120208ED

Page 24288

1 submitted in writing, and I need to deal first with the formalities

2 associated with that submission. You provided a statement to

3 representatives of the Republika Srpska MUP and were spoken to by

4 representatives of the Office of the Prosecutor in 2005 and on two

5 occasions in 2009; is that right?

6 A. Yes, that's right.

7 Q. Have you recently had the opportunity to review with the

8 assistants of an interpreter an amalgamated statement containing relevant

9 excerpts of these interviews?

10 A. Yes.

11 Q. You provided some clarifications and observations which were

12 incorporated into the signed version of that statement; is that right?

13 A. Yes, that's right.

14 MS. SUTHERLAND: Mr. Registrar, could I have 65 ter 90313,

15 please.

16 Q. Ms. Mihajlovic, on the screen in front of you do you see a

17 statement there, and is that your signature at the bottom of the page?

18 A. Yes, it is.

19 Q. Do you agree that the -- the contents of the signed statement is

20 accurate?

21 A. Yes.

22 Q. If you were asked today about the same matters that are contained

23 in that statement, would you provide the same information to the

24 Trial Chamber?

25 A. Yes.

Page 24289

1 MS. SUTHERLAND: Your Honour, I tender 65 ter 90313, please.

2 JUDGE KWON: Yes, that will be admitted.

3 THE REGISTRAR: As Exhibit P4358, Your Honours.

4 MS. SUTHERLAND: And with Your Honours' leave, I'll now read the

5 summary of the witness's written evidence.

6 The witness Mira Mihajlovic was Radovan Karadzic's secretary from

7 the 5th of January, 1993, until the 27th of January, 1996. She worked

8 together with another secretary, Milijana Rasevic, in the presidential

9 office.

10 The witness identifies her handwriting and that of her colleague

11 Rasevic in a log-book maintained by them and in Karadzic's appointment

12 books for 1994 and 1995.

13 The witness explained that the appointment books were maintained

14 to ensure that there was an accurate record of Karadzic's meetings and

15 telephone conversations. A minus symbol would be entered when an

16 appointment or telephone call was scheduled, and this would be converted

17 to a plus symbol once the appointment or telephone call had been

18 completed or realised.

19 The witness explains the process of sending and receiving

20 communications from the president's office to the Republika Srpska

21 Ministry of the Interior, the Army of the Republika Srpska, and other

22 organs.

23 Mrs. Mihajlovic or Ms. Rasevic would generally type up all kinds

24 of presidential documents for Mr. Karadzic. A courier would then deliver

25 the typed document to the republic communications centre where the

Page 24290

1 documents would be encrypted and transmitted to the recipients.

2 Similarly, couriers would deliver incoming messages to the presidential

3 office from the communications centre. With Ms. Rasevic, the witness

4 maintained archives of the presidential documents and records in a filing

5 cabinet in the office.

6 The witness explains how the OBL secured the office and that a

7 security guard was present 24 hours a day. Once Mr. Karadzic had

8 returned home for the evening, a security duty officer was always present

9 in the office to answer the telephone.

10 The witness recalls that Mr. Karadzic conducted all of his

11 meetings behind closed doors, and she would not be present during these

12 meetings and was not asked to make notes of the meetings.

13 That completes the summary of the witness's written evidence,

14 Your Honour. I have a number of questions for Mrs. Mihajlovic.

15 Q. Mrs. Mihajlovic, in your statement, you state that you and

16 Milijana Rasevic worked every other day and that in your statement you

17 also speak of an internal communication system in relation to

18 Mr. Karadzic's appointment books, and I have just read out the plus sign

19 and the minus sign.

20 You also state, and this is in paragraph 33 of the amalgamated

21 statement, that you would also record the approximate length of the

22 meeting and the call -- or the call and that was usually done in

23 parentheses and at the end of the day you would put a time when you left

24 the office.

25 I would now like to show you a couple of documents, three

Page 24291

1 documents, so that you can show the Trial Chamber how the system actually

2 worked.

3 MS. SUTHERLAND: If I could have now 65 ter 09178, please.

4 [Trial Chamber and Registrar confer]

5 JUDGE KWON: I was told that it hasn't been released yet.

6 MS. SUTHERLAND: I apologise for that, Your Honour. Just one

7 moment.

8 It should be available in e-court now.

9 Q. Mrs. Mihajlovic, we can see the document on the screen is an

10 interview of "El Pais" journalist Angel Santa Cruz Molina with

11 Radovan Karadzic on the 13th of July, 1995. This is the transcript of

12 the interview. Is this interview consistent with any entries in the

13 appointment book for 1995?

14 And to assist you, is it possible to have on the same screen, the

15 other side of the screen, the right-hand side 65 ter 04754, which is

16 P02242. And if we could go to page 78 of the English and page 90 of the

17 B/C/S.

18 It is for the date the 13th of July, 1995, and I apologise if --

19 if -- page 90 should -- should be that date. So we need to go forward

20 quite some pages. And the following page, please.

21 Mrs. Mihajlovic, do you see any entries which are consistent with

22 the interview which occurred on the 13th of July, 1995?

23 A. I do. This interview had been planned, that is obvious, and it

24 was actually held on at that day.

25 Q. And is that the last entry that we see for the date of the

Page 24292

1 13th of July, 1995, in the appointment book on the screen?

2 A. Yes.

3 JUDGE KWON: Just to be sure, can we see the English translation

4 of this diary or appointment book.

5 MS. SUTHERLAND: Your Honour, it should be on page 78 of the

6 English version.

7 JUDGE KWON: What time-frame does it refer to?

8 MS. SUTHERLAND: The 13th of July, 1995. So we can see on the

9 left-hand side of the screen starting the 13th of July. If we could go

10 to the following page in the English.

11 Q. Now, you say that the interview happened, and is that because you

12 can see that there's a plus sign before the -- the interview?

13 A. Yes, that's correct.

14 JUDGE KWON: Did we find the item in the appointment book? What

15 time was it planned at?

16 MS. SUTHERLAND:

17 Q. Mrs. Mihajlovic, if you can tell the Trial Chamber what is in

18 relation to the entry for the interview, what is in brackets, in

19 parentheses, at the end of that entry.

20 A. The parentheses show the time when the interview commenced and

21 ended. In other words, it commented at 2135 hours, and went on until

22 2210 hours.

23 JUDGE KWON: Thank you.

24 MS. SUTHERLAND:

25 Q. And then on the right-hand side of the notebook, we see the

Page 24293

1 22.15, and can you explain what that means to the Trial Chamber.

2 A. That means that the president left the office at that time, and

3 that the work-day ended at that time.

4 MS. SUTHERLAND: Your Honour, I seek to tender 65 ter 09178,

5 which is the interview with the Spanish journalist.

6 MR. ROBINSON: Object. Object. Objection, Mr. President. I

7 don't believe that this is an accurate foundation for the content of the

8 interview. Simply showing that an interview took place at a certain time

9 doesn't provide evidence of the accuracy of its contents.

10 JUDGE KWON: Would you like to respond, Ms. Sutherland.

11 MS. SUTHERLAND: Your Honour, I submit that it is relevant and

12 probative and it is linked to this witness's evidence. It may be used to

13 assist the Chamber in assessing the probative value or the weight to be

14 given to the witness's evidence in relation to the system used in the

15 appointment book [overlapping speakers].

16 JUDGE KWON: Just a second. Can you -- can you upload -- in the

17 meantime, can you upload that interview 9178, at least in English? Yes,

18 please continue, Ms. Sutherland. I'm sorry to interrupt you.

19 MS. SUTHERLAND: Your Honour, the document will assist the

20 Chamber in assessing the probative value or the weight to be given to the

21 witness's evidence in relation to the system used in maintaining the

22 appointment books to verify that a meeting or a telephone call was

23 schedule and whether in fact it actually took place. You have the

24 discretion to admit the document now for this limited reference purpose.

25 And as I said a moment ago, I would submit that it corroborates this

Page 24294

1 witness's evidence as to how the appointment books worked.

2 THE ACCUSED: [Interpretation] May I respond?

3 JUDGE KWON: Mr. Robinson, you said that -- what would be your

4 observation with respect to Ms. Sutherland's suggestion, admitting this

5 for limited purpose?

6 MR. ROBINSON: Yes, Mr. President. If that were the only purpose

7 for its admission and the contents of the interview would not be taken

8 into account by the Chamber I don't see any problem.

9 [Trial Chamber confers]

10 MS. SUTHERLAND: Your Honour, we do have the audio of the ...

11 Your Honour, we do have the audio of that interview.

12 JUDGE KWON: But your purpose of tendering this document was to

13 corroborate Ms. Mihajlovic's evidence as to how she recorded all the

14 appointment.

15 MS. SUTHERLAND: Yes, Your Honour, and that's --

16 JUDGE KWON: So we will admit this.

17 MS. SUTHERLAND: That's the basis I seek to be tendered.

18 JUDGE KWON: For the limited purpose, i.e., not for the content

19 of its truth. We'll give the number for that.

20 THE REGISTRAR: Exhibit P4359, Your Honours.

21 MS. SUTHERLAND: If I could have the next document, 65 ter 13763.

22 Q. Mrs. Mihajlovic, this is a summary of an interview of

23 Dr. Radovan Karadzic with the Bosnian Serb television on the 4th of

24 August, 1995. Is this interview consistent with any entries in the

25 appointment book? And in order to assist, if we could have again

Page 24295

1 Exhibit P02242 on the screen, and if we could go to page 102 in the

2 B/C/S. And page 88 in the English.

3 Mrs. Mihajlovic, do you see there in the B/C/S on the right-hand

4 side of the screen any entry there which is consistent with the interview

5 of Dr. Karadzic with the Bosnian Serb television on the 4th of August,

6 1995?

7 A. Yes. This -- this was the last entry for that day at 2100 hours,

8 "guest appearance on TV."

9 Q. And the entry has a plus sign next to it.

10 A. Yes.

11 Q. Which means according to your earlier testimony that that

12 actually occurred; is that correct?

13 A. Yes.

14 Q. And then we see the -- on the right-hand side of the page

15 0015 hours.

16 A. Yes.

17 Q. And again, what does that mean?

18 A. That means that our work-day ended at that time.

19 MS. SUTHERLAND: Now, if we could have the document back on the

20 screen, 13763, please.

21 Your Honour, I seek to tender that document, again for the

22 limited purpose.

