the overall situation, too.

17 The NDH was there, the independent state of Croatia. The Germans were in

18 the town. The NDH army went around the villages, rounded up the people,

19 people would flee to Kozara.

20 The Germans were present in the town, but Mico and his mother told

21 me that they would have -- that they would be happy if they came across a

22 German soldier. But if an Ustasha, and those were either Croats or

23 Muslims, they were neighbours, it was very difficult if they came across

24 Ustashas. That's why they fled to Kozara. And I am saying this for the

25 sake of the truth.

1 JUDGE SCHOMBURG: Thank you.

2 Judge Vassylenko.

3 JUDGE VASSYLENKO: My question, how it happened that your husband,

4 a person dedicated to medical profession and family life, became a

5 politician and started to wear a military uniform?

6 A. As I have already explained, he didn't want to go into politics.

7 He was a man who was well-liked by everyone -- in fact, I can't say

8 everyone, but many people liked him. I don't know whether it was because

9 of the way he was or because he was a doctor and they needed him. But he

10 was able to communicate with everyone, and he was ready to listen to

11 anyone.

12 As far as the fact that he wore a camouflage uniform is concerned,

13 I haven't portrayed Mico as his wife. He had two pairs of trousers and

14 two shirts. Perhaps that's not very important. But at the time, there

15 was no detergent. It wasn't possible to wash clothes. They received

16 those camouflage uniforms, and he said, "This is nice. It keeps you cool,

17 and when it's dirty, you don't see the dirt." So he wore that for a

18 certain period of time. At the time, everyone wore those uniforms, and

19 then he took the uniform off. Whether it was for some other reason or

20 because he understood that that uniform had another meaning, too, I don't

21 know. But later on, he didn't wear it any more.

22 JUDGE VASSYLENKO: Was your husband respected by his colleagues in

23 his profession?

24 A. Yes, very much so. Look, he came from Germany where he was

25 involved in a kind of medicine that was technically more developed, so his

1 opinion was taken into account.

2 JUDGE VASSYLENKO: Was your husband an influential political

3 figure in Prijedor Municipality?

4 A. You want to know whether he was an influential political figure.

5 I don't know. But he was too naive to be a real politician, but he did

6 have influence. That's true.

7 JUDGE VASSYLENKO: Have you ever discussed the fact of existence

8 of the camps in Prijedor Municipality with your husband?

9 A. I never discussed that with him. Well, first of all, I was aware

10 of the existence of camps, but I didn't talk about this because I knew

11 that he didn't know much about this. And even if I had asked him about

12 it, he would have said that he knew nothing about it. So I quite simply

13 didn't ask him anything about that. Perhaps it was an unpleasant subject

14 for me, too.

15 But as I say -- you don't have to believe me, but I really thought

16 that these camps were prisons where people were questioned as to what had

17 happened, how they had armed themselves, whether they had armed

18 themselves. And that then they would be sent to Omarska. I really didn't

19 go into the matter, but that's -- that was my understanding at the time.

20 JUDGE VASSYLENKO: What was your reaction to the arrest of your

21 husband?

22 A. What was my reaction? Well, I was surprised, I was shocked -- I

23 don't know. After a month had passed, only then did I realise that he had

24 really been arrested.

25 JUDGE VASSYLENKO: Thank you. I have no more questions.

1 JUDGE SCHOMBURG: Judge Argibay, please.

2 JUDGE ARGIBAY: I have no questions. Thank you.

3 JUDGE SCHOMBURG: The Defence, please.

4 MR. OSTOJIC: Thank you for your patience, Your Honour.

5 Re-examined by Mr. Ostojic:

6 Q. We're almost done, Mrs. Kovacevic, just a couple questions to

7 follow up on the questions by the Court and Mr. Koumjian. Did you have

8 any trouble whatsoever obtaining access or finding Dr. Stakic at the

9 Prijedor municipal building immediately after the arrest of your husband,

10 Milan Kovacevic, in 1997?

11 A. No, I didn't.

12 Q. Did you know, ma'am, that Dr. Stakic left the Prijedor

13 Municipality and went to Belgrade because he was getting his

14 specialisation in the field of medicine, in a specific area? Did you know

15 that?

