Tribunal Criminal Tribunal for the Former Yugoslavia

Page 15033

 1                           Tuesday, 21 June 2011

 2                           [Open session]

 3                           [The accused entered court]

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

 5             JUDGE KWON:  Good morning, everyone.

 6             There's one matter to discuss before we hear evidence of

 7     Mr. Kezunovic.

 8             We note that, Mr. Robinson, the accused has filed his 51st motion

 9     on disclosure violation.  With respect to that motion, I wonder whether

10     you can identify, with more specificity, the volume of material which the

11     accused will have to review which he contends to pertain to the testimony

12     of Nebojsa Ristic, and how much time he actually needs to review that

13     material.

14             MR. ROBINSON:  Yes, Mr. President.

15             The two interviews which were disclosed to us just recently

16     involve one transcript of the interview of Vlatko Lopatic, and from

17     memory, I'm estimating that transcript is about 60 to 80 pages.  I think

18     it would take him one to one and a half hours to review that transcript.

19             The second matter that was not disclosed to us until recently was

20     an interview of Dusko Mihajlovic, which was not transcribed, and I,

21     myself, listened to the video of that interview, and it's about four and

22     a half hours.  I don't think that Dr. Karadzic would necessarily have to

23     listen to that whole interview.  I could point him to the portions of it

24     that are useful for his cross-examination.  So I think we could safely

25     say that this whole exercise maybe could be completed within two to three

Page 15034

 1     hours.

 2             JUDGE KWON:  Thank you.

 3             Mr. Tieger, I wonder whether you can respond orally to this

 4     motion by the end of today's hearing, so far as it relates to the

 5     requested postponement of Mr. Ristic's testimony.

 6             MR. TIEGER:  We will be filing a written submission imminently.

 7     I expect it to be filed this morning, Your Honour.

 8             JUDGE KWON:  Thank you.

 9             Very well, we can proceed.  Let's bring in the witness.

10                           [The witness takes the stand]

11                           WITNESS:  DRAGAN KEZUNOVIC [Resumed]

12                           [Witness answered through interpreter]

13             JUDGE KWON:  Good morning, Mr. Kezunovic.

14             THE WITNESS: [Interpretation] Good morning.

15             JUDGE KWON:  Yes, Mr. Karadzic, please continue your

16     cross-examination.

17             THE ACCUSED: [Interpretation] Thank you.

18             Good morning, Your Honours.  Good morning to everyone.

19                           Cross-examination by Mr. Karadzic: [Continued]

20             MR. KARADZIC: [Interpretation].

21        Q.   And good morning to you, Mr. Kezunovic.

22        A.   Good morning.

23        Q.   I would like to ask you about another bit of information that was

24     part of the report from the meeting that you attended, and I'm referring

25     to 65 ter 11241.  I also believe that it has a P number.

Page 15035

 1             THE REGISTRAR:  Exhibit P2761, Your Honours.

 2             THE ACCUSED: [Interpretation] Could we now have page 38 in

 3     Serbian and 28 in English.  And that's item 4, "Organisation, Staffing

 4     and Posts."

 5             Could we then have item 4 in English.  I think that's the

 6     previous page.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   I'd like to ask you this:  We can -- if we look at the first

 9     page, we'll see that this report covers the period from April to December

10     1991.  Now, would you take a look at --

11             MR. GAYNOR:  April to December 1992.  Thank you.

12             JUDGE KWON:  Thank you.

13             Yes, let's continue, Mr. Karadzic.

14             MR. KARADZIC: [Interpretation]

15        Q.   The paragraph on the personnel policies.  Now, are you aware of

16     this information that was provided in the meeting that 210 employees were

17     dismissed over these couple of months, criminal reports were brought

18     against 29, and 59 were suspended?

19        A.   That is correct.

20             THE ACCUSED: [Interpretation] Thank you.

21             Could we now have D447, please.

22             MR. KARADZIC: [Interpretation]

23        Q.   Let us identify this document together.  Its title is "Brief

24     Analysis of the Functioning of the MUP So Far," and it is dated the 11th

25     of July, 1992.

Page 15036

 1             Can we have the next page, please.  That's page 2 in both the

 2     English and Serbian versions.

 3             Can you see your name listed here as one of the participants of

 4     the meeting?  That's in the second paragraph, about the sixth or seventh

 5     line from the top.

 6        A.   Yes, I can see it.

 7        Q.   So you did attend this meeting; correct?

 8        A.   Yes.

 9             THE ACCUSED: [Interpretation] Thank you.

10             Could we now have page 8 in both Serbian and English.

11             MR. KARADZIC: [Interpretation]

12        Q.   If we take a look at the bottom, we see that there is a

13     paragraph -- or a bullet point beginning with:

14             "The functional communications system has been destroyed.  There

15     have been talks with representatives of Rudi Cajevec ..."

16             And so on and so forth.

17             Now, can you see at the top it says that the army and the crisis

18     are requesting that as many as possible of the Muslims be gathered, and

19     do you recall that there was talk about Trnopolje and other centres where

20     civilians were being evacuated from the areas that were under combat, and

21     they were referred to the police who were guarding them?

22        A.   [No interpretation]

23             THE COURT REPORTER:  I'm sorry, sir.  I'm not receiving

24     interpretation.

25             JUDGE KWON:  We are hearing no interpretation.

Page 15037

 1             Mr. Kezunovic, could you kindly repeat your answer.

 2             THE WITNESS: [Interpretation] I said that I'm not very familiar

 3     with those problems.  I don't know any details about that, and I cannot

 4     give you a precise response to this question.  I really don't recall

 5     enough.

 6             THE ACCUSED: [Interpretation] Thank you.

 7             Could we now have --

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Or, rather, is it correct that there was an attempt to improvise

10     production, and was this done because there were sanctions imposed and

11     you could not obtain spare parts?

12        A.   Well, this was the only source where we could get them from,

13     other than the equipment that we found on the premises.  There was

14     nothing else, and the only chance was to work together with Cajevec

15     because they also produced, among other things, the shortwave radio sets

16     and also equipment -- encoding equipment.  So they were of a lot of

17     interest to us, as the manufacturer of such products.

18             THE ACCUSED: [Interpretation] Could we now have page 2 in both

19     English and Serbian --

20             THE INTERPRETER:  Page 12, interpreter's correction, of both

21     English and Serbian.

22             MR. KARADZIC: [Interpretation]

23        Q.   Let's take a look at Mr. Savic and what he has to say.  He's from

24     Trebinje, and he says -- or, rather, do you agree that

25     Eastern Herzegovina is bordering on Old Herzegovina; in other words,

Page 15038

 1     Gacko and Foca are about 40 kilometres apart, correct?

 2        A.   Yes.

 3        Q.   Does he say here that he's unable to provide any information on

 4     Stara Herzegovina or Old Herzegovina because the communications are down?

 5        A.   Yes, that's correct, for the time in question there was a total

 6     breakdown in communications.

 7             THE ACCUSED: [Interpretation] Thank you.

 8             Can we have page 13 now.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Mr. Pantic reports here on the situation in Bijeljina.  He is the

11     police station commander, but he also mentioned Brcko, and he says, among

12     other things, members of the Red Berets have conducted two attacks --

13     have carried out two attacks on the Brcko Police Station, but they were

14     disarmed subsequently.

15             Do you remember that there was a lot of talk about many people

16     putting red berets on their heads and then declaring themselves to be

17     Red Berets, and then they would attack our own police?

18        A.   Well, that's correct.  This was not the only incident of that

19     sort.  I believe that such incidents were recorded everywhere.  Some were

20     more intense and others less -- of lesser intensity.

21        Q.   We both have to make pauses between question and answer.

22             Could we now have pages 16 in Serbian and 15 in English, please.

23             On the previous page, if we can just see it briefly, we see that

24     these are the words of Minister Stanisic.

25             Can we just show briefly the previous page, just to show who the

Page 15039

 1     speaker is.

 2             So is this correct; these are the words of Mico Stanisic?  You

 3     can see it in the Serbian version.

 4        A.   Well, that's correct.

 5             THE ACCUSED: [Interpretation] Can we have the next page now,

 6     please.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   In paragraph 2, it says that:

 9             "We must provide the maximum, with minimum efforts.  There is a

10     lot demanded of too few people."

11             And then it goes on to say:

12             "At the government levels and in the Presidency, there is

13     constant talk about the need to stop the plundering, to maintain public

14     law and order, provide for the security of civilians ...," et cetera.

15             Do you recall that was the position taken by the minister?

16        A.   Yes, I do, and this was a constant topic with the police

17     officers, whoever attended the meetings, because that was within their

18     scope of work.

19             THE ACCUSED: [Interpretation] Could we now have page 16 of the

20     English, please, and 17 in Serbian.

21             The third paragraph in Serbian from the top, and in English, I

22     believe that's the paragraph beginning:  "We have opted ..."

23             "In order to establish power," and so on, it goes on.

24             MR. KARADZIC: [Interpretation]

25        Q.   Can we see here that even the MUP has decided to prevent and

Page 15040

 1     discover criminal acts perpetrated by military personnel, not just

 2     civilians?

 3        A.   Yes, I can see it.  This was an ongoing fight with the army,

 4     whether the police could actually take measures against army personnel.

 5        Q.   Thank you.  Then we see here that Vlasto Kusmuk is the next

 6     speaker.

 7             Can we have the next page in the Serbian, and I believe the same

 8     is the case in English.

 9             MR. KARADZIC: [Interpretation]

10        Q.   The third bullet, where he says that the codes have to be

11     determined for each station, and that an encoding system should be set

12     up, and that this issue had not been resolved even as late as the end of

13     1992.  Is that correct?

14        A.   Yes, that's correct.  The matter here that he mentioned, the

15     encoding books and the codes, that matter had not been resolved through

16     the very end.

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

18     English.

19             MR. KARADZIC: [Interpretation]

20        Q.   We see that the next speaker is Zdravko Borovcanin, and in

21     Serbian, we can stay on the same page.

22             In the next paragraph, he says -- he put the question of

23     jurisdiction to those present, between the army and the MUP, and then the

24     police and paramilitary units.  And:

25             "What are we to do about the Muslims who wish to move to another

Page 15041

 1     country ...," and so on and so forth.

 2             And then in the last paragraph, he says:

 3             "He stressed that it was necessary that those who are engaged in

 4     criminal activities be removed from among us."

 5             Do you recall that he, too, was a proponent of this and that this

 6     was actually something that everyone -- the position that everyone took?

 7        A.   Well, yes, I recall that there was a question put to me during

 8     one of the interviews - either with the Prosecutor or with the Defence, I

 9     can't recall - relating to these very matters, whether that was correct,

10     whether there were any measures taken against such people.  And I said

11     then, Believe me, if at any time I learned -- had I at any time learned

12     that the MUP condoned such conduct, I would have left the ministry on

13     that very spot.  I wouldn't stay there for another moment, because I

14     cannot recall that anyone condoned such acts.  Quite the contrary,

15     everyone tried their best to prevent these things.  However, it was

16     general chaos, it was wartime.  People just put on uniforms of all colour

17     and kind, and they did whatever they pleased.

18             THE ACCUSED: [Interpretation] Thank you.

19             Can we see the next page and where we see that the speaker is

20     Dobro Planojevic, assistant minister for crime prevention.  In English,

21     that would be on page 19, and in Serbian, page 20.  In English, we can

22     see that the speaker is Planojevic.  Can we have the next page in Serbian

23     now, please.

24             MR. KARADZIC: [Interpretation]

25        Q.   The fifth bullet from the top says:

Page 15042

 1             "Measures should be taken for our members to know what to waste

 2     them in case they commit a crime."

 3             And then we should skip one, and the one after that says:

 4             "The documenting of war crimes is a priority, and along with

 5     documentation (on-site investigation reports, photographs, expert

 6     opinions, medical reports) it is necessary to compile lists of war

 7     criminals which are to be exchanged with other centres," so that they can

 8     be monitored.

 9             Do you recall this was Planojevic's position and that it was

10     shared with the other members of the leadership?

11        A.   Yes, I do.  And I can tell you, when speaking about

12     Dobro Planojevic, that he was one of those who fought such incidents or

13     who was against these.  He was, as far as I can recall, one of the most

14     honest people in that respect, because he fought this as hard as he

15     could.

16        Q.   Thank you.  Could we -- can it be said, Mr. Kezunovic, of our

17     police system, that, in fact, it was a system that was organised and had

18     a small head, but a huge body, that this small head was supposed to

19     control this huge body?  There were few of you, few commanders in various

20     administrations and stations, but the huge problem?

21        A.   That's correct.

22        Q.   Now, take a look at what Cedo Kljajic says.  He's the

23     under-secretary for public security, and he emphasised the need to

24     document war crimes in order to press criminal charges.  Do you know,

25     Mr. Kezunovic, that in Krajina, for instance, all of these processes that

Page 15043

 1     were conducted in Bihac and other areas, that are being conducted

 2     nowadays, in Bihac and other areas, that all those proceedings are being

 3     tried based on the documentation collected by our bodies and our organs

 4     during the war?

 5        A.   I don't know exactly what you're referring to.  Are you referring

 6     to the proceedings and the trials that are being conducted now?

 7        Q.   Yes, that's correct.

 8        A.   Well, yes, I know that they're using documents that we had

 9     collected.

10        Q.   Now, let's take a look at what Simo Tusevljak had to say.  He was

11     the head of the Crime Department.

12             Can we have the next page in both the English and Serbian,

13     please.  In English, that's page 20, in Serbian, 21.

14             Here we see at the end of the second paragraph, where it says

15     that criminal charges are pressed against everyone:

16             "In Vlasenica alone, of 73 criminal charges, 23 were pressed

17     against Serbs.  For the time being, our most pressing task is to press

18     criminal charges.  War crimes are documented, even if they are committed

19     by Serbs."

20             Do you recall that this was the position?

21        A.   Yes, that's absolutely correct.  And it wasn't only his position.

22     He did work in the Crime Department, but that was also the position of

23     the minister as well as of all the other leaders, and this was shared

24     also by chiefs of centres and stations.

25        Q.   Thank you.  Was it your impression at this meeting that there was

Page 15044

 1     a determined position that the police should do their work in a

 2     professional way, in a determined way, and irrespective of who the

 3     perpetrators were, irrespective of their ethnicity or faith?

 4        A.   [No interpretation]

 5             THE ACCUSED: [Interpretation] Thank you.

 6             Can we now have 65 ter --

 7             JUDGE KWON:  Did we hear his answer?  What did you say,

 8     Mr. Kezunovic?

 9             THE WITNESS: [Interpretation] I said that's absolutely true,

10     that's absolutely correct.

11             JUDGE KWON:  Before we leave this document, can we see B/C/S

12     version, page 17, and English, 16.  It's the last paragraph on English.

13     I think it's somewhere in the middle on page 16.  It says:

14             "At the end of this part of the meeting, there was a separate

15     meeting among several people, among whom I included you."

16             Did you find that paragraph?  In English, we move on to the next

17     page.

18             THE WITNESS: [Interpretation] Yes.

19             JUDGE KWON:  According to this, you spoke about - can we go

20     on - spoke about connections and the Criminal Code.  I'm not sure whether

21     it's a misinterpretation, but did you talk about Criminal Code?

22             THE WITNESS: [Interpretation] Well, it's a mistranslation.  "KZ"

23     means "Encryption" or "Cryptographic Protection," "Kripto Zastita."

24             JUDGE KWON:  Thank you.

25             Back to you, Mr. Karadzic.

Page 15045

 1             THE ACCUSED: [Interpretation] Thank you.

 2             Can we now see 05297, please.

 3             THE REGISTRAR:  Exhibit P2765, Your Honours.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   This is a report by the MUP from the Romanija-Bircani CSB; is

 6     that correct?

 7        A.   Yes.

 8        Q.   And they're responding to a document, strictly confidential,

 9     dated the 19th of July, 1992, number 1492, and they say:

10             "In connection with the above-mentioned documents, which we

11     received on 24 July, we are unable to provide data and reports in more

12     detail due to the short time-limit for their delivery.

13             "The most frequent problem in the preparation of data is weak

14     communications with public security stations as a result of war

15     operation."

16             Is that correct?

17        A.   Yes.

18        Q.   And then in the second paragraph, in the middle, it states:

19             "Groups of persons in uniforms under arms are involved in the

20     looting which creates the impression that it is a case of organised

21     crime.  Reports have it that most of these people are neither in the

22     ranks of the army, nor the police.  The crime-fighting section as well as

23     the police are not able to take significant measurements and activities

24     to prevent this.  There are problems because we lacked sufficient number

25     of cadres, as well as the fact that the military and the police are

Page 15046

 1     engaged on the front-lines."

 2             Is that correct, that anybody could wear a uniform, get weapons,

 3     and become some sort of force?

 4        A.   Yes, that is correct.

 5        Q.   So this Security Centre, where there was no interruption in the

 6     territorial continuity, Birac, Romanija, Sarajevo, this person who wrote

 7     this said that he wasn't able to have good communication, even though

 8     everything was quite close; is that correct?

 9        A.   Yes, that is correct.  But at the time when he was writing this,

10     his location was in Lukavac, in the Energoinvest factory, and he had a

11     large problem.  He could see Ilidza, but he couldn't get to it.  He

12     needed half a day to go 'round to reach Ilidza.  And I don't even want to

13     talk about Ilijas, the other municipalities.  His major problem was the

14     fact that the city of Sarajevo, with the 10 pre-war municipalities, a

15     large number of population, and - how shall I put it? - the line of

16     separation was quite clumsy, and then there was the background, and then

17     we were talking about whether Bratunac belongs to Sarajevo or not.  And

18     the name actually speaks for itself, Sarajevo-Romanija-Birac.  That

19     centre covered that area of Birac.  And from Lukavica, it was hard for

20     him to command and to keep it under control and to move around.  That was

21     a major problem to him; not only to him, but all the members of the

22     service.

