Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13452

 1                           Thursday, 27 June 2013

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at of 9.31 a.m.

 5             JUDGE ORIE:  Good morning to everyone in and around this

 6     courtroom.

 7             Madam Registrar, would you please call the case.

 8             THE REGISTRAR:  Good morning, Your Honours.

 9             This is case IT-09-92-T, the Prosecutor versus Ratko Mladic.

10             JUDGE ORIE:  Mr. McCloskey, a preliminary matter to be raised on

11     behalf of the Prosecution.

12             MR. McCLOSKEY:  Yes.  Good morning, Mr. President, everyone.

13     Could we go into private session briefly.

14             JUDGE ORIE:  We move into private session.

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10                           [Open session]

11             MR. IVETIC:  Next, Your Honour, if we can go into private

12     session.  The part we were on was in private session last.

13             THE REGISTRAR:  We're in open session, Your Honours.

14             JUDGE ORIE:  Witness RM279, before we continue, I'd like to

15     remind you that you're still bound by the solemn declaration you have

16     given at the beginning of your testimony.  We'll now first move into

17     private session, and Mr. Ivetic will then continue his cross-examination.

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14                           [Open session]

15             THE REGISTRAR:  We're in open session, Your Honours.

16             MR. IVETIC:  Thank you, Madam Registrar.  If we can call up in

17     e-court your 92 ter transcript, P1614 under seal, but not broadcast the

18     same to the public.  And if we could turn to page 11 of the same.  And if

19     we could focus on line 2.

20        Q.   Sir, I'd like to read for you a part of your answer from the

21     92 ter transcript and ask you some questions following it, so please

22     follow along.

23             "A. In order to explain that, I have to go back to 1992.  The

24     unit, as such, was established -- founded from a number of enthusiasts,

25     mainly radio amateurs and officers of the Yugoslav People's Army, or,

Page 13460

 1     rather, former JNA officers who at that time were serving as officers in

 2     the BH Army.  They started with modest equipment, and the unit grew to

 3     its full size in mid-1995, numbering, on average, 50 to 60.  There was no

 4     professional-quality equipment either imported or inherited from the JNA.

 5     We just adapted and souped-up devices we had in our radio clubs, adding

 6     amplifiers, preamplifiers, and other components, and we managed to enable

 7     these devices eventually to monitor one channel from one site."

 8             Now, you've already explained to us that the modifications were

 9     done by the civilians, the ham radio operators.  The question I want to

10     ask you is a technical one:  Is it correct that civilian-grade equipment,

11     radio equipment, works on different frequencies than does military-grade

12     equipment?

13        A.   Yes.

14        Q.   And am I correct in stating that civilian grade radio equipment

15     cannot -- cannot access military frequencies with the existing parts that

16     are within a civilian radio unit?

17        A.   If you want a brief answer, with the existing components, no,

18     they can't, because every service gets their own frequency, and when you

19     acquire equipment, be it for the air force, for ham radio operators, or

20     professional military, it is done, but it is mechanically possible to add

21     certain assemblies to broaden the range.

22        Q.   Thank you, sir.  Now, I want to continue with the rest of your

23     answer here in this 92 ter transcript to ask you about from line 12

24     onward:

25             "Our capacities were modest, but they were used to the full.  We

Page 13461

 1     had in our unit former JNA officers specialised in communications, and

 2     the core of the unit was made up by ham radio operators with 10 to 40

 3     years' experience."

 4             And I want to ask you, sir, with respect to the former JNA

 5     officers specialised in communications, how many such officers did you

 6     have?

 7        A.   I can't tell you the exact number, after all it was 18 years ago,

 8     but before I joined that unit and before I took up my position, I know

 9     for sure they had five or six high-quality officers from the former JNA.

10     I know about two of them for sure who specialised in electronic

11     reconnaissance.

12        Q.   Thank you.  And if you recall, could you tell us how many ham

13     radio operators with 10 to 40 years' prior experience did you have in

14     that unit?

15        A.   You cannot hold me down to a particular number, but everybody who

16     worked there were for the most part ham radio operators or people who had

17     done that job in the former JNA, in Yugoslavia.  We had one young man who

18     worked at the installation in the south for the former JNA.  We had one

19     man who is now perhaps 75, and many others who had won awards and had

20     enormous experience.  We had one engineer, Tomo Trojak, who was the brain

21     of the whole operation.  We had another engineer of electrical

22     engineering, Miralem.  I cannot tell you how many, but there was a great

23     number of the radio -- members of the radio club Banovici, from Tuzla,

24     Gradacac, and other places.

25        Q.   And were there also individuals in the unit who did not have

Page 13462

 1     neither any prior experience in communications within the JNA nor any

 2     experience as amateur ham radio operators?

 3        A.   I don't think so.

 4        Q.   Now, as far as the staff were former ham radio operators, we've

 5     had some evidence at this trial of the role that the Bosnian Muslim ham

 6     radio operators had in relation to reporting the dire situation in 1994

 7     in Gorazde which turned out to be overstated.  That is, I believe, at

 8     transcript page 7928 to 7932.  Did any of these former ham radio

 9     operators working for this unit that you have described come previously

10     from working within Gorazde enclave?

11        A.   I don't think so.  There was no way, no opportunity.  I'm almost

12     sure nobody came from Gorazde.

13        Q.   Okay.  I want to ask you about a different aspect of this, and to

14     do so I'd like to have 1D1079 in e-court, and for the start, if we could

15     look at page 1 together.  While we wait for that, sir, you'll see the --

16     or I'll present to you the document is dated 1995 and it's from the

17     foreign military studies officer of the US armed forces and is authored

18     by Lieutenant-Colonel John E. Sray, and it relates to the Bosnian civil

19     war, and he talks of ham radio operators in Bosnia.  And if we can move

20     to page 7 of this document, we can examine together one thing that he

21     says.  If we look at footnote number 4 and I'll read for you, sir, so you

22     get the translation of what is said here.

