1 Thursday, 27 November 2003

2 [Open session]

3 --- Upon commencing at 9.05 a.m.

4 [The accused entered court]

5 JUDGE AGIUS: Yes, Madam Registrar, please proceed to call the

6 case.

7 THE REGISTRAR: Yes, Your Honour. Good morning, Your Honours.

8 This is Case Number IT-99-36-T, The Prosecutor versus Radoslav Brdjanin.

9 JUDGE AGIUS: I thank you, Madam.

10 Mr. Brdjanin, can you follow the proceedings in a language that

11 you can understand?

12 THE ACCUSED: [Interpretation] Good morning, Your Honours. Yes, I

13 can.

14 JUDGE AGIUS: I thank you, and good morning to you.

15 Appearances for the Prosecution.

16 MS. RICHTEROVA: Good morning, Your Honours. Joanna Korner,

17 Anna Richterova, and Skye Winner for the Prosecution.

18 JUDGE AGIUS: I thank you and good morning to you.

19 Appearances for Radoslav Brdjanin.

20 MR. CUNNINGHAM: Good morning, Your Honours. David Cunningham and

21 Aleksandar Vujic.

22 JUDGE AGIUS: I thank you, Mr. Cunningham, and good morning to you

23 both. And good morning also to Mr. Ackerman who is not with us today.

24 And I start with you, Mr. Cunningham, and Mr. Ackerman, I suppose you will

25 convey to him our -- the Chamber's best wishes on Thanksgiving Day.

1 So you have filed a so-called Defence first motion for protection.

2 I consider it the second actually because there was a first one which was

3 not exactly -- which did not exactly have the result that you were

4 anticipating and that we were anticipating anyway. Our decision that we

5 are communicating to you now is that -- rather, first, let's see what the

6 Prosecution has to say about.

7 MS. KORNER: No objection.

8 JUDGE AGIUS: No objection. So if there is no objection, I think

9 we can proceed to accept the motion with the understanding,

10 Mr. Cunningham, that at the beginning of the testimony of that particular

11 witness, we will go into closed session for a while, we'll interview him

12 to make sure the provision is necessary and indeed the one which should be

13 put in place. Otherwise, you don't have to worry; it will be granted as

14 requested.

15 MR. CUNNINGHAM: Your Honour, can I move the books right here so I

16 can see.

17 JUDGE AGIUS: Yes, again, yes. Chuqing.

18 MR. CUNNINGHAM: I'll do it.

19 JUDGE AGIUS: It shouldn't be you, Mr. Cunningham.

20 Francesca, it's not that I wouldn't like to see you, but I think

21 for today you have to be patient.

22 Is the witness here? Do we have any preliminaries?

23 MS. KORNER: Your Honour, no. I think the only thing and we're

24 going to leave it until Mr. Cunningham's had a chance to talk to

25 Ackerman. We're slightly confused now, again, I'm afraid, about what

1 witnesses are coming next week, but I think we can leave it until the end

2 of today or tomorrow.

3 MR. CUNNINGHAM: We're still set on the first two, Your Honour.

4 JUDGE AGIUS: Number 31 and 33 in other words.

5 MR. CUNNINGHAM: Yes, sir. There is one other thing I want to

6 inform the Chamber about this next witness. He is a little bit hard of

7 hearing, and I've told him about the procedure, but I wanted to let the

8 Court know about that as well.

9 JUDGE AGIUS: I thank you. We have a problem, we'll see how we

10 tackle it. But I think the usher puts on the volume, that should help.

11 MR. CUNNINGHAM: There's one final matter, Your Honour. I made an

12 exhibit book that has the relevant exhibits except for one in B/C/S. I

13 have that available and I've had the usher pull the English exhibits.

14 Apparently some of the DB exhibits that are on my list have already been

15 introduced as Prosecution exhibits,.

16 JUDGE AGIUS: That's not the first time.

17 MR. CUNNINGHAM: And Ms. Richterova has promised to correct me.

18 JUDGE AGIUS: Okay. I thank you.

19 Yes, could we bring the witness in, please. Thank you.

20 No protective measures for this witness, no?

21 [The witness entered court]

22 JUDGE AGIUS: Good morning to you, Mr. Bojinovic.

23 THE WITNESS: [Interpretation] Good morning.

24 JUDGE AGIUS: Welcome to The Hague and to this Tribunal.

25 THE WITNESS: [Interpretation] Thank you very much.

1 JUDGE AGIUS: You are very shortly going to start giving evidence

2 in the trial instituted against Radoslav Brdjanin. And our Rules require

3 that before you start testifying, you enter a solemn declaration

4 equivalent to an oath and that in the course of your testimony you will be

5 telling us the truth, the whole truth, and nothing but the truth. So you

6 have the text of the solemn declaration in your hand. Please read it out

7 aloud, and that will be your solemn undertaking with us.

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

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

10 JUDGE AGIUS: I thank you, sir. Please take a chair.

11 I notice that you are a little bit excited, nervous. You don't

12 need to be. I want you to feel as comfortable as possible while you give

13 evidence.

14 THE WITNESS: [Interpretation] Thank you very much, Your Honour.

15 JUDGE AGIUS: And everyone will try to make things easy for you.

16 You have been summoned as a Defence witness, and you will be examined

17 first by Mr. Cunningham who I suppose -- I presume you have met already.

18 He will ask you a number of questions, and then he will be followed by

19 Madam Richterova, the lady -- the second starting from your right. And

20 that will be cross-examination. You will be asked questions, and your

21 duty under the solemn declaration that you entered is to answer each and

22 every question as fully and as truthfully as possible, independently of

23 who is asking you the question. In other words, you cannot and shouldn't

24 even try to make a distinction between questions coming from the Defence

25 and questions from the Prosecution. Everyone has a right to ask you

1 questions here, and you have a duty to answer each question in the same

2 manner, that is truthfully and as comprehensively as possible. I would

3 also suggest that you keep your answers as concise as possible, and that

4 will ensure that you will be back home before the end of the week is over.

5 It very much depends on you. Thank you.

6 Mr. Cunningham.

7 MR. CUNNINGHAM: Thank you, Your Honour.

8 WITNESS: MILOS BOJINOVIC

9 [Witness answered through interpreter]

10 Examined by Mr. Cunningham:

11 Q. Your name is Milos Bojinovic.

12 A. Yes.

13 Q. Again, remember what His Honour has told you about listening to

14 the question and answering only the question that is asked of you. If you

15 look right to your left, you'll see a notebook, and that notebook has some

16 exhibits in it. This is the exhibit book I talked about with you

17 yesterday. It's on the table right next to you, right next to your left

18 elbow. At the appropriate time I'll have you go to the exhibit. But

19 we're not there yet. What I wanted to do is ask you some questions to get

20 started.

21 Tell us how old a man you are.

22 A. 56.

23 Q. And what municipality were you born in?

24 A. Glamoc.

25 Q. And where do you currently reside, what municipality?

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1 A. Banja Luka.

2 Q. And how long have you lived in Banja Luka?

3 A. Ten years.

4 Q. What is your profession? What do you do for a living?

5 A. I'm a teacher of the Serbian language at a secondary school.

6 Q. Is that secondary school in Banja Luka?

7 A. Yes.

8 Q. And how long have you been a teacher?

9 A. 29 years.

10 Q. Where did you complete your secondary school studies at?

11 A. In Jajce.

12 Q. And where did you attend university at?

13 A. In Belgrade.

14 Q. And what year did you get your diploma, your degree?

15 A. 1973, January of 1973.

16 Q. Save for your -- except for your one-year compulsory military

17 duty, have you continuously taught since 1973?

18 A. Yes.

19 Q. In 1990, where were you living?

20 A. In Glamoc.

21 Q. And in 1991, did you join a political party?

22 A. Yes.

23 Q. And which party did you join?

24 A. The SDS.

25 Q. And after you joined -- after you became a member of the SDS, were

1 you a regular party member, or did you have a position of authority within

2 the party?

3 A. I was just an ordinary party member.

4 Q. In 1990, 1991, as a party member living in Glamoc, did you ever

5 travel to Banja Luka?

6 A. Yes.

7 Q. And how often would you travel to Banja Luka?

8 A. To the shop.

9 Q. I want to listen carefully. Remember, my question was how often

10 would you travel to Banja Luka, not where did you go. But how often did

11 you go?

12 A. You mean by what means of transportation? I used my own private

13 car. I'm not sure I understand your question. How frequently, what does

14 the "how" mean?

15 MR. CUNNINGHAM: I'm sorry, Your Honours, to interrupt.

16 JUDGE AGIUS: It's a question of interpretation actually probably.

17 MR. CUNNINGHAM:

18 Q. When I say how frequently, did you go once a month, three times a

19 year? How often would you go?

20 A. Three times a year, two or three times.

21 Q. And in 1991 on one of those trips to Banja Luka, did you meet the

22 defendant in this case?

23 A. Yes, by chance, in 1991.

24 Q. How is it by chance that you met him in 1991?

25 A. There's always the off chance that you meet someone in the street,

1 that someone introduces you to someone else. And that's precisely how I

2 met Mr. Brdjanin, although I had previously been aware of his involvement

3 in sports.

4 Q. Okay. And do you remember where within the city of Banja Luka

5 that you met Mr. Brdjanin?

6 A. At the Bosna Hotel.

7 Q. And was there any political event going on within the Hotel Bosna

8 when you met Mr. Brdjanin?

9 A. No, this would usually not take place in hotels, no.

10 Q. Okay. So what were the circumstances that you met him? Did

11 someone introduce you to him?

12 A. As for the circumstances, we were just sitting there over a drink.

13 There were about ten people there. Mr. Ljupko Racic was the one who

14 introduced me.

15 Q. And the ten people who were sitting there in the Hotel Bosna, were

16 you talking about politics?

17 A. Yes.

18 Q. And was there a discussion going on about politics and what should

19 happen?

20 A. We discussed politics also because the situation in that area was

21 complex. The discussion was just an ordinary one; no particular plans

22 were being hatched as to what could happen.

23 Q. In this conversation, in this discussion, did you let your

24 position, your thoughts on the situation, be known?

25 A. Yes.

1 Q. What did you tell the ten people, including Mr. Brdjanin, who were

2 seated talking politics?

3 A. The conversation about the complex nature of the situation was of

4 a more general kind. I spoke about the need for every intellectual to

5 show common sense, to try to be active in their own environments, to try

6 to explain to those who are less knowledgeable, to try to tell them to

7 remain calm, to not provoke incidents. The times were such, the times

8 required calm because the times were complex.

9 Q. Now, at the time that you made this statement, participated in the

10 discussion, did you have non-Serb friends and colleagues?

11 A. You mean at the meeting?

12 Q. No, just in general, back at school, back at --

13 A. Yes, yes. Yes, yes.

14 Q. Does your family have many mixed marriages?

15 A. Yes.

16 Q. And how do you personally accept the fact that you have family

17 married to non-Serbs? Is that something that bothers you?

18 A. No. That was something that was normal. It's, I dare say, a norm

19 of civilisation.

20 Q. How long did this discussion that you've described for us, this

21 conversation with the other men, how long did it go on that day?

22 A. I couldn't say with any degree of precision, but perhaps for about

23 half an hour, as long as it took to drink a coffee or any other drink at

24 the hotel.

25 Q. During the time of this discussion when Mr. Brdjanin was there,

1 did you ever go up to him and ask him for any sort of job, any sort of

2 assistance?

3 A. There was no need for anything like that.

4 Q. Was this the first time you met Mr. Brdjanin in person?

5 A. I think so.

6 Q. Now, you were mobilised when the war started. Correct?

7 A. Precisely.

8 Q. And do you remember the date that you were mobilised and entered

9 the military?

10 A. Yes.

11 Q. And what date was that?

12 A. The 13th of April 1991.

13 Q. Okay.

14 A. Just a moment, please. Yes.

15 Q. Are you sure --

16 A. Just a moment. When did the war begin? When did the war begin?

17 I think it was in 1992, yes. Right. Okay. The 13th of April 1992, the

18 mobilisation took place in my area, and I was a member of the army, too.

19 Q. And were you sent to the front, or near the front?

20 A. To the front.

21 MS. KORNER: I'm sorry, Your Honour. I know this is

22 Ms. Richterova's witness, but I want to make the point. A lot of these

23 questions are leading questions.

24 JUDGE AGIUS: Yes. Usually as you know, I have taken the practice

25 that I will not -- most of the questions are actually from both sides.

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1 But usually I do not interfere unless there is an objection. The moment

2 there is an objection, of course, I do interfere.

3 MS. KORNER: Yes. It may be important, and I anticipate this may

4 be important, a leading question like "were you sent to the front" is not

5 one I think should be asked. "Where were you sent" is the proper

6 question. In essentials, I have no objections to leading.

