International Criminal Tribunal for the Former Yugoslavia

Page 11086

1 Friday, 24 January 2003

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.06 a.m.

5 JUDGE SCHOMBURG: Good morning to everybody. Please be seated.

6 The case, please.

7 THE REGISTRAR: Good morning. This is Case Number IT-97-24-T, the

8 Prosecutor versus Milomir Stakic.

9 JUDGE SCHOMBURG: Thank you. And the appearances for the

10 Prosecution, please.

11 MR. KOUMJIAN: Good morning, Your Honours. Nicholas Koumjian, Ann

12 Sutherland, and Ruth Karper for the Prosecution.

13 JUDGE SCHOMBURG: And for the Defence, please.

14 MR. LUKIC: Good morning. Branko Lukic and Danilo Cirkovic for

15 the Defence.

16 JUDGE SCHOMBURG: Thank you. May I ask the usher to escort the

17 witness into the courtroom. Thank you.

18 [The witness entered court]

19 JUDGE SCHOMBURG: Good morning, Madam Radakovic. You are prepared

20 to continue?

21 THE WITNESS: [Interpretation] Good morning. Yes, thank you.

22 JUDGE SCHOMBURG: Then, please, Mr. Koumjian.

23 WITNESS: STOJA RADAKOVIC [Resumed]

24 [Witness answered through interpreter]

25 Cross-examined by Mr. Koumjian: [Continued]

Page 11087

1 Q. Ma'am, could you tell us what the procedure was in Prijedor in

2 1992 where you worked, and in the period of 1996 through 1997, when you

3 wanted to take time off or request sick leave.

4 A. I never went on sick leave. Therefore, I don't know what the

5 procedure was. In 1997, mostly there were neither sick leaves nor annual

6 leaves. I didn't take my annual leave.

7 Q. In order to have a record of the time that you had worked, did

8 someone have to sign a record that you had worked those hours?

9 A. No. The hours were not accounted. But when somebody was away for

10 the day, that would enter the record, as well as when that person was in.

11 That also went into the record. There was a special service which counted

12 the days when people worked as opposed to the days when they didn't work.

13 There was a special service.

14 Q. Did Dr. Stakic sign your time records?

15 A. No. Dr. Stakic didn't sign, and very often it would happen to me

16 that I would be absent for an hour. I didn't have to ask Dr. Stakic's

17 permission but my superior in my service, who was my head of service. He

18 was my superior, I took orders from him, and he was the one who signed all

19 the documents, for example, decisions on annual leaves, that we didn't

20 take, and decisions on my salary. So I would go to that service, and I

21 would tell them I have to take my mother to the doctor's. I never went to

22 see a doctor myself. And then there would be a replacement, somebody who

23 would replace me for an hour or two hours during the time while I was

24 absent.

25 Q. Was it a common practice in your workplace that on occasions such

Page 11088

1 as someone's birthday, such as a wedding, or on sadder occasions such as

2 the death of a family member, that a card would be circulated in the

3 office, to have the colleagues sign that card?

4 A. No, there were no cards. If you had to express your condolences,

5 you didn't do it in writing. And since you've mentioned somebody's death,

6 my father died in January 1996. That's when I was absent. And I believe

7 that I was absent for one whole working week.

8 Q. And did Dr. Stakic send you any letter or communication with his

9 condolences?

10 A. No, he didn't.

11 Q. Ma'am, how do you know Simo Drljaca?

12 A. I know Simo Drljaca from before the war. He lived above my

13 parents while he worked as a lawyer in the education fund. I don't know

14 what the name of the institution was, but anyway, it was an organisation

15 in charge of primary education.

16 Q. Did you socialise with him? Did you know him well?

17 A. No, we were just sort of nodding acquaintances so to say. We just

18 would nod and greet each other passing by.

19 Q. On page 69 of yesterday's transcript - and I'm quoting the page

20 number, madam, just so you know, so the Judge and Mr. Lukic can follow

21 along - beginning on line 1, you indicated that you went "to see Mr.

22 Drljaca and asked him for a favour, and the favour was for my son not

23 to be sent to the war."

24 Why was it that you asked Mr. Drljaca to keep your son from being

25 sent to the war?

Page 11089

1 A. Because at the time, my son was a member of the reserve police.

2 He left at the beginning of June and he ended up with the police at the

3 end of September. On the 1st of October, 1992, he reported to his

4 occupational specialty unit, and he had some objections about being sent

5 to Orasje or something like that. And that was at the time when the

6 police was getting ready to go to Orasje. That is when I paid a visit to

7 Simo Drljaca. Until that moment, I didn't know him very well. And from

8 then onwards, we hardly even said hello to each other. When I was in his

9 office, I told him, "If your Sinisa was on the list --" that is his son's

10 name, Sinisa -- "and if I was the one who had to sign the list, then your

11 Sinisa, your son would not be sent to the front line, I assure you."

12 Q. Was your son's name Rade?

13 A. No.

14 Q. What is your son's name?

15 A. Aleksandar.

16 Q. Did he have the nickname "Srbo"?

17 A. No, his nickname is "Misko."

18 Q. Thank you. You said your son was in the reserve police. Was it a

19 particular unit of the reserve police that your son was in?

20 A. That was the beginning when they kept guard at checkpoints in

21 town. That's why I told him to join them, because if nothing else, at

22 least he could spend nights at home, not on the front line. It may sound

23 selfish to you, but I am a mother and only that.

24 Q. Was your son a member of the Intervention Platoon?

25 A. No.

Page 11090

1 Q. So you have heard of this -- have you heard of the Intervention

2 Platoon?

3 A. Yes, I did, but I don't know anything about it.

4 Q. Madam, you indicated that the Crisis Staff meetings were in the

5 basement, in the communications room. Is my memory correct?

6 A. It was not a proper conference room. Those were the rooms from

7 which alerts were given to the population. That was a special unit that

8 alerted the population, and it was a department before the war.

9 Q. In addition to that room, did they meet in the large conference

10 room?

11 A. I didn't know when they held meetings. Downstairs, I didn't know

12 when they held meetings. Upstairs, if it was during the working hours, I

13 didn't see it, so I wasn't aware of when and where they held their

14 meetings.

15 Q. Madam, did you ever call, on behalf of Dr. Stakic, Mr. Budimir,

16 Slavko Budimir?

17 A. I can't remember, although it is possible. But I can't remember.

18 Q. Would you call to come to meetings Ranko Travar for Dr. Stakic?

19 A. Yes. Those were not meetings, they were just briefings. He was

20 the head of finance department, and it was a very important secretariat

21 for everyday life. Everything relies and begins with finances; the supply

22 of town with petrol, food, electricity, and other necessities.

23 Q. Did you call, on behalf of Dr. Stakic, Mr. Vojo Pavicic?

24 A. Those are people who were heads of particular bodies or organs,

25 and they would meet at sessions of the Executive Board. And I believe

Page 11091

1 that Vojo Pavicic was among those who came.

2 Q. Okay. But my question is, did you call Vojo Pavicic on behalf of

3 Dr. Stakic?

4 A. I believe that I did.

5 Q. How about Dr. Zeljko Macura? Did you call him on behalf of

6 Dr. Stakic?

7 A. I don't remember whether I called Macura. He did not belong to

8 any administrative body, and I don't know what he did at the time.

9 Q. How about Mr. Bosko Mandic? Did you call him on behalf of

10 Dr. Stakic?

11 A. Bosko Mandic joined the Executive Board when Stakic was no longer

12 there. That's, at least, what I believe; while Dr. Kovacevic was there,

13 or something like that, or with Dr. Kovacevic. I don't know.

14 Q. Do you recall making calls to Mr. Bosko Mandic?

15 A. No.

16 Q. You've mentioned the name of Dr. Kovacevic. How often would

17 Dr. Kovacevic come to Dr. Stakic's office in 1992 after the takeover?

18 A. Hard for me to say or give you a number.

19 Q. Well, was it something that would happen on a daily basis?

20 A. No. There were no regular intervals at which they would meet.

21 Dr. Stakic would sometimes go there even if he was not invited -- sorry,

22 this was a slip of the tongue. Dr. Kovacevic, I meant.

23 Q. How far away was the office of Dr. Kovacevic from the office of

24 Dr. Stakic?

25 A. There are two large rooms between their two offices. I don't know

Page 11092

1 how much would that be in metres, maybe 30 metres or so.

2 Q. Okay. Thank you. They were on the same floor, just so -- just to

3 make that clear. Is that correct?

4 A. That is correct.

5 MR. KOUMJIAN: If we could have the witness shown the diagram D49.

6 Q. Ma'am, from Dr. Stakic's office -- and now I'm talking not about

7 the office he sat in as vice-president of the Municipal Assembly but the

8 office that he sat in after the takeover, are there windows in that

9 office?

10 A. Which office? All the offices have windows. There's no single

11 office in the municipal building without a window, or at least, I don't

12 know of any such office without a window.

13 Q. Thank you. The windows in Dr. Stakic's office, can you tell us

14 what they looked out on? Did they look towards the museum? Can you tell

15 us, what would you see when you looked out of those windows? And you can

16 explain if they were on just one side or two sides of the office there

17 were windows, please.

18 A. This is the entrance to the building, and approximately --

19 Q. Ma'am --

20 A. Here you mean. Okay. This is the entrance to the building. My

21 office is approximately at the middle of this gallery. This is a gallery

22 or a balcony. This is the president's office, and then a small room, and

23 then the Executive Board towards the end of the building. From this --

24 you've mentioned the museum. The museum, as far as I can tell on this

25 map, this could be the museum. Not directly, but from an angle you can

Page 11093

1 see it.

2 Q. Thank you. I think you've made that clear. Can you show us --

3 before we leave this diagram, where is the large meeting room? Was there

4 a large meeting room in the Municipal Assembly building?

5 A. Yes, this is this large meeting room, on the second floor above

6 us. And its windows look on both sides, on this side and on that side,

7 even on this side. There are also glass sort of windows or doors, but you

8 can't open those doors or windows. So actually, there are glass windows

9 on three sides.

10 Q. I'm just going to try to describe for the record so that someone

11 reading can understand what you've pointed to. When we're talking about

12 Dr. Stakic's office, you pointed towards the centre of the building, near

13 the entrance, just -- on the diagram, just to the right of the entrance.

14 When you talked -- and that was the office of the president. When we

15 talked about the Municipal Assembly meeting room, the large meeting room,

16 you pointed to the top of the building, or the left top of the building,

17 that portion.

18 MR. KOUMJIAN: Counsel and the Court agree or correct me?

19 JUDGE SCHOMBURG: I think it would be also helpful to add that it

20 was at the side heading towards, in part, museum, and from a different

21 angle, also in the direction to the MUP or SUP building. So in front --

22 in any event, in front of the building at the same side where the main

23 entrance was. Correct? Were the windows at the side where the main

24 entrance is shown on this map?

25 THE WITNESS: [Interpretation] The big conference room -- I'm

Page 11094

1 afraid I didn't understand your question well.

2 JUDGE SCHOMBURG: [Previous interpretation continues]... about the

3 office of Dr. Stakic in the period after April 30th, 1992.

4 THE WITNESS: [Indicates]

5 [Interpretation] I don't know. What am I expected to say?

6 JUDGE SCHOMBURG: So it would be at the side of the building where

7 we can also see the main entrance. Is this correct?

8 THE WITNESS: [Interpretation] Yes.

9 MR. KOUMJIAN:

10 Q. Madam, you talked about -- you said that Dr. Stakic did not call

11 Mr. Drljaca. Did you ever receive calls from Mr. Drljaca for Dr. Stakic?

12 A. No. No.

13 Q. Did you see in Dr. Stakic's office members of the Prijedor press?

14 A. I saw -- you mean during the war, the period after April 1992?

15 Q. Yes, thank you. Let's say after the takeover of the municipality

16 on the 30th of April until Dr. Stakic left in 1993 his position, did you

17 see members of the press from Prijedor in Dr. Stakic's office?

18 A. There was a meeting, but it was held - and I believe that we spoke

19 about that yesterday - when members of the press came, and I don't know

20 which month that was. I believe it was the end of July, or maybe not.

21 Q. Okay. Just so I understand, I believe now you're talking about

22 the time that foreign journalists came to Prijedor and went to the camps.

23 A. Yes.

24 Q. Before that, did you ever see, for example, Zivko Ecim? Did he

25 come to Dr. Stakic's office?

Page 11095

1 A. No. I can't remember.

2 Q. Do you remember -- first, do you know Rade Mutic?

3 A. I heard of him. He is also a journalist.

4 Q. Did he phone, did he call, or did he come to the office of

5 Dr. Stakic, or did Dr. Stakic place calls to Mr. Mutic in 1992 after the

6 takeover, that you recall?

7 A. I don't remember. I can't remember.

8 Q. Did Mr. Aprilski - forgive me if I'm mispronouncing the name - did

9 you know him; one of the editors of Kozarski Vjesnik?

10 A. No, Aprilski, I don't know. I can't remember.

11 Q. You talked about the day of the takeover and coming to work. And

12 you said that you didn't notice any changes. Let me go -- excuse me, for

13 counsel, page 61, line 10 of yesterday's LiveNote, beginning on line 9.

14 You told Mr. Ostojic: "I went to the Municipal Assembly building. I went

15 to work as usual. There were no apparent changes, however standing at the

16 door of the Municipal Assembly I saw two young men in uniform."

17 After the takeover, there was sandbags built up in front of the

18 entrance to the Municipal Assembly building. Is that correct?

19 A. I don't remember that particular detail. We used to refer to

20 those as barricades, but I believe that was only following the attack on

21 Prijedor.

22 Q. During the time that you worked with Dr. Stakic after the takeover

23 in 1992, do you recall him ever complaining about the work of any other

24 persons in the municipality?