23             JUDGE MOLOTO:  Sorry, where is the footnote?

24             MR. IVETIC:  Footnote 4.

25             JUDGE MOLOTO:  Where is it?

Page 13463

 1             MR. IVETIC:  Endnote 4, I apologise.  It's endnote 4.  It's in

 2     the middle of the screen right now.

 3             "Rumours persist that the Bosnian Muslim government has hired

 4     some of these public relations firms to conduct media campaigns on their

 5     behalf in the US and Europe.  Former President Carter was berated when he

 6     noted that the American public only knew one side of the story in Bosnia

 7     but his statement stands as a concise and astute summary of the content

 8     analysis available in the press.  One of the best examples of Bosniak

 9     propaganda occurred during the battle for Gorazde in April 1994.  The

10     Bosnian Muslim government convinced the world that the BSA demolished the

11     town and inflicted numerous civilian casualties.  (See, for example --"

12             And then he lists US media, British media, German media, and

13     French media, and then continues:

14             "The international media dutifully interviewed and subsequently

15     printed accounts of refugees which government officials made available to

16     them.  Unfortunately, most of the media failed to corroborate these

17     stories.  The press also broadcast reports from a Bosnian Muslim ham

18     radio operator whom they insisted had to be authentic due to the accuracy

19     of his reports pertaining to the NATO bombing during the fighting.

20     Verification of these events later proved this reporting to be highly

21     inaccurate, but the media had already moved on to further stories.  Most

22     of the damage that was done in the enclave had actually occurred almost

23     two years prior to the battle when Muslims had conducted their own ethnic

24     cleansing and burned out the Serbs' houses.  As for the ham radio

25     operator, no one who is hold up in a basement, as he claimed to be, can

Page 13464

 1     accurately describe events taking place on the battle-field.  Rather,

 2     this person simply monitored the unsecured radio transmissions of

 3     UNPROFOR personnel who were controlling the NATO air-strikes.  He then

 4     mixed these elements of truth with his own propaganda to deceive the

 5     media.  In fact, no conclusive evidence exists that the ham radio

 6     operator was even based in Gorazde."

 7             And now I want to ask you, sir, I need to know if the ham radio

 8     operators that worked in the unit were ever involved with this type of

 9     activity, that is monitoring unsecured radio traffic and adding their own

10     elements of propaganda to the same to achieve deception of the media,

11     whether about Gorazde or about any other event or location?

12             JUDGE ORIE:  Ms. Lee.

13             MS. LEE:  Your Honours that was a very long question, and if that

14     could be broken-down in parts, and first of all, it also mentions ham --

15     the report itself -- the document itself mention a ham radio operator,

16     and I think it is only fair to the witness if the identity at least, if

17     the witness has knowledge of -- of such person before he could make any

18     comments on what appears to be an Internet article.

19             JUDGE ORIE:  Mr. Ivetic.

20             MR. IVETIC:  Your Honours, first of all, it's a document of the

21     United States Army.  It's not an Internet article.

22             JUDGE ORIE:  [Overlapping speakers]

23             MR. IVETIC:  Second of all, I'm asking about his -- the persons

24     that were in the unit, whether they had engaged in similar activities.

25     The identity of the ham radio operator which was never, I believe, known

Page 13465

 1     is irrelevant to the question.  I'm asking about this type of activity,

 2     this type of behaviour that is being reported, whether the operator --

 3     when the ham radio enthusiasts that were part of the unit ever engaged in

 4     such activities, and I think it's relevant and germane to this trial.

 5             JUDGE ORIE:  It's -- Mr. Ivetic, if you take step-by-step.  The

 6     first question put to the witness whether anyone came from Gorazde.  Now,

 7     even without reading this long report, whatever the source is, whether

 8     it's Internet or whether it's United States military, you could have

 9     asked the witness whether he is aware of any operator at any time adding

10     anything to what he technically had listened to, and then on the base if

11     the witness says, "Yes, I have knowledge about that," then of course he

12     could tell us.  If he says, "I've got no knowledge about it," then you

13     could have some follow-up questions, one or two, such as are you aware

14     that a similar thing was at least reported to have happened in Gorazde,

15     and then we do not need to read pages and pages of reports.  This is the

16     way I suggest you would proceed.  Please go on.

17             MR. IVETIC:  So, Your Honours, my question objectionable or not?

18     I'd like to get an answer to my question.

19             JUDGE ORIE:  I invited you to -- I -- I suggested to you that you

20     would proceed in the way I indicated, and that would need a rephrase --

21     rephrasing the question, and if you have done so, we'll know whether

22     there's any objection to the new question.  Please proceed.

23             MR. IVETIC:  Can I have a ruling on the objection of my standing

24     question?

25             JUDGE ORIE:  Witness, you heard what Mr. Ivetic read to you, that

Page 13466

 1     is about operators adding information to what they listened to.  Did you

 2     have any similar experience ever in the team in which you worked?

 3             THE WITNESS: [Interpretation] Mr. President, I appreciate

 4     Mr. Ivetic's efforts.  However, first of all, I have to say that I

 5     believe this text has nothing to do with me or the work I was engaged in.

 6     We never --

 7             JUDGE ORIE:  If you'd please answer my question and --

 8             THE WITNESS: [Interpretation] We never added anything.  We did

 9     not work that way.  We were not engaged in propaganda.  We were on the

10     receiving end.  We could not even transmit.  Nobody ever added anything

11     by way of any propaganda or anything else.  I speak from experience,

12     because it was monitored at a lower level and in two facilities, so the

13     two were never aware what the other one was monitoring at the moment.

14             JUDGE ORIE:  Mr. Ivetic, if you have any further questions in

15     this field, feel free to ask the witness.

16             MR. IVETIC:  I do.

17        Q.   My original question:  Do you know if any ham radio operators

18     that you had in your unit previously had engaged in these activities?