7 JUDGE AGIUS: Exactly.

8 MS. KORNER: On matters that may be important, I do.

9 JUDGE AGIUS: I have taken it that amongst you, you accept leading

10 questions most of the time. When you have an objection or a reservation,

11 then just point that out.

12 I do share Ms. Korner's objection. Perhaps you can rephrase.

13 MR. CUNNINGHAM: Certainly, Your Honour.

14 Q. Where were you sent to, if anywhere?

15 A. I was sent to the front where -- to the border of three

16 municipalities, Glamoc, Livno, and Kupres where the borders meet. There

17 is the -- there is a very dominant feature there, Mount Cincar.

18 Q. And what were your job duties, if any, when you were at this area

19 you just described?

20 A. A common soldier.

21 Q. What was your rank?

22 A. No rank.

23 MR. CUNNINGHAM: I'd like the usher to hand you

24 Prosecution Exhibit 241.

25 Q. And Mr. Bojinovic, in that grey notebook right by your left elbow,

1 open it up, and you'll see a tab that has the number 241 on it.

2 A. Please, if you could speak up. Something's wrong with my

3 microphone.

4 Q. Okay. If you look at the yellow tabs, attached to those documents

5 you'll see the -- you should see the number 241. I believe it's the very

6 first document there. Do you see it?

7 A. Yes, I do.

8 Q. For the record, this document is a decision of the Autonomous

9 Region of Krajina Crisis Staff appointing you as chief of the agency for

10 population movement and exchange of material wealth for the Autonomous

11 Region of Krajina. Correct?

12 A. Yes.

13 Q. Did you receive this document while you were in military service?

14 A. No.

15 Q. Okay. Tell the Chamber the circumstances under which you received

16 this document, how was it delivered to you, what you did with it when you

17 got it?

18 A. While I was at the front, I was informed verbally of my

19 appointment. I received approval by my command to report to this new

20 duty. And when I came to Banja Luka on the 1st of July, I received this

21 document. I got it from the secretary of the AR Krajina.

22 Q. Okay. Was this a position that you had requested, a position that

23 you had lobbied for?

24 A. No. I did not ask for this.

25 Q. What was your reaction when you received notice that you had a new

1 job assignment?

2 A. It was just a normal reaction because it is quite normal to merely

3 do the jobs that are somehow imposed by the situation itself.

4 Q. After speaking with your commanding officers about this new

5 assignment, what did you do?

6 A. I did not talk to the commanders. But after having received this

7 decision, I went to the building housing the agency.

8 Q. And where was that building located, in what municipality?

9 A. In Banja Luka.

10 Q. The face of Prosecutor's Exhibit 241 is dated 12 June 1992. Do

11 you remember how soon after 12 June 1992 you reported to Banja Luka?

12 A. On the 1st of July 1992.

13 Q. And what was the reason for the delay of between 12 June and 1

14 July 1992?

15 A. Well, probably it took a while for the decision to arrive to the

16 command at Glamoc. There was a war on. And since I was on the front

17 line, away from the town, probably that was the reason. Therefore, the

18 mail did not take its regular route as in peacetime.

19 Q. When you arrived in Banja Luka on or about 1 July 1992, who did

20 you meet with?

21 A. I said it was exactly on the 1st of July.

22 Q. I stand corrected. Who did you meet with?

23 A. Please, if the interpreter could speak up. But let me answer your

24 question. I met with the secretary of AR Krajina, Boro Blagojevic.

25 Q. And where did you meet with him at?

1 A. In his office.

2 Q. And what happened at that meeting?

3 A. Well, we said hello to each other, and I received this decision

4 appointing me chief of the agency.

5 Q. Did Mr. Blagojevic give you any information, give you any

6 instructions?

7 A. No.

8 Q. What did he tell you?

9 A. Not much, just that the building was situated near a bridge. That

10 was all. Near the town bridge.

11 Q. Were you surprised by the information or the lack of information

12 that you got from Mr. Blagojevic?

13 A. Yes.

14 Q. And why were you surprised?

15 A. I expected someone to escort me to the agency building, but there

16 was no one, save for Blagojevic. Probably that could have been the reason

17 why.

18 Q. Did Mr. Blagojevic give you any instructions as to what your job

19 duties or job responsibilities were?

20 A. No, none.

21 Q. Did he give you any information as to what the agency's purpose

22 was, what function it served in the community?

23 A. No.

24 Q. You told us that you met Mr. Blagojevic, the secretary to the ARK.

25 During that day, did you meet anyone else from the ARK or the ARK Crisis

1 Staff?

2 A. No.

3 Q. After you got the location of the agency from Mr. Blagojevic, what

4 did you do?

5 A. Since I was not familiar with Banja Luka, I spent some time

6 looking for the building since there are many bridges in Banja Luka. It

7 took me an hour, hour and a half to find it.

8 Q. Okay. And on 1 July 1992, was that your first day as the chief of

9 the agency for population movement?

10 A. Yes.

11 Q. You started work on 1 July 1992. When was your last day with the

12 agency?

13 A. I could not tell you precisely what date it was. But the agency

14 did operate until the end of the year. It might have stopped in December.

15 Q. When you say "the end of the year," what year are you talking

16 about, just so that's clear for the record?

17 A. It was in 1992.

18 Q. From 1 July 1992 until the end of the year 1992, did you have any

19 personal face-to-face contacts with the defendant, Mr. Brdjanin?

20 A. No.

21 Q. Did you have any telephonic contact with him during this same time

22 period --

23 A. No, no.

24 Q. Did you receive any written documents, written instructions from

25 Mr. Brdjanin during this same time period?

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1 A. No.

2 Q. During this same time period, 1 July 1992 to the end of the year

3 of 1992, did you have any personal contact with any other representative

4 of the Autonomous Region of Krajina?

5 A. No.

6 Q. Did you meet with -- did you know any -- did you know about the

7 Crisis Staff for the Autonomous Region of Krajina? Had you heard of that

8 when you assumed this position?

9 A. Yes.

10 Q. And -- I'm going to go ahead and change topics now. We're still

11 on 1 July 1992, Mr. Bojinovic, but I want to have you tell the Chamber

12 about the agency. How long did it take you to actually locate the agency?

13 A. An hour or an hour and a half perhaps.

14 Q. And where was the agency physically located?

15 A. In the vicinity of the fort Kastel, near the bank of the

16 Vrbas River.

17 Q. And when you arrived there, did the agency have offices?

18 A. Yes.

19 Q. Could you describe for the Chamber what the offices looked like,

20 how big they were, what sort of equipment was available?

21 A. It was an older building, and only partly made operable and to be

22 used for an office. And the rooms had very small square areas. They were

23 maybe 4 by 5 metres, square metres. There was no luxury furniture or

24 electronic equipment there. We had one telefax device, a telephone,

25 logbooks, a car. It was an official car. That was all.

1 Q. Okay, you just answered my question that I was interrupting.

2 When you went to work there -- first of all, in that notebook,

3 look on the tabs. You'll see a tab that has the number 290 on it. Go to

4 that document, that tab, 290, because I want to ask you a question about

5 that.

6 MS. RICHTEROVA: Can we put it on the ELMO. And I think this is

7 one of our exhibits. I think it's P1687.

8 MR. CUNNINGHAM: Thank you, Ms. Richterova.

9 Q. Have you found that document, Mr. Bojinovic?

10 A. Yes.

11 Q. When I ask you to look at a document, I want you to take as much

12 time as you need to read the document to make sure that you're familiar

13 with it. So let me know when you're ready because I want to ask you a

14 question about this document.

15 A. Fine. It's fine.

16 Q. Is this document a payroll document for the agency for the month

17 of July 1992?

18 A. Yes.

19 Q. We see your name next to number one. And then underneath it we

20 see two, three, four, five names.

21 A. Yes.

22 Q. When you arrived there, how many employees did the agency have?

23 A. The four employees present here under numbers two, three, four,

24 and five.

25 Q. Who was Bandic Perka?

1 A. Perka Bandic was Slobodan Bandic's wife. He also worked in the

2 agency.

3 Q. And what was Ms. Bandic's duties? What were her responsibilities

4 with the agency?

5 A. She performed secretarial duties and other duties, when and if

6 necessary. But the duties of a secretary, therefore.

7 Q. And Slobodan Bandic, her husband, what were his duties, his

8 obligations?

9 A. His duties were of an operative nature, to escort passengers and

10 provide security to them. That was it.

11 Q. The fourth name is Stevo Gojanovic. What was his duties?

12 A. Being an occupational invalid, his duty was to simply register the

13 persons applying to the agency for assistance.

14 Q. And what do you mean by an "occupational invalid"?

15 A. His hands were disabled. His fingers were missing.

16 Q. And the very last name that we see there, what was that

17 individual's --

18 A. Ljilja Miljkovic. She was cleaning the premises, airing them.

19 Q. As you stayed with the agency, did you add more employees as the

20 year went on?

21 A. Yes. The persons came applying for assistance, and there was need

22 for more labour force. We hired more people when the circumstances

23 permitted it.

24 Q. Let me interrupt you because I want you to go look at another

25 exhibit. Looking at the yellow tab on the documents, go to the exhibit

1 that is marked 277.

2 MS. RICHTEROVA: And it is also Prosecution Exhibit P1688.

3 JUDGE AGIUS: Thank you, Madam Richterova.

4 MR. CUNNINGHAM:

5 Q. Look at that document, make sure you're acquainted with it, and

6 let me know when you're done reading it to yourself.

7 A. This document, you mean 277?

8 Q. Yes, sir.

9 A. I'm done.

10 Q. It appears that there are now 11 employees. Why were the

11 additional --

12 A. Yes.

13 Q. Why were the additional people hired on?

14 A. Because the scope of work was such that four people weren't enough

15 to do the job.

16 Q. How soon after you arrived was it necessary to get more employees?

17 A. Well, let's say we hired one or two people a month.

18 Q. We've talked about --

19 A. Perhaps even three. They weren't all employees at one time there.

20 Q. You've told us what some of the individuals listed in Exhibit 277

21 did. But let's talk about the new ones. The person next to number 4,

22 Milan Segrt, what was that individual's responsibility?

23 A. Milan Segrt was a refugee from Livno. He worked together with

24 Slobodan Bandic. They discharged operative duties, escorting and

25 providing security to passengers.

1 Q. The individual listed next to number 6, tell us that individual's

2 name and what their job responsibilities were.

3 A. Ankica Luzaic was in charge of registering persons and providing

4 assistance to persons who applied to the agency.

5 Q. What do you mean by "registering persons"? I may be getting ahead

6 of myself with that question, but what do you mean?

7 A. Just as Stevo Gojanovic was doing that, it actually took more than

8 one person to do that. You had to enter the person's first and last name,

9 and then also write down the description of what they were asking for,

10 what kind of an assistance, and why.

11 Q. Okay. The individual next to number 7, tell us the name and what

12 that individual's duties were.

13 A. Valentina Budimic, she was a lawyer by profession. And she was

14 there employed in the agency in case citizens may appear asking for some

15 sort of clarification regarding their documentation. But practically,

16 Valentina didn't have much to do. She was there just in case there might

17 be something for her.

18 Q. What about number 8, Radovan Jovic?

19 A. A refugee from Livno, and he did the accountancy.

20 Q. Okay. The next name is Mira Borkovic?

21 A. A typist.

22 Q. And tell us about the person at number 10, who is that and what

23 was that person's responsibilities?

24 A. A refugee from Bugojno, also a typist.

25 Q. Okay. When you arrived at the agency on 1 July 1992, was the

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1 agency already in operation?

2 A. Yes.

3 Q. And what was your understanding of why the agency was formed and

4 what its original function was?

5 A. The agency was established with the aim of assisting people of all

6 ethnicities in the area of the AR Krajina because there was a war on. In

7 order to prevent the population from suffering the war and to prevent any

8 illegal acts, and unfortunately there were many of such acts present in

9 all ethnicities, the agency was established for the purpose of protecting

10 the people and providing them with the necessary assistance.

11 Q. When you went down the list of employees, you told us that several

12 of those employees were refugees. Were those individuals that you

13 described as refugees --

14 A. Yes.

15 Q. Were those individuals that you described as refugees, were those

16 Serbs or non-Serbs? I'm just talking about the ones that worked for the

17 agency.

18 A. Yes, yes. Just a moment, please.

19 Valentina Budimic is married to a Croat. I don't know, however,

20 which ethnicity she belongs to.

21 Mira Borkovic, I don't know which ethnicity she belongs to. I

22 know that Milan Segrt is a Serb. And Stevo Gojanovic as well, just as

23 Radovan Jovic. As for Ankica Luzaic, I couldn't tell her ethnicity. Now,

24 in the cases where I cannot guess the ethnicity, I think the people

25 actually come from mixed marriages or they might be of Croat or Serbian

1 ethnicity. But I'm not sure, nor did I really ask.

