1 Tuesday, 3
2 [Open session]
3 [The witness entered court]
4 --- Upon commencing at 2.05 p.m.
5 [The accused entered court]
6 JUDGE RODRIGUES: [Interpretation] Good afternoon all, to the
7 technical booth, the interpreters, the registry staff, the counsel for the
8 Prosecution and for the Defence. Good afternoon, General Krstic.
9 As you see, we are sitting without Judge Fouad Riad who had a
10 medical appointment so he was unable to join us. So Judge Wald and
11 myself, we decided to sit in accordance with Rule 15 bis. I think that we
12 were about to complete the cross-examination of our witness.
13 Let me remind you once again that you are still testifying under
14 oath and I will give the floor to Mr. Harmon to complete your
15 cross-examination please.
16 MR. HARMON: Good afternoon Judge Rodrigues, Judge Wald. Good
17 afternoon counsel.
18 WITNESS: WITNESS DB, [Resumed]
19 [Witness answered through interpreter]
20 Cross-examined by Mr. Harmon [Continued]
21 Q. DB, good afternoon.
22 You testified that you moved the communications vehicle from the
23 forward command post at Pribicevac at approximately 1900 hours on the 11th
24 of July, and in your previous testimony, you testified that you did so
25 unilaterally without an order from either General Krstic or General
1 Mladic. Do you remember that testimony?
2 A. Yes, I remember having said that I don't know whether one of them
3 had given me the order but that most probably, based upon my own
4 judgement, I moved the communications centre.
5 Q. Let me clarify what you did say, because what you have just said
6 is a little different. I will refer you to the transcript at page 7257,
7 lines starting at line 25 and going over to 7258 lines 1 through 3.
8 At 7257, line 25 you were asked this question by me on the 8th of
9 November 2000:
10 Q. Did you receive an order from either General Krstic or
11 General Mladic to pack up the mobile communications centre and
12 proceed to Bratunac?
13 A. I did not get such an order.
14 On page 7263, I'm referring to that page lines 13 through 18. I
15 asked you the question:
16 Q. Let me repeat my question to you, Witness DB. Did you
17 receive an order to dismantle the communications centre of the
18 forward command post from either General Krstic or General
20 A. No.
21 Q. And is it your testimony that you unilaterally made that
23 A. Yes.
24 Now, is it your testimony today that you may have received that
25 order but you don't remember that?
1 A. I think I did not receive that order and that on the basis of my
2 own judgement of the situation, I packed up the centre and moved it.
3 Q. Now, who was the Commander of the Drina Corps on the 11th of July,
5 A. I think it was General Zivanovic.
6 Q. Did you receive an order from General Zivanovic to move the
7 communications centre of the forward command post at Pribicevac?
8 A. No.
9 MR. HARMON: Could the witness please be provided with Prosecution
10 Exhibit 402, tab 4. Mr. Usher, if you could place -- I could show you the
11 English version of which page to place in just a minute.
12 Q. But Witness, 402, tab 4, the exhibit in front of you is "The Rules
13 of the Corps of the Ground Forces Provisional" dated 1990, and rules which
14 General Krstic said in his testimony were operative and applied to the
16 MR. HARMON: Now, Mr. Usher, if you could kindly place the page 38
17 of that version, the English version and what should be your first tab on
18 the ELMO.
19 Q. And Witness, I'm going to refer you to a portion of this document.
20 It has been tabbed for your convenience, and if you turn to the first tab,
21 please, in that document, it should be tabbed in the B/C/S version. It
22 should be a blue tab on the document. If you would turn to the portion
23 that deals with the command posts, and specifically -- let me ask you,
24 Witness, are you familiar with these rules?
25 A. I think that everything that is contained in these rules was
1 studied by me as well, though I was never Corps Commander.
2 Q. Now, I'd like to draw your attention, please, Witness, to
3 paragraph 129 of these rules which falls in the section dealing with
4 command posts, and if you would take a look at and read to yourself
5 paragraph 129, I will read it in English while you're looking at it in the
6 B/C/S. "The command moves from one command post to another following the
7 plan or in emergency, but always by decision of the Commander and with the
8 approval of the senior officer. The time of the move is notified to
9 directly subordinated commands, the headquarters of Territorial Defence,
10 neighbours, and, as required, bodies of socio-political communities and
12 Now, this particular section, Witness DB, deals with command posts
13 being of three types: principal command posts, logistical command posts,
14 and forward command posts. Could you turn -- have you had a chance to
15 read that section, Witness?
16 A. Yes, I've read point 129.
17 JUDGE RODRIGUES: [Interpretation] Yes, Mr. Petrusic.
18 MR. PETRUSIC: [Interpretation] Mr. President, the Defence objects
19 to this question. It is my impression that the Prosecutor is going beyond
20 the scope of the examination-in-chief and also the testimony of this
21 witness in the rejoinder case, simply because it is entering into the
22 rules and responsibilities and the organisational structure of the army of
23 Republika Srpska with respect to reporting of the command post and forward
24 command post.
25 The main question here is whether the command post on the 11th of
1 July, as testified by the witness, was operational after 1900 hours or
2 not. Whether it was dismantled in accordance with the rules of the corps
3 of the ground forces of the former SFRY or not is a question which this
4 witness could answer if asked by an investigator within his organisation,
5 and I do not see that that fits into the purpose of the proceedings here.
6 Therefore, this whole series of questions being put by my learned friend
7 we are objecting to.
8 JUDGE RODRIGUES: [Interpretation] Mr. Harmon.
9 MR. HARMON: Mr. President, this witness testified about the move
10 of the communications centre and the forward command post on a certain
11 date, at a certain time, and under certain conditions. I intend to direct
12 his attention to rules that apply to the movement of communication
13 centres. I've only directed his attention to the first of two provisions
14 in this, but I'd like to direct his attention to -- and will have bearing
15 on the question of who he received an order from and when he received that
16 order to move the communications centre. That's the relevance of it.
17 MR. PETRUSIC: [Interpretation] I beg your pardon, Mr. President.
18 May I respond? If that is the subject, if that is the question, then the
19 witness has answered that question on the 8th of November and also today.
20 JUDGE RODRIGUES: [Interpretation] Mr. Petrusic, there seems to be
21 two points that you have raised: the scope of the cross-examination. As
22 you know, we have adopted a rather flexible interpretation of the rules
23 with respect to the scope of the cross-examination in relation to the
24 examination-in-chief. The other point that you raise, what I think is
25 that Mr. Harmon has -- is confronting the witness with a statement that he
1 himself transferred the communications centre. So Mr. Harmon is trying to
2 see whether he respected the rules or not which the witness should have
3 known. Therefore, I'm going to ask Mr. Harmon to continue with his
4 questions, Mr. Petrusic.
5 Please proceed.
6 MR. HARMON:
7 Q. Witness DB, if that -- I would like that -- strike that. I would
8 now like to direct your attention to the second blue tab that is in the
9 package of materials in front of you. It falls within the same section
10 and is part of provision 129.
