Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14925

 1                           Monday, 20 June 2011

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 9.02 a.m.

 6             JUDGE KWON:  Good morning, everyone.

 7             Good morning, Ms. Hanson.

 8             THE WITNESS:  Good morning, Your Honour.

 9             JUDGE KWON:  I hope you had a good weekend.

10             THE WITNESS:  Thank you.

11             JUDGE KWON:  At the end of Friday's hearing, Mr. Karadzic asked

12     to be allowed to further re-examine Ms. Hanson, in light of the

13     Prosecution's re-examination in relation to the formation of the agencies

14     and operation of them for the movement of population.

15             The Chamber notes that the Prosecution, during re-examination,

16     indeed, introduced new evidence regarding the existence and operation of

17     crisis staffs and the agencies for the movement of population.  However,

18     this seems to have been triggered by the habit of unnecessary comments

19     made by Mr. Karadzic on 14th of June, 2011, at transcript page 14641,

20     regarding the implementation of population movement measures by these

21     agencies, as Ms. Sutherland did, we took it to mean that such agencies

22     actually were not established or were not in operation.

23             The Chamber therefore considers that Mr. Karadzic can ask

24     questions of Ms. Hanson in further re-examination, but only to the extent

25     that they pertain to the existence and operation of the crisis

Page 14926

 1     staffs/agencies for the movement of population.

 2             Yes, Mr. Karadzic.

 3             THE ACCUSED: [Interpretation] Thank you very much.

 4             Can we look at P2723.

 5                           WITNESS:  DOROTHEA HANSON [Resumed]

 6                           Further cross-examination by Mr. Karadzic:

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Ms. Hanson, my question is this:  The agencies, did they issue

 9     any kind of certificate or did they certify agreements on the exchange of

10     property?

11        A.   Yes, I've seen certificates issued by these agencies.  I believe

12     I -- I note that in my report -- I don't have a copy of my report this

13     morning.  I don't know if it's possible.

14             JUDGE KWON:  It's coming.  Thank you, Ms. Sutherland.

15             MR. KARADZIC: [Interpretation]

16        Q.   And who was it that exchanged the property?

17        A.   I haven't seen many certificates of property exchange.  What I

18     have seen are people signing certificates to the -- to these committees

19     that they are leaving voluntarily and that they are voluntarily donating

20     their property to the municipality.  As for the actual exchange, this

21     one, yes, that we saw before, it says two people here, someone from

22     Zagreb and someone from Banja Luka, exchanging apartments, is the example

23     we have now.  But I haven't seen as many of these as I have of the people

24     simply signing their property over without an exchange.

25        Q.   We're talking about exchanges now.  The agencies are for the

Page 14927

 1     purpose of property exchange, so among whom was the property exchanged?

 2        A.   In this document, it's Bosiljka Njenjic from Zagreb exchanging

 3     with Fetah Kotari [phoen] from Banja Luka.  In general, it was non-Serbs

 4     leaving and Serbs moving in, is my understanding of the general patterns.

 5     As I say, I haven't seen a lot of the exchange certificates.

 6        Q.   Which Serbs?

 7        A.   In this case, it appears to be a Serb from Zagreb, Croatia.  As I

 8     say, I haven't seen enough to claim a pattern, but, in general, Serbs

 9     from elsewhere who are moving into the territory of Republika Srpska, is

10     my understanding.  And if they're exchanging, then obviously it's someone

11     who is moving out of Republika Srpska is exchanging with someone who's

12     moving in.

13        Q.   Thank you.  Well, let's just agree on our terms.  Did these Serbs

14     flee?  Are they refugees from these Muslim locations that are offering

15     their property for exchange?  Are they people who voluntarily left?

16        A.   I don't know enough.  I imagine it's both.  I imagine it's --

17     some are refugees from fighting, some are people who would rather live in

18     Republika Srpska.  In this case, it's someone from Zagreb, where there

19     was no actual fighting, but apparently she preferred to live in

20     Banja Luka than Zagreb for whatever reasons.  I haven't seen enough to

21     say -- I certainly don't know the individual's circumstances.

22        Q.   Thank you.  Why would somebody give away their property when

23     there is an agency through which they can exchange the property?  You

24     keep saying that the property was given away.  Do you know that on the

25     19th of August, 1992, I cancelled all of those decisions and that none of

Page 14928

 1     them was actually implemented?

 2        A.   You said earlier -- last week, you said that you had cancelled

 3     those decisions.  I was not aware of it then.  You said it now, so I now

 4     know that you say that.  I haven't seen a -- I don't -- if I saw such a

 5     declaration, I certainly would have changed -- well, I wouldn't have

 6     changed my idea of how much those declarations were signed under free

 7     will or not.  I don't -- the reason why someone would sign such a

 8     declaration, give away their property, rather than exchange it, I believe

 9     they were moving out in such numbers, under considerable pressure to

10     leave, that they felt the only way they could leave was to sign those

11     certificates, but that is going beyond the scope of what I can actually

12     show in this report.  But I've seen many more, as I say, certificates

13     donating property, supposedly voluntarily, than I have exchanges, and

14     I've seen departures in such numbers that exchanges could not possibly be

15     arranged for everyone.

16        Q.   Ms. Hanson, were you stating the opinion on the influence of the

17     central organs of power upon the crisis staffs?  And if you did, why

18     didn't you look at my decision of the 19th of August, in which I forbid

19     such acts and cancel all of them that were signed before that date?  It's

20     a very important document.  You don't have it, and you say you wouldn't

21     change your opinion, regardless of new facts appearing?

22             JUDGE KWON:  Before you answer:  Yes, Ms. Sutherland.

23             MS. SUTHERLAND:  Ms. Karadzic raised this with Ms. Hanson earlier

24     in his cross-examination, and he could have followed up with this

25     question when he was dealing with the topic then.

Page 14929

 1             JUDGE KWON:  Yes, I tend to agree, but I consult my colleagues.

 2                           [Trial Chamber confers]

 3             JUDGE KWON:  Your re-cross-examination is limited to what is new

 4     in her evidence adduced during the re-examination, so move on to another

 5     topic.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             Can we look at P2725 now, please.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   You said that those who wanted to leave had to pay transport

10     costs; is that correct?

11        A.   We saw that in one document that was shown in the redirect, and I

12     have seen others.  I don't -- some of the agencies, yes, demanded a fee

13     for the -- even for signing the certificates.

14             Yes, this is the document that here I noted they had to pay a

15     fee.

16        Q.   Madam, this notice of where people are assembling and where they

17     will be departing from, are you calling that the forcible transfer of the

18     population?  It states:

19             "All passengers travelling on the convoy ..."

20             And the time is announced where, and the account is stated where

21     the money is to be paid.  Does this amount to forcible transfer of the

22     population?

23        A.   This document, itself, does not.  Taken in totality with the

24     documents and other information on the movement of population, this is

25     certainly consistent with the stories we know of forcible transfer.  This

Page 14930

 1     document, on its face, doesn't indicate one way or another.  It does

 2     indicate the operations of this Agency for Population Movement, which is

 3     why, I believe, the Prosecution brought it to my attention.

 4        Q.   Thank you.  And what happened to those who did not pay for the

 5     ticket?  Did you investigate that?

 6        A.   This document was not one I looked at for my report, so I imagine

 7     in this case they didn't leave.  But I can't do more than speculate on

 8     that.

 9        Q.   Those who did not pay for their ticket stayed and lived where

10     they lived, and then we saw in Kotor Varos that money is being returned,

11     even those who didn't take the bus.

12             MS. SUTHERLAND:  Is that a comment or a question?

13             THE ACCUSED: [Interpretation] It's a question.

14             MR. KARADZIC: [Interpretation]

15        Q.   Is it correct that those who did not pay did not come to the bus,

16     and those who paid and did not come to the bus, their money was refunded,

17     as we saw in the case of Kotor Varos?

18        A.   I can't know, on the basis of the documents I've seen, what

19     exactly happened to those people, certainly not throughout the various

20     municipalities.  You did show me a document that said those who are not

21     leaving will have their money refunded in Kotor Varos.  Certainly, if

22     this convoy is being organised from Banja Luka, there were non-Serbs in

23     Banja Luka into 1993, so not everybody -- not all the non-Serbs left in

24     1992 from Banja Luka.  But what happened to everybody, that's far beyond

25     the scope of my report.

Page 14931

 1        Q.   Madam, you will agree that in some cases, the municipalities

 2     asked for documents, among whom Banja Luka was the most liberal

 3     municipality, asking for just three documents.  Some municipalities asked

 4     for as many as 10 documents in order for people to be able to leave.

 5     Does that sound reasonable to you, to ask for so many papers to be able

 6     to approve your departure?  Does that sound like somebody was voluntarily

 7     departing or forcibly departing?

 8        A.   Asking for 10 documents in order to leave does not sound like

 9     simple rounding up and pushing them out.  Of course, it sounds much more

10     bureaucratic, more organised.  But I don't know which municipalities

11     you're talking about, if you're familiar which ones only needed three,

12     which ones needed ten for departure.

13             The voluntariness -- the voluntariness of their departure, this

14     is one of those awkward places in my report where when I'm relying on

15     only the documents of the crisis staffs, themselves, or their

16     certificates, it is described as voluntary.  I hope that there will be

17     other evidence from other people that gives -- will explain to the Judges

18     why I put "voluntary" in quotation marks.  I think it's the totality of

19     the events in the summer of 1992 that explains why these people departed.

20     Once again, I cite Krupa as saying, Either you do it yourselves or we'll

21     do it by military means.

22             We see lots of evidence of the desire to be rid of non-Serbs in

23     order to hold Serbian power in the territories claimed by the RS.  We see

24     Rajko Dukic in the assembly saying, I hope we've gotten rid of 60.000

25     Muslims from Birac.  There is so much evidence as to the voluntary nature

Page 14932

 1     of the departure that I -- or the lack of free will in these situations,

 2     but I note that using the documents of the crisis staffs, themselves, it

 3     is described as voluntary.

 4        Q.   Madam, do you differentiate between free debate among the

 5     deputies and the documents that are the product of an Assembly session?

 6     Do you find that there is a link between an address by a deputy and what

 7     ends up in the Assembly documents?  Did you find any documents that would

 8     support what you are saying?

 9        A.   Well, as I pointed out, we have Vjestica at the 12th of May

10     session saying he's heard the happy news, that the Una will be the border

11     and he doesn't think the Muslims will come back.  Following that, we see

12     the War Presidency of Bosanska Krupa suggesting to the army that it

13     destroy property because -- and expel the Muslims because of the

14     strategic decision that the Una would be the border of Republika Srpska,

15     so there I find a connection.

16        Q.   And did you show that document for those purposes?  Do you have

17     the document saying that there is demolition underway to prevent them

18     from returning?  More precisely, Ms. Hanson, do you know that those

19     buildings that are abandoned can be used by the enemy army for waging

20     war?

21        A.   I did show the document to which I refer.  It was part of my

22     examination-in-chief, I believe.

23             JUDGE KWON:  Mr. Karadzic, I think you almost exhausted the

24     topic.  Do you have more questions?

25             THE ACCUSED: [Interpretation] Well, let us now move to what

Page 14933

 1     Ms. Hanson mentioned now.

 2             Can we have P2737 to see what was going on in Krupa.

 3             MS. SUTHERLAND:  Your Honour, that --

 4             JUDGE KWON:  Yes, Ms. Sutherland.

 5             MS. SUTHERLAND:  That was on a topic which was straying from what

 6     Mr. Karadzic is actually allowed to further cross-examine Ms. Hanson on.

 7             JUDGE KWON:  Can I see what 2737 is first?

 8             THE ACCUSED:  [No interpretation]

 9             JUDGE KWON:  Mr. Karadzic, this is not related to the document

10     for the Agency for Movement Population.

11             THE ACCUSED: [Interpretation] This document was introduced by

12     Madam Sutherland during the redirect, and I didn't have the opportunity

13     to ask the witness to look at this explanation and present it to the

14     Trial Chamber.  Now I will continue to --

15             JUDGE KWON:  You haven't explained to the Chamber why this

16     amounted to new evidence.

17             MR. KARADZIC: [Interpretation]

18        Q.   Ms. Hanson --

19             JUDGE KWON:  No.  Before you ask the question to Ms. Hanson, you

20     have to explain to us why this arose from the re-examination by

21     Ms. Sutherland which amounted to new evidence.

22             THE ACCUSED: [Interpretation] This was admitted in the redirect

23     as evidence that I did not properly present matters, but what we have

24     here is lack of knowledge about the locality.  This is completely

25     legitimate.  I --

Page 14934

 1             JUDGE KWON:  The fact that a certain document was admitted during

 2     re-examination does not necessarily mean the Defence is given another

 3     opportunity to further cross-examine that evidence.  You could have

 4     covered this kind of line of questioning during your cross-examination.

 5             I'll consult my colleagues.

 6                           [Trial Chamber confers]

 7             JUDGE KWON:  Yes, Mr. Robinson, do you have something to raise?

 8             MR. ROBINSON:  Actually, I wanted to check with my client, but

 9     what we had discussed before coming to court today was this particular

10     document.  He has information.  He wanted to confront the witness with

11     information explaining how this -- the limitations of this document and

12     how, in fact, the expulsions claimed to have arisen from this document

13     were not, in fact, outside the territory of Republika Srpska.  So he was

14     attempting to shed light on this document and put it in its proper

15     context, and I think that's something -- if, in fact, that's what he

16     intends to do with this document, I think that's the proper thing to do

17     when a document is introduced for the first time on re-examination.

18             JUDGE KWON:  Yes, Ms. Sutherland.

19             MS. SUTHERLAND:  Your Honour, this document's been available to

20     Mr. Karadzic.  He could have put it to Ms. Hanson during his

21     examination-in-chief -- cross-examination, I'm sorry.

22             JUDGE KWON:  Yes, I tend to agree with you, Ms. Sutherland.

23             So unless you have further questions about the documents relating

24     to population movement agencies, I'll ask Ms. Sutherland whether she has

25     any further questions to be --

Page 14935

 1             MS. SUTHERLAND:  No, Your Honour.

 2             JUDGE KWON:  Then that concludes your evidence, Ms. Hanson.  Now

 3     it's --

 4             THE ACCUSED: [Interpretation] May I put one last question?

 5             JUDGE KWON:  Very well, yes.

 6             MR. KARADZIC: [Interpretation]

 7        Q.   Ms. Hanson, do you think that the Crisis Staff reports, written

 8     for the Assembly and for the leadership as confidential and so on, do you

 9     think that they were written and that what is there is false, and that

10     they were written for the media?  Do you have evidence that this was done

11     in order to --

12             THE INTERPRETER:  The interpreter did not hear the last word

13     relating to "public."

14             JUDGE KWON:  Mr. Karadzic, I think that has been asked and

15     answered.

16             Thank you, Ms. Hanson.  That concludes your evidence.  Thank you

17     for your patience.  Now you are free to go.

18             THE WITNESS:  Thank you for your attention to my work,

19     Your Honour.

20             JUDGE KWON:  When Ms. Hanson excuses herself, I'd like to discuss

21     with the Appendix, what documents are still outstanding to be tendered.

22                           [The witness withdrew]

23             JUDGE KWON:  Yes, Ms. Sutherland.

24             MS. SUTHERLAND:  Your Honour, there are 13 documents remaining on

25     Appendix B which we would seek to admit.  Do you have the document in

Page 14936

 1     front of you, the filing of --

 2             JUDGE KWON:  Yes, I have it.

 3             MS. SUTHERLAND:  Okay.

 4             Document number 13 --

 5             JUDGE KWON:  Yes.

 6             MS. SUTHERLAND:  -- the minutes.

 7             JUDGE KWON:  Proceed, Ms. Sutherland.

 8             MS. SUTHERLAND:  Number 17.

 9             JUDGE KWON:  Yes.

10             MS. SUTHERLAND:  Number 19.

11             JUDGE KWON:  Yes.

12             MS. SUTHERLAND:  Number 21.

13             JUDGE KWON:  Yes.

14             MS. SUTHERLAND:  Number 24.

15             JUDGE KWON:  Have we admitted 22?

16             MS. SUTHERLAND:  No, Your Honour, and I don't seek to have that

17     admitted.  Sorry.

18             JUDGE KWON:  Thank you.  24.

19             MS. SUTHERLAND:  25, 26, 27, 30.

20             JUDGE KWON:  How about 29?

21             MS. SUTHERLAND:  That was admitted as Exhibit P2741, Your Honour.

22             JUDGE KWON:  Thank you.

23             MS. SUTHERLAND:  Number 31, number 32, 33 and -- no, 33.  34 was

24     admitted as P2734.

25             JUDGE KWON:  32.  In any event, that has been admitted.

Page 14937

 1             MS. SUTHERLAND:  Yes, Your Honour.

 2             JUDGE KWON:  Thank you.

 3             As I indicated, we'll issue a decision in due course on the

 4     admission of those documents.

 5             MS. SUTHERLAND:  Your Honour, just a couple of administrative

 6     matters.

 7             The 1991 census that I went to in re-examination, Exhibit P2736,

 8     that is 65 ter 00242, Part C, and I would suggest we also tender the

 9     three -- the translation of the headings of the document.

10             JUDGE KWON:  Fair enough.  Unless it is objected to, I think

11     that -- yes, could you identify those pages to the Registry so that they

12     can be up-loaded?

13             MS. SUTHERLAND:  Yes.

14             And the English translation of the handwritten diary P2716 is now

15     up-loaded.

16             JUDGE KWON:  Thank you.

17             MS. SUTHERLAND:  It was MFI'd before, but I seek its admission

18     now.

19             JUDGE KWON:  Then it will be fully admitted.

20             I assume that that has been checked.

21             MR. ROBINSON:  We haven't checked it, but we take their word for

22     it.

23             JUDGE KWON:  Very well.

24             MS. SUTHERLAND:  And, Your Honour, lastly, in relation to

25     Exhibit P970, the 50th Assembly session, we had some troubles, you may

Page 14938

 1     recall, in relation to the page numbers.  The English is starting on

 2     page 315, and the actual quote is on page 316.  And in the B/C/S, it

 3     starts at page 277, and the quote is on page 278.

 4             JUDGE KWON:  Thank you.

 5             Can we go into private session briefly.

 6                           [Private session]

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 14939

 1                           [Open session]

 2             MS. SUTHERLAND:  Your Honour, may I now be excused?  Thank you.

 3             JUDGE KWON:  Yes.  Thank you, Ms. Sutherland.

 4             THE REGISTRAR:  Your Honours, we're back in open session.

 5             JUDGE KWON:  Good morning, Mr. Gaynor.  I take it it's you who

 6     will lead the next witness.