2 Q. Did the agency provide -- well, let me back up. In 1992, had any

3 Serbs come to Banja Luka as refugees?

4 A. Yes.

5 Q. Did the agency provide any assistance to Serbian refugees in

6 Banja Luka?

7 A. Yes. At the beginning. At the beginning, it was only Serbs who

8 applied for assistance because they were the ones who were refugees for

9 the most part. Later on, as the war between Croats and Muslims broke out

10 in the territory of the Federation, then both Muslims and Croats applied,

11 as well as Slovenians, Hungarians. Therefore, the non-Serb population.

12 Q. Now, when you arrived there 1 July 1992, was the agency one that

13 was solely assisting Serbian refugees or had it changed as you had

14 described?

15 A. Yes. At the time, the agency assisted all the people who applied

16 for help. Therefore, Muslims, Serbs, Croats, Slovenians, and others.

17 Q. Using the notebook, I want you to go to the tab that is marked

18 with the number 260. Let me know when you find that document and when

19 you're done reading it to yourself.

20 JUDGE AGIUS: Is this a --

21 A. I've found it.

22 JUDGE AGIUS: -- One of your documents, Madam Richterova?

23 MS. RICHTEROVA: No, no. Defence.

24 JUDGE AGIUS: Okay.

25 MR. CUNNINGHAM:

1 Q. What is this document?

2 A. This document is meant to be used to familiarise those citizens

3 who apply to the agency for help with the fact that the agency may be able

4 to perform some of these specific tasks at a given moment.

5 Q. Let's very briefly talk about these functions. Number one talks

6 about organising bus travel on routes from Banja Luka-Gradiska, and then

7 in parentheses to Zagreb, and then Banja Luka-Vlasic, and then in

8 parentheses, to Travnik.

9 We'll cover this in more detail shortly, but did the agency

10 actually provide these services?

11 A. Citizens would come to the agency to help them travel to Zagreb or

12 to Travnik. The agency always found a way to be of service to those

13 people. So yes, the answer is the agency did perform those services.

14 Q. Okay. And remember not only what I've told you, but more

15 importantly what His Honour has told you, to listen carefully to the

16 question and answer only the question. And I'm not mad at you for this,

17 but this could have been answered with a simple yes or no. So keep that

18 in mind, please, as we go through this.

19 The next thing, number two says: "The agency organises furnish

20 removal using trucks. Truck transport is based on a three-room apartment.

21 That is, it can transport belongings of two or three individuals who will

22 pay for the truck together."

23 The service of furniture removal, did the agency ever actually

24 remove furniture for individuals?

25 A. No.

1 Q. Why was that? Why couldn't that be done?

2 A. This was not possible in wartime.

3 Q. The third entry under Exhibit DB260 says that a service provided

4 by the agency is it organises a convoy of private luxury vehicles. "The

5 car must be cancelled at the CSB, and the trial -- and the trial

6 registration plates obtained. The technical goods that are being

7 transported must be taxed at customs, and the customs declaration must be

8 kept. Personal items should be listed, and the list verified at the

9 agency."

10 My first question with respect to that service was did the agency

11 ever actually provide organised convoys of private luxury vehicles leaving

12 the Municipality of Banja Luka?

13 A. Yes. For persons who had small children, those were not precisely

14 luxury vehicles, though.

15 Q. In the time that you were the chief of the agency, how many

16 vehicles actually left?

17 A. I don't know. But if it's necessary, I could say up to five, six,

18 perhaps ten vehicles a month. I can't be sure, however.

19 Q. Look at -- go now to the tab that is marked Exhibit 254. When you

20 locate that document, take your time reading it and let me know when

21 you're ready.

22 A. Can you give me the number again, please.

23 Q. Absolutely. 254.

24 A. Yes, I'm ready.

25 Q. First of all, who is DD D-O-M-E-T, DD DOMET in Zagreb?

1 A. That's an agency based in Zagreb which tried to run business in

2 the Autonomous Region of Krajina. It was only natural for us to get in

3 touch with them.

4 Q. This document is -- and we're getting a little bit far afield, and

5 it's my fault. But this document is entitled "a contract on cooperation."

6 Was this contract ever finalised? Was there ever a final agreement?

7 A. No. Never.

8 Q. Go down to the very last entry, the entry number is number 10.

9 That entry says: "The issue of luxury vehicles remains to be solved."

10 During the time that you were the chief of the agency, was it ever

11 possible to arrange a convoy of luxury vehicles to leave Banja Luka?

12 A. No.

13 Q. Why was that?

14 A. Can you repeat the question, please.

15 Q. Sure. I asked why was it not possible to arrange a convoy of

16 luxury vehicles to leave Banja Luka?

17 A. Whoever had an expensive or luxury vehicle would have gone long

18 before the agency was there to give them a hand. Secondly, in wartime, it

19 just wasn't possible. The reaction of other people, bystanders and

20 onlookers would have been unpredictable, those watching the cars and

21 convoys of luxury cars leaving the Banja Luka area.

22 Q. Let's go back to Exhibit 260, that's the exhibit that you looked

23 for, looked at earlier that talks about services provided by the agency,

24 because I want to talk to you about the last two services that are listed

25 in this document dated 25 November 1992.

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1 Are you back to that exhibit, sir, to number 260?

2 A. Yes.

3 Q. Thank you for that.

4 Number 4 says: "The agency conducts exchange of apartments/houses

5 and other material assets. In fact, the agency's task is to act as a

6 middleman between the interested parties." Now, we're going to talk about

7 this in more detail in just a minute. But yes or no, was the agency able

8 to provide that service to people?

9 A. No.

10 Q. What about number 5? Let's go back to number 4. You just told me

11 that no, they were not able to provide that service to people. Did the

12 agency have a function trying to assist people with apartments, with

13 flats?

14 A. Yes.

15 Q. And tell us very briefly what the agency's purpose was, what they

16 did to assist people who had flats?

17 A. People who had flats or houses would address the agency asking the

18 agency whenever it was possible to find them people with similar problems.

19 The agency would then put these people in touch, and they would then

20 proceed to sort out their own business and needs.

21 Q. Okay. And we'll talk about that in just a minute. But let's

22 finish up this document by talking about number 5, services provided by

23 the agency. Number 5 says: "Makes a contract between the parties who

24 manage to agree on an exchange."

25 You told us that you had a lawyer on staff. Did this lawyer

1 provide the contracts that are discussed in number 5?

2 A. No.

3 Q. Was the agency ever able to provide the service listed in number

4 5?

5 A. No.

6 Q. Why was that?

7 A. This was the competence of judicial organs, not of the agency.

8 Q. Okay. Let's go back to talk about the conducting of exchange of

9 apartments and houses that's referenced in number 4. You just told us a

10 minute ago that people who had flats or houses would address the agency

11 asking whenever it was possible to find them people with a similar

12 problem. Let's go into a little bit more detail now. How would that

13 work?

14 Let's assume I am a Croat. I have come to Banja Luka, and I have

15 a flat -- I own a flat or have access to a flat in Zagreb. If I came to

16 the agency, what services could you provide to me?

17 A. You come to the agency. You say that you own a flat in

18 Banja Luka. You want to go to Zagreb and swap your flat for the same kind

19 of flat in Zagreb. The first thing we had do is look through our records,

20 through our files, to see whether we had any people on file who had

21 arrived from Zagreb offering the same kind of thing. Whenever we found

22 such people on our lists, we would put them in touch with each other. We

23 give them phone numbers, or they would use our offices to make phone

24 calls, get in touch with each other, make appointments. And then they

25 would probably reach some kind of an agreement between themselves. That's

1 where our job stopped.

2 Q. Now -- and my question made no sense because I just said I'm a

3 Croat who has come to Banja Luka. So let's just assume that I was a Croat

4 living in Banja Luka with a flat, and I wanted to go back to Croatia.

5 When I showed up at the agency, what would I do?

6 A. First of all, you should inform us about your problem, the problem

7 being that you actually own property in Banja Luka and want to find an

8 equivalent in Zagreb and are ready to travel. Then a replacement would be

9 found for you, or some other flat that you may like. That's where our

10 service ends as concerns your property.

11 As for the second thing, your readiness to travel, there are

12 several steps to be gone through. But we can discuss that once you

13 actually ask me the question.

14 Q. Absolutely. Thank you for that. Where would the information be

15 kept? I am the Croat who owns the flat in Banja Luka, and I want to

16 exchange it. Would that be posted on the wall, anywhere within the

17 office? How would that work?

18 A. Information on citizens addressing the agency was kept secret. If

19 there was a citizen who did not wish his information to be displayed on

20 the bulletin board, this was complied with. If the citizen wanted to make

21 his personal information public, then this information would be placed

22 outside the agency on a pane of glass where everyone could see it. And

23 then they could look for people with similar problems and similar cases,

24 and just get in touch without any assistance whatsoever from anyone in the

25 agency.

1 Q. Now, did the agency charge a fee for serving as the middleperson?

2 A. I believe so, yes, pursuant to municipal regulations. This would

3 have been the normal fee charged for administrative services, for phone

4 services, and the like.

5 Q. And do you remember what that administrative fee would have been

6 back in 1992?

7 A. I can't quite remember, but it was in the regulations of the

8 town's administration. It was all pursuant to law.

9 Q. How would you -- I know you can't remember the specific numbers.

10 But would you characterise it as a high administrative fee, a low

11 administrative fee? How would you characterise it?

12 A. No. Not high, not low. Just usual. If you make a cash

13 withdrawal totalling 100 euros in a bank, the bank officials will probably

14 charge you a fee for their service. So this is the usual thing to do.

15 And our fee was the usual fee which was precisely stipulated in the

16 regulations of the municipal authorities. This was not down to any

17 personal decision taken by any individual; this was all done according to

18 regulations.

19 Q. And what would happen with the money that was collected, this

20 administrative fee? Where would it go?

21 A. The money would go to the agency's account, the agency's account,

22 the account that the agency had. Accurate records were kept, and money

23 was immediately placed into the account.

24 Q. Was information about that account, the agency's accounts, posted

25 openly, publicly within the office of the agency?

1 A. No. Only the head accountant had this information, those people

2 who were in charge of the specific tasks. There was no need to publish

3 this information in our offices. This kind of information is never

4 published in any company. You don't exactly put this kind of thing on a

5 bulletin board.

6 Q. Okay. And who had control over the account? Who had signature

7 privileges or authority over that account?

8 A. The head accountant, Mr. Radovan Jovic. He was in charge of

9 control. He monitored the transactions, further signatories were the head

10 of the agency, and the secretary, Perka Bandic. Whenever necessary, she

11 was authorised to make withdrawals from the bank on behalf of the agency,

12 and she only did that.

13 Q. Okay. We're at that point where I want to talk with you and to

14 have you inform the Chamber about one of the services provided by the

15 agency, and that is listed at number 1. It says: "Organises bus travel

16 from Banja Luka to Gradiska, Banja Luka to Vlasic." While you were the

17 chief of the agency, and if you need to find an exhibit, go back to

18 Exhibit 260, while you were chief of the agency --

19 A. Yes, yes.

20 Q. -- did the agency, in fact, arrange travel between Banja Luka to

21 Zagreb?

22 A. No, not Zagreb. As far as the border which was controlled by the

23 Croatian authorities.

24 Q. Did the -- while you were chief of the agency, did the agency

25 actually provide service from Banja Luka all the way to Travnik?

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1 A. Not all the way. Only as far as the Muslim-controlled line.

2 Q. Okay. And with respect to both the Croat-controlled line and the

3 Muslim-controlled line, what would happen at that point to individuals

4 that were on buses leaving Banja Luka?

5 A. As far as I know, there would be vehicles there waiting for people

6 who were travelling to their destinations.

7 Q. Which of these two routes, Banja Luka to Gradiska or Banja Luka to

8 Vlasic, which one of them was travelled more frequently?

9 A. Banja Luka to Gradiska.

10 Q. In the roughly six months that you were at the agency, on the

11 average, per month, how many buses would leave?

12 A. Two or three, sometimes only one. Sometimes two. It only

13 occurred once that there were actually six buses leaving. So the main

14 value would have been two or three.

15 Q. Okay. I think you might have misunderstood my question. I'm not

16 talking about how many buses might have been in a convoy; I'm just talking

17 about the frequency, how often it is that a bus or a group of buses left

18 Banja Luka. So let me ask that question again.

19 Just talking about the frequency, on a monthly average, how

20 many - I'm going to call them convoys - how many convoys would leave

21 Banja Luka?

22 A. On a monthly basis, it may have been twice, departures from

23 Banja Luka, perhaps three departures. The nature of the activities was

24 quite complex, but we can see about that later on.