11 MR. HARMON: And if you, Mr. Usher, could place that section on
12 the ELMO.
13 Q. Would you read to yourself the section that has been tabbed,
14 Witness DB. Have you had a chance to read that?
15 A. Yes.
16 Q. Let me read this into the record, the portion that I'm referring
17 to: "Communications centres are dislocated in keeping with the
18 dislocation of the command while securing uninterrupted communications."
19 Now, these rules, this rule 129, puts forth two propositions:
20 One, the command can only move based on the decision of the commander; and
21 second of all, that communication centres are dislocated in keeping with
22 the dislocation of the command.
23 Witness, let me ask you again: Did you receive an order from
24 General Zivanovic, General Krstic or General Mladic to dislocate the
25 communications centre of the forward command post of Pribicevac?
1 A. In the execution of our orders, there is a principle known as
2 self-initiative. It implies that one may take upon oneself responsibility
3 for certain acts and procedures which perhaps may not be fully in accord
4 with the rules and regulations as they are stipulated here. On that date
5 and at that time, in accordance with the evolution of the combat
6 situation, both my Commander and Chief of Staff had left the forward
7 command post. They had gone forward following combat operations and all
8 that remained of the forward command centre was the communications
10 A command post is an all-embracing concept including many elements
11 of which the communications centre is one only. I did have uninterrupted
12 communications because a soldier with a mobile device was in the command
13 vehicle of General Krstic whereby uninterrupted communications was
14 guaranteed. However, as there was no one left at the forward command post
15 because of the very rapid development on the front line, everyone else had
16 gone forward so that means all of the other elements of the command post.
17 I gave myself the right to make my own judgement. Instead of
18 staying behind and spending the night there alone with five soldiers, I
19 followed the combat formations which were changing rapidly in accordance
20 with the offensive as it developed. So that I think that with respect to
21 the transfer of the communications centre, I did not receive orders from
22 anyone. I took the decision on the basis of my own judgement, and I
23 explained this in detail to the investigator Ruez, and to you during my
24 previous testimony.
25 I find this to be quite normal and customary as I had been left
1 behind with five or six soldiers whereas everyone else had gone on
3 Q. At the time you left the Pribicevac area, Obrad Vicic was present,
4 wasn't he?
5 A. No. I don't know whether you are trying to mislead me. I told
6 you last time that Colonel Vicic and Lieutenant Colonel Kosoric were not
7 present. They had left the forward command post either before or just
8 after General Krstic. All I know is that they were not there. I think
9 that I have just given you an identical answer to what I gave during my
10 previous testimony.
11 Q. And are you aware, Witness DB, that General Krstic said that on
12 the 11th of July at approximately 8.00 p.m., he was at the forward command
13 post in Pribicevac and present at that location were Obrad Vicic, his
14 operations officer, Lieutenant Amovic, and Lieutenant Colonel Kosoric.
15 Are you aware of that testimony?
16 A. I am not aware of that testimony.
17 MR. HARMON: Your Honours, I would direct Your Honours' attention,
18 I won't read that now, but I would direct Your Honours' attention now to
19 General Krstic's testimony, pages 6195 to 6215, and you'll find in the
20 testimony those -- that information that I've just revealed to Witness
22 Q. Now, Witness DB, at the time you packed up your communications
23 centre and moved unilaterally on your own decision, were you aware that
24 there was going to be an attack on Zepa, or did you learn for the first
25 time about the new operation that was planned against Zepa at the Bratunac
1 Brigade headquarters at the meeting that took place at 2200 hours that
2 same day?
3 A. Could you please put your question to me precisely? You started
4 your question by saying, "When you were packing up, did I learn about it,"
5 and then later on during the meeting at the Bratunac headquarters. What
6 precise time are you referring to, please?
7 Q. In previous testimony you said that on the 11th of July, at
8 approximately 2200 hours, you drove in your communications vehicle through
9 Potocari to Bratunac. Can you hear me?
10 A. I can't hear the interpreter very well. It's all right now.
11 Q. Can you hear the interpreter now, Witness DB?
12 A. Yes.
13 Q. Your previous testimony, Witness DB, you said that after you
14 packed up the communications centre at Pribicevac, you drove to Bratunac
15 and you attended a meeting where General Mladic was present, General
16 Krstic was present, General Zivanovic was present, the Brigade Commanders
17 were present, and General Mladic ordered General Krstic to form groups to
18 go attack Zepa. And my question to you, Witness DB: Was that the first
19 time that you learned about the new operation that was going to be mounted
20 against Zepa?
21 A. Yes. That was the first time at that meeting in the command of
22 the Bratunac Brigade some time around 2200 hours, I learned from the
23 orders of General Mladic that all units should be regrouped and should
24 head towards Zepa.
25 Q. Okay. Now, it's the Prosecutor's submission in this case, Witness
1 DB, that the communications centre at the forward command post in
2 Pribicevac was not moved on the 11th, it was moved at a time later than
3 that. What do you say to that?
4 A. I can only repeat all that I have already said to the investigator
5 and during my previous testimony. After the 11th of the evening, a
6 soldier signalsman stayed with General Krstic with a mobile device and
7 General Krstic, as he moved after the evening of the 11th, when I, with my
8 communications vehicle, headed towards Vlasenica could have used that
9 mobile device to command units that had still remained in the broader area
10 of Srebrenica.
11 All the other elements of the communications centre, including the
12 radio relay connection, the encrypted lines, and the teleprinter lines
13 moved with me and the other soldiers, signalsmen, to Vlasenica where we
14 arrived at about 2400 hours. And the communications centre ceased to
15 exist at Pribicevac around about 1900 hours on the 11th of July, and
16 General Krstic had, at his disposal, only a single mobile device for
17 communications purposes.
18 Q. It's further the Prosecution's submission, Witness DB, that the
19 forward command post communications centre at Pribicevac was not moved
20 until after the Drina Corps Command was informed that the new operation
21 was to take place at Zepa, and was to commence on the 14th of July.
22 That -- it's further the Prosecution's submission, Witness DB, that such a
23 scenario is consistent with the rules that you and I have discussed and
24 that are found in Prosecution Exhibit 402, tab 4.
25 Now, let me ask you just a few more questions. When you moved the
1 communications centre --
2 JUDGE RODRIGUES: [Interpretation] Mr. Harmon, excuse me for
3 interrupting, but we really do have to finish the cross-examination.
4 Though we do have a flexible interpretation for the cross-examination, but
5 there are time constraints and I think you have already overstepped the
6 amount of time used by the Defence for the examination-in-chief so I'd
7 like you to wind up.
8 We're only working until 4.00 today, I should like to let you
10 MR. HARMON: I intend to comfortably finish within that time
11 frame, Mr. President.
12 Q. When you left the forward command post in the communications
13 vehicle, were you escorted by other vehicles of the VRS or did your
14 vehicle travel to Bratunac unescorted?