 7             MR. GAYNOR:  Good morning, Mr. President.  That's correct.

 8             JUDGE KWON:  Yes.  Please call your next witness.

 9             MR. GAYNOR:  The Prosecution calls Dragan Kezunovic.

10                           [The witness entered court]

11             JUDGE KWON:  Good morning, sir.

12             If you could take the solemn declaration, please.

13             THE WITNESS: [Interpretation] I solemnly declare that I will

14     speak the truth, the whole truth, and nothing but the truth.

15                           WITNESS:  DRAGAN KEZUNOVIC

16                           [Witness answered through interpreter]

17             JUDGE KWON:  Thank you.  Please make yourself comfortable.

18             Yes, Mr. Gaynor.

19             MR. GAYNOR:  Thank you, Mr. President.

20                           Examination by Mr. Gaynor:

21        Q.   Good morning, sir.

22        A.   Good morning.

23        Q.   Could you state your full name for the record, please?

24        A.   My name is Dragan Kezunovic.

25        Q.   You've previously testified in the trial of Mico Stanisic and

Page 14940

 1     Stojan Zupljanin; is that correct?

 2        A.   That's correct.

 3        Q.   And you've previously met with members of the Office of the

 4     Prosecutor and provided information to them; is that right?

 5        A.   That's correct.

 6             MR. GAYNOR:  Could I ask for 65 ter 90246, please.

 7        Q.   Mr. Kezunovic, I understand that you have reviewed an amalgamated

 8     statement containing relevant portions of your testimony before this

 9     Tribunal as well as other information you've provided to the Prosecution;

10     is that correct?

11        A.   That's correct.

12        Q.   Mr. Kezunovic, do you see on the screen in front of you an

13     electronic version of the first page of your amalgamated statement?

14        A.   I do.

15        Q.   That is your signature on the bottom right-hand corner; is that

16     correct?

17        A.   Yes.

18        Q.   Do you adopt that statement as your evidence?  And if you were

19     questioned today about the same issues, would you provide the same

20     information to the Trial Chamber?

21        A.   I do adopt it as my own, and I would provide that same

22     information.

23             MR. GAYNOR:  I tender that, Mr. President.

24             JUDGE KWON:  Could you briefly tell us what is in Appendix A and

25     what is Appendix B?  Some part of his statements were tendered

Page 14941

 1     confidentially, Mr. Gaynor?

 2             MR. GAYNOR:  The entirety of Mr. Kezunovic's statement is

 3     tendered as a public document.

 4             JUDGE KWON:  Yes.  I was looking at the 1st of June notification,

 5     which has Confidential Appendix B, but I'll look into the matter

 6     separately.

 7             MR. GAYNOR:  I believe the reason we filed it as a confidential

 8     appendix is because that was the draft statement which had not yet been

 9     reviewed by the witness.

10             JUDGE KWON:  Very well.  This will be admitted.

11             THE REGISTRAR:  Exhibit P2743, Your Honours.

12             MR. GAYNOR:  Your Honours, I now propose to read a summary of the

13     witness's evidence.

14             JUDGE KWON:  Please.

15             MR. GAYNOR:  Mr. Dragan Kezunovic served as the chief of

16     communications for the Ministry of the Interior of the Serbian Republic

17     of Bosnia and Herzegovina, the RS MUP, from its inception and throughout

18     the 1992-to-1995 conflict.  Before the war, he worked as the head of the

19     Communications and Crypto-Protection Administration for the BiH MUP.

20             Mr. Kezunovic was tasked by Mico Stanisic, the RS minister of the

21     interior, to create a communications network for the RS MUP.  The seat of

22     the RS MUP moved from Vraca to Pale in April 1992.  At Pale, it was first

23     in Kalovita Brda, in an Energoinvest building.  It later moved to

24     Kikinda, also in Pale.  In around December 1992, the RS MUP had a seat in

25     Bijeljina, although the minister maintained an office and communications

Page 14942

 1     staff in Kikinda.  The RS MUP contained both state security (RS RDB) and

 2     public security (RS RJB) branches.  The RS MUP Communications Centre

 3     handled communications for both branches.  The state security branch of

 4     the RS MUP was also entitled to use its own communications network.  As

 5     in the pre-war network, RS MUP local police stations, SJBs, were

 6     connected to their regional centres, CSBs; the CSBs were connected to

 7     each other; and the CSBs to the republic-level RS MUP communications

 8     centre.

 9             The RS MUP Communications Centre at Kikinda worked 24 hours a

10     day, 7 days a week.  It had a backup electricity generator.  Teleprinter

11     operators worked in shifts and slept in the Kikinda building.

12     Communications were sent and received using shortwave radio,

13     ultrashortwave radio, radio relay, telephone, telegraph and fax.

14     Communications sent by teleprinter were manually typed into the

15     teleprinter, which encrypted outgoing and decrypted incoming

16     communication.  A digital communications system was used towards the end

17     of the conflict.  The RS MUP also made extensive use throughout the

18     conflict of couriers who distributed communications by car.

19             Acquiring equipment for the newly-created RS MUP was not

20     difficult, as all existing CSBs and SJBs possessed teleprinters, other

21     communications equipment, and backup electricity generators from the

22     pre-war period.  Almost every RS MUP police officer carried an

23     ultrashortwave radio.  There were some communications difficulties during

24     the first few months of the RS MUP.  These are described in the section

25     co-authored by Mr. Kezunovic, of an RS MUP report concerning the first

Page 14943

 1     months of the RS MUP's operation: April to June 1992.  Despite those

 2     initial difficulties, the report reflects the fact that there was always

 3     at least one form of communications link between the RS MUP

 4     Communications Centre and its subordinate CSBs.  There were five such

 5     CSBs, and they were located in Sarajevo, Banja Luka, Trebinje, Bijeljina

 6     and Doboj.

 7             Mr. Kezunovic discusses several log-books and written

 8     communications which illustrate the functioning of the RS MUP

 9     communications system in 1992, as well as RS MUP communications documents

10     relating to security arrangements for convoys containing

11     President Karadzic and others in 1995.

12             I would now like to call up, Mr. Registrar, please,

13     65 ter 16194A.

14        Q.   Mr. Kezunovic, on the screen in front of you, in a moment you'll

15     see a document.  I'll be asking you a couple of questions about that.

16             If we could go to page 21 in B/C/S and 21 in English of that

17     document, please.  If we could focus in on the first entry in B/C/S,

18     please.

19             If you can see the first entry, Mr. Kezunovic, could you just

20     explain what the first entry tells us?

21        A.   This page is an excerpt from the records of telegrams -- or,

22     rather, dispatches.  As far as I can see, this is a record of the

23     dispatches received.  Most probably, it is the Public Security Station of

24     Prijedor.

25             Now, there is certain information contained in this document.  I

Page 14944

 1     don't know if you're interested in that.  There is the number, then the

 2     date; that is the first and second column.  Then the third one is the

 3     time, and then the fourth one is the designation of that telegram, and

 4     then who this document comes from.  For instance, the one in the first

 5     line is from the Bosanski Novi station.  And then the next one is for who

 6     this is.  That is marked by the number of the organisational unit

 7     involved.

 8             If I'm not mistaken -- well, the letters are very small, so I

 9     cannot really see this very well, but I think that it's the name of the

10     document -- or, rather, the brief content of the document, and then you

11     can derive the name of the document from there.

12             Further down, I think you can see it better.  In line 4 or 5, you

13     can see that this is information, as it were.  Finally, there is the

14     signature of the recipient.

15        Q.   Mr. Kezunovic, you told us earlier that this appears to be a

16     record of documents received by Prijedor SJB.  And just as a general

17     matter, looking at the "From "column, that's column 8, we see a reference

18     to CSB Banja Luka in almost every entry.  Do you see that?

19        A.   I do.

20        Q.   This is, therefore, a record, is it, of communications from CSB

21     Banja Luka, apart from the first communication, which is from SJB

22     Bosanski Novi, to SJB Prijedor; is that right?

23        A.   That's right.

24             MR. GAYNOR:  If we could just turn the page to the next page in

25     the English and the B/C/S, please.

Page 14945

 1        Q.   Again, I would like you to scan just the column 8 showing the

 2     sender of all of the documents which are recorded here.  Would you look

 3     at that, please?

 4        A.   I see that.

 5        Q.   Again, this is a record of a series of communications from

 6     CSB Banja Luka to Prijedor SJB; is that right?

 7        A.   That's right.

 8        Q.   Could you describe, in general terms, if you're able to do so,

 9     the method by which SJBs communicated with their -- with the CSB in their

10     area?

11        A.   You mean in general terms, not only in this period, but generally

12     speaking, or do you mean by which means they communicated, or do you want

13     me to describe this mode of sending and receiving written communication?

14        Q.   I'd like to you discuss the communication in general from SJBs to

15     CSBs, and I'd like you to focus on the period after the establishment of

16     the RS MUP.

17        A.   Generally speaking, we tried to establish communication of all

18     kinds; that is to say, speech and written communication.  Of course, the

19     possibilities were not the same everywhere.  But specifically speaking,

20     Prijedor and Banja Luka, that is where the system functioned, the one

21     that existed before the outbreak of the conflict.  That is to say,

22     nothing changed there.  There only could have been some small technical

23     snags; for example, a power cut or damage on certain pieces of equipment,

24     but that was redressed rather quickly.  There was a system of telephone

25     communications.  Then also the coding system was in place, and coded

Page 14946

 1     messages could also be sent.  That is to say that in all public security

 2     stations, we tried to make it possible to have telephone communication

 3     and written communications, either by teleprinter or telefax, depending

 4     on whether the messages were of an open nature or whether they needed to

 5     be encrypted, coded.

 6             As a reserve backup system, we had a system of shortwave radio

 7     stations that was used for the transmission of short messages, for the

 8     most part, because not all stations at first had the capacity or

 9     equipment to process written messages.  It had to be done manually, and

10     that is why more time was needed for the encoding process.  Also, we had

11     ultrashortwave radio that was used by the crime police and other

12     operatives, whoever needed to move out in the field.  At any rate, that

13     happened locally on the territory of that public security station or CSB.

14             MR. GAYNOR:  Thank you, Mr. Kezunovic.

15             Mr. President, I would like to tender that log-book which covers

16     the year of 1992.

17             JUDGE KWON:  Yes, that will be admitted.

18             THE REGISTRAR:  As Exhibit P2744, Your Honours.

19             MR. GAYNOR:  I'd now like to call up 65 ter 11541, please.

20        Q.   If you would just look, Mr. Kezunovic, at the way that

21     "Mico Stanisic" is written at the bottom of this document.  Simply

22     explain, very briefly, why it's spelt in this way.

23        A.   That is because this telegram was typed out on a teleprinter, and

24     on a teleprinter you do not have the letters "ch," "sh," "ch," "dj," et

25     cetera.  So, for example, "Ch" was written as two Cs, "Ch" as two Cs, if

Page 14947

 1     that's what you meant.

 2        Q.   Thank you.  If you could tell us, just as a general matter, how a

 3     document signed and typed by somebody - for example, here

 4     Mr. Stanisic - would be communicated by teleprinter, just very briefly?

 5        A.   If we are speaking in general terms, that is to say, not about

 6     this specific document, but any document, it would first be typed up in

 7     an organisational unit, on a typewriter in the organisational unit where

 8     the document originated.  Then it would be signed by the signatory, by

 9     the author.  Then the document would be taken to the

10     Communications Centre.  Then it would be recorded by the communications

11     operators in the log-book.  If it is to be sent as an open message, then

12     it can be sent by telefax or teleprinter, but without applying encryption

13     methods.  If it is supposed to be coded, then -- well, at any rate, it

14     has to be re-typed on a teleprinter if it's to be sent by teleprinter.

15     If it's to be sent by telefax, then it can be sent in its original

16     version, as it was originally typed up.  Also, the time is stated when it

17     was handed over and who received it on the other side, and that would be

18     it.

19        Q.   Very well.  And is it correct that the teleprinted version of a

20     communication normally would not contain the signature of the author?

21        A.   The signature of the author was on the original document that was

22     brought to the Communications Centre, whereas this technical document, if

23     I can call it that way, that is created by having it re-typed, because

24     the operator has to re-type it from the authentic version into the

25     teleprinter in order to be able to send it.  Of course, there is no

Page 14948

 1     signature of the author on such a document.  Only the name of the author

 2     is written, and then it means that it was signed in that way.

 3        Q.   At the top of this document, we see that it's addressed to all

 4     CSBs and to all SJBs.  Was it the general practice, would you say, for

 5     the minister to communicate directly to all SJBs?

 6        A.   It was up to him to decide who this document was to be sent to.

 7     That is to say, every author of a dispatch or any document that was being

 8     sent assesses who this document should be sent to.  If it was the

 9     minister's assessment that it should be sent directly to all the public

10     security stations and all the CSBs, and that goes without saying if it is

11     written this way, not in some other way, it goes without saying that it's

12     sent to the chief of the CSB and to all the chiefs of the public security

13     stations.

14             MR. GAYNOR:  I'd like to tender that, Mr. President.

15             JUDGE KWON:  Yes, that will be admitted.

16             THE REGISTRAR:  Exhibit P2745, Your Honours.

17             MR. GAYNOR:  Thank you.

18             Could I now have 65 ter 04817, please.

19        Q.   Mr. Kezunovic, this document here appears to be sent from

20     Banja Luka CSB to a number of recipients.  Could you describe, just

21     briefly, who the recipients are?

22        A.   Let us take it one at a time.

23             "The MUP of the Republic of Bosnia-Herzegovina-01."  That means

24     the MUP of Bosnia-Herzegovina, 01, is -- I think it was the

25     Police Administration.  And 05, by way of information, I think that was

Page 14949

 1     the Analysis Department.  Then the "MUP of the Serb Republic of

 2     Bosnia-Herzegovina - by way of information."  So it is clear that in

 3     practice, there were cases when the same dispatch would be sent to

 4     several addressees.  Some are supposed to take action on the basis of the

 5     document sent whereas the document was simply being copied to others so

 6     that they would informed as to what was going on and who communicated

 7     with who and for what reason.  Then "Public security stations, to all,"

 8     "the chief and the commander of the Milicija station," and then finally

 9     it also says, "Bosanska Grahovo, Bosanski Petrovac, Drvar, Glamoc,

10     Kupres, Donji Vakuf, Srpska Bosanska Krupa, Srpski Bosanski Brod, to the

11     chief."

12        Q.   Now, the reference -- the second reference to the MUP of the Serb

13     Republic of BiH, where was that physically at this time, the 10th of

14     April, 1992?

15        A.   Physically, it was in several locations, mostly in the area of

16     Pale, and a part of the ministry was in Vraca, in the former Cadre

17     Education Centre of the Ministry of the Interior.

18             MR. GAYNOR:  I would like to tender that, Mr. President.

19             JUDGE KWON:  Yes, that will be admitted.

20             THE REGISTRAR:  As Exhibit P2746, Your Honours.

21             MR. GAYNOR:  I'd like to call up now, please, 65 ter 21888,

22     please.

23        Q.   You see, in this document, there is a reference to a daily

24     incident bulletin.  Do you see that, Mr. Kezunovic?

25        A.   If you can just zoom in a little bit.  It's a little bit too

Page 14950

 1     small, the text that I'm to look at.

 2        Q.   If you can't see it, just say so, and we can put the English

 3     aside for a moment.

 4        A.   It's all right now.

 5        Q.   Very well.  Could you tell us what the daily incident bulletin

 6     is, insofar as you understand it?

 7        A.   I will answer that question, but I don't see, in this document,

 8     that it says "Bulletin."

 9        Q.   Sorry.  Just on the second line in the middle of the document, do

10     you see the word "bulletin"?

11        A.   Ah, yes, I see it.  "In view of the fact that the MUP of the

12     Serbian Republic of Bosnia-Herzegovina is now located in Sarajevo... "

13             They are thinking of Vraca.  The 18th of April, I direct that the

14     bulletin of daily events and other significant security information of

15     interest be sent to this ministry by telefax.  Yes, I can answer your

16     question now, what the bulletin is.

17             A bulletin is an information review of daily events which are of

18     security interest, as we refer to them, regarding events that happened on

19     the ground, in the broadest possible sense, in the field.  Then the

20     bulletins which, during the previous 24 hours, covered the events would

21     be sent by Public Security Station officials and compiled into one

22     report, which would be sent to their superior security centre, which put

23     it all together into one report and sent it to the ministry, at the

24     headquarters.  And then the Information and Analysis Service would go

25     over all the information and classify them according to their set system,

Page 14951

 1     and then make an overview of all those events, and that was the bulletin.

 2     It could also be a weekly bulletin, not just a daily one.  But in the

 3     operative sense, a daily bulletin was something that was most efficient.

 4        Q.   Thank you.  And this communication is addressed, as we see, to

 5     the CSBs -- to all five CSBs of the RS MUP; is that right?

 6        A.   That's correct.

 7             MR. GAYNOR:  I'd like to tender that, Mr. President.

 8             JUDGE KWON:  Yes.

 9             THE REGISTRAR:  Exhibit P2747, Your Honours.

10             MR. GAYNOR:  Could I have document 20636, please.

11             Could we zoom in on the top left-hand corner of the document,

12     please, the top third.

13        Q.   Could you describe what this document is, please, Mr. Kezunovic?

14        A.   This is one of those daily bulletins, a bulletin of daily events,

15     number 3, specifically, relating to the 22nd and the 23rd of April, 1992.

16             Do I need to comment on the contents?

17        Q.   No, that will do for the moment.

18             Could I direct your attention -- there's no need to read the

19     entire document, but we see a reference to events taking place in

20     Sanski Most municipality further down that page.  Could you simply tell

21     us, which CSB area did Sanski Most fall under?

22        A.   Sanski Most was part of the Banja Luka CSB.

23        Q.   Further on in this document - perhaps we can turn to it - we see

24     a reference to events taking place in Zvornik.  It's on page 2 in the

25     B/C/S and page 3 in the English.  Which CSB did Zvornik fall under?

Page 14952

 1        A.   In that period, it belonged to the Bijeljina CSB.

 2        Q.   On page 4 in B/C/S and page 4 in English, we see a reference to

 3     events taking place in Brcko.  Which CSB did Brcko fall under?