25 Q. Okay. When these buses were leaving twice, maybe three times on a

1 monthly basis, typically how many buses would leave as a group?

2 A. On average, two or three. On average. Sometimes only one.

3 Sometimes two. I do remember that once, however, once only, there were

4 five or six buses leaving together. But this only happened once. As for

5 the rest, there would be one, two, or three buses leaving at a time.

6 Q. In order to become a passenger on a bus, was there a procedure

7 that needed to be followed?

8 A. The only thing I heard, in order to become a passenger on a bus,

9 there was a procedure to be followed. Was that your question?

10 Q. Yes, was there a procedure that needed to be followed?

11 A. Yes.

12 Q. Did the agency charge a fee for the bus service?

13 A. No -- yes, for transport. Yes, everyone needed to purchase a

14 ticket.

15 Q. And could you purchase the ticket in dinars or Deutschmarks? What

16 currency would the agency want?

17 A. Mostly in dinars. Whichever citizens did not have dinars, they

18 were free to pay in Deutschmark.

19 Q. And do you remember what the fee was the six months that you were

20 the head of the agency?

21 A. The travel fee was also regulated by the town's laws. It was the

22 same fee that other regular bus lines applied.

23 Q. Where did the fee go once it was collected by representatives of

24 the agency?

25 A. The money would be paid by citizens into the account and bring pay

1 slips. The agency had an account, and that's where the money was paid.

2 The citizen would normally bring back a pay note or a pay slip proving

3 that they purchased their ticket.

4 MR. CUNNINGHAM: Your Honour, I'm at a good stopping point, and

5 it's time for a break.

6 JUDGE AGIUS: Thank you, Mr. Cunningham. We'll stop here for a

7 short break of 25 minutes starting from now. Thank you.

8 --- Recess taken at 10.28 a.m.

9 --- On resuming at 11.01 a.m.

10 JUDGE AGIUS: Yes, Mr. Brdjanin is here.

11 Mr. Cunningham, please proceed.

12 MR. CUNNINGHAM: Thank you, Your Honour.

13 JUDGE AGIUS: Thank you.

14 MR. CUNNINGHAM:

15 Q. Before the break, we were at that point where I was going to have

16 you discuss the procedure to be followed if one wanted to leave, so let's

17 start there. If I was an individual who wanted to leave Banja Luka

18 between July 1992 and the end of the year of 1992 and I came to your

19 agency, how would it be that I got on a bus? Was there certain paperwork

20 that I needed to supply to the agency?

21 A. Yes.

22 Q. How would it work? Walk us through the process. I'm -- take a

23 typical person who comes to the agency who wants to leave either for

24 Gradiska or Vlasic. What's the first thing that they do?

25 A. All right. The procedure would be as follows: First you would

1 approach the agency and tell them what your wishes and intentions are.

2 You wish to travel. Then you get the instructions. You need to obtain a

3 document that you have registered out of your place of residence. If you

4 have obtained such a document, then you can be put on the list of persons

5 scheduled for the travel. Unless you have obtained the document, you

6 cannot be put on the list.

7 Q. Okay. When you talk about this document to show that you have

8 registered out of your place of residence, how would one go about getting

9 that document? Who do you go to to get that document?

10 A. This document can be obtained from any municipality, that is, from

11 the municipality where the person concerned is residing. And that is with

12 the Ministry of the Internal Affairs, that is, the police. They hold all

13 the information concerning the persons residing in the area. If there are

14 no problems involved, for instance, you are not under any criminal

15 investigation or you have not been charged with anything, you can obtain

16 the document there. You can be registered out of your place of residence

17 there. That's it.

18 Q. Okay. If I was travelling -- if an individual was travelling from

19 Banja Luka going to a Western country, say, the Netherlands, Sweden, a

20 place like that, was it ever necessary to have a letter of acceptance or a

21 letter of guarantee?

22 A. The person travelling knows, of course, what his or her

23 destination is and whether they can reach the destination. If they need a

24 letter of guarantee from, for instance, Sweden or The Netherlands, then

25 this person would be the one to ask the agency to try and obtain the

1 letter of guarantee from their friends. In some cases, the letter of

2 guarantee was not required; in others, it was. It all depended on the

3 wishes of the person travelling.

4 Q. In your answer, you said something I don't quite understand. You

5 said: "This person would be the one to ask the agency to try and obtain a

6 letter of guarantee from their friends." Would the agency actually be the

7 one to contact the individual in The Netherlands or Sweden or whatever

8 that Western country may be for that document?

9 A. No. Rather, the people in Sweden or The Netherlands would be

10 sending such letters to the AR Krajina; that is, these letters would first

11 arrive in Zagreb, and then would be forwarded to the border where the

12 persons travelling would arrive. So our employees would be the ones to

13 bring these letters of guarantees and deliver them to the persons to whom

14 they were addressed.

15 Q. And again, there's something in your answer that confuses me,

16 because you said that these letters of guarantee would first arrive in

17 Zagreb, and then be forwarded to the border. Would they be forwarded to

18 Zagreb, or be forwarded to Banja Luka?

19 A. To Banja Luka. But this was the way of actually having it arrive

20 in Banja Luka.

21 Q. And I'm still not clear on it. One more time. How would it

22 arrive in Banja Luka?

23 A. The letter would reach the border, for instance, at Okucani or any

24 other town controlled by the Croatian authorities. When the buses

25 carrying passengers from Banja Luka would reach that particular location,

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1 the -- our operative employees, Bandic and Segrt, would apply to the

2 Croatian authorities asking whether there are any documents for Banja Luka

3 citizens, any documents that arrived by mail. And then if there is -- if

4 there was something, if there was a letter of guarantee, then the Croatian

5 authorities would hand it over to us. If not, then nothing would come of

6 it.

7 Q. And were those -- your employees authorised to do that, what

8 you've just described, to pick up the letters and do the transfers?

9 A. They did have the authorisation. They were supposed to do so

10 because this was one of the services provided by the agency.

11 Q. Okay. So after an individual goes to the agency with the proper

12 documentation, what's the next step? Is that when the individual's put on

13 a list to leave?

14 A. The person has to bring the document testifying to the fact that

15 the person has registered out of its municipality of residence. And then

16 the list of persons is made, and the list is then double-checked in

17 Banja Luka. And once it has been established that the list is a final

18 one, then the persons involved have to purchase their ticket and can

19 travel by bus when scheduled.

20 Q. In the notebook, go to the exhibit marked 253, please. When you

21 find that document, read it to yourself and let us know when you're done.

22 A. I'm done.

23 Q. Is this exhibit, DB253, an example of what you're just talking

24 about, that is, that the persons involved purchasing their ticket and then

25 travelling on the bus when scheduled?

1 A. Yes.

2 Q. I look here at the top of that document, and it says: "In October

3 1992, the payment is 14.000 dinars." What was the purchasing power of

4 14.000 dinars --

5 A. Yes.

6 Q. What was the purchasing power of that amount of money in October

7 of 1992 in Banja Luka?

8 A. You could have bought two kilogrammes of meat.

9 Q. Right. We've talked about how passengers get on the list. Let's

10 now switch topics and talk about how the buses were acquired for the

11 actual transportation. Who was -- was there any particular person within

12 the agency that was responsible for locating and securing the buses for

13 transport?

14 A. Yes.

15 Q. And who was that?

16 A. Slobodan Bandic.

17 Q. Okay. Was there -- were there negotiations over the price of the

18 bus rental, or how was the fee set for the buses?

19 A. The fee for the bus was not something arbitrarily determined by

20 the agency. It was determined by the regulations governing regular

21 passenger travel.

22 Q. And I failed to ask you this question earlier, but I take it that

23 the agency did not have its own fleet of buses but had to hire buses or

24 rent buses to take passengers. Correct?

25 A. Yes. It did not have its own fleet of buses or its own vehicles.

1 Q. After the list of passengers is set, after the buses have been

2 hired, is there still a security concern that needs to be addressed before

3 the buses can leave?

4 A. Yes.

5 Q. And tell the Chamber if you would, please, what steps were taken

6 with respect to security.

7 A. If there was need to ensure safer transportation for the

8 passengers, we asked for the protection by the police. Otherwise, those

9 travelling were escorted by our operative employees, Segrt and Bandic.

10 Otherwise, passengers would be travelling regardless of the fact whether

11 police escort was required or not.

12 Q. How would you determine if a police escort was required? What

13 steps would be taken?

14 A. It was a simple procedure. The operative employees escorting the

15 bus, once they have done their job, they submit a report as to whether the

16 trip was a safe one. And particularly at the line of separation between

17 the two armies, if there were no war operations, the passengers could

18 travel. If there are war operations, then the passengers cannot go.

19 Q. So I take it -- well, I don't want to lead. Were there ever

20 instances that trips were cancelled because of security concerns caused by

21 military operations near the roads that the passengers would travel on?

22 A. Yes.

23 Q. Did you ever determine that it would be appropriate for a bus or a

24 group of buses to leave, but with a police escort?

25 A. If the assistance of the police was required, then we always asked

1 for it.

2 Q. In your notebook, please, find first of all the yellow tab marked

3 256, go to that, read it to yourself and let us know when you're done with

4 it.

5 A. I'm ready.

6 Q. Is that document dated 13 November 1992 an example of your request

7 for a police escort?

8 A. Yes.

9 Q. Go to Exhibit 259, and I want you to find that tab with the number

10 259. Read it to yourself because I want to ask you a question about that.

11 A. Fine.

12 Q. Is that another example of what we just talked about a minute ago,

13 that is, a request to the Security Services Centre.

14 A. Yes.

15 Q. After the security arrangements had been made, the passenger lists

16 compiled, the monies collected, what would be the next step?

17 A. The next step would be to establish the time of travel. Once this

18 has been done, the passengers are notified of the time of travel. Usually

19 the departures took place in the morning around 8.00, 9.00, or 10.00. The

20 persons travelling would show up at the place that was previously agreed

21 upon and at the scheduled time. And if there were two buses, then they

22 would be numbered 1 or 2. And by these numbers, you could always know

23 which passengers were supposed to go to bus 1 and which to bus 2. The

24 persons were roll-called, and upon hearing their name they would take

25 their seat on the bus. Because the passengers didn't have a ticket

1 bearing the number of the seat, which wasn't really important. The

2 important thing was that the passengers had their seats. They could take

3 their seats. And once this was done, the departure took place to the

4 desired destination.

5 Q. Okay. I want to go through and break down your answer in a little

6 bit more detail. First of all, where would the buses typically depart

7 from? Would they depart from the agency? Where would they leave from?

8 A. Outside the agency. There was an area of some five --

9 THE INTERPRETER: Interpreter's correction: 50 metres.

10 A. And the bus could fit there.

11 Q. And were you present and could you observe what happened when the

12 buses would leave from that location?

13 A. Not always. Sometimes. Our operative employees were in charge of

14 that.

15 Q. Sure. And what I want you to do is to talk about your personal

16 knowledge, what you saw those times that you saw the buses leave. This

17 location, first of all, that we've talked about, was that a public

18 location or was it private?

19 A. Public location.

20 Q. Would the location of the departure be posted to the public?

21 A. Yes.

22 Q. Okay. Would individuals who wanted to leave Banja Luka, would

23 they be required to come alone, by themselves, or could they be

24 accompanied by friends, family, relatives?

25 A. It was up to them. They could have shown up alone or in the

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1 company of their friends. It was up to them.

2 Q. And when you observed buses leaving, did you see -- happen to see

3 passengers saying their farewells to friends and family, or who would

4 appear to be friends and family?

5 A. Yes.

6 Q. Sometimes we know from looking, for example, at -- and you don't

7 need to look at this, I'm just using it as an example -- from looking at

8 Exhibit 259, this was two buses heading from Banja Luka towards Vlasic,

9 and it's a request for security. Those instances where the security

10 service centre was providing security, what would the officers, the police

11 officers be doing as the passengers were arriving at the scene and then

12 making ready for their departure on the buses? What would those officers

13 do?

14 A. Nothing in particular. They would be in their vehicle, and they

15 weren't interested in this procedure, in the employees doing their job.

16 Q. The times that you observed buses leaving that had security like

17 we've just described, did you personally ever see police officers

18 maltreat, do anything improper with passengers getting on the bus?

19 A. No.

20 Q. While you were present and watching these buses get loaded and

21 passengers made ready to travel, did you ever see any civilians maltreat

22 the people who were leaving?

23 A. No.

24 Q. Did you ever see the police ever attempt to extort, demand, take

25 money or property from passengers as they were making ready to leave or

1 boarding the buses?