16 A. No, I didn't know that. But I subsequently found out that he had

17 gone there to get his specialisation. Later on, I was told that he had

18 gone there and that the reason for his departure was this specialisation

19 course. I think that I have explained this sufficiently.

20 Q. The Honourable Judge Vassylenko asked you a question about your

21 reaction to the arrest of Milan Kovacevic. Immediately subsequent to

22 that, were you provided any aid or assistance or help by the Red Cross?

23 A. I don't remember.

24 Q. To follow up on a question by Mr. Koumjian regarding the records

25 and you having been at the centre where these records are kept, where they

1 kept information on individuals who did not migrate into Prijedor, but

2 left other areas because they were forced to leave, keeping those records,

3 is there anything to your knowledge which would prevent the Office of the

4 Prosecution with their subpoena power in order to tell a Chamber the truth

5 or to get to the truth about a situation to have subpoenaed those same

6 records that you brought to us? Do you know of anything that would have

7 prevented them from being able to do that?

8 A. I wasn't able to follow you quite well. I spoke the truth only.

9 And everything else that is needed regarding these records, I can tell you

10 that there are registry books. And in addition to that, there are three

11 types of parallel records that can be provided to this Tribunal, and that

12 identical to the data contained in this diskette. This is contained in

13 those records.

14 Q. And I understand that. For example, some of the documents that

15 the Prosecution was kind enough to share with you, do you know that, for

16 example, some of those documents were subpoenaed by the Office of the

17 Prosecution from the municipal building, the police station, the Kozarski

18 Vjesnik building? And likewise -- likewise, they were also able to,

19 without any hesitancy, to be able to subpoena the records from your --

20 JUDGE SCHOMBURG: Sorry to interrupt. But the witness can't

21 answer these questions. These are internals of the criminal procedure,

22 and it's not a question to be put to a witness.

23 MR. OSTOJIC:

24 Q. Let me ask you these couple more final questions, if I may: Did

25 you know or did you hear at any time that when there was an arrest by the

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1 Office of the Prosecution of Milan Kovacevic and the killing of

2 Simo Drljaca, that there was a secret indictment that no one knew about

3 that may have been in existence against Dr. Milomir Stakic? Did you know

4 that?

5 A. No.

6 Q. A couple questions, if I may. The Honourable Judge Schomburg,

7 president of this Chamber, asked you a question in connection with the

8 childhood of Milan Kovacevic. And you mentioned the camp that he was in.

9 But at any time, having been with him for 30 years approximately, did you

10 ever feel that Dr. Kovacevic had some ill feelings towards other

11 individuals, whether they were Muslims, Croats, or any non-Serbs, because

12 of the experience that he had with his mother as a child? Did he ever

13 tell you: "It's because of my youthful experience that I now, at the age

14 of 58, would like to impose that same suffering on other individuals"?

15 A. I didn't know these facts about the camp until journalists wrote

16 about that. When he was in prison here, I asked him about that. I said:

17 "Mico, it is said here that you had been in Jasenovac." And then he told

18 me that it wasn't Jasenovac, but rather a camp in the vicinity of

19 Prijedor. So as far as the camp is concerned, he never told me that it

20 was the camp experience that had scarred him.

21 What he suffered as a child left no marks on him because he

22 developed and was a successful man. And that created new-life

23 opportunities for him. I remember well that that summer of 1992, we were

24 getting ready to go on vacation in Cairo rather than wage war. Knowing

25 him as a person, I don't believe that one could ever come to the

1 conclusion that he had a difficult or tragic childhood. He was a person

2 with a great sense of humor, with a kind heart, and one would be more

3 likely to say that I had been in Jasenovac rather than him. He liked

4 people. And there is something I didn't tell you. Dr. Stakic should know

5 about this.