23             THE ACCUSED: [Interpretation] Thank you.

24             Can we briefly have 65 ter 05631.

25             THE REGISTRAR:  Exhibit P2767, Your Honours.

Page 15047

 1             MR. KARADZIC: [Interpretation]

 2        Q.   This is a periodical report, dated the 1st of July, covering the

 3     period up to the 30th of September; July, August and September for the

 4     Banja Luka, or the CSB area of Banja Luka; is that correct?

 5        A.   Yes.

 6             THE ACCUSED: [Interpretation] Can we have the ERN, because there

 7     are certification pages in the document.  I'm not sure which number it

 8     is.  The ERN is 0074-9631.  The document has been admitted.  I just want

 9     to see what they say about communications at the end of this period in

10     late September.

11             MR. KARADZIC: [Interpretation]

12        Q.   Can you see this first paragraph, which states -- this is item 5,

13     5.1.  Can we have the same in the English, please, 5.1, "Other Tasks and

14     Assignments."  And it states that in communications and cryptographic

15     protection, repairs were made, objects' malfunctioning was repaired, and

16     that during this period, non-coded dispatches and 152 coded dispatches

17     were received.  Is this much less than was actually needed?

18        A.   Yes, of course.  If you recall, some of the previous reports on

19     the work that you showed yesterday, they encompass the period from the

20     beginning of 1992, and actually a much larger of dispatches involved.  So

21     this is an incomparably lower number in comparison to the first quarter

22     of that same 1992, before the conflict broke out.  So this can indicate

23     what the ratio was.  It's some 10 or 15 times, as far as I can remember

24     these figures.

25             THE ACCUSED: [Interpretation] Can we now please have 0074-9641,

Page 15048

 1     please.

 2             MR. KARADZIC: [Interpretation].

 3        Q.   Do you agree -- let's look at this second paragraph in the

 4     middle.  They're talking about the lack of materiel and technical

 5     equipment, out-dated equipment, worn-out equipment, shortage of spare

 6     parts, and so on and so forth?

 7        A.   Yes, that is all correct.

 8             THE ACCUSED: [Interpretation] Can we briefly have D473.

 9             MR. KARADZIC: [Interpretation]

10        Q.   This is a summary from a working group meeting of the MUP

11     management, held on the 20th of August, 1992, in Trebinje.  Do you recall

12     that this meeting was held in Trebinje?

13        A.   Yes, I do.

14             THE ACCUSED: [Interpretation] Can we now look at English page 3

15     and Serbian page 3 in the document.  Actually, the page bears the

16     number 2.

17             MR. KARADZIC: [Interpretation]

18        Q.   It states at the top that the meeting was chaired by the

19     minister.  In the third paragraph, it says that there was an analysis of

20     the implementation of the conclusions from the previous meeting.  The

21     fourth paragraph talks about removing from the MUP all those who are not

22     at the requisite professional and moral level, and it also states that

23     the army was dealing with combat activities, and the MUP can then carry

24     out its function to fight crime; is that correct?

25        A.   Yes.

Page 15049

 1             THE ACCUSED: [Interpretation] Can we have the following page both

 2     in the English and the Serbian.

 3             THE WITNESS: [Interpretation] Well, can I just add something

 4     else, which is quite a feature?  And these days, this is a discussion

 5     ongoing regarding the change of laws in veterans' benefits, and the

 6     pension and retirement law and so on.  All the policemen who went to the

 7     lines as fighters, when they returned, they didn't have any breaks or

 8     rests, but went back to their regular jobs, so that these people really

 9     were overloaded, not loaded, burdened, but over-burdened, and that was a

10     characteristic feature in that period.

11             THE ACCUSED: [Interpretation] Can we look at page 4 in the

12     English and I think it's also page 4 in the Serbian.  Yes, it's the

13     following page in the Serbian too.

14             MR. KARADZIC: [Interpretation]

15        Q.   Krsto Savic is speaking, and in the second paragraph it states:

16             "Paramilitary groups are present in the area of the CSB but,

17     following the minister's order, this problem was successfully resolved in

18     co-operation with the Army of the Serbian Republic."

19             So now there are remnants of those groups in some areas, like

20     Nevesinje, where such formation used to number up to 200 members.

21             Do you recall that there were arrests, pursuant to my general

22     order and pursuant to the order of the minister, on the ban of military

23     formations, and here we have, at this time in late August, this

24     gentleman, Mr. Savic, reporting that this has already been cleared up, to

25     a large degree, and do you agree with this?

Page 15050

 1        A.   Yes, I remember, and I do agree.  Police even -- and this is

 2     somewhere in the documentation, I think, with the Prosecutor.  There are

 3     lists of members of the police who were leaving the ranks of the police

 4     without returning their uniforms and official IDs, so it had to be

 5     established where they were, what they were doing, and the rest of that,

 6     specifically to prevent such occurrences.

 7        Q.   Well, I'm trying to save time by focusing as much as possible on

 8     your area of expertise.

 9             Thank you.  Can we now have 1D3602.  1D3602.

10             MR. KARADZIC: [Interpretation]

11        Q.   Could you please look at this telegram of the 22nd of October,

12     1992.  It's written by the under-secretary for the National Security

13     Service.  It's dispatched to all the sector of the National Security

14     Service, and it states:

15             "Since the communications system between the SNB and the seat and

16     all SNB sectors is operative, in the future it is necessary that you

17     inform us regularly ..."

18             And so on and so forth.

19             Do you agree that only on the 22nd of October, he could request

20     that regular reports be sent in future, which implicitly means that up

21     until that time, he could not state such requests because the

22     communications were not satisfactory?

23        A.   Yes, I agree.  I believe that this is absolutely correct, because

24     it was in their interest to be able to communicate with everybody.

25        Q.   But you agree that he could ask this only on the 22nd of October?

Page 15051

 1        A.   Yes, I agree, because you can see the date when this telegram or

 2     dispatch was sent.

 3             THE ACCUSED: [Interpretation] Thank you.

 4             Can we admit this?

 5             JUDGE KWON:  Yes.

 6             THE REGISTRAR:  Exhibit D1368, Your Honours.

 7             THE ACCUSED: [Interpretation] Can we now have 1D3603, please.

 8             MR. KARADZIC: [Interpretation]

 9        Q.   Do you agree that on the 15th of December, 1992, this is sent to

10     all the CSBs and the SJBs, and the under-secretary of the SNB?  It's a

11     request by the minister for a report on the work, and then he goes on to

12     state:

13             "Measures and activities aimed at creating and the functioning of

14     the MUP of Republika Srpska, information about the data on personnel ..."

15             Can we have the following page, please.

16             We can look at item B towards the end, the bullet point before

17     last:  To inform him about the number of MUP removed from the MUP they do

18     not meet the criteria for work in the MUP, because of crimes committed

19     before the 4th of April, 1992; 2, for crimes committed after April 4th,

20     1992; and for other reasons making them unfit to work in the MUP organs;

21     and four, because of criminal charges submitted against workers of the

22     MUP of Republica Srpska, property crimes, and so on and so forth.

23             Do you recall that here, at the end of year 1992, he is asking to

24     be regularly informed about how ranks of the police are being cleansed of

25     unsuitable members?

Page 15052

 1        A.   Yes, I agree, that is correct.

 2             THE ACCUSED: [Interpretation] Then the -- if they are talking

 3     about the number of criminal charges submitted, can we have the following

 4     page, please.

 5             MR. KARADZIC: [Interpretation].

 6        Q.   It goes on to Article G.  We need to look at the following page

 7     in the English, total number of crimes, total number of criminal charges.

 8     And then they are talking about the number of criminal reports that were

 9     recorded.  Do you agree that the ministry at the seat was very strict and

10     demanded complete adherence to the Rules of Service and to the law?

11        A.   Yes, that is absolutely correct.  While you were reading these

12     certain points, I just glanced at the rest of the things written, and

13     everything is stated here in the same way it would be during peacetime,

14     plus it takes into account wartime activities of the minister.  Before he

15     became a minister, worked in the Crime Investigation Section of the

16     police, so he's a professional and knows his job.

17             THE ACCUSED: [Interpretation] Can we look at the last page, where

18     we can look at Roman II.

19             MR. KARADZIC: [Interpretation]

20        Q.   Roman II --

21             THE INTERPRETER:  Could we have the reference, please, in the

22     text.

23             THE ACCUSED: [No interpretation]

24             THE INTERPRETER:  Interpreter's note, we would like to have the

25     reference in the text.  The reading is too fast.

Page 15053

 1             JUDGE KWON:  Mr. Karadzic, you were too fast and the interpreters

 2     couldn't follow.  If you could repeat.

 3             THE ACCUSED: [Interpretation] It's the third paragraph, where it

 4     states here:

 5             "In order for the MUP report to be ready in time to be presented

 6     to the Government, Assembly and Presidency of the Republika Srpska, the

 7     centre shall submit reports by the 5th of January, 1993, at the latest.

 8     The chiefs of centres and administrations shall be held personally

 9     responsible for the timeliness and accuracy of data and assessments."

10             MR. KARADZIC: [Interpretation]

11        Q.   Do you agree that the Presidency, the Government and the Assembly

12     were periodically informed about the work of the MUP, as well as briefly

13     about the data according to the questionnaire sent by the minister?

14        A.   Personally, I think that that was, indeed, the case, because

15     these reports had been done before the war to inform the government and

16     other agencies that needed to have them.

17             THE ACCUSED: [Interpretation] Thank you.

18             I would like to tender this document, please.

19             JUDGE KWON:  Yes.

20             THE REGISTRAR:  Exhibit D1369, Your Honours.

21             JUDGE KWON:  And I would like to tell you that your time is

22     almost up.  You have about 10 minutes, or 15, so try to finish it as soon

23     as possible.

24             THE ACCUSED: [Interpretation] Thank you.

25             I will try to do that.  But before that, I'd like to show

Page 15054

 1     65 ter 04250 and ask the witness to mark this map; in fact, to mark the

 2     deployment of infrastructure.

 3             MR. KARADZIC: [Interpretation]

 4        Q.   Would you please take a look at this map, Witness, and then I

 5     will show you another one so that you can tell us which one would make it

 6     easier for you to mark, to show the main nodes or centres, and what you

 7     had to reconnect?

 8             Now, could we have D484?

 9             But in the meantime, are you familiar with this map?  This map

10     shows the ethnic distribution?

11        A.   Well, yes, it is familiar.  I don't know what period this relates

12     to.

13        Q.   It relates to 1991.  It's from the census of 1991.  But are you

14     aware that the fighting actually followed these ethnic lines?

15        A.   Well, yes, for the most part.

16             THE ACCUSED: [Interpretation] Can we now have D484, please.

17             And could the witness be assisted with the electronic pen,

18     please.

19             MR. KARADZIC: [Interpretation]

20        Q.   Now, would it be easier for you to mark this map to show the

21     centres, the main nodes, the communication nodes, and the main relay

22     stations on it?

23             Could the Usher please assist the witness with the electronic

24     pen.

25        A.   Well, I will give you a brief reply.

Page 15055

 1             All the networks, both telephone and teleprinter networks, had

 2     the node.  The main node was in Sarajevo, at the Telecommunications

 3     Centre building.  Such telecommunications centres existed in all regional

 4     centres, in other words in Banja Luka, Bihac, Prijedor, Livno, Mostar,

 5     Tuzla, Gorazde; in other words, in 10 centres.  If, in Banja Luka alone,

 6     and Doboj, and of course Prijedor too, but at this time point in time

 7     Prijedor was just a public security station, now all of those facilities

 8     were controlled by Serbs, but in all other areas and, crucially, in

 9     Sarajevo, which was the main node from which all the communications

10     spread out to all other centres in the republic, and also towards other

11     republics and federal institutions, all of those were controlled by the

12     other side.  So simply put, by simply plugging out these systems in

13     Sarajevo, they could disable all of these centres.  So it's really

14     completely irrelevant what -- where these -- all of these lines -- or how

15     they ran, along which routes, because that's really just a secondary

16     issue, because they were able, both in peacetime and also in wartime, to

17     disable all those communication by plugging them out from Sarajevo.  So

18     they kept their own communications live, whereas they plugged or cut off

19     the communications controlled by Serbs.

20             Now, I don't know if you need me to mark this.  I could, but this

21     is my explanation.

22        Q.   Well, I would like to -- I would like you to mark it.  But would

23     it be easier to use the other map, the ethnic map, as it were?  Could you

24     just show us the routes that the communications ran?  Could you please

25     put little squares to indicate the main nodes, and mark the ones that

Page 15056

 1     were under the control of the Muslims in red, and in blue for the ones

 2     controlled by the Serbs?

 3        A.   Well, here we have Sarajevo, Mostar.  They had them [marks].

 4     Bihac, let me find it.  Bihac [marks].  Tuzla [marks], Gorazde [marks],

 5     Livno [marks], Zenica [marks].  All of these centres were -- remained in

 6     their -- under their control.

 7        Q.   Thank you.  Now, would you please use the blue pen to mark what

 8     remained under our control?

 9        A.   Well, here it is.  It's Banja Luka [marks], Prijedor [marks], and

10     Doboj.  Let me see where that was.  Yeah, here it is [marks].  However,

11     all the rest that was part of the Serbian territory was connected or

12     linked up to the centres that were under their control.  Now, I don't

13     know what colour pen I should use to show that.  But, for instance,

14     Trebinje, the entire area of Stari Herzegovina all the way to Trebinje,

15     was linked up to Gorazde and Mostar.  Brcko, Bijeljina, Zvornik,

16     Bratunac, all of that was linked or gravitated towards Tuzla; in other

17     words, the entire area of Central Bosnia.

18        Q.   Could you indicate these areas by marking them with arrows?

19        A.   Well, for instance, here, Trebinje [marks].  I didn't quite get

20     it, but it doesn't really matter.  All of these municipalities here were

21     linked up to Mostar.  The ones here, they gravitated towards Gorazde,

22     they links in Gorazde [marks], these municipalities around here, Rudo,

23     Visegrad.  Now, Rogatica was linked with Sarajevo [marks].  All areas

24     around Brcko, Bijeljina, Zvornik, they were connected or linked up with

25     Tuzla, including Srebrenica, Vlasenica and so on [marks].  Well, I don't

Page 15057

 1     even have to mark Bihac because that was, anyhow, territory under the

 2     control of that side.

 3        Q.   What about the Serb municipalities of Petrovac, Drvar, Kljuc?

 4     Where did they have their links?

 5        A.   Well, in part, they had links in Banja Luka and in other -- and

 6     part of them had links in Bihac.  I am not absolutely certain, but in any

 7     case, they were linked up to areas, to centres that were under their

 8     control.

 9        Q.   And Glamoc and Grahovo?

10        A.   Well, they were connected and linked up to Livno.

11        Q.   Thank you.  Would you please date and sign this map?

12        A.   [Marks]

13             JUDGE KWON:  Thank you.  We'll admit this.

14             THE REGISTRAR:  Exhibit D1370, Your Honours.

15             THE ACCUSED: [Interpretation] And the last document.  I would

16     appreciate the understanding of the Prosecution.  This is a document that

17     was not on the list, but it's 65 ter 18342.  And perhaps we can mark it

18     for identification, because we don't have a translation, but we would

19     like to use this document as it arose from something the witness said,

20     and we would like to take advantage of this witness being here.  So,

21     that's 65 ter 18342, could we have it, please?

22             MR. KARADZIC: [Interpretation]

23        Q.   Would you agree that this is a meeting of an expanded session --

24     or, rather, minutes from an expanded meeting of the

25     Professional Collegium of the Ministry of the Interior, and we see here

Page 15058

 1     that your name is mentioned in the third line from the bottom, where a

 2     list is given of the participants?

 3        A.   Yes.

 4        Q.   Since we don't have a translation, I'll have to read this slowly.

 5             We can see here that part of the session was attended by the

 6     counsel to the minister, Kusmuk, the commander, Karisik and so on.

 7             Now, could we have the third page, please.

 8             By the way, did you know these people, Kusmuk and

 9     Milenko Karisik?

10        A.   Yes.

11        Q.   Was Milenko Karisik the deputy commander of the joint

12     Special Brigade, the commander of which was Dragan Vikic?

13        A.   Yes.

14        Q.   As far as you know, was Karisik, Milenko, a very strict man when

15     it came to conditions for those who wanted to join his unit?

16        A.   Yes.

17             THE ACCUSED: [Interpretation] Could we now take a look at the

18     third paragraph from the top, where Trebinje is mentioned and it says:

19             "We have to resolve all our weaknesses ... "."

20             And it says:

21             "It was emphasised one more time that only those individuals who

22     met the legal requisites to work in the organs of the interior can become

23     members of the service, and we have to rid our ranks of those individuals

24     who committed acts, that they should not be -- deliberately committed

25     acts which were not legitimate."

Page 15059

 1             Now, there is an error in the transcript.  There is Dragan Vikic,

 2     that's the name, and do you agree that he was the commander of the joint

 3     brigade, he was a Muslim, and Milenko Karisik was his deputy.

 4        A.   That's correct, and I believe this was called the

 5     Special Detachment of the Republic SUP, and the commander was Vikic.

 6        Q.   Thank you.  Can we see from this paragraph that Milenko Karisik

 7     did not allow criminals to join his unit, and that he stressed that in

 8     this meeting, which you attended as well, and it was re-affirmed that

 9     this was the position, that the police should always be rid of such

10     individuals?

11        A.   Well, yes, we can see it from this text.

12             THE ACCUSED: [Interpretation] Can we now have page 6.  I'm not

13     exactly sure.  That's AD-2.

14             MR. KARADZIC: [Interpretation]

15        Q.   In the first paragraph, it says:

16             "The minister also ordered that, like what was done in the SJB in

17     Zvornik, rigorous action be taken against chiefs of SJBs, including

18     dismissals, if so necessary, because of their failure to report to CSB

19     and MUP."

20             Does this show that the minister was completely reliant on the

21     information that he received and that there were some errors in the

22     reporting system; in other words, that the minister was misinformed at

23     some times?

24        A.   Yes, there were such instances as well, and it is also true that

25     he was completely dependent on what was being reported to him from the

Page 15060

 1     field.

 2        Q.   And it would appear that those people did not really report their

 3     own errors; correct?