15 A. My vehicle travelled unescorted because there were no other
16 vehicles apart from, perhaps, one vehicle of the command headquarters but
17 as far as I remember, it was a transport vehicle.
18 Q. How many people were in the vehicle besides yourself?
19 A. In my vehicle, there are about four or five soldiers apart -- in
20 addition to myself.
21 Q. Is a communications vehicle -- strike that. Where were you seated
22 in the vehicle?
23 A. I was seated next to the driver as a co-driver.
24 Q. Who was the driver?
25 A. The vehicle was driven by the driver.
12 Blank page inserted to ensure pagination corresponds between the French
13 and English transcripts.
1 Q. Where were the other persons seated?
2 A. The other soldiers were sitting in the cabin of the vehicle, in
3 the communications system section.
4 Q. Did the communications system section, the cabin, have windows you
5 could look out?
6 A. There is the entrance door and very small slits, small windows or
8 Q. Now, after you left Bratunac on the 11th, could you just identify
9 the road and the villages that you passed through to arrive at Vlasenica?
10 A. Let me repeat my November testimony. The road I took was
11 Bratunac-Krivace-Konjevic Polje-Kasaba-Milici-Vlasenica.
12 Q. Were you escorted on your route to Vlasenica?
13 A. Nobody was assigned for an escort of any kind, but in front of us
14 there was a passenger car from Bratunac and there was also a truck, and I
15 remember that we were the third in line, approximately. We did not pass
16 anyone on the road. So this was a sort of encouragement for us because we
17 thought that some groups of the 28th Division were perhaps moving in the
18 same direction, so this helped us. It was important for us to know that
19 we had during the night somebody in front of us. And as I say, we didn't
20 overtake anyone on route.
21 Q. Witness DB, thanks very much.
22 MR. HARMON: I have no additional questions.
23 JUDGE RODRIGUES: [Interpretation] Thank you, Mr. Harmon.
24 Mr. Petrusic, any additional questions?
25 MR. PETRUSIC: [Interpretation] Yes, thank you, Mr. President, very
1 briefly, just a few.
2 I should like to ask the usher to provide us with OTP Exhibit 881,
3 please, and 882.
4 Re-examined by Mr. Petrusic:
5 Q. And while we're looking for those exhibits, Witness DB, in your
6 testimony you referred to a statement you gave on the 4th of April to the
7 Office of the Prosecutor in Banja Luka. Did you receive that statement?
8 Do you in fact have that statement with you or at all?
9 A. No, I do not.
10 MR. PETRUSIC: [Interpretation] Mr. President, to save time,
11 perhaps I could give the witness a copy and it could be placed on the
12 ELMO. Would you place the first page on the ELMO, please. Thank you.
13 Q. Witness DB, this interview or, rather, newspaper article is dated
14 the 24th of July, 1995, and in the last sentence of this article, mention
15 is made of General Krstic. On the 24th of July, 1995, was General Krstic
16 the Commander?
17 A. I think he was on that date.
18 MR. PETRUSIC: [Interpretation] On the -- could we have the
19 photograph placed on the ELMO now, please.
20 THE INTERPRETER: Could counsel speak into the microphone,
21 please. We're having trouble hearing.
22 MR. PETRUSIC: [Interpretation]
23 Q. On this photograph, it is the assumption that Colonel --
24 Lieutenant Colonel Svetozar Andric is sitting there, that he's in the
1 A. Yes. It could be him, yes.
2 Q. Lieutenant Colonel Andric was the Commander of the Biscani
4 A. Yes, at the time he was the Commander of the 1st Biscani Infantry
5 Brigade -- Birac Brigade.
6 Q. The Birac Brigade had its headquarters in Sekovici; is that right?
7 A. Yes.
8 Q. This individual here wearing the black shift or jacket whom the
9 Prosecution maintains is Miso Pelemis, is that individual from Sekovici or
10 the surroundings of Sekovici; do you know, happen to know?
11 A. Yes. He's from the village of Pelemici, and that is near
12 Sekovici, a village that was burnt in 1992, and I know that at the
13 beginning of the war he was the Commander of a battalion in that brigade.
14 Q. Bearing that in mind, Miso Pelemis at the beginning of the war,
15 therefore, was the Commander of the battalion in the Birac Brigade; is
16 that right?
17 A. Yes. At the start of the war he was a battalion commander --
18 first of all, a light assault unit or intervention unit within the
19 composition of this brigade, and later on he was even the Commander of a
20 battalion in the brigade commanded by the then Colonel Andric.
21 Q. Bearing that in mind, Witness DB, do you allow for the possibility
22 that this photograph was taken in some other area, in another locality
23 within the zone of the Birac Brigade while the two of them were superior
24 and subordinate?
25 A. Yes, that is highly probable, and I mentioned that yesterday,
1 because we have the defence positions, and had this photograph been taken
2 at Zepa, we were there in an attack. We did not remain or set up our
3 defence positions there, so it is highly possible. And as I deal in
4 newspaper work myself, this is probably a photograph where Colonel
5 Svetozar Andric was taken -- a picture of him was taken with his former
7 MR. PETRUSIC: [Interpretation] I should now like to ask the usher
8 to place Exhibit 882 on the ELMO, please.
9 Q. Witness DB, during yesterday's testimony you were informed of the
10 contents of this conversation, and I don't want to refer back to that. I
11 have a question of my own. This question [as interpreted] was recorded on
12 the 25th of June, 1995, and my question is the following: On the 25th of
13 June, 1995, was the forward command post at Pribicevac functioning,
15 A. No.
16 Q. Witness DB, thank you. I have no further questions for you.
17 MR. PETRUSIC: [Interpretation] Mr. President, the Defence has
18 concluded its examination of this witness. Thank you.
19 JUDGE RODRIGUES: [Interpretation] Thank you very much,
20 Mr. Petrusic.
21 Madam Judge Wald has the floor.
22 Questioned by the Court:
23 JUDGE WALD: I have only one question, and it's a general
24 operational question. If a communication is being sent to the forward
25 command post wherever, and before it gets there the forward command post
1 communications centre is dissembled along the lines that you packed up and
2 moved someplace else, what happens to the communication? I mean, what
3 precautions or protections are taken if it can't get to the communications
4 centre which has been dissembled to make sure it gets to whoever it was
5 addressed to? What's the procedure?
6 A. When the teleprinter operator gets from the encoder an encoded
7 message, he calls the dispatcher at the forward command post to dispatch
8 it to him, to send it on to him. Now, if at that particular point the
9 forward command post is being moved or the communication lines are severed
10 and impossible to each, then the teleprinter operator hangs up the
11 telegram on a position where undispatched telegrams are put, and he tries
12 to establish in any way other communication with that particular unit or
13 the forward command post for him to be able to send the telegram on.