23 JUDGE KWON: Yes. We'll admit it for limited purpose, i.e., for

24 the purpose of corroborating Ms. Mihajlovic's evidence as to the method

25 of keeping -- or, Mr. Karadzic's appointment book, and we'll give the

Page 24296

1 number.

2 THE REGISTRAR: Exhibit 4360, Your Honours.

3 MS. SUTHERLAND: And the final document is 65 ter 13684.

4 Q. Mrs. Mihajlovic, as you can see, this is a 1st Krajina Corps

5 report dated the 30th of September, 1995, regarding a meeting of

6 Republika Srpska government with municipal War Presidency representatives

7 on the 29th of September, 1995, which was chaired by the president and

8 the prime minister and one other. Is this report of a meeting that

9 stated that the president participated consistent with any entries in the

10 appointment book?

11 MS. SUTHERLAND: And again if we could assist the witness with

12 Exhibit P02242, the 1995 appointment book, and if we could go to B/C/S

13 page 116. And the English, page 96.

14 So we can -- I think it may be page 119 in the B/C/S. I'm sorry.

15 We can see in the English down the bottom it starts the

16 29th of September, 1995. And in the B/C/S, could we go back one more

17 page, and one more. Sorry, no. We're on the right page.

18 Q. Mrs. Mihajlovic, do you see there --

19 MS. SUTHERLAND: If we could reduce it just a tiny, bit,

20 Mr. Registrar.

21 THE WITNESS: [Interpretation] Yes. The date is the 29th of

22 September, the top of the page, and the first meeting scheduled and noted

23 there is 1100 hours meeting with the municipal War Presidency.

24 MS. SUTHERLAND:

25 Q. And again, if you could explain the full entry to the Chamber.

Page 24297

1 It has a plus sign, so is it correct, according to your evidence, that

2 the meeting occurred?

3 A. Yes. That means that the meeting was held and that it lasted

4 until 2000 hours, as far as I can see.

5 MS. SUTHERLAND: Could we have the previous page in English on

6 the screen, please.

7 Q. And so you just mentioned that it had 2000 hours. That is at the

8 end of the entry; is that correct?

9 A. Not -- up until 2000 hours. That's what it means. That was the

10 first duty he had on that day, the first meeting, from 1100 to 2000

11 hours, to 8.00 p.m.

12 Q. Yes. And then I think we can see the rest of the meetings that

13 occurred on that day are all after 2000 hours?

14 A. That's correct.

15 MS. SUTHERLAND: Your Honour, again I tender --

16 JUDGE KWON: Could we ask Ms. Mihajlovic to read out the first

17 two lines on the B/C/S page.

18 A. Plus "1100 hours, meeting with the presidents of the

19 War Presidency -- municipal War Presidencies." And the second one is a

20 minus, and then there's a telephone number 332-611, Professor Lukic.

21 JUDGE KWON: Do we see the minus sign in the English translation?

22 MS. SUTHERLAND: If we can go to the following page. Your

23 Honour, that's a plus, and --

24 JUDGE KWON: So that's an error in translation.

25 MS. SUTHERLAND: That's an error in translation, and it will be

Page 24298

1 corrected.

2 JUDGE KWON: Yes. Can we go back to the first page. Where do we

3 see not until 2000 hours?

4 MS. SUTHERLAND: At the end of the entry, Your Honour. Right

5 down the bottom of the page in English.

6 JUDGE KWON: No, I mean in B/C/S.

7 MS. SUTHERLAND: At the end -- at the end of the entry. You can

8 see the word "Twenty." Twenty hundred.

9 JUDGE KWON: Just beneath "1995."

10 MS. SUTHERLAND: Yes.

11 Q. Ms. Mihajlovic, is -- is -- from your reading of this entry, do

12 you understand that the meeting commenced at 11.00 and finished at 2000

13 hours from your understanding of reading that entry now?

14 A. Yes.

15 JUDGE KWON: Thank you.

16 MS. SUTHERLAND: Your Honour, I seek to tender that document 65

17 ter 0 -- sorry. 65 ter 13684 again for the limited purpose as discussed.

18 JUDGE KWON: Mr. Robinson, do you still maintain your objection

19 for the purpose of admitting that 1st Krajina Corps document?

20 MR. ROBINSON: Well, Mr. President, I think that in this

21 situation since it's probably a document that could be admitted from the

22 bar table at least we can not object to its full admission.

23 JUDGE KWON: Yes. It will be fully admitted.

24 THE REGISTRAR: Exhibit 4361.

25 MS. SUTHERLAND: That completes my examination-in-chief,

Page 24299

1 Your Honour. If we could deal with the associated exhibits.

2 JUDGE KWON: Yes. Except for those that were already admitted,

3 are there any objections, Mr. Robinson?

4 MR. ROBINSON: No, Mr. President.

5 MS. SUTHERLAND: And, Your Honour --

6 JUDGE KWON: Can we take a look at 65 ter 21458, which is a

7 log-book.

8 What log-book is this, Ms. Mihajlovic?

9 THE WITNESS: [Interpretation] This is a log-book where we

10 recorded the documents that left the institution, documents that were

11 assigned a certain number and that were registered in this book.

12 JUDGE KWON: And you're tendering it in its entirety.

13 MS. SUTHERLAND: Yes, Your Honour.

14 JUDGE KWON: Very well. That will be all admitted and given a

15 new number in due course.

16 MS. SUTHERLAND: Thank you, Your Honour. And also, sorry, I

17 forgot to mention, Your Honour, in the Rule 92 ter notification 10832 is

18 actually already admitted as Exhibit P02820.

19 JUDGE KWON: Yes. Mrs. Mihajlovic, your statement was admitted

20 in lieu of your oral testimony in this case, and then you will be further

21 cross-examined by Mr. Karadzic.

22 THE WITNESS: [Interpretation] Very well.

23 JUDGE KWON: Mr. Karadzic.

24 THE ACCUSED: Thank you.

25 Cross-examination by Mr. Karadzic:

Page 24300

1 Q. [Interpretation] Good afternoon, Ms. Mihajlovic.

2 A. Good afternoon.

3 Q. I would like to thank you for having been so kind as to meet with

4 me and my associate. I hope that this will help us finish this

5 cross-examination quickly.

6 A. The pleasure was mine as well. Thank you.

7 Q. I would like us to go through a few things from your statement.

8 I have to remind myself, actually, to pause between question and answer

9 so that we do not exhaust our interpreters.

10 In paragraph 23 -- actually, do you have your amalgamated

11 statement printed out? Do you have it there?

12 THE ACCUSED: [Interpretation] Could Mrs. Mihajlovic please be

13 given a copy of her amalgamated statement.

14 THE WITNESS: [Interpretation] Thank you.

15 MR. KARADZIC: [Interpretation]

16 Q. Thank you. You started working in the president's office in the

17 beginning of 1993, regardless of who this president may be?

18 A. Yes, that's right.

19 Q. If you have the transcript, you can see when the interpretation

20 is over. I mean, I paused now waiting for the interpretation to finish.

21 You are talking about the establishment of different services.

22 That is what you refer to in this paragraph. And you also talk about

23 advisors and associates. This is what I wanted to ask you: At that

24 point in time, did I travel often, especially to Geneva, Belgrade, and

25 elsewhere, and were all of these trips exclusively made for the purpose

Page 24301

1 of negotiating for peace?

2 A. As far as I can remember, you travelled often and for that

3 purpose, and I think that that is recorded in our books, in our notes.

4 Q. Thank you. Do you agree that the days when there was nothing

5 were primarily Sundays, whereas on Saturdays I would come and work at the

6 office?

7 A. I think that's the way it was.

8 Q. Thank you. Do you agree that my advisors read reports from the

9 field, everyone in their own particular areas, and they underlined what I

10 should focus on, or they would tell me when we talked about what I should

11 focus on since there were a great many reports?

12 A. Yes.

13 Q. In my absence, did the service function as follows: The advisors

14 would receive reports, and if there was something urgent, they would

15 address the ministries or the Main Staff?

16 A. Yes.

17 Q. In paragraph 25 and further on, there is a description of the

18 stay in Banja Luka. We saw the reports today. This period in

19 Banja Luka, was it marked by the fall of many municipalities, and large

20 parts of territory in western Bosnia -- or, rather, in western

21 Republika Srpska, Croatia and NATO enter the war?

22 A. As far as I can remember, yes, that was the main reason why you

23 were there for a longer period of time.

24 Q. Thank you. Do you remember a document in which Gordana Milinic

25 asked for the reports to be sent to Banja Luka because for some time they

Page 24302

1 were not being sent to Banja Luka, so we did not have insight into what

2 was happening?

3 A. I'm sorry, I don't remember that.

4 Q. Thank you. Perhaps we'll find it some other time.

5 In paragraph 28, you say that there were lots of people, panic,

6 chaos. Do you remember that from all of these municipalities that were

7 falling then, namely Drvar, Glamoc, Grahovo, Bosanski Petrovac, Jajce,

8 and later on Mrkonjic Grad as well, do you remember that all of these

9 people who were refugees flooded Banja Luka?

10 A. I was there briefly. I came after you, but I know that the

11 situation was chaotic in the streets of Banja Luka, that people were

12 panic-stricken. It was a very bad picture. There was no electricity.

13 It was totally chaotic.

14 Q. Thank you. Do you remember that in the beginning of August

15 hundreds of thousands -- actually, over 200.000 Serbs from Krajina, from

16 the Serb Krajina, passed through Banja Luka as well as they were trying

17 to reach Serbia as refugees after Croatian Operation Storm?

18 A. Yes, I remember that.

19 Q. Did that lead to an increase in fear, and was it reminiscent of

20 the fall of the Serb Krajina, or was there fear that Republika Srpska

21 would fall as well because these municipalities were falling one after

22 the other?

23 A. Yes. That's the way it seemed. People were panic-stricken.

24 Q. Thank you. In paragraph 29, you say Professor Koljevic,

25 Professor Plavsic, and Momcilo Krajisnik could see me without having made

Page 24303

1 an appointment as high-ranking officials, eminent persons. Do you agree

2 that nevertheless their visits would be recorded in your diary?

3 A. Yes.

4 Q. In paragraph 36, you talk about how telephone calls were made,

5 and you say -- I'm going to read it out in English:

6 [In English] "If the president at that time received a telephone

7 call, he could maybe speak on the phone for 30 minutes and that almost an

8 hour does not mean that really somebody spoke with him for almost an

9 hour."