 4        A.   Well, most probably so, as we see that he was upset about it.

 5        Q.   Thank you.  And then under "AD-2," Minister Stanisic describes

 6     why it was necessary to establish a Special Brigade of the police,

 7     bearing in mind that the state is being established, and that in wartime

 8     conditions, there is an emergence of destructive forces which are

 9     attempting to subvert it, and so on and so forth.  And he explains that

10     this is why the Special Brigade had to be established.

11             Now, do you remember whether this Special Brigade arrested

12     members of paramilitary units in Zvornik, but also elsewhere?

13        A.   Yes, I remember that.

14        Q.   It would appear, based on that, that Minister Stanisic had

15     established the Special Brigade because it was necessary to support law

16     and order on the territory of Republika Srpska?

17        A.   That's correct.

18             THE ACCUSED: [Interpretation] Thank you.

19             Can we have the next page, please.

20             MR. KARADZIC: [Interpretation]

21        Q.   Here we see that there's a proposal to review all the

22     registrations of vehicles because there were cases of vehicle thefts, and

23     then there is also mention that there is general chaos in this respect.

24     And then in the third paragraph, it says that:

25             "The chiefs of CSB are also duty-bound to make a complete list of

Page 15061

 1     the entire property of the MUP and to do a review from the beginning of

 2     the war of all the items that had been seized, especially money and

 3     valuables.  And then it says:

 4             "At the proposal of the chief of the Administration for

 5     Communications and Encryption, we support the organising of a course for

 6     training personnel for encryption."

 7             Were you the chief of that administration?

 8        A.   Yes.

 9        Q.   Why were such courses necessary?

10        A.   Well, precisely because we didn't have enough men who could

11     encode messages, written messages as well as all others.

12        Q.   And we're talking about the 5th of November, 1992, right, in this

13     document?

14        A.   Yes, that's correct.

15             THE ACCUSED: [Interpretation] Thank you.

16             Can we have the next page, please.

17             JUDGE KWON:  Mr. Karadzic, it's time for you to conclude.

18             THE ACCUSED: [Interpretation] Your Honour, I just have one or two

19     questions related to this document, and then I will be done.

20             MR. KARADZIC: [Interpretation]

21        Q.   Here, under paragraph 4, in the second paragraph we see that

22     there were questions from certain SJBs whether it was allowed to --

23     whether citizens were allowed to change their first and last name,

24     citizens of non-Serb nationality, and it was concluded that in such

25     cases, one should act according to the law, and that the SJB should have

Page 15062

 1     special record-keeping in such instances.  So there were instances where

 2     people wanted to change their names, correct, and it was required that

 3     that should be done according to the law; correct?

 4        A.   Yes.

 5             THE ACCUSED: [Interpretation] Well, we don't -- I don't have any

 6     other questions.

 7             I would like to tend this document, please.

 8             MR. GAYNOR:  Sorry.

 9             THE ACCUSED: [Interpretation] And perhaps we can just put an MFI,

10     pending its translation, unless Mr. Gaynor has it.

11             MR. GAYNOR:  Just a couple of observations.

12             No objection to its MFI'd.  This document wasn't on the list, nor

13     was D447, and I think we had about 12 or 13 pages of cross-examination

14     about D447.  So we would request notification, even if it's by late

15     evening, of additions like this.  Thank you.

16             JUDGE KWON:  Very well, thank you.

17             We'll mark this document for identification.

18             THE REGISTRAR:  As MFI D1371, Your Honours.

19             MR. KARADZIC: [Interpretation] Mr. Kezunovic, thank you very

20     much, and may I just say that I am sorry that we haven't met before.

21             THE WITNESS: [Interpretation] Thank you, too, and good luck.

22             JUDGE KWON:  Yes, Mr. Gaynor.

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

24             First of all, could I call up P2765.

25                           Re-examination by Mr. Gaynor:

Page 15063

 1        Q.   Mr. Kezunovic, earlier today you were asked a few questions about

 2     this document which you'll see on the screen in front of you, and the

 3     question was put to you as follows:

 4             "This person who wrote this said that he wasn't able to have good

 5     communication, even though everything was quite close; isn't that

 6     correct?"

 7             And your answer, you said that:

 8             "Yes, that is correct."

 9             And then you went to point out that his location was at Lukavac,

10     and he could see Ilidza, but he couldn't get to it.  "He needed half a

11     day to go 'round to reach Ilidza, and I don't even want to talk about

12     Ilijas, the other municipalities."

13             Do you recall that exchange?

14        A.   I do.

15             MR. GAYNOR:  Could we look at the bottom of page 2 in English,

16     going on to the top of page 3 in English.  And if we could look at the

17     bottom of page 2 in B/C/S.

18        Q.   Now, do you see a reference there to communications between this

19     CSB and the Sarajevo Romanija Corps?

20        A.   Which line is that?

21        Q.   It's halfway down the page in your version.  It's the third-last

22     paragraph, the fourth-last paragraph.

23        A.   I can see it.

24        Q.   So you accept that this CSB was in contact with the

25     Sarajevo Romanija Corps?

Page 15064

 1        A.   This does not mean that this was -- how do you mean; in contact,

 2     physically, that somebody would go to the command, or are you thinking of

 3     links, communications?

 4        Q.   Communications links.  There were communications links?

 5        A.   No, they didn't have that, they didn't have communication.  What

 6     it says here, that they handed over such and such a number of written

 7     documents.  It was either delivered by courier or some other way.  You

 8     can see that it says that some information was also given orally.

 9             MR. GAYNOR:  That's correct.

10             If we could go to the next page in English.  We can stay on the

11     same page in B/C/S.

12        Q.   Now, at the top of this, we see a reference to:

13             "100 written and a significant number of oral reports to the

14     units in the field (Vogosca, Ilijas, Ilidza, Hadzici, Pale, Sokolac and

15     Han Pijesak)."

16             Do you see that?

17        A.   I see that.

18        Q.   Do you, therefore, accept, yes or no, that there was, in fact,

19     communication from this CSB to Ilijas and Ilidza, as well as the other

20     areas mentioned?

21        A.   I have to say, just briefly, that communication did exist, but

22     it's a question of at which point it was working and at which point it

23     wasn't, for the different reasons that I cited during the testimony;

24     power cuts, something that broke down, things like that.  If everything

25     was working, in principle, within the municipality, there was

Page 15065

 1     communication, but that does not mean that this was available

 2     continuously at all times.  Especially in this area, a lot of power cuts

 3     occurred, and that would be enough to knock the communications out.

 4        Q.   I'd like to move to another point, and that is -- at pages 18 and

 5     19 today, you were shown a document signed by the minister on the 22nd of

 6     October, 1992, and a question was put to you:

 7             "Do you agree that only on the 22nd of October, he could request

 8     that regular reports be sent in future, which implicitly means that up

 9     until that time he could not state such requests because communications

10     were not satisfactory?"

11             And you said that you agreed, and you believed that to be

12     absolutely correct.

13             Do you remember that exchange?

14        A.   I do.

15        Q.   Now, yesterday you described for us - this was at pages 14950 to

16     14951 - the process by which the daily bulletins were issued by the

17     minister, and you said that:

18             "The bulletins which during the previous 24 hours covered the

19     events would be sent by the Public Security Station officials and

20     combined into one report which would be sent to their superior security

21     centre, which put it all together into one report and sent it to the

22     ministry at the headquarters."

23             Do you recall your evidence about that?

24        A.   I do, although this translation is a little bit confusing.  But I

25     understand the sense; I agree with that.

Page 15066

 1        Q.   Essentially, you're telling us that the SJBs would communicate

 2     reports to the CSBs, and the CSBs would collate the information within

 3     their area of operation and provide that to the ministry?  Is that a

 4     reasonable summary?

 5        A.   Well, I explained that for these problems, the Analysis and

 6     Information Administration was in charge of.  This is not my area.  As

 7     for communications links, I recognise elements in the dispatch, and I

 8     confirm that and I draw possible conclusions.  I explained that several

 9     times already.  I don't know what was instructed in the minister's

10     dispatch, whether the Public Security Stations should directly report

11     back or should they sent a report to the centre, and then the centre

12     would put them all of them together and send them to the MUP.  I don't

13     know that.  I don't know, I don't remember what the original source

14     dispatch from the minister said.  If there was an order for each station

15     to send back a report, then that's probably how it was done.  If it was

16     ordered by the stations to send their reports to the centres, for the

17     centres then to make a collective report and send it to the ministry,

18     that's probably how it was done.  It was done as ordered.  So now I

19     really don't remember what the original dispatch by the minister said,

20     even though you showed it, but I didn't really pay attention.  As far as

21     I'm concerned, this is of lesser importance.  The important thing is for

22     the information to reach their destination.  Of lesser importance is the

23     type of organisation, you understand.

24             THE ACCUSED: [Interpretation] May I assist?

25             MR. GAYNOR:  Well, I'd prefer to carry on, if I may,

Page 15067

 1     Mr. President.

 2             JUDGE KWON:  Just what is it?  You were going to object to

 3     something, Mr. Karadzic?

 4             THE ACCUSED: [Interpretation] It's an objection, because we're

 5     talking about state security here, but Mr. Gaynor continues to ask about

 6     public security.  These are two separate services.

 7             JUDGE KWON:  Not helpful.

 8             Please carry on, Mr. Gaynor.

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

10        Q.   Mr. Kezunovic, yesterday you were shown a series of daily reports

11     issued by the minister, starting, I think, with Report 3 and going up to

12     Report 109, 111, 113.  Do you remember that?

13        A.   I do remember, but the reports were not drafted by the minister,

14     but by the Administration for Analysis and Information Affairs, and they

15     acted pursuant to the instructions by the minister.  They didn't send

16     anything back to the minister because there are two situations.  One is a

17     collation of everything that happened during a certain period, and then

18     this is sent in order to make a kind of report.  The second thing is

19     sending a report on any kind of event of interest, from the intelligence

20     point of view, and that is something that is reported upon immediately in

21     order for action to be, perhaps, taken.

22             You understand, if something happened, anything which was of

23     interest in the security sense, then perhaps it's necessary for some unit

24     to intervene in the field, and a report about that is sent immediately.

25     That later, then, is included in the general overview in the bulletin.

Page 15068

 1     The bulletin is just a collective review of all the events that happened

 2     over a certain period of time.  It's not an operative document.

 3        Q.   Now, the bulletins which you were shown yesterday, dated mainly

 4     from April and May of 1992, and as we saw yesterday, they covered events

 5     taking place in municipalities falling within the area of responsibility

 6     of Banja Luka CSB as well as Bijeljina CSB and other CSBs.  Do you

 7     remember that?

 8        A.   I do.

 9        Q.   So at least during the early months after the establishment of

10     the RS MUP, there was capacity for those reports to be drafted at the

11     seat of the MUP, in accordance with the procedure you've described; is

12     that right?

13             MR. ROBINSON:  Objection.  Leading.

14             JUDGE KWON:  Yes.  Could you reformulate?

15             MR. GAYNOR:  I'll reformulate, Mr. President.

16        Q.   During that period, April and May of 1992, Mr. Kezunovic, was

17     there, yes or no, capacity for the CSBs in Banja Luka and Bijeljina and

18     elsewhere to provide information to the seat of the ministry for

19     insertion into the daily report?

20        A.   Again, I'm repeating the same thing.  I cannot answer with a yes

21     or no, because, in principle, they can, but there were countless problems

22     for each specific day, so I don't know whether they were able to deliver

23     that for each specific day, because you could see in a lot of the

24     documents, only two centres provide reports and some information and

25     three of them do not for that particular day.  I don't know if they

Page 15069

 1     provided the documents the following day, the third day, the fourth day,

 2     whenever they were able to.  That is something that I don't know.  I

 3     wasn't really monitoring them.  All I can do is to interpret what is

 4     written in the document.  You could see that two delivered and three did

 5     not, and that is something that I can say for each document.  But the

 6     general conclusion as to whether it could have been, perhaps it could

 7     have been, but perhaps it could have not.  I repeat, there were countless

 8     problems, combat actions, power cuts, failures, and sometimes it was true

 9     that communications were not working continuously along all directions.

10     Sometimes there were interruptions, so it's difficult to give a general

11     assessment.  It's much easier to give an answer for each specific case,

12     even with a yes or no.

13        Q.   Finally, I'd like to clarify one small point.

14             Yesterday, at page 14995, a couple of questions were put to you

15     about the log-book of Prijedor SJB, which was the first exhibit you were

16     shown during your direct, and the question that was put to you was:

17             "Would you agree that everything that was received by Prijedor

18     was from its immediate vicinity, Banja Luka, Bosanski Novi, and so on?"

19             And then you went on to give your answer about that.

20             I want you to clarify for Their Honours that after the

21     establishment of the RS MUP, was Prijedor a CSB or was it an SJB?

22        A.   I think it was an SJB, a public security station.

23        Q.   And was it the practice, generally speaking, for an SJB in the

24     Krajina to communicate directly with entities over in Eastern Bosnia?

25     Was that the general method by which SJBs would give their information to

Page 15070

 1     the minister?

 2        A.   I don't know now.  I don't understand the question.  What does it

 3     mean, "over in Eastern Bosnia," and then you mention the minister?  In

 4     which context?

 5        Q.   I'll reformulate my point.

 6             You've explained already the process by which SJBs would provide

 7     reports to CSBs, and CSBs would then provide a collated report to the

 8     minister.  My question is this:  Would you ordinarily expect an SJB

 9     located within the area of responsibility of Banja Luka CSB, such as

10     Prijedor SJB, would you ordinarily expect that level of police station to

11     be in direct contact with, for example, SJBs in Eastern Bosnia or with

12     the seat of the ministry in Pale?

13        A.   Well, I don't know why they would do that.  That's why there was

14     an organisation of the ministry in the way that it existed, so that

15     everything was resolved in the way that if something happened in the

16     field, first of all, it happened in the territory of some public security

17     station area, regardless of whether there was a CSB in that town.  The

18     SJB was in charge, primarily, of maintaining law and order, dealing with

19     crimes and things like that that are under the jurisdiction of the MUP.

20     The SJB is in charge of things like that first.

21             Since a problem could have something to do affecting the

22     neighbouring municipalities, the organisation is set up in such a way

23     that the CSB is in charge of co-ordinating things like that.  It

24     co-ordinates within a region.  If co-operation between two SJBs is

25     required, which are, for example, in different regions, for example, one,

Page 15071

 1     let's say belongs to Bijeljina and the other one belongs to Doboj, but

 2     they are boundary, neighbouring stations, but from two different regions,

 3     then the matter has to be also carried through to the authorised CSBs.

 4     Because they are better equipped, they have better trained personnel,

 5     police crime investigation inspectors and other experts.  And in that way

 6     the manner of communication is set up in such a way that the stations

 7     exclusively communicate to the centres, and the centres communicate with

 8     the ministry, because the ministry is at the top of that overall problem

 9     matter along the lines of work.  It doesn't make sense for the Trebinje

10     SJB to be sending something to the Gradiska SJB unless they are, for

11     example, providing the name of the owner of a vehicle who comes from

12     Trebinje and has created a problem in Gradiska.  Only things like that

13     were resolved directly among the municipalities.  Otherwise, it all went

14     up to the CSBs.

15             MR. GAYNOR:  Thank you, Mr. Kezunovic.  No further questions.

16             Thank you, Mr. President.

17             JUDGE KWON:  Thank you.

18             Thank you, Mr. Kezunovic.  That concludes your evidence.  On

19     behalf of this Chamber and the Tribunal, I thank you for your coming to

20     the Tribunal to give it.  Now you are free to go.

21             THE WITNESS: [Interpretation] Thank you.

22             JUDGE KWON:  We'll rise all together.  It's time to have a break.

23     We'll resume at 11.00.

24                           [The witness withdrew]

25                           --- Recess taken at 10.30 a.m.

Page 15072

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

 2             JUDGE KWON:  Yes, Mr. Robinson.

 3             MR. ROBINSON:  Yes, Mr. President.

 4             I'm sorry to disturb you.  I wanted to advise you of some

 5     developments that had taken place with respect to Mr. Ristic.

 6             And we have filed, a few minutes ago, the 52nd motion for finding

 7     of disclosure violation and a motion to exclude his testimony entirely.

 8     The most recent developments is that today, the Prosecution has informed

 9     us that they neglected to disclose to us two statements of this very

10     witness, Mr. Nebojsa Ristic, which were taken by the Ministry of Interior

11     of the Republika Srpska and which we suspected, from the interview, may

12     have been in the possession of the Office of the Prosecution.  This is

13     another violation of Rule 66(A)(2), and one which the Prosecution has

14     conceded in their response to our 51st motion.  So this will affect our

15     preparation, obviously.

16             But more so than that, we think that this is -- the time has come

17     where the Chamber has to do something more than put a Band-Aid on a small

18     cut, because these disclosure violations are pouring in at an

19     unprecedented rate, well after your final dead-line for disclosure, and

20     we simply can't continue to operate this way.

21             I know if that if we hustle and scratch around, we can find a few

22     extra hours to accommodate these violations, but it's completely unfair

23     for a trial to be conducted in this manner, where the burden is on us to

24     interrupt our preparation, to scramble around, when the Prosecution is

25     responsible entirely for unjustified and inexcusable violations of the

Page 15073

 1     rules of disclosure.

 2             Thank you.

 3             JUDGE KWON:  Thank you.

 4             I take it, Mr. Tieger, that you are minded to file your response

 5     in writing.

 6             MR. TIEGER:  Mr. President, these interviews are dealt with in

 7     the response we just filed.  What Mr. Robinson is aware of, and fails to

 8     mention, or at least I believe he's aware of it, is that these interviews

 9     are irrelevant to the events during the indictment period and are of a

10     very -- relatively short nature.  In any event, it's dealt in the motion,

11     the need for oral submissions to supplement the written filing is

12     difficult to see, as is the stridency of the language used in the

13     submission, so the Court will see what this matter is about in the filing

14     that was made earlier this morning.

15             JUDGE KWON:  So you'll not respond to this separately?  All we

16     have to do is to read your response?

17             MR. TIEGER:  I'm happy to look at it again to see if any further

18     information for the Court is necessary.  But as I say, we dealt with it

19     in the filing.  I think that will be sufficient.  If further information

20     appears necessary, we'll let the Court know right away.

21             JUDGE KWON:  So if there's anything for you to raise, then do it

22     by the close of business today.  Thank you.