 4        A.   Bijeljina, too.

 5        Q.   And, very briefly, Ilidza is also mentioned in this document.

 6     Which CSB region did it fall in?

 7        A.   Sarajevo.

 8             MR. GAYNOR:  I'd like to tender that, Mr. President.

 9             JUDGE KWON:  Mr. Kezunovic, in the previous document we saw

10     Mr. Stanisic's order to report to the MUP in the form of a daily

11     bulletin.  But this document is a daily bulletin, written by Stanisic,

12     addressed to whom?

13             THE WITNESS: [Interpretation] What you mentioned previously,

14     Stanisic issued orders that the report should be sent to the ministry,

15     based on which a bulletin was made.  I don't know what happened to the

16     bulletin after that, because the Administration for Information and

17     Analysis was in charge of that.  I don't know if it was sent to the

18     ministry in order for events to be analysed, in order to - how shall I

19     put it? - devise operative plans for orders and measures for action in

20     the field.  It could also have been used to inform any of a number of

21     politicians, if any of them requested that at the time, but I doubt that

22     anybody did because probably there was some kind of special list of

23     persons to whom the reports were sent.  From this, I really cannot see

24     that this document was sent to anyone, unless there is another

25     accompanying list or document that goes with it.

Page 14953

 1             JUDGE KWON:  Thank you.

 2             This will be admitted as Exhibit P2748.

 3             Yes, Mr. Gaynor.

 4             MR. GAYNOR:  Thank you, Mr. President.

 5             Could we call up 65 ter 08542, please.

 6        Q.   When this arrives on the screen in front of you, Mr. Kezunovic,

 7     we'll see that this is Daily Report 6, dated the 6th of April -- sorry,

 8     excuse me, the 25th of April of 1992.  And if you look at the second

 9     paragraph, we see a reference to events in Prijedor.  Do you see that?

10        A.   I do.

11        Q.   Now, in the third paragraph in your version on the same page, on

12     the next page in English, we see a reference to a case -- certain

13     criminal offences taking place in Banja Luka, including the case of

14     pick-pocketing or pocket-picking, as it's expressed in the English

15     translation.  Do you see that?

16        A.   The last paragraph.  In Banja Luka, during the day, 16 crimes

17     were committed; 11 break-ins, three vehicle thefts, two fuel thefts, and

18     one pick-pocket theft.  In one attempt, public order was disturbed by an

19     unidentified person or unidentified persons.

20        Q.   Later on in this document, we see references to events in

21     Bratunac municipality.  Which CSB did it fall under at this time?

22        A.   I'm not 100 per cent sure, but it was either Bijeljina or

23     Sarajevo, one of those two, because organisation changed several times,

24     in terms of which station would fall under which centre.  This changed

25     several times, so I cannot really say at that point in time, on that

Page 14954

 1     date, whether it fell under the Bijeljina or the Sarajevo centre.

 2        Q.   There are also references to Brcko and Zvornik.  You told us

 3     already they were under CSB Bijeljina; is that right?

 4        A.   In the beginning, yes.  Later, Zvornik at some point in time

 5     became a security centre.

 6             MR. GAYNOR:  I'd like to tender that, Mr. President.

 7             JUDGE KWON:  Yes.

 8             THE REGISTRAR:  Exhibit P2749, Your Honours.

 9             MR. GAYNOR:  Could we now call up, please, 65 ter 16186.  And if

10     we could go, please, to page 4 in B/C/S and page 4 in English.

11        Q.   This is a document, Mr. Kezunovic, which you've already referred

12     to in your amalgamated statement, and I want to draw your attention to a

13     couple of the entries in it.

14             If we could look at entry numbers 13 and 15 on the page in front

15     of you.  Perhaps for the moment, if we could put the English to one side

16     and bring up the B/C/S only just for the moment.

17             I want you to focus on the fourth column across, which indicates

18     the addressees.

19             And, first of all, could you just describe entry 13?  What does

20     it tell us, in brief terms; who it's from and who it's to?

21        A.   It states that it's being sent by the B and H MUP under the

22     number such and such.  I don't have to read it.  It's an addendum to a

23     dispatch of 01/18/92 of the 20th of April regarding -- and this is

24     something that I cannot read.

25        Q.   Sorry.  Just to clarify, Mr. Kezunovic, don't worry about the

Page 14955

 1     actual title of the document.  I just want to focus on the addressees.

 2     We see there "Banja Luka 078," then "CB Sarajevo," "CB Bijeljina,"

 3     "CB Trebinje," "CB Doboj"?

 4        A.   That is correct.

 5        Q.   Are those the five CSBs of the RS MUP?

 6        A.   Yes.

 7        Q.   If you look at item 15, are the addressees the same five CSBs?

 8     And that's a communication of the 27th of April, 1992.

 9        A.   Yes, the same centres and the same telephone numbers.

10        Q.   The signature in the extreme right column, could you just tell us

11     what that should indicate?

12        A.   This is the signature of the operative, the person who sent the

13     dispatch.  It's not the author of the document, but the communications

14     person, the operator.

15             MR. GAYNOR:  Thank you.

16             Could we move to page 6, please.  Keep the B/C/S for the moment.

17             JUDGE KWON:  Just for the record, Mr. Gaynor, the column of --

18     can we see the English page.  What I meant to say is the column for

19     addressees in number 13 should be identical to that for number 15, given

20     the English translation is -- some part of the English translation is

21     missing.

22             MR. GAYNOR:  Thank you for that, Mr. President.  That is the

23     case.  Thank you.

24             JUDGE KWON:  Thank you.

25             MR. GAYNOR:  Could we move now to page 6 of this document in

Page 14956

 1     B/C/S.

 2        Q.   Mr. Kezunovic, on page 6 -- sorry, could we move to the next

 3     page, please.

 4             Just focus on item number 30.

 5             If we could blow that up, please.

 6             This appears to be a record of a communication on the 4th of May,

 7     1992, addressed to the same five CSBs as well as to SJB Pale; is that

 8     correct?

 9        A.   That is correct, and it writes -- it states here that the

10     Sarajevo and Pale centres received it by messenger.

11        Q.   Could you look at entries 33 and 34.  The recipients in 33 are

12     described as "SSUP" and "MUP R Srbije," and in 34, the recipient is

13     "SSUP."  Could you indicate, in items 33 and 34, where are they located?

14        A.   This is the federal SUP and the MUP of the Republic of Serbia,

15     and you can see that by the telephone numbers, by the area codes.

16             MR. GAYNOR:  Could we move to the next page, please.

17        Q.   If you could look at items 37 and 40.  37 refers to a

18     communication on the 8th of May, 1992, to CB Banja Luka.  Communication

19     40, first a communication on the 9th of May, 1992, to "B.L.," with

20     "078 39-155."  Can you see that?

21        A.   I can see that, yes.

22        Q.   Do they appear to be records of communications to Banja Luka?

23        A.   Yes, this is a Banja Luka number.

24             MR. GAYNOR:  If we could move to the next page, please.

25        Q.   Very briefly, items 42 and 44, dated the 10th and 11th of May,

Page 14957

 1     1992, do they appear to be addressed to the same number in Banja Luka?

 2        A.   42, yes.  And what was the other number you mentioned; 44?

 3        Q.   Yes.

 4        A.   Yes, the same number.

 5             MR. GAYNOR:  Could we turn the page, please.

 6        Q.   And we have two entries for the 11th of May, 1992.  Both entries

 7     appear to be addressed to all five CSBs.  Could you confirm that?  Those

 8     are entries 47 and 48.

 9        A.   Yes, it's for all five centres.  But I cannot see the numbers for

10     Doboj and Trebinje, which probably means that it was probably not

11     delivered to them, because in earlier cases where we saw all five of

12     them, we saw phone numbers for each of the five.  Here, we don't have

13     phone numbers for Doboj and Trebinje.  I don't know what that means.

14     Perhaps for some reason it was not delivered, perhaps because of an

15     electricity cut or some other malfunction.

16        Q.   This log-book, I think you've described it in your statement

17     earlier, was one held by the RS MUP Communications Centre at Vraca; is

18     that right?

19        A.   I think so, yes.

20        Q.   At that time, was the minister, Mico Stanisic, was he personally

21     based at Vraca?

22        A.   In the sense that he spent more than a day there at a time, I

23     don't recall that I met him at that building, in the office where all the

24     people from the MUP were sitting, the chiefs of administrations and some

25     departments, including myself.  I saw him once, but it doesn't mean that

Page 14958

 1     he didn't come more than once.  But I only met him, actually, once.

 2        Q.   During the period of the entries that we've been looking at, was

 3     there a separate Bosnian Serb MUP -- RS MUP communication centre in Pale?

 4        A.   Yes, there was a MUP communications centre in Pale.  In the

 5     beginning, briefly, it was in the Energoinvest facility at Kalovita Brda,

 6     and then later it moved to a children's holiday resort from Kikinda,

 7     which is how it got its name, "Kikinda."  That's where the MUP

 8     Communications Centre was located.

 9        Q.   So, briefly, this log-book that we've been looking at does not

10     contain a reference to any communications that might have been sent

11     during that period from Pale to the CSBs; is that right?

12        A.   Well, I didn't pay attention to all the documents, but I think

13     that all the documents that are recorded in this record of received and

14     sent dispatches from Vraca originated from people who were actually

15     there, which doesn't mean that some document that was received there was

16     not received in Pale at the same time.  It could happen that it was

17     received by the Pale Communications Centre and here as well, because both

18     centres had the same weight as the Communications Centre of the ministry

19     at the seat, because if there was a need for ministry people who were in

20     Pale to be informed about something, it would be sent to them.  I don't

21     know if there was a technical possibility for them to receive it there.

22     Perhaps those in Pale could receive it and those who were in Vraca could

23     not, but that's another case.  But, generally, this is how it should have

24     been.

25             MR. GAYNOR:  I'd like to tender that document.

Page 14959

 1             I'd like to note for the record that in the amalgamated statement

 2     of the witness, he explains that the rest of this log-book is a record of

 3     communications from CSB Sarajevo.  That's explained in his amalgamated

 4     statement.

 5             JUDGE KWON:  Thank you.  Just for our convenience, do you have

 6     the para numbers?

 7             In the meantime, this will be admitted.

 8             THE REGISTRAR:  As Exhibit P2750, Your Honours.

 9             MR. GAYNOR:  Yes.  This is explained at page 40 of his

10     amalgamated statement, Mr. President.

11             JUDGE KWON:  Thank you.

12             I note the time.  It's about time to take a break, if it is

13     convenient, Mr. Gaynor.

14             MR. GAYNOR:  It is, indeed, Mr. President.

15             JUDGE KWON:  Yes.

16             We'll have a break for half an hour and resume at 11.00.

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

18                           --- On resuming at 11.00 a.m.

19             JUDGE KWON:  Yes, Mr. Gaynor.

20             MR. GAYNOR:  I could call up 65 ter 05046, please.

21        Q.   As you'll see in a moment, this document is headed information on

22     the daily events from 9th and 10th May, 1992, on the territory of

23     Banja Luka.  It is dated the 10th of May.  If we could focus on the top

24     of the B/C/S version, please.

25             Mr. Kezunovic, I think you see a fax header and a stamp there.

Page 14960

 1     Would you be able to tell us anything about those?

 2        A.   This is something that was not customary, to place a stamp later

 3     on and to register a document under a certain number within that stamp.

 4     Most probably this is a document that was received from someone.  I say

 5     "someone" intentionally, because I don't know who it could be.  So

 6     someone who received this document and registered it under this number

 7     and date within their own records.  It is like when you hand in a

 8     document in a court of law or in the municipality or somewhere and then

 9     when they stamp your own copy as a receipt that they had received the

10     same document but in the original.  This was not the usual thing in terms

11     of the documents that were exchanged in communication centres, but you

12     can see here it says "Serbian --" I can't read the second word, and then

13     it says "Bosnia-Herzegovina, Sarajevo."

14        Q.   In fact, could you help us with that.  Where it says in the

15     header to the left "Serb Republic of Bosnia and Herzegovina, Ministry of

16     the Interior, Sarajevo," was the Ministry of the Interior -- I think

17     you've expressed this before, was it in fact based in the city of

18     Sarajevo at the time?

19        A.   Well, one of the seats, that was in Vraca.  I don't know up until

20     which date it was in Vraca, but it could be treated as the seat of the

21     MUP.  Part of the MUP, that is.

22        Q.   Now, the B/C/S version of this document in fact contains two

23     versions, one of which contains the signature of Mr. Stanisic.  We can

24     look at it if you want, Mr. Kezunovic, but my question is this:  This

25     document contains information about events only on the territory of

Page 14961

 1     Banja Luka.  It covers Sanski Most, Kljuc, Banja Luka, Prijedor, Bosanska

 2     Dubica, Bosanska Gradiska, Prnjavor, Bosanski Novi and Gornji Vakuf

 3     municipalities and it is signed by Mico Stanisic.  Perhaps you could

 4     explain why or how Mr. Stanisic is in receipt of all of that information

 5     about events taking place in those municipalities.

 6        A.   Well, that's a hard question, because he could have received this

 7     in several different ways.  Most probably he received it by way of a

 8     dispatch, a report from Banja Luka about daily events in the form of a

 9     telegram or a dispatch.  Again, not he but the analysis and information

10     department, and then they wrote it up as an information on daily events.

11             There's another possibility.  If that was sent to the ministry --

12     from the ministry by someone else, then the minister was supposed to sign

13     that.

14             MR. GAYNOR:  I'd like to tender that document, please,

15     Mr. President.

16             JUDGE KWON:  Yes.

17             THE REGISTRAR:  As Exhibit P2751, Your Honours.

18             MR. GAYNOR:  Thank you.

19        Q.   We'll take break in the documents for a minute, Mr. Kezunovic.

20     The Trial Chamber has heard evidence of a meeting of the Bosnian Serb

21     Assembly which took place in Banja Luka on the 12th of May of 1992,

22     attended by, among others, Karadzic, Krajisnik, Koljevic, Plavsic,

23     Mladic, and deputies from across many parts of Serb-held territory.  Are

24     you aware yourself of that meeting?

25        A.   I think that I wasn't aware of it and that I wasn't in Banja Luka

Page 14962

 1     at the time.  That is why I didn't know.

 2        Q.   You've had a chance to inspect briefly minutes of that meeting;

 3     is that correct?

 4        A.   That's right.

 5        Q.   Those minutes are P135, for the record.  Now, do you have any

 6     experience in your career both before the war and during the conflict

 7     with the security of major events attended by high-level dignitaries?

 8        A.   Yes.  Yes, I had such experience before the war and during the

 9     war and after the war.

10        Q.   Could you tell us just a little bit about the kinds of security

11     arrangements that would have to take place within the MUP to co-ordinate

12     the security for delegates visiting a city from other parts of the

13     Republika Srpska?

14        A.   Well, if necessary, I can give an example.  For example, this

15     Assembly session in Banja Luka, what measures would be taken for such an

16     event.  In the briefest possible terms, it involves everything that is

17     the regular work of the Ministry of the Interior but with heightened

18     intensity, and more people take part in the security operation, that is

19     to say, more members of all services participate.

20             Now, what does that mean?  Security should be provided for such

21     an event for as long as it lasts.  If it's two days, then it's two days

22     round the clock.  If it's three days, then it's three days round the

23     clock.  Also, special measures should be taken in terms of physically

24     securing the facility itself where that Assembly is being held, the

25     building.  Then the building or buildings where the MPs are staying --

Page 14963

 1     or, rather, the dignitaries that are entitled to special protection under

 2     the law, for example, the president of the republic, the president of the

 3     Assembly, the prime minister.  Then security has to be provided in

 4     traffic on such an occasion.  If there is special regulation that is

 5     needed for such an event, then that has to be prepared according to a

 6     special plan.

 7             My role was to create a plan of communication for such a

 8     situation but for the needs of the security service, that is to say, so

 9     that all the services within the Ministry of the Interior could function

10     properly.  That would be it in the briefest possible terms.

11        Q.   Thank you.  And do you happen to know how delegates arriving from

12     Pale and Han Pijesak made it to Banja Luka on the 12th of May, 1992?  Do

13     you have any information about that?

14        A.   I personally have no such information, but I think that it was

15     only possible by air.  It was impossible by land to reach Banja Luka from

16     Pale.  I assume that that was the case.

17        Q.   Do you have experience with coordinating security for transport

18     of dignitaries by air within the Republika Srpska?

19        A.   I don't have that kind of experience, because that is for air

20     controllers.  That is a different kind of security, namely whether the

21     flight is safe and at what time it should take place and all these other

22     elements.

23        Q.   Thank you.  Now back to the documents, Mr. Kezunovic.  Could I

24     have 65 ter 05291, please.  Again, this is a document signed by

25     Mico Stanisic.  It's dated the 17th of May, 1992, and it is addressed to

Page 14964

 1     the security services centres in Banja Luka, Bijeljina, Doboj, Sarajevo,

 2     and Trebinje.  I would like you to look at the stamp at the top -- excuse

 3     me, the handwritten comments on the top right-hand corner of this copy,

 4     please, Mr. Kezunovic, and could you tell us anything about that.

 5             MR. GAYNOR:  Perhaps we could expand the top right-hand corner,

 6     please.  Thank you.

 7             THE WITNESS: [Interpretation] The comment is as follows:  "Was

 8     not given to Doboj.  Sent by courier on the 18th of May, 1992," and the

 9     signature of some person, probably an operator at the communications

10     centre.

11             MR. GAYNOR:

12        Q.   Thank you.  Now, in the last sentence of the body of the

13     communication we see Minister Stanisic setting out a dead-line for

14     submission of reports, and he says:

15              "Due to the content of reports --"

16             JUDGE KWON:  Let him see the sentence.  Zoom out.

17             MR. GAYNOR:  Thank you, Mr. President.

18        Q.   It says:

19             "Due to the content of the reports, send the reports by courier

20     or coded with full guarantee of confidentiality of the information."

21             Are you able to tell us which of the CSBs would have used

22     couriers at this time which would have used coded communication?

23        A.   I think that if there are no technical problems involved then

24     everybody could have received this coded via teleprinter.  However, as I

25     said, if there were no technical problems at that point in time.

Page 14965

 1             As far as I can remember, during the proofing I explained this to

 2     you, namely that during 1993 -- so it was even worse in 1992, but anyway,

 3     in 1993 when I was transferred to Bijeljina, when the ministry definitely

 4     moved to Bijeljina, I was the last one to move.  Every day there would be

 5     brief power cuts, 50 times or even more than that, which means that if

 6     you start transmitting a dispatch and if there's a power cut, you have to

 7     wait for electricity to come back again or to have the generators turned

 8     on and then to start all over the again.