19        A.   I don't know, but I don't think so.

20        Q.   Thank you.  Now, if we can go back to your Rule 92 ter

21     transcript, P1614 under seal, and not broadcast the same.  And we'll be

22     looking at the bottom of page 9 of the same, leading on to perhaps page

23     10.  And if we could focus on line 20 on this page.  And it reads as

24     follows, sir:

25             "A. It all depended on the amount of equipment that was available

Page 13467

 1     at a given point in time.  Since our unit was providing support to

 2     intelligence structures and, to that end, gathered information, it was

 3     never manned 100 per cent.  On average, in the northern facility the

 4     tasks were performed by a platoon of approximately 15 men.  They worked

 5     according to the following system:  They would spend seven days in the

 6     facility and then seven days at home.  It could change depending on the

 7     frequency of traffic, or [sic] they could spend 10 or more days in the

 8     facility, and this mostly happened in the summer of 1995, and then the

 9     subsequent 10 days at home.  The workload was enormous.  One worked

10     'round the clock under very difficult conditions, with poor equipment and

11     poor training -- or, rather, poor clothing, I meant.  And this was

12     especially the case in the winter.  There was no heating.  Old heating

13     stoves were used, if only just to keep the equipment in working order.

14             "A similar situation prevailed in the southern facility as well.

15     This facility was even more difficult to access, especially in the

16     winter.  It was also manned by a platoon which monitored radio-relay

17     communications with approximately 12 to 18 men; on average, 15.  They had

18     the same work regime."

19             Now, first I'd like to ask you, you say that the stations were

20     not manned 100 per cent, but you have not stated what percentage the

21     situation depicted.  Could you tell us as far as the manning of the

22     stations was concerned what portion of 100 per cent was actually staffed?

23        A.   I can't be precise in mathematical terms, but there was the unit

24     establishment which changed from time to time.  For the most part it was

25     between 80 and 120 people per formation on paper.  If one takes that at

Page 13468

 1     the moment we had between 80 and 90 people as per establishment, and if

 2     indeed on the spot there were only between 50 and 60, then you can do the

 3     maths for yourself to reach the percentage of the staffing.

 4        Q.   Thank you, sir.  And little further down on this page, I believe

 5     it's not the part that's not visible on the monitor.  If we go down a few

 6     more lines, you talk about that each shift was 24 hours in length, and I

 7     want to ask you:  How many hours during a 24-hour shift did a particular

 8     operator work sitting at the receiver/scanner listening to communications

 9     without a break?

10        A.   At each facility they had a roster in principle.  It was pinned

11     on the wall just simply to be there, but in my view, each operator worked

12     on average between 15 and 18 hours manning the device.  We knew more or

13     less that right after midnight there would be little traffic, so some men

14     would go in to sleep for five or six metres.  It was all within the

15     radius of 5 metres.  If there is an increase in traffic, the people were

16     awakened.  You need to understand that it was wartime.  It was not like

17     in peacetime; otherwise, I could tell you how many people one would need

18     and what sort of equipment you would need, but that was what it was like.

19        Q.   And the same question now for the operators that would be sitting

20     down and listening to prerecorded transmissions on the UHER tape device.

21     How many hours during a 24-hour shift would a particular operator be

22     sitting working on that machine listening to communications and writing

23     them down without a break?

24        A.   I have to repeat there were no others.  They were all the same

25     people.  They all sat down together, listened together, eat and drink

Page 13469

 1     together.  They only had to make a few steps to take the notebooks to the

 2     encryption unit which was next door.  That's where everything took place.

 3        Q.   And is it correct that operators could and did work on two

 4     machines at a time?

 5        A.   The question is a bit, well, not necessarily unclear, but

 6     difficult to answer.  Before that I have to tell you that a person had

 7     two devices in front of him.  One was RRU 1 and the other RRU 800.  Each

 8     work station had two, and they did not change work station unless they

 9     needed to help their colleague in his own work.  Every person had two

10     machines in front of them.  They were the UHER devices.  Everyone knew

11     who was to man each work station and who was then supposed to replace

12     them.

13        Q.   Did you mean to say that your unit had a RRU 800 device and a RRU

14     1 device?  Is that accurate?

15        A.   If you have in mind professional military equipment, we did not,

16     but these were modified amateur devices.  One could monitor channels,

17     that is to say, communication between 610 and 950; whereas, the other one

18     could follow the frequencies between 230 and 270.

19             JUDGE ORIE:  Could I ask one question.  The devices, they depict

20     the frequency range covered by that device.  Is that -- or is it a

21     specific piece of equipment?

22             THE WITNESS: [Interpretation] They are modified ham radio

23     devices, Mr. President.  A Kenwood 450, an ICR 100.  It's all in the

24     notebooks which work station used which device.

25             JUDGE ORIE:  Yes.  And then the reference to RRU 800 and RRU 1

Page 13470

 1     mainly refers to what frequency is covered by that -- covered by that

 2     modified equipment?

 3             THE WITNESS: [Interpretation] Yes.

 4             JUDGE ORIE:  Thank you.  Please proceed, Mr. Ivetic.

 5             MR. IVETIC:  Thank you, Your Honour.

 6        Q.   How many channels or frequencies could each the northern and the

 7     southern stations follow at any one time simultaneously?

 8        A.   I think I can say -- well, four workstations by 2 channels times

 9     8.  So 16 channels at both facilities.  So at the moment when they are

10     recording, at any given time they could only record up to 16 channels.

11     As for scanning, they could cover well over a hundred.

12        Q.   As for the playback of prerecorded tapes of transmissions, could

13     you tell how many tapes be listened to simultaneously for purposes of

14     writing them down into a notebook at any given time?

15        A.   Well, listening to the tapes, depending on the number of people

16     who were at the facility.  So between four and eight.

17        Q.   If we can briefly turn to page 13 of the Rule 92 ter statement

18     and focus on lines 15 through 21, I'd have a question to ask you about

19     this.  And you're quoted here as answering as follows:

20             "After we identified -- or, rather, discovered participants in

21     the traffic, we would proceed to record the communication.  People could

22     not memorise and then note down what they heard, so they first had to

23     make a recording, then play it back and listen, and note it down.  Such

24     information was written down into station log-books according to the

25     recipe of the former JNA or in our working notebooks, because we did not

Page 13471

 1     have any dedicated documents for writing this down."