10 [Interpretation] I would like us to clarify something. For

11 example, if you would write down that somebody entered my office at 1.00

12 in the afternoon and stayed until 6.00 in the afternoon, and in the

13 meantime I would receive other persons as well, would that mean that they

14 were all in the same room, or could I leave one room and receive other

15 people while that first delegation would be working with somebody else?

16 A. Well, yes. That kind of thing would happen. Would you receive

17 some people in your office, and then some other people would come. You

18 could leave and leave these people in your office so that you could

19 receive some other people in some other room within your office.

20 Q. Thank you. I would like to ask you to take a look at the

21 14th of July, when there was a visit from the delegation of the

22 municipality of Srebrenica, Skelani, headed by Mr. Deronjic.

23 We are calling that up, but in the meantime can we have a look at

24 the next page and paragraph 41. Forty-one refers to the period from

25 April 14 through 16. It says that there is no information there. Do you

Page 24304

1 remember that on the 15th of April, the 50th Assembly of Republika Srpska

2 was held in Sanski Most, and is that the reason why your diary or

3 log-book was empty?

4 A. The log-book was certainly empty because you were not active in

5 your office. I don't remember that the Assembly session was held at that

6 point in time, but what is certain is that you were absent from the

7 office.

8 Q. Thank you. I think it's the log-book -- no. No. The log-book

9 is not picture. No. Can somebody help us with the number, the number of

10 this diary, the log-book, the secretary's diary?

11 MS. SUTHERLAND: For 1995, it's Exhibit P02242.

12 THE ACCUSED: [Interpretation] Can we have that in e-court and

13 then the date of the 14th of July in that document. Thank you.

14 MR. KARADZIC: [Interpretation]

15 Q. Is it correct that Churkin, Ambassador Churkin, was scheduled for

16 1800 hours, but he arrived at 1925 hours, and stayed until 2240 hours?

17 A. Yes.

18 Q. Is it correct that Miroslav Deronjic and the delegation of

19 Srebrenica were scheduled for 11.00 and they arrived -- what time was

20 this? 12.40.

21 A. I think 14.25.

22 Q. I see. 14.25 and they stayed until 18.25; right?

23 A. Yes, but there is this bit of information a bit further up, and I

24 think that is unclear. It says 12.40 in parentheses.

25 Q. I see. Does it pertain to Ostojic and Karadzic, or you don't

Page 24305

1 know?

2 A. Well, let me take a look. One moment, please.

3 JUDGE KWON: Just a second. Just a second. We can -- for the

4 purpose of -- yes. We zoom in for -- a bit further. Yes.

5 So can you tell us what the -- the item which says 12.40 to 13.10

6 refers to what?

7 THE WITNESS: [Interpretation] I don't remember, but it could mean

8 that Miroslav Deronjic was there only in that period. And later on, this

9 other period of time, the delegation.

10 JUDGE KWON: Thank you.

11 MR. KARADZIC: [Interpretation]

12 Q. Is it possible that Karadzic and Ostojic were scheduled for that

13 time for the following day and then they stayed for that period of time?

14 A. I'm not sure, because there is a minus before that. They were

15 certainly planned for that day, but they probably remained to be seen on

16 the following day.

17 Q. Thank you. So the period for the delegation of Srebrenica and

18 Deronjic, that is 14.25 to 18.25. Let us take a look further down and

19 see who else came to see me.

20 JUDGE KWON: In -- in the meantime, Ms. Sutherland.

21 MS. SUTHERLAND: [Overlapping speakers] ... wasn't what the

22 witness said.

23 JUDGE KWON: In the meantime, I wanted to note that the minus for

24 Professor Karadzic and Ostojic was not correctly reflected in the English

25 translation.

Page 24306

1 MS. SUTHERLAND: No, no. I actually noted it myself and I was

2 going to bring it to your attention that that is also something that we

3 will have --

4 JUDGE KWON: So can you upload the English translation as well.

5 So, in your view, the English translation on the right side is correct.

6 MS. SUTHERLAND: Is that a question to Mrs. Mihajlovic?

7 JUDGE KWON: Yes, Mrs. Mihajlovic.

8 Mr. Deronjic stayed from 12.40 to 13.10, and together with the

9 delegation from 14.25 to 18.25?

10 THE WITNESS: [Interpretation] From 14.25 until 18.25. That's

11 what this note should mean. However, the plus is a mistake. The plus

12 further up. Professor Karadzic and Velibor Ostojic, there's a minus

13 there.

14 THE ACCUSED: [Interpretation] And the marking.

15 JUDGE KWON: Yes. About the 12.40 to 13.10, what does it refer

16 to, Mrs. Mihajlovic?

17 THE WITNESS: [Interpretation] Since it's unclear and our notes

18 are sort of squeezed in, it may relate to Mr. Deronjic, because it's

19 right above his name, but I'm not sure.

20 JUDGE KWON: Thank you.

21 Yes, Mr. Karadzic.

22 MR. KARADZIC: [Interpretation]

23 Q. Now, do you agree that in that same period of time, say

24 beforehand from 13.45 until 18.25, Professor Koljevic and

25 Ljubisa Vladusic were in one of the rooms there and that I also worked

Page 24307

1 with them during that period of time; is that correct?

2 A. Yes, that's correct.

3 Q. Thank you. And then Krajisnik, the speaker of the Assembly, was

4 there from 10 past 2.00 until 4.15, so this same period of time. So I

5 was sharing this time while these people were there. I was receiving

6 him, too.

7 A. That's right.

8 Q. And then you can see that the others were also received -- let's

9 just take a look at this. From 17.00 onwards, Bob Djurdjevic until

10 19.15. Actually from 17.00 to 19.15. Again this overlaps part of the

11 time that the delegation from Srebrenica spent there; is that correct?

12 A. Yes, that's correct.

13 Q. So while I was receiving other people, the delegation was working

14 with other people -- or, rather, doing something else, while I was

15 walking from one visitor to another; right?

16 A. That's right.

17 Q. Thank you. We see here that Vladimir Dimitrijevic was there. Do

18 you agree that this is an eminent publisher, the owner of L'Age d'Homme

19 from Lausanne and Paris?

20 A. I remember his name and I know that he's a man from Paris, but I

21 forgot the other details. I am sorry.

22 Q. Thank you. Do you agree that it was easy to get to me and that I

23 was happy to receive people, especially people who were from the diaspora

24 and I had my picture taken with them and there were no restrictions

25 whatsoever? Would you agree with that?

Page 24308

1 A. I do agree with that.

2 Q. Thank you.

3 THE ACCUSED: [Interpretation] This was tendered in its entirety?

4 JUDGE KWON: I think so, yes.

5 MR. KARADZIC: [Interpretation]

6 Q. I would kindly ask you to assist us in explaining how, at the

7 time when you worked, documents were created, that is to say how they

8 were received and processed.

9 Am I correct in saying that a document produced after a meeting

10 or an oral or written request by an institution was typed out either by

11 you or Milijana? I signed it then, following which a copy would be kept

12 for the archives and an original copy was sent to the addressee or to the

13 encoding centre.

14 Can you explain how a document was created and processed.

15 A. When a document was ready to be sent out, it means it had been

16 typed out, signed by you or the chef de cabinet or one of the advisors.

17 Next, the document was registered in the Protocol Book and assigned a

18 specific number. Then it was sent to the addressee. If it was the

19 Main Staff, usually the documents were sent through the communications

20 centre. It also happened that if a document was for an institution which

21 was at the same location as we, then it was taken by the courier. In any

22 case, a copy was always kept in the cabinet and put in our binders in the

23 archive.

24 Q. Thank you. In your statement you discuss that, but please assist

25 us in clarifying the following: When we were in the same building with

Page 24309

1 the Assembly, was there a period when there was a common Protocol Book

2 and common archives? Does it mean that some documents from the beginning

3 of the war were kept in the joint archives?

4 A. As far as I recall, at the time when we were physically in the

5 same building with the National Assembly, all joint administrative

6 affairs were handled by the appropriate administrative office of the

7 Assembly. It was Ms. Rajka Stanisic who was in charge of the archives,

8 as well as Marina Ratkovic.

9 Q. Is it correct that from the start the bureaucratic apparatus of

10 the National Assembly was far larger in size than the presidential

11 office's staff?

12 A. That is correct. The cabinet of the republican president at the

13 time only employed a secretary and a chef de cabinet. All other general

14 administrative affairs were handled by the appropriate office of the

15 National Assembly.

16 Q. Can you recall when we separated physically from the Assembly,

17 when we went to the Famos managing building?

18 A. I know it was sometime in 1994, although I no longer recall the

19 month. In any case, it all had to do with the arrival of Mr. Dmicic as

20 chef de cabinet. Upon his arrival, he restructured the service of the

21 president of the republic and expanded it.

22 Q. Thank you. Did you learn at some point that Mr. Dmicic, who is a

23 university professor nowadays, was Deputy General -- Secretary-General of

24 the common Presidency before the elections in 1990 and we left him in

25 that position following the 1990 elections, although he was not a member

Page 24310

1 of the SDS?

2 A. Yes, I'm aware of that fact.

3 Q. Do you agree that he restructured the president's service as of

4 1994, later, based on his experience when the office of Secretary-General

5 was established as well, so his position was no longer chef de cabinet?

6 A. After the president's office service was formed, he became the

7 Secretary-General and we moved to another location.

8 Q. Do you agree that all documents that the Presidency had or were

9 sent from the president's office -- do you agree that all documents the

10 Presidency had were sent from the president's office or received by the

11 president's office?

12 A. I'm sorry, I didn't understand the question.

13 Q. Was a document created that was not sent to someone else but just

14 kept in the president's office, or were all documents either received or

15 sent?

16 A. They were all either received or sent.

17 Q. In other words, if the presidential archives went missing, could

18 such documents be found elsewhere, either as documents received by the

19 Presidency and kept -- of which a copy was kept, or that they were sent

20 from the president's office and that they kept the original?

21 A. Yes, of course.

22 Q. In your view, what size was the archive? How many binders or

23 what size of truck one would need to transport it all.

24 A. I remember that the archives were in large closets with many

25 shelves and many binders. We really tried to register and archive each

Page 24311

1 and every document. There were many binders, and I think you would need

2 quite a large truck for that.