14 If he is not successful, then after a certain period of time it is
15 his duty to inform the person who wrote the telegram to say that there has
16 been an interruption in communication lines, that he was unable to hand
17 over the telegram. But the telegram itself then waits for the first
18 opportunity, depending on the urgency of the telegram, of course, to be
19 sent to the person it was intended for.
20 JUDGE WALD: And just a short follow-up. If that happens and the
21 teletype operator finds out that in fact he can't deliver it to the --
22 because the forward command post communications centre has been
23 dissembled, roughly how long do you think it would be before the message,
24 if he can't find the other person -- I mean, if he tries to find the
25 person that should have been at the forward command post in some other
1 place, he tries to find out where he is and get it sent to him there, is
2 that what you said? And if he can't, it stays with undelivered telegrams
3 until he can find a place to send it, and meanwhile he calls the sender
4 and informs the sender, "I wasn't able to deliver it," right? Is that --
5 that was the essence of your answer?
6 A. Yes.
7 JUDGE WALD: Okay. Roughly how long would that process take?
8 Like, in your experience, what's the longest time it's ever taken for a
9 so-called undelivered message to finally get to its, to its recipient
10 through this process? I mean, do sometimes messages lie undelivered for
11 days or weeks, or is it pretty much, much more common in your experience
12 for them to get to the recipient within a couple of hours or something
13 like that?
14 A. Well, the time can differ quite a lot, depending on the specific
15 circumstances of each individual case and the situation on the front and
16 combat operations and so on and so forth. If the communications centre
17 has been dismantled, destroyed, that is to say, it cannot be sent, if the
18 communications centre has been dissembled and transported elsewhere, then
19 the printer operator seeks ways and means to deliver the message, but he
20 can't keep a telegram ad infinitum without sending it on.
21 If this time is prolonged, he must inform the writer of the
22 telegram that he is unable to deliver the telegram for the time being and
23 that he has not sent it on to the recipient, and then other steps are
24 taken if the communication lines are down. Perhaps a courier is used to
25 take the telegram. Everything depends on whether the telegram is an
1 urgent and important one or not.
2 JUDGE WALD: Who makes the decision whether it's urgent or
3 important, the teletype operator?
4 A. The teletype operator gets the telegram with a mark on it saying
5 whether it's urgent, priority, whether it has priority or whether it is an
6 operational telegram. So it says on the telegram when the teleprint
7 operator receives it. If it is urgent, he sends it on. If it sent then
8 they pass on the urgent telegrams, and then the others are sent on
10 JUDGE WALD: My last question: In your experience, in the
11 majority of cases, in the majority of cases, how long before a telegram
12 marked "urgent" that you would get back to the sender if you couldn't
13 deliver it?
14 A. He must inform the teletype operator if he fails to send the
15 telegram on within two hours, within two hours. Then he informs the
16 person sending the telegram, writing the telegram, and then he will tell
17 him whether he insists that the telegram be sent on or whether he will
18 find another means of having the telegram delivered.
19 JUDGE WALD: Thank you.
20 JUDGE RODRIGUES: [Interpretation] Thank you very much, Madam Judge
21 Wald. Witness DB, I myself have two questions for you and the first is
22 the following: The forward command post on the 13th of July, I think that
23 you said to the Prosecutor that General Mladic was not there. Did I hear
24 you correctly?
25 A. Yes. I don't think I saw General Mladic on the 13th of July.
1 JUDGE RODRIGUES: [Interpretation] Okay. The Prosecutor also asked
2 you whether you know whether he was elsewhere and you said, "I don't
3 know." Do you remember your answer?
4 A. Yes, I remember having said that.
5 JUDGE RODRIGUES: [Interpretation] My question then is the
6 following: How did you know that General Mladic was not there?
7 A. In the area of the Krivace forward command post on the 13th of
8 July which is where I was, I did not see him there.
9 JUDGE RODRIGUES: [Interpretation] Okay. So the reason is that you
10 were there and you didn't see him there; is that right?
11 A. Yes.
12 JUDGE RODRIGUES: [Interpretation] My second question: Mr. Harmon
13 asked you who the driver was driving the vehicle and you said, "The
14 vehicle was driven by the driver." That's what you said. Now, who was
15 the driver?
16 A. The driver was my soldier from the communications battalion and
17 his name was Veljko Vukosavljevic.
18 JUDGE RODRIGUES: [Interpretation] Okay, thank you. Witness DB, we
19 have no other questions for you. Thank you for answering all our
20 questions put to you by the Prosecution, the Defence, and the Judges and
21 thank you very much for coming to the Tribunal once again.
22 I shall now ask the usher to escort you out of the courtroom,
23 thank you very much. Mr. Usher, would you see the witness out.
24 But maybe, Witness, stay where you are for the moment for the
25 usher to be able to lower the blinds. Those are the protective measures
1 for you.
2 THE WITNESS: [Interpretation] Thank you, Your Honours, too.
3 [The witness withdrew]
4 JUDGE RODRIGUES: [Interpretation] I think that we can now continue
5 with the cross-examination of Witness DG; is that right, Mr. Harmon?
6 MR. HARMON: Yes, I'm prepared to proceed, Mr. President.
7 JUDGE RODRIGUES: [Interpretation] Okay, very well. Let us take
8 advantage of this break to hear whether we can have the witness brought
10 [The witness entered court]
11 JUDGE RODRIGUES: [Interpretation] Good afternoon, Witness DG. Put
12 your headset on, please. Can you hear me now?
13 THE WITNESS: [Interpretation] Yes.
14 JUDGE RODRIGUES: [Interpretation] Good afternoon. Let me remind
15 you that you need not take the solemn declaration again. You are still
16 under oath, of course, and this afternoon you will be answering questions
17 put to you by the Prosecutor, Mr. Harmon. So please be seated. Try and
18 get as comfortable as possible, approach the microphones, please, and
19 prepare yourself for answering questions.
20 Mr. Harmon, your witness.
21 MR. HARMON: Thank you, Mr. President.
22 WITNESS: WITNESS DG [Resumed]
23 [Witness answered through interpreter]
24 Cross-examined by Mr. Harmon:
25 Q. Good afternoon, Witness DG.
1 A. Good afternoon.
2 Q. Witness DG, in respect of the events that took place five and a
3 half years ago about which you've testified yesterday, can you tell me,
4 did you maintain any notebooks, any journals, any documents at all that
5 would help you refresh your recollection?
6 A. I had the dispatch book when I would hand over telegrams to
7 somebody. That person would sign my dispatch book.
8 Q. Where is that dispatch book?
9 A. I don't know.
10 Q. When did you last see that dispatch book?
11 A. In Vlasenica. When I left all the other documents, I left that
12 book there too --
13 Q. So --
14 A. -- in the encryption room.
15 Q. Five and a half years ago, approximately?
16 A. Yes.
17 Q. My question was a little bit more oriented towards the present.
18 Before coming to testify in this case, did you have an opportunity to go
19 back and look at the dispatch book or any other documents including
20 personal notes that you may have maintained to refresh your recollection
21 about the events that you've testified about, or are you testifying solely
22 on memory?