 2             Now, this answer leaves me a bit confused, because on the one

 3     hand it seems to imply that the procedures of the JNA were followed but

 4     also at the same time they were not followed.  Could you please clarify

 5     for us whether the unit followed the prescribed procedures set forth by

 6     the JNA for memorialising these communications?

 7        A.   I don't want to be critical of anyone, but there may be small

 8     mistakes occurring in the process of interpretation.  In principle, we

 9     used the documents of the former JNA to create this mosaic, the jigsaw

10     puzzle, because it was easiest way to do so.  Since we did not have

11     proper documentations with rubrics and columns, we used notebooks for

12     that purpose.  Perhaps I'm not expressing myself all too well, but we

13     followed the procedures used by the JNA, but, however, it was translated

14     into our circumstances.

15        Q.   Did you follow by what is prescribed by JNA protocol and

16     procedure for the archiving and preservation of such log-books?

17        A.   In principle, we did.  However, given the fact that we did not

18     have logistical support because it had not been dealt with in the best

19     possible way by our competent command, we did the following:  The

20     typed-out encrypted report containing the conversation was the most

21     important document leaving the facility.

22        Q.   Am I correct that certain log-books were destroyed or burned?

23        A.   You're 100 per cent correct.  There was a whole sea of such

24     notebooks from previous periods, from subordinate units, from the

25     division, from our unit.  It all burnt down.  Well, it was used also to

Page 13472

 1     fuel fire, to roll cigarettes, et cetera.  There were not only notebooks.

 2     It was mentioned in all of the trials here that the notebooks became

 3     widely available, especially in 1995.  So we used different kinds of

 4     formats.  From the northern facility, you'll see that they frequently

 5     have mining logs because it was -- it used to be a mining location, and

 6     they could only use one side of each sheet.  In any case, we used

 7     anything that we could get our hands on just to note down information.

 8        Q.   Now, I believe that you have stated that one operator would

 9     normally listen to the transmissions recorded on the tape through the

10     UHER device for purposes of writing them down in a notebook but that

11     others would be called in to listen to the tape with him if there was

12     unclarity or question about a particular part that was hard to decipher.

13             First of all, is there any notation or marking that would be

14     visible on the notebook or on the typed report which would be generated

15     from the notebooks which would denote these parts which were unclear and

16     which had to be deciphered with the help of multiple persons listening to

17     tape?

18             MS. LEE:  If the question could be broken down.  It's a very long

19     question, and I just want to know -- first of all, I think it's fair to

20     the witness if there were any notations or markings that would be visible

21     in the notebook or the typed report, and if that could be -- if then a

22     second question could be asked about the rest -- the remainder of the

23     question.  It's just a very run-on question.

24             JUDGE ORIE:  I think the question, although being rather long,

25     could be put in a short form to the witness and then to further elaborate

Page 13473

 1     on details.

 2             If one person had doubts as whether he could decipher what he

 3     heard and was then assisted by others to decipher, would that be noted

 4     down in the transcript or the document they created?  Would it say I

 5     sought the assistance of A and B are or would it just result of it being

 6     jotted down on paper?

 7             THE WITNESS: [Interpretation] Mr. President, it was mainly as you

 8     conclude.  Due to the rate of speech, two people may put headsets on

 9     their heads and listen together, and then they would try to reach a

10     conclusion as to what the word used was and how the conversation

11     developed.

12             JUDGE ORIE:  Now --

13             THE WITNESS: [Interpretation] And then they jot it down, and

14     that's how it would leave the facility.

15             JUDGE ORIE:  Yes.  And it would not be noted that another person

16     had also listened to that text.  There was no --

17             THE WITNESS: [Interpretation] No, there was no need.

18             JUDGE ORIE:  Please proceed, Mr. Ivetic.

19             MR. IVETIC:

20        Q.   Now, in relation to the recordings themselves, you have testified

21     that there was a process by which re-recording of important

22     communications on a different tape took place and then the old tapes were

23     erased or dubbed over.  I want to ask you first:  Did this re-recording

24     take place -- strike that.  When this re-recording took place, who was it

25     that decided what material was considered important enough to be saved on

Page 13474

 1     another tape?

 2        A.   I explained that several times.  Whenever there was a change of

 3     shift, we took full tapes to the intelligence department when -- where

 4     they would be listened to again to verify or check the reports we had

 5     submitted by that time.  They rerecorded the tapes that they believed

 6     were important in terms of the conversations they contained.  We had

 7     nothing to do with it.  It was also done for the sole purpose because we

 8     did not have enough tapes.  If something was interested, it was

 9     rerecorded, and the rest would then be reused.  So the tapes were

10     returned to us.  It was done for -- by the electronic warfare department

11     which was within our intelligence unit.

12        Q.   And I want to ask you at page 22 of your --

13             JUDGE ORIE:  Mr. Ivetic, before we start with new questions, if

14     it would be one question, okay, but otherwise I would prefer to take the

15     break first.  It's --

16             MR. IVETIC:  We can take the break.

17             JUDGE ORIE:  -- 10.30.  We briefly go into closed session, then

18     we'll resume after 20 minutes' break again in closed session so as to

19     then return in open session once the witness has again entered the

20     courtroom.

21                           [Closed session]

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 13475

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 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12                           [Open session]

13             THE REGISTRAR:  We're in open session, Your Honours.

14             JUDGE ORIE:  Thank you, Madam Registrar.

15             Mr. Ivetic, you may proceed your cross-examination.

16             MR. IVETIC:  If we could turn to page 22 of the 92 ter transcript

17     that is on the screen.

18        Q.   I'd like to discuss with you, sir, the testimony that's recorded

19     at lines 7 through 11 of the same, and it reads as follows, and we should

20     not broadcast the same, it is quoted as saying:

21             "The reports were analysed in detail in the Analysis Department,

22     and based on their analysis, guidelines were given for work.  But, of

23     course, every operator had to have an idea of how radio-relay systems in

24     the VRS worked.  So the process can at once appear simple and

25     complicated."