3 Q. Thank you. Although you were on maternity leave, do you

4 remember, as you mentioned it in your amalgamated statement, that in the

5 summer of 1998, you were warned by the --

6 MS. SUTHERLAND: Your Honour.

7 JUDGE KWON: Yes, Ms. Sutherland.

8 MS. SUTHERLAND: I'd like the cite for that in the witness's

9 amalgamated statement, because I don't believe it is there.

10 JUDGE KWON: Yes.

11 THE ACCUSED: [Interpretation] That is possible. I have read

12 everything else and perhaps it was omitted from the amalgamated statement

13 by the Prosecution.

14 MR. KARADZIC: [Interpretation]

15 Q. But can the witness confirm, if indeed it is not in the

16 amalgamated statement, whether something happened in the president's

17 office in the summer of 1998 when you were advised not to enter the

18 Presidency building?

19 A. I was not on maternity leave at the time. I was still pregnant.

20 It was in August 1998. I went to work but was warned by the person who

21 was on duty at the gate of the Famos factory that some people entered the

22 presidential premises, and given the fact that I was pregnant, the man

23 advised me that it would be better for me not to go to work and to go

24 home.

25 Q. Was it not after the killing of the regional police chief at

Page 24312

1 Pale, Srdjan Knezevic, who was a celebrated fighter? He was assassinated

2 by terrorists.

3 A. Yes, that is correct. I heard that late Mauzer's men were the

4 ones who broke into the presidential premises, but I didn't go there, so

5 I didn't see anyone.

6 Q. Do you remember that after the split between Ms. Plavsic and the

7 SDS, Mauzer was appointed to a senior police position and that as the

8 head of investigating team, he came to Pale to investigate the murder of

9 the late Knezevic?

10 A. That is correct. I remember that.

11 Q. Did you hear that even witnesses were kept tied up there for a

12 week, let alone those who were suspected of having done so? Was it not a

13 terrible period of time where even witnesses suffered?

14 A. Yes. I heard that some people were tied up there, and it is

15 correct that -- that it was a very insecure, unsafe time. But I didn't

16 go there. I didn't see it. I just know that everyone talked about it.

17 It was a well-known fact.

18 Q. By that time, I no longer came to the office. I had stopped

19 coming a few months before; correct?

20 A. Yes. You were not there at the time.

21 Q. Is it correct that in late 1996 and early 1997, that is to say in

22 December and January, The Hague investigators visited Republika Srpska

23 and Pale? On both occasions, they could access the entire archives and

24 copied whatever they wanted.

25 A. I remember that. Did I not personally take part in the photocopy

Page 24313

1 process, but I do know that some of my work colleagues were included in

2 that.

3 Q. When you returned after a month or so to the office, what did you

4 find?

5 A. Do you mean in 1998 when Mauzer was there?

6 Q. Yes, yes. I was waiting for interpretation.

7 A. Yes. It was for about a month that we did not come to work. We

8 returned later, and we no longer found the archives.

9 JUDGE KWON: Yes, Ms. Sutherland.

10 MS. SUTHERLAND: Your Honour, is it the -- is it the accused's

11 position that on both occasions they could access -- that is, the OTP

12 could access the entire archives and copied whatever they wanted, because

13 we have had evidence to the contrary. Is that his position?

14 JUDGE KWON: Mr. Karadzic, by the entire archives, what did you

15 mean?

16 THE ACCUSED: [Interpretation] To my knowledge, they had access to

17 everything that was otherwise not stipulated under the law as state

18 secret. After the law on co-operation with this Tribunal was

19 promulgated, they even had access to that because the state secret

20 designation was removed from the documents. I also know that they seized

21 over 300 documents at the time. It is also a fact that the first

22 government to co-operate with this Tribunal was precisely the Government

23 of Republika Srpska.

24 JUDGE KWON: Are you satisfied with that answer, Ms. Sutherland?

25 MS. SUTHERLAND: Yes, Your Honour.

Page 24314

1 JUDGE KWON: Let's carry on. Yes.

2 THE ACCUSED: [Interpretation] Thank you.

3 MR. KARADZIC: [Interpretation]

4 Q. What was the state of the premises? Was something else missing?

5 Were the rooms empty?

6 A. I remember that the door to our office was locked. There were no

7 signs of breaking and entry, but when we got inside, the cabinets where

8 the archives were empty. I don't recall any other details. There was a

9 mess. At least not in our office -- there was a mess in other offices

10 but in ours, things seemed to be tidy save for the missing binders.

11 Q. Although the presidential archives were taken away, it seems, by

12 someone, could the copies of all documents be found in other locations?

13 A. Yes, I think so, because for the most part the documents were

14 sent to us. So the sender should have kept their copies, or in other

15 cases, we sent those documents to someone else and they should have their

16 copy as well.

17 Q. Thank you. Do you know of the existence of the international

18 committee to find out the truth about Radovan Karadzic, which was founded

19 in Belgrade, which is headed by Professor Smilja Avramov and

20 Kosta Cavoski, who is the president, and other prominent professors and

21 professionals from Belgrade?

22 A. Yes, I have heard of that organisation.

23 Q. Did you know that they published six books of my wartime orders,

24 wartime letters, interviews, and statements, as well as pardons? They

25 published it in six volumes. They published all the documents that they

Page 24315

1 could find.

2 A. Yes, I am familiar with that.

3 Q. Do you recall that the liaison person in Pale was my daughter

4 Sonja? She communicated with the cabinet and people such as Mitar Kokolj

5 and others who had some of our documents, so that the documents were

6 gathered by her and then made part of the books? She did the work, not

7 someone from the cabinet.

8 A. Yes. In any case, I didn't take part in that, so it could be

9 Sonja, although I'm not certain.

10 Q. At that time you were on maternity leave.

11 A. I was on maternity leave twice, from January 1996 and again from

12 January 1999. In both cases for a year.

13 Q. Can we have a look at 1D5040. Thank you. Is this the first book

14 from the series that contains a number of my wartime orders? And they

15 printed my signature here. It's the sail signature on all the books?

16 A. Well, that's probably the book. If I could see the contents,

17 please.

18 THE ACCUSED: [Interpretation] Can we have the next page now. Can

19 we leaf through the preface so that we get to the other documents. So

20 could we please move on from this page. Could we please leaf through the

21 book. Can we move further. This is the preface written by

22 Professor Cavoski. I think we have all of this in English too. So can

23 we finally get to the documents now. Further on, please. Thank you.

24 MR. KARADZIC: [Interpretation]

25 Q. At that point in time you were not working, but the members of

Page 24316

1 the Presidency were -- aha. This is already the 12th of May, so it's all

2 three of us. This was the constituent session of the Presidency.

3 Perhaps you don't know this but until the 12th of May, I was not on the

4 Presidency but I was selected on the 12th of May. So can we move on to

5 1993. Can we just skip 1992 altogether.

6 JUDGE KWON: Yes, Ms. Sutherland.

7 MS. SUTHERLAND: I was going to say that Mr. Karadzic should

8 refrain from his comment and put a question to the witness.

9 JUDGE KWON: Yes. Please continue, Mr. Karadzic. What is your

10 question?

11 THE ACCUSED: [Interpretation] Well, I would like us to move

12 further on from this document, to 1993, and then I'm going to put a

13 question.

14 Yes, now we have a document. Can it be enlarged, please.

15 MR. KARADZIC: [Interpretation]

16 Q. From December 1993. Is this what the documents looked like,

17 those that were created in our office or cabinet?

18 Could this please be enlarged.

19 Do you recognise the form and also the number, the registration

20 number? Can you explain this to the Trial Chamber, what it is that we

21 see here?

22 A. Yes, I do recognise this. We see the letterhead of the

23 president, and it says Republika Srpska, president of the republic,

24 Sarajevo, underneath. That's in the right-hand corner. The left-hand

25 corner shows the addressees, the Government of Republika Srpska, the GS,

Page 24317

1 that is to say, the General Staff of the Army of Republika Srpska, the

2 MUP, the Ministry of Health, and the co-ordinating body of the

3 government. Below is the number 01-400/93. That is the number from the

4 log-book where we registered all the outgoing documents from the office

5 and then the date when the document was created, that is the

6 18th of December, 1993. So that is something that reflects how we

7 worked. If I can see the signature and seal then I can be more certain.

8 Q. Let me just ask you something before we move on from this page.

9 What does this mean 01, and what does 400 mean? Does it only pertain to

10 that year?

11 A. 01 is the number that we always placed before each document that

12 left our institution; that is to say, every number would start with 01.

13 And 400 is the number from the log-book, and 1993 means that it was

14 registered in 1993.

15 Q. Thank you. 01, who does that denote? If Dmicic or an advisor

16 sent this document, would it also be 01?

17 A. Well, as a rule it would have to denote you. So I'm not quite

18 sure. I think that that is how we marked the documents signed by

19 advisors as well.

20 Q. If they wrote on my behalf; right?

21 A. Supposedly. That's the way it should be.

22 Q. Can we have the next page.

23 JUDGE KWON: For the record, we are looking at e-court page 84.

24 Yes. Please carry on, Mr. Karadzic.

25 THE ACCUSED: [Interpretation] Thank you.

Page 24318

1 MR. KARADZIC: [Interpretation]

2 Q. We have a translation of the document on the right. The number

3 is the same, 01-400/93. And on the left-hand side do you see whether

4 this is the usual -- actually, can the left side be zoomed in. Yes, the

5 Serbian version.

6 Is this something that was quite customary, my title, signature,

7 stamp? Can you explain this to the Trial Chamber? What is -- what is it

8 that makes this document a presidential documents?

9 A. Primarily your signature and the stamp on that signature which is

10 proof of the fact that that is your signature and that this document was

11 created in our institution.

12 Q. Thank you.

13 THE ACCUSED: [Interpretation] Excellencies, is it time for the

14 break now or should I go on?

15 JUDGE KWON: Yes. We'll have a break for an hour and resume at

16 1.30.

17 --- Luncheon recess taken at 12.32 p.m.

18 --- On resuming at 1.32 p.m.

19 JUDGE KWON: Yes, Mr. Tieger.

20 MR. TIEGER: Thank you, Mr. President. Could I just advise the

21 Trial Chamber that in consultation with the Registry and the Defence,

22 that we have arranged for the next witness not to be brought to the

23 Tribunal in light of today's schedule.

24 JUDGE KWON: Thank you.

25 Yes, Mr. Karadzic.

Page 24319

1 THE ACCUSED: Thank you, Excellency.

2 MR. KARADZIC: [Interpretation]

3 Q. Could you please look at the Serbian version, the last page of

4 this document. Does it look like what you would otherwise expect from

5 such a document in terms of language and format?