25 A. No. Not to me. We didn't discuss such things, such things as him

Page 11096

1 being unhappy about someone else's work.

2 Q. Did Dr. Stakic ever complain in your presence about the accuracy

3 or the work of the Official Gazette or of press articles?

4 A. No.

5 Q. Would Dr. Stakic receive reports, to your knowledge, of

6 interrogations that took place at the Omarska camp?

7 A. I didn't see any reports.

8 Q. Now, I asked you a question yesterday that perhaps was not as

9 clear as it should have been about whether you kept Dr. Stakic's agenda,

10 and I want to make sure that there's not a problem in the word I'm using.

11 What I mean to ask you is did you keep Dr. Stakic's schedule of meetings,

12 in other words, his appointments? Would you keep a record that at 11.00

13 on Thursday, Mr. Travar wants to come to see Dr. Stakic?

14 A. No. No. If there had been such a meeting, the two of them would

15 have been in direct contact, and then they would come and visit each

16 other, especially in the afternoon when I didn't...

17 Q. Madam, how many times, to your knowledge -- how often would the

18 Crisis Staff meet? And I'm referring to the Crisis Staff in Prijedor

19 after the takeover.

20 A. I did not convene the Crisis Staff, so I can't say how often. I'm

21 not sure. And then I'm better off not saying anything. Whether it was

22 once a day, once a week, I really don't know.

23 Q. Madam, wasn't it part of your responsibilities to know where

24 Dr. Stakic was so that if someone came to see him or called him, you would

25 be able to say, "He's in a meeting in the basement," for example, "and

Page 11097

1 will be back in an hour, expected back"?

2 A. There were moments when Dr. Stakic would just go and say, "I'm

3 going to a meeting." Now, where the meeting was taking place, I really

4 don't know. The Executive Board, perhaps, or the Crisis Staff, as you

5 say. Whether it was in the basement or in a different place, I really

6 don't know. It may have been in the big hall also.

7 Q. Well, if there was an urgent reason to contact Dr. Stakic, wasn't

8 it important for you to know where he was?

9 A. Well, yes. Then I asked the other people in the service who else

10 went to the meeting - I could have known approximately - but no one said

11 where they were, what the meeting was or anything.

12 Q. So do I take it from your answer that you don't know how often the

13 Crisis Staff met? Would that be correct?

14 A. Yes.

15 Q. Did Dr. Stakic convene, to your knowledge, meetings of the

16 National Defence Council?

17 A. No, Dr. Stakic didn't. The Secretariat for National Defence was

18 in charge of that, people who worked for them, whoever was in charge of

19 that particular thing.

20 Q. Madam, aren't you aware that the chairman of the National Defence

21 Council for Prijedor or the president was, by law, the president of the

22 municipality?

23 A. Yes, I do know that. We say "by virtue of his office," the

24 president of the council was always the president of the municipality,

25 both in peacetime and in wartime.

Page 11098

1 Q. And this was a body that brought together the police, the

2 military, and the civilian leadership of the municipality. Is that

3 correct?

4 A. I don't know who was there in that body during the war, or who was

5 present, because I wasn't the one convening the meetings. I think not the

6 civilian authorities or the army, but before the war, yes.

7 Q. So your testimony is that before the war, the civilians, the army

8 -- correct me if I'm wrong, the way I understand your answer, that the

9 civilians, the police, and the army would meet and confer, but not during

10 the war.

11 A. What I said is that I didn't know about during the war because I

12 didn't convene these meetings.

13 Q. You talked about an argument you overheard between Dr. Stakic, or

14 hearing them, Dr. Stakic and Mr. Drljaca arguing. Did you hear what they

15 argued about?

16 A. No. But they were very loud. I said I had to stand up and close

17 the window.

18 Q. So all you know was that they were speaking in very loud voices.

19 A. Yes, yes, they really raised their voice. I could almost say they

20 were swearing at each other.

21 Q. Ma'am, when Dr. Stakic came back to power in Prijedor, you

22 indicated you thought it was 1996, who became the chief of police of

23 Prijedor at that time?

24 A. I can't remember. If you remind me, perhaps then I'll know.

25 Q. Ma'am, Simo Drljaca came back and served as the chief of police,

Page 11099

1 with Dr. Stakic as the president of the Municipal Assembly, up until the

2 time he was killed following his attempted arrest in July 1997. Isn't

3 that true?

4 A. I'm not sure. I really don't know.

5 Q. Did you attend the funeral of Simo Drljaca?

6 A. No, I didn't. I had my own reasons.

7 (redacted)

8 (redacted)

9 (redacted)

10 MR. LUKIC: Excuse me, Your Honour. Can we go to a closed

11 session, as we did yesterday.

12 JUDGE SCHOMBURG: Closed session, please.

13 MR. LUKIC: And to be redacted from the video and... Thanks.

14 MR. KOUMJIAN: I apologise.

15 [Closed session]

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17 [Open session]

18 MR. KOUMJIAN: Perhaps it might be useful for me to restate the

19 question.

20 Q. Ma'am, after the takeover, from the 30th of April, 1992, through

21 the end of September, you were aware that massive crimes were occurring in

22 Prijedor against citizens of Croat and Muslim ethnicity. Isn't that

23 correct?

24 A. Massive crimes, I don't know about massive crimes. I think that

25 may be a bit too harsh. But later, in September or thereabouts, I did

Page 11102

1 learn about some things like that. And again, I didn't hear this in the

2 office where I worked, I heard it from my neighbours and people talking.

3 None of this was ever said in any of the offices where I worked. People

4 didn't talk about that. I had a serious relationship with Dr. Stakic, and

5 not only with Dr. Stakic but rather with all the presidents that I worked

6 for. They didn't talk to me about what they discussed at any of their

7 meetings.

8 Q. Ma'am, I'm now talking about what you saw and knew in 1992. You

9 told us that you knew that a mosque in the town, the main mosque, was

10 destroyed and burned in July of 1992. Correct?

11 A. Yes. That was on the 11th of July, just before St. Peter's day.

12 I said that.

13 Q. In fact, all of the mosques, all of the churches in Prijedor were

14 destroyed in 1992, weren't they?

15 A. I know about the mosque in Puharska, too. It was destroyed. The

16 young man I mentioned yesterday, he lived nearby. He told us that. My

17 son's friend.

18 Q. There was a --

19 A. Nedzko, we used to call him Nedzko. I didn't see that myself

20 because I couldn't see it. It was too far for me to see.

21 MR. KOUMJIAN: I'm sorry. Mr. Lukic, do there need to be any

22 redactions?

23 Q. Ma'am, I just wanted to make sure it was okay to mention the name

24 of your son's friend.

25 In fact, you knew that your son's friend was in the Omarska camp,

Page 11103

1 so you knew that there was a camp where people were held under horrible

2 conditions. Isn't that correct?

3 A. I don't know about the circumstances, because I wasn't there. But

4 when my son received a message from this friend of his, it was written on

5 a slip of paper used to wrap biscuits in. Then my reaction was as I

6 described yesterday.

7 Q. In fact, you were so concerned with the survival of that young man

8 that you swallowed your pride and went to speak to your ex-husband about

9 that. Is that correct?

10 A. That's correct, yes.

11 Q. Because you knew that that was a camp where horrible things were

12 being done to people. Correct?

13 A. Back then, I didn't know, but later, yes, I did hear that. This

14 young man didn't tell me anything, and he never said that anyone had done

15 anything to him or that he had been physically abused.

16 Q. Living in Prijedor, you had seen that Stari Grad had been

17 completely destroyed, both of its mosques and all of the houses except for

18 one or two were destroyed and eventually bulldozed. You saw Kozarac and

19 the Brdo area had been destroyed. Houses burned. Isn't that correct?

20 A. Well, I only went back to the old town after the war, because I

21 simply couldn't go there. I only saw Kozarac after the war also, because

22 there was no need for me, during the war, to go in the direction of Banja

23 Luka. We didn't drive around in our cars exactly because we were short of

24 petrol. Petrol was a very rare and precious commodity. Throughout the

25 whole war, I never once entered my car.

Page 11104

1 Q. Madam, for a year and a half, you worked with Muhamed Cehajic.

2 And correct me if I am wrong, but you had a good relationship with him,

3 and you saw him as a very -- a man of integrity who treated all people

4 very well. Correct?

5 A. Yes.

6 Q. You knew, in 1992, that he had been arrested and disappeared from

7 the Omarska camp. Correct?

8 A. I didn't know until much later, two or three months later. People

9 just didn't talk about these things. At least, I was never told.

10 Q. Ma'am, do you know of any Muslim or Croat that Dr. Stakic helped

11 or tried to help in Prijedor after the takeover of the municipality?

12 A. No, no, I don't know. Stakic never spoke to me about these

13 things.

14 Q. Do you know of anything that Dr. Stakic did or tried to do to stop

15 crimes from happening in Prijedor against the citizens of Prijedor?

16 A. No, I don't know. I'm not a politician myself. No one told me

17 anything about these things, nor was I in any position to see for myself.

18 MR. KOUMJIAN: I believe I do not have any further questions at

19 this time. Thank you.

20 JUDGE SCHOMBURG: Thank you.

21 MR. KOUMJIAN: I'm sorry, I did think of one. I don't know if you

22 want me to do it now. I did think of one area I forgot to cover. I could

23 probably do it in two minutes.

24 JUDGE SCHOMBURG: Please do so.

25 MR. KOUMJIAN:

Page 11105

1 Q. Madam, what do you know about why Dr. Stakic left the position of

2 president of the municipality at the end of 1992, early 1993?

3 A. No one told me officially why, but I heard that there had been

4 disagreements within the party and that that was why he left.

5 Q. Madam, in 1997, you said you came back from a sick leave and

6 Dr. Stakic was no longer coming to work. Did you have any contact with

7 him after that time?

8 A. I didn't say that I was on sick leave in 1997. That was in 1996,

9 in January, between the 23rd of January and -- you've got me confused now.

10 I can't even remember on which day my father died.

11 Q. Let me just then go to -- do you recall the day that Mr. Kovacevic

12 was arrested and Mr. Drljaca was killed?

13 A. Yes, I do.

14 Q. Were you working --

15 A. I was not at work in those days. I was on sick leave for two

16 months. I was getting my teeth fixed. And I had a visitor, and that's

17 why I remember clearly that I was not at work during those months.

18 Q. Okay. And you testified on page 80, you were asked: "When you

19 came back to work, was Dr. Stakic still coming to work as the president of

20 the Municipal Assembly?" Line 13. And you answered, "No." Is that

21 correct? When you came back from having your teeth fixed, Dr. Stakic was

22 no longer coming to work. Is that correct?

23 A. Yes, that's correct.

24 Q. Thank you. And did you have any contact with him? Did he ever

25 call you? Did you ever see him after Dr. Kovacevic was arrested? Let's

Page 11106

1 just use that as the point.

2 A. No, never.

3 Q. Did he in any way communicate to you, or did you see any

4 communication by him as to why he stopped coming to work? Did you see it

5 in the media? Did you see it in the Municipal Assembly building?

6 A. Well, there were rumours, but I don't know precisely what

7 happened.

8 Q. The rumours were that he had left Prijedor because of

9 Dr. Kovacevic's arrest. Correct?

10 A. No. What I know is that he went to pursue further studies.

11 That's what I learned later on.

12 Q. When you say learned that later on, when did you learn that? Was

13 that this week you learned that?

14 A. No. Perhaps two or three months after the date you asked me

15 about.

16 Q. Thank you.

17 MR. KOUMJIAN: I have no further questions.

18 JUDGE SCHOMBURG: Thank you.

19 Questioned by the Court:

20 JUDGE SCHOMBURG: Madam, I have sometimes difficulties with my

21 sense of orientation. And we are grateful that you described on the map

22 where the office of Dr. Stakic was located. It was on the first or on the

23 second floor of the building?

24 A. On the first floor. You have the ground floor, the first floor,

25 the second floor, and that's all. His was on the first floor, in the

Page 11107

1 middle of the building.

2 JUDGE SCHOMBURG: May I ask the usher to present to the witness

3 this piece of paper and put it on the ELMO and give at the same time a

4 pencil or a pen to her.

5 May this document be provisionally marked as J26.

6 You can see my more or less helpless attempt to draw a sketch on

7 the first floor. And to the left-hand side, I wanted to indicate that's

8 the area where the entrance was. Could you please assist us and show us

9 where and from which side the staircase arrived at the first floor.

10 A. May I use the pen to draw? This middle part, is that supposed to

11 be the corridor?

12 JUDGE SCHOMBURG: My attempt was the line in the middle, this

13 should be the corridor. Maybe I'm totally wrong and it was not such a

14 corridor, but then, please assist me.

15 A. Let me just turn the paper this way to start with.

16 [Marks]

17 These are the staircases leading from the first floor upstairs,

18 and all of this is the hallway or the corridor. These are the offices.

19 And this here, these are also offices. This is the hallway, but the

20 entrance is on the other side. Not here but on the other side. And the

21 staircase is here.

22 JUDGE SCHOMBURG: Right. And can you then please indicate on this

23 sketch where was your office.

24 A. Here. "M," my.

25 JUDGE SCHOMBURG: So this would mean that your office had no

Page 11108

1 window heading to the side where the entrance was. Correct?

2 A. There was a large window -- there was a balcony, and I could open

3 the door to the balcony. I could come out to the balcony.

4 JUDGE SCHOMBURG: But heading to the back side of the building.

5 Do you regard the part of the building where the entrance was the front

6 side?