2 A. No.

3 Q. During the time that you were there, did you ever see any

4 civilian, and just as importantly, any of your operative employees, do the

5 same? That is, extort, demand, take money or personal property from

6 passengers that were leaving?

7 A. No.

8 Q. Did the agency ever try to limit the amount of money that a

9 departing person could take with him or her?

10 A. No. The agency didn't have the authority to do so.

11 Q. I'm going to show you -- I'd like to show you an exhibit. This is

12 Prosecutor's Exhibit P227. This, for the record, is the ARK Gazette.

13 MR. CUNNINGHAM: And what I'd like to do, Mr. Usher, is if you can

14 find -- I apologise for not having a B/C/S copy for this witness. But we

15 need to find entry number 26. Entry number 26 is on page 44 of the

16 English version.

17 Q. Mr. Bojinovic, I'm going to read you what this decision of the ARK

18 Crisis Staff, issued on 3 June 1992, approximately three and a half weeks

19 before you started, says. Article 3 reads as follows: "Natural persons

20 leaving the Autonomous Region of Krajina may take out a maximum of 300

21 Deutschmarks or corresponding amounts in other currencies which may not

22 exceed this limit. Amounts of foreign currency which persons refer to in

23 paragraph 1 of this article may take out pursuant to Articles 8, 21, and

24 28 of the decree on official business travel expenses and establishment of

25 residence abroad which for the organs and organisations of federal

1 administration are recognised as material expenses shall be limited by

2 present regulations. Amounts exceeding the limit prescribed in paragraphs

3 1 and 2 of this article which the persons refer to in paragraphs 1 and 2

4 of this article, attempt to take out, shall be confiscated."

5 Did you as head of this agency ever receive any directives, any

6 orders, any suggestions, anything whatsoever that told you to limit the

7 amount of money departing passengers could take with them?

8 A. No.

9 Q. Did you ever ride along these routes with buses of passengers? I

10 should say a busload of passengers.

11 A. Yes.

12 Q. And how many times did you do that?

13 A. Once when we were headed for Vlasic, and once in the direction of

14 Gradiska.

15 Q. Now, I want to talk about those two separate trips. Let's go

16 ahead and take the trip to Gradiska. How is it -- why did you go along on

17 that trip?

18 A. There were two reasons for this. Firstly, I wanted to experience

19 in person what the ride was like, how the passengers felt on the trip.

20 Secondly, I had at the time friends of mine, Muslims, on the bus. And as

21 a person, I felt the need to escort them to the border and to part with

22 them there. I did not want to wait in Banja Luka.

23 On the bus, there was a wife and two daughters of a colleague of

24 mine who worked with me in a secondary school. And that was this once.

25 Q. And when you say the colleague with the wife and two daughters,

1 was that colleague a Muslim?

2 A. Yes.

3 Q. The day that you rode the bus with your colleague's wife and

4 children, what was the nationality, if you know, of the people that were

5 leaving Banja Luka?

6 A. I can't be a hundred per cent certain. But there were different

7 ethnicities there. Muslims, Croats, Slovenes, I believe, Serbs. I'm not

8 sure if there was anyone else. But I am certain about those that I've

9 mentioned.

10 Q. When you made this trip to Gradiska, what was the procedure? Did

11 it differ any from what I had you -- what you described earlier?

12 A. No. It was no different. Everything was the same as earlier.

13 Q. Okay. When you boarded the bus, how many people were on the bus?

14 A. Everything was done in compliance with regulations. There was a

15 regulation governing how many people you were allowed to fit on to a bus.

16 The bus, for example, could have 52 seats, and then in practice a mother

17 would have been allowed to have two children on two other seats. But not

18 more -- no more people were allowed on to the buses than could be seated.

19 Q. And was that the practice and procedure of the agency, not only

20 for this trip, but for other trips?

21 A. Yes, yes, this was regular procedure.

22 Q. Now, this bus trip that you took to escort your family's -- your

23 colleague's family, did the bus go all the way to Zagreb or did it stop

24 short of Zagreb?

25 A. I stayed back in Gradiska, but the bus drove on. As far as the

1 Croat-controlled line. I don't think the bus drove on after that, past

2 the Croat-controlled line. I don't think it did; that was the established

3 practice.

4 Q. And from Gradiska across the Sava to the Croat-controlled line, do

5 you know how long that would be? What distance?

6 A. No.

7 Q. As you rode the bus from Banja Luka to Gradiska, were you

8 accompanied by a police escort?

9 A. No.

10 Q. Was the bus that you were travelling with with your Muslim

11 colleague's family, was it ever stopped by men in uniform?

12 A. No.

13 Q. During the time that you were with the bus and escorting your

14 colleague's family, was there -- did you see anyone on that bus being

15 maltreated?

16 A. No.

17 Q. Did your colleague's wife and family arrive safely at their

18 ultimate destination?

19 A. Yes. They called me from Paris ten days later.

20 Q. And what was their attitude? How did they react to their safe

21 arrival?

22 A. They wanted to travel through Travnik. There was fighting between

23 Croats and Muslims going on down there, so the agency did not approve the

24 route on account of the safety of those travelling. Once they had passed

25 the Croatian border and reached Zagreb, a friend of mine, Meho Sihalic

1 [phoen], a geography teacher called to thank me for the fact that his

2 family had arrived safely. His children were very young. I used to be

3 Santa Claus for his children.

4 Q. I had to say this. You almost have the right hair colour for it.

5 I guess I really don't have any room to joke --

6 A. Thank you very much.

7 JUDGE AGIUS: Let's move.

8 MR. CUNNINGHAM: Very well, Your Honour.

9 Q. You also told us you made the trip to Travnik. How many times did

10 you make the trip actually not to Travnik but to Vlasic?

11 A. Yes.

12 Q. How many times did you make that trip?

13 A. Just once.

14 Q. And what was your reason for making this trip?

15 A. To assure myself personally of what the journey itself looked

16 like, how safe it was, and just to be there with the people travelling

17 because they placed great confidence in me.

18 Q. Okay. When -- obviously you were there as the passengers were

19 boarding the bus. Did you observe anything improper going on?

20 A. No.

21 Q. Did the -- were the buses boarded like you've described earlier,

22 in the same location at roughly the same time?

23 A. Yes, everything went fine.

24 Q. Okay. Let's go through it step by step. The nationalities, the

25 ethnicity of the people that were on the bus, could you tell?

1 A. Only Muslims.

2 Q. Okay. As they were -- as -- I'm sorry --

3 A. My apologies. There were people from mixed marriages, too, here

4 and there, the occasional mixed marriage between Serbs, Croats, and

5 Muslims. Whoever felt that it was safer for them to go to Travnik.

6 Q. Okay. Was this -- how many buses were in this group of buses that

7 were leaving?

8 A. One. One.

9 Q. Was it escorted by anyone from the Security Services Centre or any

10 other police or law enforcement agency?

11 A. Of course, there were Bandic and Segrt on behalf of the agency,

12 the usual escort. The public security station provided two police

13 officers driving an official vehicle following the bus.

14 Q. Okay. Did those police officers either at the point of departure

15 or anywhere along the route ever do anything improper? By that I mean

16 attempt to get any money, personal property, jewellery, or anything like

17 that from any person on the bus?

18 A. No.

19 Q. Was the bus ever stopped along its route and boarded by anyone who

20 treated passengers improperly?

21 A. No.

22 Q. Was there anything improper or unusual or illegal as that bus made

23 its way from Banja Luka towards Vlasic?

24 A. No. The road across the mountain is not of the same quality as

25 roads in the town. Aside from that, everything was as usual.

1 Q. What about the seating arrangements? Was this -- you told us

2 earlier that there were regulations that limited the amount of passengers

3 that could ride in a bus. Was that regulation observed on this trip?

4 A. There may have been four or five passengers more than could be

5 seated. But this was something you couldn't sort out on the spot because

6 those were families after all. You couldn't leave someone behind in

7 Banja Luka and take all the others away. Regulations were complied with,

8 but on this particular occasion, I think there were four or five people

9 more on the bus than the bus could actually seat.

10 Q. Okay. Where was the drop-off point, if you will, for passengers

11 on the buses travelling from Banja Luka to Vlasic?

12 A. The place is called Galica. It's a mountain pass where passengers

13 would get off the bus. And at that point, there was a kilometre or two

14 left for them to walk before they reached Muslim-controlled territory.

15 Q. Okay. Were you satisfied with -- well, what was your reaction as

16 the chief of that agency after you had made the trip from Banja Luka to

17 Galica?

18 A. Every smooth journey, whenever there was a smooth journey, and

19 there were never any problems, I was extremely satisfied because I knew

20 that all the those people were only leaving temporarily. I knew they

21 would be back sometime later, and that I would see all of them again. I

22 shared their grief. I shared their vicissitudes, and I encouraged people.

23 The hardest thing for me was to watch children travelling because there

24 was no way for me to explain to them what the whole thing was about. I

25 was happy to be in a position to provide my services, whatever services I

1 was in a position to provide to people. But that's what I do after all.

2 I teach. I teach young people to uphold standards of humanity, to show

3 character, to be honest, and the like.

4 Q. Let me -- I'm going to talk to you about your salaries, because in

5 evidence as both Prosecution and Defence exhibits are the payrolls first

6 from July of 1992, then from December of 1992. Let's just first of all go

7 to Exhibit 290. That would be number 2-9-0 on the yellow tab in your

8 binder. This is the payroll documents for July 1992.

9 A. Can you please give me the number again.

10 Q. Yes, sir. 2-9-0.

11 A. I'm ready.

12 Q. First of all, it says "payment in dinars," "payment in

13 Deutschmarks". What is it?

14 A. Only in dinars.

15 Q. And how was -- for example, we see the third column over, it says:

16 "Coefficient." How was it that your salary was determined? What does

17 that coefficient have to do with your salary?

18 A. The coefficient is the equivalent of your education level. People

19 who have merely completed secondary school cannot have the same salary as

20 people who have a university education. So that's what the coefficient

21 means.

22 Secondly, the level of complexity entailed in someone's work

23 varies from individual to individual, which again affects their salaries.

24 The coefficient is official. This is something that is determined under

25 law.

1 Q. Okay. We look at Exhibit 290, it shows that your net amount is

2 what, sir?

3 A. 16.900 dinars.

4 Q. Okay. Now I want you to look at, if you please, Exhibit 277,

5 which is the payroll records for December 1992.

6 A. Yes.

7 Q. It looks like the fourth column in, it shows your net amount. And

8 what is that net amount?

9 A. Based on this document, my amount was 93.381 dinars. The other

10 people on the list had the salaries indicated here.

11 Q. Now, if we were to compare July's payroll with December's payroll,

12 it almost looks like you had a raise of -- a fivefold raise; that is, you

13 went from approximately 17.000 to approximately 94.000 dinars. Did you,

14 in fact, get such a raise?

15 A. This strikes me as a bit strange. This is actually a decrease in

16 salaries on account of the inflation rate. Every ten days, the dinar

17 would drop, plummet, in relation to the mark. So this amount of money, it

18 seems like there has been an increase, but it's not actually true. As for

19 the exchange rate between the dinar and the German mark, it was published

20 every day in the Glas daily paper. It was no secret really.

21 Q. Okay. What would be the purchasing power in December 1992 or

22 January 1993 when you got paid for approximately 94.000 dinars? What

23 could you buy with that sort of money?

24 A. I can't quite say right now, but it was a very small salary,

25 insufficient to cover all the needs of an average person through a month.

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1 Not a single member of a family, let alone families with two, three, four

2 or more persons. I couldn't say exactly what you could buy with this kind

3 of money, but it would not have been sufficient to cover even a third of

4 average monthly expenditure.

5 Q. Were you married, or are you married?

6 A. Yes, I was married, and I still am.

7 Q. Okay. And do you have children?

8 A. Yes. Two daughters.

9 Q. The amount of money that you received in January 1993,

10 approximately 94.000 dinars, was that enough for you to support yourself,

11 your wife, and two daughters?

12 A. No.

13 Q. Okay. I want to go to a different exhibit, and that exhibit is

14 marked 278. I want you to find that document and read it to yourself.

15 And once you are done with it, please let me know.

16 MS. RICHTEROVA: This was also exhibited as P1689.

17 JUDGE AGIUS: Yes.

18 MS. RICHTEROVA: And I want to mention that all these three

19 exhibits which were previously exhibited by the Prosecution were exhibited

20 under seal.

21 MR. CUNNINGHAM: Well, I wish I would have known that earlier,

22 Your Honour, because I --

23 JUDGE AGIUS: Let's go into private session for a moment.

24 [Private session]

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25 [Open session]

1 MR. CUNNINGHAM:

2 Q. Looking at Exhibit DB278, this is an authorisation. What is this

3 authorisation all about? What purpose did this document do -- serve, I

4 should say?