6 A. Yes. This is what I would expect.

7 Q. So it says "Protocol 01-400/93." It means the 400th document in

8 that year. So every year began with 01-1 -- or 01.

9 A. Yes, 01-01.

10 Q. Thank you. Can we keep leafing through the document.

11 JUDGE KWON: Yes, Ms. Sutherland.

12 MS. SUTHERLAND: Your Honour, I thought that the witness said

13 before the break that the 01 stood for the president, not for the first

14 document of the year.

15 JUDGE KWON: But she referred to the next numbers after 01-.

16 MS. SUTHERLAND: Yes. In Mr. Karadzic's question he says so

17 every year began with 01, but I --

18 JUDGE KWON: 01-01.

19 MS. SUTHERLAND: I understood the 01 in protocol 01-400/93. I

20 understood the 01 in that context was to mean it was sent from the

21 president and it was document number 400. That was my understanding of

22 her evidence before the break.

23 JUDGE KWON: Very well. Having heard your intervention, I take

24 it Mrs. Mihajlovic can explain that in clearer terms.

25 THE WITNESS: [Interpretation] The first two digits, 01, means

Page 24320

1 that the document was created in the president's office. -400 means it is

2 the document number in the Protocol Book. That is document number 400

3 for that year. Once we were in the next year, the first document

4 produced was marked as 01-01. The second 01 is the ordinal number in the

5 Protocol Book.

6 JUDGE KWON: Now is it clear, Ms. Sutherland? I think that's

7 what witness said.

8 MS. SUTHERLAND: Yes, Your Honour.

9 JUDGE KWON: Yes, Mr. Karadzic, please continue.

10 MR. KARADZIC: [Interpretation]

11 Q. What do you have to tell us about this document then in terms of

12 numbers? It seems to be the beginning of 1994, and it seems that already

13 on the 1st of January, eight documents were produced; is that correct?

14 A. Yes.

15 Q. Can we go to the next original. You can keep leafing through.

16 Can we go -- yes. Orders. Yes. Can we go one by one, the original

17 documents. Please zoom in. Not in the English language, the Serbian,

18 please.

19 Is this the 281st document that year, and it was only the

20 7th of February, 1994. Also, is the format something that you would

21 expect it to be?

22 A. Yes.

23 Q. Thank you. Keep going, please. Just the originals, please.

24 THE ACCUSED: [Interpretation] Your Excellencies, can we show

25 Ms. Mihajlovic the whole set of books so that she can identify them?

Page 24321

1 MR. KARADZIC: [Interpretation]

2 Q. Is this from May? It seems that on the 19th of May, there were

3 already 955 documents; correct?

4 A. Yes.

5 Q. We have a stamp. The protocol number seems to be correct. It

6 was signed; correct?

7 A. Yes.

8 THE ACCUSED: [Interpretation] Your Excellencies, could we ask

9 Ms. Mihajlovic to go through the books? These are collections of

10 documents created by the president's -- created by the president's office

11 and certified by either this witness or her colleague, and the documents

12 were sent to different addressees. They conclude [as interpreted]

13 wartime letters, wartime orders, et cetera. It's all in e-court, but

14 perhaps it would be easier for the witness to peruse it as such.

15 JUDGE KWON: Ms. Sutherland, do you object to the admitting of

16 this compilation or book?

17 MS. SUTHERLAND: If Your Honour can give me a moment.

18 MR. TIEGER: Mr. President, I understood at the moment the issue

19 of admission is not on the table. It's more a question of the format in

20 which the witness reviews at least certain portions of that

21 documentation. Is that not correct?

22 JUDGE KWON: But that was asked in order to tender it into

23 evidence. So I wanted to pre-empt it. If there's no objection, there's

24 no need to go through that procedure.

25 [Prosecution counsel confer]

Page 24322

1 JUDGE KWON: In the meantime, do you have it in hard copy?

2 THE ACCUSED: [Interpretation] They are all in e-court.

3 JUDGE KWON: By the way, in e-court I have only 182 pages.

4 THE ACCUSED: [Interpretation] They were scanned two-sided. All

5 six books were scanned and uploaded in e-court.

6 JUDGE KWON: Does it contain all pages of those six books?

7 THE ACCUSED: [Interpretation] Yes, absolutely.

8 JUDGE KWON: In the meantime, why don't we hand them over to the

9 witness so then she can take a look.

10 Yes, Ms. Sutherland.

11 MS. SUTHERLAND: Your Honour, this isn't a complete collection.

12 It's a selective collection.

13 JUDGE KWON: Yes, that was my point that I asked Mr. Karadzic,

14 but he said to the contrary.

15 THE ACCUSED: [Interpretation] I didn't take part in that. I was

16 already up in the mountains when my colleagues published this, whatever

17 documents could be sent to them by my daughter. It's definitely not all

18 of the documents, but we have the majority of wartime letters and a fair

19 amount of orders. I just wanted the witness to confirm that all these

20 documents were created in our office. Many of them have already been

21 admitted as individual documents.

22 JUDGE KWON: Mr. Karadzic, please be precise in answering the

23 question by the Chamber. I specifically asked you whether it contains

24 all pages of those six books. Your answer was "Yes, absolutely," and now

25 you're speaking otherwise.

Page 24323

1 Yes, Mr. Robinson.

2 MR. ROBINSON: I think that what's in e-court does contain all of

3 the pages of those books, but what he was trying to tell you is that

4 what's in those books are not all of his orders and wartime letters, but

5 everything that's in the book is in e-court.

6 JUDGE KWON: In this number.

7 MR. ROBINSON: I believe there's several numbers.

8 [Trial Chamber and Registrar confer]

9 MS. SUTHERLAND: Your Honour --

10 JUDGE KWON: Yes. I was advised just one book has only one

11 65 ter number.

12 Yes, Ms. Sutherland.

13 MS. SUTHERLAND: But what's the point Mr. Karadzic is trying to

14 make if this is only a selective version of the documents?

15 JUDGE KWON: This being what --

16 MS. SUTHERLAND: This is only a selective amount of --

17 JUDGE KWON: This being the book, the original book.

18 MS. SUTHERLAND: Yes, but they don't contain every -- every order

19 or decision that has ever been issued by him, and so what's the point

20 of -- of submitting this selective few?

21 JUDGE KWON: Do you -- is it your case that the entire --

22 compilation of entire order or documents exist?

23 MS. SUTHERLAND: Your Honour, there are documents that have been

24 issued by the president which are not included in these -- in these

25 volumes.

Page 24324

1 JUDGE KWON: Yes. So you're object to go the admission of this

2 document.

3 MS. SUTHERLAND: Well, I'm wondering what -- what the point

4 Mr. Karadzic is trying to make with the witness with these documents, by

5 tendering these selective number of documents.

6 JUDGE BAIRD: But are you saying they're inadmissible? Are you

7 saying that they're inadmissible?

8 MS. SUTHERLAND: No, I'm not saying that, Your Honour. I'm

9 simply saying that he's -- what is he trying -- what's the point that

10 he's trying to make with the witness with these volumes of documents?

11 JUDGE BAIRD: Well, he would know, presumably.

12 MS. SUTHERLAND: But if -- he's wanting the witness to say --

13 he's asked the witness: Are these all the documents that I produced?

14 Well, unless the witness sits there for a day and goes through every page

15 of every volume, she's not going to be able to confirm or deny. And even

16 then, she may not be in a position, once she's reviewed them all, to

17 answer that question he's put to her.

18 THE ACCUSED: May I intervene in language? I did not

19 pretend [sic] to say: Are those all the documents produced in our

20 cabinet? My question was: Are all of those documents produced in our

21 cabinet?

22 MS. SUTHERLAND: Again, unless the witness is given a substantial

23 amount of time to go through the volumes, she's not going to be able to

24 answer that question.

25 JUDGE KWON: Very well. We heard the submission.

Page 24325

1 Ms. Mihajlovic, do you have any observation after having looked at those

2 six books?

3 THE ACCUSED: [Interpretation] May I, before that, make a

4 suggestion? We don't have to read it all. She was just asked to look at

5 the protocol number and the stamp.

6 JUDGE KWON: I think she testified and gave evidence as to how

7 the book was compiled and published.

8 Would you like to add anything, Ms. Mihajlovic?

9 THE WITNESS: [Interpretation] What I said was that I knew that

10 such books were published and that some of my colleagues directly

11 participated in their production. I did not, however, but I am aware of

12 their existence. I leafed through book number 1 called "Wartime orders."

13 I skipped the first part because it concerns 1992, when I was not

14 employed by the president's office. However, as I keep going through

15 1993, I managed to view a few documents, and I can confirm that they were

16 positively created in our office, and the layout is what we used in our

17 work.

18 Perhaps we should choose at random. I only managed to see only a

19 small part of the first book.

20 JUDGE KWON: I noted that you wanted to say something,

21 Mr. Tieger.

22 MR. TIEGER: I don't know if I can add any clarity to this

23 discussion or not, Mr. President, but it does occur to me that the

24 discussion thus far has not clearly identified both aspects of the

25 admissibility issue or at least discussed them independently. One, of

Page 24326

1 course, is the question of authenticity. Are those documents created

2 under certain conditions, and then are they what they purport to be? And

3 the second one is relevance. There are many documents which we can deem

4 authentic under -- for various reasons under various circumstances and

5 then the question is: Do they rise to the level which would justify

6 admission in -- in this Chamber. And I think that's the issue upon which

7 Ms. Sutherland was focusing before. We have no reason at this moment to

8 challenge the authenticity of any of these documents in particular at

9 this moment, but the relevance of such a volume of documents is something

10 that might occur to us, particularly when the Prosecution has attempted

11 on other occasions to get in other statements by the accused for reasons

12 that we'd be happy to -- and have articulated at the time are relevant,

13 but those have been deferred for subsequent bar table submission. So I

14 don't want to make it more complicated, but I thought I wanted to bring

15 us back to some of the factors that I thought had guided the

16 admissibility process throughout.

17 JUDGE KWON: Can you be a bit more specific as to what you had in

18 mind by -- when you referred to the other accused's statements?