7 A. No, no, the entrance was here. All the windows are here. This is

8 the municipal building. There are windows on the side as well, but those

9 were the windows of the offices looking at the other side. And our

10 offices were on the front of the building. It was the southern side.

11 JUDGE SCHOMBURG: So I apologise when my -- as I already

12 previously said, unhelpful attempt to draw a sketch about the real

13 entrance. On the map, we saw an entrance. So this would mean that the

14 entrance was immediately beyond your office and the balcony of your

15 office. Correct?

16 A. Yes, yes. I may have been wrong. I should have turned the paper

17 the other way around and I would have used your entrance as the real

18 entrance but I may have made a mistake by turning it the way I did.

19 JUDGE SCHOMBURG: We shouldn't discuss mistakes --

20 A. It depends on how you look at this piece of paper. I could have

21 drawn everything the other way around, on the other side.

22 JUDGE SCHOMBURG: Please do so and indicate with your own words

23 where the main entrance of the building was located.

24 A. Not here. Let's say this is the back side of the building, but

25 here, below this balcony, here is the staircase below. It's protruding a

Page 11109

1 bit further.

2 JUDGE SCHOMBURG: Okay. Then we know where we have each other.

3 Could you then indicate the room of Professor Cehajic before the takeover.

4 A. [Marks]

5 JUDGE SCHOMBURG: And Dr. Stakic's room before the takeover.

6 A. To my left was the vice-president, and to my right was the

7 president.

8 JUDGE SCHOMBURG: And to the best of your recollection, at that

9 time, in 1992, do you know about other persons having their office on the

10 same corridor? Maybe to be absolutely exact, if there was a change,

11 please indicate. Maybe a person was in an office before April 30th or

12 after. Who else had offices on this corridor?

13 A. These were the offices of communal professional affairs. This is

14 a small conference room, and this is the office of the vice-president of

15 the Executive Board. Am I doing something wrong, sir?

16 JUDGE SCHOMBURG: No, it just will be extremely difficult to

17 follow this without having it on the transcript. So the office beside the

18 office of Professor Cehajic, this was a conference room. Then it was

19 followed by the office of the vice-president of the Executive Board.

20 Correct?

21 A. Yes. And the entrance was from the Executive Board. That's what

22 I'm trying to draw.

23 JUDGE SCHOMBURG: So once again, the same system; secretary in the

24 middle room, vice-president to one side --

25 A. Yes.

Page 11110

1 JUDGE SCHOMBURG: -- and president to the other side.

2 A. Correct.

3 JUDGE SCHOMBURG: Anybody else you would identify where an office

4 was located?

5 A. Here, it was the way I've drawn it. Maybe you would be interested

6 to know that the employees of the Executive Board were sitting in the

7 offices here, across the corridor. Maybe you would also like to know

8 that.

9 JUDGE SCHOMBURG: So just on the other side of the corridor,

10 opposed to the office of the president and the vice-president of the

11 Executive Board.

12 A. Yes.

13 JUDGE SCHOMBURG: May we now turn to the other side of the first

14 floor. Who had offices there?

15 A. Here, you mean?

16 JUDGE SCHOMBURG: Yes.

17 A. These were the offices of the technical services.

18 JUDGE SCHOMBURG: To the left-hand side, offices of technical

19 service. This means the office headed by Mr. Dusan Baltic. Correct?

20 A. Yes, he was the secretary of the assembly, Municipal Assembly.

21 JUDGE SCHOMBURG: And the remaining offices, please.

22 A. In this line of offices here, there are only four offices.

23 JUDGE SCHOMBURG: And then on the other side, beside the office of

24 Dr. Stakic, these offices were occupied by whom, please?

25 A. These offices housed people from the so-called common affairs; the

Page 11111

1 personnel, education. The period of time that I'm talking about is

2 recently, as far as I can remember. I believe that it was so at that

3 time, as far as I can remember.

4 JUDGE SCHOMBURG: Thank you. This already helped a lot. If you

5 could, please, add, if you know, the names of the vice-president and the

6 president of the Executive Board on this sketch as well.

7 A. What period of time are you referring to?

8 JUDGE SCHOMBURG: Before the takeover. 1992, January until April.

9 A. President of the Executive Board, Dr. Kovacevic; Vice-president

10 Enes, and I can't remember his last name.

11 JUDGE SCHOMBURG: So this would be Kovacevic's room, the first one

12 on the right-hand side; and Enes, you said, the third one on the

13 right-hand side.

14 A. Yes, if the entrance is here, then Kovacevic is on the left, and

15 Enes is on the right. And the situation is the same as it is with my

16 office.

17 JUDGE SCHOMBURG: Thank you. I just wanted to ask you this

18 question: Whenever a person wanted to enter the office of Dr. Stakic or

19 the late Professor Cehajic, he had first to go through your office, or

20 were there separate doors to these two offices?

21 A. The small conference room here was adjacent to the president's

22 office. From the president's office, one could go to the small conference

23 room, and the small conference room also had a door directly to the

24 corridor. There is also a door from the president's office and from the

25 vice-president's office, but these doors are not really doors. They

Page 11112

1 served as a cupboard, and they were padded. And they never opened. One

2 couldn't open them.

3 JUDGE SCHOMBURG: So in conclusion, whenever a visitor entered one

4 of these two offices, he would have to go through your office. Correct?

5 A. Yes, but also no. If there was a meeting, then I would be told to

6 open the door to the small conference room. Then that conference room

7 would be open, the door would be left open. So if somebody was coming to

8 the meeting, they could do it through the -- directly to the small

9 conference room. Or if somebody wanted to go to the toilet, or if the

10 person who brought coffees and refreshments, they could also enter the

11 small conference room directly. So the meeting would start, would go on,

12 and would finish without me knowing who attended it, who left early or who

13 came later. Given the way the staircase is, it's easier for them to

14 actually go directly from the staircase to the small conference room,

15 rather than come all the way to my office, and then go through three rooms

16 in order to get to the conference room.

17 JUDGE SCHOMBURG: It becomes clearer and clearer. But I

18 understand it was for you first to open this conference room, the small

19 conference room. Normally, it was closed. Correct?

20 A. Very often. We kept them closed and locked so nobody would be

21 able to come to the president's office from, so to say, from the back

22 door. So that was the system that we used. So the technical part of my

23 job was always the same.

24 JUDGE SCHOMBURG: I understand. And from your testimony, I took

25 it that it was a different job to do the work of a typist. The typists

Page 11113

1 were in which floor of the building?

2 A. Every service or department had either one or two typists. So

3 there were typists everywhere. And the number of typists depended on the

4 size of a particular department or secretariat, as they used to be called.

5 There were no designated offices for typists.

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 A. Do I really have to say that? Because the ladies who worked

12 there, I don't know whether they will appreciate their names being

13 mentioned here.

14 JUDGE SCHOMBURG: I understand. Let us go in closed session for a

15 moment, please.

16 [Closed session]

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 11114

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5

6

7

8

9

10

11

12 Pages 11114 to 11117 redacted closed session

13

14

15

16

17

18

19

20

21

22

23

24

25

Page 11118

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 --- Recess taken at 10.39 a.m.

15 --- Upon commencing at 11.03 a.m.

16 [Open session]

17 JUDGE SCHOMBURG: Please be seated.

18 I just had forgotten one final point. You mentioned yesterday,

19 and once again today during the cross-examination by Mr. Koumjian, that on

20 the occasion of a dispute, you had to close windows. These were windows

21 in your office, being between the two other offices, or in the room

22 occupied at that time by Dr. Stakic?

23 A. First of all, Mr. Koumjian, you mean the Prosecutor?

24 JUDGE SCHOMBURG: Yes. Correct.

25 A. And now, excuse me, can you please just try to explain your

Page 11119

1 question about the windows.

2 JUDGE SCHOMBURG: You told us that once upon a time, there was a

3 such a loud dispute that you thought it would be better to close the

4 window, that others outside couldn't follow this dispute. These were the

5 windows of your office or the office of Dr. Stakic?

6 A. My window, my window. Outside, you couldn't hear, because this

7 was on the first floor. I was the only one who could hear, or anyone else

8 who happened to be sitting with me in the same office.

9 JUDGE SCHOMBURG: So the dispute, I understand, was in your own

10 office at that time?

11 A. No, no. In Mr. Stakic's office.

12 JUDGE SCHOMBURG: Not that I misunderstand anything, you were in

13 your own office, you heard a dispute in Dr. Stakic's office, and then you

14 entered, proprio motu, the office of Dr. Stakic, and then you closed the

15 window --

16 A. No. I stood up and closed my own window. May I continue,

17 please? I stood up, I closed my own window, which was behind my back.

18 JUDGE SCHOMBURG: Maybe I have some difficulties today. But when

19 closing your windows, it appears that you heard the dispute or the voices

20 from the open windows of Dr. Stakic's office. And in order not to follow

21 this dispute, you closed your windows because the voice did not come

22 through the wall or the door, but through both windows? Or was there an

23 additional window maybe between your office and the office of the

24 president of the Municipal Assembly?

25 May I ask the usher, please, once again to present Document J26 to

Page 11120

1 the witness. Sorry that I don't understand this.

2 A. That's fine.

3 JUDGE SCHOMBURG: So could you please indicate where was the

4 window you closed at that time.

5 A. This is my office. This is the balcony door, and the balcony door

6 also has a window. That's here. The balcony is just outside the

7 president's and vice-president's office. And it has both a balcony door

8 and a window, but the office is twice as big and has another window right

9 here.

10 JUDGE SCHOMBURG: And now, please, once again, cross-mark the

11 window you closed.

12 A. This window here. This is the window looking out onto the

13 balcony. And the window is just one part of it. This is the window and

14 the balcony door, a double door.

15 JUDGE SCHOMBURG: But still I don't know how could this -- closing

16 this window prevent others from listening to the dispute when --

17 A. The others, in the sense of someone walking into my office in the

18 meantime.

19 JUDGE SCHOMBURG: Okay. I think I've got the gist of it now. And

20 this concludes the reference to this document. Thank you. This can be

21 removed from the ELMO.

22 Before turning to other questions, I want to proceed based on

23 yesterday's transcript. On page 52, line 13 through 19, you explained

24 your duties as a technical secretary. You received visitors, you talked

25 to the visitors, you answered their telephones, and you would connect

Page 11121

1 calls. That, obviously, depended on whether they wanted to talk to the

2 person who wanted to talk to them. In part, it was already covered by the

3 question by the Prosecution this morning: You received visitors. Did

4 they come by chance and you were not prepared at all to receive those

5 visitors, or did you have a kind of calendar where you made your own notes

6 that a visitor would come because there was an appointment?

7 A. It's true that they came, clients would come, business people. I

8 didn't take any notes. Perhaps a name or two, so I could read it out as I

9 was speaking, but it wasn't the sort of paper or notes that I would keep,

10 because I didn't think that I would need it.

11 JUDGE SCHOMBURG: So that --

12 THE INTERPRETER: Microphone, Your Honour, please.

13 JUDGE SCHOMBURG: Sorry that we have we go in that details, but

14 related to phone calls, you told us, "I would connect them if they had a

15 call and that also obviously depended on whether they wanted to talk to

16 the person who wanted to talk to them." So a visitor arrived. You had no

17 marks in any calendar. Would you first contact Dr. Stakic or, previously,

18 Professor Cehajic whether or not they wanted to receive this person, they

19 wanted to greet or meet them, or they had no time at all?

20 A. Yes. When a client walked in -- this is how it looked roughly. A

21 client walks in and says, "I would like to speak to the president or the

22 vice-president." Very often, I would ask about the reason. And then the

23 client would either give me the reason or decline to do so. In that case,

24 I would phone the president or the vice-president if they could see this

25 particular client. If the president was busy, in that case, I would come

Page 11122

1 out and tell the client that the president was unavailable and tell them

2 to come another day. And then the day I told them to come back, the

3 client would remember it, but I didn't keep any records of that because

4 the client would just simply be back, and then I would remember that that

5 was that and that the president would be available on that day.

6 JUDGE SCHOMBURG: In the case at that point in time the president

7 was absent, and the client would ask, "What would be the appropriate point

8 in time that in all likelihood I would and could meet Dr. Stakic?" what

9 would be your answer?

10 A. In that moment, I would tell the client that I would tell the

11 president about that, and then that the client could come back at a

12 different time to see what the response would be.

13 JUDGE SCHOMBURG: So you mentioned beforehand, it is your

14 testimony that you had no overview at all on the availability in the

15 office of, be it the president or the vice-president.

16 A. No. There weren't such big meetings that you couldn't remember

17 back in that period.

18 JUDGE SCHOMBURG: Apart big meetings, to the best of your

19 recollection, do you know for what purposes this conference room close to

20 the office of Dr. Stakic at that time, for which purposes this conference

21 room was used? Who met there?

22 A. That office was used normally if the president had one client in

23 his office, and there was another client he was supposed to be seeing. In

24 that case, he would go to this small hall - that's how we referred to this

25 hall - he would open the door and see this other client if the matter was

Page 11123

1 urgent. As far as meetings, obviously when things got going, that kind of

2 thing.

3 JUDGE SCHOMBURG: Thank you. I turn now to another topic. On

4 page 56, lines 2 through 6 on LiveNote, you were asked: "Could in 1991

5 and 1992 the president of the Municipal Assembly fire, discharge, or

6 dismiss you from your employment that you held?" And your answer was:

7 "No. That would take a major violation, and then there would be a

8 disciplinary committee which would decide." Given the case, you wouldn't

9 report for a period of five days or more to work, would this be a major

10 violation, allowing for dismissal?