23 A. No. I just saw the dispatch book then and at no other time after
24 that, just at Mr. Petrusic's with -- I saw the original. I saw the
25 original telegram that I received at 11.50.
1 Q. Other than the telegram, I'm trying to be very clear on this,
2 Witness DG, other than the telegram, did you see any dispatch books prior
3 to coming here to testify?
4 A. I didn't see a single dispatch book, no.
5 Q. I take it when you've testified about events that took place more
6 than five and a half years ago, you're testifying based on your own
7 recollection of these events; is that correct?
8 A. Yes.
9 Q. Yesterday, my colleague, Mr. Petrusic, asked you the following
10 question and I'm referring to page 54 of LiveNote, lines 19 through 23.
11 "When did you leave the forward command post at Pribicevac?" Your answer
12 that is recorded is as follows: "We left Pribicevac when the army entered
13 Srebrenica. I don't remember the exact date, but I do know that when the
14 army passed the centre of town and went further on, we received orders
15 from Major Jevdjevic. We packed up our things, and went towards
17 Now, witness, you don't remember whether that was the 11th or the
18 12th or the 13th of July 1995, do you?
19 A. No, not the date.
20 Q. When you said in your answer that, "I do know when the army passed
21 the centre of town and went further on," what did you mean by "and went
22 further on." Can you explain that to us, please?
23 A. Well, the army passed through Srebrenica and went on I don't know
24 where, where it was supposed to.
25 Q. Well, do you know where the army went on after it went past the
1 centre of Srebrenica?
2 A. No.
3 Q. Do you know that the army went on to Potocari?
4 A. No.
5 Q. Do you know that the army went to Potocari on the -- arrived at
6 Potocari on the 12th of July 1995?
7 A. No.
8 Q. So -- all right. Now, when you left in the communications vehicle
9 and went to Bratunac, do you know where the army, the VRS army had
10 reached, what part of the Srebrenica enclave it occupied?
11 A. No.
12 Q. When you left in the communications vehicle, where were you seated
13 in the communications vehicle?
14 A. There's a sort of container in the vehicle, and myself and two
15 other soldiers were in that part. It has a door to it, this section.
16 Q. How many people were inside the communications vehicle that
17 travelled through Srebrenica and arrived in Bratunac?
18 A. I don't know exactly. In that container section, three or four,
19 and two in front because it changed.
20 Q. Was your communications vehicle escorted to Bratunac by any other
21 VRS military vehicle?
22 A. I didn't see any, no.
23 Q. Now, could you see outside of your vehicle based on the position
24 that you were in?
25 A. I said that once when the door was opened --
12 Blank page inserted to ensure pagination corresponds between the French
13 and English transcripts.
1 Q. How long was the door opened?
2 A. -- I did see outside.
3 Q. How long was the door open, Witness DG?
4 A. Briefly.
5 Q. Can you estimate, to the best of your recollection, how long that
6 might be in a matter of seconds or minutes?
7 A. Whoever was opening the door held it open for a minute or two.
8 Q. Was that the only time that the door was opened and you could see
9 outside during your entire journey from Pribicevac to Bratunac?
10 A. Yes. I also opened the door once when I saw the UN Compound and
11 the UN hangars.
12 Q. Again, to the best of your recollection, how long did you keep the
13 door open on that occasion?
14 A. Two or three minutes.
15 Q. Now, on whose order was it that the communications vehicle from
16 the forward command post was packed up?
17 A. Major Jevdjevic.
18 Q. Who gave him that order?
19 A. I don't know.
20 Q. Did the order to pack up the communications vehicle occur before
21 you were informed you were going to Zepa or after you were informed you
22 were going to Zepa?
23 A. Could you repeat your question, please?
24 Q. Was the communications vehicle at the forward command post at
25 Pribicevac packed up before you received information that you were going
1 to Zepa or after you received information that you were going to Zepa?
2 A. Before we received information.
3 Q. Now, when -- are you familiar with the rules of the army that deal
4 with when a forward command post can be dislocated and when a
5 communications centre and a command post can be dislocated or moved?
6 A. No.
7 Q. Are you aware that a command post can be only dislocated on the
8 order of a commander?
9 A. I don't know that.
10 Q. All right. Now, after you left the forward command post, Witness
11 DG, who of the Drina Corps staff remained at that location?
12 A. I don't know. I think no one.
13 Q. Let me read you the testimony of General Krstic and see if this
14 will refresh your recollection.
15 MR. HARMON: I am referring to the testimony of General Krstic,
16 the transcript at page 6198, lines 6 through 23.
17 Q. General Krstic testified as follows, and this testimony, to put it
18 in the proper context of time, is the 11th of July. Question, "So you
19 left Srebrenica and went to Bratunac?" Answer -- I'm sorry, I'm going to
20 read you some testimony, Witness DG. I want you to listen to this
21 testimony --
22 A. I see.
23 Q. -- and perhaps this will refresh your recollection. Understanding
24 your testimony that you -- well, let me ask, what time did you leave the
25 forward command post in the communications vehicle on some date?
1 A. About half past six or half past seven, something like that.
2 Q. Let me read you what General Krstic had to say about the 11th.
3 Q. So you left Srebrenica and went to Bratunac?
4 A. No, I didn't leave Srebrenica for Bratunac. Immediately
5 after we had received the order and had been informed
6 about the meeting, the time of the meeting and my
7 presence there, I went back to Pribicevac forward command
8 post along the Srebrenica-Bojna-Zeleni Jadar-Pribicevac
9 axis. So I went back.
10 Question by Mr. Petrusic:
11 Q. Who did you find at Pribicevac?
12 A. At the Pribicevac forward command post I found Colonel
13 Vicic, Lieutenant Colonel Kosoric, and the commander of the
14 command staff Lieutenant Amovic.
15 Q. So those were probably already evening hours?
16 A. Yes. It was already evening, around 8.00.
17 Q. Did you at that point leave Pribicevac and go to Bratunac?
18 A. After I had briefed Colonel Vicic about what General
19 Mladic had ordered, that is, that the units should stop at the
20 lines and stabilise their positions, I ordered Colonel Vicic
21 to continue monitoring the situation in the units. After
22 that, I left for Bratunac along the Pribicevac-Sase-Bratunac
24 Now, Witness, who is Colonel Vicic? What position did he occupy
25 in the Drina Corps?
1 A. I don't know.
2 Q. Wasn't he General Krstic's operations officer?
3 A. He worked in the operations centre.
4 Q. Correct.
5 A. But people changed there.
6 Q. Correct. And he worked at the operations centre at the Pribicevac
7 forward command post, didn't he?
8 A. He was there probably. I don't know.
9 Q. And Lieutenant Colonel Kosoric, do you know who he is?
10 A. No.
11 Q. Do you know who the intelligence, the head of the intelligence
12 section of the Drina Corps staff, Lieutenant Svetozar Kosoric, a man with
13 a large moustache? Did you see him at the forward command post?