Page 13476

 1             I want to ask you, when you say that the Analysis Department

 2     which was a part of military intelligence issued guidelines for the work,

 3     what kind of guidelines are we talking about?

 4        A.   So that there is no mistake, this analysis section is the

 5     counter-electronic warfare section.  The guidelines were given for the

 6     most part for intensified reconnaissance if in a certain part of the

 7     front line increased activity was expected.  If they had such information

 8     from other sources, they would give us instructions to pay more attention

 9     to the north, the south, south-east, because our zone was from north-west

10     to south-east.

11        Q.   Thank you.  And if we could go to the bottom of the page, and it

12     bleeds onto the next page.  Your answer reads as follows:

13             "So primary analysis was made by our unit.  Because of the

14     frequency of traffic, we didn't have time for anything else.  In the

15     command of the 2nd Corps, there existed an Analysis Department, and

16     opposite that department there existed a department for

17     counter-intelligence protection which had the task of analysing all the

18     information gathered through electronic reconnaissance and to fill out

19     all the gaps in the communications system as it existed on the other

20     side."

21             Could you please tell us exactly what it means here to fill out

22     all the gaps?

23        A.   Considering that we were not the only unit engaged in electronic

24     reconnaissance, this section, which is now here called anti-electronic

25     activity, that's in fact counter-electronic warfare, received reports of

Page 13477

 1     this kind from intelligence sections of divisions, and they would put

 2     together the entire jigsaw puzzle for radio and relay communications in

 3     the area of the corps.  That's why they put it this way.  Fill in the

 4     gaps if, of course, we had information to fill in these gaps.

 5        Q.   Thank you, sir.  And if we could now turn to the very last page

 6     of this document in e-court and still not broadcast the same.  I'd like

 7     to focus on lines 11 through 14 of that page.  And it read as follows:

 8             "We were not under any obligation to store these tapes and ...

 9     material recorded on them.  The moment the intelligence section returned

10     them, that meant they -- that they lost their importance.  However, there

11     was no time to erase everything.  Some things were dubbed, some things

12     remained on the tapes that were in use, and that happened in 1996 and

13     1997."

14             Now, in relation to this testimony, would it sometimes result

15     that conversations and recordings of old communications would blend into

16     newer and subsequent recordings?

17        A.   That happened very rarely.  If in the electronic warfare section

18     they failed to erase it completely, we would do the erasing in our

19     locations.  During the transformation of the army in 1997, all the

20     division units came to us with their own equipment.  It simply didn't

21     happen.  There could be noise or interference only from the wear and tear

22     of the tapes on which we made recordings.

23        Q.   And, sir, in your answer here you have identified this in

24     relation to the years 1996 and 1997.  Am I correct that the same

25     procedure was also employed in the years prior, including 1995?

Page 13478

 1        A.   You're absolutely right, because as I said before, I know exactly

 2     how things are properly done, but our logistics and our technical

 3     capabilities simply did not allow us to do it perfectly.  We did our job

 4     as best we could.  That was the only way to preserve things.  I'll say

 5     again the reports bearing numbers are the official part of our work.

 6        Q.   Thank you, sir.  Now I'd like to look at another case with you,

 7     Popovic.  If we can call up 1D1076, and page 5 of the same in e-court,

 8     and not broadcast the same just to be safe.

 9             JUDGE ORIE:  Ms. Lee.

10             MS. LEE:  As the document is getting pulled up, I just wanted to

11     make one minor transcript correction.  It's on page 24, at line 19, and

12     it's -- it goes:

13             "The guidelines were given for the most part for intensified

14     reconnaissance in certain part of the front line," and here it says "in a

15     person part."

16             And this is just to clarify the record.

17             JUDGE ORIE:  That seems to be obvious that there was a small

18     mistake.

19             MR. IVETIC:  Yes, Your Honour.

20             JUDGE ORIE:  Please proceed.

21             MR. IVETIC:  Thank you.

22        Q.   If we can focus on line 13 and onwards to the bottom of the page,

23     and I'd like to first read for you, sir, and then ask you some questions.

24             "Q. We can now turn to a different topic.  In response to the

25     questions put to you by John Ostojic yesterday about what you said in

Page 13479

 1     your examination-in-chief, you said that in relation to certain persons,

 2     there existed already dossiers in which you wrote some of their features,

 3     their voices, and some of their personal features.  Do you remember that?

 4             "A. Yes.

 5             "Q. And I suppose that this was done on the basis of long-term

 6     work and a large number of intercepts, that that was used to compile a

 7     dossier; right?

 8             "A. Yes.  That's correct.  I came to this unit in February of

 9     1995 and there already existed a certain database for certain persons."

10             I'd like to ask you, sir, do you stand by what is recorded here

11     as being your testimony from the Popovic case as being both truthful and

12     accurate such that you would so answer the same questions if posed today?

13        A.   To the best of my recollection, yes.  I don't know what details

14     you mean, but it's certain that we had a database for certain persons,

15     mainly with information collected through electronic reconnaissance.

16     This database covered mainly persons in the VRS involved in

17     communications and the command staff.

18        Q.   Thank you.  And if we could turn to the next page of this

19     document.  The continuation of the discussion there talks about at line

20     12:

21             "Q. There are situations in which certain assumptions of

22     operators were recorded, as you said, but that does not necessarily imply

23     that they were correct.

24             "A. Assumptions were confirmed at a higher level.  They did not

25     necessarily need to be correct, but were taken at face value, so that

Page 13480

 1     this -- so that was one of the positions taken."

 2             Do you stand by this portion of your testimony as recorded as

 3     being truthful and accurate such that you'd so testify today if asked the

 4     same?

 5        A.   I would say the same to these questions today.  I'll repeat.  Our

 6     job was to collect information as it was and submit it to the superior

 7     command, including our conclusions, suggestions, et cetera, which doesn't

 8     mean that the necessarily -- the superior command will take it at face

 9     value.  It will accept it or not.