11 A. Well, that would depend on the reason why you were absent. It's

12 up to your direct superior to decide on that, not the president of the

13 municipality. My superior, my absence could have been justified. I could

14 have been sick without even reporting. But if after five days I appeared

15 with a medical explanation, with a medical justification, then obviously

16 that would have been accepted.

17 JUDGE SCHOMBURG: And in case there wouldn't be such a -- forget

18 about now your person as such, but in principle, if there wasn't such

19 apology or justifying your absence from work or another person's absence

20 from work, would it then be as you quoted yesterday, for a disciplinary

21 committee to decide whether a dismissal is justified or not?

22 A. I think the book of regulations governing our employment, it says

23 that if you fail to report for three or five or six, or I don't know

24 exactly how many days, entails a certain responsibility, of which nature

25 exactly, I don't know. But during my time at work, not a single person

Page 11124

1 was dismissed simply because they failed to show up for work for five

2 consecutive days.

3 JUDGE SCHOMBURG: Did you know about the existence of such a

4 disciplinary committee?

5 A. When? Now?

6 JUDGE SCHOMBURG: In 1992 and, more precise, two-fold, before the

7 takeover and after the takeover.

8 A. I didn't know about that. I do know that before the party

9 arrivals, the president and the vice-president, when the parties came to

10 power, until then, yes, there was.

11 JUDGE SCHOMBURG: This was the purpose of my question, because in

12 fact you were answered whether in 1991 and 1992, there could be a

13 dismissal on this or that basis, and then it was for you to answer

14 covering two years; but now I wanted to concentrate the question on the

15 period from January 1992 through April 1992, and then the next period

16 following the takeover. And you yourself mentioned that there would be a

17 disciplinary committee which would decide. Once again, was there, before

18 the takeover and after the takeover, such a disciplinary committee?

19 A. I don't know.

20 JUDGE SCHOMBURG: What was the reason, may I ask, that yesterday

21 you said, "Then there would be a disciplinary committee which would

22 decide"?

23 A. Perhaps I haven't understood the question, that it's only

24 referring to a certain period, or normally, otherwise.

25 JUDGE SCHOMBURG: On today's transcript, page 39, line 9, you

Page 11125

1 stated: "I didn't know about that. I do know that before the party

2 arrivals, the president and the vice-president, when the parties came to

3 power, until then, yes, there was." There was what, please?

4 A. The disciplinary committee.

5 JUDGE SCHOMBURG: Until then, you are sure that there was such a

6 committee; later, you don't know. Correct?

7 A. Yes, that's correct.

8 JUDGE SCHOMBURG: Thank you. (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 Sorry, now it was my fault. For the protection of the witness,

14 may the entire question please be redacted from the transcript and I

15 repeat it in closed session. Sorry for this.

16 THE REGISTRAR: May the public be removed from the public gallery.

17 Thank you.

18 MR. KOUMJIAN: Your Honour, is it possible to do it private

19 session?

20 JUDGE SCHOMBURG: Yes. It's easier for the public gallery, we do

21 it in private session. Do you agree? Okay. All the parties agree.

22 [Private session]

23 (redacted)

24 (redacted)

25 (redacted)

Page 11126

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 [Open session]

20 JUDGE SCHOMBURG: Yesterday, transcript page 64, and also today,

21 you mentioned Mr. Cehajic seeking to talk to Dr. Stakic. What about Minka

22 Cehajic? Did she ever try to contact Dr. Stakic?

23 A. Yes. I think it was at the beginning of June, but I can't

24 remember exactly. She said she needed to speak to Dr. Stakic, and I put

25 her through.

Page 11127

1 JUDGE SCHOMBURG: You put her through immediately on the first

2 attempt?

3 A. Yes. Yes. Immediately. The very moment after I had had a word

4 with the president.

5 JUDGE SCHOMBURG: Isn't it true, ma'am, that Minka Cehajic asked

6 you whether it would be possible, to quote from our transcript, page 2693,

7 line 22, whether it would be possible to come the following day?

8 A. I don't remember that being said. I know I just put her through.

9 JUDGE SCHOMBURG: Isn't it true, madam, that the following

10 morning, she arrived at about 9.30 in the office? Same page of the

11 transcript; 2693.

12 A. I don't remember.

13 JUDGE SCHOMBURG: You said, on today's transcript, page 41, line

14 24, that Minka Cehajic, "I think it was at the beginning of June, but I

15 can't remember exactly." May it be possible that she tried to come in

16 contact with Dr. Stakic already the 3rd or the 4th of May? So several

17 days after the takeover, end of quote, line 25, page 2693.

18 A. After the takeover, it was Mr. Cehajic who spoke to Dr. Stakic. I

19 don't remember that Minka did the same.

20 JUDGE SCHOMBURG: And it's your testimony, as you sit here, that

21 you never saw Minka Cehajic in either your office or the office of

22 Dr. Stakic?

23 A. I can't remember. I saw Minka Cehajic after the war. We bumped

24 into each other. We sat down, had a cup of coffee together.

25 JUDGE SCHOMBURG: I have to apologise. I just confused the

Page 11128

1 transcript. The meeting with -- what I just discussed - and my sincere

2 apologies - the questions were related to a meeting with Mr. Muharem

3 Murselovic. Sorry for this.

4 Did he ask immediately after the takeover to get in touch with

5 Dr. Stakic?

6 A. Murselovic, I don't remember. No.

7 JUDGE SCHOMBURG: Once again, it's the same page of the

8 transcript. Isn't it true that Mr. Murselovic asked you to get in touch

9 with Dr. Stakic and that you told him to come the following day?

10 A. I really don't remember.

11 JUDGE SCHOMBURG: You remember that the following morning, he, in

12 fact, arrived at about 9.30?

13 A. No. I believe that Murselovic mentioned that in a conversation,

14 but I can't really remember that I saw him.

15 JUDGE SCHOMBURG: Page 2695 of our transcript, isn't it true that

16 Mr. Murselovic "joked a little bit with the secretary, with Mica, and I

17 told her: `Listen, Mica, the presidents here keep changing, but you are

18 constant. You are also here.' She was the secretary for Mr. Cehajic

19 before." And so -- another quote, Mr. Murselovic told you: "Well,

20 listen, Mica, the presidents keep coming and going, but you are here

21 always."

22 A. I don't remember those times. I even told him that when we had

23 this private conversation when he was the vice-president of the Municipal

24 Assembly. It was an informal conversation in which I told him that.

25 JUDGE SCHOMBURG: Did you at that time discuss with Muharem

Page 11129

1 Murselovic the fact that Dr. Stakic occupied Mr. Cehajic's office within

2 days of the takeover?

3 A. No, I don't remember at all that Muharem was there. Therefore, I

4 don't remember the conversation.

5 JUDGE SCHOMBURG: Was it ever discussed at that point in time that

6 Dr. Stakic had or would go to Banja Luka?

7 A. No.

8 JUDGE SCHOMBURG: So then we really can come back to Dr. Minka

9 Cehajic. Once again that we have the necessary follow up, we discussed

10 this already beforehand, she tried to contact Dr. Stakic by telephone.

11 And is it correct that you told her that Dr. Stakic and Kovacevic could

12 not be reached?

13 A. I told you that I don't remember that, and especially not about

14 Dr. Kovacevic, who was not sitting together with me and whose calls I

15 couldn't put through even if I wanted to do that.

16 JUDGE SCHOMBURG: Would it be correct that Minka Cehajic tried for

17 several times to reach, in this case, Dr. Stakic?

18 A. I don't remember. And I'm really sorry for Minka if that indeed

19 was the case, but I don't remember.

20 JUDGE SCHOMBURG: Did you then later - maybe not in the office but

21 in town or elsewhere - have a discussion with Dr. Cehajic on Professor

22 Cehajic's fate?

23 A. Dr. Cehajic and I met, I believe it was last year, in the street

24 where the restaurant Expres is. There were two other persons with us, and

25 the gentleman who was with us suggested that we should sit on the terrace

Page 11130

1 in front of the Expres restaurant and have a cup of coffee. The

2 conversation was friendly and informal. We were asking after each other's

3 children and what each of us was doing at the time and how we were.

4 Things like that. None of us mentioned the period in question, the period

5 that you are asking me about.

6 JUDGE SCHOMBURG: Let me try the other way around. You were the

7 receptionist, we understood, opposed to the ordinary work of a secretary.

8 But from your own assessment, seeing the visitors coming in and out, from

9 your point of view, who was the more important person; the president, the

10 vice-president?

11 A. There was a hierarchy. The president was on the top of that

12 hierarchy, and he was followed by the vice-president.

13 JUDGE SCHOMBURG: And what about the hierarchy when we take into

14 account also the name of Dr. Kovacevic?

15 A. When it comes to the municipality, it is the president and then

16 the vice-president and the Executive Board is a different body, and

17 Dr. Kovacevic was its head. And then there were heads of various services

18 or departments.

19 JUDGE SCHOMBURG: From your point of view as a citizen of

20 Prijedor, who was, in terms of influence, political influence, the

21 high-ranking person; Dr. Stakic as the president of the Municipal

22 Assembly, or Kovacevic in his area?

23 A. As far as politics go, I don't know. But if we're talking about

24 administrative body, the influence on the assembly, on the administrative

25 bodies, Stakic was the president of the assembly, and Dr. Kovacevic was

Page 11131

1 the president of the Executive Board, which indicates that Dr. Kovacevic

2 had influence on administrative organs because they were under the

3 authority of Dr. Kovacevic.

4 JUDGE SCHOMBURG: So once again, the question I have put to you

5 already: Did you see Dr. Kovacevic in Dr. Stakic's office?

6 A. Yes.

7 JUDGE SCHOMBURG: This happen --

8 A. But not in the office. They would pass by me, so I would see them

9 passing by. And when he entered or when I entered, then obviously, he

10 would ask me what I was going to drink, for example. But that was only

11 when I was invited.

12 JUDGE SCHOMBURG: How often did this happen that both of them came

13 together? To the best of your recollection, of course.

14 A. To go through my office, I don't remember the number of times.

15 JUDGE SCHOMBURG: Frequently, daily, weekly, monthly?

16 A. They did not need to see each other every day. Maybe once or

17 twice a week, or even less than that.

18 JUDGE SCHOMBURG: I take it from your testimony that you were

19 invited going for a drink together with them. Is this correct, or was

20 this a misunderstanding?

21 A. It was a misunderstanding. That was a misunderstanding. They

22 would invite me, they would call me and ask me to order a drink for them.

23 We had a kitchen, a kitchenette, and a person working there. So I would

24 call that person and I would order drinks for Dr. Stakic or for

25 Dr. Kovacevic if he was in Dr. Stakic's office. I would ask them to bring

Page 11132

1 a cup of coffee or something, whatever they asked me to order for them. I

2 never had a drink with any president ever.

3 JUDGE SCHOMBURG: Thank you for this clarification. And I take it

4 from this that apparently you told us yesterday the limited responsibility

5 you had at that time, and you were not at all involved, for example,

6 preparing a cup of coffee for Dr. Stakic or any visitor. You would ask

7 others to bring this to the office. Correct?

8 A. I don't remember that we spoke about coffee yesterday. But you

9 are right. If somebody wanted coffee in their office, I would call this

10 lady who worked in the kitchenette, and I would ask her to bring the

11 coffee.

12 JUDGE SCHOMBURG: I'm following the order of the transcript, and

13 therefore it leads me to page 80, yesterday it was discussed what happened

14 in July 1997. On line 12, you said: "I had been on sick leave for almost

15 two months." When you came back to office, who was in both rooms you

16 mentioned previously and indicated on Exhibit J26? This was your sketch.

17 Were both offices occupied or only one?

18 A. Both offices were empty, as far as I can remember.

19 JUDGE SCHOMBURG: So I would ask, me myself, coming back from a

20 sick leave for almost two months, the president not there, vice-president

21 not there, what did you do? Whom did you ask what to do?

22 A. I did not return after two days after the day in question but

23 after more than a month, so that I don't know what I did, whether I asked

24 somebody or not. I can't remember. I don't know. I can't remember.

25 JUDGE SCHOMBURG: When was it that the one -- that Dr. Stakic or

Page 11133

1 both positions, that there was a replacement, if so?

2 A. I can't remember the date when that happened.

3 JUDGE SCHOMBURG: This is easy to understand due to the course of

4 time. But who were the next ones in the line of your bosses? We learned

5 that you had apparently up to 13 presidents, and maybe then later even a

6 mayor. But who was the next in line following Dr. Stakic, and when did he

7 arrive, or she maybe?

8 A. After the year 1997, that is.

9 JUDGE SCHOMBURG: Right.

10 A. It was Borislav Maric who came.

11 JUDGE SCHOMBURG: She was then acting as the president of the

12 Municipal Assembly at that time, or already as mayor? I'm sorry, I'm not

13 aware when this change happened.

14 A. Mr. Maric stayed in the position for quite some time, until the

15 arrival of the lady who replaced him in the year 2000. And I don't know

16 how long Borislav Maric stayed. Well, this is an example to show that I

17 really don't know how long people stayed in office.

18 JUDGE SCHOMBURG: Following your long career, this is easy to

19 understand, no doubt.

20 Page 82 of yesterday's transcript, you mentioned that it was not

21 for you to take care that Dr. Stakic received documents, newspapers, or

22 the Official Gazette. Correct?

23 A. Up to the takeover, we received Politika, Oslobodenje, and Glas

24 regularly. When Kozarski Vjesnik started being printed, I don't know when

25 that was, and I don't know who brought it to our office. But in any case,

Page 11134

1

2

3

4

5

6

7

8

9

10

11

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

13 English transcripts. Pages 11134 to 11144.

14

15

16

17

18

19

20

21

22

23

24

25

Page 11145

1 we would find it on our desks in the morning when we arrived at work.