 9             I'm giving you this example, but theoretically it could have been

10     sent to all five addresses if there were no technical problems at that

11     particular point in time, and I have no way of knowing that right now,

12     and I cannot remember either.

13        Q.   Now, the handwritten comment at the top right says -- indicated

14     it was sent by courier to Doboj.  Do you see anything to suggest that it

15     was sent by courier to any other of the CSBs?

16        A.   I don't see anything.

17             MR. GAYNOR:  Very well.  I'd like to tender that, please,

18     Mr. President.

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit 2752, Your Honours.

21             MR. GAYNOR:  Could we call up document 22932, please.

22        Q.   Now, you see the number of this particular daily bulletin,

23     Mr. Kezunovic?

24        A.   Yes.  106.

25        Q.   And you'll remember that earlier on we saw a daily bulletin with

Page 14966

 1     a much lower number.  I think it was number 6?

 2        A.   Correct.

 3        Q.   In this particular daily bulletin, we see reference to events

 4     described as being within the areas of the Sarajevo CSB and the

 5     Banja Luka CSB and the Bijeljina CSB.  At the very end it indicates that

 6     Doboj and Trebinje did not submit their daily incident bulletins.  Do you

 7     see those references?

 8        A.   I don't see the last part where it says that these two had not

 9     submitted.  That's what I don't see.  The rest is all right.

10        Q.   That's on the next page, please.  Sorry about that.

11        A.   Yes, yes.  I see it.

12        Q.   The information collated in this document was collated in the

13     same way as you've described earlier.  Is that your understanding?

14        A.   Yes.

15             MR. GAYNOR:  Now, Your Honours, I also have daily report number

16     107 from the 23rd of May, 109 from the 25th of May, 111 from the 27th of

17     May.  I propose in the interests of expeditiousness to tender those

18     without showing them to the witness, but I'd just like to record that

19     daily report number 107 refers to events in Banja Luka, Kotor Varos,

20     Donji Vakuf, Prijedor, and Kljuc among other areas.  109 refers to events

21     in Kotor Varos, Sanski Most, and Banja Luka.  111 refers to events in the

22     municipality of Rogatica as well as the village of Kozarac in the

23     municipality of Prijedor, and I'd like to tender those for admission.  I

24     can read out the 65 ter numbers.

25             JUDGE KWON:  Witness has confirmed the authenticity during the

Page 14967

 1     course of proofing.  That's what you're suggesting.  Witness has --

 2             MR. GAYNOR:  Yes.  He has looked at them and he agrees that these

 3     are part of the same series of daily reports issued by the minister.

 4        Q.   Is that correct, Mr. Kezunovic, or would you like to see them?

 5             JUDGE KWON:  Before that -- thank you.

 6             THE WITNESS: [Interpretation] Correct.

 7             JUDGE KWON:  Mr. Robinson.

 8             MR. ROBINSON:  Yes, Mr. President.  Although in principle we

 9     don't believe that documents should be admitted without being shown to

10     the witness, given their similarity to what he's just described, we don't

11     object.

12             JUDGE KWON:  Given that observation, we'll admit those three

13     documents.  We'll give the numbers for those.

14             THE REGISTRAR:  The current document will be Exhibit P2753, and

15     the three mentioned by Mr. Gaynor will be Exhibits P2754, P2755, and

16     P2756 respectively.

17             MR. GAYNOR:  Thank you, Mr. Registrar.

18        Q.   My final question, Mr. Kezunovic, concerns the network of radio

19     relay stations used by which the RS MUP.  Could you explain to Their

20     Honours whether the network of radio relay station which your service

21     used was identical to or distinct from the network of radio relay

22     stations used by the army?

23        A.   The network of radio relay stations is actually a network of

24     links, as we call them, between different points.  This network that we

25     used was the telecom network, that is to say, the public PTT company.  A

Page 14968

 1     small capacity of theirs was used by MUP.  And that has nothing to do

 2     with the radio relay stations of the army.

 3        Q.   Just to clarify the transcript.  It has nothing to do with the

 4     radio relay stations, the network, did you mean the plural, of the army?

 5        A.   Radio relay stations are devices that are on hills at certain

 6     altitudes, and some centres are linked up that way, in big towns and

 7     elsewhere.  So the radio relay network, the radio relay communications

 8     through one or more radio relay stations is actually just one type of

 9     link between these points that goes through the air.  Another type of

10     link are cables.  So the same thing happens either via cable or via radio

11     relay points, the very same thing.  So the same communication can go via

12     radio relay networks or via cable.  Radio relays are just optically

13     visible to one another, and then it depends on how many are needed

14     between Sarajevo and Banja Luka, for instance, and that is how this

15     communication is ensured.  In principle, this kind of communication is a

16     back-up for the cable system which is more secure and more stable.  Radio

17     relay systems are actually a back-up.  And now the fact that it was

18     simpler in technical terms to maintain this radio relay system in

19     peacetime is a different matter.  So most of the communication went that

20     way.

21             So what was used by the MUP was an integral part of these links,

22     either radio relay or cable but that were owned by the telecom -- or,

23     rather, the PTT as it was called at the time.  The military had separate

24     systems, cable and radio relay.

25        Q.   Thank you, Mr. Kezunovic.

Page 14969

 1             MR. GAYNOR:  That ends the examination-in-chief subject to the

 2     tendering of the associated exhibits.  I'd like to tender all of the

 3     exhibits which have been listed in the notification for Mr. Kezunovic

 4     which have not already been admitted by the Trial Chamber.

 5             JUDGE KWON:  Yes.

 6             Mr. Robinson, do you have any observations?

 7             MR. ROBINSON:  We don't object, Mr. President, to any of them.

 8             JUDGE KWON:  On a separate matter - excuse me, Mr. Gaynor - I

 9     forgot to ask you about your position in relation to the Appendix B in

10     relation to Ms. Hanson.  If you have any, the Chamber would be assisted

11     by hearing you again on those issues, on those items.

12             MR. ROBINSON:  In general I don't have a need to discuss the

13     specific items but in general we think the Chamber ought to stick with

14     its position that it announced at the beginning of the examination which

15     was that any documents that the Prosecution wanted admitted from

16     Appendix B should be put to the witness and those that were not put to

17     the witness we don't believe should be admitted by a bar table motion.

18     Thank you.

19             JUDGE KWON:  If my memory's correct, please correct me if I am

20     wrong, did you not say you objected to only one item when asked at the

21     outset?

22             MR. ROBINSON:  I think at the outset I said that we prefer to

23     have them all presented to the witness for her comment, and I pointed out

24     and in specific there was at least one item we thought was objectionable

25     because it was a newspaper article.  So we didn't mean to waive our

Page 14970

 1     objection to the procedure which seems to have been that documents ought

 2     to be placed before the witness, and as illustrative of that I pointed

 3     out at least one document that we felt would not be appropriate for bar

 4     table.

 5             JUDGE KWON:  And that article is still included.

 6             MR. ROBINSON:  I think that was withdrawn by Ms. Sutherland

 7     today.

 8             JUDGE KWON:  Thank you.  Yes, Mr. Tieger.

 9             MR. TIEGER:  Forgive if me if I'm belabouring the obvious but I

10     thought it necessary to point out that the discussion at the outset of

11     the examination was not -- could not be simply characterized as the

12     Chamber sticking to its position that any documents had to be put to the

13     witness as we were -- as we noted, we were operating consistent with the

14     specific guidelines of the Chamber in crafting appendix B but would

15     endeavour to heed the Court's preference and present as many as possible

16     to the witness while nevertheless preserving the existence of Appendix B

17     pursuant to the Court's guidelines.

18             JUDGE KWON:  Yes.  We'll issue a decision in due course.  Thank

19     you.

20             Yes, Mr. Gaynor.

21             MR. GAYNOR:  Thank you, Mr. President.  I just want to clarify

22     that the first daily report that I showed to Mr. Kezunovic was actually

23     daily report number 3.  That's P2748, not number 6, as I mentioned

24     earlier.  I have no further questions.  Thank you, Mr. President.

25             JUDGE KWON:  Thank you.  The associated exhibit will be admitted

Page 14971

 1     and given number by the court deputy.  Thank you.

 2             MR. GAYNOR:  Thank you, Mr. President.

 3             JUDGE KWON:  Mr. Karadzic, now it's for you to cross-examine the

 4     witness.

 5                           Cross-examination by Mr. Karadzic:

 6        Q.   [Interpretation] Good day, Mr. Kezunovic.

 7        A.   Good day.

 8        Q.   I would like to express my gratitude for kindly meeting with the

 9     Defence and with me personally, and I hope that this will help us to

10     present your knowledge in a focused way.

11             During this interview, you confirmed that before the elections in

12     the republican SUP you were called in the republican SUP, and you were

13     told that the party organisation in state organs will no longer apply.

14     Up until that time, did the League of Communists have the leading role in

15     the organisation of institutions, including the MUP?

16        A.   Yes, that is correct.  Up until those elections, it did have its

17     basic organisations in all state organs, and this is how it functioned up

18     until these multi-party elections.

19        Q.   You told us that you were angry at the state organs because the

20     state was falling apart.  You left the party, and after that you did not

21     join any other party; is that correct?

22        A.   Well, this is how it was:  Party meetings were convened at the

23     organisational entities.  That's how it was organised.  And we were told

24     that from that point on, pursuant to a decision by some organ, I cannot

25     remember which one, any kind of party organisation in the state service

Page 14972

 1     no longer applies and that we all needed to decide where we wanted to go

 2     in the field, and I demonstratively stood up at the time, you are

 3     correct, and said that the League of Communists was the one that was most

 4     to blame for the break-up of Yugoslavia.  I ripped up my party booklet in

 5     two, handed it to the party secretary and I told him that I hoped the

 6     court and everybody I said that they could spit on my cheek if they see

 7     me at any party or that one again.

 8             Well, I don't know how things proceeded from there, what the

 9     people decided, who organised themselves in what manner.  I don't know,

10     and it's not important to me.

11        Q.   I would kindly ask you to know that I am waiting for the

12     interpretation, and that is why I'm making these breaks.

13             After the first multi-party elections in November 1990, did you

14     remain at your post even though you were not a member of the

15     Serbian Democratic Party and you did not know me personally?

16        A.   That is correct.  I stayed at my post, my job.  I was not a

17     member of any party, and I was actually at that time the acting chief of

18     the administration.  According to the rules, I was the chief of a

19     department, and as such I was the deputy of the chief of the

20     administration since there was no chief of administration at the time.

21     He was transferred to the city SUP.  Later he retired, but at that point

22     in time, I was acting chief of the administration.

23        Q.   Thank you.  And then in the interview with the OTP of the 8th of

24     November, 2004, pages 7 and 8, this is 65 ter 22432, as well as in your

25     testimony in the Stanisic/Zupljanin case, this is 1D356, page 1, page 102

Page 14973

 1     and 104, you confirmed that the SDA primarily was the most persistent in

 2     appointing their people at MUP positions, bringing in numerous people who

 3     did not work in the MUP before then; is that correct?

 4        A.   Yes, that is so.  First of all, the -- certain people were

 5     appointed to the key positions in accordance to their party affiliation

 6     who did not perform those jobs in the ministry if they were in the

 7     ministry already, and then people from outside of the ministry were

 8     brought in as well.  Allegedly, I'm saying allegedly, because at the time

 9     I didn't know about these things, an agreement was reached among the

10     parties how to divide the key posts among the parties.  Specifically, I

11     know that the minister was from the SDA, the deputy was from the SDS, the

12     chief of the administration for personnel was from the SDA, and then for

13     the second part of the answer I would say that it was quite

14     characteristic for the situation at the time that Hilmo Selimovic was

15     appointed to execute those jobs as an SDA cadre.  And what else became

16     characteristic in general, after those elections, as far as the relations

17     inside the MUP were concerned, there was no longer any mutual

18     co-ordination or mutual information exchanged about common matters

19     relating to the ministry, including the personnel policies as well.  So

20     the chief of the personnel administration simply, as far as I know

21     through my administration, basically what happened was that, I'm

22     so-and-so.  I don't know where I've been before that.  Where is my new

23     chair?  That is how people were being brought in.

24        Q.   Thank you.  First of all, our usual manner and usual practice in

25     multi-ethnic Bosnia is something that I would like to clarify.  During

Page 14974

 1     the Communist times or socialist times, was it not a habit to appoint

 2     somebody from one ethnic community as chief and then his deputy would be

 3     from the other ethnic community simply in order to control each other and

 4     so that their work, that of one or the other, could go through democratic

 5     checks?

 6        A.   Yes, that's how it was in practice, and care was taken, as far as

 7     I can remember.  It wasn't just a pure formality.  It was something that

 8     thorough agreements were reached about.

 9        Q.   You remember that after the elections these posts were divided in

10     such a way so that if the chief was a Muslim the deputy was a Serb, or if

11     the Serb was the chief, the deputy would be a Muslim or a Croat, and that

12     these were divided among the three victorious parties; is that correct?

13        A.   That is how the whole story went.  As far as those of us who were

14     actually doing the work, this is what we were told, that everything would

15     be balanced out.

16        Q.   Thank you.  And this Selimovic, am I correct when I say that this

17     Hilmo Selimovic who was brought in as the chief of the personnel service

18     was a party member from the hard-core SDA party who came to the MUP from

19     somewhere else?

20        A.   Yes.  I think that's how it was.

21        Q.   And the Serbian side, the Serbian Democratic Party, did it

22     nominate Vito Zepinic as minister, who was a professor at the police

23     school, the police academy and was not a member of the SDS for that post?

24        A.   As far as I know, that's what was said, that he would be deputy

25     minister.  As for whether he was a member or not, that's something that I

Page 14975

 1     don't know.  Many at the time said that they were not members, but they

 2     turned out to be.  For many of them, there was talk that they were not

 3     members, but then in the end it turned out to be that they were.  So I

 4     don't know whether he was a cadre of the SDS or not.

 5        Q.   Thank you.  Well, as far as you're concerned, you confirm that

 6     you were not a member of the SDS and that we were in favour of you

 7     staying at your post because of your expertise, and that post was

 8     allocated to the Serbian Democratic Party.

 9        A.   Yes, that's correct, and had it not been that way, I would have

10     been removed a long time before that.

11        Q.   Thank you.  You described that in the Stanisic case.  This is

12     1D3596, Stanisic transcript pages 14 and 15, and again pages 101 and 102,

13     where you describe that a new administrator, Akif Sabic, suddenly turned

14     up who told you that you were to look for a new job; is that correct?

15        A.   Yes.  This is just a brief telling of that story.  I don't know

16     how long I was acting official in that post, and then just one morning

17     this Akif Sabic turned up.  He -- Hilmo Selimovic called me to his

18     office.  This other guy was sitting up there with him, and he told me

19     this is the new chief of the administration, introduce him to the work,

20     through all the organisational units, show him his office, and where his

21     posts are.

22        Q.   All right.  And when you showed him the ropes, then after a

23     certain period of time he told you that you were fired from the service;

24     is that correct?

25        A.   Well, actually, there is one other period, which is the period

Page 14976

 1     during which I was quietly excluded from certain activities so that even

 2     some very ordinary simple tasks from my department were not given to

 3     others as tasks by me but were given by someone else.  This couldn't have

 4     been done by this Sabic because he wasn't that familiar with the

 5     organisation and the manner of work, especially not in the way that we

 6     did the work but it was some other associate from the administration that

 7     probably did that, telling them what they were supposed to do, and then

 8     it all culminated in me being summoned one day and being told that I have

 9     an hour to find a job and to tell him where it was exactly that I had

10     found this job.

11        Q.   Thank you.  Does that mean that he felt that you did not accept

12     your marginalisation?  Did you sense that, and did he sense that you had

13     not accepted that?

14        A.   Yes.  I was absolutely sidelined.  You could see that in all

15     manner of ways.  Simply when I went to the workshops where the workers

16     were, if they were talking, this would suddenly stop.  They would stop

17     talking about the work in front of me, meaning that I was not fit to hear

18     what they were talking about, even though in a way I was a superior to

19     all of those workers.  And there was a situation in which the only thing

20     that I was obliged to do was when the salary was due, I would go and

21     receive that salary.

22        Q.   Thank you.  In the interview you said that there was a close

23     family relation between Akif Sabic and Hilmo Selimovic who appointed him

24     as the chief?

25        A.   Yes, that is correct.  This is not something that I know

Page 14977

 1     directly.  I heard this story from my colleagues, from inspectors in the

 2     MUP who wanted to rush to give me the good news first, that they were

 3     actually very closely related.

 4        Q.   Thank you.  And then in your interview you said that with the

 5     arrival of Branko Kvesic at the head of the State Security Service, he,

 6     together with Zijo Rahimic on behalf of the SDA started to appoint their

 7     own people and to distribute equipment from the MUP depot only to those

 8     in the SDA and the HDZ, and in that way they started to dismantle the

 9     MUP.  Is that correct?

10        A.   Well, let me say right away -- let me explain it a little bit.

11     You gave a very concise version and put a number of questions in one.

12     First of all, Branko Kvesic became the head of the state security service

13     and this other guy Zijo was working in the warehouse.  He wasn't any kind

14     of official but he had to be a person of confidence by the very nature of

15     the work he was doing so that there wouldn't be any talk which organs

16     were receiving which equipment in the field, was somebody being favoured,

17     and somebody neglected.  So in that sense they had to have confidence in

18     this Zijo Rahimic.  Not only Branko Kvesic, he was leader of the State

19     Security Service, but also his immediate superior of Rahimic.  This was

20     the chief of the material and financial administration services, and that

21     was Bruno Stojic who was from the HDZ and before the war he worked in

22     Neum in the utility company.

23        Q.   And then was there reallocation of the resources of the MUP to

24     the detriment of municipalities with a Serb majority?

25        A.   I can assume that that was the case, and this is why --  here are

Page 14978

 1     the facts that can support that:  All the way up until that point in

 2     time, that is to say, until Akif Sabic came to head the administration, I

 3     was I was absolutely aware of all the plans on the equipment and

 4     modernisation of all organs of the interior in Bosnia-Herzegovina.  That

 5     is to say that I directly authored some of these plans, and I was also in

 6     charge of the implementation of such a document.  That was done in

 7     five-year intervals.  The government would adopt such a document,

 8     financial document, then the Ministry of the Interior would define it in

 9     terms of its structure and in terms of the types of communications

10     involved, then also the level of development of various municipalities

11     was taken into account.  There were six categories of municipalities,

12     those that were the more developed ones, and then further on.  I don't

13     remember the exact names as to how they were defined.  The very last

14     category was the category of highly underdeveloped municipalities.