10        Q.   The question I have for you, sir, is these reports and these

11     notebooks that would be your end of it going up to the superior command,

12     where would we look to find corrections, verifications, or nullifications

13     by the higher authority about the assumptions that were made at the lower

14     level, at the unit?

15        A.   You should look at the intelligence department.  The commander

16     never received information in the form of an intercept.  It would first

17     go to the counter-electronic warfare section, which would make their

18     input, then to the analysis department of the intelligence department

19     where they included their conclusions, and in a simplified form presented

20     the information to the commander describing the situation on the ground.

21     There were no major corrections or anything.  It was simply a synthesis

22     and an analysis of all the intelligence coming into one place from

23     various sources.

24        Q.   I understand that, sir, and that's how I understood it.  The

25     question I have for you then is so these reports that are typed and these

Page 13481

 1     notebooks that we have from the unit are merely the assumptions by the

 2     unit, and we don't have any way of knowing what the verifications of the

 3     higher authority were, whether they found parts to be wrong, whether they

 4     found parts to be right.  We can't find that out from these reports

 5     themselves.  Is that accurate?

 6        A.   I would put it differently.  These are not all assumptions.

 7     Assumptions are only certain parts of the report.  And I'm going to say

 8     this again:  This was a lengthy process over many years.  In my mind

 9     these are facts that can be correct or incorrect.  It's up to the higher

10     level to decide what the essence is and what is not, because in addition

11     to our information, they received information from other sources.

12        Q.   I understand that the assumptions may not cover the entirety of

13     the typed reports, but could you please enlighten us.  How are we to

14     identify those parts that are assumptions?  Are they noticed in the

15     documents in any particular way?

16        A.   I don't know how they marked it at the higher level, but I know

17     from all that we did, 90 per cent was the truth, and I leave a 10

18     per cent margin for assumptions and certain errors [Realtime transcript

19     read in error "in certain areas"], et cetera.

20        Q.   I'm not asking about the higher authority.  I'm asking about the

21     unit.  How did the unit mark --

22             JUDGE ORIE:  Mr. Ivetic, the issue you're raising, the point

23     you're making is perfectly clear to the Chamber at this point in time.  I

24     think the witness in various ways answered the question that he doesn't

25     know how any acceptance or nonacceptance by the higher level would be

Page 13482

 1     visible in any of the reports.  That's how I understood it.  Therefore,

 2     you're pointing at certain risks that assumptions which were part of the

 3     reports may not have been visible and that therefore the Chamber should

 4     pay specific attention to the risks involved in that.  If that's your

 5     point, then it's clear.  If not, then please put focused questions to the

 6     witness.

 7             JUDGE FLUEGGE:  May I raise a problem for -- in the transcript.

 8     Page 30, line 4.  I read there, I quote:

 9             "... I leave a 10 per cent margin for assumptions in certain

10     areas, et cetera."

11             I heard the -- a different answer from the witness.  I thought

12     you were talking about a 10 per cent margin for assumptions in certain --

13     and certain errors.  Is that correct or what did you say?

14             THE WITNESS: [Interpretation] Precisely.  Yes.

15             JUDGE FLUEGGE:  Certain errors.  Certain errors.

16             THE WITNESS: [Interpretation] Yes, some errors in the work,

17     omissions of a letter, misspelling, et cetera.

18             JUDGE FLUEGGE:  Thank you very much.

19             JUDGE ORIE:  Please proceed, Mr. Ivetic.

20             MR. IVETIC:  Thank you.

21        Q.   Now I'd like to move on to some technical aspects.  First of all,

22     would you agree with me that the VRS basically used pre-existing JNA

23     radio relay systems, radio relay locations?

24        A.   The Army of Republika Srpska did not use them more or less.  They

25     used all the assets and resources of the JNA.  Only the roles were

Page 13483

 1     changed on paper.  All that had already been installed and in place in

 2     the previous communications system me which had worked perfectly well for

 3     the 30 years before and longer.

 4        Q.   And that would mean that you, your unit, knew where these

 5     pre-existing relay stations and transmission stations were located.  Is

 6     that accurate?

 7        A.   Again, let's not talk about assumptions.  I told you we had one

 8     man in our installation in the south, and we knew about all the -- these

 9     things.  We did not know which radio relay asset was exactly in which

10   (redacted)

11   (redacted)

12             THE INTERPRETER:  Interpreter's correction:  Not Zepa but Zep.

13             MR. IVETIC:

14        Q.   Would you agree that the radio relay communications from

15     Vlasenica to Veliki Zep to Zvornik were conducted using radio relay

16     devices RRU 800 and SMC 1306B over four radio relay routes or RR sub-D?

17        A.   I would agree with what you stated here, but I'm saying again it

18     was our opinion that we reached by just monitoring radio relay

19     communications and occasionally we would check the strength of the signal

20     across the entire range.

21        Q.   Would you agree with me that communications from -- by the VRS

22     from Vlasenica to Veliki Zep were performed via a RRU 800 and that the

23     distance between the two was approximately 15 kilometres?

24             JUDGE ORIE:  Ms. Lee.

25             MS. LEE:  Yes.  I was -- I would just like it to be clarified to

Page 13484

 1     the witness.  I mean, we're talking about equipments taken from the JNA,

 2     and so I would like to know the time-frame.  Are we talking about in -- I

 3     mean, what year are we talking about?  Are we talking about in 1995 or

 4     are we talking about sometime before that?  And if that could be put to

 5     the witness just for clarification purposes.

 6             JUDGE ORIE:  Mr. Ivetic, are you willing to adopt the suggestion?

 7             MR. IVETIC:  Sure.

 8             JUDGE ORIE:  Please do so.

 9             MR. IVETIC:

10        Q.   Sir, these radio locations of the former JNA that you said even

11     little children knew, did they change at all during the time-period when

12     the unit was in existence?

13        A.   I've told you the main hubs did not change.  The only thing that

14     changed were end radio relay stations of individual brigades.  These are

15     specialised installations that cost a lot of money, including atomic

16     shelters, huge stocks, et cetera.  That's not something you create in one

17     day.