5 A. The purpose of this document is to authorise persons to talk to

6 representatives of the Croatian authorities on behalf of the agency and

7 discuss possible cooperation.

8 Q. Early this morning -- earlier this morning, we talked about

9 Prosecutor's Exhibit 241, and we don't need to exhibit it, that's the

10 decision of 12 June 1992 appointing you to the chief of the agency. Did

11 you ever have any contact with Mr. Brdjanin, any of his representatives,

12 after you took control of this agency?

13 MS. KORNER: Actually, Your Honour, the asked-and-answered

14 objection. He has already answered that one. If you want to ask him

15 again, I have no objection.

16 MR. CUNNINGHAM: He just answered it again.

17 Q. Mr. Bojinovic, how would you respond to people who criticised you

18 and your agency as people who were in effect stealing from the non-Serb

19 population who were trying to get out of Banja Luka? Is that a valid

20 criticism?

21 A. I have never heard any such criticism uttered while I was working.

22 First I hear of it. It strikes me as illogical. If there are persons who

23 address the agency, why would they need to address the agency in the first

24 place if they knew that the agency was stealing from them, robbing them,

25 and taking them somewhere they wouldn't necessarily be safe? There's no

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1 logic in this. It just wouldn't have worked had the agency really been

2 involved in robbery, in stealing, or anything like that.

3 Q. Well, how do you -- you've talked about logic. I want to hear

4 your personal reaction. If someone were to criticise you and your agency

5 that in 1992, that you were stealing from people who were desperate to

6 leave Banja Luka, would that be a valid criticism? Did that happen?

7 A. No. This didn't happen. This would not have been possible.

8 There were people living in Banja Luka, citizens facing great difficulty.

9 Refugees coming from the area of the Federation, coming from Croatia.

10 Those people would not have allowed such things to happen. They would not

11 have allowed some people to steal, to make profit, while other people were

12 on the front facing great danger to their lives.

13 Q. Did your tenure, the time you spent with the agency, go to satisfy

14 your work obligation?

15 A. I'm not sure I understand your question.

16 Q. Sure. Did the time that you spent with the agency, did that

17 excuse you -- well, obviously did, because you've testified from it.

18 Forget that last question because I think you can answer it better by

19 answering this question: When you -- when your job ended in -- at the end

20 of December 1992, what happened to you? Did you go back to teaching?

21 A. I went back to teaching, which is what I actually do

22 professionally.

23 Q. Okay. And how soon were you back in the teaching profession?

24 A. It was on the 15th of March 1993. Therefore, you see, in the

25 meantime, there were half-term holidays, so I started working in the

1 second term, on the 15th of March 1993.

2 Q. Okay.

3 MR. CUNNINGHAM: That's all the questions I have, Your Honours.

4 JUDGE AGIUS: I thank you, Mr. Cunningham.

5 Ms. Korner, do you want to start -- I'm sorry. Madam Richterova,

6 do you want to start straight away, or do you want to have the break now

7 and start later?

8 MS. RICHTEROVA: No, we can start now.

9 JUDGE AGIUS: All right.

10 In the meantime, let's suspend the sitting for one minute, two

11 minutes.

12 --- Break taken at 12.02 p.m.

13 --- On resuming at 12.04 p.m.

14 JUDGE AGIUS: Yes, my apologies to you, Madam Richterova.

15 MR. CUNNINGHAM: Your Honour, I apologise. I did not get a copy

16 of the exhibits the OTP plans to use.

17 JUDGE AGIUS: I'm sure that was an oversight.

18 MS. KORNER: Your Honour, no, it's not an oversight. The fact is

19 we don't actually know what these witnesses are going to say until they

20 say it. So there's only a provisional list that is prepared.

21 JUDGE AGIUS: But it was an oversight certainly not handing it to

22 Mr. Cunningham.

23 MS. KORNER: You were given now the provisional list, Your Honour.

24 It could have been given --

25 JUDGE AGIUS: Yes.

1 MS. KORNER: It's only handed out once the witness --

2 JUDGE AGIUS: That's what I meant.

3 Yes, you are going to be cross-examined by the Prosecution now,

4 Madam Richterova will be putting the questions to you. Please.

5 Cross-examined by Ms. Richterova:

6 Q. Good morning, Mr. Bojinovic. I will start with --

7 A. Good morning.

8 Q. -- with the part you were talking about your first meeting with

9 Mr. Brdjanin which took place sometime in 1991. And you said: "I spoke

10 about the need for every intellectual to have common sense, to try to be

11 active in their own environment, to try to explain to those who are less

12 knowledgeable, to try to tell them to remain calm, to not provoke

13 incidents."

14 When you were talking about these intellectuals and about these

15 less knowledgeable, did you -- or do you consider to be an intellectual?

16 A. It is for the others to say if I am or am not. In the area I come

17 from, everyone who has graduated from a university is considered to be a

18 sort of an intellectual.

19 Q. You were a teacher. And if I understood correctly, you were not a

20 head teacher; you were just an ordinary teacher?

21 A. I was not a headmaster. I was a teacher.

22 Q. Which means you had no managerial experience either in 1990, 1991,

23 or 1992?

24 A. No.

25 Q. And you stated that when you were appointed the director of this

1 agency, you didn't receive any instruction, you weren't told what to do,

2 how to do it. Do you consider it right that you, as an intellectual --

3 A. No.

4 Q. So you as an intellectual, intelligent person, you took a job

5 about which you didn't know absolutely anything?

6 A. Well, I thought it was a proper thing to do because these duties

7 were of later date. Something that was not known before came up as a

8 result of the circumstances. Probably those who took this decision of who

9 to appoint as head of the agency, they probably wanted to have an

10 intellectual, a person who had good communicative skills, who had a

11 psychological insight into the people and could be of help under the given

12 circumstances.

13 Q. I will talk about your work with the agency at some later stage.

14 Now, I would like to ask you about your membership in the SDS. When did

15 you -- when did you become a member of the SDS?

16 A. Officially in 1991. And unofficially as soon as the SDS had been

17 established, I was a follower of this party. I adhered to its programme

18 just as my people did.

19 Q. Why do you say "unofficially"? What do you mean by stating

20 "unofficially"?

21 A. First, a party has to be established in order to have members.

22 Q. Did you participate at these initial steps of setting up of the

23 party together with Jovan Raskovic or Radovan Karadzic?

24 A. Yes.

25 Q. Did you participate in all the meetings which took place in Drvar

1 during the year 1990?

2 A. No.

3 Q. You didn't participate in any, or did you participate in some of

4 these?

5 A. I was in Drvar on the 4th of July as a common citizen. I didn't

6 know either of the two men. And in Sarajevo on the 12th of July in 1990,

7 I was there with all the other citizens. I was even in contact with the

8 late Izetbegovic. And that's about it as concerns my acquaintances. I

9 wasn't an organiser. I was just an anonymous person, and my community is

10 also a very small one, and I could not have really been an organiser or an

11 ideologist of any sort.

12 Q. A second ago you said: "I was a follower of this party. I

13 adhered to its programme just as my people did." Who are "my people"?

14 Who are you referring to?

15 A. I mean the Serbian people because up to then, you only had one

16 party in the former Yugoslavia. It was the League of Communists. And I

17 never really agreed with the League of Communists' programme. When

18 Yugoslavia came to be dissolved, then the peoples living in the

19 area -- yes.

20 Q. Thank you. We know about the League of Communists. I was

21 just -- if you could answer just my question. And if I need some more

22 information, I would ask you.

23 You mentioned you were in Drvar on 4th of July 1990. Were you

24 ever a member of -- and I'm talking about these initial steps or initial

25 meetings. Were you ever a member or candidate for the position of the

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1 member of the main board of the SDS?

2 A. Yes.

3 Q. So when was it?

4 A. It was in 1990 following the establishment of the party.

5 Q. So you were a member of the main board of the SDS?

6 MR. CUNNINGHAM: I'm going to object for the form of the question

7 because he said he wasn't a member of the main board. I apologise.

8 JUDGE AGIUS: So please proceed.

9 MR. CUNNINGHAM: Well, what he said yes was to "were you ever a

10 member or a candidate for the position of member of the member of the main

11 board of the SDS," so I think my objection is valid because it's not

12 clear.

13 JUDGE AGIUS: Were you ever a member of the main board of the SDS?

14 THE INTERPRETER: Microphone for Your Honour, please.

15 JUDGE AGIUS: My apologies. Were you a member?

16 THE WITNESS: [Interpretation] No.

17 JUDGE AGIUS: No. So you were only a candidate?

18 THE WITNESS: [Interpretation] Yes.

19 JUDGE AGIUS: So let's proceed from there.

20 MS. RICHTEROVA:

21 Q. So you were a candidate to become a member of the main board. So

22 it means that you belong among the organisers of the party or the policy

23 of this party. Is that correct?

24 A. No.

25 Q. And what happened -- you said you were on the candidate list.

1 Were you appointed a member --

2 A. Yes.

3 Q. Were you appointed a member of the main board?

4 A. No.

5 Q. Were you politically active in your municipality, in Glamoc?

6 A. No.

7 Q. Do you know a man called Milorad Bojinovic?

8 A. Yes.

9 Q. Who was it? Who was him?

10 A. He was the gentleman who passed away a couple of months ago. He

11 lived in Banja Luka, if this is the person you are talking about, who

12 worked in the pension/disability insurance.

13 Q. No, I was talking about one Milorad Bojinovic from Glamoc.

14 A. Yes, that is him. He moved over to Banja Luka and lived there.

15 If you are talking about him.

16 Q. Was this Milorad Bojinovic the president of the SDS in Glamoc?

17 A. No.

18 Q. What was the name -- what was the name of the first president of

19 the SDS in Glamoc?

20 A. Up until the establishment of the SDS, there was no president.

21 And after the SDS was established in 1990, I think it was Milorad Babic.

22 Babic. That's his family name. But I'm not sure about his first name.

23 Q. And for how long was this Milorad Babic president of the SDS in

24 Glamoc?

25 A. I don't know. I think he was still president during the war, but

1 many people changed, were replaced during the war, and I wasn't really

2 keeping contact with them.

3 Q. Mr. Bojinovic, you stated that you were candidate for the main

4 board of the SDS, you followed the policy. Can you tell us why you

5 weren't politically active in Glamoc?

6 A. I was never really attracted by politics.

7 Q. So why was this reason that right from 1990 you were involved in

8 the setting up of the party, of the party of your people, as you said?

9 A. Yes.

10 JUDGE AGIUS: I don't think the witness has understood your

11 question. It's certainly not your fault, Madam Richterova. I

12 will -- with your indulgence, I will put the question again myself.

13 You've just told us, Mr. Bojinovic, that you were never really

14 interested in politics.

15 THE WITNESS: [Interpretation] Yes.

16 JUDGE AGIUS: If that is so, how come that you involved yourself

17 in precisely the setting up of a political party, namely, the SDS, if you

18 were not interested in politics?

19 THE WITNESS: [Interpretation] The setting up of a political party

20 is something that came out of the circumstances in 1990. I was interested

21 in the fate, not only of my people, but of the entire area of the former

22 Yugoslavia, which doesn't mean that I had any political pretensions. From

23 the party's establishment to this date, I have never held any political

24 duty.

25 MS. RICHTEROVA:

1 Q. And only one more question, I again, repeat this, that you were a

2 candidate for the main board of the Bosnia and Herzegovina SDS, which is

3 quite an important position. So you say "I was not interested in

4 politics," so what was the reason that you stand for this rather important

5 position in the SDS?

6 A. Well, probably the people appreciated me, the people in my

7 community.

8 Q. Just because the people appreciated you as a person, it was the

9 reason why you stand for this -- for this important position within the

10 SDS?

11 A. I don't know if there were any other reasons. But I think this

12 was the main one.

13 Q. So it was the people who wanted you to be a member, but it was not

14 you who wanted to be a member of the main board?

15 A. Yes.

16 Q. Now I would like to go back to the meeting which occurred in

17 Banja Luka in 1991 during which you met Mr. Brdjanin. You were introduced

18 to Mr. Brdjanin by one Ljupko Racic, if this is correct. Who was this

19 man, Ljupko Racic?

20 A. I knew him from before. He wrote poetry.

21 Q. And you met him by chance in Banja Luka, or did he accompany you

22 to Banja Luka?

23 A. No. He lived in Banja Luka, and I knew him as a poet.

24 Q. And was it him who took you to the Hotel Bosna?

25 A. No, no. Rather, he had told me that one could have a drink at

1 Hotel Bosna, that he went there quite frequently, and that was it.

2 Q. So you went to Hotel Bosna with Mr. Ljupko Racic, and how did you

3 meet Mr. Brdjanin?