15             So then this plan took all of that into account.  The most

16     developed ones, the most developed municipalities, financed 80 per cent

17     of the equipment that they were entitled to, and the republic provided

18     only 20 per cent, whereas in the last category, it was the other way

19     around.  The municipality itself would finance 20 per cent and the

20     republic would finance 80 per cent.

21             Of course, the proper administration took account of the actual

22     equipment that was needed.  I was the person who drafted this plan, and I

23     was in charge of its implementation.  When I, in that position, no longer

24     saw these plans and had no further insight of what was being given to

25     who, obviously it wasn't being done properly since they were hiding what

Page 14979

 1     they were doing, because why would you be hiding something that was

 2     right?  You would hide something that is wrong.

 3        Q.   Thank you.  Is it correct that the SDA brought Alija Delimustafic

 4     to head the MUP who had nothing whatsoever to do with the profession?  He

 5     came from the business community.  Not to mention that his brothers were

 6     operating on the very verge of lawfulness.

 7        A.   That's correct.  Alija Delimustafic, and that I know for sure --

 8     actually, I'd have to remember which years were involved.  He was

 9     assistant cook at the army centre in Sarajevo, and then he took a course

10     for policemen, because every now and then these crash courses were

11     organised for training such personnel.  And then he started working as a

12     policeman on the beat.  Later on, I don't know how and according to what

13     system, he established a company of his own, a trading company.  It was

14     probably -- how do I put this?  He was not there all alone.  He was part

15     of a team that backed all of this up.  The company was called Cenex, and

16     then as such he came to head the MUP.  It could not be said that he was

17     qualified for that position.

18        Q.   Thank you.  Do you remember -- I think it's contained in your

19     statements, that you were shown an intercept of a telephone conversation

20     between me and Mr. Zepinic where I am asking why they want to transfer

21     you to the Ministry of Defence.  This shows that you and I do not know

22     each other, because you remained in that position as an expert.  Do you

23     remember seeing that intercept?

24        A.   I do.  I do remember, and to tell you the truth, it was only from

25     that text that I realised what was being discussed about me.  No one

Page 14980

 1     every told me that I was supposed to be transferred to the Ministry of

 2     Defence or anywhere else in accordance with my professional background.

 3     I just know that I complained to Vito Zepinic, as deputy minister, about

 4     the attitude that was taken towards me.

 5        Q.   Was that also an attempt to remove you from the MUP and from the

 6     service where you matured and where you were an acting chief?

 7        A.   Precisely.  That was one such attempt.  There were quite a few of

 8     them.

 9        Q.   Thank you.  Can you tell us whether the SDS or Radovan Karadzic

10     or any other party leader, apart from a demand to abide by the

11     distribution of different posts among the different ethnic communities,

12     did the SDS or Radovan Karadzic give any other orders to the police?

13        A.   I'm not aware of any.

14        Q.   Did you ever receive orders from the SDS?

15        A.   No.

16        Q.   We have agreed that the technical services for intercepts, et

17     cetera, were taken up by the SDA and the HDZ.  Do you know that from the

18     very outset citizens' calls were being intercepted illegally, especially

19     ethnic Serbs, and especially the SDS officials, and they were partners in

20     government at the time.

21        A.   As for the service that was involved in that, it was within the

22     State Security Service, and it was located in the training centre of

23     internal affairs in Vraca.  If one looks at the personnel structure at

24     the time, you will see that such work is carried out by Croats and

25     Muslims; they are in charge of it.  Now, if someone managed to do

Page 14981

 1     something apart from their superiors who were from those two groups, I

 2     don't know about it.  Maybe there were such cases, but I don't think so.

 3     Perhaps it went the other way.

 4        Q.   Thank you.  Is it correct that this eavesdropping was for the

 5     benefit of the SDA and the HDZ, the other two partners in government?

 6        A.   Well, judging about how things developed generally speaking in

 7     terms of personnel policies and some lack of confidence which was

 8     developed as such and was on the rise within the Ministry of the

 9     Interior, and in other ministries the situation was not much butter.

10     That I know from my contacts with colleagues elsewhere.  It could be

11     concluded that many things were being done apart from usual procedures,

12     that is to say, that there was certain abuse of authority.  That means

13     that some people could abuse the fact that they have certain technical

14     equipment in their hands.  They could abuse it by not informing all of

15     those who they should inform and not receiving all the approval that they

16     should receive in order to do something like that.  That is an

17     assumption.  As I've already said, a lot of stories were being bandied

18     about.  It was not exactly hearsay from the street.  After all, there are

19     quite a few people in this ministry, even those who belong to political

20     parties, who were not exactly delighted by all of this, by doing away

21     with the rules of service as such and by not doing things as they should

22     be done in practice.  A lot of these people were professionals, after

23     all.  They were a minority, truth to tell, but everything I heard from

24     these people leads me to believe what they said, and I have no reason to

25     doubt their truthfulness.

Page 14982

 1        Q.   Thank you.  You mentioned procedure.  In order to intercept

 2     conversations of citizens, SDA -- SDS officials included, was it

 3     necessary to have official permission, and, if so, from whom?

 4        A.   One had to receive a written order from the minister himself.  Of

 5     course -- I mean, I don't want you to take this too literally.  It's not

 6     that those people who were actually doing the bugging had to see the

 7     order themselves.  Their supervisor would see the signed order and

 8     nothing could be done without that kind of signed order.

 9             Let me explain a milder form of this kind of work.  On one day

10     within my service in the telegraph and telephone department that I

11     headed, a particular device appeared overnight, and I said, "What is

12     this?"  And they said, "Such and such a person is going to explain this

13     to you."  And he said to me, "This is a registering phone involving

14     several channels, so it can record 10 or 20 different channels at a given

15     point in time."  So what was the task involved?  And they said it was

16     several telephone booths that were bugged, because there were

17     provocations coming from these telephone booths.  So we want to follow

18     that.

19             I don't know whether that was actually the case or not, so even

20     though I was head of that department, I was not allowed to be part of

21     this, and I was not familiar with all of details involved.

22        Q.   Thank you.  Could the minister issue this kind of order for

23     listening in on conversations of citizens without a court order?

24        A.   I think it could not have been done without a court order.  I'm

25     saying it because I am not sure because that was not exactly my line of

Page 14983

 1     work, but the very logic of the situation would indicate that probably he

 2     had to issue an order on the basis of a court order.

 3        Q.   Thank you.  Let me ask you as an expert in this field whether it

 4     is possible for intercepts to be changed, rigged, doctored in any way,

 5     both the recording and the transcript, by deleting parts of sentences or

 6     entire sentences?

 7        A.   If you're asking whether it's possible technically, yes.  The

 8     technical service is just one segment of this service, the ones who

 9     handle the actual equipment.  Then there is the other service that

10     listens to the recorded conversations and types up transcripts.  So if it

11     is in the hands of someone who is prepared to commit a violation and to

12     abuse this in some way, of course they can do it.

13        Q.   Thank you.  In your interview, you mentioned that you knew, that

14     some Serb inspectors had told you about that, that Muslims and Croats

15     from the police of Bosnia-Herzegovina were being sent to some training

16     camps.  They had recently been admitted, and then they were sent for

17     training to camps in Croatia.  Is that correct?

18        A.   I don't know about Croatia, but that certain personnel were sent

19     to training camps, that is correct.  However, I don't know which camps

20     exactly and where all these camps were.  That I don't know.  However, I

21     know that inspectors from the police administration went there as

22     instructors.  How should I put this?  Everyone knew about it.  A person

23     would be gone for 15 days and then he'd come back and go away for another

24     seven days, and then he'd come back to work, and that's how it went on,

25     round and round in circles, so I think this had to do with the training

Page 14984

 1     of the reserve police.  For the most part, it was the reserve police that

 2     was being trained, and perhaps the active-duty police to a lesser degree.

 3        Q.   Generally speaking or only from among the ranks of Muslims and

 4     Croats?

 5        A.   As far as I know, that was the case.  I didn't hear of Serbs

 6     going there.

 7        Q.   Thank you.  Is it correct that the MUP of Bosnia-Herzegovina --

 8     or, rather, as for the representatives of the Croat ethnicity, the MUP of

 9     Bosnia-Herzegovina received for ethnic Croats various types of badges and

10     other equipment that would show them as -- show them to be Croatian

11     police?

12        A.   I did hear of that, so I could either die with that knowledge

13     or -- or convey it further on.  I heard about that from several people.

14        Q.   Thank you.  Immediately after the elections in December 1990, at

15     Sokolac, your house had burned down, however, you assume that that was

16     the fault of a Serb; right?

17        A.   That's correct.  That is correct that the house burned down, and

18     my friend, that is to say who worked in the service as an expert for

19     arson, he's a personal friend of mine, he told me in confidence that all

20     the material evidence indicates that this is a classical example of how

21     the perpetrator of such a crime can be identified, that it was a case of

22     arson, and then he explained how this happened, that floors can never

23     move from one corner to the other unless some inflammable liquid was

24     poured all over them and so on and so forth.  Sokolac is an ethnic Serb

25     area, so I don't see it could have been someone else.

Page 14985

 1        Q.   Thank you.  In your interview with the OTP, 65 ter 22842, dated

 2     the 8th of November, 2004, on page 11, you described a bus that you took

 3     from Sokolac to go to work to Sarajevo was stopped at check-points of the

 4     Green Berets that checked people's IDs and asked the passengers whether

 5     they had any weapons.  Is that right?

 6        A.   Yes, that's right.  After the fire in my house, it was the month

 7     of December, so it was wintertime, right, we just managed to cover all of

 8     this with some kind of plastic sheets so that it wouldn't be even more

 9     damaged, and then we agreed -- we at home agreed that I would sleep in

10     the house but at a lower level and that I would go to work every day by

11     bus from Sokolac.  So I went to work and I returned by bus to Sokolac,

12     and I usually took the bus on the outskirts of town because it didn't

13     really matter.  Any bus that went to the east passed either through

14     Sokolac or 3 or 4 kilometres in the direction of Romanija.  So I used

15     these buses for transportation, and I watched what was going on every

16     single day.  I saw it myself.  They checked my IDs a countless number of

17     times.  They even asked me, "What's with you?  We see you here every

18     day."  I invented all sorts of excuses.  Sometimes, I actually told them

19     the truth, that I was going home.  Anyway, that was a fact.  That went on

20     every day and it went on for quite a while, as a matter of fact, from

21     December when the fire took place in 1990 and then further on.  Later on

22     it happened more and more, of course.

23        Q.   Thank you.  In your Zupljanin/Stanisic evidence on page 107 in

24     e-court, 1D3596, you confirmed that they even disarmed members of the

25     MUP, the Green Berets that we mentioned, that they took their arms and

Page 14986

 1     checked their IDs, referring to MUP members who were not members of SDA.

 2     Was this Green Beret unit in any way authorised to perform these kinds of

 3     checks?

 4        A.   No.  It was neither a legitimate nor authorised unit to do so.

 5     And I even heard from police inspectors, to make matters even worse, is

 6     that those who had uniforms, they had badges, inspector badges, and

 7     Muslims who returned home late at night from Sarajevo going to the

 8     outskirts, that they would be stopped and take their weapons, and they

 9     would even comment and say, "You know what?  You're lucky you weren't

10     slapped.  I was slapped when they did that."  So that's how it was.

11        Q.   Thank you.  So even Muslims who were not members of the SDA were

12     not spared; correct?

13        A.   Well, I wasn't a member of the SDA, but I suppose so.  They would

14     probably know better anyway.  But in any case, they had a grudge against

15     regular police officers.

16        Q.   Thank you.  In your interview, in your statement, you also said

17     that thanks to the kindness of a man from Tuzla, you got a list of Serbs

18     who were slated for execution, and your name was pretty high up on that

19     list, under number 4, and when you saw that on the eve of New Year of

20     1992, you left on vacation in order to hide yourself, in fact.

21        A.   Well, that's correct.  I was shown this by a JNA officer, and to

22     be honest, I was so shocked by that I can't recall who the one, two,

23     three, and five, and six and so on people were.  It was so shocking that

24     I just recall seeing my name under number 4 there.  That was in late 1991

25     that I was shown this.

Page 14987

 1        Q.   Yes, on the eve of New Year's Eve in 1992.  Now, do you recall

 2     that in those days some prominent officers, primarily Serbs and people of

 3     other ethnicities, could observe that their apartments and their houses

 4     were marked by special symbols?

 5        A.   Yes.  There were numerous such instances.  It was the case with

 6     homes of police officers but also of simple people.

 7        Q.   Thank you.  Did this strike fear into people's hearts or unease?

 8        A.   Well, of course.  There were even cases.  Well, there were

 9     even -- it was even possible to blow through the keyhole a -- some kind

10     of gas that could either kill or disable a person.

11        Q.   Thank you.  In other words, after the war broke out, you were

12     summoned by the minister and invited to come to Pale and to join the

13     service in keeping with your experience and your expertise; is that

14     correct?

15        A.   Yes, that's correct.  He conveyed this message via his

16     communications officer who was from Sokolac and who was working at the

17     SJB, and he sent this message to me that I could -- that I should report

18     to him for this purpose, and this happened in the very first days of the

19     conflict.

20        Q.   Thank you.  You also said that for half a year or so you just sat

21     there and you couldn't move anywhere other than around Pale and in that

22     general area; is that correct?

23        A.   Well, yes, that's correct.  When I was invited to go there, I

24     went to Pale, to Karlovita Brda, to the Energoinvest building where I

25     spent a few days.  Then I received an order to go with a group of

Page 14988

 1     colleagues, chiefs of administrations and some other services to Vraca.

 2     We spent some time at Vraca, for as long as we could, but at one point in

 3     time it was no longer possible to stay there because there was a lot of

 4     sniping going around, and when they start shelling the area it became

 5     unbearable because this entire compound in Vraca was very open and

 6     vulnerable.  There was nothing to protect it.  Everything was

 7     aboveground.  And I know that we would go to a kitchen that was

 8     underground to take a meal or so, and then we used some blankets and

 9     tents in order to try and build up some kind of screen in order to

10     protect us.  But when that became unbearable, we moved to Lukavica, and

11     as a member of MUP at the headquarters, I remained there for a while,

12     after which I returned to Pale, to the Kikinda facility, and only then

13     did I get a bit more freedom of movement.  I was even assigned a vehicle

14     so I could move around, and then I started building up this system from

15     scratch.

16        Q.   When you mention this fire being opened at Vraca, am I correct

17     when I say that you could be targeted from -- from Zlatiste, Hum,

18     Velesici, Pofalici, Zuc, Barino Brdo, Sokolje, and so on, so around 200

19     degrees around, Vraca was actually exposed to fire from all of these

20     areas and this entire section?

21        A.   We I can tell you: Not 200 degrees, 360 degrees.  We were exposed

22     to fire from all areas.  Because MUP had one building at Zlatiste that

23     had been built for wartime purposes - this was built before the war - and

24     I took part in the construction of that facility.  Well, I had to do with

25     the communication equipment.  That was my involvement there.  Now, when

Page 14989

 1     it was taken over from these people from the federation, Muslims - well,

 2     I don't want to say Muslim - Muslim units, part of the Special Unit of

 3     the Muslim federation, they all took up this facility.  You also failed

 4     to mention Sanac, which is where they also took position.  This was

 5     otherwise a neighbourhood where people from Sandzak lived.  So they took

 6     position there, too, and opened fire from there as well.  So whenever we

 7     went to Vraca, we would have to seek the cover of darkness in order to

 8     protect ourselves from the fire, from Sanac specifically.

 9        Q.   Thank you.  Do you agree that the government and the Presidency

10     could not survive anywhere in the -- in the Sarajevo valley?

11        A.   Well, if the MUP could not survive there, I'm sure no one else

12     could manage to stay there.

13        Q.   Thank you.  Now, at this -- during this period, as you said

14     during your Zupljanin evidence, that's 1D3596, pages 19 and 20, you said

15     that when you started this work, there was barely any infrastructure and

16     that there were only two police officers, you and Zoran Borovcanin;

17     correct?

18        A.   Yes, that's correct.  He was the one who actually conveyed Mico's

19     message to me.

20        Q.   Thank you.  Can you tell us how many men would it take to set up

21     such a service and this -- without taking into account the loss of relay

22     stations and so on?  So how much time and how many men would it take to

23     build up this kind of system?

24        A.   Well, perhaps the best way to answer this is to tell you that

25     before the war my administration, which maintained all those

Page 14990

 1     communications stations and equipment, including the operators at the

 2     teleprinter centre, counted over 100 men, 100 staff, which means that in

 3     this situation, too, that number should not have been much lower, but we

 4     started off with just the two of us.

 5        Q.   Thank you.  The need for communications in wartime, is it

 6     comparable to the needs that the services have in war -- in peacetime?

 7        A.   Well, in any way you look at it, it has to be greater.  There has

 8     to be a greater need in wartime.

 9        Q.   Thank you.  Now, you said in your Stanisic testimony, that's

10     13596, on pages 20, 22, 23, and 27, that while you were at Vraca, you did

11     not have any phone lines with Pale and that by using mobile radio

12     stations -- you could only use mobile radio stations, in fact, if there

13     was electric power.  Is that correct?

14        A.   Well, that is correct, but I would like to explain that a bit

15     further.  The Vraca facility was connected to the republic SUP -- or,

16     rather, MUP, with two cables.  One was for public lines and the other one

17     was for special lines, as we referred to them.  In other words, police

18     telephone lines and links to various police exchanges, because each

19     police station had a telephone exchange, and it had as many connections

20     as there were offices within it.

21             Now, as soon as we moved into Vraca, this special cable was cut

22     off from the main MUP building, and at the Dolac Malta telecommunications

23     building, which we could see from Vraca, on orders from MUP the public

24     cable was cut off as well, so that we were completely cut off.

25             Later on, some police officers managed to obtain from their

Page 14991

 1     relatives or friends from their private homes, and they pulled two

 2     telephone cables to there, to the facility there in order to provide us

 3     with those -- these two phone lines.  They were private phone lines from

 4     their homes.

 5             Now, as for the U -- the ultra shortwaves, there was radio waves,

 6     there was communication via a relay station, a repeater, and this was

 7     accessible to everyone, but there was no security provided and there

 8     could be no security provided on such open communication lines.