19 MR. TIEGER: Speeches on video, interviews with newspapers. In

20 my -- I mean, in those in -- in the system -- the domestic system from

21 Mr. Robinson and I come, I think would be clearly admissible when made by

22 an accused, and the question is not one of their authenticity. They're

23 often on tape. Those, in many cases, have been deferred for bar table

24 submission. Maybe that's not the most efficient way. Maybe they should

25 just be let in as we proceed, but I think in an effort to abide by the

Page 24327

1 standards that have -- we have been following as we progress, that was

2 the nature of the reference that was made, and I think part of the reason

3 why this volume of material was -- one of the comments about this volume

4 of material were made at this time. So not so much the authenticity

5 issue, which presumably this witness can illuminate to some extent, but

6 the relevance issue.

7 JUDGE KWON: Very well. The Chamber will consider the issue and

8 give its ruling in due course. In the meantime, let's proceed.

9 THE ACCUSED: [Interpretation] Thank you.

10 JUDGE KWON: Before that, can I -- can the Chamber be informed of

11 the 65 ter numbers of those six volumes.

12 THE ACCUSED: [Interpretation] Yes. 1D5040, 5041, 5042, 5043,

13 5044, 5045 inclusive. That's it.

14 JUDGE KWON: It includes not only the letters but also the

15 interviews and speeches.

16 THE ACCUSED: [Interpretation] One of the books contains public

17 appearances, speeches, et cetera. The other one deals with various

18 charitable action -- actions. One contains letters to various heads of

19 state and government, and the first book contains orders, wartime orders.

20 JUDGE KWON: Yes, Ms. Sutherland.

21 MS. SUTHERLAND: Your Honour, just with respect to your last

22 observation in relation to 65 ter number Defence 1D05045 containing the

23 interviews and speeches, the Defence can't have it both ways.

24 JUDGE KWON: Not only that, the previous version also has these

25 similar contents, interviews and speeches.

Page 24328

1 MS. SUTHERLAND: Yes, Your Honour. I mean, this witness can't

2 speak to the -- to the truth of the contents of them, but they want them

3 in for -- for all purposes, and I would submit, for example, the

4 interview with the Spanish journalist earlier today, "El Pais," which was

5 admitted for the limited purpose which I sought to -- to tender it, we do

6 have the audio. It is a recording of the accused, and that could be also

7 admitted in its entirety given that it's an interview with the accused.

8 JUDGE KWON: I --

9 MS. SUTHERLAND: [Overlapping speakers]

10 JUDGE KWON: I thought at first the books contained only orders.

11 We didn't know about the letters, interviews or speeches. Whatever the

12 result may be, if you are to tender these documents -- books through this

13 witness, you better deal with it one by one with this -- with this

14 witness, in particular the letters and interviews and speeches,

15 Mr. Karadzic.

16 MS. SUTHERLAND: Your Honour, sorry, the Prosecution wouldn't

17 object if -- if the documents that we have sought to -- to tender for the

18 limited purpose also came in for all purposes.

19 JUDGE KWON: I do not follow. Are you referring to that specific

20 interview or as a whole about this book?

21 MS. SUTHERLAND: Your Honour, I'm saying that the Prosecution

22 wouldn't object --

23 JUDGE KWON: To what?

24 MS. SUTHERLAND: To Mr. Karadzic's speeches being tendered --

25 JUDGE KWON: In its entirety.

Page 24329

1 MS. SUTHERLAND: -- if -- if the -- any interviews that

2 Mr. Karadzic gives that the Prosecution wishes to put in come in for all

3 purposes.

4 JUDGE KWON: Yes. You heard the intervention -- submission of

5 Ms. Sutherland --

6 MS. SUTHERLAND: [Overlapping speakers] I'm talking specifically

7 about the two I used this morning with the witness.

8 JUDGE KWON: I'm not clear. If those two are to be admitting,

9 you are not objecting to the admitting of those last two volumes? Is

10 that what you're saying?

11 MS. SUTHERLAND: Yes, Your Honour. I'm just saying that

12 Mr. Karadzic or Mr. Robinson objected this morning when I initially

13 sought to tendere the document --

14 JUDGE KWON: Yes, I see your point.

15 MS. SUTHERLAND: And I clarified how I was seeking to tender it.

16 JUDGE KWON: Yes, your point is taken.

17 Yes, Mr. Karadzic.

18 THE ACCUSED: [Interpretation] In relation to this, I'd like to

19 say the following: The letters and orders are documents that I can stand

20 by.

21 JUDGE KWON: Mr. Karadzic --

22 THE ACCUSED: [Interpretation] As for the interviews, I have not

23 authorised them. That's the difference. I have not authenticated the

24 interviews, and, for instance, made objections or something like that.

25 JUDGE KWON: You're not giving evidence, and what I told you, we

Page 24330

1 heard some foundation about the first volume which contains your orders

2 during the wartime. You didn't lead any evidence in relation to other

3 volumes. In order to tender them, what I said is to lead -- ask

4 questions, ask questions to this witness. That's what I said.

5 THE ACCUSED: [Interpretation] That you.

6 MR. KARADZIC: [Interpretation]

7 Q. Ms. Mihajlovic, would you please take a look -- after you've

8 looked at the orders, could you take a look at the book containing

9 letters. Are those letters also -- do they appear to be authentic, and

10 if you look at the form, have they also been produced and drafted at the

11 office -- by the office of the president?

12 JUDGE KWON: Should we upload 65 ter 5041.

13 THE WITNESS: [Interpretation] Well, I'm leafing through this

14 book, and what I can observe is that these letters do not bear signatures

15 or stamps on the basis of which I could confirm that they were indeed

16 produced by the office of the president, but what I do recall with

17 certainty is that you did send letter to many of these individuals. I

18 cannot recall the content, obviously, but I do know that you exchanged or

19 wrote to these individuals quite frequently.

20 THE ACCUSED: [Interpretation] Could we have the next page in

21 e-court so that we can take a look at one of the sample letters. This is

22 just the introduction.

23 Can we move on? These are not letters. Could we, for instance,

24 take a look at page 20, for instance.

25 MR. KARADZIC: [Interpretation]

Page 24331

1 Q. Now, here, these are not facsimile. This is retyped?

2 A. Well, yes, I can see that your signature's missing as well as the

3 stamp, but I do recall with certainty that you wrote letters to these

4 individuals very frequently.

5 Q. Thank you.

6 THE ACCUSED: [Interpretation] Now, if there is any problem with

7 these letters, can I just say that they were within my control, whereas

8 the interviews weren't, so if I hadn't authenticated them, that's how it

9 is. But the letters I can authenticate, because they were under my

10 control. And if this is acceptable, the Trial Chamber could benefit from

11 obtaining -- looking at these letters that refer to various situations.

12 JUDGE KWON: Probably the Chamber would be benefitted if it hears

13 from you, Mr. Robinson, as to this issue.

14 MR. ROBINSON: Yes. Mr. President, I advised Dr. Karadzic to

15 move on and use his time with this witness on other things, because I

16 think it's not possible to admit these globally at this point. We can do

17 that through other means, but given that this is an important witness and

18 there's other important things to cover, I think it's better for him to

19 seek to admit these documents with -- through another means.

20 JUDGE KWON: So you are not tendering those six volumes in its

21 entirety, or --

22 MR. ROBINSON: I think it would be difficult to tender all of

23 those six volumes given the fact that they contain a variety of items,

24 including interviews. So I think it's better for us to be more selective

25 and tender them at a time when we can do that and not lose some

Page 24332

1 opportunities to obtain important information from the current witness.

2 JUDGE KWON: Very well. Let's proceed. I thank you,

3 Mr. Robinson.

4 MR. KARADZIC: [Interpretation]

5 Q. Can we then have 1D5040 one more time so that you may identify

6 several other documents, and then I will move on to a new topic.

7 Could we please move towards the end of the book. Towards the

8 end. This is still 1992. Very well. Here we are.

9 Could we now see the document that I have requested. That's on

10 the next page, please.

11 Is this a standard document produced in November 1995, which

12 means that the preceding document would have been 2053?

13 A. Well, this one is 2054.

14 Q. Yes, that's correct. It's 2054. Now, could you tell us, please,

15 what kind of stamp is this that we see on the top of the page?

16 A. Well, if we can just zoom in on that part only, please.

17 Q. What is the handwriting that we see there? What does that mean,

18 and what is the significance of this? It says "Delivered --"

19 A. Yes, now I recall. This means that this document was sent to the

20 Main Staff of VRS via the communications centre. It means that somebody

21 took this document to the communications centre and it is probably there

22 that this document was stamped in this manner.

23 Q. And it was received there at 19.20, and it was then delivered at

24 20.45.

25 A. Yes. They received it at 19.20, and they forwarded it onward at

Page 24333

1 20.40.

2 Q. Thank you. Could we see the next page, please. This is after

3 the signing of the Dayton Accords. It's one of the orders. The content

4 is irrelevant, just the format. Let's take a look at the form of this

5 letter.

6 This, too, is a standard form, isn't it?

7 A. Yes, that's correct.

8 Q. Thank you. Now I would request P -- or, rather, 1D2739. Please

9 take a look at this document. Was this document produced at our office?

10 This is not an order. Rather, it is decision on -- a decision on a

11 pardon.

12 I don't think this document has been admitted, or has it?

13 Is this a decision on pardoning the individuals mentioned below?

14 If you look at the names, would you agree that all of these individuals

15 were -- are Muslims, and it says they're from Prijedor and Sanski Most?

16 A. Yes. The names are Muslim names.

17 Q. Was this drafted in our office? In the preamble it says,

18 "Pursuant to the constitution and the legal basis," and so on, and then

19 it's a decision. Was this produced at our office?

20 A. Well, very frequently when the document in question was a

21 decision, then the date would be at the bottom of the page. That was the

22 form. But I believe that this document was -- as we can see in

23 Article 2, it was published in the Official Gazette of Republika Srpska.

24 Q. Thank you.

25 THE ACCUSED: [Interpretation] I'd like to tender this document,

Page 24334

1 please.

2 JUDGE KWON: Does the number at the bottom of the page refer to

3 the fact that it was produced by the president's office, number 01-562?

4 THE WITNESS: [Interpretation] Yes, yes.

5 JUDGE KWON: Very well, this will be admitted.

6 THE REGISTRAR: Exhibit 4362.

7 THE ACCUSED: [Interpretation] Could we please keep on the

8 left-hand side the Serbian version. And now I would like to call up

9 5039. And can we just keep on the screen the Serbian version, please?

10 1D2739. I'm sorry, P3039. It's Prosecution Exhibit P3039. Yes, that's

11 it.