14 A. No.
15 Q. Now, let me ask you, then, when you left the forward command post,
16 Witness, did the forward -- with the communications vehicle on a date
17 unknown, did the forward command post remain in existence?
18 A. I don't know.
19 Q. Assuming General Krstic has accurately described what he did in
20 the course of this answer, that is, had he asked Colonel Vicic to continue
21 monitoring the situation in the units, and assuming this is the 11th of
22 July, 1995, after Colonel -- after the communications vehicle left the
23 forward command post at Pribicevac, how was Colonel Vicic to monitor the
24 situation of the units?
25 A. I don't know. I'm not aware of that. We were 50 or 100 metres
1 away from them.
2 Q. In fact -- go ahead, I'm sorry. I didn't mean to interrupt you.
3 Please proceed with your answer.
4 A. Whether someone stayed behind up there or not, I don't know. I
5 think I saw Colonel Vukotic at that time over there, no one else.
6 Q. In fact, Colonel Vicic needed communications to monitor the
7 situation in the units, didn't he? You couldn't monitor the situation
8 without communications, could you?
9 A. I don't know. There was nothing to observe there or monitor.
10 Q. Now, let me read on what General Krstic has said about who
11 remained at the forward command post in Pribicevac.
12 MR. HARMON: And for Your Honours' and counsels' notations, I'm
13 referring to General Krstic's testimony found at page 6214, lines 4
14 through 15.
15 Q. And this, Witness DG, is what General Krstic testified about on
16 the morning of the 12th of July, 1995. "The next day, the 12th of
17 July --" this is questions by my colleague Mr. Petrusic.
18 The next day, the 12th of July, what did you do?
19 A. My activities were primarily linked with the tasks
20 assigned to me in connection with the Zepa operation. I got
21 up early at 6.00. I dropped in to see the duty officer, and
22 he told me that General Mladic had ordered that I should
23 attend again the meeting at 1000 hours. After that, I
24 immediately went to the forward command post at Pribicevac
25 where I found Colonel Vicic and the commander of the staff
1 command, Lieutenant Amovic, at the forward command post in
2 Pribicevac. I went to Pribicevac from Bratunac taking the
3 same route that I had taken to go to the meeting, and that is
4 Bratunac, Voljevica, Sase, and Pribicevac.
5 Let me read you further what General Krstic testified about that
6 occurred later that same day, on the 12th.
7 MR. HARMON: And I'm referring to the transcript at page 6221,
8 lines 5 through 13.
9 Q. And this also is on the 12th of July. "Is this where you," and
10 this is -- I'm sorry, let me start again. This is questions by
11 Mr. Petrusic to General Krstic.
12 Is this where you -- is this the point from which you went to
13 the new forward command post at Krivace?
14 A. When I arrived at the forward command post at Pribicevac
15 from the meeting at Bratunac, it was around, I think, 1330,
16 maybe 1400 hours. I stayed there a while, acquainted myself
17 with what Colonel Vicic had done, we had lunch together, and
18 then we went together to Viogora or the units we were supposed
19 to assemble. This was the assembly area for the units engaged
20 in the operations. We headed towards Viogora on a route
21 Pribicevac-Zeleni Jadar-Srebrenica-Viogora.
22 Now, Witness, isn't it a fact that the forward command post, while
23 Colonel Vicic was present, maintained communications and had the ability
24 to communicate with units and with the command? Isn't that a fact?
25 A. I don't know.
1 Q. Now, Witness, your testimony is that you went towards Srebrenica
2 some date, unknown precisely, but around 6.30 or 7.30, and that you
3 arrived in Vlasenica that same day sometime before midnight; is that
5 A. Yes.
6 Q. Now, that would mean, by my arithmetic, that you were outside of
7 the communications network for between four and a half and five and a half
8 hours; isn't that correct?
9 A. In the period between 6.30 or 7.30 and until 12, yes.
10 Q. Now, did you inform the command at Vlasenica that you were going
11 to be out of the communications network, that you were going to go silent?
12 A. I did not.
13 Q. Did anybody else?
14 A. Among my colleagues, possibly somebody did.
15 Q. Now, wasn't that your normal practice when you were in a
16 communications centre to inform the headquarters that you were getting off
17 the communications network?
18 A. Mine, no.
19 Q. Wasn't that the normal practice in the army, I'm asking you,
20 Witness DG, or is it a normal practice in the VRS to have a forward
21 command post communications centre that arbitrarily goes off the
22 communications net without telling anyone that they're going to do that?
23 A. For me to inform anyone, I would have to spend a lot of paper of
24 17 millimetres which we were very short of at the time.
25 Q. Well, wouldn't it consist -- wouldn't it merely consist of
1 informing them through an encoded message or an encrypted message that you
2 were going to be out of communication contact for a certain period of time
3 so they could properly organise their own operations?
4 A. Yes, but that's not a short message. It's quite a long one on an
5 encrypted form of paper.
6 Q. So what is the best of your recollection, Witness: Did you, Major
7 Jevdjevic, or did any of your colleagues inform the Drina Corps
8 Headquarters Command that you were going off the communications network
9 for a certain period of time, that you were pulling up stakes, that you
10 were packing up, and that you were leaving?
11 A. I personally did not. Whether someone else did, I don't know.
12 Q. Now, when you arrived at the Vlasenica headquarters -- strike
14 When you arrived at the Vlasenica headquarters shortly before
15 midnight, did you tell the -- did you personally, did Major Jevdjevic, or
16 did anyone else in your staff inform the duty officer at the headquarters
17 or anybody else in the Drina Corps headquarters that there was no longer a
18 communications centre operating at the Pribicevac forward command post?
19 A. I did not, and Major Jevdjevic may have, because I went to my
21 Q. Now, wouldn't that be a prudent thing to do, inform the corps
22 headquarters that there was no longer a communications network,
23 communications centre at the forward command post at Pribicevac?
24 A. That was not my job.
25 Q. I know it wasn't your job. You're a soldier in the VRS, and I'm
1 asking you your opinion. Isn't that the type of information that
2 necessarily should have been communicated and was communicated to the
3 Drina Corps headquarters, that there was no longer a communications centre
4 at the forward command post in Pribicevac?
5 A. I don't know that, don't know those things. In the army, it is
6 clearly specified who does what.
7 Q. So you not only -- are you unable to inform this Trial Chamber --
8 well, let me ask you this question: How long were you a signalsman in the
10 A. A year and a half to two.
11 Q. And did you -- were you assigned to communications centres of
12 forward command posts in the past?
13 A. Yes, but mostly stationary facilities.
14 Q. Did you go to Krivace, the forward command post in Krivace in the
15 communications vehicle?
16 A. Yes.
17 Q. Did you go to the two other forward command posts that were set up
18 in the Zepa area of responsibility?