 9             Now, what happened without this repeater there was a direct link

10     or communication between two -- if there was to be communication between

11     two points, there would have to be visibility between them, but we would

12     have to switch wavelengths all the time, but that, too, was no guarantee

13     because any ham operator could actually be able to locate the frequency

14     on which we would operate under such circumstances.

15             Now, we also had shortwave stations, but as you know, such

16     stations would have to have a special plan of work which would also

17     provide for the time of communication, the wavelength and so on.  So

18     that, too, was practically useless.  We did have one such device, but it

19     was practically of no use.

20        Q.   Thank you.  Is it correct that the Trebevic relay saw frequent

21     power shortages and that in wintertime you would have to carry oil, fuel,

22     up there in through very high snow.

23        A.   Well, that's true.  The -- it was without power very

24     frequently -- in the beginning it was on and off, but then at the end it

25     was completely cut off.  However, it did have a generator, but for the

Page 14992

 1     generator we needed fuel and that was a problem, because getting up to

 2     Trebevic, it was a difficult route that you had to actually negotiate on

 3     the way up there.

 4        Q.   Thank you.  Now, you said that in the first few months you did

 5     not know who was holding what, because from Pale you couldn't get

 6     anywhere farther than Sokolac and that there was no communication between

 7     Banja Luka and Pale, so that in the first few days all communications and

 8     meaning here technical resources and various devices, all communication

 9     was for the most part local.  Now, Mr. Gaynor pointed out, page 19 of the

10     then transcript --

11             MR. GAYNOR:  Could I have a reference for the part that you've

12     just road, Mr. Karadzic.

13             JUDGE KWON:  I think he's giving that.

14             MR. GAYNOR:  I think he's referring to today's transcript with

15     page 19.

16             JUDGE KWON:  Page 19 of the then transcript.  Could you give the

17     reference, Mr. Karadzic.

18             THE ACCUSED: [Interpretation] The first portion I related to the

19     interview with the Defence.  If it wasn't interpreted, my apologies.  So,

20     I just wanted the witness to confirm whether he actually said this to the

21     Defence and then leading up to I'm going to ask him about Prijedor.

22             MR. KARADZIC:  [Interpretation]

23        Q.   Now is this correct, as I've read it out from our interview, that

24     there were no communications from Banja Luka and Pale, and that in the

25     first few months you couldn't -- in the first few days, you couldn't move

Page 14993

 1     much further from Pale than Sokolac because nobody knew which territory

 2     was under what control?

 3        A.   That's correct, because this territory was completely unsafe.  As

 4     you can see from the documents shown by the Prosecutor today, there were

 5     all the communications sent to those five CSBs via telephone.  So it was

 6     possible to the teleprinter connection during those lines.  However, in

 7     order to cover the information that also had to be protected -- or,

 8     rather, encrypted, there would have to be someone who would physically

 9     take these encryption codes and plans of work to all the participants in

10     that network and on the first time it was me.  At the time I went to

11     Banja Luka it was the time when the corridor towards Brcko was broken

12     through.  I don't recall the exact dates but I know that I had to stay.

13     I was stuck in Brcko for several days, and only a few days later somebody

14     said, "Well, now you're free to go."  And that was the first time I went

15     to Banja Luka myself and discussed the problems that they had there, and,

16     of course, the problems were more or less the same as everywhere else,

17     however, the greatest problems would always be within the newly

18     established bodies, because they had to start from scratch, including

19     buildings, personnel, and so on.

20        Q.   Thank you.  Today's transcript, on page 15, the log-book for

21     Prijedor was shown.  Is it correct that only dispatches received from

22     neighbouring municipalities are shown there and none from eastern

23     municipalities?  Can we look at this log-book now.  I failed to write

24     down which P exhibit that is.  274.  It was the first shown exhibit

25     today.

Page 14994

 1             JUDGE KWON:  Exhibit P2744.

 2             MR. KARADZIC: [Interpretation] Yes.  Can we please have P2744 in

 3     e-court.

 4             Do you agree, Mr. Kezunovic, can we look at the first page with

 5     the names of the municipalities -- or, actually, the CSBs or SJBs, if

 6     it's not here.

 7        A.   What is on the screen here is before April 1992.  That's the

 8     beginning of 1992.  You can see in the second column the dates, 6th of

 9     January, 1992, onwards.  This refers to the pre-war period before the

10     conflict broke out.

11        Q.   Thank you.  I any that this was not the first exhibit.  The first

12     exhibit, I think, was something else, and it referred only to Prijedor.

13             JUDGE KWON:  The first exhibit this witness dealt with is an

14     order from Mr. Stanisic, wasn't it?

15             MR. GAYNOR:  The first exhibit that I showed the witness during

16     the direct was the log-book from SJB Prijedor.  It's not an order from

17     Mr. Stanisic.  The 65 ter number --

18             THE ACCUSED: [Interpretation] I think this was 16194A; is that

19     right?

20             JUDGE KWON:  This is what we are seeing now.

21             THE ACCUSED: [Interpretation] Can you please help me then to show

22     what was received in Prijedor.  Or it's a page in this document, but it's

23     a bit further on.  Page 20 in the Serbian and page 21 in the English.

24             THE WITNESS: [Interpretation] From April on.

25             MR. KARADZIC: [Interpretation]

Page 14995

 1        Q.   Serbian page 20, English page 21.  Would you agree that

 2     everything that was received by Prijedor was from its immediacy vicinity,

 3     Banja Luka, Bosnia Novi, and so on?

 4        A.   From what I can see on this page there's only Banja Luka, only in

 5     the first line we can see Bosanski Novi.

 6        Q.   And were there wire connections there?  Actually, Prijedor didn't

 7     receive anything from the headquarters, did it?

 8        A.   No, it did not.  Prijedor, before the conflict broke out, was a

 9     security centre, and it covered Bosanski Novi, Sanski Most.  Some four

10     municipalities, actually.

11        Q.   Let me ask you this, Mr. Kezunovic:  When we see a book, a

12     log-book, that -- saying that something was received, can we take it

13     definitely that this was actually received?

14        A.   Yes, I think that we can, because how could it be recorded then

15     at all, what was received or not?  I mean, how else could it be other

16     than that it was received?

17        Q.   All right.  But then when we see a log-book about what was

18     dispatched, can we be sure that it actually arrived at its destination?

19        A.   Well, that would be a little more difficult.  That does not have

20     to indicate that.  Perhaps it did and perhaps it didn't.  Sometimes

21     operators would tell the author of the document, the person sending the

22     document, that it wasn't sent out because of such and such a reason.

23     Sometimes it would send it out in five days' time.  It doesn't matter

24     what the degree of urgency was.  If there were technical difficulties,

25     then that's how it was.  There were some cases that we looked at where

Page 14996

 1     the addressee would receive the document in five days, whereas at the

 2     other end from where it was being sent it would say that the dead-line to

 3     send the document would be six hours.

 4             THE INTERPRETER:  Interpreter's note:  The last two questions and

 5     answers were not translated because the speakers were too fast.

 6             JUDGE KWON:  Interpreters couldn't interpret the last

 7     conversation, but I note the time.  If it is convenient, we'll take a

 8     break for half an hour and resume at 1.00.

 9                           --- Recess taken at 12.31 p.m.

10                           --- On resuming at 1.02 p.m.

11             JUDGE KWON:  Yes, Mr. Karadzic.

12             MR. KARADZIC: [Interpretation]

13        Q.   Am I correct that something was not completed?

14             JUDGE KWON:  I do not know, so you can tell what was missed.

15             MR. KARADZIC:  [Interpretation]

16        Q.   It was the last part of your answer.

17        A.   Well, if I may help you.

18        Q.   All right.  Thank you.

19        A.   There were two questions.  The first one related to the incoming

20     dispatches, whether what is written here would indicate that it was

21     actually received, and I confirmed that.

22             The second question referred to dispatches that were being handed

23     in -- that were received.  So did they actually arrive at their

24     destination.  And I said that it does not mean if it states so here that

25     they were necessarily received at the other end.

Page 14997

 1        Q.   All right.  My question was if they were handed in late, five or

 2     six days late, would the document still bear its old date?

 3        A.   Everything stays as in the original.  Nothing is change --

 4     changed.  The operator possibly would write in by hand when it was

 5     actually delivered.

 6        Q.   Thank you.  Or would not do that, would not indicate it.

 7        A.   Yes.  Or would not indicate.

 8        Q.   All right.  Thank you.  Do you agree that in view of the open

 9     lines and lack of coded documents the minister could not be informed

10     about very delicate matters?

11        A.   I agree.  It was always a question of - how shall I put it? - of

12     to be or not to be in the dispatch traffic.  Can we or can we not?  So it

13     was a matter of what at a certain point in time the availability of

14     encryption would affect how something that was highly confidential would

15     be sent out or not.

16        Q.   Well, people are reluctant to take the blame on themselves in

17     front of the minister.  Did the minister have the ability to send out an

18     inspector to check whether the reports were correct?

19        A.   Well, I don't know specifically, but he could have done that.  I

20     don't know whether he actually did.

21        Q.   Was communication easy, especially before the end of June, before

22     the corridor was created?

23        A.   No, it wasn't, not even on the Pale-Sokolac line.  If you're

24     thinking about physical communications.

25        Q.   Well, I was thinking about the possibility of movement of an

Page 14998

 1     independent inspector to check whether the reports were accurate.  Would

 2     he have difficulties reaching all these different destinations?

 3        A.   Yes.  Thank you.

 4        Q.   In your interview, you mention that even before the territorial

 5     links were established between certain regions in Republika Srpska, and

 6     after that communications or MUP connections depended to a large degree

 7     on the PTT telecom -- telecoms?

 8             JUDGE KWON:  Just a minute, Mr. Karadzic.  Is it that you want

 9     some reference?

10             MR. GAYNOR:  Yes, specifically, I would like Mr. Karadzic to

11     clarify when he refers to the interview between himself, or rather, the

12     Defence team, and Mr. Kezunovic and when he's referring to -- a copy of

13     which the Prosecution does not have, we don't have any record of that

14     interview - and the interview between the Prosecution and Mr. Kezunovic,

15     and both parties have copies of that interview.

16             JUDGE KWON:  Fair enough.  Mr. Karadzic, are you referring to

17     your interview, your meeting with the witness?

18             THE ACCUSED: [Interpretation] Yes.  I said in the interview with

19     the Defence, but with the Defence it was not recorded, either because I'm

20     speaking fast or either because I am not enunciating it correctly.  If it

21     had been an interview with the Prosecution, I would have given the

22     number.

23             JUDGE KWON:  Very well.

24             Mr. Kezunovic, do you still remember the question, or shall I ask

25     him to repeat it?

Page 14999

 1             THE WITNESS: [Interpretation] Well, I would like the question to

 2     be repeated, please.

 3             MR. KARADZIC:  [Interpretation].

 4        Q.   I wanted to say whether it was correct about what you told us in

 5     the interview, that before territorial links were established between

 6     certain regions of Republika Srpska and after that the situation with the

 7     communications to a large degree depended on the situation with the PTT

 8     network.

 9        A.   As far as written and spoken messages were concerned, that

10     exclusively depended on PTT telecommunications, because everything relied

11     on that.  So depending on the situation of the general system or system

12     in certain areas, we always depended on -- on that.

13        Q.   Thank you.  We noticed in reports that often a report from

14     Trebinje was missing.  That is covering the whole the

15     Eastern Herzegovina.  Is it correct that communications with Trebinje

16     proceeded via Montenegro and that we depended on the goodwill of an

17     operator over there who was running the communications system?

18        A.   Yes, that is correct.  That system was modified and turned

19     towards Montenegro and linked up to some node in Montenegro.  So I think

20     that even the numbers of Trebinje and all the connections began with the

21     Montenegro area code.

22        Q.   Thank you.  You said that there were such problems with repairs.

23     There was a shortage of cable or wire or equipment, or there was a

24     shortage of qualified staff; is that correct?

25        A.   Yes.  We were short of everything, material, instruments, tools,

Page 15000

 1     workers, especially workers with experience.  For example, 50 per cent of

 2     our technical personnel were without any experience at all of working in

 3     the police system.

 4        Q.   Thank you.  And you say that in this interview with the Defence,

 5     the Ministry of Defence and the Ministry of the Interior often faced

 6     identical problems, because they both depended on the telecommunications

 7     system; is that right?

 8        A.   Yes.  Precisely.  I think our problems were very similar.

 9        Q.   You spoke about encryption.  This is 1D5396, testimony in the

10     Stanisic/Zupljanin case, pages 116 and 117.  Stating that the MUP had

11     internal regulations regarding the type of documents which could be

12     communicated in open lines.  The criteria was based on the

13     confidentiality and importance of the data; is that correct?

14        A.   Yes.  There were instructions drafted describing all the possible

15     situations regarding contents so that the author could correctly

16     determine the degree of confidentiality and urgency.

17        Q.   Thank you.  You mentioned today that you physically had to take

18     the documents and the encryption things, and in the pages in the

19     Zupljanin and Stanisic case, 121 and 122, the encryption codes would

20     expire so that new ones had to be taken over physically.

21        A.   The code books had a certain period of validity.  When they

22     expired, they had to be replaced, and this had to be organised in time so

23     that there would be no interruption, because new documents failed to

24     arrive.  However, there were some extraordinary situations as well.  The

25     rules on keeping documents were very rigorous so that sometimes it would

Page 15001

 1     happen that one of the articles defining events in which the secrecy of

 2     the code book was violated.  Even if it was suspected that something like

 3     that happened, even if we didn't have specific data that the document was

 4     compromised, we would be suspicious.  Somebody would try to open it,

 5     perhaps, and perhaps by mistake the encryption operator would take out

 6     the wrong book and then he wouldn't be able to admit that he actually did

 7     it, but if even there was a suspicion of somebody violating the

 8     confidentiality of the code book it had to be replaced, which involved

 9     additional time, additional complications, expenses, and so on and so

10     forth.

11        Q.   Thank you.  In your interview with the Prosecutor, that is

12     65 ter number 22482, on page 26 and 30, and in your testimony in Stanisic

13     and Zupljanin, 1D3596 on page 118, you said that there was shortwave

14     communication but that it was limited and it wasn't sufficient for

15     sending longer messages or written messages; is that right?

16        A.   Yes, I can explain it briefly why that was the case.

17             Not all organs had the possibility, especially in the beginning,

18     of this machine encoding.  That is to say that there is a device that

19     produces coded text as fast as possible, and then it would be transmitted

20     via shortwave radio.  It actually had to be done manually, so it was a

21     slow procedure and rather complicated at that.  We tried to transmit only

22     the shortest dispatches via that system, only those consisting of a few

23     sentences.  However, we tried to keep it going for the sake of practice,

24     as it were.  We established connections, and we established what the

25     quality of the connection was, but it was possible to communicate via

Page 15002

 1     that system as well.  Now, how long it would take depended on the

 2     individual case involved.

 3        Q.   Thank you.  In this interview 65 ter 22482, on page 33 you say

 4     that communications could go via radio relay stations that were on

 5     mountaintops and through cables on the ground, and you say that it was

 6     easy to cut cables when they passed through enemy territory.  Was it easy

 7     to cut cables that went close to the separation lines?

 8        A.   Well, it was possible.  It was possible.  In practice, there were

 9     all sorts of situations.  However, more often it was the relay stations

10     that were under attack quite simply by virtue of their physical position.

11     They are more exposed to artillery fire.  Quite simply, as soon as

12     somebody cuts your power off, everything else becomes useless.  They

13     don't need to do anything else.

14        Q.   Thank you.  In the same interview, on page 30 you said that radio

15     communication largely depended on weather conditions, and in poor weather

16     conditions, waves could not reach the receiving party; right?

17        A.   Well, that pertains to shortwave radio stations.  When work plans

18     are elaborated, then different weather forecasts have to be taken into

19     account, geomagnetic ones as well and others, so that at a given point in

20     time a proper range would be selected that would be least susceptible to

21     atmospheric conditions.  Since we could not use this kind of forecast at

22     the time, we worked out these plans of frequency selection approximately.

23     Sometimes it was simply impossible to establish any communication through

24     the frequencies selected.

25        Q.   Thank you.  In Stanisic/Zupljanin on pages 35 and 112, you said

Page 15003

 1     that there was a courier service but that its limitations were the lack

 2     of vehicles and manpower for this to be able to function; is that right?

 3        A.   Yes, that's right.  Officially this courier service was

 4     established only, I think in 1993, perhaps even in 1994.  And I was

 5     actually the one who insisted on it the most, because these different

 6     centres were under such great pressure with regard to documents that were

 7     not urgent at all.  As a matter of fact, we were wasting resources, the

 8     code books and the paper and the equipment we had, and the special paper

 9     for telefaxes and teleprinters, et cetera.  Then they embarked on this

10     organisation.  They decide it had would be within the duty service.  So

11     I'm saying "they," because I was not involved.  Then the area was

12     visited.  They had vehicles at their disposal.  You know what it was

13     like.  They collected things from different centres, and then the

14     couriers would go to different centres.  They would then distribute

15     whatever was there, and that's how it functioned during a certain period

16     of time until there were no more resources left starting with vehicles,

17     fuel, and the like.

18        Q.   Thank you.  Was the proximity of the front line another factor

19     that worked against this, also the fact that the territory was all split

20     up?  Would couriers sometimes actually get killed?

21        A.   Well, I don't know, but these official couriers who work -- who

22     worked on such jobs and all other members the service who went out on the

23     ground were asked by other persons to carry some mail.  That would

24     happen.

25        Q.   Do you remember that the chief of the security centre of the

Page 15004

 1     Sarajevo Romanija region, Zoran Cvijetic, got killed?

 2        A.   Yes, I remember that.

 3        Q.   As he was travelling by car?

 4        A.   Yes, yes.

 5        Q.   In Stanisic/Zupljanin on page 176 you said that the MUP did not

 6     dare use a fax because these messages could not be coded.  And on pages

 7     103 through 126, you say in relation to a letter sent by Predrag Jesuric,

 8     you say that he said in that letter that there was no communication

 9     between Bijeljina and Pale, and you said in that testimony that you

10     believe that was mainly due to power cuts.

11        A.   I think that that was the main reason, and that's what I said in

12     some of my previous statements.  I confirm that.  When I was transferred

13     to Bijeljina, I saw for myself that a countless number of times, 50 times

14     during a single day there would be no power.