12 MR. KARADZIC: [Interpretation]

13 Q. Would you please take a look at the heading and protocol. What

14 can you tell us about this when you compare them to the documents

15 produced at the office the president?

16 A. This document was not produced at the cabinet -- at the office of

17 the president. I'm sure of that.

18 Q. This is a document from the end of 1993, and then we see that for

19 the entire year the number is 02 -- 2 and then -934; correct?

20 A. Yes, that's correct, but this is not our document.

21 Q. Thank you. Can we have the next page, please. The Serbian

22 version, the last page.

23 Could you please read out who drafted this document, who typed it

24 up, and --

25 JUDGE KWON: This is -- the page we are seeing on left side is a

Page 24335

1 different one, isn't it?

2 THE ACCUSED: [Interpretation] Yes. On the left-hand side we are

3 showing the form of a document sent from the office of the president, and

4 now we would like to show what a document that wasn't produced at the

5 office of the president looks like.

6 JUDGE KWON: Thank you.

7 THE WITNESS: [Interpretation] This document was definitely not

8 produced at the office of the president of the republic. It is obvious

9 due to several reasons. First of all, your position, the supreme

10 commander. We never signed your name that way. Also, the note that says

11 that it was typewritten in a single copy. That's strange, because I've

12 already said, we always had several copies. One was went to the

13 addressee and another stayed in the archives. So there was never a

14 single copy only.

15 Thirdly, the full stop after DR. And also the fact that the

16 document was typewritten in the Roman script. We always did our typing

17 in Cyrillic. That is something that I noticed, and that is why I believe

18 this document was definitely not created in the office of the republic.

19 THE INTERPRETER: Interpreter's note: We did not hear the

20 question.

21 THE WITNESS: [Interpretation] Yes.

22 JUDGE KWON: Because of the overlapping, the interpreters

23 couldn't hear you. Would you repeat your question, Mr. Karadzic.

24 MR. KARADZIC: [Interpretation]

25 Q. So the elements that indicate creation were not created in the

Page 24336

1 office, but somebody brought this and got the signature he wanted and the

2 stamp.

3 A. Yes. This is your signature and stamp.

4 Q. However, there is no copy in the Presidency, because they did

5 not -- it was in a single copy.

6 A. Yes, that's right.

7 THE INTERPRETER: The interpret did not hear the question.

8 JUDGE KWON: Could you repeat what you just said.

9 MR. KARADZIC: [Interpretation]

10 Q. P838. It's a Prosecution exhibit, 838. Thank you. Please take

11 a look at the letterhead here as well, the protocol involved, and

12 everything that has to do with the creation and the origin of the

13 document.

14 A. Could this be enlarged, please? This document was not created in

15 the president's office either. The letterhead is not right, and the

16 number of the register is not right.

17 Q. Thank you. This is directive for further operations number 7

18 that is rather well known in this trial and in this courtroom.

19 Can we have the last page now. Could the lower part please be

20 zoomed in so the witness can see it properly.

21 What is your conclusion on the basis of the end of this document?

22 A. Yet again, this is not the office that we put on the documents

23 that we generated. And number two, the stamp is not the stamp of the

24 president of the republic but, rather, of the Main Staff of the

25 Army of Republika Srpska.

Page 24337

1 Q. Thank you. Can we zoom in on the stamp, because in the

2 translation there is no reference to the contents. And could you please

3 read out what it says on the stamp?

4 A. It says the "Main Staff of the Army of Republika Srpska."

5 Q. In this documents, it's not only that it wasn't created in the

6 Presidency, but it wasn't even brought to the Presidency for signing and

7 stamping.

8 A. We may conclude that because it bears the stamp of the

9 Main Staff.

10 Q. Thank you. So much for directives 6 and 7.

11 Now I'd like to ask for 1D --

12 JUDGE KWON: Ms. Mihajlovic, how about the signature? Is it

13 Mr. Karadzic's?

14 THE WITNESS: [Interpretation] Yes. I could say with certainty

15 that it is his signature.

16 JUDGE KWON: Yes. Please continue.

17 MR. KARADZIC: [Interpretation]

18 Q. Thank you. Can we take a look at the top of the page. How many

19 pages are there?

20 JUDGE KWON: Yes, Ms. Sutherland. Was it because of that that

21 you rose?

22 MS. SUTHERLAND: Yes, Your Honour.

23 JUDGE KWON: Thank you. Yes, let's continue.

24 THE ACCUSED: [Interpretation] It seems that the pages are not

25 numbered. Can someone help us with the number of pages that this

Page 24338

1 document has?

2 JUDGE KWON: I think it's about 24, but probably including the

3 cover letter or -- it's 21 pages, if I'm correct.

4 Ms. Sutherland?

5 THE ACCUSED: [Interpretation] If we see the penultimate page in

6 Serbian, we'll be able to tell.

7 JUDGE KWON: Page 20 or -- or page 19. There are blank pages

8 every other page. Its format is very strange.

9 Yes, Ms. Sutherland.

10 MS. SUTHERLAND: Your Honour, it's a matter of re-scanning, if

11 it's done from back to front.

12 JUDGE KWON: Uh-huh.

13 THE ACCUSED: [Interpretation] So there are 10 or 11 pages.

14 Eleven pages, can we agree on that?

15 MS. SUTHERLAND: Eleven pages in the B/C/S.

16 THE ACCUSED: [Interpretation] Thank you.

17 MR. KARADZIC: [Interpretation]

18 Q. In view of the time that you spent in the office and the fact

19 that you're familiar with my habits, would you agree that I signed

20 shorter documents without reading them, let alone a long document like

21 this if the documents were prepared by one of my collaborators?

22 A. Yes, very often.

23 Q. Thank you. On the assumption that this is really my signature,

24 that it was signed, rather, would you agree that it had to be signed

25 somewhere else, not in the office or cabinet itself, because there would

Page 24339

1 have been a stamp had it been signed in the office?

2 A. That is certainly the way it would have been done had it been

3 done at the office of the president of the republic. It would have borne

4 the stamp of the president the republic.

5 THE ACCUSED: [Interpretation] I see Madam Sutherland.

6 MS. SUTHERLAND: Your Honour, can Mr. Karadzic put his case in

7 relation to this document? Did he sign -- he has said -- he's put it to

8 this witness that he didn't sign this document. Is that his case, that

9 he didn't sign directive 7?

10 JUDGE KWON: Yes, Mr. Robinson.

11 MR. ROBINSON: Mr. President, I don't think that Dr. Karadzic has

12 put his case to this witness in that way, but it's not -- when and if he

13 gives evidence, he can give that answer, but it's his case. It's simply

14 to elicit from the witness the nature of the document, including the

15 signature, the stamps, and the other things. So he's not required to

16 give in the middle of the trial his evidence or his position as to a

17 particular piece of evidence. You've heard the answers from the witness,

18 and we'll each be able to argue what you should conclude from that at the

19 end of the case.

20 MS. SUTHERLAND: Your Honour, under Rule 90(H) he has to put his

21 case. This is a matter that's disputed between the parties, and he has

22 to put his case to the witness. The witness has said that it's his

23 signature.

24 MR. ROBINSON: And he's not seeking to impeach the witness on

25 that answer at all.

Page 24340

1 [Trial Chamber confers]

2 JUDGE KWON: Mr. Robinson, you referred to the impeachment of

3 the -- or cross-examination, but here how do you read Rule 90(H)(ii):

4 "In the cross-examination of a witness who is able to give

5 evidence relevant to the case for the cross-examining party, counsel

6 shall put to that witness the nature of the case of the party for whom

7 that counsel appears, which is in contradiction of the evidence given by

8 the witness"?

9 So your case is that she never gave contradictory evidence so

10 far.

11 MR. ROBINSON: That's correct.

12 JUDGE KWON: And it is not now that he should give his case at

13 the moment.

14 MR. ROBINSON: That's correct.

15 JUDGE KWON: Ms. Sutherland, would you like to respond?

16 MS. SUTHERLAND: Yes, Your Honour. The witness was asked by

17 Your Honour how about the signature, "Is it Mr. Karadzic's?" And she

18 said, "Yes, I can say with certainty that it is his signature."

19 Now, if it's Mr. Karadzic's case that it's not his signature,

20 then he has to put it to her that it's not his signature and he didn't

21 sign it.

22 JUDGE KWON: Was he not asking where it was possibly signed?

23 MS. SUTHERLAND: No, Your Honour. He says:

24 "Q. In this document, and it's not only that it wasn't created

25 in the Presidency, but it wasn't even brought to the Presidency for

Page 24341

1 signing and stamping."

2 JUDGE KWON: Yes, Mr. Karadzic, but you said on the assumption

3 that this is really my signature. Rather, would you agree that it had to

4 be signed somewhere else, not in the office of the cabinet itself.

5 Because that was asked after having heard from the witness that it was

6 your signature.

7 Then I think, to that extent, Ms. Sutherland has a point. If you

8 have to challenge that it was not your signature then you have to put

9 your case.

10 MR. ROBINSON: Well --

11 JUDGE KWON: Yes.

12 MR. ROBINSON: If we were challenging that it was not his

13 signature, then we would put our case.

14 JUDGE KWON: So it is your case that it is not Mr. Karadzic's

15 signature?

16 MR. ROBINSON: No, that's not our case, and --

17 JUDGE KWON: Not your case. I misunderstood. Thank you. That

18 clarifies everything.

19 Yes, please continue.

20 THE ACCUSED: [Interpretation] Maybe all this confusion was

21 created by the interjected phrase, the phrase that I interjected. Even

22 if I did sign this elsewhere, we can disregard all of that together. My

23 question to the witness is as follows:

24 MR. KARADZIC: [Interpretation]

25 Q. Was this signed at the cabinet? The directive number 6 was

Page 24342

1 probably signed at the cabinet and has the stamp of the office of the

2 Presidency. So that's the only difference between directives 6 and 7,

3 where it was signed, but both documents were created elsewhere. Would

4 you agree with that, Witness?

5 A. Yes, I agree that this document was not signed in the cabinet.

6 Q. Thank you. Now I would like to ask for 1D5037. Can you tell us

7 now what the difference is between these two certifications?

8 A. The first difference is in the name of the office you hold. We

9 would usually write down the office that is on the left-hand side, that

10 is to say, "President of the republic and the supreme commander of the

11 Army of Republika Srpska." However, we did not always add "supreme

12 commander." We always put "president of the republic," but sometimes we

13 also did say "and supreme commander of the Army of Republika Srpska."