4 A. There were people seated around a table, as is usual. And also as

5 usual, then you get to know these people, people introduce themselves.

6 That was all.

7 Q. Was it Mr. Ljupko Racic who introduced you to Mr. Brdjanin?

8 A. No. I merely came up and shook hands with everyone. It wasn't

9 really a formal introduction by this gentleman we are talking about.

10 Q. Can you tell us who else apart from Mr. Brdjanin was that day in

11 the Hotel Bosna sitting around the same table with you.

12 A. I didn't know other people from before.

13 Q. And why do you remember that Mr. Brdjanin was there?

14 A. Mr. Brdjanin was well known as a sportsman, and it is only natural

15 that when I got to know that the person in front of me was him, I knew him

16 because he had been known to show up in the mass media as a sportsman.

17 But I had not met him personally earlier.

18 Q. Was he introduced only as a sportsman, or was he also introduced

19 in his professional capacity or any other capacity?

20 A. As a sportsman, because I am keen on sports.

21 Q. And you were introduced as a teacher?

22 A. No. As Milos Bojinovic.

23 Q. Did you talk about your profession?

24 A. At this particular meeting we did not talk about our occupations.

25 It was just an ordinary chat over a drink as happens in similar

1 situations.

2 Q. You testified that you talk about politics during this meeting.

3 Is it correct?

4 A. Whether you can term it as politics or not, but we talked about

5 the emerging situation which wasn't particularly nice.

6 Q. Mr. Bojinovic, I will read you what you stated. "We discussed

7 politics because the situation in the area was complex. The discussion

8 was just an ordinary one. No particular plans were being hatched as to

9 what could happen." Why were you talking about plans? Were there any

10 plans at some later stage?

11 A. No, not that I know of. I have no knowledge of any plans. At

12 this particular meeting, there were people who happened to be there by

13 chance, and of course they didn't go there to discuss anything specific.

14 We merely talked of a situation which was complex.

15 Q. And why did you mention in your testimony, why did you mention

16 this plan? Why did you mention the word "plan"?

17 A. Well, another term could have been used instead of "plan," but the

18 question was what did you talk about and whether there were any plans.

19 Well, there were no plans. I am not an engineer, nor a high-ranked

20 politician planning anything.

21 Q. Mr. Bojinovic, I didn't -- it wasn't me who was talking about

22 plans; it was you who said, and I quote: "No particular plans were being

23 hatched as to what could happen." You said it. So why did you say it?

24 A. Yes. I don't --

25 Q. Do you have an explanation?

1 A. Well, I could explain it the following way: Normally people talk

2 about the goings on, the plans that are in existence and so on. My

3 logical answer to that is there were no plans -- or instead of saying

4 plans, you could say there were no specific arrangements. This term

5 "plan" could be replaced by a number of alternatives. So it might be an

6 important thing to you as a Tribunal, "plan"; to me, it is just an

7 ordinary word.

8 MS. RICHTEROVA: We have time for a break.

9 JUDGE AGIUS: I think we can leave it at that for the time being.

10 Mr. Bojinovic, we are going to have another break for 25 minutes starting

11 from now. Thank you.

12 --- Recess taken at 12.30 p.m.

13 --- On resuming at 12.58 p.m.

14 JUDGE AGIUS: Do you think you will finish today, Ms. Richterova?

15 MS. RICHTEROVA: No, I won't.

16 JUDGE AGIUS: I would appreciate then if you could leave us just a

17 few minutes, or rather you can take up to the very end, because I only

18 need one or two minutes --

19 MS. KORNER: Your Honour, I was going to actually ask if we could

20 have a few minutes at the end anyhow because I want to try and sort out

21 the witnesses again. So perhaps if Ms. Richterova could stop at around

22 half past 1.00, because we'll certainly finish tomorrow.

23 JUDGE AGIUS: Okay, that's perfect. That would suit us perfectly

24 well.

25 Yes, Madam Richterova.

1 MS. RICHTEROVA:

2 Q. Mr. Bojinovic, before the break we were talking about the meeting

3 which you had with people in Hotel Bosna among which Mr. Brdjanin was

4 present. And we were talking about this word "plan." And I again will

5 quote what you said: "Normally people talk about the goings on, the plans

6 that are in existence, about specific arrangements. There were no such

7 plans." My question is "no such plans," plans for what?

8 A. I don't know what plans people could be hatching who only just met

9 for the very first time. There were no plans. We just chatted away over

10 a drink. This word "plan," I'm not sure what it refers to.

11 Q. As I said, it was you who mentioned this word. And it is the

12 reason why I am asking you. But you were just talking. Can you be a

13 little bit more specific and very briefly tell us what you were talking

14 about.

15 A. We just met by chance. Everyone wanted to say something just by

16 way of introduction. I can only tell you what I was talking about. But

17 after so many years, you can hardly expect me to remember what the other

18 people were saying. I can hardly remember what I had for lunch yesterday,

19 let alone what people were saying at a completely meaningless meeting ten

20 years ago. I can tell you what I said at the meeting.

21 JUDGE AGIUS: I think you would be repeating. You have already

22 told us what you said, unless you have anything different or anything new

23 to add.

24 THE WITNESS: [Interpretation] No.

25 MS. RICHTEROVA: Your Honour, if -- he said that they were talking

1 about politics.

2 JUDGE AGIUS: Yeah, and he said before that the situation was such

3 that one needed to stay calm. It's -- if there's anything else, let's

4 hear, but I think it's a series of questions and answers that are not

5 going to lead us anywhere. So the message, according to what I

6 understood, was that the discussion was very general, generic, not

7 specific. That's what I understood. I'm not going to stop you,

8 Ms. Richterova. Don't misunderstand me.

9 MS. RICHTEROVA:

10 Q. I will ask you this: You mentioned this meeting was sometime in

11 the year 1991. Can you recollect approximately in which part of that

12 year?

13 A. I don't think I can with any degree of precision whatsoever.

14 Q. Was it after the war in Croatia started?

15 A. I don't know when the war started in Croatia. I don't know when.

16 Therefore, I'm not able to tell you anything about that, not with

17 certainty at any rate. I know that the war in Croatia began in 1991, but

18 I couldn't give you the exact month.

19 Q. You were -- you mentioned that you were talking about your

20 opinions. Were you talking about the policy of the SDS? And if I

21 presume, you were all members of the SDS?

22 A. I don't know if any of the people there were members, in fact. I

23 know that I myself was a member. If any of the others were, I really

24 don't know.

25 Q. Did Mr. Brdjanin mention that he was a member of the SDS?

1 A. No.

2 Q. Did he mention which position he held at that time?

3 A. No.

4 Q. Did he tell you whether he worked at the time in Banja Luka or in

5 Celinac?

6 A. No.

7 Q. Did you have any private conversation with Mr. Brdjanin at that

8 time or at any later stage?

9 A. No.

10 Q. Was it the only time -- until the moment you were appointed the

11 director of the agency, was it the only time you met Mr. Brdjanin?

12 A. Yes.

13 Q. And at that time you met him in 1991, you didn't mention that you

14 were a teacher, he didn't mention what position he held. Is that correct?

15 A. I can't remember specifically. But I don't think it would have

16 been necessary for anyone to say what their profession was. This is

17 usually referred to as boasting where I come from. I didn't find out

18 about the professions of any of the people present back then.

19 Q. And you didn't exchange addresses, telephones, anything?

20 A. No, no.

21 Q. And very last question, during -- about this meeting is I

22 just -- you said you do not remember who else was present. I will just

23 tell you randomly some names, and you can tell us whether you remember by

24 any chance that such a person would be present. Vojo Kupresanin, was he

25 present at that meeting?

1 A. I don't remember him being there. I was not exactly in touch with

2 him. I don't think he was there, but I can't be sure. I'm not sure of

3 any of the people because that was the first time we met. I'm only sure

4 about Mr. Brdjanin being there. I did not know any of the other people at

5 the meeting.

6 Q. And Radislav Vukic? Was he present?

7 A. Will you please repeat the name for me.

8 Q. Radislav Vukic?

9 A. Vukic. No. No.

10 Q. Can you tell us why you are so sure that Mr. Brdjanin was present

11 at that meeting? You say there were ten people. You do not remember

12 anybody else but Mr. Brdjanin.

13 A. That's right. There were about ten people there. I'm not sure if

14 it was ten, nine, eight. Mr. Brdjanin has a very striking appearance

15 physically. He's an athlete. He's the kind of person you tend to

16 remember. What you don't remember doesn't matter.

17 Q. Mr. Bojinovic, Mr. Brdjanin became a politician, a public figure.

18 Did you follow his career after this meeting when you were able to say I

19 met such a sportsman, such an important person?

20 A. I didn't really have anyone else's careers in mind. It wasn't my

21 business. It was their own business. I didn't really follow

22 Mr. Brdjanin's career or anyone else's.

23 Q. But what I am saying, I understand that it's everybody's business

24 which career he or she follows. But he became a public figure. You met

25 him. You became an acquaintance of him based on this meeting. So did you

1 follow his professional development?

2 MR. CUNNINGHAM: I object. That's repetitive. It has been asked

3 and answered.

4 JUDGE AGIUS: Yes, but -- it is repetitive in a way,

5 Mr. Cunningham. I'm going to allow the question because the witness did

6 not exactly answer the previous question that was put to him. He answered

7 it partially and at a tangent. So please answer the question.

8 THE WITNESS: [Interpretation] Will you please repeat the question

9 in that case.

10 MS. RICHTEROVA:

11 Q. Yes, I can repeat the question. My question was: Mr. Brdjanin

12 became a public figure. Did you -- and you met him. You became an

13 acquaintance of his. Did you follow his professional development after

14 the meeting, of course?

15 A. I'm not sure I understand what you mean by "follow." You mean

16 watch whenever he appeared on TV, read about him in the printed media, or

17 whether I had a personal insight into his activities. Can you please

18 specify.

19 Q. Yes, I can elaborate. I mean, were you able to attend any rallies

20 in which he would be present? Or did you read any interviews with him in

21 any kind of newspaper articles? Did you watch him, did you see him on

22 television?

23 A. I never attended any rallies whatsoever. As for Mr. Brdjanin as

24 someone who was very much in the public eye, it was there for all to read

25 in the papers. You could see it on TV whenever they showed anything like

1 that. Anyone could see it. Anyone who was able to read or switch on a TV

2 set.

3 Q. Mr. Bojinovic, I am not talking about anyone; I am talking about

4 you. And my question is whether you followed his development, whether you

5 were able to say, "this is Mr. Brdjanin," and he is whatever he was at the

6 time you watched the TV, you read the newspaper article about him.

7 A. Yes.

8 Q. So you read -- you knew what was his position? You were able to

9 learn his position from what you read in the newspaper? Is it correct?

10 A. Yes.

11 Q. And what you see on television or what you learned from any other

12 sources. Is it correct?

13 A. I'm afraid the question is not clear. Can you please repeat the

14 question.

15 Q. I think I will move on. You answered it -- my previous question.

16 I want to ask, were you aware that Mr. Brdjanin became a

17 vice-president of the ARK Assembly?

18 A. No.

19 Q. That he became president of the ARK Crisis Staff? Did you know

20 about this?

21 A. No.

22 Q. So because you said that you were able to follow Mr. Brdjanin, or

23 better say, his professional development, what did you learn about him?

24 What was he? Was he just a sportsman, and you read about Mr. Brdjanin as

25 a sportsman? Or what did you read about Mr. Brdjanin or what did you see

1 on television about him?

2 MR. CUNNINGHAM: Your Honour, I hesitate to object, but there's

3 six different questions there, and I'd ask as best as she could to limit

4 her --

5 JUDGE AGIUS: Yes.

6 MR. CUNNINGHAM: -- to avoid the compound question.

7 JUDGE AGIUS: You are right, Mr. Ackerman -- Mr. Cunningham. Mr.

8 Cunningham understands why I keep saying Mr. Ackerman.

9 Let's split this question into parts, Madam Richterova, please.

10 MS. RICHTEROVA: Yes, I will.

11 Q. You just stated that you didn't know that Mr. Brdjanin was

12 vice-president of the ARK, that he was the president of the crisis staff.

13 Did you know that he was a politician?

14 A. No.

15 Q. What did you know from what you read in a newspaper that

16 Mr. Brdjanin was?

17 A. I knew that he was a minister for construction. But that was only

18 later. That was after the ARK. You're talking to me -- you're asking me

19 about his position as vice-president of the Krajina Assembly. But at that

20 point, I knew nothing about that, and I knew nothing about that before

21 Mr. Brdjanin became the minister for construction and civil engineering.

22 I think that's what it's called. It was only after that you could read

23 about him in the papers, about ministers, about government members. It was

24 the daily kind of thing that was in the press.