6 We lived in an apartment that had 50 square metres. It was on the

7 last floor. It had no balcony. In 1991, Mico was given an apartment, and

8 I asked him, Well, where was that apartment? And he said I've given this

9 apartment to somebody else. I asked him to who? And he said to

10 Suljanovic who I believe was his deputy -- perhaps I got the name wrong,

11 but it was somebody who was a Muslim. And then I said, Well, Mico, why

12 did you give him an apartment when we have no proper apartment ourselves?

13 And he said to me, Why would we need a new apartment? I simply threw the

14 keys to the apartment to him. Perhaps this is not important, but we could

15 prove this through other witnesses including the man who had been given

16 this apartment. Somebody who hated Muslims would not have done that.

17 Q. I have one final question, if I may, with the Court's permission.

18 You were asked several questions regarding Dr. Stakic, if you saw him on

19 the television or heard him on the radio. I know you left the Prijedor

20 Municipality in September of 1992, because of your son's education, and

21 you went to Belgrade. However, during the period of September 1992, were

22 you able to read any newspaper accounts where Dr. Stakic was critical of

23 the police and the military? Do you know if you ever had an opportunity

24 to review such articles?

25 A. No.

1 MR. OSTOJIC: That's all I have. Thank you very much, ma'am.

2 MR. KOUMJIAN: I have two brief questions.

3 Further cross-examined by Mr. Koumjian:

4 Q. Ma'am, am I correct that you brought the information on the

5 computer disk at the request of Mr. Ostojic?

6 A. No, not Mr. Ostojic. Mr. Lukic.

7 Q. Thank you. And the second question: Did you ever hear

8 Dr. Stakic, the president of the Municipal Assembly in 1997, after your

9 husband's arrest, give any speech or any public statement to the people of

10 Prijedor saying "I'm going to Belgrade to do a specialisation and

11 resigning my position"?

12 A. Giving a speech about going to specialisation in Belgrade, or

13 giving any speech? I think that I heard him give a speech in 1997 or

14 around that time.

15 Q. Thank you.

16 MR. KOUMJIAN: No further questions.

17 JUDGE SCHOMBURG: I can't see any further questions. So I have to

18 thank you, not only for coming, but also going through this difficult line

19 of questions. I know it must have hurt you sometimes, and we all know how

20 difficult it is to reopen some wounds. And I hope that as soon as

21 possible, you can overcome all this. Thank you for coming. And thank you

22 for testifying to the best of your recollection. [Foreign language

23 spoken]

24 THE WITNESS: [Interpretation] May I say something, Your Honour.

25 This was my moral duty that I have with respect to my husband, to everyone

1 who perished during this war, and the duty I have with respect to the

2 truth.

3 JUDGE SCHOMBURG: Thank you once again. May I ask the usher to

4 escort the witness out of the courtroom. Thank you for today. You're

5 excused.

6 [The witness withdrew]

7 JUDGE SCHOMBURG: Very briefly, I don't want to step over the

8 time. But we have to clarify what will happen on Monday. Until now, we

9 didn't receive any questions for Mr. Sivac from the side of the Defence.

10 MR. OSTOJIC: We have them. It's just there has never been an

11 opportunity to share with the Court. We thought we would do it in open

12 Court. The Court asked for it today, this morning. We had it. We can

13 tender it now. We have a copy of -- for the OTP as well under the Court's

14 ruling. If the usher would be kind enough --

15 JUDGE SCHOMBURG: Yes, please. Maybe, please, distribute it. And

16 please understand that we can't rule now on the question of whether or not

17 these questions met the threshold indicated beforehand, and the

18 Prosecution has also the right to comment on this. But nevertheless, I

19 would ask the OTP to be prepared that Mr. Sivac is ready to appear on

20 Monday afternoon 2.15. And until you are maybe disalerted.

21 In the moment, we can't really concentrate on this and go through

22 this line of question. In principle, we are prepared to hear Mr. Sivac.