19 A. At Zepa? I was only at Krivace.
20 Q. Now, would it be fair to say, Witness, that after you arrived in a
21 communications vehicle that had been a communications centre at
22 Pribicevac, when you arrived with Major Jevdjevic with yourself and all of
23 your communications crew, that the people at the Drina Corps headquarters
24 knew there was no longer communications centre at Pribicevac. Is that a
25 fair conclusion?
1 A. I don't know.
2 Q. We'll move on to a different topic then. When you went to -- from
3 Bratunac -- strike that.
4 While you were at Bratunac, did you get out of the communications
6 A. No.
7 Q. When you went from Bratunac to Vlasenica, which road did you take
8 to get to Vlasenica?
9 A. I don't know. Probably Konjevic Polje, Milici, Vlasenica.
10 MR. HARMON: Now, I'd like to have the witness please be shown
11 Prosecutor's Exhibit 830 and if the registrar could also prepare 831 as
12 well, we'll start with Prosecutor's Exhibit 830. They both could be
13 brought to the witness. If you would start, Mr. Usher by putting the
14 English version of Prosecutor's Exhibit 830 on the ELMO.
15 Q. Witness, if you could take a look at the B/C/S version of 830, do
16 you see that in front of you, sir?
17 A. Yes.
18 MR. HARMON: Mr. Usher, if you could turn to the second page of
19 the English translation, place that on the ELMO.
20 Q. Witness, referring to Prosecutor's Exhibit 830, this is a document
21 that was sent from the Drina Corps Command for Commander Major General
22 Milenko Zivanovic, and it was sent to, among other locations, the IKM, the
23 Drina Corps forward command post; correct?
24 A. Yes.
25 Q. This document is marked "very urgent," isn't it?
1 A. Yes.
2 Q. In fact, if you examine the content of this document, Witness,
3 this document is urgent because the substance of it relates to potential
4 enemy forces coming from a different location and linking up with the 28th
5 Division forces within the enclaves; correct?
6 A. I don't know. It's not up to me to judge the urgency of a
7 telegram on the basis of its contents.
8 Q. But the face of this document says it's very urgent. We can let
9 other people conclude what the substance --
10 A. Yes.
11 Q. -- of it was, and why it was urgent. But witness, turning to the
12 second page of this document, you will see on the second page that this
13 document was transmitted to the addressees at 2250 hours; correct?
14 A. No. That it was handed to the teletype operator on -- at 2250
15 hours. That's the offices opposite the encryption room.
16 Q. Correct. And then it is processed out and sent; correct?
17 A. No.
18 Q. Well, then, I seriously misunderstood what the previous witness
19 has previously testified about this exhibit. Witness, what does the 2250
20 hours mean that's located in the stamp on this document?
21 A. It means that the encoder needed 20 minutes to process and encrypt
22 the telegram and to hand it to the teletype operator who was to forward it
23 on to the designated addressee.
24 Q. So after 2250 hours, an attempt was made to send this to the
25 addressees on this document; correct?
1 A. Yes.
2 Q. Now, can you tell me, is there any trace on this document showing
3 that this document was not transmitted to the Pribicevac forward command
4 post? Is there any mark on this document to show that it wasn't
6 A. There is. Down there below, it says "delivered," and there's
7 nothing filled in on this same stamp.
8 Q. Correct. So this was not delivered to any of these subordinate
9 commands in this -- of the addressees and by that I mean the 2nd Romanija
10 Motorised Brigade, the Vlasenica Light Infantry Brigade, the 1st Milici
11 Light Infantry Brigade, the forward command post, the 1st Podrinje Light
12 Infantry Brigade, the 5th Podrinje Light Infantry Brigade, et cetera, et
13 cetera, et cetera. This simply was not delivered to anybody; is that
15 A. No.
16 MR. HARMON: Now, can we examine 831, please.
17 JUDGE RODRIGUES: [Interpretation] Excuse me, Mr. Harmon, something
18 is not quite clear here. You said this order was not delivered to all
19 these addressees that you listed and et cetera, et cetera so it was not
20 sent to anyone, is that correct, and the witness says no.
21 So I want to know what he meant. Does he mean that that was
22 correct or that it wasn't sent? You understand my question, I hope.
23 MR. HARMON: I do.
24 Q. Was this document, Prosecutor's 830, sent to any of the
1 A. This stamp here with nothing written on it, either the date or the
2 hour or a signature means that this telegram was not delivered to any one
3 of those stations. If the encoder had signed it and placed the date, that
4 would have meant that it had been delivered to everyone. That is why his
5 signature is not there nor is the hour or date indicated.
6 JUDGE RODRIGUES: [Interpretation] Excuse me, Mr. Harmon, I'm sorry
7 for insisting.
8 Witness, do you have any indications as to the reasons why someone
9 went to the trouble to write this without managing to achieve any
10 purpose? Can you give us any possible reason for this?
11 A. No. Probably later on he somehow managed to have it signed and
13 JUDGE RODRIGUES: [Interpretation] Who would have taken the
14 decision not to send it because, you see, somebody received it? Somebody
15 went to the trouble of doing everything, encrypting it, et cetera, and
16 after all that work, the objective was not achieved. Who would have
17 decided that?
18 A. I don't know.
19 JUDGE RODRIGUES: [Interpretation] Please continue, Mr. Harmon.
20 MR. HARMON:
21 Q. Witness, if you could turn your attention, please, to Prosecutor's
22 Exhibit 831.
23 Mr. Usher if you could put the English version of that on, the
24 second page.
25 Witness, this is a document which is the same in substance as the
1 previous exhibit, isn't it? Did you understand my question?
2 A. No.
3 Q. Let me -- the contents of this document are identical to the
4 previous exhibit; correct?
5 A. These two telegrams, you mean?
6 Q. Yes. The content.
7 A. Yes. Yes.
8 Q. Now, on this -- this is the document, I believe you testified,
9 that you received in Vlasenica on the night you arrived and that you
10 inserted the time and signature at the end of that document. Do you see
11 what I'm referring to? Is that your signature?
12 A. Yes.
13 Q. Now, let me ask you, Witness, before coming to The Hague to
14 testify, did you tell anyone that you had received this order on the 11th
15 of July at 1800 hours?
16 A. No.
17 Q. Did you tell anyone that you had received this order at the
18 Pribicevac forward command post on that date and at that time?
19 A. No.
20 Q. Did you tell anyone that because there were no authorised officers
21 at the forward command post, you couldn't deliver the order?
22 A. I spoke to the attorney about this telegram two or three months
23 ago when we met. I said that I didn't receive that telegram up there, but
24 at Vlasenica. But I left the possibility open that if I had received it
25 there, that I must have done so by 6.00 or 6.30 and that I had no one to
1 hand it to so that I handed it to someone in Vlasenica.
2 Q. All right. Now, examining Prosecutor's Exhibit 831, is there any
3 trace on this document to show that it was received by you in Vlasenica?
4 A. No.
5 Q. Now, let's take your testimony at face value. When you received
6 this telegram in Vlasenica at 2350 hours, what did you do with it? It's
7 marked "very urgent."