25 Q. Mr. Bojinovic, do you want to tell the Judges that you never read

1 or heard anything about Mr. Brdjanin during the year of 1991 and the first

2 half of the year 1992?

3 A. It simply wasn't possible. I was in Glamoc at the time, which is

4 a very small town. And it's far away from Banja Luka. We did not get any

5 press, daily press from Banja Luka. We had the general Bosnia and

6 Herzegovina press. We only had the daily, Oslobodjenje, which as a rule

7 contained no information whatsoever on Mr. Brdjanin.

8 Q. You were not allowed -- you were not able to read the Glas

9 newspaper in Glamoc?

10 A. No.

11 Q. And you were not able to receive Banja Luka TV in Glamoc?

12 A. No. There was no such thing as Banja Luka TV.

13 Q. At a later stage when there was Banja Luka TV? Did you watch it

14 either in Glamoc or in Banja Luka?

15 A. Let's try to be accurate. I arrived in Banja Luka on the 1st of

16 July 1992. Prior to that, I had no information from TV or the press on

17 Mr. Brdjanin. He was not a person in the public eye before that time,

18 before I arrived in Banja Luka. He came into the public eye, at least as

19 far as I was aware, after he had been appointed minister. But this was

20 already 1993.

21 Q. Mr. Bojinovic, you mentioned that you were mobilised approximately

22 in April 1992. Is it correct?

23 A. On the 13th of April 1992.

24 Q. At that time, you were a teacher. You were 40 -- approximately 45

25 year old. Was it normal that an intellectual, a teacher, would be

1 mobilised?

2 A. Yes.

3 Q. And he would be mobilised and sent to the front line?

4 A. Yes.

5 Q. And you also told us that you learned about your appointment to

6 the position of director of this agency while you were in the -- on the

7 front line. Is it correct?

8 A. Yes.

9 Q. And you were informed verbally?

10 A. Yes.

11 Q. Who conveyed this message to you?

12 A. The messenger of my battalion.

13 Q. Can you tell us, what was the message? Was it you got a position,

14 or was it already specific what kind of position you were going to hold?

15 A. No. There was nothing specific. According to the rules of

16 service that applied in the army, the messenger would inform any soldier

17 to report to the command. That was the procedure followed. Let me add

18 this, too. The command informed me that I had been informed and advised

19 of my duty to report to Banja Luka following my appointment to one of the

20 agencies.

21 Q. And this happened when? Do you remember how many days before you

22 left for Banja Luka?

23 A. That was a day or two before I arrived in Banja Luka. This

24 happened at the same time as my regular leave that every soldier is

25 entitled to.

1 Q. So you report to your commander. And were you --

2 A. Yes.

3 Q. And were you demobilised?

4 A. No.

5 Q. So how it was possible that you left the army, that you left the

6 front line?

7 A. Can you please repeat the question.

8 Q. You were mobilised, you were in the army, you were at the front

9 line. You received the message to report in Banja Luka. You left for

10 Banja Luka, but you say that you were not demobilised. How is that

11 possible that you started working? Were you still mobilised at that time?

12 A. I'll try and explain. I left for Banja Luka. I was told about my

13 duties. My duty was to go back to my command to complete my military

14 stint with that particular unit. Once I'd done that, I was as a

15 consequence demobilised, which means that I ceased to be a soldier with

16 the unit that I had originally come from.

17 Q. You were supposed to go to Banja Luka. Where were you -- where

18 did you report yourself in Banja Luka?

19 A. I reported to Mr. Blagojevic. We have referred to him today.

20 Q. And was it a part of this message that you were supposed to

21 contact Mr. Blagojevic?

22 A. There was no special recommendation, if that's what you have in

23 mind. The decision on my assignment stated clearly in the heading "the

24 Autonomous Region of Krajina." And then I asked, who is the man in

25 charge? Who is the man I should report to? I talked to people on the

1 street, and I asked them the question. And they told me such and such a

2 man is occupying such and such a position, that is the building. And

3 that's how I found him.

4 Q. Mr. Bojinovic, but you stated that you received the information

5 about your appointment verbally first. And second, in fact, you didn't

6 know what kind of --

7 A. Yes.

8 Q. -- Assignment you received.

9 A. Yes.

10 Q. So how did you know that you were supposed to contact

11 Mr. Blagojevic?

12 A. Because I was informed that this had come straight from the

13 Autonomous Region of Krajina. I asked around who was there, who was in

14 charge of these affairs. And then people on the street told me where the

15 offices of the Autonomous Region of Krajina were, and I went there. I

16 spoke to staff as soon as I got there. I didn't know who they were. They

17 said: "Go and speak to Mr. Blagojevic," and that's how I eventually

18 reached him.

19 MS. RICHTEROVA: Your Honour, I think this would be the right

20 moment because I would like to discuss the appointment and the work of the

21 agency.

22 JUDGE AGIUS: Okay. I thank you, Madam Richterova.

23 So Mr. Bojinovic, we are going to stop here today. We will

24 continue tomorrow, and we hope to finish tomorrow so you can go back to

25 your family. The usher will be escorting you out of this courtroom.

1 Thank you.

2 THE WITNESS: [Interpretation] Thank you.

3 [The witness stands down]

4 JUDGE AGIUS: So, Ms. Korner.

5 MS. KORNER: I don't know whether Your Honour wanted to -- I know

6 Your Honour said there was a matter you wanted to raise.

7 JUDGE AGIUS: Well, the matter is I want to know roughly when to

8 expect Mr. Ackerman back, because he's on my mind, of course. I want to

9 clear a few things about the expected day of completion of the Defence

10 case. And I don't want to burden you with all the responsibility,

11 Mr. Cunningham, unless you are in a position to assume responsibility for

12 some information.

13 MR. CUNNINGHAM: I'm not ready to assume -- put that yoke on just

14 quite yet. Mr. Ackerman can be here in the morning, I'm sure that

15 wouldn't be a problem, or at a time that's convenient for this Chamber.

16 JUDGE AGIUS: The reason I'm saying this is because throughout

17 Mr. Ackerman had been assuring us that he would be in a position to

18 conclude the Defence case by the end of January, and now we're talking of

19 the end of February or beginning of March.

20 MR. CUNNINGHAM: And I know he's in a much better position to tell

21 you where we stand. The other day I alluded to some of the concerns that

22 potential witnesses were raising. And apparently, that's reared its ugly

23 head more than one time.

24 JUDGE AGIUS: And another thing I want to mention, I want to make

25 sure that you are aware that we are sitting in the -- in January in the

1 week starting on the 12th.

2 MR. CUNNINGHAM: Right. We're aware of that and everything has

3 been adjusted because of that.

4 JUDGE AGIUS: That's also a concern that I had. I had a vague,

5 vague -- obviously now I was wrong. I realise I was wrong. A vague

6 impression that you were assuming that we were restarting on the 17th or

7 19th of --

8 MR. CUNNINGHAM: I wish that was the case, but I have been

9 corrected.

10 JUDGE AGIUS: All right, okay.

11 Yes, Ms. Korner.

12 MS. KORNER: Well, Your Honour, it's running along the same

13 linings in a sense. As I recall, Mr. Ackerman, he said this visit to

14 Banja Luka might shorten matters for the end of the January. And I fully

15 appreciate, and it became absolutely clear to us that there was no

16 conceivable way given there are only about another ten sitting days left

17 of this year, and we don't start until the 12th of January. But

18 Your Honour, what I'm concerned about is this, and I'll raise it for

19 Mr. Ackerman to deal with tomorrow morning.

20 First of all, I understand the problem. The third witness listed

21 for next week, I gather, is not inclined or has reasons why he want turn

22 up and will be rescheduled.

23 JUDGE AGIUS: Yes.

24 MS. KORNER: Therefore, we would like to know obviously as soon as

25 possible, if possible tomorrow, who the third witness next week is likely

1 to be because the name of a witness was mentioned by Mr. Cunningham who

2 isn't on any lists that we've got as intending to come before Christmas.

3 Again, I say -- I'm not objecting to it, we would just like to know who's

4 coming.

5 We don't have any witnesses listed for after the week of the 8th

6 of December. The only list we have been given by Mr. Ackerman is up until

7 that week. And there's one more week sitting after that. So that's the

8 next matter.

9 MR. CUNNINGHAM: Let me try to address these concerns as quickly

10 as I can. Witness number 38 has some concerns, and he is going to be

11 rescheduled. What we were doing is trying to find a witness who would be

12 of a similar length, and originally Witness number 42 came to mind.

13 Witness Number 42 is hesitant for the reasons we've talked about before.

14 We should know something about him this afternoon, whether he's coming or

15 not. If he's not coming, what we -- what we're going to talk about doing

16 is maybe moving up two of the one-day witnesses. I don't know which ones

17 those will be. I hope to address the Court on that tomorrow.

18 With respect to the week after that, because you had a concern

19 over that, it is still our intention the week that I believe

20 begins -- it's either 7 December or 8 December --

21 JUDGE AGIUS: 8.

22 MR. CUNNINGHAM: 8 December, to start out with witness Number 34

23 and follow him up with Witness Number 40. Now, the people that we

24 intended to follow that witness, they're up in the air because we're -- we

25 don't know whether they're going to be moved up to next week or not.

1 Ms. Korner, if helps you somewhat, at least it appears to me Witness

2 Number 34, Witness Number 40 are -- I'd like to call them firm for the

3 week of December 8.

4 MS. KORNER: Yes. Well, Your Honour, again it's the week after

5 that. As Your Honour appreciates, as I've said over and over again, we

6 have to prioritise the work that's done because there's many competing

7 claims on the particular...

8 Your Honour, the last matter is this, and I did send

9 Mr. Cunningham an email yesterday, but for some reason he and I, our

10 emails don't always communicate very well. I don't think he's received

11 it. Can I just mention it. I also said I want to deal with that

12 tomorrow, and that is I have listed what I described as the witnesses

13 whose cross-examination is likely to be lengthy and asked for confirmation

14 now that the visit to Banja Luka has taken place as to which, if not all

15 of these witnesses will actually be attending. Because that obviously

16 will effect the structure because as I said to Your Honours yesterday,

17 we're going to make it very clear that we'll be asking for the witnesses

18 to be in such a position to give sufficient time to properly

19 cross-examine. So Your Honour, I've listed those, I don't think I need to

20 go through them.

21 JUDGE AGIUS: No. I would prefer you didn't actually for obvious

22 reasons.

23 MS. KORNER: Your Honour, I've only listed the ones as far as we

24 know who as far as we know will testify in open session and just given

25 numbers for the others.

1 JUDGE AGIUS: Yes, exactly. But I suppose that if the list or the

2 information is communicated to Mr. Ackerman, he should be in a position

3 to, if not confirm to us, at least liaise with the Prosecution on the

4 matter.

5 MR. CUNNINGHAM: I will bring that up with him this afternoon.

6 And if I can communicate by way of email with Ms. Korner, I'll update her

7 as best as I can electronically. Otherwise, Mr. Ackerman will be here in

8 the morning.

9 MS. KORNER: And Your Honour, finally, and again Mr. Ackerman may

10 want to deal with this, we have been told that we can't get any expert

11 reports before Christmas. But also it appears there has been a change in

12 the constitutional expert who I understood to be some lady from Belgrade

13 or somewhere. But it appears it may be somebody different now. If it is

14 somebody different, if we could be told tomorrow.

15 MR. CUNNINGHAM: Absolutely, Your Honour.

16 JUDGE AGIUS: Okay. Point taken.

17 Anything else?

18 My exhortation, if I may use that word, is to try and put us in a

19 picture, the best picture possible, because we need as you can imagine

20 with a case of this dimension, we need considerable time for our

21 deliberations. And to liaise with the staff and meet amongst ourselves,

22 meet amongst -- with our staff, draft parts ourselves, have other parts

23 drafted for us. It's going to be a mammoth exercise. And every day that

24 we can gain, you realise that we would be always in a better position. So

25 expect us to do our best to gain as much time as we can. Okay?

1 So we'll -- what I suggest, Madam Chuqing, can you copy this part

2 for me, this part of the transcript after Madam Richterova finished so

3 that I make notes of every point raised so that I'll make sure that

4 everything is addressed tomorrow morning when hopefully Mr. Ackerman will

5 be with us. All right. And please, we try and make sure that the witness

6 will be in a position to leave.

7 MS. RICHTEROVA: Definitely he will. He will.

8 JUDGE AGIUS: All right. Thank you.

9 --- Whereupon the hearing adjourned at 1.38 p.m.,

10 to be reconvened on Friday, the 28th day of

11 November, 2003, at 9.00 a.m.

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