23 But we'll let you know the final outcome.

24 Related to next week, you should only know that on Wednesday, we

25 sit in the morning instead of the afternoon. On Thursday, we start now,

1 once again, a change of the bureau meeting, we start as scheduled, but we

2 have to stop at 6.00.

3 Do you have any informations from the side of the Defence related

4 to the translation of your exhibits?

5 MR. OSTOJIC: We did call, and we are still waiting to hear back

6 from them, Your Honour. It doesn't seem -- because when we leave they are

7 already gone, we left messages during the break. We hope to accomplish

8 that by early next week and share that with the Court.

9 JUDGE SCHOMBURG: We come back to this immediately on Monday.

10 What about the status of disclosure of Ms. Plavsic's interviews?

11 MR. OSTOJIC: Yes, I was not promised, but there was an indication

12 that they were going to present that to us today by the end of the day.

13 And we just don't have it yet. I would also like to make the request in

14 connection with that if we could have --

15 JUDGE SCHOMBURG: It's also our desire to have as soon as possible

16 these documents that we are prepared.

17 MR. OSTOJIC: I just wanted to make a point, if we could also have

18 them in the B/C/S version so that our client could review them. And I

19 think the interviews were done. So I don't have to make the application

20 later. Thank you, Your Honour.

21 JUDGE SCHOMBURG: Right.

22 MR. KOUMJIAN: I don't believe that there is a B/C/S transcript.

23 There may be actual tapes.

24 JUDGE SCHOMBURG: Yes.

25 MR. KOUMJIAN: My understanding is that -- I just was informed

1 that we haven't received an answer yet from the Defence of Plavsic about

2 whether they have an objection to the interviews. We did ask to give them

3 an opportunity to make an objection. But they are being copied now.

4 We'll also ask for the tapes to be copied.

5 JUDGE SCHOMBURG: So we can expect these documents and the tapes

6 by Monday. Because you have seen the scheduling order, and maybe -- I

7 don't know what will be the direction, but there are two options, either

8 to testify after the sentencing judgement or before.

9 And then finally, it should not be forgotten, what about the

10 typewriting expert?

11 MR. KOUMJIAN: I haven't heard from him, and I will check on

12 that. Coincidentally, I asked Ms. Karper about that this morning.

13 JUDGE SCHOMBURG: Please don't forget that this question is still

14 open. Any other issues to be resolved today?

15 MR. OSTOJIC: Not at this time, Your Honour. Thank you.

16 JUDGE SCHOMBURG: Then you should only know that it is envisaged

17 that from 20th January, whenever we sit in the morning, we sit as from

18 9.30 until 5.00. Sometimes the entire day in Courtroom I, sometimes in

19 the beginning in Courtroom II, and then later in Courtroom I to have as

20 much as possible time.

21 MR. OSTOJIC: Just to remind the Court, we also -- I think it's

22 one of the four of the six individuals that we received the tapes on under

23 Rule 68. We -- they are not cooperating in terms of coming as our

24 witnesses. We would ask the Court, if acceptable, that the Court calls

25 them. But I would like to sit with the Court and the OTP obviously and

1 talk about when we can fit that in based on our schedule and the Court's.

2 We think it's -- at least we think it's relevant --

3 JUDGE SCHOMBURG: I think the time is ripe for another 65 ter (i)

4 meeting during the next week.

5 This really concludes now this week's hearing. I thank everybody

6 also for the extra time, but it was really helpful for the witness had not

7 to come for a second time to The Hague. Thank you everybody. And have a

8 nice weekend.

9 --- Whereupon the hearing adjourned

10 at 7.04 p.m., to be reconvened on Monday,

11 the 13th day of January, 2003,

12 at 2.15 p.m.

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