14 On the right-hand side is "The office of supreme commander." We

15 certainly did not do this at our office. That is not the way that we

16 would refer to the office you held. That is not the office that you held

17 that we placed above your signature. Also, there's a difference

18 involving the stamp. On the left-hand side is the president of the

19 republic, and on the right-hand side is the stamp of the Main Staff of

20 the Army of Republika Srpska.

21 THE ACCUSED: [Interpretation] Thank you. Can this be admitted?

22 JUDGE KWON: But you need to tell us the origin of these stamps.

23 Where did you collect them?

24 MS. SUTHERLAND: [Overlapping speakers]

25 Yes, Ms. Sutherland, was that your point?

Page 24343

1 MS. SUTHERLAND: [Overlapping speakers]

2 JUDGE KWON: I take it the right one is from directive 7, and the

3 left one comes from where, Mr. Karadzic?

4 THE ACCUSED: [Interpretation] Any document. It's from any

5 document. It's typical. But if it's of assistance, 1D5036. Can we call

6 that up. Thank you.

7 MR. KARADZIC: [Interpretation]

8 Q. Do you agree, Mrs. Mihajlovic, that in the corner on the left

9 there is the letterhead and the end of directive number 6, and on the

10 right-hand side the same, the end of number -- directive number 7 and

11 that all the other stamps are from any document that was created in our

12 office?

13 A. Could it be enlarged a bit more, please.

14 THE ACCUSED: [Interpretation] Can you zoom in, please.

15 MR. KARADZIC: [Interpretation]

16 Q. Here where it says directive 6 and directive 7, those are not our

17 log-book numbers; correct?

18 A. Yes. That's what I was going to say. Neither the heading where

19 it says "Supreme Command of the armed forces of Republika Srpska," nor

20 the protocol number are ours. They certainly were not produced at the

21 office of the Presidency. And then the signature and the title, as I've

22 already said, the supreme commander is not the title that we usually used

23 at the office of the president when we put your name as the undersigned

24 of a document, and also the stamp is not -- it's a stamp from the

25 Main Staff. It's not from our cabinet. And I think in a document which

Page 24344

1 says directive 6, there is a dot after doctor, and it's also in the Latin

2 script which definitely means that it wasn't at the -- it wasn't produced

3 at the office of the president. And also after Dr, doctor, we do not put

4 a dot. That's not proper in Serbian.

5 Q. Well, it is proper if you're half literate, correct,

6 semi-literate?

7 Now, the two that were not produce by the Presidency, what do

8 they refer to?

9 JUDGE KWON: Before you answer, yes, Ms. Sutherland.

10 MS. SUTHERLAND: Your Honour, the witness cannot answer that

11 question from the document that she's got in front of her. Mr. Karadzic

12 took her earlier to directive 6 and directive 7 separately. And if he --

13 JUDGE KWON: But in the previous document 1D5037, the witness

14 said that the left stamp and the format were consistent with other --

15 Mr. Karadzic's signature at the time, didn't she?

16 MS. SUTHERLAND: Yes, Your Honour.

17 JUDGE KWON: So on that basis we have a basis to admit that

18 document, don't we?

19 MS. SUTHERLAND: Your Honour, these -- these are simply cutting

20 and pasting from the top of the documents and the bottom of the

21 documents, and are identified as directive 6 and directive 7.

22 JUDGE KWON: For convenience of comparison, I'm referring to the

23 previous document, 1D5037. Do you object to admitting this document?

24 MS. SUTHERLAND: No, Your Honour, but -- but what I'm saying is

25 the witness has been taken to the full documents of directive 6 and

Page 24345

1 directive 7 --

2 JUDGE KWON: Yes.

3 MS. SUTHERLAND: -- and, rather, those are admitted documents

4 rather than admitting this piece of paper which purports to be the stamps

5 from those two documents. You actually have those two documents that you

6 can look at.

7 JUDGE KWON: Those -- directive 6 and directive 7 were already

8 admitted, weren't they? Those two have P number already.

9 THE ACCUSED: [Interpretation] That's correct.

10 MS. SUTHERLAND: Yes, Your Honour, I will get Mr. Reid to give

11 them to me.

12 JUDGE KWON: Yes, they were admitted, yes. And then this 1D5037

13 will be a convenient tool to compare the signature part. So on that

14 basis we can admit this.

15 Yes, this will be admitted as the next Defence Exhibit.

16 THE REGISTRAR: D2057, Your Honours.

17 JUDGE KWON: Yes, carry on, Mr. Karadzic.

18 THE ACCUSED: [Interpretation] Thank you.

19 MR. KARADZIC: [Interpretation]

20 Q. Now, in view of the charges and the indictment where it is

21 claimed that we were intolerant of other ethnicity as well as that we

22 were insensitive to the suffering of civilians, wherever they were --

23 they came from, including our own, I would like to ask you this: What

24 was the position, not only my personal position but also our entire

25 office as well as the entire official part of Republika Srpska, what was

Page 24346

1 our position and our attitude towards Muslims and Croats, as far as you

2 know?

3 A. As far as I know, and I can only speak about myself and about

4 you, as far as I know, you were not in any way intolerant of other

5 ethnicities. You never displayed any such position. I, at least, never

6 witnessed that. On the contrary, I am aware of the fact that among the

7 closest of your associates, including your counsellors, there were people

8 of other ethnicities or people who came from mixed marriages or who

9 were -- or who were themselves in mixed marriages. In other words,

10 married to people of other ethnicities. So one could absolutely not say

11 that you were intolerant of other ethnicities. As for others, I really

12 couldn't speak about them.

13 Q. Thank you. But do you agree with me that a Catholic church

14 remained standing in downtown Pale, that my hairdresser was a Croatian

15 woman, that there was no -- not a trace of intolerance in respect of

16 those people?

17 A. Well, yes, that's correct. The Catholic church remains at Pale

18 to this day. I live there. And I do recall your hairdresser, and I know

19 that she was a Croatian and I know because we frequently made reference

20 to that fact.

21 Q. Thank you. You probably had occasion to see and type up a lot of

22 documents produced or sent on my behalf where I intervened on the matter

23 of humanitarian aid and humanitarian issues. Do you recall that the

24 vice-president -- Vice-president Koljevic, who was a very respectable

25 man, the second person in the republic was actually appointed to the post

Page 24347

1 of commissioner for humanitarian matters?

2 A. Yes, I agree.

3 Q. Do you agree it was necessary for me to strengthen this role of

4 his and that I sent orders to the effect that humanitarian convoys should

5 be allowed through and similar? And do you recall that there were a lot

6 of documents to that affect that were sent out from the office because

7 there were many humanitarian convoys that were -- for some reason that

8 were stopped or it was difficult for them to move on?

9 A. Yes. And I do recall now that I saw a document just a moment

10 ago, and there was your signature at the end of it, and I recall that you

11 frequently intervened, and you frequently called on people to be careful

12 and abide by the Geneva Conventions and the -- and to be careful about

13 how they treated prisoners, and I know that you frequently intervened,

14 and I know that sometimes you would get really upset about those

15 instances where there were violations of your orders.

16 Q. Thank you. Now, do you agree with me that this was too much for

17 me, for my office, so I nominated for this high position the

18 vice-president, Mr. Koljevic, and as you recall, I was really very busy

19 with work day and night, almost like 24-hour stores?

20 A. Well, yes, I remember that, and we can see that from the times

21 indicated at the -- at some of those documents we saw.

22 Q. Thank you. Now, do you remember that mention was made when the

23 Srebrenica was issue was discussed? Well, I won't ask you about 1993.

24 Let me ask you about 1995. Did you ever hear or learn about the

25 developments in Srebrenica -- or, rather, when was the first time that

Page 24348

1 you heard of these developments?

2 A. As far as I can recall, I heard about this incident from the

3 media, and I am absolutely certain that I did not discuss this either

4 with you or any other of your aides, and at first, to be honest, I didn't

5 really believe what was reported in the media because the media

6 frequently misrepresented or broadcast incorrect information but that's

7 how I heard of it.

8 Q. Was the position at the office of the president that this was

9 not -- actually, was the situation in the president's office such that

10 this was not really discussed or at least wasn't a topic of discussion

11 for a long time?

12 A. Well, as far as I can recall, we did not discuss this. Well,

13 especially I recall this because at the time I was pregnant and I was

14 really quite absorbed by other things. I was focused on other matters,

15 so I didn't really pay attention to information that I at the time

16 considered incorrect.

17 Q. May I just ask you something about the amalgamated statement

18 where you were asked about me, what kind of person I was, whether I had a

19 tendency to yell at people. I don't know if it was in this statement or

20 in the amalgamated statement, but would you tell the Trial Chamber what

21 you know about me, not only what your opinion is about me but also the

22 things that you know about me being a -- an educated, an intellectual

23 person. So tell the Trial Chamber who was I. What kind of person was I

24 as a president, as a human being, and a boss?

25 A. Well, first of all, I can say that our relationship was purely

Page 24349

1 professional. You were very kind and very respectful with all your

2 assistants, not only your assistants but also all employees, including

3 the lowliest, or, including the cleaning ladies and the waiters and so

4 on. And I can say that everyone there respected you.

5 You were not a person given to yelling. Perhaps there were times

6 when you angry if people failed to carry out their duties, but I know for

7 sure that you never raised your voice to me.

8 What else can I say? Well, I think you were very dedicated to

9 your family, which was something that really appealed to me. And I don't

10 know if this is sufficient, and quite certainly my opinion is very

11 positive, and I believe that it's a great pleasure -- I believe it would

12 be a great pleasure for anyone to have that kind of boss. You were a

13 very good boss. And as the president, you were not a person who tried

14 to impose your authority, rather, you tried to lead and be -- work with

15 your employees in a democratic way.

16 Q. Thank you. That is very flattering. Thank you very much for

17 your effort and for coming here to testify. I would like to wish you a

18 pleasant stay here and a safe trip home, and, please, all the best to

19 your family and your two daughter who were born once I fled into the

20 hills.

21 A. And thank you very much, and all the best to you too.

22 THE ACCUSED: [Interpretation] I have no further questions.

23 JUDGE KWON: Yes, Ms. Sutherland.

24 MS. SUTHERLAND: Your Honour, I would ask that the witness leave

25 the courtroom for a short time. I wish to make a submission to you in