23             Before we bring in the witness, shall we go into private session

24     briefly.

25                           [Private session]

Page 15074











11  Page 15074 redacted. Private session.















Page 15075

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 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17                           [Open session]

18             JUDGE KWON:  Yes.  Let's bring in the next witness.

19                           [The witness entered court]

20             JUDGE KWON:  Good morning, sir.

21             If you could take the solemn declaration, please.

22             THE WITNESS: [Interpretation] Just a moment, please.

23             JUDGE KWON:  Take your time, sir.

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

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

Page 15076

 1                           WITNESS:  RANKO VUKOVIC

 2                           [Witness answered through interpreter]

 3             JUDGE KWON:  Thank you.

 4             Please be seated.

 5             THE WITNESS: [Interpretation] Thank you.

 6             JUDGE KWON:  Mr. Gaynor from the Prosecution will ask you some

 7     questions.

 8             Yes, Mr. Gaynor.

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

10                           Examination by Mr. Gaynor:

11        Q.   Good morning, sir.

12        A.   Good morning.

13        Q.   Could you state your full name, please?

14        A.   My name is Ranko Vukovic.

15        Q.   You've previously testified for this Tribunal in the trial of

16     Mico Stanisic and Stojan Zupljanin; is that correct?

17        A.   That's correct.

18        Q.   You've previously met with members of the Office of the

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

20        A.   That's right.

21        Q.   You've reviewed an amalgamated statement containing relevant

22     portions of your testimony from the Stanisic and Zupljanin case, as well

23     as other information that you've provided to the Prosecution; is that

24     true?

25        A.   That's true.  However, I would like to take this opportunity to

Page 15077

 1     say that all the statements were shown to me in the English language, and

 2     I only speak Serbian, and this although I requested that I be provided

 3     these statements in my mother tongue.

 4        Q.   Was the amalgamated statement read back to you in a language that

 5     you understand?

 6        A.   Yes, they were read back to me, but there were some issues in one

 7     part of the statement with the word "ostali," because that word can

 8     have -- its meaning is twofold in our language.  It can mean -- it can

 9     relate to a person and others or it can be a verb where it would mean "we

10     remained" in a certain area.  The same word would be used in Serbian.

11     Subsequently, when I checked the text, I realised that that word remained

12     in the text of my statement.

13        Q.   Did you have an opportunity to consult with someone who speaks

14     both English and B/C/S as to the form of the translation used in your

15     statement?

16        A.   When I was interviewed at the Office of the International

17     Criminal Tribunal for the former Yugoslavia in Sarajevo, in Nedzarici, I

18     requested that the interpreter provided be from my own nation, that that

19     person speak Serbian.  However, because of some personal reason, that

20     personal could not attend, so that I had an interpreter who was of

21     Bosniak ethnicity.  They said that that word in part of my statement was,

22     in fact, quite appropriate, as far as the structure of the sentence was

23     concerned.  However, I requested that it be checked because this word,

24     "ostali," which can mean either "the others" or "to remain," that it

25     should be -- that it should actually remain, because if it was skipped

Page 15078

 1     and taken out, that then it would completely alter the sense of the

 2     sentence, and this in context of an order which was issued on the 29th of

 3     April, 1992, by the commander of the then BH Army -- or, rather, the

 4     BH TO, Territorial Defence, Mr. Hasan Efendic.

 5             MR. GAYNOR:  Your Honours, perhaps the easiest way to clarify the

 6     position would be to bring up the document in question and ask the

 7     witness to clarify which word he's referring to.

 8             JUDGE KWON:  Very well.  Which paragraph is he referring to?

 9     Let's bring up the document?

10             MR. GAYNOR:  It's 65 ter 22912.  This particular exhibit is

11     discussed by the witness on page 33 of his statement.

12        Q.   Now, Witness, you see the order of Hasan Efendic in front of you,

13     do you?

14        A.   Yes, I do.

15             JUDGE KWON:  Before we proceed, could you -- you said page 33 of

16     his amalgamated statement.  Do you know which part he is referring to?

17             MR. GAYNOR:  Your Honours, I'm somewhat unclear, but I believe

18     the translation difficulty might arise out of the document, itself.  It's

19     not a translation difficulty in the statement.  But I'm hoping to clarify

20     that with the witness right now, that the word which was in discussion

21     between the interpreter and the witness appears in the document.

22             JUDGE KWON:  Very well.  Let's first proceed with this document.

23     I leave it in your hands.

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

25        Q.   Mr. Vukovic, do you see in this document the reference that

Page 15079

 1     you're concerned about?

 2        A.   That word does not appear in the document, itself.  However,

 3     during the interview and during the investigation, a question was put to

 4     me where I was asked to explain a sentence, where I replied -- in reply

 5     to the question, I said that we remained as part of the communications

 6     system of the former Territorial Defence and BH Army, so that they were

 7     able, in all the documents that they sent to their subordinate units in

 8     the period of the month of April and May, if those messages were sent to

 9     all units, then we would have received them at our centre at Pale.  In

10     other words, we remained within their system of communications, remained,

11     "ostali".

12        Q.   Thank you, Mr. Vukovic.  The reference is, in fact, from the

13     middle of the witness's statement, page 33, and perhaps I can read the

14     words to you, Mr. Vukovic.

15             JUDGE KWON:  Why don't we bring it up.

16             MR. GAYNOR:  Yes.  I'm sorry, it's -- 90245 is the 65 ter number,

17     and if we can go to page 33.

18        Q.   Perhaps, Mr. Vukovic, I will read the question to you and I will

19     read the answer to you, and then you can make whatever clarifications

20     necessary.  Is that all right?

21        A.   All right.

22        Q.   The question is as follows:

23             "Let's just clarify one thing.  That communications centre, that

24     belonged to the city of Sarajevo, with which you were linked, as you say,

25     that was under the control of the Muslim forces; right?"

Page 15080

 1             Your answer reads as follows:

 2             "When we were part of the line of command of the city centre,

 3     that was before the conflict started.  In 1992, in the month of April, we

 4     remained linked with the same city centre, and we could still communicate

 5     with them freely."

 6             That's the end of the quote.

 7             Would you like to clarify your answer in any way?

 8        A.   Well, that was the tendency of my explanation.

 9             On the critical day, when that order was sent from the

10     teleprinter of the republic centre for communications and encryption and

11     monitoring and information, from the Executive Council building, or,

12     rather, from the Republican Secretariat of National Defence, as it was

13     called at the time, from a teleprinter machine which was on the 14th

14     floor, a TX-100, manufactured by EI Nis, we received that order because

15     it was sent to a number of different addressees.  And in that way, we

16     received it as well, it found its way to our desks at our centre.  At the

17     time, the communications were still intact, the communications between

18     all of those different users which had been part of the Republic

19     Secretariat of National Defence.  So the communications had still been

20     intact, and in this way we received that order at Pale as well.  And I

21     believe this is sufficient, by way of explanation.

22        Q.   Thank you, Mr. Vukovic.  If we look at the first page of your

23     amalgamated statement, please.  Is that your signature on the first page?

24        A.   Yes.

25        Q.   As we've discussed previously, there is a typographical error.

Page 15081

 1     It says that you reviewed this statement on the 23rd and 24th of May,

 2     2011, and we have to correct that, because you reviewed this statement on

 3     the 23rd, the 24th, and the 25th of May, 2011; is that correct?

 4        A.   Yes, that's correct.

 5        Q.   As I discussed with you previously, I want to note two minor

 6     typographical errors.

 7             Paragraph 77 refers to 65 ter 29798.  The correct number is

 8     65 ter 21798.

 9             Second, footnote 115 that's on the page we were looking at

10     earlier refers to 65 ter 22910 --

11             JUDGE KWON:  Just a second.  Did you say page 67?

12             MR. GAYNOR:  Sorry, the first erratum refers to paragraph 77.

13     The second refers to footnote 115.  That refers to 65 ter 22910.  The

14     correct number is 22912.

15        Q.   Subject to the clarification that you provided to the Court, and

16     to the three typographical corrections we've just made, do you adopt the

17     amalgamated statement as your evidence?  And if you were questioned today

18     about the same issues, would you provide the same information to the

19     Trial Chamber?

20        A.   Yes.

21             MR. GAYNOR:  Mr. President, I propose -- first of all, I would

22     like to tender the statement, and I would propose to read a summary of

23     it.

24             MR. ROBINSON:  No objection.

25             JUDGE KWON:  Thank you.  That will be admitted.

Page 15082

 1             THE REGISTRAR:  As Exhibit P2794, Your Honours.

 2             MR. GAYNOR:  Thank you.

 3             Ranko Vukovic was the chief of the Republic Communications Centre

 4     in Pale for the duration of the 1992-to-1995 conflict.

 5             JUDGE KWON:  For the public, what you're doing is reading out the

 6     summary of his evidence.

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

 8             JUDGE KWON:  Thank you, Mr. Gaynor.

 9             MR. GAYNOR:  The primary purpose of the Republic

10     Communications Centre was to provide oral and written communications

11     links to civilian authorities in Pale, including the RS Presidency,

12     Assembly and Government.  The Republic Communications Centre was equipped

13     with telephone lines, switchboards, teleprinters, fax, radio and

14     radio-relay equipment.  It also used couriers.

15             Radovan Karadzic's office in Pale was connected to the Republic

16     Communications Centre by a secure telephone line.  Mr. Vukovic describes

17     the methods used to keep the Republic Communications Centre in contact

18     with the regional communications centres.  The Republic

19     Communications Centre was connected to the VRS Main Staff

20     Communications Centre by radio relay and by the PTT network.  The VRS

21     Main Staff Communications Centre was located in a former JNA facility

22     situated deep underground in Crna Rijeka, near Han Pijesak.  The

23     transmitters for the Crna Rijeka Communications Centre were located on

24     Veliki Zep, a hill above Crna Rijeka.  Communications from Pale to

25     various parts of territory under Bosnian Serb control were routed through

Page 15083

 1     the VRS Main Staff Communications Centre at Crna Rijeka.

 2             Maintenance teams for the VRS 67th Communications Regiment at

 3     Han Pijesak would come to repair the Republic Communications Centre's

 4     equipment as necessary and very quickly.  The system functioned well

 5     during the war.  Mr. Vukovic identifies communications sent from Karadzic

 6     to the VRS Main Staff using the link from the Republic

 7     Communications Centre to the VRS Main Staff Communications Centre at

 8     Crna Rijeka.  He also identifies documents sent from Crna Rijeka to other

 9     locations, such as the commands of the corps of the VRS.  It was usually

10     possible for the Republic Communications Centre to connect Karadzic to

11     whomever he wished to contact.  Karadzic's office also sometimes used the

12     RS MUP communications network and had access to its own couriers.  The RS

13     MUP Communications Centre in Pale was separate from the Republic

14     Communications Centre and used a separate communications system, but the

15     Republic Communications Centre assisted the RS MUP organs with their

16     communication if they were having difficulty with their own system.

17     Mr. Vukovic provides his comments on a selection of documents, including

18     communications between the Presidency and the VRS Main Staff, as well as

19     communications log-books and documents sent by the RS MUP communications

20     system in 1995 concerning security for convoys containing Karadzic.

21             That ends the summary for the benefit of the public.

22             I want to return briefly to two points arose in that summary, but

23     they're listed in your statement.

24        Q.   Could you describe very briefly, Mr. Vukovic, the relationship

25     between the RS MUP Communications Centre in Pale and your centre, the

Page 15084

 1     Republic Communications Centre?

 2        A.   The Communications Centre of the MUP had its own independent

 3     system of communications.  In other words, they did not depend on the

 4     Ministry of Defence, but, rather, they used the Republic

 5     Communications Centre at Pale.  They developed their own documents,

 6     independent of us, and they also developed their plans of work of radio

 7     communications.  They had trained staff to do that.  But in the

 8     beginning, and I'm referring to the communication centres at Pale, the

 9     MUP Communications Centre, where Paunovic, Milenko -- the late

10     Milenko Paunovic worked.  They had trouble hiring staff which had

11     military specialties from the Signals Corps, and we would assist them

12     with that.  We would assist them to identify the required personnel that

13     was deficient, that they were short in.

14             Now, at the Republic Communications Centre throughout the combat

15     operations, throughout the war, we had also personnel problems, and in

16     those conditions we managed to carry out all the tasks that were required

17     of us, sometimes successfully, but sometimes not as successfully, and

18     sometimes we broke through the dead-lines that were asked of us because

19     we had difficulties in maintaining the communications lines, because

20     frequently they would break down and be out of operation.  And until they

21     were re-established, we had to use other means of communications that we

22     developed and kept on standby as a back-up system precisely because we

23     had frequent problems with the lines going down, so that it was really

24     with super-human efforts that we managed to maintain communications

25     throughout the war.

Page 15085

 1             JUDGE KWON:  Just one minute, Mr. Gaynor.

 2             MR. GAYNOR:  Yes, sir.

 3             JUDGE KWON:  Mr. Vukovic, I forgot to tell you that if you need a

 4     break at any time, don't hesitate to let us know.

 5             THE WITNESS: [Interpretation] Thank you.

 6             JUDGE KWON:  Yes, Mr. Gaynor.

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

 8        Q.   Mr. Vukovic, in your statement you refer to the

 9     67th Communications Regiment of the VRS.  Insofar as you know, what do

10     you understand the role or mandate of the 67th Communications Regiment

11     was?

12        A.   Very well.  From the aspect of the functioning of the Republican

13     Communications Centre, I cannot assess the operation of the

14     communications unit of the Main Staff, the 67th Communications Regiment,

15     because I'm not competent to evaluate their positions and their manner

16     and method of work, and I cannot talk about that either, because I

17     stated -- I gave the solemn declaration, I'm holding to it, and it

18     obliges me to speak about only those things that I can talk about

19     competently.

20             As for the 67th Communications Regiment, I can say that we often

21     repaired our equipment through them, equipment that we had in our centre,

22     and that we always were met with understanding, professionalism, good

23     attitude, because they had personnel that was trained to maintain certain

24     communications equipment that we were unable to fix in our own workshops.

25             The 67th Communications Regiment, by establishment, was

Page 15086

 1     duty-bound to assist either us, or the MUP, or anyone in the case this

 2     was required, if we had problems with communications, with means and

 3     equipment, with training, for certain deficient specialties in the VS.

 4     They -- for example, when we were equipping centres with new equipment,

 5     in case we needed some experts which could only be trained by the

 6     Main Staff of the Army of Republika Srpska, this was done because we

 7     didn't have any way of training one or two of these people, because what

 8     was required was to create some kind of model environment to work.  And

 9     there was a special unit in the 67th Communications Regiment that

10     provided training, but I can say that in all aspects of service that had

11     to do with communications, their attitude was very professional.  That's

12     all I can say.

13        Q.   In your answer, you referred to the abbreviation "VS."  Could you

14     tell us what that means?

15        A.   It's not "VS," it's "VES."  This is the military occupation

16     specialty.

17             MR. GAYNOR:  Could I request 65 ter 23143, please.

18        Q.   Now, in a moment, Mr. Vukovic, on the screen in front of you,

19     you'll see a map, and it's one you've seen before.  If you could, first

20     of all, just tell Their Honours what you understand the map to be.

21             I beg your pardon.  This is a diagram.  We're coming to the map.

22             If you can explain to Their Honours what you understand, in

23     general terms, this diagram to be, and then I will ask you some specific

24     questions about it.

25        A.   I cannot interpret the diagram of the protected communications of

Page 15087

 1     the Main Staff of the Army of Republika Srpska.  But as for the part

 2     relating to communications between the Main Staff of the VRS and the

 3     Communications Centre -- the Republican Communications Centre in Pale,

 4     I can speak about those particular branches and the connection with the

 5     stationary communications centre at Pale and the stationary

 6     communications centre at Crna Rijeka.  This is a little bit unclear.  I

 7     cannot really see very well.

 8        Q.   I'm sorry to interrupt you, Mr. Kezunovic.

 9             Could I ask the Registrar to expand the central box, the one big

10     box that we see at the centre.

11             Now, in the top right-hand corner of the screen in front of you,

12     Mr. Vukovic, you see "SCV Veliki Zep."  Could you tell us what that

13     means, please?

14        A.   This is not "SCV Veliki Zep," but this is the stationary node

15     "SCV."

16        Q.   And could you just expand the abbreviation for us?  "SCV" refers

17     to what?

18        A.   Stationary Communications Node, Veliki Zep, is located at the

19     command post of the Main Staff of the Army of Republika Srpska, and this

20     diagram should be interpreted by the senior officer who made it from the

21     Army of Republika Srpska.  I can recognise some communications here which

22     began or ended at the stationary communications hub at Veliki Zep or the

23     one in Pale.  This is an automatic telephone exchange which ended in the

24     offices of the president of the Republika Srpska and the president of the

25     Assembly of Republika Srpska.  These were automatic telephone exchanges.

Page 15088

 1        Q.   Can I interrupt for a minute there.

 2             In the box in the top right-hand corner of the screen in front of

 3     us, we see, as the seventh and eighth entries, "ATC G-1 Predsed.RS."

 4             The next one refers to "Pr.Skup.RS."  Are those the two entries

 5     you were just referring to?

 6        A.   Yes.

 7             JUDGE KWON:  Are we looking at that box, Mr. Gaynor?

 8             MR. GAYNOR:  Yes, the box in the top right-hand corner.

 9             JUDGE KWON:  Top right-hand corner in this box?

10             MR. GAYNOR:  Yes, the box on the screen in front of us in the top

11     right-hand corner.

12             JUDGE KWON:  Thank you.

13             MR. GAYNOR:

14        Q.   Could you please explain to us what you understand "Predsed.RS"

15     and "Pr.skup.RS" mean yes?

16        A.   The first one is Pr, "Predsednik," that is, president of the RS,

17     meaning that this extension was in the office of the president of

18     Republika Srpska.  This extension, 171, "Prsk" means the president of the

19     Assembly of Republika Srpska.  That extension was in the Cabinet of the

20     president of the Assembly of Republika Srpska, according to this

21     particular scheme.

22        Q.   Thank you.  And just to clarify the point:  After the Presidency,

23     we see the number 230, and after the president of the Assembly, we see

24     the number 171.  Is that right?