2 JUDGE SCHOMBURG: So this was -- it arrived daily, both the

3 Kozarski Vjesnik, and then later, as we have seen it, the wartime edition

4 of Kozarski Vjesnik?

5 A. Kozarski Vjesnik is a weekly, and it was published on Fridays, I

6 believe.

7 JUDGE SCHOMBURG: So you received Kozarski Vjesnik, all of you,

8 you as the person responsible for the reception of persons, the president

9 and the vice-president. Correct?

10 A. I did not receive it. It was not envisaged for me to receive it.

11 When I say press, I have in mind the period before the takeover and after

12 the takeover. So the press arrived for both the president's office and

13 the service, that is, the technical service.

14 JUDGE SCHOMBURG: Just for clarification, on page 48, line 25, you

15 stated, "Up to the takeover, we received Politika, Oslobodenje, and Glas

16 regularly. When Kozarski Vjesnik started being printed, I don't know when

17 that was, and I don't know who brought it to our office. But in any case,

18 we would find it on our desks in the morning when we arrived at work." So

19 this was what confused me, reading the "we received it." What means "we"?

20 A. We. I may have used the wrong word. I would find a stack of four

21 or five copies. I would give one to the president, the other to the

22 vice-president, and the other copies would be sent throughout the

23 different services. If I needed one, I had to put it away somehow because

24 we weren't getting a sufficient number of copies.

25 JUDGE SCHOMBURG: Thank you. And the final question before the

Page 11146

1 break: What about the Official Gazette? Was it the same approach taken

2 there, that it also arrived with you and then distributed?

3 A. No. The Official Gazette, I'm not sure when it was printed.

4 Someone from the services - because that's where it was printed - would

5 bring it to the president, so there was no need for me to know what the

6 agenda of the assembly would be. Those were just brief overviews of the

7 minutes.

8 JUDGE SCHOMBURG: I didn't ask you about the agenda of the

9 assembly. I only asked whether or not in -- put it more generally: In

10 the office of the president, in your office, or in the office of the

11 vice-president, there was this Official Gazette available.

12 A. The Official Gazette, as I've said, would be brought by someone

13 from the services when, I suppose, one of the secretaries -- employees, I

14 don't think they only came for the Official Gazette. Maybe there were

15 other things or documents. And then they would give the Official Gazette

16 to both the president and the vice-president. When the Official Gazette

17 was published and when they began publishing, when they first began

18 publishing, I really don't know.

19 JUDGE SCHOMBURG: Thank you for your assistance until now.

20 We'll have a break now. And therefore, the trials stays adjourned

21 until half past 1.00.

22 --- Luncheon recess taken at 12.05 p.m.

23

24

25

Page 11147

1 --- On resuming at 1.33 p.m.

2 JUDGE SCHOMBURG: Please be seated.

3 May the witness please be shown Document S180.

4 Immediately before the break, we discussed questions related to

5 the Official Gazette. It's now more than ten years, but would you

6 identify this document as Official Gazette 2 of 1992, dated the 25th June,

7 1992?

8 A. Yes, the Official Gazette had exactly this kind of heading. That

9 should be it.

10 JUDGE SCHOMBURG: Could you please be so kind and have a look on

11 item number 117.

12 A. I can't seem to find it right now.

13 JUDGE SCHOMBURG: It was just a random decision to ask you to have

14 a look on 117. If you could have a look, for example, on 115, did you

15 ever see these kinds of decisions, conclusions, orders or whatsoever?

16 A. This decision specifically, I have never seen.

17 JUDGE SCHOMBURG: In general, did you see decisions taken by the

18 Crisis Staff and then appearing in the Official Gazette?

19 A. No. I didn't need to read the Official Gazette, and I happen to

20 know what it looks like from the time I worked in the technical services.

21 JUDGE SCHOMBURG: Nevertheless, the question, you can see here on

22 this example, this document, a typewritten, signed by Dr. Milan Kovacevic.

23 The one before was signed by Dr. Stakic. Do you know what was the reason

24 that some decisions were signed by Dr. Kovacevic, some by Dr. Stakic?

25 A. No.

Page 11148

1 JUDGE SCHOMBURG: Dr. Stakic at any point in time approach you,

2 telling you that it's impossible that these decisions bearing his name --

3 if you, on perusal, you will see that most of the decisions were signed by

4 Dr. Stakic in this Official Gazette 2 of 1992, that they were signed

5 allegedly by him. Did he ever tell you this was not correct, there was

6 something wrong with these signatures?

7 A. No, he never said anything like that, nor did we ever discuss

8 anything along these lines.

9 JUDGE SCHOMBURG: Thank you.

10 May I then ask the witness be shown Exhibit Number S79.

11 In the moment, we are not interested in the contents of this

12 document, but if you could be so kind and look on the signature.

13 And do we have the B/C/S original version? Okay, thank you. If,

14 please, the B/C/S version could be put on the ELMO.

15 What would be your comment, without any questions, related to this

16 signature block on the right-hand side of the bottom lines of the

17 document?

18 A. I don't know Dr. Stakic's signature. If you had hidden the part

19 towards the top, if you only made me read what's written towards the

20 bottom of the page, I wouldn't even be able to read it.

21 JUDGE SCHOMBURG: What about the stamp we can see here? Where in

22 your office or Dr. Stakic's office was actually the stamp?

23 A. That was in the technical services; neither of the offices you

24 have just referred to.

25 JUDGE SCHOMBURG: So it was your testimony that neither stamped --

Page 11149

1 any of the documents were stamped in the office of Dr. Stakic or in your

2 office. Correct?

3 A. It certainly wasn't in my office. And in Dr. Stakic's office, I

4 didn't see it.

5 JUDGE SCHOMBURG: Tell me, from my experience in former communist

6 countries, were your offices locked in the evening by seal?

7 A. No, never. Never. I would come to work, and the office would be

8 unlocked. There was even a fire usually left burning during the time

9 there was no heating.

10 JUDGE SCHOMBURG: Was there a special cupboard for different

11 stamps to be used in office?

12 A. We didn't have any stamps. I didn't see any stamps being used. I

13 guess that's self-implicit.

14 JUDGE SCHOMBURG: "We" means you and Dr. Stakic?

15 A. Yes, yes, and the vice-president, too.

16 JUDGE SCHOMBURG: So the whole of the president's office, as you

17 previously testified on page 52, line 21, that was in the technical

18 services. And you are quite sure that the stamps were attached at the

19 technical services unit?

20 A. When I said that, I meant the usual work performed by the

21 technical services, the technical services unit. If you show me one from

22 the Crisis Staff, I really don't know who did it.

23 JUDGE SCHOMBURG: You're talking now about a stamp used by the

24 Crisis Staff. Correct?

25 A. I don't know what it looks like. I don't even know who put the

Page 11150

1 stamps there for the Crisis Staff, on behalf of the Crisis Staff. I

2 really don't know. Wherever I say, I would only be guessing.

3 JUDGE SCHOMBURG: Right.

4 Then please leave the document with the witness, and show the

5 witness now Exhibit Number S71. As usual, the best possible, and if

6 possible, even the colour copy.

7 Would you please comment once again on the signature and stamp

8 block, and compare the two documents you have before you.

9 A. I don't know the signature. I'm sure about that.

10 JUDGE SCHOMBURG: Is there a difference between the two

11 signatures?

12 A. Yes. By just looking at it, I would say yes.

13 JUDGE SCHOMBURG: So why this? You're more acquainted with your

14 mother language than we are. Can you see the reason why we have two

15 different signatures, apparently?

16 A. The shape is different. Can't read either of these signatures. I

17 really don't know.

18 JUDGE SCHOMBURG: Then leave also the two documents with the

19 witness, and show -- the witness may be shown Exhibit 79.

20 Once again, the signature block, can you identify "Za" in front of

21 the typed name Milomir Stakic?

22 A. Well, I can see some of the stamp, but I can't see "Za" written

23 anywhere. Perhaps it is, but I can't see it.

24 JUDGE SCHOMBURG: What would it mean if there would be a "Za" in

25 front of the signature?

Page 11151

1 A. From my own experience, that means that someone else is signing on

2 behalf of the person.

3 JUDGE SCHOMBURG: On which occasion was it necessary that somebody

4 else signed on behalf of Dr. Stakic?

5 A. I really can't even assume. I really don't know.

6 JUDGE SCHOMBURG: So let's take the scenario, a person, as you

7 told us, is coming in. He or she wants to have the signature of

8 Dr. Stakic. He's not available. To whom would you send this person

9 interested to have the signature as soon as possible?

10 A. Well, whoever brought something to be signed, that person should

11 know who's in charge of signing the paper. It wasn't up to me to decide

12 such issues.

13 JUDGE SCHOMBURG: So your testimony is you are not aware who was

14 in charge in case Dr. Stakic was not available to sign documents if

15 necessary. Correct?

16 A. I simply don't know. I'm not a lawyer, to know about what other

17 people's authorities were. That's a purely legal matter, I think.

18 JUDGE SCHOMBURG: Maybe one can have a different view and see it

19 as a more practical matters that one knows who has to sign, and therefore

20 sent the requesting person immediately to the person in charge. But your

21 testimony is quite clear, and so therefore, we have to take it as it is.

22 But let's have two additional documents. Leave the others,

23 please, with the witness. And then Exhibit S70, 7-0.

24 What about signature, what about stamp?

25 A. You can see that the stamp is of the Municipal Assembly. And the

Page 11152

1 signature, I'm really not familiar with this signature.

2 JUDGE SCHOMBURG: And then if you have a look to the left-hand

3 side, in front of the date 9 June 1992, what can we read there?

4 A. You mean the date? The date beneath the number.

5 JUDGE SCHOMBURG: Yes. The word in front of the 9. What does it

6 say?

7 A. I really don't know. This is illegible. I can't read this.

8 JUDGE SCHOMBURG: And then please go to the top of this page,

9 right-hand side. Yes, thank you. What can we read there?

10 A. Here it says "Jankovic," and "Prpos".

11 JUDGE SCHOMBURG: Who was Mr. or Mrs. Jankovic or Prpos, do you

12 know?

13 A. No. It would be a difficult assumption to make just by looking at

14 this family name. I really don't know.

15 JUDGE SCHOMBURG: Right. What about the filing system? Let us

16 take -- stay for a moment with this document. When such a document was

17 filed, do you have a central registry or registrar where all these

18 documents were archived, or was it the case that in order that the one

19 signing documents had an overview of what he had signed in the past, that

20 one copy was left in the office of the signing person?

21 A. We have a special filing room in which all the documents that

22 reach the Municipal Assembly end up. And then documents are forwarded

23 through the records to a certain service or department.

24 JUDGE SCHOMBURG: So it's your testimony none of the copies would

25 be left by the signator in his or her office?

Page 11153

1 A. I really wouldn't know. You asked me about the general method of

2 keeping records, incoming records. I don't think that even existed in

3 terms of all documents that were signed being recorded in some sort of a

4 filing archive. I don't think there was such a thing.

5 JUDGE SCHOMBURG: Thank you.

6 And then may the witness please be shown additionally

7 Document S96.

8 And once again, please, concentrate on this block, the signature

9 and stamp block. What can you read there?

10 A. I am not familiar with this signature. It's typed very clearly,

11 so I may be able to assume what's written there, but the signature itself,

12 I don't recognise.

13 JUDGE SCHOMBURG: In this case, I don't want only -- not only to

14 refer to the signature, but also to the words typed. Would you please

15 read them aloud.

16 A. "President of the Assembly of the Serbian people of Prijedor

17 Municipality." I didn't realise that that was the official name. Serbian

18 people. God forbid. I really don't know about this.

19 JUDGE SCHOMBURG: And then the name typed there?

20 A. What I see typed here is Dr. Milomir Stakic.

21 JUDGE SCHOMBURG: And can you identify the stamps? And especially

22 the left-hand stamp, the insignia in this stamp?

23 A. Yes, the coat of arms bears the letters SDS. But I don't

24 recognise the entire stamp. I do know some of these marks.

25 JUDGE SCHOMBURG: Thank you. And then additionally, S101. What

Page 11154

1 can you identify there, be it handwritten or be it typed, the signature

2 block?

3 A. I can't recognise anything. The only thing I can do is read it

4 out. But it doesn't remind of anything I had seen before.

5 JUDGE SCHOMBURG: Okay. In this case, we have to add another

6 exhibit, 172, please.

7 Can you identify this document?

8 A. No. I see for the first time that there was some record of people

9 who attended a session. This is absolutely unknown to me, something like

10 that. I'm absolutely not familiar with this.

11 JUDGE SCHOMBURG: Okay. Then thank you for this at the moment.

12 And the documents may be returned to Madam Registrar.

13 Totally different topic: We touched briefly upon it yesterday.

14 At what point in time did Dr. Stakic wear a uniform?

15 A. As far as I can remember, it was only on some very few occasions,

16 when he would go to see the recruits off. I really didn't make a note of

17 these things. They were not relevant, and it is really very unusual for

18 me to have to think back on those occasions after such a long time.

19 JUDGE SCHOMBURG: Were you yourself ever asked to wear a uniform?

20 A. No, no. I wore civilian clothes, and I just did my job.

21 JUDGE SCHOMBURG: Was there ever a duty for members of part of the

22 civil servants, be it the Executive Board or others, to wear uniforms at a

23 certain point in time?

24 A. Only the military wore uniforms. We were an administrative body,

25 and just civil servants, just -- and the employees of that body never wore

Page 11155

1 uniforms.

2 JUDGE SCHOMBURG: Therefore, my question: Did you see Dr. Stakic

3 in his office wearing a uniform?