18        Q.   Thank you.  And then I ask you again, sir, from the installation

19     at Vlasenica to the installation at Veliki Zep that the distance between

20     the two was 15 kilometres and that the device that was installed there

21     was a RRU 800.

22        A.   According to our information, yes.

23             JUDGE ORIE:  I'm a bit confused now.  I think I earlier asked

24     what an RRU would be.  Would that be a specific device, or would that be

25     a device which would cover a certain frequency.

Page 13485

 1             Now, Mr. Ivetic, did you intend to ask whether the device

 2     installed was fit to cover the RRU 800 range of frequency?  Is that -- or

 3     did you have a specific installation, a specific equipment in your mind?

 4             MR. IVETIC:  I'm talking about the installation at both the

 5     Vlasenica pre-existing station of the JNA and the Veliki Zep pre-existing

 6     installation of the JNA which both operated a RRU 800 and that the

 7     physical distance between those two locations was 15 kilometres.

 8             JUDGE ORIE:  Yes.  That's a few questions in one.  Let's first

 9     start with the -- with the distance.

10             Is it 15 kilometres between Vlasenica and Veliki Zep?

11             THE WITNESS: [Interpretation] I can't say exactly, but if we had

12     a map, we would calculate it easily.  It's around 15.  As the crow flies,

13     that is.

14             JUDGE ORIE:  Second, the equipment at Veliki Zep, was that of the

15     RRU 800 type?

16             THE WITNESS: [Interpretation] One of the pieces of equipment at

17     Veliki Zep was RRU 800.  It's the size of a small cupboard, rather heavy.

18             JUDGE ORIE:  Please proceed, Mr. Ivetic.

19             MR. IVETIC:

20        Q.   And, sir, in relation to the installation at Veliki Zep and the

21     installation at Cer, am I correct that the distance as the crow flies is

22     approximately 70.7 kilometres?

23        A.   I would agree with you, yes.  It's around -- around that.

24        Q.   And would you agree with me that according to your information,

25     the communications done on that route would have been by the SMC 1306B

Page 13486

 1     because of the distance involved, and so that is it exceeds the RRU 800's

 2     capabilities?

 3        A.   I would agree with you.  This SMC 1306B was used because that was

 4     one of the main communications with Belgrade.  SMC 130 is high quality,

 5     it has a more directed antenna, and it's safer for maintaining

 6     communication, plus it has 116 channels that can operate simultaneously.

 7        Q.   And am I correct that the other device at Veliki Zep was also a

 8     RRU 1 radio relay device?

 9        A.   From what we know, yes.

10        Q.   And from what you know, would you agree that from the Cer

11     installation to Crni Vrh, the air distance as the crow flies is

12     approximately 28 kilometres?

13        A.   I didn't measure, but it's around that distance, Vlasenica, and

14     up there is Sabac.

15        Q.   And -- and was there, as you understood it, two RRU 800 devices

16     on Crni Vrh elevation with communications going towards the Zvornik --

17     going towards Zvornik and from Zvornik by that means?

18        A.   I don't know how many devices there were at Crni Vrh, but we know

19     from monitoring long-term communications that at Crni Vrh, at

20     Mount Gucevo, there was one RRU 800, and since Zvornik is in a valley

21     near the Drina River, it had a direct communication with this end radio

22     relay station.  And what's more, from our information, I remember this

23     clearly, from Zvornik and up there they provided crews to their

24     personnel.  It must be written somewhere.

25        Q.   And would you agree with me that all the radio relay

Page 13487

 1     communications devices that we are talking about are for duplex

 2     communications, meaning a communication as a distinct transmission and

 3     reception direction or telephone channel on the entire external

 4     communication route, meaning that communications on one radio relay route

 5     is conducted using two different radio frequencies?

 6        A.   I agree with you.  There is a receiving and transmitting

 7     frequency with the RRU 800, as well as with the RRU 1, which is a radio

 8     relay device.

 9        Q.   Great.  Now I'd like to clear up some more matters.  In your Rule

10     92 ter transcript P1614 under seal, page 15, and it's lines 8 through 25

11     that are recorded there that are for me, I think, also a translation,

12     perhaps, issue, because it's not clear which devices you're identifying

13     and which comments about your abilities as to the devices are accurate.

14     So to clear it up, I'd like to talk about the technical aspects and see

15     if we can reach some agreement.

16             First of all, on the route of Vlasenica-Veliki Zep, there was a

17     radio relay device, an RRU 800, which transmitted 24 telephone channels,

18     namely two primary groups from which one group ended in Veliki Zep and

19     the second group was forwarded to Cer by way of the SMC 1306B relay and

20     further to Sazbrenica [phoen] over a JNA -- over the JNA system.  Is

21     that -- does that comport with your knowledge of the communications that

22     were underway on that system?

23        A.   Well, I would agree with you again.  It was normal to change a

24     lower frequency to a higher frequency.  That's why the devices were used,

25     and it is rather difficult to explain in technical terms, speaking from

Page 13488

 1     memory.  In any case, from Vlasenica there was an RRU 800, and then

 2     further to Cer we used an SMC.  That was because we were never able to

 3     either locate or monitor that frequency range.

 4        Q.   Sir, if I can ask you to correct something.  I think you had

 5     testified accurately but that the transcript may have an error.  It is

 6     said that -- that further to Cer, we used an SMC.  Was it "we" the ABiH

 7     that used the SMC or was it the VRS that used the SMC, sir?

 8        A.   The VRS, not the army.

 9        Q.   And just so we are clear, the SMC 1306B that we're talking about

10     is a dual device that transmits and receives working with frequencies of

11     4.4 to 4.6 gigahertz and 4.8 to 5.0 gigahertz?

12        A.   Yes, yes.

13        Q.   And is it correct that the ABiH did not have the technology

14     required to intercept communications which used this device set-up?