25        A.   Yes.

Page 15089

 1        Q.   Now, a few entries further down, we see "Preds.VL.RS," followed

 2     by the number 182.  Could you tell us what that refers to?

 3        A.   Yes, I see it.  This the prime minister's office of

 4     Republika Srpska, and this was extension 182.

 5             MR. GAYNOR:  If we could zoom out, please, and look at the top

 6     right-hand corner under, first of all, the box marked "SCV Jahorina,"

 7     which is under the box marked.  Thank you very much.

 8        Q.   Again, I think we can see, under number 7 here, a reference to

 9     the Presidency of the RS, and, number 8, a reference to the president of

10     the Assembly of the RS.  Could you confirm that, Mr. Vukovic?

11        A.   Yes, I can see this.  This is a stationary communications node at

12     the Jahorina facility, from the radio-relay communications diagram of the

13     Main Staff of Republika Srpska.  Again, I note, I cannot discuss or talk

14     about that, because this is not really my jurisdiction.  I'm not

15     competent to interpret the diagram of radio communications of the army.

16     But 7 and 8, those items refer to the radio-relay connections between the

17     Cabinet of the president of Republika Srpska and the Cabinet of the

18     president of the Assembly of Republika Srpska, with the stationary hub at

19     Veliki Zep.

20             MR. GAYNOR:  Now, could we zoom out a bit again, Mr. Registrar,

21     please, and zoom in on the box marked "Pale."

22        Q.   The last two entries in this box, again, Mr. Vukovic, could you

23     clarify what they are?

24        A.   These two last entries show that these numbers, 230 and 171,

25     ended at the offices in Pale of the president of Republika Srpska and the

Page 15090

 1     president of the Assembly of Republika Srpska via an automatic telephone

 2     exchange.

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

 4             JUDGE KWON:  You're not going to translate this?

 5             MR. GAYNOR:  The existing translation does not contain the

 6     translations of everything inside it, but we --

 7             JUDGE KWON:  We have an English translation.  [Overlapping

 8     speakers].

 9             MR. GAYNOR:  No, the English translation that's been up-loaded

10     simply gives the title of the graph, but does not indicate the entities

11     within the graph.

12             JUDGE KWON:  I don't think that the translation would help us.

13     We'll admit it as it is now.

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

15             THE REGISTRAR:  Exhibit P2795, Your Honours.

16             MR. GAYNOR:  Could I please ask for 65 ter --

17             JUDGE KWON:  But just for the purpose, could you read the title

18     on the top of the page?

19             MR. GAYNOR:

20        Q.   Could you read that title, please, Mr. Vukovic?

21             Perhaps we can zoom in, please.

22        A.   The heading of the document is "Diagram of the --" wait, I've

23     lost it.

24             JUDGE KWON:  Thank you.  We have that translation.

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

Page 15091

 1             JUDGE KWON:  Yes.

 2             MR. GAYNOR:  Could I ask the Registrar, please, for 65 ter 04325.

 3     In a moment, you'll be seeing the map I promised earlier.

 4        Q.   If you could explain to Their Honours, briefly, before I ask you

 5     any questions about it, what you believe the map to be?  It will be on

 6     your screen in a moment.

 7             Sorry, the 65 ter number of the map should be 04325.

 8             Perhaps we could zoom in a little on the top portion of the map

 9     to assist Mr. Vukovic.

10             Could you tell us what this map appears to be?

11        A.   The map shows the communication connections plan of the

12     Drina Corps in defence, approved by Major General Radislav Krstic, the

13     commander.

14        Q.   Do you see, in the middle of the map, the Cyrillic letters "IBK"?

15        A.   I don't, no.  No, no, I see it, I see it.  Large letters standing

16     for "Eastern Bosnia Corps," "IBK."

17             MR. GAYNOR:  Could we move down the map a little bit, please.

18             Now, if we could centre in on the centre of the map.

19        Q.   First of all, on the right, you see large Cyrillic letters "DK"?

20        A.   I do, "Drina Corps."

21        Q.   And on the left-hand of the map a little further down, you see

22     "SRK" in Cyrillic?

23        A.   Yes, that's the Sarajevo Romanija Corps.

24             MR. GAYNOR:  Could we zoom in, please, on the flag with the five

25     Cyrillic letters under it.  If we could zoom in a little more, please.

Page 15092

 1        Q.   Could you tell us what this represents?

 2        A.   This represents the command post of the Main Staff of the Army of

 3     Republika Srpska and the radio-relay hub Veliki Zep.

 4        Q.   The five Cyrillic letters mean what?

 5        A.   "The Main Staff of the Army of Republika Srpska," "GS VRS."

 6        Q.   Underneath that, we see a box.  Inside the box are the letters

 7     "V. Zep."  What is that?

 8        A.   That is a hill where the Stationary Communications Centre of the

 9     Main Staff of the Army of Republika Srpska was located.  That is the

10     radio-relay hub.

11        Q.   Now, if we could -- first of all, you see on your left another

12     box at Han Pijesak.  Do you see that?

13        A.   Yes.

14        Q.   What do you understand that to be?

15        A.   This shows the Han Pijesak PTT.  This is the forward command post

16     at Han Pijesak, the IKM.

17             MR. GAYNOR:  Now, could I ask the Registrar to follow the line

18     down from Han Pijesak.  You can see a straight line.  If we could just

19     follow that line down the map, please.  And a bit further down, please.

20     And could you go a little bit further south, please, Mr. Registrar.

21     Sorry, a little further west.  We need to get over to the left-hand side

22     of the -- very good, and carry on, and a little further south.

23             Now, could we zoom in there a little bit, please.

24        Q.   Do you see the town of Pale on this map?

25        A.   Yes.

Page 15093

 1        Q.   Do you see the non-straight line, the line which looks like it's

 2     following a road from Pale, which meets the straight line that we've just

 3     followed down from Han Pijesak?

 4        A.   [No interpretation]

 5        Q.   Could you tell us what you understand that to be?

 6        A.   Again, I note that I'm not competent or authorised to interpret

 7     the scheme of radio-relay connections of the Drina Corps in any shape or

 8     form, nor am I competent to interpret any kind of connections leading

 9     from the Main Staff to subordinate units.  I can help here to say that

10     this is the diagram showing how radio communications of the Army of

11     Republika Srpska functioned, but it does not show that the Republican

12     Communications Centre was part of it, the one that was located in Pale.

13     However, however, since these radio-relay routes going from the

14     Main Staff, from Veliki Zep, to all the subordinate units, then the

15     radio-relay node that we looked at just now in Jahorina is, of course,

16     part of the radio-relay connections shown on the diagram, and the

17     Republican Communications Centre had a priority in providing certain

18     services to the institutions of the civilian government.  Then it had the

19     priority of being allowed access to the communications system of the

20     army, which means that we were obliged to help one another, and we were

21     at each other's disposal, which was something that was expected of us.

22             This diagram talks about the connections of the Army of

23     Republika Srpska, showing the connections of the Main Staff and the

24     subordinate corps.

25        Q.   Does -- this particular map that we've just been inspecting, does

Page 15094

 1     it show the entirety of the radio-relay network of the Army of

 2     Republika Srpska?

 3        A.   This part of the radio-relay connection on this map does not show

 4     the complete radio-relay communications of the Army of Republika Srpska.

 5     This is only a part of it, covering the Drina Corps, the Main Staff and

 6     the Sarajevo Romanija Corps.

 7             So based on what I see here, I don't see the diagram in order to

 8     be able to say that this represents the entire network of the Army of

 9     Republika Srpska.  This is only one section of it, showing the

10     communications of the Main Staff, the Drina Corps and the

11     Sarajevo Romanija Corps.  That's what I can see.

12             MR. GAYNOR:  Can I tender that map, Mr. President?

13             JUDGE KWON:  Yes.

14             THE REGISTRAR:  Exhibit P2796, Your Honours.

15             MR. GAYNOR:  I'd now like to call up, please, 65 ter 23144.

16        Q.   Could you, first of all, read out the title at the top of this

17     document, please?

18        A.   Again, this is a diagram of radio relay and wire links of the

19     Drina Corps Command.

20        Q.   Now, if you could help us with a few things.  You see the large

21     box to the right which is marked "Veliki Zep."

22             Could we home in on that, please.

23        A.   Yes.

24        Q.   Could you tell us what this represents, as far as you're aware?

25        A.   This square represents the stationary communications hub at

Page 15095

 1     Veliki Zep.  It was located at Veliki Zep.

 2        Q.   We see coming out of this straight lines, and we also see a

 3     curled line which goes to Crna Rijeka.  Could you clarify this difference

 4     between straight lines and curled lines, as a general matter, on

 5     communications maps?

 6        A.   Yes.  We have radio-relay communications here, which are shown

 7     with a straight line, full straight line, and this curly line is a wire

 8     communications line, communications established through wire

 9     communications.

10        Q.   On this map, if we could zoom out of the map, please, we see a

11     number of circles with flags on them.  Could you tell us what a circle

12     with a flag on it denotes?

13        A.   The circle marks the place where a certain communications unit,

14     or a communications centre is located, or where a certain command of a

15     unit is located, or a socio-political organ, or a social political

16     community, civilian organs.  On the diagram, I can see that this covers

17     the distribution of the radio-relay and wire communications in the area

18     of responsibility of the Drina Corps, Drina Corps.

19        Q.   Now, this particular map doesn't happen to show any connection to

20     the town of Pale.  Would you be able to explain why that is?

21        A.   Well, it doesn't show Pale because this is a unit subordinated to

22     the Main Staff of the VRS and not to the civilian authorities that were

23     based in Pale.  So this is a diagram of communications between units of

24     the VRS.  And, again, I have to say that I'm neither competent nor

25     authorised to discuss this, because this was prepared -- this diagram was

Page 15096

 1     prepared by an officer of the Drina Corps Command, a communications

 2     officer.

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

 4             JUDGE KWON:  Yes, that will be admitted.

 5             THE REGISTRAR:  Exhibit P2797, Your Honours.

 6             MR. GAYNOR:  Could I now call up, please, 65 ter 02655.

 7        Q.   There's a map coming up now, Mr. Vukovic, which was provided to

 8     us by the Army of Bosnia and Herzegovina.  I'm not going to ask you about

 9     what it purports to depict.  We're just going to look at one small part

10     of the map.

11             Could we -- could you tell us what the title of the map appears

12     to be, Mr. Vukovic?

13        A.   This is a working map of the Section for Counter-Electronic

14     Combat of the 2nd Corps, Counter-Electronic Surveillance of the

15     2nd Krajina Corps, but I can't really see clearly.  What I can see is

16     that this is a map for counter-electronic surveillance of the 2nd Corps

17     of the BH Army, most probably.

18             MR. GAYNOR:  Could I ask the Registrar just to go down to the

19     very bottom of the map.  In fact, that will do for the moment.

20        Q.   Do you see the straight lines that we see on this map?

21        A.   Yes.

22        Q.   Would you be able to comment in any way as to what they might

23     represent?

24        A.   They might represent radio-relay routes of the commands that

25     developed certain communications centres in these areas.  I'm not really

Page 15097

 1     the best-placed person to interpret this.  I don't know what units or

 2     what armed forces developed these communications centres.  This is

 3     something that probably relates to the BH Army, the so-called BH Army.

 4             JUDGE KWON:  The witness may be assisted by seeing the letters on

 5     the bottom right.

 6             MR. GAYNOR:  Yes.  Thank you, Mr. President.

 7             Could we focus in on the bottom right part of the map.

 8             JUDGE KWON:  And zoom in a bit further.

 9             MR. GAYNOR:

10        Q.   Once you've read that, Mr. Vukovic, could you tell us if that

11     informs you about what the straight lines on the map might represent?

12        A.   These straight lines might represent radio-relay routes between

13     command posts of certain units.

14             MR. GAYNOR:  Now, could I ask the Registrar to move west on this

15     map.

16             JUDGE KWON:  Can you tell us whether this is related to BH Army

17     or the VRS?

18             THE WITNESS: [Interpretation] I cannot really interpret this map.

19     I did not draft it, nor did anyone from my centre produce this.  This map

20     is totally new to me and unfamiliar.  But from what I see, I can tell

21     that it's a diagram of communications between some centres of

22     communications and commands of units.

23             MR. GAYNOR:  Perhaps could I ask the Registrar to move to the

24     west, and we'll see there something which might assist you in determining

25     which army this relates to.  If we could focus in a little bit on the

Page 15098

 1     central part there, please.

 2        Q.   Does that help you at all, Mr. Vukovic?

 3        A.   From what I see before me, I can assume -- unless this was

 4     produced by someone from the other side, the other party, the other armed

 5     forces, the BH Army, I can assume that this was perhaps developed within

 6     units of the Main Staff of the VRS.  However, the map that you're showing

 7     me here could also have been produced from the communications -- from a

 8     communications unit of the BH Army.  It could also be a VRS map.  This is

 9     the first time that I see this map, and I'm not really competent to

10     interpret it.

11        Q.   In any event, Mr. Vukovic, do you accept that it appears to

12     denote a curled line going from Veliki Zep to Han Pijesak, as in the

13     earlier Drina Corps map that you inspected?

14        A.   Well, based on this code-name, "Panorama," "Panorama" or

15     "Prostor," space, I can tell that this is a VRS map, and the curled line

16     would then denote a wire line between Han Pijesak and the radio-relay

17     node at Veliki Zep.  But, again, I'm not competent to interpret this map.

18     However, I do see that, based on what I see before me, that this was a

19     map developed at the Main Staff of the VRS.  I judge that by this

20     code-name, "Panorama."

21        Q.   If we can look further down the map, just further south, we see a

22     straight line, and it ends with the word "Pale."  Do you see that?

23        A.   Yes.

24        Q.   Could you express what that straight line might refer to?

25        A.   This line, according to me, is a radio-relay route between Pale

Page 15099

 1     and Veliki Zep, but that would have had to go through Jahorina.

 2             MR. GAYNOR:  Thank you, Mr. Vukovic.

 3             Your Honours, we'll be showing this particular map to other

 4     witnesses, who will be familiar with it.  Nevertheless, I believe

 5     Mr. Vukovic has provided some useful information about it.

 6             JUDGE KWON:  Just for the record, Mr. Vukovic, you referred to

 7     "Panorama" as a code-name.  It's a code-name of which organ, just to be

 8     clear?

 9             THE WITNESS: [Interpretation] That was the Communications Centre

10     at the Main Staff.

11             JUDGE KWON:  So "Panorama" was the code-name for the

12     Communications Centre of the VRS?

13             THE WITNESS: [Interpretation] Yes.

14             JUDGE KWON:  Any objections?

15             We'll admit this.

16             THE REGISTRAR:  Exhibit P2798, Your Honours.

17             MR. GAYNOR:  Thank you very much.

18             Now, subject to the tendering of those associated exhibits which

19     have not already been admitted by the Trial Chamber, that ends my

20     examination-in-chief.  So I'd like to tender the balance of the exhibits

21     at this stage.

22             JUDGE KWON:  Any observation, Mr. Robinson?

23             MR. ROBINSON:  We don't have any objections to any of them,

24     Mr. President.

25             JUDGE KWON:  I noted just one typo, Mr. Gaynor.

Page 15100

 1             MR. GAYNOR:  Sorry.  I meant to clarify one thing, Mr. President.

 2     I sent an e-mail to the parties and to the Trial Chamber about that.

 3             The exhibits that we're tendering are all of those referred to in

 4     the amalgamated statement, itself.  Now, in the appendix which we filed

 5     with our 92 ter notification, we omitted six 92 ter numbers which are, in

 6     fact, discussed by the witness in his statement.  I can read those into

 7     the record at this point.

 8             JUDGE KWON:  Very well.

 9             MR. GAYNOR:  The six 92 ter numbers which were not listed in

10     Appendix A, but which are discussed by the witness in his amalgamated

11     statement, are 18575, 17569, 18577, 22866, 21272, 22909.

12             Thank you, Mr. President.

13             JUDGE KWON:  You said 92 ter numbers?  65 ter numbers?

14             MR. GAYNOR:  I beg your pardon.  65 ter numbers.  Thank you.

15             JUDGE KWON:  Yes.

16             In your second-last item in the first page, you refer to

17     65 ter 13606.  Is it not a typo for "13626"?

18             MR. GAYNOR:  Thank you, Mr. President, that's very possibly the

19     case.  I'll verify that.  Unless I come back to you, that is the

20     understanding.  Thank you.

21             JUDGE KWON:  Yes, we'll admit them all.  The Court Deputy will

22     assign appropriate numbers and inform the parties.

23             Thank you, Mr. Gaynor.

24             MR. GAYNOR:  Thank you, Your Honours.

25             JUDGE KWON:  Well, Mr. Karadzic, if you are ready, start your

Page 15101

 1     cross-examination.

 2             THE ACCUSED: [Interpretation] Thank you.

 3                           Cross-examination by Mr. Karadzic:

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Good afternoon, Major Vukovic.

 6        A.   Good afternoon, Mr. President.

 7        Q.   I'm sorry I didn't have an opportunity to meet you before you

 8     began your evidence here, but I would like to thank you for meeting my

 9     associates, and I hope that our cross-examination will run more smoothly

10     and more quickly as a result.

11        A.   Thank you, Mr. President.

12        Q.   Major -- I would now like to request that we move briefly into

13     private session or a closed session because of a bit of information that

14     my Defence has obtained, and I need to be in private session for that

15     purpose.

16             JUDGE KWON:  Yes.

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 15102











11  Pages 15102-15107 redacted. Private session.















Page 15108

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6                           [Open session]

 7             JUDGE KWON:  Mr. Vukovic, we'll have a break for half an hour and

 8     resume at 1.00.

 9                           --- Recess taken at 12.29 p.m.

10                           --- On resuming at 1.02 p.m.

11             JUDGE KWON:  Yes, Mr. Karadzic.

12             MR. KARADZIC: [Interpretation] Thank you, Your Excellency.

13        Q.   Major, when Mr. President asked you to explain the part that the

14     interpreters didn't catch, you explained what your role was.  And it was

15     thanks to that role of yours that you knew what the location of various

16     installations was about the town?