4 A. I said that he would come to the office, and then he would go to

5 see the recruits off. And he only wore uniform on those occasions. I'm

6 not talking about people being sent to war, but young people, young men

7 who were recruits and who were being sent to the regular army.

8 JUDGE SCHOMBURG: Do you know Mr. Milovan Dragic?

9 A. No. I know Dragic.

10 JUDGE SCHOMBURG: Milovan Dragic.

11 A. Yes, I know Dragic.

12 JUDGE SCHOMBURG: He was a visitor to Dr. Stakic's office?

13 A. I can't remember.

14 JUDGE SCHOMBURG: I apologise --

15 A. If anything --

16 JUDGE SCHOMBURG: -- for being not concrete. When I ask you this

17 line of questions, it's always related to the period of time after the

18 takeover until the end of 1992. So to the best of your recollection, you

19 don't know. If so --

20 A. I can't remember.

21 JUDGE SCHOMBURG: Transcript page 10.526, Mr. Dragic testified, on

22 line 25: "Members of the Executive Board wore uniforms, too, but only for

23 a very brief while." Is this correct?

24 A. I don't know. I didn't even know who the members of the Executive

25 Board were. I'm sorry. If you refer to the members of the Executive

Page 11156

1 Board, I really don't know. And that is what I'm reading in front of me.

2 JUDGE SCHOMBURG: Yes. But what about the persons living together

3 or working together with you on the same corridor on the first floor of

4 the municipal building? For example, Mr. Kovacevic and his deputy, did

5 they wear, at a certain point in time, uniforms in office?

6 A. I do not recall that as being an obligation. I remember

7 Dr. Kovacevic wearing running shoes, Adidas shoes, and a pair of worn-out

8 blue jeans. That's what I remember.

9 JUDGE SCHOMBURG: But please, this was not the question. The

10 question was: Did you see Mr. Kovacevic in office wearing a uniform?

11 A. No. I didn't go to his office, and I don't remember that he did.

12 JUDGE SCHOMBURG: Without quoting a name, because it was in closed

13 session, page 7563, when Dr. Stakic wore a camouflage uniform, did he, in

14 addition, wear a belt around his waist and had a pistol tucked away in his

15 belt?

16 A. I don't remember.

17 JUDGE SCHOMBURG: Experience shows that extraordinary incidents or

18 accidents are recalled easily. So wouldn't it be extraordinary if you

19 would see your boss wearing a pistol tucked away in his belt?

20 A. Yes, you're right. I should be able to remember that, but I

21 really don't.

22 JUDGE SCHOMBURG: Did Dr. Stakic wear a camouflage uniform the day

23 after the attack? I make reference to transcript pages 3209, following.

24 A. I can't remember. I don't know.

25 JUDGE SCHOMBURG: May then I ask the video unit to play the first

Page 11157

1 video. This is - please assist me - exhibit number S7.

2 Could it please be started. Today I can't see anybody through the

3 glass. Oh, yes.

4 [Videotape played]

5 THE INTERPRETER: Microphone, Your Honour.

6 JUDGE SCHOMBURG: So stop, please. May I ask you --

7 THE INTERPRETER: Microphone, Your Honour.

8 JUDGE SCHOMBURG: May I first ask the video unit to try to fix

9 that we have a kind of a still -- yes, thank you.

10 Can you identify persons sitting here?

11 A. Zeljaja, and the others I can't recognise.

12 JUDGE SCHOMBURG: Where would Zeljaja sit? We have five persons.

13 A. He is the first.

14 JUDGE SCHOMBURG: To the left-hand side or to the right-hand side?

15 A. On my right.

16 JUDGE SCHOMBURG: We can read that it's 11:36:34:03, and this

17 would be the person immediately over 34:03. Correct?

18 A. Yes.

19 JUDGE SCHOMBURG: If you could please rewind the video. Very

20 short. Stop.

21 Can you now identify additional persons?

22 A. Yes, I can see Budimir and Dr. Stakic.

23 JUDGE SCHOMBURG: Budimir would be seated where, please?

24 A. On my right. Looking from my position, he is on the right.

25 JUDGE SCHOMBURG: Beside Dr. Stakic?

Page 11158

1 A. Yes.

2 JUDGE SCHOMBURG: For the transcript, it's now 11:36:30:13.

3 And could you please rewind a little bit further. Okay. This was

4 not helpful. Please play it again.

5 [Videotape played]

6 JUDGE SCHOMBURG: Stop. On the left-hand side, you can identify a

7 person?

8 A. No.

9 JUDGE SCHOMBURG: Okay. Then please continue with the video.

10 [Videotape played]

11 JUDGE SCHOMBURG: Stop.

12 Do you know one of these three persons? We are now at

13 11:36:37:02.

14 A. No. No.

15 JUDGE SCHOMBURG: Then please continue playing the video.

16 [Videotape played]

17 JUDGE SCHOMBURG: Stop.

18 We are now at 11:36:46:21.

19 A. It's very dark, so I can't see very well.

20 JUDGE SCHOMBURG: Is it better now for you?

21 A. No. I can't see their faces.

22 JUDGE SCHOMBURG: So please continue with the video.

23 [Videotape played]

24 JUDGE SCHOMBURG: Whenever you see a person you know, please stop.

25 You didn't see anybody else whom you would know?

Page 11159

1 A. Yes.

2 JUDGE SCHOMBURG: Then please, wind it forward once again. Say

3 stop, please, when you --

4 A. Okay, stop. I can see Dragan Savanovic.

5 JUDGE SCHOMBURG: 11:37:06:02. This would be the person seated in

6 the middle of the three persons. Correct?

7 A. Yes.

8 JUDGE SCHOMBURG: Anybody else you identified during --

9 A. I don't know anybody else.

10 JUDGE SCHOMBURG: Thank you. Then let's conclude with this video,

11 and then go immediately to the next video. This would be S157. Correct?

12 Please start.

13 [Videotape played]

14 JUDGE SCHOMBURG: You can see the persons sitting here?

15 A. Now I can see Dr. Kovacevic.

16 JUDGE SCHOMBURG: Can you see Dr. Stakic?

17 A. Yes.

18 JUDGE SCHOMBURG: Can you see him wearing a uniform?

19 A. No, I can't see it in this photo.

20 JUDGE SCHOMBURG: So then, please, rewind the video. Please

21 rewind the video to the beginning.

22 Stop. Just the first seconds of the video. Stop.

23 A. I can see it now.

24 JUDGE SCHOMBURG: And was this one of the occasions you previously

25 told us Dr. Stakic would wear a uniform?

Page 11160

1 A. I don't know what this occasion is. I don't know what this is.

2 JUDGE SCHOMBURG: Then please play the video.

3 [Videotape played]

4 JUDGE SCHOMBURG: You can identify the lady sitting there?

5 A. Can you maybe rewind a little or forward it a little, if possible?

6 JUDGE SCHOMBURG: So let's, please, rewind a little bit, and then

7 forward, and then --

8 A. Maybe zoom it in.

9 JUDGE SCHOMBURG: Let's stop here. Try whether you can see it.

10 Can you identify the lady?

11 A. I can't see very well. I'm not sure that I do. I think it may be

12 Mrs. Balaban, but I'm not sure because I don't see it very well.

13 JUDGE SCHOMBURG: At what occasion were you asked to call Madam

14 Balaban?

15 A. I believe that foreign journalists were there at the time, or

16 something like that. I don't know what kind of a meeting that was.

17 JUDGE SCHOMBURG: And can you try to explain to us why the persons

18 we are -- we can see on this still and on other occasions, being members

19 of the Executive Board or of the police or the army or of the Municipal

20 Assembly, as we can see in front of us, Dr. Stakic wearing uniforms, not

21 only for this official ceremonies, as you told us previously, but when

22 international journalists arrived. Why is this?

23 A. Can you please, Your Honour -- I didn't understand your question.

24 JUDGE SCHOMBURG: You told us previously that on special

25 occasions, special ceremonies, it was the custom of that Dr. Stakic at

Page 11161

1 least wore a uniform. Now we can see here on the video that not only

2 Dr. Stakic, but also other representatives, be it from the Executive

3 Board, be it from the police, be it from the military, wearing uniforms.

4 A. Am I supposed to now tell you why they wore uniforms on that

5 occasion? I really don't understand what is expected of me.

6 JUDGE SCHOMBURG: Can you give us the reason why, based on this

7 video, based on the testimony of other witnesses, having seen Dr. Stakic,

8 Dr. Kovacevic wearing uniforms in the building where you worked, in

9 uniform? What was the reason why a president of a Municipal Assembly wore

10 a uniform, why a president of the Executive Board wore a uniform?

11 A. Firstly, I can't see that this is really a uniform on the

12 president of the Executive Board. I don't know what kind of a meeting

13 this is. Was that maybe on that day when he was supposed to see the

14 recruits off, and then after that he attended this meeting? I don't know.

15 JUDGE SCHOMBURG: Okay. Let's now turn to some remaining topics.

16 Thank you, in the direction of the video unit. We can stop this

17 now.

18 During yesterday's testimony, LiveNote page 84, line 19 through

19 21, you were asked: "Decisions within the competence of the Municipal

20 Assembly. In other words, the work that the Municipal Assembly would

21 normally do, the decisions that they would normally make, who was making

22 those decisions when the Municipal Assembly was not meeting in 1992?"

23 Answer: "I don't know. The assembly wasn't meeting. There were

24 no written decisions to be made, so I don't know."

25 How did you know that the assembly wasn't meeting, having learned

Page 11162

1 that you didn't have any calendar, any kind of schedule, any kind of

2 overview of the work exercised by Dr. Stakic?

3 A. I simply couldn't remember.

4 JUDGE SCHOMBURG: But you explicitly stated, "The assembly wasn't

5 meeting." What brings you to this testimony?

6 A. I think the last meeting of the assembly was held when Bosnia and

7 Herzegovina seceded from Yugoslavia. I don't know when they met again

8 after that.

9 JUDGE SCHOMBURG: For a better understanding, you just said: "I

10 think the last meeting of the assembly was held when Bosnia and

11 Herzegovina seceded from Yugoslavia." What has this to do with the

12 internal affairs in Prijedor?

13 A. All I know is that that was when the last meeting of the assembly

14 took place. And after that, I don't really know whether there were any

15 further meetings or not.

16 JUDGE SCHOMBURG: The second part of your answer yesterday was:

17 "There were no written decisions to be made, so I don't know." What

18 brings you to your testimony? What's the underlying basis for this

19 testimony that you can state that there were no written decisions to be

20 made?

21 A. Can you please repeat the question, Your Honour. Because I'm not

22 sure what I meant yesterday when I said that. So if I can just have the

23 question repeated, I'll try to think back.

24 JUDGE SCHOMBURG: I want to repeat your answer in context. When

25 asked whether or not there was a Municipal Assembly meeting in 1992, your

Page 11163

1 answer was: "I don't know. The assembly wasn't meeting. There were no

2 written decisions to be made, so I don't know."

3 My question was: What brings you to the testimony that there were

4 no written decisions to be made, having stated previously that you were

5 not involved at all in the preparation and execution of written decisions?

6 A. Well, I could have heard when the meeting of the assembly was

7 supposed to be held. Some of the people I worked with would probably have

8 brought up the subject. They would say something like, "We're going to

9 the meeting." So that's the only way I could have known.

10 JUDGE SCHOMBURG: But my question was related to exactly why did

11 you know that there were no written decisions to be made?

12 A. I didn't see any. They didn't pass through my hands, not before

13 that point and not after that point. So I really don't know.

14 JUDGE SCHOMBURG: But read in context, you stated: "The assembly

15 wasn't meeting. There were no written decisions to be made." Normally,

16 one could conclude from this that, previously, written decisions were made

17 when the assembly was meeting, but not later on. Is this assessment

18 wrong?

19 A. I don't know. All I can say is, again, when there was a meeting

20 of the assembly, I wouldn't know the date because the whole of the

21 department would go, or many people from the department would go to attend

22 the meeting. And usually, they would tell me that they would be absent.

23 Whenever the president went to an assembly meeting, or the vice-president,

24 and when I said what I said yesterday, what I must have meant was that

25 throughout that period, there were no such moments.

Page 11164

1 JUDGE SCHOMBURG: So it would be now your testimony that when the

2 assembly met, you were informed by Dr. Stakic. Correct?

3 A. I could have known that he was going to an assembly meeting. Some

4 people from the department would tell me, or Dr. Stakic could have said it

5 himself, too.

6 JUDGE SCHOMBURG: And apropos meeting, when we saw the video just

7 some minutes before, did you identify the room where this meeting with the

8 journalists was held? Was this a conference room? Was it a room where

9 the assembly was meeting? Unfortunately, we all don't know, so if you

10 could be kind enough and assist us in identifying the room we saw.

11 A. It's not the hall where the assembly was meeting, because that

12 hall must be much bigger in order to be able to seat all the deputies.

13 JUDGE SCHOMBURG: So in which room met the Crisis Staff; in the

14 one we saw on the video or in the room where normally the assembly met?

15 A. I didn't recognise this particular room, nor do I know where

16 Crisis Staff meetings were held.

17 JUDGE SCHOMBURG: Page 85 of yesterday's testimony, when asked

18 about documents, you stated on line 8: "No, I never brought him any

19 documents to be signed." And then you added: "Not even before the war."

20 What does it mean, "never brought him any documents to be signed,

21 not even before the war"? Why this distinction between the time before

22 and after the war?

23 A. What I really wanted to say is that it wasn't part of my job. It

24 wasn't part of my job before the war, it wasn't part of my job during the

25 war.