8 A. I took it to the operations centre straight away.
9 Q. What did they do with it?
10 A. I don't know.
11 Q. Did you give it to Major Jevdjevic?
12 A. No.
13 Q. Did you inform him that you were in receipt of a very urgent
15 A. No.
16 Q. All right.
17 MR. HARMON: May the witness be given Defence Exhibit 165,
18 please. Put the English version, Mr. Usher, on the ELMO, the second
19 page. Actually, start with the first page, if you would, Mr. Usher.
20 Q. Now, Witness, have you seen this document before?
21 A. No.
22 Q. Well, examine it for just a minute starting at the top and you'll
23 see the addressees. And I'll direct your attention, because I'm conscious
24 of the time, if you read the first paragraph and then turn over to the
25 last page and look at the individual who sent this document.
1 Now, witness, this is a document that is dated the 12th of July
2 and was sent to the forward command post attention of, in Pribicevac,
3 attention of General Krstic. And from reading this document, which is
4 information about a prisoner who was captured at 1800 hours along the
5 Bratunac-Kravica region, and I think it's fair to assume that it took a
6 while to interrogate him, to prepare this report and then to transmit it.
7 You can see at the bottom of this report that this was received by the 2nd
8 Romanija Motorised Brigade at 2210 hours, sometime after 10.00 at least.
9 My question to you, and -- I'm sorry, and the person who has sent this
10 message is General Tolimir from the VRS Main Staff.
11 Witness, can you explain why the VRS Main Staff more than 24 hours
12 after your command communications centre allegedly left Pribicevac was
13 still sending communications to General Krstic personally at the forward
14 command post in Pribicevac?
15 A. I don't know.
16 MR. HARMON: All right. Can we have the next exhibit which is
17 Prosecutor's Exhibit 739, please.
18 Q. Witness, if you just quickly glance at this document, particularly
19 the addressees in the document.
20 Mr. Usher, if you could place the document on the ELMO. Could you
21 move it up, Mr. Usher, just a bit.
22 Witness, have you had a chance to look at this document?
23 A. No.
24 Q. Take your time. Have you had a chance to look at that document,
1 Now, this document, Witness, is from the Ministry of the Interior,
2 and it is a document wherein the Ministry of the Interior forwards the
3 full text of a message from the Drina Corps, and then you'll see that the
4 Drina Corps message in toto is reproduced. The document is dated the 13th
5 of July, and you'll see one of the recipients is indicated, and I quote,
6 "Pribicevac forward command post, General Krstic personally."
7 MR. HARMON: And Mr. Usher, if you could move it up now, the
8 document all the way up to the bottom so we can see who sent it.
9 Q. This document has been sent by the chief of the intelligence and
10 security department, Lieutenant Colonel, and then there's an omission.
11 Are you aware, Witness, that the chief of the intelligence and security
12 department of the Drina Corps was Lieutenant Colonel Kosoric, the
13 brother-in-law of General Krstic? Are you aware of that fact?
14 A. Yes.
15 Q. Now, can you tell me why on the 13th of July, Witness, after the
16 forward command post was alleged -- the communications centre at the
17 forward command post was allegedly packed up on the 11th, why General
18 Krstic's brother-in-law, who is the chief of intelligence and security, is
19 sending a message to General Krstic at the Pribicevac forward command post
20 on the 13th of July?
21 A. I don't know.
22 Q. Now, it's the Prosecutor's submission, Witness, that the forward
23 command post and the ability to receive and transmit communications
24 continued in existence on the 12th of July and the 13th of July, 1995.
25 What do you say to that?
1 A. Impossible at Pribicevac.
2 Q. All right.
3 MR. HARMON: I have no further questions, thank you.
4 Q. Thank you, Witness.
5 JUDGE RODRIGUES: [Interpretation] Thank you very much, Mr. Harmon.
6 Mr. Petrusic, re-examination? And could you tell me, please, how
7 much time you will need, approximately.
8 MR. PETRUSIC: [Interpretation] Very brief, Mr. President.
9 JUDGE RODRIGUES: [Interpretation] Very well. Please go ahead.
10 Re-examined by Mr. Petrusic:
11 Q. I'd like to go back to Exhibit 830, please. On the stamp, the
12 last portion says "delivered." At your centre, the centre from which you
13 sent out messages or, rather, telegrams, is there a book in which you
14 write in who you sent the telegram to and who received it? Is there a
15 standard form of book for this type of thing?
16 A. Yes.
17 Q. Now, am I right in saying that if on this particular stamp it does
18 not say who the telegram was delivered to, is it written into that book?
19 A. Yes.
20 Q. And you'll agree with me that this particular telegram was sent,
21 that is to say, the addressees were 11 -- 12 addresses, there were 11 or
22 12 addressees, so it's impossible to write in this section all the
23 recipients; is that right?
24 A. Well, probably, yes. Probably it didn't reach some of the
25 stations, addressees.
1 Q. Witness, on the 12th of July with the communications centre and
2 your devices, in the afternoon hours and later on, were you at the Krivace
3 forward command post?
4 A. Yes.
5 MR. PETRUSIC: [Interpretation] Mr. President, the Defence has no
6 further questions for this witness.
7 JUDGE RODRIGUES: [Interpretation] Thank you very much,
8 Mr. Petrusic.
9 Madam Judge Wald has the floor. No questions?
10 Questioned by the Court:
11 JUDGE RODRIGUES: [Interpretation] Witness, I have just one
12 question for you. Do you happen to remember the name of the driver who
13 drove the vehicle from Pribicevac to Bratunac?
14 A. Veljko.
15 JUDGE RODRIGUES: [Interpretation] Did he have another name?
16 A. No.
17 JUDGE RODRIGUES: [Interpretation] So Veljko, that's the name, is
18 it, Veljko?
19 A. Yes, Veljko.
20 JUDGE RODRIGUES: [Interpretation] Very well, Witness. We have no
21 further questions for you. Thank you very much for coming. I'm now going
22 to ask the usher to lower the blinds to ensure that you are protected, and
23 afterwards he'll show you out of the courtroom. Thank you.
24 [The witness withdrew]
25 JUDGE RODRIGUES: [Interpretation] As I have already said, we will
1 have to end by 4.00, so I don't think it is possible for us to have a new
2 witness shown in. We'll leave that for tomorrow.
3 We overstepped the time indicated by someone for the interpreters'
4 working hours. Now, I don't want to turn this into a rule. It was an
5 exception, and I admitted it because I know that our interpreters are the
6 best in the world.
7 So for the time being, I think we'll stop there, that is, we'll
8 stop there for today and adjourn and reconvene tomorrow morning at 9.20 as
10 --- Whereupon the hearing adjourned at 3.48 p.m., to
11 be reconvened on Wednesday, the 4th day of
12 April, 2001, at 9.20 a.m.
12 Blank page inserted to ensure pagination corresponds between the French
13 and English transcripts.