17        A.   Yes.  I worked before the war, and it was TO 2120 Sarajevo that

18     was my superior command, and Velesici came under that particular command.

19        Q.   Thank you.  In addition to this particular feature, do you recall

20     any other military installations being present in Velesici?

21        A.   There was a training centre in Velesici which specialised in

22     training senior officers of the Territorial Defence in the former

23     Yugoslavia.  They were members of town TO staffs.  There was also an arms

24     depot there, as was a general storage place for military equipment.  All

25     of this was housed in the facility at Velesici, which is located just

Page 15109

 1     next to the General Motor Car Servicing Centre.

 2        Q.   Do you know that it was this particular General Motor Car

 3     Servicing Centre that serviced and repaired military vehicles before the

 4     war?

 5        A.   Yes, I am aware of this.  We had our observation posts at various

 6     points in the town, and VRS personnel observe the movement of enemy

 7     personnel and their equipment, especially those that posed a threat to

 8     our forces, our commands, and various military and civilian authorities.

 9     They reported to us whenever such movement was observed.  Our duty, among

10     other things, was to protect the civilians from surprise attacks,

11     including artillery attacks, aircraft raids, or sabotage actions.

12        Q.   Was there a hotel facility belonging to the railways or something

13     of the sort there, and was the Delta Unit stationed there or was it

14     somewhere else?

15        A.   I don't know where the Delta Unit was stationed.  It was a

16     special sort of unit.  I did hear of it, as I heard of the Black Swans.

17     However, there was the secondary school for railway staff stationed

18     there.

19        Q.   Thank you.  Major, sir, before the war broke out, you had the

20     Municipal Centre for Monitoring and Reporting at Pale, and the capacities

21     you had were those required by a municipal centre of this sort; is that

22     right?

23        A.   Yes.

24        Q.   When you mentioned the monitoring and reporting activities

25     intended for civilians, can you confirm or deny that Pale were also the

Page 15110

 1     subject -- was also the subject of mortar and howitzer fire?

 2        A.   In addition to our duties related to encryption, we were also

 3     duty-bound to monitor the activities in the air and on the land,

 4     especially when it came to combat activities directed against civilians

 5     and civilian authorities or VRS military installations.

 6             I do recall that back in 1992 - it was in the month of

 7     August - on around the 7th of August, 1992, the urban core of Pale came

 8     under artillery fire from the direction of Precko Polje, Cakre [phoen],

 9     which is between Bjelasnica and Mount Igman.  It was at this time that

10     the attack resulted in one death.  It was a man I knew before the war, a

11     resident of Pale.  I don't know if I should mention his name or --

12        Q.   Well, I do believe that we owe him that much.

13        A.   It's late Njegos Marinkovic, who was killed on his own land,

14     close to his home.  He was on his way to the cattle barn.  The shell

15     landed on this out-building, and the shrapnel killed him.  It was up

16     until the 20th of August, 1992, that the artillery fire continued, when a

17     152-millimetre Nora ^ gun was finally detected.  It was the gun that kept

18     firing on the urban core, and it was destroyed.

19        Q.   In your testimony in the Stanisic and Zupljanin case, at page 14,

20     in 1D3616 - we don't have to call it up; it's there for everyone to

21     see - you explained what it was that the Republican Centre engaged in;

22     i.e., encryption of data, monitoring and reporting.  And at page 15 of

23     that same testimony, you said that you served the municipal authorities

24     and their needs.

25             And now I will continue in English.

Page 15111

 1             [In English] "And due to a lack of men, we had the role of

 2     Republic centre, Regional Centre, and Municipal Centre, of the

 3     cryptographic data-protection system, and of monitoring and information."

 4             [Interpretation] As you grew out from a municipal centre into a

 5     republican centre, did you find yourself in difficulties with regard to

 6     personnel and equipment?

 7        A.   May I just supplement what I said in that earlier testimony, when

 8     we talked about the artillery fire directed at Pale.  There is this one

 9     detail that I left out, and if this honourable Chamber would allow me to

10     explain this, I will move on to the evolution from the Municipal to the

11     Republican Centre.

12             I forgot to mention:  The artillery fire that was also present in

13     1995, in the period between, I think, the 10th of June, 1995, and the

14     28th of July, 1995, there was non-stop fire.  At a later date, on the

15     30th of August, 1995, there was an all-out attack across

16     Republika Srpska, where VRS installations were targets.

17        Q.   Thank you.  Can I then ask you:  The shelling of Pale between the

18     10th of June and the 28th of July, does it coincide with a major Muslim

19     offensive on Sarajevo?

20        A.   Yes, indeed.  We were able to observe, when Pale was shelled,

21     since it was our duty to find refuge for civilians and to alert the

22     civilian and military authorities of the threat coming from the enemy

23     side, we were able to observe that as soon as aircraft appeared in the

24     air, an alarm would be sounded in the enemy section of Sarajevo, where

25     the civilian population would go into the shelters, and we would then

Page 15112

 1     come under attack.

 2             I'm sorry, should I clarify something?

 3        Q.   No, no, I'm just waiting for the interpretation to end.

 4             Can you tell us, this Municipal Centre, as it grew into a

 5     republican centre which had more duties on its hands, did it come across

 6     difficulties, in terms of personnel and equipment that they had?

 7        A.   It was a municipal centre which had a small number of staff,

 8     because it had been set up for peacetime activities, which now had to

 9     transform into a republican centre and service the entire republic.  We

10     were confronted with a vast number of problems.  In fact, the same number

11     of staff we had in 1992, as we set about these activities, remained there

12     on the 21st -- up until the 21st of November, 1995, at which point, in

13     fact, the staff was downsized.  Throughout this time, we had some eight

14     to nine staff, including late Milorad Kotlica, who died in Nis in 1994

15     and was buried at Bonn [phoen], in Montenegro.  He was in charge of

16     communications and encryption.  And we didn't have proper personnel to

17     replace him there, so it fell upon me to take up these duties.  We had

18     very few people, we had very little equipment and assets that we were at

19     great pains to maintain, and we were confronted with major problems.

20     This was a period of time when communications systems worked

21     intermittently because of the combat activities or because, simply, we

22     had some of the wires crossing enemy territory.  The enemy would engage

23     in sabotage activities, cut these wires.  They electronically surveilled

24     our activities.  They jammed our radio-relay communications across

25     various routes and at various nodes.  For this reason, the 67th Regiment

Page 15113

 1     that I mentioned provided great assistance to us in overcoming

 2     difficulties that we faced in these poorly-functioning communications

 3     systems.

 4             The MUP Communications Centre - I believe I mentioned this - had

 5     great difficulties at Pale.  The chief of the Communications Centre was

 6     late Milenko Paunovic, also known as Mile, a friend of mine, who

 7     frequently complained to me about the difficulties he had or inability to

 8     carry out some of the difficulties where we were supposed to lend them a

 9     hand, and we did whenever we were able to.  This does not mean that we

10     were always able to assist him in whatever difficulties he had.  There

11     was many an occasion when he would not ask for our help at all.  Of

12     course, the Communications Centre I'm referring to belonged to the MUP,

13     and the army had its own Communications Centre.

14             I don't know if I answered your question.

15             THE ACCUSED: [Interpretation] Yes.

16             Can we call up 1D3617 in e-court.

17             MR. KARADZIC: [Interpretation]

18        Q.   Before the war, as part of your duties, you helped the Red Cross

19     and various humanitarian organisations, including the UNHCR which, back

20     in 1991, had to receive refugees from Western Slavonia, et cetera.  Did

21     this situation prevail during the war as well?

22        A.   In 1991, it was a large influx of refugees from the former

23     Yugoslav Republic of Croatia, from Western and Eastern Slavonia, from

24     Bila Gora, Papuk, Okucani, and those areas inhabited by Serbs.  Since

25     there was an offensive by the Croatian forces, the population had to flee

Page 15114

 1     in 1991, and a number of those refugees came to Pale.  We were helping

 2     those people set up communications amongst themselves.  There were a lot

 3     of problems.  Families were separated, parents and children, and they had

 4     spread out all the way from Krajina to Vojvodina.

 5             THE ACCUSED: [Interpretation] Can we please have the following

 6     page of this document.  Can we look at the bottom of the next page.

 7     We're looking there -- we will see the information that the witness has

 8     just mentioned.

 9             MR. KARADZIC: [Interpretation]

10        Q.   Is this your statement, is this your signature, and are you

11     explaining here what was done, just as you have told us now?  Is that

12     correct?

13        A.   Yes, that is my signature, Mr. President.

14             THE ACCUSED: [Interpretation] Thank you, Major.

15             Can we tender this document?

16             JUDGE KWON:  Yes.

17             THE REGISTRAR:  Exhibit D1372, Your Honours.

18             MR. KARADZIC: [Interpretation]

19        Q.   Well, you spoke about similar issues in the Stanisic/Zupljanin

20     case in page -- 1D36136, on page 23, and then on page 31 you said that --

21     I'm going to read it in English:

22             [In English] "We had our own problems.  Those were the first

23     months of combat operations, and those communications systems would be

24     down quite often."

25             [No interpretation]

Page 15115

 1        A.   That is correct.

 2             THE ACCUSED: [Interpretation] Thank you.

 3             Can we now call up D95, please.

 4             MR. KARADZIC: [Interpretation]

 5        Q.   Major, sir, do you recognise this dispatch?

 6        A.   Yes, I do.

 7        Q.   If you agree, I am instructing the presidents of municipalities

 8     here in all villages in which the Croatian and Muslim inhabitants have

 9     handed over their weapons and do not intend to fight, should enjoy

10     protection.  Anyway, I would like you to look at the municipalities

11     listed, where it says "Gorazde, by radio"; "Foca, by radio relay";

12     "Han Pijesak, by telephone"; "Sokolac, by teleprinter"; "Rogatica, by

13     radio"; "Visegrad, by radio"; "Rudo, by radio relay to Foca and then by

14     radio"; "Cajnice, by radio relay."

15             Now, are you able to tell us why there is such an uneven method

16     of communication and why was this not done with a single means?

17        A.   We had problems, especially in this period from April 1992

18     throughout the rest of 1992, when certain communication routes were

19     disrupted, certain types of communications were down.  Since there was a

20     small number of people available, we tried to fulfill all of our

21     obligations in order to protect any citizen of the then Serbian Republic

22     of Bosnia and Herzegovina because at the beginning of the war, I think it

23     was the Serbian Republic of Bosnia and Herzegovina, regardless of the

24     ethnicity, regardless of their place of residence, where they were

25     located, and in this way we were trying to resolve the problem of

Page 15116

 1     communication.  Telephones were not functioning, teleprinter

 2     communications were down, so we had to find a way to see what kind of

 3     communication could serve a particular type of area to reach a certain

 4     municipality, a centre, in order to be able to convey the users'

 5     dispatches, telegrams and orders.

 6             I know that there was the matter of protection for the Muslim and

 7     Croat citizens who had handed over their weapons, who did not intend to

 8     put up any kind of fight against the Army of Republika Srpska, and I

 9     recall very well that it was ordered that all those citizens had to be

10     protected and looked after, offered the full extent of the protection of

11     the Bosnian Serb Republic.

12             I can see that in Gorazde, we used the -- we delivered the

13     telegram by radio.  Rogatica, also in Visegrad, the dispatch was

14     delivered by radio.  This was an ultrashortwave 745 or 700Y device which

15     any ham radio operator would be able to use, and this is the type of

16     communications that we managed to set up.  And we managed to dispatch the

17     telegrams to certain centres 24 hours a day, from where they were passed

18     on further.

19        Q.   Thank you, Mr. Vukovic.  Do you see that the late Colonel Kotlica

20     is suggesting here to me, because it will be copied to me, that I should

21     inform the media.  Does that indicate that he wasn't sure that all of

22     that would go through and that it would be a better thing to also publish

23     it in the media?

24        A.   Very often, we didn't have return information, whether something

25     reached its destination or not; for example, telegrams that were sent by

Page 15117

 1     ultrashortwave operators, by radio.  We would receive a confirmation that

 2     it was received, but we don't know whether the same thing applied in

 3     Rogatica, in Foca, or in some other place where there was a communication

 4     centre.  We were unable to know what was done there from Pale.  They

 5     would confirm receipt, but we don't know whether the telegram was

 6     actually delivered or not.  This is something that would perhaps need to

 7     be looked into.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             And now I would like us to briefly look at P2412.  Can we look at

10     that in e-court, please.

11             MR. KARADZIC: [Interpretation]

12        Q.   By establishment, you were under the Ministry of Defence before

13     the war and during the war; is that correct?

14        A.   Yes.

15        Q.   Thank you.  Do you recognise this telegram, and did you dispatch

16     it to Banja Luka, all the bodies in the ARK and the SAO Krajina?

17        A.   Yes, this telegram was sent.  It was received in the Banja Luka

18     Municipal Assembly at 0959 hours.  I can see the number here.

19        Q.   "1/92," is that the first telegram of some Serbian defence

20     organisation?

21        A.   Yes, yes.  That is the number from the log-book of outgoing

22     telegrams.  I don't have the log-book in front of me now, but that should

23     be the number from the log-book.

24             I can see at the top this number "45100 Banja Luka Municipal

25     Assembly."  That should have been the regional centre which was in Banja

Page 15118

 1     Luka at the time which received the telegram by teleprinter which was

 2     addressed to the governments of the autonomous region and the Serbian

 3     Autonomous Region of the Serbian Republic of Bosnia-Herzegovina, to all

 4     Serbian assemblies.

 5        Q.   All Serbian assemblies.  Now, I would like to ask you to help us

 6     a little bit, in view of the fact that you're a member of the military.

 7     Are you familiar, and I assume that you are, with the Law on

 8     All People's Defence, and do you agree that pursuant to that law, every

 9     municipality had a sovereign right to defence on its own territory?

10        A.   Yes, it did have the right to defend its territory and endangered

11     population from any type of enemy actions which endangered the civilian

12     population or buildings on the territory of any of those socio-political

13     communities.

14        Q.   Do you agree that it states in the first point the

15     Territorial Defence was being formed?  Would you agree that that would

16     then mean that the municipal TOs were all being merged at the level of

17     the Republic of the Serb -- of the Serbian Republic of

18     Bosnia-Herzegovina, that they would be under the command of municipal,

19     district, and regional staffs, and the republican staff of the TO?

20        A.   Yes, that is natural that all municipalities had their own TO.

21     This was something that was true at the level of the whole of the former

22     Yugoslavia, and at the level of the former republics making up the former

23     Yugoslavia.  The republics had their own municipal TO units, which would

24     then break down to units in the municipalities.  There were TO peacetime

25     and wartime units.  And they would break down into staffs.  They had the

Page 15119

 1     required number of people available, and they functioned in peacetime.

 2     During war, military conscripts were called up, and they were deployed to

 3     TO units at different levels and strengths, and the units were commanded

 4     by non-commissioned officers who were in the commands of the TO units.

 5        Q.   Thank you.  Major, sir, in view of the fact that you were in the

 6     TO of the Republic of Bosnia and Herzegovina before the war, and that on

 7     the 16th of April, 1992, this is the first telegram of the Ministry of

 8     the Serbian Republic of Bosnia and Herzegovina, before that did the

 9     Serbian side in Bosnia and Herzegovina have any type of armed formation?

10        A.   No.  As far as I know, the Serbian side didn't have any

11     formations, it didn't form any formations.  But, for example, in 1991, I

12     know that units were formed of the Green Berets and the Patriotic League

13     already in Bosnia and Herzegovina.  These were units that were formed by

14     the Party of Democratic Action.

15        Q.   Thank you.  Major, sir, you were asked in the Zupljanin case,

16     Stanisic/Zupljanin case -- this is 1D3616, page 21.  They asked you if

17     this document was passed down to the municipalities, and now I'm going to

18     read what you said in English:

19             [In English] "At the top of the document, you can see that the

20     memorandum was in the centre in Banja Luka.  And as far as I can

21     remember, the number indicated on the document was the number of the fax

22     in the Banja Luka centre.  I can't tell you whether the operator faxed

23     these documents to somebody else.  I don't know that.  I am not able to

24     see it from the document without the log-book.  If I saw the log-book, I

25     would be able to tell you who the document was sent to.  Since Banja Luka

Page 15120

 1     was a regional centre at the time and this document applied to all

 2     Serbian municipalities, I suppose that he did fax these documents to the

 3     municipalities in the Krajina region."

 4             [No interpretation]

 5             [In English] "And that's what I conclude based just on looking at

 6     the document."

 7             [Interpretation] So you know that there was possibly return

 8     information, that it did reach that centre, but what happened with this

 9     and similar documents is something that you cannot know; is that correct?

10        A.   Yes, that is correct, because I see here that the telegram was

11     sent by teleprinter.  In the memo of the telegram at the top, you can see

12     that this was sent by fax, and there is a fax "12566."  This is the

13     Regional Centre in Banja Luka.  So the Regional Centre in Banja Luka,

14     unable to send it to all the municipalities by teleprinter because it was

15     probably down, they sent the telegram by fax, which was not permitted.

16     But at the time, that was how they did it because there was no other way

17     to do it, and that means that a fax like this and a telegram like this,

18     whoever was involved in anti-electronic surveillance could have been

19     recorded.  The tapping -- surveillance Centre could have picked up this

20     document.  It was not permitted to send text like this by fax because

21     that was an open communication.  If it was a protected document, and in

22     this way, if it was sent, it would practically become a public one.

23     Anyone could pick it up and record it.

24        Q.   Major, sir, in paragraph 46 of your statement, you say that by

25     June there was no developed system of protection of military data and

Page 15121

 1     there was no encryption in order to protect data; is that correct?

 2        A.   Yes.  Encryption in our centre, i.e., Cryptographic Protection,

 3     began to operate, I think, around the 20th or the 22nd of June, so it was

 4     in the second half of June 1992.

 5        Q.   Thank you.  You said the same thing during your testimony in

 6     Stanisic/Zupljanin, 1D3616, on pages 59 and 60.

 7             Now, do you remember, Major, sir, that on the 20th of June, or

 8     maybe the 22nd, but I believe it was the 20th, the presidency of Bosnia

 9     and Herzegovina, the Croatian Muslim part, declared war on us?