Page 11165

1 JUDGE SCHOMBURG: Thank you.

2 I think on page 94, 95 of yesterday's testimony, you told us that

3 in July 1992, Dr. Stakic received Mr. Zupljanin. Correct?

4 A. No, that was a slip of the tongue. Zupljanin used to come --

5 because the Prosecutor had mentioned -- I can't remember what his name

6 was. And then I said no, because there were two persons being referred to

7 by the Prosecutor. Zupljanin used to come before the war, yes. Before

8 the takeover.

9 JUDGE SCHOMBURG: And he met with whom? Was he alone with

10 Dr. Stakic or were other persons present at a meeting with Mr. Zupljanin?

11 Sorry that I can't pronounce correctly the name.

12 A. You're doing fine. Zupljanin came in April, immediately after the

13 secession of Bosnia and Herzegovina, and he was supposed to meet with

14 Dr. Cehajic in the small hall. I remember that day. I opened the door of

15 the small hall, small meeting room, and Mr. Mirza - I think his last name

16 was Mujadzic - and Zupljanin came in. When I called the lady who worked

17 in the restaurant, in the canteen, after some ten minutes, I thought it

18 was time for the others to come in, too. The lady from the cafeteria went

19 to the meeting room, and then she came back to me, saying there's no one

20 there in the room. I went into Dr. Cehajic's office. He was sitting at

21 his table, reading papers. He said: "There's no meeting." He gave no

22 explanation.

23 So this meeting seems to have ended before it even began. And

24 that's why I remember the moment and the day of Zupljanin's visit.

25 JUDGE SCHOMBURG: So to be absolutely --

Page 11166

1 THE INTERPRETER: Microphone, Your Honour, please.

2 JUDGE SCHOMBURG: So to be absolutely on the safe side, it is your

3 testimony that there was no meeting with Mr. Zupljanin in July 1992?

4 A. No. It is my submission that there was no meeting with

5 Mr. Zupljanin. I don't remember.

6 JUDGE SCHOMBURG: Thank you. And then on transcript page 102,

7 line 3, you mentioned that Dr. Stakic had a driver. Did he have only one

8 driver or several drivers?

9 A. Only one.

10 (redacted)

11 (redacted)

12 (redacted)

13 JUDGE SCHOMBURG: So please, for a short moment, in closed

14 session -- or private session is enough.

15 [Private session]

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 11167

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 [Open session]

15 JUDGE SCHOMBURG: It's absolutely correct that you asked me to

16 rephrase the question. I should have asked you first, was there a

17 departure and voluntary exodus from Prijedor Municipality prior to April

18 1992?

19 A. Yes. People were leaving, people of non-Serbian ethnicity, in

20 great numbers. You could notice it about the town outside the hotel. The

21 Balkan Hotel, I would often pass it on my way to the supermarket.

22 JUDGE SCHOMBURG: Can you tell us what was the reason that, as you

23 said, people of non-Serbian ethnicity were leaving the town prior to April

24 1992?

25 A. I don't know that.

Page 11168

1 JUDGE SCHOMBURG: You mentioned, just by chance, the Balkan Hotel.

2 Did you ever make an appointment or put through a telephone call from or

3 to Dr. Stakic in September 1992 to a hotel in preparation of a meeting of

4 representatives from the entire region?

5 A. No, I can't remember that happening.

6 JUDGE SCHOMBURG: We previously touched upon this issue already,

7 but could you please tell us why it was that at the same time a number of

8 persons resigned or were compelled to resign or even dismissed together

9 with Dr. Stakic in January 1993?

10 A. I don't know.

11 JUDGE SCHOMBURG: You worked together with the person who replaced

12 Dr. Stakic?

13 A. Yes. Excuse me --

14 JUDGE SCHOMBURG: Just for the purpose of transcript, the name of

15 this person replacing Dr. Stakic, once again, was?

16 A. In 1993?

17 JUDGE SCHOMBURG: Right.

18 A. It was Dusan Kurnoga.

19 JUDGE SCHOMBURG: Did you discuss with Mr. Dusan Kurnoga the

20 reasons why Dr. Stakic was replaced?

21 (redacted)

22 (redacted)

23 (redacted)

24 JUDGE SCHOMBURG: Let's go for a moment in private session.

25 THE INTERPRETER: Microphone, Your Honour, please.

Page 11169

1 JUDGE SCHOMBURG: I requested private session. Thank you for

2 assisting.

3 [Private session]

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 [Open session]

16 JUDGE VASSYLENKO: Madam Radakovic, can you tell us who telephoned

17 Dr. Stakic regularly or more often than others between April 1992 and

18 September 1992?

19 A. I don't remember. At least not in those terms.

20 JUDGE VASSYLENKO: Did representatives of Bosnian Serb political

21 and military leadership ever contact Dr. Stakic? I mean Mr. Radovan

22 Karadzic, Biljana Plavsic, General Ratko Mladic, and the like?

23 A. No. No, I have never seen any of them. I have never seen any of

24 these people you've just referred to in my life.

25 JUDGE VASSYLENKO: Whom Dr. Stakic telephoned very often, on a

Page 11170

1 regular basis, let us say?

2 A. There weren't any particular obligations to make any regular

3 calls, nor do I remember any such regular calls to anyone.

4 JUDGE VASSYLENKO: Next question: Who visited the office of

5 Dr. Stakic on a regular basis?

6 A. On a regular basis, I don't know. People would come, people from

7 the body we worked in.

8 JUDGE VASSYLENKO: More or less often than others.

9 A. Mainly people from administrative bodies, managers on different

10 levels.

11 JUDGE VASSYLENKO: Did Dusan Baltic ever visit the office of

12 Dr. Stakic?

13 A. The secretary of the assembly? Yes.

14 JUDGE VASSYLENKO: How often? Once a week, twice a day --

15 A. Only rarely. I can't remember the exact frequency. It's really

16 difficult to say. We had clients coming in, so...

17 JUDGE VASSYLENKO: What about Spiro Marmat?

18 A. I can't remember. I know that he worked in the Secretariat for

19 Defence. It was under the -- now it's the Ministry of Defence.

20 JUDGE VASSYLENKO: And the last question: Was Dr. Stakic absent

21 from his office from time to time due to the official business trips

22 outside Prijedor or Prijedor Municipality during the period between April

23 and September 1992?

24 A. I don't know about any such absences.

25 JUDGE VASSYLENKO: Thank you. I have no more questions.

Page 11171

1 JUDGE SCHOMBURG: The trial stays adjourned until 25 minutes past

2 3.00.

3 --- Recess taken at 3.03 p.m.

4 --- On resuming at 3.29 p.m.

5 JUDGE SCHOMBURG: Please be seated.

6 And please, Judge Argibay, the floor is yours.

7 JUDGE ARGIBAY: Thank you.

8 Good afternoon, madam. I have a few questions to put to you. The

9 first one relates to the April the 30th, remember, the day when you went

10 to your work, found two young soldiers who looked at your identity card or

11 something to that -- in that way, and let you in, and the day you said

12 that Dr. Stakic came as usual to work. May I ask, did he look surprised

13 at what was happening in the municipality?

14 A. I didn't see Dr. Stakic when I first entered the building.

15 JUDGE ARGIBAY: I don't mean --

16 A. He looked normal.

17 JUDGE ARGIBAY: He looked normal. You saw him afterwards. He was

18 there already when you arrived?

19 A. I believe so, but I am not sure. Yes.

20 JUDGE ARGIBAY: Okay. You were not surprised, you yourself, that

21 Professor Cehajic didn't arrive to work?

22 A. I was surprised. Of course I was. After the telephone call and

23 after my friend told me what she told me, my second surprise came when I

24 entered the building. And a third surprise of that day was the fact that

25 Cehajic didn't come to work.

Page 11172

1 JUDGE ARGIBAY: And didn't it surprise you that Dr. Stakic was not

2 surprised at the circumstances?

3 A. I couldn't actually tell whether he was either surprised or not

4 surprised. We didn't talk about it.

5 JUDGE ARGIBAY: I'm changing to another point, and I want to come

6 back to your sketch of the municipal building and the quarrel or

7 discussion you heard in Dr. Stakic's office between Dr. Stakic and

8 Mr. Drljaca. You told us, and I saw in this sketch you made, that your

9 window gives on to a balcony, and that you can go through the balcony to

10 the other offices, the ones that are beside your office. Is that correct?

11 JUDGE SCHOMBURG: Maybe for a better --

12 A. Correct.

13 JUDGE SCHOMBURG: -- it's appropriate to put J26 on the ELMO,

14 please.

15 JUDGE ARGIBAY: Was the argument in very loud voices, as I

16 understand, correct?

17 A. It was a discussion. There was noise, a quarrel, an argument, a

18 loud argument. Something was happening during that discussion. Some

19 different interests and views were expressed.

20 JUDGE ARGIBAY: You don't know what was the matter of that thing,

21 the subject properly?

22 A. No. I didn't hear anything, and I stood up to close the window,

23 that is, the door, for the purpose of not being able to hear the

24 discussion because I was not interested in hearing it.

25 JUDGE ARGIBAY: I can understand that. Wouldn't it better to go

Page 11173

1 out on the balcony and close the windows of Dr. Stakic's office from the

2 outside?

3 A. That was not necessary because the only place where their

4 conversation could be heard was in my office, close to my window. There

5 is another window in the other office, and then after that there is a

6 small conference room with nobody there at the time.

7 JUDGE ARGIBAY: And you couldn't hear anything through the door,

8 for instance?

9 A. No. Through the window.

10 JUDGE ARGIBAY: Thank you. Let's change the subject, please.

11 You told us today in, I think it was, for the benefit of the

12 parties, page 66, line 9, you told Judge Schomburg that the last meeting

13 of the Municipal Assembly was held when Bosnia and Herzegovina seceded.

14 Do you remember the date of the secession?

15 A. I believe it was the 4th of April -- no, the 6th of April. I

16 remember the date because on that same day, the 6th of April, during the

17 Second World War, Belgrade was bombarded, was shelled.

18 JUDGE ARGIBAY: And so it's your memory that after April the 6th,

19 1992, there were no more assembly meetings?

20 A. Yes. I don't remember that there were any.

21 JUDGE ARGIBAY: And are you aware that the political parties at

22 that moment, being a part of the assembly having the deputies, the

23 president who was Professor Cehajic, another who was the vice-president

24 who was Dr. Stakic, and all the people involved in the Municipal Assembly

25 were taking some measures, proposing something to go on?

Page 11174

1 A. I'm not aware of any conclusions or decisions from the sessions of

2 the assembly.

3 JUDGE ARGIBAY: Where in the building did the Municipal Assembly

4 meet?

5 A. I believe that at that time, the sessions were held in an adjacent

6 building, next to the building of the municipality. There was no room in

7 the building of the municipality that would be suitable for the purpose.

8 So in that period, I believe that they allocated the other building for a

9 longer period of time, not only for that session, but for a longer period

10 of time, it was that building.

11 JUDGE ARGIBAY: And in reference to what you told us in page 71,

12 line 21, about the lot of non-Serb persons leaving Prijedor before the

13 30th of April, 1992, you said that you did not know the cause for this

14 exodus, as Judge Schomburg asked you. Did you ever ask someone, the

15 families of these persons, why were so many people leaving Prijedor at

16 that time?

17 A. No. I didn't ask.

18 JUDGE ARGIBAY: You weren't interested in knowing why your

19 neighbours were leaving?

20 A. No. If I had known why they were leaving, I would have left

21 myself. Maybe I would have been better off if I had left at that time.

22 JUDGE ARGIBAY: Can you explain this answer. I really don't

23 understand what you mean.

24 A. I don't know. If there was a good reason for them to leave, then

25 I should have left myself. I don't know.

Page 11175

1 JUDGE ARGIBAY: Thank you. I have no more questions.

2 JUDGE SCHOMBURG: The Defence.

3 MR. LUKIC: I have only one, Your Honour. So thank you.

4 Further examination by Mr. Lukic:

5 Q. [Interpretation] Mrs. Radakovic, Judge Schomburg asked you today

6 on page 45, line 12 and onwards, something about the hierarchy in the

7 Municipal Assembly. I would like to ask you something about the

8 secretary-general of the Municipal Assembly. Is the secretary-general of

9 the Municipal Assembly an official of the Municipal Assembly?

10 A. Yes.

11 Q. Is the secretary-general responsible? Does he answer to the

12 Municipal Assembly?

13 A. Yes, for his work.

14 Q. Is the president of the Municipal Assembly the secretary-general's

15 boss, superior? Do you know that?

16 A. No. The president of the --

17 Q. I use the --

18 MR. KOUMJIAN: Sorry, I don't think we got the interpretation of

19 the answer because counsel started his question.

20 MR. LUKIC: [In English] I put a double negative question, so maybe

21 Your Honour can ask. I don't want to be in jeopardy --

22 JUDGE SCHOMBURG: I don't want to step into the shoes of the

23 Defence. Therefore, please repeat the question and break it down.

24 MR. LUKIC: [Interpretation]

25 Q. Is the president of the Municipal Assembly boss of the

Page 11176

1 secretary-general of the Municipal Assembly?

2 A. No. He is not his boss, but he is not my boss either. But he is

3 an official who is appointed to serve the president and the

4 vice-president. And my obligations are only towards the

5 secretary-general, and he is the one who is in charge of signing the

6 documents about my salary and other similar documents. And he does the

7 same thing for the president of the assembly.

8 MR. LUKIC: [Interpretation] Thank you. I have no further

9 questions.