15             As for the death of couriers, an engineer who worked in

16     communications and was then transferred to state security communications

17     and a technician who accompanied him, they were killed at Crni Vrh.

18             THE INTERPRETER:  The interpreter did not hear the end.

19             MR. KARADZIC: [Interpretation]

20        Q.   Thank you.  In Stanisic --

21             JUDGE KWON:  Interpreters noted that they did not hear the end of

22     the answer.

23             MR. KARADZIC: [Interpretation]

24        Q.   Crni Vrh and Caparde.  That's the only thing that's missing.

25     Crni Vrh is in the area of Caparde; is that right?

Page 15005

 1        A.   Yes.

 2        Q.   Caparde.

 3             THE INTERPRETER:  Interpreter's note:  C-a-p-a-r-d-e.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Thank you.  Do you mention that Caparde was the only area that

 6     allowed for communication, because the Muslims held Konjevic Polje and

 7     the area between Vlasenica and Zvornik and as for this only road that was

 8     functioning they had ambushes even there and were killing civilians.  Do

 9     you remember that?

10        A.   Yes, I remember.  These two men got killed on that road.  And it

11     wasn't only the two of them.  They were in a column, and it was ambushed.

12        Q.   Thank you.  I see that that's what you confirmed on pages 131 and

13     132 in Stanisic/Zupljanin.  3596 is the e-court reference, 1D, that is.

14             During that testimony, also on page 129, you confirmed --

15     actually, they showed you a letter that shows that between Pale and

16     Sarajevo there were major problems in terms of communication, and that's

17     only about 15 kilometres; right?

18        A.   That's right.  That's right.  There were two roads across

19     Trebevic that was constantly under sniper fire and other fire, and also

20     another one around Jahorina and I can't remember now, Tilava.  Yes, yes,

21     that's it.

22        Q.   Thank you.  When you testified in Stanisic/Zupljanin pages 164

23     and 165 in e-court you give your comments on reports of the CSB

24     Banja Luka and these reports say that telephone and telefax lines were

25     interrupted and that that led to chaos in the communications system.

Page 15006

 1     Also, that from the beginning of the war, 50 per cent of all telegrams

 2     were sent in the Banja Luka region, and you say -- or you said to us in

 3     the interview that this situation was even worse.  That's later; right?

 4        A.   That's right.  That situation was created by intentional cuts in

 5     Sarajevo, in the MUP of the BH.  That is to say all communications from

 6     the centres led to the MUP of Bosnia and Herzegovina, the centre in

 7     Sarajevo.  And it was the easiest to switch off equipment there.  You

 8     didn't have to destroy anything.  You simply unplugged something.  You

 9     take part of the device out and that's it; an entire communication line

10     is down in that way.

11        Q.   Very often regionalisation and how justified or unjustified it

12     was has been discussed here.  I don't want to go into that, but you will

13     note this from the professional point of view, from the point of view of

14     your very own profession.  Am I right if I say that all the Eastern

15     Herzegovina were --

16             THE INTERPRETER:  Interpreter's note:  Mr. Karadzic will have to

17     start again.  This is too fast.

18             JUDGE KWON:  Mr. Karadzic, you're speaking too fast.

19             MR. KARADZIC: [Interpretation]

20        Q.   So Serb areas, Eastern Herzegovina were linked to Mostar and

21     depended on Mostar; is that right?

22        A.   That's right.

23        Q.   Serb areas in Old Herzegovina were linked to Gorazde where 30 per

24     cent were Serbs and 70 per cent were Muslims; right?

25        A.   That's right.

Page 15007

 1        Q.   Serb areas around Sarajevo linked to the centre of Sarajevo.

 2        A.   That's right.

 3        Q.   Serb parts of Semberija and Posavina were linked to Tuzla; right?

 4        A.   And also Zvornik.

 5        Q.   Oh, Zvornik was also linked to Tuzla?

 6        A.   Yes, Bratunac, Srebrenica, Vlasenica, that entire eastern area.

 7        Q.   The Serb part of Posavina and Doboj and Ozren were linked to

 8     Zenica; right?

 9        A.   Part to Zenica and part to Doboj.

10        Q.   Thank you.  And Visoka Krajina, that is to say Drvar, there was

11     100 per cent Serb; and then Grahovo, predominantly Serb, over 90 per

12     cent; Glamoc, 11 per cent were non-Serbs; Petrovac, and so on, they were

13     linked to Bihac; right?

14        A.   Part of them to Bihac and part to Livno as a pre-war centre.

15        Q.   Thank you.  Neither Bihac nor Livno were predominantly

16     Serb-populated territory; right?

17        A.   That's right.

18        Q.   So with the exception of Banja Luka, all other Serb areas were

19     linked to centres where the SDA or the HDZ were in power; right?

20        A.   Yes, that's right.  And what I mentioned a moment ago was the

21     reason for the damage sustained.  Nobody had to destroy stations or cut

22     lines along roads.  They could simply unplug all of this at the various

23     centres without any destruction whatsoever and later they could simply

24     plug all of this back in when they needed it.

25        Q.   Did they do that?

Page 15008

 1        A.   Of course.  Of course, they did.

 2        Q.   Thank you.  You said in your testimony in Stanisic/Zupljanin,

 3     that is 1D3596 on page 161, that on average there were about 300.000

 4     dispatches per year before the war.  That is to say about 22.000 per

 5     month going through the communications centre of the MUP in the

 6     Socialist Republic of Bosnia-Herzegovina.

 7        A.   Yes.

 8        Q.   Thank you.  On page 162 and page 163, you said that after the war

 9     broke out in Republika Srpska that covered 70 per cent of the territory

10     of Bosnia-Herzegovina at the time, during the first nine months of the

11     war there were about 8.500 dispatches, and that was due to poor

12     communication.  You didn't say that there, actually, that that was

13     because of poor communication.  Wasn't that the case?

14        A.   Yes, that's right.  That is what was written in the report, the

15     report on the work involved where all the results were brought together.

16        Q.   Today you confirmed that most of these dispatches were open

17     rather than coded and that when the war broke out there was increased

18     need for dispatches and the number was actually brought down to some

19     10 per cent; is that right?

20        A.   Yes, that's right, because that reflects the situation of

21     communications, the actual state of the communications involved.

22        Q.   Thank you.  In the interview with the Defence, you confirmed that

23     from time to time you did attend, not always, that you attended collegium

24     meetings but that you attended one meeting when Mr. Stanisic, the

25     minister, was shouting at the police and calling for the arrest of the

Page 15009

 1     Yellow Wasps, although this was a risky and difficult operation; is that

 2     right?

 3        A.   Yes, that's right.

 4        Q.   Further on -- actually, can I summarise now the ways in which

 5     communications went down.  First of all, most of the nodes remained under

 6     control of the Muslims and Croats, especially those in mountains and in

 7     centres.

 8        A.   That's right.

 9        Q.   The main communications centre in Dolac Malta and Mostar, Tuzla,

10     Zenica, Bihac, and so on; right?

11        A.   That's right.  And in appropriate units, organisational units in

12     the MUP.  That is to say that in each and every one of these centres that

13     is where the final -- that's where the lines ended.

14        Q.   Thank you.  Especially in newly established municipalities and

15     also the existing ones there were many shortcomings.  There wasn't enough

16     equipment, and there weren't enough trained people; right?

17        A.   That's right.

18        Q.   The repairs to the communication routes close to the front lines

19     suffered damage in combat, but also it was risky because of fire that

20     was -- and the fighting that was going on there.

21        A.   That's correct.

22        Q.   The severing of cables, that was something that was done in

23     sabotage operations; correct?

24        A.   Yes.

25        Q.   There was also a problem with power shortages as well as fuel

Page 15010

 1     shortages, fuel that was needed for generators.

 2        A.   That's correct.  Also, there was a shortage in spare parts for

 3     these generators, not just fuel, because every 15 hours or so, I believe,

 4     these generators had to be updated.  Some parts had to be replaced.  So

 5     that, too, was a problem.  And I believe that we broke all records in our

 6     work under such conditions.

 7        Q.   Thank you.  Was there also a shortage of spare parts for

 8     telecommunications equipment?

 9        A.   Well, of course, like for everything else.

10        Q.   We do not have a map ready today, and I will ask you tomorrow to

11     mark the various nodes or hubs of communication, but for now I would

12     request 65 ter 30888.  30088.

13             THE REGISTRAR:  Admitted as Exhibit D364, Your Honours.

14             THE ACCUSED: [Interpretation] My apologies.  Thank you.

15             Could we now have the next page, please.

16             MR. KARADZIC: [Interpretation]

17        Q.   Here where we see Zepinic says -- could we have the same page in

18     Serbian as well.  In the middle approximately it says, or I say:

19             "We should take a position."

20             Do you recall that this was an intercept of a conversation

21     between me and Zepinic on the 24th of July, 1992?

22        A.   Yes.

23        Q.   And I see here it says I'm supposed to sign something.  Simovic

24     signs something for Kezunovic, a man I don't know but what we know is

25     that it's coming from the MUP, from the Ministry of Defence.  Is this

Page 15011

 1     what we were talking about a little earlier, an attempt to remove you

 2     from the MUP?

 3             JUDGE KWON:  Yes, Mr. Gaynor.

 4             MR. GAYNOR:  Yes, Mr. President.  Excuse me.  The record we have

 5     is that the conversation took place on 24th July, 1991, not 1992.  Thank

 6     you.

 7             THE ACCUSED: [Interpretation] I did say 1991, but never mind.

 8             JUDGE KWON:  Thank you.

 9             MR. KARADZIC: [Interpretation]

10        Q.   On the same page it says, Zepinic says that it's important that

11     that position at the Ministry of Defence is important and then I ask,

12     "Well, do you know this man?"  Can we have the next page.

13             He says, "Well, this morning he same to see me," and so on and so

14     forth.  The next page, please.

15             And then here I say, "Well, no.  Let him -- let Kezunovic stay

16     where he is if that's of interest to us.  He shouldn't be moved without

17     our approval.  What Hilmo is doing or what Alija is doing or whoever

18     else, the basic thing is they should never again --"

19             JUDGE KWON:  Just a second.  Probably the next page for English.

20             MR. KARADZIC: [Interpretation]

21        Q.   Please see in Serbian this part.  I won't read any more.

22             So do you agree that what I am saying here is that Serbian staff

23     that are appointed should be appointed by Serbs and not by Hilmo or

24     Alija?  Do you agree?  Is that what I'm saying?

25        A.   Yes, I agree.

Page 15012

 1        Q.   Thank you.  Could we now have 65 ter 1505, please.  65 ter 01505.

 2             THE REGISTRAR:  Admitted as Exhibit P2768, Your Honours.

 3             THE ACCUSED: [Interpretation] Well, apparently there's nothing I

 4     can offer as an exhibit that Mr. Gaynor hadn't already done.

 5             MR. KARADZIC: [Interpretation]

 6        Q.   Well, here we see on the first page that you attended a meeting

 7     of the professional collegium on the 14th of April, 1992, and then this

 8     paragraph 3 it says:  "There is a gap between Pale and the Serbian

 9     MUP ..."

10             And then a bit further down it says:  "People move in a

11     disorderly fashion or without any official badge within the MUP

12     premises."

13             Can we have the next page, please.  The next page where it says

14     "Dragan Kezunovic."

15             "Dragan Kezunovic:  We don't have a sufficient number of men

16     at -- in the communications department.  Only three men applied.  We

17     should provide resources, staff, and so on.  We have major problems with

18     communications in the field and maintaining links with other structures."

19             That's what you were talking about a little earlier; correct?

20        A.   Yes, that's correct.

21        Q.   Thank you.  Can we have 65 ter 11527, please?

22             THE REGISTRAR:  Your Honours, this is Exhibit P2758.

23             MR. KARADZIC: [Interpretation]

24        Q.   The last paragraph, it says:  "Because of problems with

25     communication, the above-mentioned centres must inform all SJBs in their

Page 15013

 1     territory of the concerns of this dispatch."  Is that correct?

 2        A.   Yes, that's correct.

 3        Q.   Thank you.  Could we now have 1D3597, please.  I believe that

 4     Mr. Gaynor has already used this.  It's dated the 18th of April, and it's

 5     a request for a daily report.  So we don't have to look at that.  Can we

 6     have 18366, 18366.  The earlier document has already been admitted into

 7     evidence.  It was tendered by Mr. Gaynor.  So 65 ter 18366, please.

 8             Would you agree that it says here:

 9             "We warn you once again --"

10             Minister Stanisic says, on the 20th of April:

11             "I'm warning you again that you're obliged to submit a bulletin

12     of daily events everyday ..."

13             And so on and so forth.

14             So this shows that there were certain difficulties; right?

15        A.   Yes.

16        Q.   Thank you.  Could we have 1D3598, please.  1D3598, please.

17             JUDGE KWON:  But you are tendering the previous document, are you

18     not?

19             THE ACCUSED: [Interpretation] Yes, certainly.  I thought that

20     Mr. Gaynor had already tendered it.  He hasn't?  Well, could I tender it

21     then.

22             JUDGE KWON:  That would be admitted.

23             THE REGISTRAR:  As Exhibit D1363, Your Honours.

24             MR. KARADZIC: [Interpretation]

25        Q.   Would you agree that this is a dispatch from the Minister of the

Page 15014

 1     Interior, Stanisic, to the Ministry of the Interior of the Republic of

 2     Montenegro where he requests that communications with Trebinje be

 3     enabled?

 4        A.   Yes.

 5        Q.   Thank you.  I would like to tender this.

 6             JUDGE KWON:  Yes.

 7             THE REGISTRAR:  Exhibit D1364, Your Honours.

 8             THE ACCUSED: [Interpretation] Could we now have 1D3599, please.

 9     I don't know if we have a translation.  Yes, we do.  Okay.

10             MR. KARADZIC: [Interpretation]

11        Q.   Would you agree here that Minister Stanisic is requesting

12     information on the resources at the disposal of the centres of the

13     republic -- Republika Srpska MUP?  So this is sent to all SJBs in the

14     Sarajevo area.  In other words, not even in Sarajevo at this time did he

15     know what resources were at the disposal of the SJBs; correct?

16        A.   That's correct.

17             THE ACCUSED: [Interpretation] I'd like to tender this, please.

18             JUDGE KWON:  Yes.

19             THE REGISTRAR:  Exhibit D1365, Your Honours.

20             THE ACCUSED: [Interpretation] Thank you.  65 ter 07502, please.

21             THE REGISTRAR:  This is Exhibit P2763, Your Honours.

22             MR. KARADZIC: [Interpretation]

23        Q.   In the first paragraph of this communication from Mr. Jesuric,

24     the chief of the Bijeljina CSB, addressed to the minister, the minister

25     of the interior, and he says:

Page 15015

 1             "Due to a breakdown in the telephone, telegraph, and fax

 2     communications, during the period from the last report you did not

 3     receive any reports, although they were compiled by the chief of the

 4     Bijeljina CSB."

 5             Correct?

 6        A.   Yes.  Correct.  Perhaps this is a good time for me to repeat what

 7     I said earlier.  As far as the system that was in use by the Ministry of

 8     Interior - and I am referring to all types of communication equipment -

 9     in the period before the conflict broke out, all towns except Banja Luka

10     and Doboj, in other words, all the communications centres, nodes where

11     the communications could be manipulated or plugged or unplugged, they

12     were all on the other side.  In other words, the opposing side had all

13     the possibilities to plug or unplug anything, any mode of communication,

14     not to mention all the resources that the MUP had in Sarajevo and what

15     all equipment and devices our side could not use, whereas they could

16     because it had remained in their territory regardless of where those

17     cables and wires ran, through what territory.  And regardless of what

18     cables and wires we had in town.  So all of our difficulties -- or our

19     disadvantages were their advantages.

20        Q.   Thank you.  Now, I will ask you to mention -- to mark these nodes

21     and the relay stations on elevations tomorrow.

22             Now, could we please have 1D00668.

23             THE ACCUSED: [Interpretation] My apologies, just one question.

24     How late are we working today, to 2.30?

25             JUDGE KWON:  Yes.

Page 15016

 1             THE ACCUSED: [Interpretation] So could we have 65 ter 00668,

 2     please.  65 ter 00668, please.  Unless Mr. Gaynor beat me to it here too.

 3             THE REGISTRAR:  This is P2764, Your Honours.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Here the Zvornik SJB, public security station, we can see that on

 6     page 1, is complaining about the emergence of these paramilitary units,

 7     but can we have page 3.  There's a portion I would like to refer you to.

 8     This is page 2.  Can we have page 2 now, please.  Or, rather, we can stay

 9     here.

10             The difficulties at the very top.  The difficulties in work -- we

11     have another difficulty in the work.  It's called by the system of

12     communications between the reserve police station and the neighbouring

13     municipalities.

14             And then a little lower down, a little further down in the same

15     paragraph it says:

16             "We also lack other technical equipment such as means for

17     carrying out on-site investigations of car accidents and crimes."

18             And then further down the third paragraph from the bottom, it

19     says that communications should be established with the army and other

20     organs.

21             Now, does it say here that there was no communication even with

22     police stations in their own areas, let alone the neighbouring

23     municipalities?

24        A.   My apologies.  Can you just tell me where this document is coming

25     from?

Page 15017

 1        Q.   Well, can we have the first page.  This is the Zvornik MUP, the

 2     public security station in Zvornik.  We need the page before this one in

 3     Serbian.  Now we need the next page in Serbian.

 4        A.   Yes.  This is a report on the situation in Zvornik public

 5     security -- in the Zvornik Public Security Station, that's correct.  They

 6     couldn't even maintain communication with their reserve stations.

 7             THE ACCUSED: [Interpretation] can we now have 65 ter 00793,

 8     please.  Maybe this one was -- has already been admitted too, I'm not

 9     sure.

10             THE REGISTRAR:  As Exhibit P2762, Your Honours.

11             MR. KARADZIC: [Interpretation]

12        Q.   Thank you.  We don't have to call it up.  Now you remember that

13     Mr. Gaynor asked you here -- he referred you to the place where it says

14     that CSBs Bijeljina --

15             THE INTERPRETER:  Could the accused please repeat the question.

16             MR. KARADZIC: [Interpretation]

17        Q.   Thank you.  Can we have 1D3600, please.  [In English] It's

18     admitted already, no?  [Interpretation] 1D3600.

19             Do you agree that on the 20th of May the minister is writing to

20     all the CSB centres and states:

21             In order to monitor the status of organisations, personnel,

22     replenishment and other elements in the police command and control

23     system, it is required that you submit the following information broken

24     down by public security station and then there is a list of data required

25     by the minister, and in the last number it states data is to be provided

Page 15018

 1     by messenger by the 5th of June, 1992, at the latest.