10        A.   On the 20th of June, 1992, I believe, I believe that war was

11     declared -- well, I believe that war was declared on the Republika Srpska

12     far sooner.  I believe there was an order of April 1992, consisting of

13     four points, which arrived on the 29th of April, 1992, an order that was

14     signed by the first commander of the so-called BH Army, because the

15     Territorial Defence was just one component of the armed forces, the

16     component of the armed forces of Yugoslavia.  However, by issuing that

17     order, consisting of four points, they declared war on the entire

18     territory of Bosnia and Herzegovina.  And I think that the authors of

19     that order are still at large and that no one was ever brought to

20     justice, not one of them, although all the following events -- the

21     subsequent events, all the deaths and the suffering of the civilians, the

22     Vase Miskina incident, the Markale I and II incidents, all of that arose

23     from that first order, a monstrous order, because that order made it

24     binding on every soldier of Bosnia and Herzegovina to wage war.  This can

25     also be -- this is also confirmed in a book issued -- published by

Page 15122

 1     Hasan Efendic, the first commander of the BH Army, the book entitled "Who

 2     Defended Bosnia."  This book was published in 1991 by the Association of

 3     Noble Descent -- of People of Noble Descent in Bosnia-Herzegovina, and

 4     this very order is mentioned on pages 135 or 136, or perhaps on the pages

 5     between 128 and 136, where Colonel Efendic makes a reference to that

 6     order of the 23rd of April, 1992, and says that that order had created a

 7     major disturbance both at Pale and in Belgrade.  This order of 29th -- we

 8     received it on the 29th of April, 1992, at Pale.  This was sent to all

 9     municipalities, this order, and they probably felt that Pale, too, would

10     respond to this order and implement the four items listed there.  And one

11     such copy of that order was also handed in to you and the then

12     Colonel Subotic.  Another copy of this same order also arrived --

13             JUDGE KWON:  Mr. Vukovic, I appreciate your detailed explanation,

14     however we have only a limited time, so if you could concentrate on

15     answering the question.  So Mr. Karadzic will lead you with his

16     questions.  The question was whether Croatia declared war.

17             Continue with your next question, Mr. Karadzic.

18             THE ACCUSED: [Interpretation] Can we briefly see D332, please,

19     and see whether this is the document that you are referring to.

20             MR. KARADZIC: [Interpretation]

21        Q.   But my question was whether the formal declaration of war came on

22     the 20th of June, 1992, and we were declared the enemy, "we," as

23     Yugoslavia.  First of all, is this the document that you're referring to,

24     the document that was a trigger for war even before it was declared?

25        A.   Yes, this is that document of the 29th of April, 1992.  That's

Page 15123

 1     the document I was just referring to.

 2        Q.   Thank you.  Do you recall that there was an order on combat

 3     readiness that was issued by this same colonel on the 12th of April,

 4     1992, and it preceded this order we have before us?

 5        A.   I'm not aware of that document.  I cannot recall it as I sit

 6     here.  But I do remember this order, and I just mentioned it a moment

 7     ago, because it says in paragraph 4:

 8             "Hurriedly plan and begin combat operations in the entire

 9     territory of the Republic of Bosnia and Herzegovina and co-ordinate them

10     with the territorial defence staffs of regions, districts and the

11     Republic of BH."

12             Practically, in paragraph 4, he is ordering that war should be

13     waged on the entire territory of Bosnia-Herzegovina, and each soldier of

14     the BH Army had to enforce this order.  And this is the source of all the

15     problems in Bosnia and Herzegovina later on, and I find it hard to

16     believe to this day that not one of the authors of this order ever were

17     called to justice.  It is really mind-boggling, and I don't know when

18     Croatia did that.  I don't know what that relates to.

19        Q.   Well, maybe the interpretation was incorrect.  I said the Bosnian

20     and -- Bosnian Muslim and Croatian part of the Presidency declared war.

21        A.   Well, that's correct.  What I received as my interpretation was

22     that it was Croatia, which I cannot confirm.  But, yes, that the part of

23     the Presidency consisting of the Bosnian and Croatian representatives

24     did, yes, that's correct.

25        Q.   Thank you.  Now, you just reminded me of another problem with

Page 15124

 1     Colonel Efendic.

 2             Could we now see 1D3618 in e-court, please.  This is an interview

 3     that you had with the Prosecution.  The Prosecutor interviewed you on the

 4     27th of January, 2010.

 5             Could we see that, please, 1D3618.  We need page 64 of the

 6     interview.

 7             Major, sir, do you remember what kind of measures were taken, and

 8     how strict was the enforcement, if a soldier would waste a single bullet

 9     in the JNA?

10        A.   Well, it was taken very seriously because each bullet meant a

11     human life, so all the bullets, all the rounds that were issued, had to

12     be returned.

13        Q.   Thank you.  Now, here we see, and perhaps you can just glance at

14     it - we're not going to read it out - but there is mention here of

15     Territorial Defence of Sarajevo, and Hasan Efendic was part of it, and

16     then you go on to say that somehow 40.000 rounds went missing, and then

17     that Budimir Djordjic the prosecutor, tried to initiate the procedure in

18     1987 [Realtime transcript read in error "1997"] or 1988 [Realtime

19     transcript read in error "1998"], but that he was not able to continue

20     with it, and that it was never explained and it was never clarified how

21     it came about; correct?

22        A.   Yes.  There was this issue where ammunition went missing from the

23     depot at Koran?

24        Q.   Thank you.  Would this 40.000 rounds approximately equate to 240

25     combat kits?

Page 15125

 1        A.   Certainly, because a lot of ammunition went missing then, and it

 2     was even reported in the press, in "Oslobodjenje," because there was a

 3     clash within the Territorial Defence Staff.  And I know this because at

 4     the time I was the deputy -- I was the assistant commander for

 5     mobilisation and recruitment in Pale, and I was also involved in security

 6     and intelligence.  And the assistant commander for logistics complained

 7     to me that he could not account for that amount of ammunition and a

 8     certain number of long barrels, and then it was said that that was not

 9     quite the case.  I even happened to fall ill at the time.  I got blood

10     poisoning, I ended up in hospital, so that's where it remained.  But I

11     know that they tried to clarify this, but the military prosecutor who

12     tried to conduct an investigation, he did manage to identify where the

13     problem was.  He was preparing to issue an indictment against the

14     individuals who are responsible for this.  However, this indictment was

15     never issued, probably because of the clash that ensued, and this same

16     person later on became one of the first commanders of the BH Army.  And

17     then we know what happened next.

18             JUDGE KWON:  Yes, Mr. Gaynor.

19             MR. GAYNOR:  Your Honour, I just wanted to point out an error in

20     the transcript, just in case it isn't picked up later.

21             The events we're looking at took place in 1987 or 1988, not 1997

22     and 1998, which brings me on to my second point.

23             In my submission, this entire area of evidence is really of very

24     little assistance to the Chamber, concerning, as it does, events five

25     years before the outbreak of the conflict.

Page 15126

 1             JUDGE KWON:  Thank you.  Thank you, Mr. Gaynor.

 2             THE ACCUSED: [Interpretation] May I reply to this?

 3             JUDGE KWON:  Yes.

 4             THE ACCUSED: [Interpretation] With all due respect for

 5     Mr. Gaynor, this gentleman, Efendic, he was the commander, the man

 6     responsible -- the responsible man at the time of this theft.  On the

 7     11th of April, he became the commander of the Territorial Defence, and on

 8     the 12th of April, he ordered attacks.  On the 29th of April, he ordered

 9     an all-out attack.  And this theft of ammunition was, in fact, to benefit

10     his side.

11             JUDGE KWON:  We still have a question how relevant this is to

12     your case.  Come to the question which is relevant to your case and to

13     the issues he dealt with in his examination-in-chief.

14             Please move on, Mr. Karadzic.

15             MR. KARADZIC: [Interpretation] Thank you.

16        Q.   You confirmed that up until mid-June, approximately, or, rather,

17     at the declaration of war, there was no code for protecting military

18     data.  And then in paragraph 9 of your statement, you said that at that

19     time a code system was established, and it was referred to as "Vatra" or

20     "Fire."  Could you tell us how that came about and how the whole thing

21     functioned?

22        A.   On the 29th of June, 1992, at the Republican Centre of

23     Communications, we established a code system to encode communications

24     that were going out to certain addressees.  Now, the communications plan,

25     code-named Vatra, was a communications plan for maintaining radio

Page 15127

 1     communications, so it is a code-name for radio communications, where

 2     radio units -- radio sets were used, and it did not contain only one code

 3     book, but a number of code books and documents, such as identifying

 4     documents, the code book, then the key for the code book.  So, in other

 5     words, this is a communications plan for the secret commanding of troops,

 6     or TKT for short.

 7             This Vatra plan of communications could also be applied for

 8     telephone communications and it would then -- it could then be forwarded

 9     to the addressees or the end users either by telephone lines or through

10     the radio communications system.

11        Q.   Thank you.  Now, today, during the examination-in-chief, you

12     mentioned that -- on page 51, line 11, that services developed their own

13     documents independently.  Would you please tell the Trial Chamber what

14     you mean by the word "documents"?

15        A.   Well, "documents," that means those are parts of a communications

16     plan.  So, for instance, the communications plan code-named Vatra

17     consisted of a number of documents, such as the keys for the codes, and

18     the communications plan code-named Vatra consisted of a code book.  And

19     at a certain point in time, that communications plan was called Vatra.

20     Some, say, 10 months later or 15 months later, the code-name would change

21     to, for instance, Apollo.  Then some few months later, it would be

22     renamed and called Ares.  So all these were code-names for the plan.  The

23     plan, itself, contained keys.  For instance, the plan would have Lines A

24     and B, and then there would follow five-digit numbers that would, in

25     fact, be the keys to the code book.  And then, in alphabetical order,

Page 15128

 1     there would be different terms that are developed in the code book,

 2     itself.

 3             For instance, if there was an aircraft in question, then there

 4     would be a five-digit number that would, in fact, stand for the word

 5     "aircraft"; for instance, that an aircraft was observed or used in an

 6     area and so on.  So this plan could be used for communicating covertly.

 7     In other words, that was the plan for the secret commanding of troops.

 8        Q.   Thank you.  When you say that various services would each develop

 9     their own documents, and you mentioned a moment ago that after some time

10     those documents would have to be changed, is it correct that such

11     documents at times had to be sent by courier to the end user so that they

12     could all change the code-name at the same time or the whole code at the

13     same time, and that this was a timely and risky endeavour?

14        A.   Yes, exactly, because they all had to reach certain centres at

15     the same time, I mean the changes in the plans.  This would be done via

16     radio, for instance, where a special frequency would be agreed, and then

17     they would relay the information about where such code books and plans

18     should be taken over.  And then couriers would take them to these

19     locations at the time, the agreed time, and they would take them over and

20     take them to the centres where they were to be used.  Now, this, of

21     course, was a very timely project.

22             Now, all of the various services developed their own plans, their

23     own systems.  The police had its own and the army had its own, and they

24     were independent of each other, and they developed their own documents as

25     part of their radio communications systems.  However, we could exchange

Page 15129

 1     the documents amongst ourselves.  And if it was necessary, if all our

 2     communication lines were down, we could try and use those plans in order

 3     to establish the communication, pending the repairs of our downed

 4     communications lines or system.

 5        Q.   Thank you.  Major, sir, you prompted me to ask you that in

 6     paragraph 28 of the amalgamated statement, you spoke about these

 7     stationary nodes, Jahorina, Veliki Zep and so on, radio-relay

 8     connections.  Even though each of you had your own documents, did you

 9     share the difficulties you all encountered when there would be a power

10     cut, when the fuel would run out for the generators, when combat would be

11     directed at radio-relay facilities on the hills, and at other times?  Did

12     this equally affect all the services, the police, the military and the

13     ministry?

14        A.   Yes.  Looking at it from my own point of view, and based on the

15     experiences in combat, let's say, during the bombing of facilities at

16     Jahorina, the VRS communications system was damaged.  It was difficult to

17     set up communications between the Main Staff and the units, so then we

18     activated our own system of communications using our centres, and thus we

19     managed to receive information from certain areas.  For example, this was

20     in 1995 when there was an offensive on the Western Krajina, when the VRS

21     communications system was destroyed, when the Jahorina facilities were

22     ripped up from the ground, practically, when the communications were

23     broken down, when it was very difficult to carry out repairs and

24     maintenance.  We used radio communications developed by the Republican

25     Centre for Monitoring Information, Communications, and Cryptographic Data

Page 15130

 1     protection from Pale.  So through this, we managed to convey brief

 2     information to and from the Main Staff, because they could not use their

 3     own communication links to be able to report back and forth about

 4     everything that was happening on the ground.  It was very difficult to

 5     set up communications.

 6             The police also had their own communications system, which I

 7     cannot comment on.

 8        Q.   But that also depended on the status of the relays.  Other than

 9     the radio-relay communications, how much did the other types of

10     communication depend on the PTT system?

11        A.   Well, in quite a lot of cases, they depended a lot on the PTT

12     system of communications, but even that was damaged, because they also

13     used those repeaters, those relays, to maintain the communications.

14        Q.   Thank you.  You told the Defence how, from time to time because

15     of difficulties and lack of equipment, you had to tie equipment to

16     radiators; is that correct?

17        A.   Yes, this is true.  At the beginning of combat activities, this

18     happened at the MUP school at Vraca.  The school was moved.  It passed

19     hands from the B and H MUP to the Republika Srpska MUP, and there was a

20     communications centre there which was destroyed.  And those people who

21     were there, our police that was located in that centre, was unable to

22     communicate with their superiors, their superior commands.

23     Colonel Kotlica and I went downstairs and -- well, it's not an anecdote.

24     Actually, it's our reality.  Since they had some shortwave radios --

25     ultrashortwave radios, in order to set up any kind of communications, we

Page 15131

 1     tied those radio devices of theirs to the radiators, and then they served

 2     as antennas.  So you can imagine how reliable and secure that kind of

 3     connection was.

 4        Q.   Thank you.  You were shown document P2798 today, and the document

 5     has the heading, some sort of counter-electronic warfare.  Is it correct

 6     that the 2nd Corps wire-tapped -- not only the 2nd Corps, but that it was

 7     also trying to listen in to our radio-relay communications?  I'm talking

 8     about the Muslim army here.

 9        A.   Yes, it was registered that they were involved in

10     counter-intelligence activities and that they tried to wire-tap our

11     communications.  This is normal in all kinds of combat, that the enemy

12     tries in any way possible to acquire data by wire-tapping or

13     eavesdropping.  Many times, we had the case of registering such events.

14     The units that were supposed to create peace or implement peace were also

15     involved with that, gathering information from specific units and so on,

16     or about specific units.

17             I cannot really interpret a map which I'm not familiar with.  I

18     saw it for the first time here a little bit earlier.  I don't know what's

19     there, what's what.  I did not draft the map.  I don't know when it was

20     created, in which period.  But I remember that at times when we were

21     supposed to send you a telegram - I don't know if you were in your office

22     or you were somewhere else, I don't remember - you didn't inform us about

23     your movements, but I remember very well that Mr. Milanic, Gordan was a

24     chief on your end at one time, and he informed me - this was summer

25     1995 - that you were going to be somewhere in Banja Luka, and that we

Page 15132

 1     tried to send a telegram to you through the 1st Krajina Corps, if we are

 2     not able to deliver it to your office in Pale.  So I am not able to

 3     actually say what happened, because a lot of time has passed since then.

 4     I couldn't say where you were.  I don't know if you were in the territory

 5     of Pale, or the territory of Banja Luka, or perhaps you were in Belgrade

 6     at the time.  I don't know.

 7        Q.   Thank you.  Major, sir, when you mentioned that, do you happen to

 8     remember that information to secure routes were routed through you?  Do

 9     you remember that I travelled a lot all over the country and that I

10     travelled a lot abroad for negotiations, peace negotiations?

11        A.   Yes, I remember that, and I remember when, for example, you had a

12     peace conference in Lisbon, and Mr. Carrington was there, I think, at the

13     time.  The hydroelectric power-station in Visegrad was mined at the time,

14     and you were supposed to fly from Belgrade to that peace conference at

15     the time, and we managed, since there was the danger of the hydroelectric

16     power-plant being knocked down by that Muslim side, the then Muslim side

17     at the time, we managed to find an architect, the one who actually

18     designed the station, Mr. - can I mention his name? - Dragan Bulajic.

19     And so when you were just getting into the plane, we told you that you

20     can fly freely, without any worries, there's no need to worry, that it

21     was an insignificant amount of explosives, and that it could not really

22     damage significantly the hydroelectric power-plant in Visegrad.

23        Q.   All right, thank you.  Well, about the protected radio-relay

24     communications, you know that we have a whole collection here, that

25     Croatia, itself -- not Croatian from Bosnia, but Croatia practically

Page 15133

 1     recorded every single word of ours that passed through that communication

 2     of ours?

 3        A.   Well, that is possible, probably because the Pleso Airport was

 4     also where the NATO had installed its own listening centres.  We knew

 5     that they had a listening centre there, and all the hostile parties

 6     tried, by all possible means, to register all conversations by various

 7     methods.  We had some devices or stations in our centres which could

 8     register anybody picking up any phone.  These were some Alin stations.

 9     That was the model that operated on low frequencies, and it could

10     register certain telephone conversations just like that.

11             THE ACCUSED: [Interpretation] Thank you.

12             Can I ask for D235 for a second.

13             MR. KARADZIC: [Interpretation]

14        Q.   And can I ask you to look, together with us, at what the

15     situation was with the military communications in 1992.  This is an

16     analysis of combat readiness.

17             Can we look at that document.  That is document D325.

18             No, no, that's not it.  Either we made a mistake or -- combat

19     readiness analysis.  It's a different thing.

20             All right, we have the correct document now, and let's just wait

21     for the English version.  Can we look at 27 in Serbian and page 30 in

22     English, paragraph 1, please.

23             Paragraph 1, I'm not sure if this the correct page.  Yes, it

24     should be.