10 JUDGE SCHOMBURG: The Prosecution.

11 MR. KOUMJIAN: Two short areas.

12 Further cross-examination by Mr. Koumjian:

13 Q. Ma'am, you talked about in 1997 when you came back from having

14 your teeth fixed, and both the office of the president and vice-president

15 were empty, the president having been Dr. Stakic. Is it correct that the

16 vice-president in 1997, who also was not there following the arrest of

17 Dr. Kovacevic, was Momcilo Radanovic, otherwise known as Cigo?

18 A. Yes.

19 Q. And Cigo left Prijedor at the same time. Correct?

20 A. Yes. I learned that when I came back to work.

21 Q. Okay. The other short area is on page 103 of yesterday's

22 transcript, line 14, you were asked: "Did Dr. Stakic wear a gun?" And

23 you answered: "Not that I saw."

24 I would like to go back to the video that you were shown last,

25 S157. I have asked for just one still to be shown from that video, if you

Page 11177

1 could look at your monitor. Stop.

2 Ma'am, do you see the gun on the right-hand hip of Dr. Stakic?

3 A. No, I don't. It's very dark. Secondly, I don't know where this

4 is, what was the occasion. Maybe this was not the building of the

5 Municipal Assembly at all.

6 MR. KOUMJIAN: If we could just go a couple frames further. Stop.

7 JUDGE SCHOMBURG: May I ask the registry and the audio unit -- the

8 video unit, please prepare a still of this picture we just saw. Thank

9 you.

10 MR. KOUMJIAN: Thank you. No further questions.

11 JUDGE SCHOMBURG: Any further questions? I can't see any

12 questions.

13 Then, I have to thank you for accompanying us through this long

14 journey through documents, videos, exhibits. I hope you have got the

15 impression that we try to highlight that what happened in 1992 to your

16 country, to your hometown, to yourself, and to your neighbours from all

17 perspectives, not only from one side. And only this enables us to come to

18 a final judgement on individual criminal responsibility, if so. And this

19 is the task we have to exercise because we strongly believe that there

20 must be justice, and there will be no peace without justice. And we can't

21 obtain justice without coming as close as possible to the truth. And

22 thank you for assisting us in this work, and I wish you a safe trip home.

23 Thank you.

24 THE WITNESS: [Interpretation] May I say something now?

25 JUDGE SCHOMBURG: Please, it's always your testimony.

Page 11178

1 THE WITNESS: [Interpretation] It doesn't need to be.

2 I value this Tribunal greatly. I can see that you're working very

3 hard, that you have a lot of work to do. We follow your work on

4 television. I didn't know it would be so long and thorough. I'm sorry if

5 I couldn't help you with some details. The only reason I couldn't was my

6 mental absence at the moments when this was all happening because, for me,

7 the war began in 1990 at the moment when my son went to serve his

8 compulsory military service. I suffered from depression because already

9 at the time unrest could be felt in Croatia.

10 My son was not released from the army when he was supposed to be

11 released, when he completed his compulsory military service. I went to

12 see what was going on, so his military service was extended due to the

13 conditions that prevailed in Karlovac at the time. The barracks were --

14 was encircled. I had some legal possibilities available to me. Firstly,

15 I could show his student's booklet, showing that he was a regular student

16 at the university in Bihac in that year. That was 1991. But I did not

17 have any contacts with my son over the telephone, so I had to go there, to

18 physically go there. The barracks was encircled. When I asked for my

19 son's superior officer, he was not there. And I went back home without my

20 son. And that is something, an event that was really hard to live with.

21 It would have been hard even for some men. And my son only returned when

22 all of the barracks, all the manpower, moved out from the barracks.

23 After a very short period of time, some six months or so, all

24 these things that you were asking me about started happening in Prijedor,

25 and I was not able to remember some of those things that you asked me

Page 11179

1 about. And the only reason why I couldn't remember them is the fact that

2 all throughout that time, I was under the impression and I was concerned,

3 and I worried how to save my child, how to help him. When I couldn't help

4 him, I had to pack him to go to the front line. So I witnessed that.

5 Besides that, I lived in my household together with my father and

6 my mother. My father was on heavy medication. He was wounded in the

7 Second World War. Since then, he didn't have one leg. He suffered from

8 asthma. Those were his regular complaints. And on top of those, there

9 were some other complaints he had. Every day, day in, day out, I had to

10 struggle to get food, to get the medication that was necessary, and I had

11 very little time to think about the things that were happening at the

12 time. Maybe that is the reason why I wasn't aware of things. Maybe that

13 is the reason why I couldn't provide you with the information that you

14 asked me about.

15 On my way here, I realised, and then I saw that a lot of effort is

16 being invested about the arrival of witnesses. Our accommodation is very

17 good. I am here with the best intention to help you, the Honourable

18 Judges, but Dr. Stakic as well. And if I was not convinced, if I was not

19 sure that Dr. Stakic just found himself at a wrong place at a wrong time,

20 and that things may have just been misrepresented in his case, if I wasn't

21 convinced that he is innocent, I wouldn't be here. I would really regret

22 the time that I have spent here if the contrary to what I believe was

23 proven correct.

24 Thank you for listening to me.

25 JUDGE SCHOMBURG: We have to thank you for your additional and

Page 11180

1 very personal remarks. And it will assist us in a better understanding of

2 your entire testimony. Once again, thank you for coming and, hopefully,

3 having a safe trip home.

4 May I ask the usher, please, to escort the witness out of the

5 courtroom. Thank you, ma'am.

6 THE WITNESS: [Interpretation] Thank you very much.

7 [The witness withdrew]

8 JUDGE SCHOMBURG: Down to earth, we have to discuss now some

9 administrative matters. May I ask you, what about the witnesses of next

10 week?

11 MR. LUKIC: Your Honours, for the next week, we were in danger not

12 to have a single witness because the rumours were spreading down there

13 that the witnesses of the Defence are ill treated in front of this

14 Tribunal, and we have many problems with providing the Defence with the

15 witnesses. So we still don't know whether we will have anybody for next

16 week. And if we do, we'll be able only to bring three witnesses. It's

17 Witness 021, 088, and 090.

18 JUDGE SCHOMBURG: What about the other envisaged --

19 THE INTERPRETER: Microphone for the presiding judge.

20 JUDGE SCHOMBURG: What about the other envisaged witnesses?

21 MR. LUKIC: For now, they refuse to testify in front of this

22 Tribunal.

23 Also, in connection with this, we have to have on the record that

24 Your Honour read to this witness statements of other witnesses. And when

25 we tried to do it during the Prosecution case, the Prosecution witnesses,

Page 11181

1 you ruled that it's forbidden.

2 JUDGE SCHOMBURG: Before making these statements, could you please

3 offer some evidence for this.

4 MR. LUKIC: Yes, you read from Dr. Minka Cehajic --

5 JUDGE SCHOMBURG: No, it's quite clear: The question is whether

6 it was ever forbidden to put questions based on concrete testimony to

7 other witnesses.

8 MR. LUKIC: We will provide you with that, Your Honour, gladly.

9 Also, when you cross-examined the witnesses of the Prosecution,

10 you yourself never read to the witnesses of the Prosecution from the

11 statements of other witnesses. So we just want to have this on the

12 transcript. And we will find in the previous transcripts places where you

13 ruled and forbid both the Defence and the Prosecution to present the

14 statements of another witness to the present witness. Thank you.

15 JUDGE SCHOMBURG: May I first ask the Prosecution for submissions

16 on this issue.

17 MR. KOUMJIAN: Your Honour, I would just draw the distinction

18 between reading from an out-of-court statement and reading from testimony

19 and giving a witness an opportunity to comment upon other testimony that

20 might refresh recollection or in which the witness may deny the other

21 testimony. That's different from an out-of-court statement.

22 As for the schedule next week, we will cooperate in any way we can

23 so the Defence can get their witnesses. If at some point witnesses refuse

24 to voluntarily come, there, of course, is the power of the Tribunal to

25 subpoena witnesses to come to testify.

Page 11182

1 JUDGE SCHOMBURG: And when you already start discussing this

2 point, can you please tell us in a very concrete way what are the names or

3 the numbers of the witnesses you're referring to refusing to testify

4 because of that what I think you called it wrong or ill treatment by the

5 Chamber.

6 MR. LUKIC: Our investigator informed us only about the names of

7 the people who may come, and he complained the whole last week that he has

8 a lot of problems in regard of this issue. And that's why I reacted

9 yesterday also improperly, because I was aware of this problem. And I was

10 aware that we might not have any witnesses tomorrow -- actually, the next

11 week.

12 JUDGE SCHOMBURG: Can you give us the name or the number of only

13 one witness that refused or tries to refuse to come to this Court based on

14 this.

15 MR. LUKIC: I don't know it by heart, and I don't have it written

16 here. I have only three names of the people who are coming.

17 JUDGE SCHOMBURG: Will it be possible to have additional witnesses

18 that we can fill in the entire time provided for us during the next week?

19 MR. LUKIC: We will do our best. The problem with our witnesses

20 is that they need visas. And although the Witness and Victims Unit is

21 trying their best, they need at least five working days to provide the

22 witness with the visa. We'll try to have at least another one or two

23 witnesses for the next week, although we cannot promise to be successful

24 because of these restrictions.

25 JUDGE SCHOMBURG: As to the fact that you yourself stated that you

Page 11183

1 reacted yesterday improperly, I don't want to go into further more

2 details, but please, I would ask both parties, in future, to refrain from

3 discussing these issues in front of a witness. And it may be also the

4 result of these false and misleading statements by the Defence that there

5 is this wrong impression. And therefore, I think on the basis of that

6 what you stated today, we need not go any more into details of this what

7 you said wrongly yesterday. But please refrain from doing so in the

8 future.

9 Could you please assist us with the number of witnesses in the

10 final list of Defence witnesses updated the 7th of January 2003. There is

11 no such 88 and 09.

12 THE REGISTRAR: It's the registry's mistake, Your Honour. I have

13 updated the list, and these witnesses are added now. I will provide it.

14 JUDGE SCHOMBURG: So what, then, about the proffer of the next

15 witness? When -- will it be possible -- I know you are working extremely

16 hard also during the weekend -- to have it at least in the morning of

17 Monday?

18 MR. LUKIC: Yes, Your Honour, we'll try to provide you on Sunday.

19 I don't know whether it would be possible for you to find it, but maybe we

20 can e-mail it on Sunday. We will try to make it on Saturday or Sunday at

21 least.

22 JUDGE SCHOMBURG: Thank you. Then we will be prepared to hear

23 Witness 21 on Monday afternoon.

24 Anything else for the next week to be discussed? Because we

25 calculated that there would be in the moment 34 witnesses remaining, and

Page 11184

1 among those witnesses, three witnesses -- at least three witnesses that

2 will take us more than one day. And in all likelihood, two experts. And

3 we have already arrived at Day 106. That means there are only remaining

4 34 additional days, maximum. So it will be extremely difficult to follow

5 our schedule in case there is no -- at one point in time, no witness

6 available. And as I said since December, there is no leeway to have

7 additional time for hearing the Defence case. So whenever it's possible

8 and you hear from your investigators, I think also the OTP will be ready

9 to hear additional witnesses. And I can only encourage you to do the very

10 best that we have, per week, five witnesses, if not six, available.

11 MR. LUKIC: Your Honour, we would -- hopefully, we will be able to

12 provide more witnesses for this trial, but we worked every day this week,

13 and we finished only three witnesses. So also Your Honours and the

14 Prosecution might consider to cut shorter your examination.

15 JUDGE SCHOMBURG: I think we'll all try to do our very best in

16 reaching this goal. And no doubt it also depends on the provided scope of

17 what will be covered by a witness on the basis of your proffer. We are

18 grateful that the proffer is now -- the last proffers have been reliable

19 ones. But tell us when you feel not necessary to cover the one or other

20 area, as it was done in the past.

21 Is there any progress - and this is a point of real concern - any

22 progress with the translations of the exhibits? And if not, please tell

23 us where is the bottleneck and what is the name of the responsible person

24 that we may speed up and assist you in speeding up with the translations.

25 MR. LUKIC: I really don't know where the bottleneck is. But our

Page 11185

1 documents have been divided to three parts, and we just received the first

2 one finished. So we'll provide Your Honours and the Prosecution with our

3 exhibits at the beginning of the next week. We have this weekend to

4 photocopy what we received, and the rest in B/C/S. And I think that the

5 Prosecution has everything in B/C/S already.

6 JUDGE SCHOMBURG: Correct? It's already with the Prosecution?

7 MR. KOUMJIAN: We've received several binders in B/C/S. I take

8 counsel's word that it's everything.

9 JUDGE SCHOMBURG: Okay. When can we expect the first bundle of

10 translations, of translated documents, which would normally be 65 ter

11 documents?

12 MR. LUKIC: As we like to say, to be on the safe side, on Tuesday.

13 I cannot promise Monday.

14 JUDGE SCHOMBURG: As regards the witnesses, once again, as already

15 stated by the Prosecution, if a person you need for your purposes, and

16 refusing for what reason soever to appear, don't hesitate, as you did in

17 the past, to ask for a subpoena for this witness. We will let you be

18 informed on the ongoing attempts to have the two witnesses you requested

19 as Chamber witnesses as soon as possible available.

20 Any other submissions by the parties? Prosecution.

21 MR. KOUMJIAN: No, Your Honours.

22 JUDGE SCHOMBURG: Defence.

23 MR. LUKIC: Nothing else, Your Honour. Thank you.

24 JUDGE SCHOMBURG: Then this concludes the hearings of this week.

25 And we will continue, as foreseen, on Monday afternoon, same courtroom, a

Page 11186

1 quarter past 2.00. The trial stays adjourned.

2 --- Whereupon the hearing adjourned

3 at 4.15 p.m., to be reconvened on Monday,

4 the 27th day of January, 2003, at 2.15 p.m.

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