 2             Do you remember that the corridor was not broken through until

 3     the 28th of June, 1992, until St. Vitus Day?

 4        A.   Well, I recall it wasn't broken through at that time.

 5        Q.   Thank you can we admit this please?

 6             MR. GAYNOR:  I don't think that one's already been tendered.  No

 7     objection to its admission.

 8             JUDGE KWON:  Yes.  That will be admitted.

 9             THE REGISTRAR:  As Exhibit D1366, Your Honours.

10             MR. KARADZIC: [Interpretation]

11        Q.   We have P39 here.  I don't know if we should call it up or should

12     I just ask you -- well, let's call it up, P39, so you can just look at

13     it.  P39?

14             JUDGE KWON:  I was told that this is a document under seal, so we

15     need to go into private session.

16             THE ACCUSED: [Interpretation] I don't see any reason for that.  I

17     don't see why it would be under seal.

18             JUDGE KWON:  In any event, if we don't broadcast this document, I

19     think we can remain in public session.

20             THE ACCUSED: [Interpretation] I agree.

21             MR. KARADZIC: [Interpretation]

22        Q.   Could you please see if this is a dispatch by the minister of the

23     17th of June asking for assessments to be provided, and in the middle it

24     says incidents of looting and war profiteering and other severe crimes

25     that have an affect on the state of security and so on and so forth.  Can

Page 15019

 1     we conclude on the basis of this that it is not essential to report on

 2     any lighter, less serious crime, but he is asking for reports of more

 3     serious crimes?

 4        A.   Yes.  It's probably so.  For the purposes of statistics, it's

 5     necessary to report back urgently.  Not about every single crime that

 6     occurs, but only those grave ones.

 7        Q.   The last sentence says that it should be submitted by the

 8     courier, by the dead-line.  Does that mean that the secure connection is

 9     not operating on the 17th of July either?

10        A.   Yes.  Most probably, since in the beginning he already stated the

11     manner in which it should be delivered, and probably these are quite

12     detailed information describing the crimes which would bottle up the

13     system.  It would become blocked.

14        Q.   And at the bottom it says "Failure to respect the order shall be

15     deemed a severe violation of work duty," so-and-so and then there is a

16     signature at the bottom.

17        A.   Yes, of course.  And this is what he insisted on all the time.

18        Q.   Can we please know why this would be something under seal?

19             JUDGE KWON:  That was the question I was want -- about -- I was

20     considering.  Shall we go into private session.

21                           [Private session]

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 15020

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12                           [Open session]

13             THE REGISTRAR:  We're back in open session, Your Honours.

14             JUDGE KWON:  Proceed, Mr. Karadzic.

15             THE ACCUSED: [Interpretation] Thank you.  Can we have 1D3601 now,

16     please.

17             MR. KARADZIC:  [Interpretation]

18        Q.   Could you please look at the document of the 1st of October,

19     1992.  It's an activity report of the communications and cryptographic

20     data protection department for the period from 30th of July to 30th of

21     September, 1992, for the Doboj CSB.  Does this document speak of the

22     difficulties in setting up communications, in disruptions, depending on

23     the combat and so on and so forth?  Can you please briefly tell us about

24     the problems.  Well, here is the end of the second paragraph:  "Frequent

25     disruptions in the communications with Maglaj and Petrovo due to the

Page 15021

 1     damage caused by intensive war activities."

 2        A.   Well, that's what that is.  We've been talking about it the whole

 3     time.  First of all, there was the problem in the direction towards the

 4     MUP and then also along the lines of the subordinated police station.  So

 5     the problems spread upwards and downwards, hierarchically speaking, and

 6     this is a brief description of it.  It was our practice to speak about it

 7     in much more detail, but there was no need to put all of that in in the

 8     reports, to speak specifically of the problems.

 9        Q.   So this was the situation at the end of September.  The report is

10     dated the 1st of October, 1992; is that correct?

11        A.   Yes, yes, yes.

12        Q.   Can this be admitted?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit D1367, Your Honours.

15             THE ACCUSED: [Interpretation] Can we have 65 ter 18452.  This has

16     already been admitted; right?

17             THE REGISTRAR:  As Exhibit P2760.

18             THE ACCUSED: [Interpretation] Thank you.  Can we look at the

19     second page, please.  Second page in the Serbian.  In the English I think

20     that it's all right.

21             MR. KARADZIC: [Interpretation]

22        Q.   Can you see that towards the end of the first paragraph in the

23     middle it says --

24             THE INTERPRETER:  Could we have the reference in the English,

25     please.

Page 15022

 1             JUDGE KWON:  Just a second.  Could you give the reference from

 2     which you are reading in English.

 3             THE ACCUSED: [Interpretation] It's this page.  It's the end of

 4     the second paragraph.  [In English] "Problems in providing material and

 5     technical ..."

 6             [Interpretation] And so on and so forth.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   In addition, there were initially hardly any records, crime

 9     investigation technical equipment, communications equipment, et cetera,

10     which is all essential for the quality of work, especially in the case of

11     internal affairs organs.  Does this correspond to your experience?

12        A.   Yes, that is correct.  And this is the gist.  This is a

13     conclusion pertaining to all of those questions.  Simply it puts all of

14     the problems clearly into one sentence.

15        Q.   Can we look at page 5 in the Serbian, please.  It bears 4 as the

16     page number, but I think it's actually the fifth page.  6796 is the ERN

17     number.  One page further in the Serbian.  I think in the English we're

18     all right for the beginning, and then we can turn the page.

19             "Duties and tasks of the public security service."  It states

20     here -- yes, this part in the English is okay.  Ministry of the Interior

21     of the Serbian Republic, crime fighting department, I'm skipping some

22     things.

23             THE INTERPRETER:  Interpreters note:  This is too fast.

24             JUDGE KWON:  With this speed, the interpreters can't follow you

25     simply.

Page 15023

 1             THE ACCUSED: [Interpretation] Can we look at the following page

 2     in the English.  It should be at the end of 6796.

 3             JUDGE KWON:  But again I'm repeating, Mr. Karadzic.  You don't

 4     have to read all the sentences.  You can just summarise and put the

 5     question, and then we can read the documents later on.  If the witness

 6     can't follow, then you can read them.  Proceed, Mr. Karadzic, please.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   These two paragraphs are actually the first paragraph beneath the

10     tasks and assignments of the National Security Service.  Do they indicate

11     that before the war broke out the Serb cadres were decimated, replaced,

12     retired off, dismissed from work and that the service cleansed in such a

13     way was in the service of the policy of the SDA and the HDZ and that SDS

14     leaders, members of the JNA, prominent Serbs were followed; is that

15     correct?

16        A.   Yes.

17        Q.   In the English, it should be National Security Service, and I

18     don't see that in the English.  I apologise.  It's my mistake for not

19     indicating the pages in the English.

20             Can we look at page 8 in the Serbian and page 6 in the English.

21             Well, this was the duties and task of the public security

22     service.  A little bit earlier it was the national -- nations and that

23     document was already adopted, and it says:  "According to information

24     available to the ministry, and they're not complete because of the bad

25     communication systems with certain security services centres in the

Page 15024

 1     Srpska Republika ..."

 2             Does that confirm that the communications were bad?

 3        A.   Yes.

 4        Q.   Can we have the next page in the Serbian and in the English we

 5     can stay on this page for a while, this page 6.  The first paragraph

 6     speaks about the number of submitted criminal reports and then the next

 7     one talks about that there is data about war crimes and other crimes and

 8     that it -- they are being documented.  I am not reading now.  I am

 9     putting the question.  I'm paraphrasing.  Thus, do you agree that the

10     first paragraph indicates that criminal charges were entered against 24

11     persons and everything is being documented including war crimes?  Is that

12     correct?

13        A.   Yes, yes, that's correct.

14        Q.   In the third paragraph it is stated that a greater degree of

15     linking in is required, especially regarding war crimes; is that correct?

16        A.   Yes.

17        Q.   Are you aware of the degree of effort invested by the MUP in

18     order to update the communications systems between the MUP and the CSBs?

19     Was everything done that could be done?

20        A.   Everything that could have been done was done.  Everything that

21     we were able to think of and within the means that we had at our

22     disposal.  Let me just say this:  It's much easier when you start making

23     something from scratch and you have a normal situation, but it's very

24     difficult but when you are in the position of practically reconstructing

25     something.  Even the things that were supposed to operate in the

Page 15025

 1     territory in which Serbs were -- could not function because the most

 2     crucial and most important elements were switched off in those

 3     communications centres, in the buildings and MUP organs, and these were

 4     the telecoms which were the main bearer and it was the infrastructure

 5     that the MUP used.  So it was very difficult in those circumstances,

 6     because that does not only depend on whether you know how to build

 7     something but how to combat these persistent actions by the opposing

 8     side.  Hopefully, I was clear.

 9        Q.   Thank you.  Do you agree that the sanctions imposed on Yugoslavia

10     and Republika Srpska interfered with the procurement of up-to-date

11     equipment and spare parts for old equipment?

12        A.   Of course.  And it wasn't just that.  This was also subject to

13     procurement of spare parts and other materials.  It's not just

14     specialised equipment that was under special regime but also paper was a

15     part of that.

16        Q.   Paper as subject to restrictions.  Can we have page --

17             THE INTERPRETER:  Interpreter kindly asks the accused to repeat

18     the page numbers.

19             JUDGE KWON:  Could you repeat the page number.

20             THE ACCUSED: [Interpretation] 11 in the Serbian, 7 in the

21     English.

22             MR. KARADZIC: [Interpretation]

23        Q.   "Duties and tasks related to communications and cryptographic

24     protection."  And then the second part of the sentence states:  "Resulted

25     in the total collapse of all communications systems of the former MUP due

Page 15026

 1     to either physical damage and destruction or deliberate shutdowns by the

 2     former MUP."

 3             "For instance, special telephone links -- can we have the

 4     following page in the Serbian, the following page in the Serbian, please.

 5     Special telephone links, teleprinter links and cryptographic protection

 6     systems were either destroyed or shut down."

 7                 let me not read any further.  So is this what your experience

 8     is and what you know of these matters and this is on the 29th of June,

 9     1992?  That is the date of the report.

10        A.   Yes, this is what we spoke about earlier.

11        Q.   Can we just have page 8 in English, please.  Does it say here the

12     shortwave and ultra shortwave radio networks used by internal affairs

13     organs are also falling apart?  And then further down it says that in

14     newly formed security centres there is also a shortage of these material

15     and in Serbian, and I believe in English as well, it says that electronic

16     jamming is also present in this system, and it says, Some of our

17     participants in these communications engage in futile quarrels with the

18     enemy through this system, thus rendering it inoperative.

19        A.   The last bit was characteristic of all parties in the conflict.

20        Q.   So there was electronic jamming as well?

21        A.   Yes, yes.

22        Q.   Since this document was admitted, can we just have page 14 in

23     Serbian and 9 in English to see what was situation was with regard to

24     providing information about difficulties.

25             This is what it says here, right, that CSBs and public security

Page 15027

 1     stations informed -- I'm actually not reading; I'm just speaking about

 2     this.  It depended on the quality of communications and other

 3     circumstances.  Can we have the next page in Serbian.  Is it right as is

 4     written here?

 5        A.   That's right.  That's right.

 6        Q.   The next page in Serbian, the second paragraph, to inform top

 7     officials, basically the minister and the prime minister, a daily

 8     bulletin was being issued.  Sixty came out until now.

 9             Do you agree that the Presidency and the Assembly did not have to

10     be rapported [as interpreted] on daily matters, except if something

11     dramatic happened?

12        A.   I agree.  That was not within my own line of work, so I did not

13     have any influence there.  It's not that I provided any opinions of my

14     own at that point, but I fully agree.

15        Q.   It says here that basically this is being sent to the minister

16     and the prime minister; right?

17        A.   That's right.

18        Q.   Thank you.  Since the document has been admitted, we're not going

19     to waste any time.  Let's just find this.  65 ter 11241.

20             THE REGISTRAR:  This is Exhibit P2761, Your Honours.

21             THE ACCUSED: [Interpretation] Obviously the Prosecution was very

22     hard-working.  Can we have -- I see this is the report on the period for

23     April/December 1992, that is to say all of the war year of 1992; right?

24        A.   Yes.

25             THE ACCUSED: [Interpretation] Page 31 in e-court in Serbian,

Page 15028

 1     please, and 22 in English, e-court.

 2             MR. KARADZIC: [Interpretation]

 3        Q.   Do you agree that this says that there is a lack of operative

 4     records and there are difficulties in communication due to war

 5     operations, that there is a shortage of personnel and so on and so forth,

 6     and these were all difficulties that affected proper information?

 7        A.   I agree, especially in the operative services, because that's

 8     what they were called, operative records from different fields; crime

 9     prevention, public law and order, and various other things that were part

10     of the work of the Ministry of the Interior.  So then you have systems of

11     persons and -- and crimes that were committed, particular cases that were

12     being solved, and so on.  And if you have no knowledge from earlier on,

13     you have no records of perpetrators from earlier on, of course it's more

14     difficult to work under such circumstances.

15        Q.   Thank you.  Do you agree that information that is important for

16     the security of the country would have to be submitted to the

17     president -- or, rather, the Presidency of the republic so that this

18     could be shared with the military, whereas as far as crime is concerned,

19     the president doesn't need to be informed about that if work is being

20     done about that already?

21        A.   Exactly.

22        Q.   Thirty-six in Serbian, 25 in English.  Could we have those pages

23     now please.

24             "Tasks and duties of communications and cryptographic data

25     protection."  Do you agree that it refers to three basic elements of work

Page 15029

 1     in communication and cryptographic data protection; personnel, technical

 2     equipment and documents, and that at first most of the problems were in

 3     those areas?  And also in nine -- also that nine centres, those nodes

 4     that you refer to are -- are in the former centres of security.  In our

 5     hands, we only had the CSB Banja Luka and the CSB Doboj and the nodes

 6     within them; is that right?

 7        A.   Yes, that's right.

 8        Q.   And also the cryptographic data protection system broke down, et

 9     cetera, et cetera.  Then the system of radio communications was also

10     falling apart.

11        A.   That's right.

12        Q.   Thank you.  Thank you.  So this has already been admitted we're

13     not going to dwell on it.

14             THE ACCUSED: [Interpretation] 65 ter 05511, could we have that,

15     please.

16             THE REGISTRAR:  This is Exhibit P2766, Your Honours.

17             MR. KARADZIC: [Interpretation]

18        Q.   Can we then have -- actually, I believe it's number 18 in

19     e-court.  The ERN number is 0324-6781.  Yes, that's it in Serbian.  And

20     in English may God help us.  671.  Other tasks.  Do you agree that the

21     Banja Luka centre is providing information here to the effect that they

22     do not have enough professionals and not enough vehicles and fuel and

23     towards the bottom it says that what has been received is 728

24     confidential dispatches?  Is this about 10 per cent of what the situation

25     was before the war, and was the Banja Luka centre in a better position

Page 15030

 1     compared to the public security stations that were around it?

 2        A.   Well, it was better off in relation to the other centres, but

 3     also in it's area it had newly established stations that had started from

 4     scratch as well.  However, this is a report of the 1st of January.  That

 5     is to say, before the outbreak of the armed conflict and then up until

 6     the 30th of June, so most of it refers to the time before the outbreak of

 7     the conflict.  So these figures are not very relevant for the period

 8     during war.

 9        Q.   It's three months before the war broke out and three months after

10     the war broke out; right?

11        A.   Yes.  And the Banja Luka centre was a focal point for dispatches

12     for Livno, Doboj and Prijedor.  That is to say, it covered a territory

13     that was much larger, technically speaking, than the centre covered.

14        Q.   Thank you.  Can we have the one-but-last page in Serbian, and I

15     believe that's the way it is in English too.  The penultimate one in

16     Serbian and in English too.  It says, "The engagement of organs."  So one

17     page back in Serbian and in English.

18             You see that part where it says that in Bosanska Krajina, in the

19     war-ravaged part of Bosnia-Herzegovina actually various phenomena or

20     described, and if these tendency continue in the coming period, it is

21     realistic to expect a deterioration in the actual situation and it would

22     be unrealistic to expect self-organisation in terms of government.  And

23     then further on it says terror and violence against the population, grave

24     forms of crime and general anarchy.  Can we move on to the next page in

25     both languages?

Page 15031

 1             So is this in line with your own experience and knowledge and the

 2     capabilities of our MUP at the time and their ability to introduce law

 3     and order?

 4        A.   Everywhere the situation was more or less the same like this.

 5        Q.   Thank you.

 6             JUDGE KWON:  That will be it for today.

 7             Mr. Tieger.

 8             MR. TIEGER:  Yes.

 9             JUDGE KWON:  We are seized of two motions, one related to

10     upcoming witness Nebojsa Ristic, and the other a protected witness about

11     whose protective measures the Defence is challenging.  Could we expect

12     some expedited responses from the Prosecution, given that they are coming

13     very soon.

14             MR. TIEGER:  Yes, Your Honour.  We're aiming at with respect to

15     the first an expedited response by -- hopefully by close of business

16     tomorrow.  And --

17                           [Prosecution counsel confer]

18             MR. TIEGER:  We may be talking about two different things.  One

19     response has already been filed that you haven't received, so I misspoke,

20     and I think we're even faster than I might have hoped.  I also wanted to

21     respond to the Court's inquiry earlier this morning concerning the motion

22     for access in the Dragomir Milosevic case, and first I wanted to

23     apologise to the Court for the oversight, but more substantively, I

24     wanted to indicate to the Court that there will be no objection and that

25     the OTP will co-ordinate with the Registry to identify any documents

Page 15032

 1     subject to Rule 70 protections that may require consent of the provider

 2     in order to disclose in other cases such as this one.  And we are willing

 3     to assist the Registry in -- in obtaining such consent in those cases

 4     where the exhibit was provided initially to the Defence by the

 5     Prosecution, but, of course, we are not in a position to know about or

 6     address conditions for documents submitted by the Defence for documents

 7     that didn't originate with the OTP.

 8             JUDGE KWON:  Thank you Mr. Tieger.

 9             We will rise for today.  Tomorrow, 9.00 in the morning.

10                           --- Whereupon the hearing adjourned at 2.31 p.m.,

11                           to be reconvened on Tuesday, the 21st day

12                           of June, 2011, at 9.00 a.m.