25             The first paragraph:

Page 15134

 1             "Combat missions in 1992 were characterised by frequent changes

 2     in the situation, continuous operations, heavy shelling of communications

 3     stations and centres, of stationary communications centres, stationary

 4     communications hubs, PTT communication centres, auxiliary PTT

 5     communications centres and connections, at a time of simultaneous and

 6     massive-scale offensive and defensive operations on both sides.

 7             MR. KARADZIC: [Interpretation]

 8        Q.   Is this something that comports with your information and

 9     experience?

10        A.   Well, it's possible.  I'm seeing this type of report for the

11     first time, but it's all possible, it was possible.  Certain nodes and

12     hubs were the targets to be destroyed in order to prevent functioning and

13     to damage the communication lines.  Well, I'm not able to comment on the

14     report.  I did not participate in its drafting.

15        Q.   But the situation sounds familiar to you, doesn't it?

16        A.   Yes, this is quite usual.  There were actions like this; and

17     there was a continuous threat to the nodes and the communications.

18        Q.   Could you please look at paragraph 4?  I don't want to read it,

19     but it says that the biggest problem was the destruction of the

20     stationary section of the system, especially some vital objects like

21     Bjelasnica, Zlovrh and Vlasic?  Was this something that affected you as

22     well, this loss of communications at Mounts Bjelasnica, Zlovrh and

23     Vlasic?

24        A.   Yes, and we had a lot of problems that we had to bridge by other

25     communications, those problems.  For example, we had a lot of problems in

Page 15135

 1     the functioning of the communications in the direction of Herzegovina,

 2     towards Trebinje, because the facility and node at Boracko Jezero,

 3     Orasnica [phoen], was problematic because it was unable to cover the

 4     whole area, so we had problems there and constant back-ups and hold-ups

 5     on the command-and-control line.  There were plenty of problems there,

 6     not just at those three facilities at Bjelasnica, Zlovrh and Vlasic.

 7     There were problems at other places as well.

 8             THE ACCUSED: [Interpretation] Thank you.

 9             Can we look at the following page in the Serbian.  The English

10     page can stay.  Can we look at paragraph 6 in the English, and on the

11     following page in the Serbian, can we look at paragraph 1.

12             MR. KARADZIC: [Interpretation]

13        Q.   Do you agree with what it states here, that the situation was

14     similar with others?  Towards the bottom, there was similarities with

15     other places, and it states that facilities at Ljuta, Konjic, Bosut,

16     Trebevic, were damaged, and other facilities that were earlier in the

17     communications system, these places were damaged; is that correct?

18        A.   Yes, that is correct.

19        Q.   Paragraphs 3 and 4 say the same thing.  On the English, page 31,

20     let's look at paragraphs 1 and 2 from the top.  You can see that on the

21     Serbian page.

22             Eleven facilities, out of a total of 32 facilities, 11 were left

23     or destroyed, three were damaged, and there is a review also about that

24     in the English version on page 31, paragraphs 1 and 2.

25        A.   These facilities were covered by the military, and it was their

Page 15136

 1     duty to compile reports of this kind.  And these reports are quite

 2     realistic.

 3             As far as specific problems were concerned, they informed us, but

 4     they didn't inform us about all the problems; for example, problems at

 5     damaged facilities.  There was time required for radio-relay

 6     communications or certain routes to be set up.

 7             THE ACCUSED: [Interpretation] Can we look at page 29, Serbian,

 8     paragraph 4, and English, paragraph 6.

 9             MR. KARADZIC: [Interpretation]

10        Q.   It's completely the same situation with the VVF radio network

11     which, at the very beginning, with the destruction of other

12     communications, has completely been thrown out of the communications

13     system.  Can you please tell us what this WWF system is?

14        A.   This is very high-frequency radio waves.  We didn't have a system

15     like that, this was a system that the army had, and these were the types

16     of problems they were facing.  I don't recall us working with the VVF

17     communications at our centre.

18             THE ACCUSED: [Interpretation] Thank you.  Can we look at page 35

19     in the Serbian and page 39 in the English now.  Last paragraph on the

20     Serbian page, and in the English, page 39, paragraph 3, where it is also

21     noted that there is lack of staff, senior officers at key posts, and it

22     is noted that there are no radio-relay technicians, radio teleprinter

23     operators, and so on and so forth.

24             MR. KARADZIC: [Interpretation]

25        Q.   Was this something that crippled the military as well and damaged

Page 15137

 1     its capability to communicate?

 2        A.   Well, there were problems like this throughout the whole

 3     1992-1995 period, and it is precisely for these reasons that we were

 4     facing certain problems, shortage of staff with certain special skills;

 5     for example, radio technicians, radio-relay operators, radio teleprinter

 6     operators.  There were problems, and because of that and because of what

 7     the army needed at the beginning, we talked about organising and the

 8     classification of posts in our system, from the regional to the municipal

 9     level.  We organised all those three functions, the Municipal Centre, the

10     Regional Centre and the Republican Centre, with the same number of

11     people.  That was eight people plus the odd colonel or the communications

12     manager, who was the ninth man.  But as I said, he died in 1994, so we

13     were left with a set number of eight people who had to perform all the

14     duties and tasks that were before us from 1992 to 1995.  There was this

15     shortage of staff in all the units, and this was a major problem.

16        Q.   Thank you.  I would like to briefly refer you to a portion of the

17     interview of General Subotic.  That's 65 ter 22622, page 3, please.

18             I will read out a portion of his answer.  That's toward the

19     bottom of the page.

20             Could we please yes, scroll it down.  Thank you.

21             [In English] "Yes, of course.  Regular reports were sent.

22     Regular reports.  Practically daily reports.  After the communications

23     system were set up.  I would say that that started in the beginning of

24     1993.  Halfway through 1992 to the end of 1992, it was based on what was

25     possible.  But from 1993, we had communications between ..."

Page 15138

 1             And so on.

 2             [Interpretation] Do you agree with this statement of

 3     General Subotic, that from 1992 to the end of 1992, it was based on what

 4     was possible, but then in 1993, a communications system sort of became

 5     settled?

 6        A.   Well, yes, basically we could take this to be a true description,

 7     because we were attached to the Ministry of Defence, and General Subotic

 8     was there at the beginning of the war as the minister of defence.  We

 9     sent regular reports on the telegram and other traffic, which went

10     through the regional and republican and municipal centres.  And this is a

11     very good observation, and I believe that he gave a pretty good picture

12     here in his report.

13             THE ACCUSED: [Interpretation] Thank you.

14             I believe that Mr. Gaynor will need some time to put questions to

15     you, so I will just have one final question -- or, rather, one final

16     topic.

17             MR. KARADZIC: [Interpretation]

18        Q.   Did you read everything that you sent, and did you read

19     everything that came in to your centre?

20        A.   Each operative who worked at the Communications Centre,

21     especially at the encryption station, had to read and review what had

22     arrived, and then to be -- and then to be aware if there was any

23     interventions needed.  But you know how it was.  In our work, you had to

24     forget what you had read out as soon as you've done it.  So we didn't do

25     any corrections or anything.  We just returned documents to the senders.

Page 15139

 1     For instance, for us it was very important to have -- to know the exact

 2     log-books -- to keep the log-books very precisely so that those log-books

 3     would show each document coming in or going out; the time, date, and so

 4     on.  However, there were a lot of documents in our log-books that were

 5     not only from our republic centre, where I was the chief of centre in

 6     1995, and those log-books were not very up to date.  There were a lot of

 7     omissions that I was able to observe.  But whether the officers took any

 8     measures to improve the way records were kept, I don't know.  But in any

 9     case, the information should be contained in the log-books as to who the

10     document was sent by, who it was processed by, and whom it was sent to.

11        Q.   I wanted to ask you whether there was anything, in your

12     knowledge, that was ordered or recommended or proposed and that would be

13     against the law, in terms of the laws of war, anything.  So was there

14     ever any order that would not be in keeping with those laws and

15     regulations?

16        A.   As far as your orders or any written document coming from you, or

17     orders or decisions coming from any of the commanders, irrespective of

18     the level, all of these men were highly educated, and they were fully

19     aware of the time and space where they were working and operating and

20     what was going on, and I know that you always ordered that each

21     individual, from the very last private up until to the highest officer,

22     had to be aware of the laws on war and the Geneva Conventions in order to

23     be able to act in keeping with them.  And that was an order that was

24     issued by you, and I know that at the centre where I worked as the chief

25     of the service, I informed everyone, to the last officer, of the Geneva

Page 15140

 1     Conventions and all of its provisions, but particularly those that

 2     related to prisoners of war and the treatment of civilians.  And as far

 3     as I can recall, I cannot remember any instance where you ordered

 4     anything that would be contrary to law and legal provisions.

 5             THE ACCUSED: [Interpretation] Thank you, Major, for making the

 6     effort to come to The Hague to testify.

 7             THE WITNESS: [Interpretation] Thank you, Mr. President, and thank

 8     you, Your Honours.

 9             JUDGE KWON:  Any questions from you for re-examination,

10     Mr. Gaynor?

11             MR. GAYNOR:  Very briefly, Mr. President.

12             JUDGE KWON:  Yes.

13             MR. GAYNOR:  Thank you.

14                           Re-examination by Mr. Gaynor:

15        Q.   Major, earlier on today you gave evidence that -- I'll read out a

16     quote of what you said:

17             "For example, this was in 1995, when there was an offensive on

18     the Western Krajina, when the VRS communications system was destroyed,

19     when the Jahorina facilities were ripped up from the ground, practically,

20     when the communications were broken down, when it was very difficult to

21     carry out repairs and maintenance."

22             Do you remember that evidence?

23        A.   Yes, I do remember that.  This was in 1995, on the 30th of

24     August, 1995, at 0155 hours, when the mass bombing of Republika Srpska

25     began, and especially the bombing of a communications centre in Jahorina

Page 15141

 1     and Pale.  So not only were they disrupted, the systems; they were ripped

 2     out of the ground.  And when I say "ripped out," I mean with all the

 3     bombing, where very heavy bombs were used, they just came out of the

 4     ground.  And all of these systems were disrupted.  In Jahorina alone, we

 5     had 5 dead and 3 wounded soldiers.  The entire facility was destroyed.

 6     People were practically blown out or blown away from the facility.  We

 7     couldn't even recover their bodies.

 8             And as for the main relay centre at Jahorina, the so-called U-4

 9     facility where there was Captain --

10        Q.   I'm sorry to interrupt.  It was the date of the incident that I

11     was interested in, and --

12             JUDGE KWON:  Just before you --

13             MR. GAYNOR:  Yes.

14             JUDGE KWON:  How long would you expect?

15             MR. GAYNOR:  Literally, about two minutes.

16             JUDGE KWON:  Thank you.

17             MR. GAYNOR:  If that could be provided.

18             Yes.  Could I call up, please, 23160.

19        Q.   If you'll see this document in front of you, you'll see it's

20     dated the 30th of August, 1995.  And on the next page, we'll see it comes

21     from General Mladic.  And this, indeed, in the first paragraph, refers to

22     what you've just described, if we go back to page 1.  You just described

23     the large-scale NATO attacks on the 30th of August.  Can you just look at

24     the first paragraph and tell me if this is what you were referring to?

25             Could we -- thank you.  If we could blow up paragraph 1, please,

Page 15142

 1     in the B/C/S.

 2        A.   Yes, this is a reference to that same incident, and I remember

 3     that I received a report from the Main Staff, from General Tolimir.  I

 4     was advised that we might be targeted, that there was -- that we were one

 5     of the possible targets.  And he also mentioned the possible time, 01,

 6     03, 05, 07, and so on.

 7             MR. GAYNOR:  Thank you.

 8             I'd like to tender that and just to show one other document.

 9             Could I have 23159, please.

10             JUDGE KWON:  In the meantime, that will be admitted.

11             THE REGISTRAR:  As Exhibit P2825, Your Honours.

12             MR. GAYNOR:  The next document is also dated the 30th of August,

13     1995.

14        Q.   This document is not in your language, I'm afraid, Major, but it

15     is from Janvier at UNPF in Zagreb to Annan at UN --

16             JUDGE KWON:  I think we have the translation.

17             MR. GAYNOR:  Do we have it in -- I beg your pardon.  Yes, thank

18     you, Mr. President.

19        Q.   Now, on the first paragraph of this document, Major, you see a

20     reference to NATO air-strikes, and it says they were predominantly

21     targeted against the Bosnian Serb Integrated Air Defence System, that is,

22     radar, missile and communications sites.  Do you see that?

23        A.   Yes.

24        Q.   Now, is that also a reference to the attack that you were

25     referring to earlier?

Page 15143

 1        A.   Yes, this is a reference to that, except that the attack started

 2     exactly at 0155 hours; not at 0210 hours, but it started exactly at 0155

 3     hours on the 30th of August.

 4        Q.   Do you happen to be aware of any co-ordinated NATO attack on

 5     Bosnian Serb communications targets prior to 30th of August, 1995?

 6        A.   Well, there were air-strikes.  For instance, there was an

 7     air-strike on the 25th and the 26th of May, 1995, in other words, some

 8     three to four months prior to this, and these were air-strikes on Pale,

 9     and some warehouses were destroyed at the Jahorinski Potok site, where

10     the Depot 23 was destroyed.  And a private was lightly wounded at the

11     time, but there was a lot of material damage.  This was an air-strike on

12     the 25th.  There were six aircraft which participated in the attack, in

13     the air-strike.  The aircraft were A-10 Thunderbolt and F-16.  And on the

14     26th, there were 14 air-strikes, also targeting Jahorinski Potok and

15     destroying several ammunition depots.

16        Q.   Can I interrupt there just so --

17        A.   Yes.

18        Q.   -- we can get through this as soon as possible.

19             Though air-strikes, can you confirm, to the best of your

20     knowledge, they were targeting ammunition dumps or depots, as you've just

21     said?

22        A.   These air-strikes of the 25th and 26th targeted also ammunition

23     dumps.  However, before they destroyed the ammunition dumps, it would be

24     necessary - and this would be in any army - to destroy anti-aircraft

25     defence facilities.  And in order to do that, you also have to destroy

Page 15144

 1     communications centres and nodes because it is necessary to disrupt the

 2     command-and-control chain.  And the forces that carried out these

 3     air-strikes, they carried out air-strikes of these facilities on the

 4     ground, but they also protected the air-space from any other flights.

 5     However, they did not accomplish what they were supposed to, but they did

 6     bomb and carry out air-strikes on any facility that could present a

 7     threat to them.  So they did conduct air-strikes on communications

 8     centres; for instance, on Jahorina, where there was a communications

 9     centre for the Main Staff which had links to the other units in that

10     territory, because I remember that when that was accomplished, they flew

11     at a lower height, altitude, and they just sort of waved their wings and

12     flew away.

13             Mr. Gaynor, I thank you for treating me fairly, and I thank you

14     for having understanding for me, but you will understand that I am kind

15     of eager to get home.

16             MR. GAYNOR:  Yes, absolutely.  I think I'll just end with this,

17     Major.

18        Q.   The air-strikes targeting the ammunition dumps in Pale have been

19     the subject of evidence before Their Honours already in this trial.  Are

20     you suggesting that there was an attack on Bosnian Serb military

21     communications facilities prior to the May attack, similar to the one

22     which started on the 30th of August, 1995, or could it be that you're

23     thinking of the one that started on the 30th of August, 1995?

24        A.   Mr. Gaynor, any attack against any target requires very careful

25     preparation and protection of one's own forces from strikes from the

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 1     other party.

 2             Now, I remember this attack of the 25th of May, 1995, which,

 3     during the first air-strike on the Jahorinski Potok Barracks, that attack

 4     started sometime at around 1550 hours, around 4.00 p.m., in other words,

 5     and there were six aircraft that participated, that took part in that

 6     attack.  They were F-16 aircraft.  And on that occasion, the

 7     Ammunition Dump 23 was destroyed, and one soldier was slightly wounded.

 8     However, when you have a synchronised attack against such facilities, you

 9     also have to ensure that there is radio communications and electronic

10     jamming to disable the anti-aircraft defence system.

11             On the 26th of May, there were 14 formations that took part in

12     the air-strike on Jahorinski Potok, and as a man who was at the

13     Centre for Monitoring and Information, I monitored all the information

14     through my own system regarding the situation in air-space on that

15     territory.  And we registered 14 formations that carried out sorties

16     against 26 facilities in Jahorinski Potok.

17             THE INTERPRETER:  Interpreter's correction:  On the 26th of May.

18             THE WITNESS: [Interpretation] There was a problem with these

19     facilities at Jahorina because, in addition to a radar installation that

20     was monitoring the air-space between the Mediterranean Sea and the

21     territory of Yugoslavia, the thing is they had to disable those radars as

22     well.  There was strong jamming and also some targeting of those antenna

23     systems and radar installations.  And as soon as that happened, as soon

24     as you targeted those facilities, immediately you would disrupt the

25     communications system.

Page 15146

 1             I don't know if that answers your question.

 2             MR. GAYNOR:  Mr. President, I'd like to tender the cable from

 3     Janvier to Annan of the 30th of August, 1995.

 4             JUDGE KWON:  Thank you.

 5             MR. GAYNOR:  I have no further questions.

 6             JUDGE KWON:  That will be Exhibit P2826.

 7             And by hearing nothing from you, Mr. Tieger, I take it that

 8     there's nothing to be added to what is contained in your written response

 9     about the disclosure violation.

10             MR. TIEGER:  I'm sorry, you were.

11             When you indicated the end of the day, we are preparing a written

12     submission which will be filed by close of business.

13             JUDGE KWON:  Thank you, Mr. Vukovic.  That concludes your

14     evidence, and on behalf of the Tribunal and the Bench, I'd like to thank

15     you for your coming to The Hague.  Now you are free to go.

16             THE WITNESS: [Interpretation] Thank you, Your Honour.  And I

17     thank the Tribunal, and also the Prosecution, as well as the accused.

18             JUDGE KWON:  I'd also like to extend my thanks to the staff

19     members for their patience.

20             Tomorrow morning at 9.00.

21                           [The witness withdrew]

22                           --- Whereupon the hearing adjourned at 2.41 p.m.,

23                           to be reconvened on Wednesday, the 22nd day of

24                           June, 2011, at 9.00 a.m.