15        A.   I don't know about the ABiH, but my unit did not have that

16     possibility.  We had an old device which I believe we had received from

17     Travnik.  It was an SMC, but we were never successful in making it

18     operational.

19        Q.   Now, is the SMC 1306B a system that employs so-called satellite

20     frequencies and is used when there is no optical and therefore no radio

21     visibility between two points?

22        A.   I'm not aware of that characteristic.  I know it's a radio relay

23     device and that one needs a clear line of vision.  In other words, there

24     should be no obstacles between the two end points.

25        Q.   Was there optical and therefore radio visibility between

Page 13489

 1     Veliki Zep and Zvornik between the radio end points at those two

 2     installations?

 3        A.   If you have in mind Veliki Zep and the end point radio relay

 4     station in Zvornik, there was no optical vision.  That's why the

 5     alternative was used via Cer and Veliki Zep.

 6        Q.   Would you agree that the RRU 1 device or system was not utilised

 7     during the period of June to August 1995 on the territory of Vlasenica to

 8     Veliki Zep?

 9        A.   I cannot confirm or deny that.  The RRU 1 radio relay device is

10     something at that can be put on one's back and carried to whatever place

11     you want, as long as you can mount an antenna and to be within the range

12     of Veliki Zep or another radio relay hub.  It can also establish direct

13     communication between two radio relay devices of the same kind if there

14     is optical visibility.  It's a single-channel device, so it receives and

15     transmits on one channel only.

16        Q.   And in radio parlance that would be called a simplex

17     veza [phoen], or simplex device; right?

18        A.   Yes.

19        Q.   And just so that we're also clear, this RRU 1 device that we're

20     both talking about manufactured in Iskra factory in Ljubljana operated

21     on -- in simplex mode on a frequency of 300 to 340 hertz, and then if it

22     was used in a duplex mode it would have been on the principle of frequent

23     modulation in the range of 235 to 270 megahertz; is that correct?

24        A.   I think it was produced in Slovenia, so it was of domestic

25     production.  Its working frequency is the second one you mentioned

Page 13490

 1     between 235 and 270 megahertz.

 2        Q.   Thank you.  Now, in -- in relation to this RRU 1 device working

 3     on that frequency, am I correct that the range of coverage of the same,

 4     of the signal from the same, is about 30 kilometres from the centre and

 5     the receiver unit?

 6        A.   In the textbooks I believe that is what is stated, but I have to

 7     repeat yet again:  Each manufacturer provides the characteristics of a

 8     device where they guarantee that it will function within that range and

 9     at that distance.  It doesn't mean, though, that communication cannot be

10     established at bigger distances.  Electromagnetic waves are not something

11     tangible.  You never know how far they can go.  It depends on a number of

12     factors.  For example, for the RRU 800 they say that the range is up to

13     80, but it can reach as far as 120 or 130 kilometres depending on the lie

14     of land and whether there are depressions or features on the way -- in

15     the way.  Perhaps I don't need to repeat everything now.

16        Q.   And weather conditions would also affect it, temperature, et

17     cetera?  Pardon me, sun activity, et cetera?

18        A.   As I said, there's a number of factors, time of day, whether it

19     is day or night, vegetation, humidity, whether it is overcast.  It all

20     has an impact.

21        Q.   And now in this part of your Rule 92 ter transcript, you also

22     mention the HVT 1 device that operated between 400 and 500 megahertz but

23     it's a little unclear as to this device whether in fact your unit had the

24     ability to intercept this device or not.

25        A.   I already answered saying that our unit could not follow the SMC,

Page 13491

 1     HVT 1, and FM 200, so frequency modulation, which is also used for radio

 2     relay communication.

 3        Q.   Thank you.  I'd like to take the last two one by one.  With

 4     respect to the HVT 1, was this also a device manufactured in the

 5     Ljubljana Iskra factory with a maximum range of 50 kilometres?

 6        A.   I didn't read about its specifications, but as far as I recall,

 7     it is so.

 8             JUDGE ORIE:  Could I ask you, you are talking about factory

 9     specifications.  You earlier explained to us that the range in kilometres

10     given by the factory would be a guaranteed range but that it may well go

11     beyond that depending on all the circumstances you mentioned, including

12     atmospheric circumstances.

13             Where you answered the question about the maximum range, did

14     you -- where you said you did not know, would you consider such a factory

15     specification in similar terms as you explained to us before as to

16     whether it really was limited to a given range or whether it could go

17     beyond or perhaps under circumstances stay below that distance?

18             THE WITNESS: [Interpretation] I agree with you, Mr. President.

19     These are the technical specifications of a device.  When a factory

20     produces a device, they say you can establish communication up to

21     80 kilometres.  If you place two stations within that range, they

22     guarantee that the device will work properly, which in our parlance

23     means, although it is not guaranteed by the factory, that their device

24     can reach up to 100 or 120 kilometres if there are no significant

25     features in the way such as mountains.

Page 13492

 1             JUDGE ORIE:  Maximum range means maximum guaranteed range by the

 2     factory.  Is that understood?

 3             THE WITNESS:  Yes.

 4             JUDGE ORIE:  Please proceed.

 5             MR. IVETIC:

 6        Q.   And as for these guaranteed ranges, according to the

 7     specifications of the factory, that would be for a brand new device

 8     capable of powering up to 100 per cent.  Is that accurate?

 9        A.   Again, this question is something to ponder, but a new device

10     with good characteristics and all the necessary checks should, with

11     maximum power, establish communication without any problems at the

12     specified range, which doesn't mean that it could not reach such

13     communication with less capacity.

14        Q.   And if we could focus on the RRU 800 for a moment.  That device

15     was new in the 1950s and 1960s, and in 1995 was already considered an

16     old-fashioned device.  Is that accurate?

17        A.   Well, for Europe it was old fashioned.  If you take into account

18     that it worked, say, four [as interpreted] hours a day for over 40 years,

19     one could definitely not say that it is at its best any longer.

20             JUDGE ORIE:  Could I ask there one question.  The device was new

21     in the 1950s and 1960s.  Does that mean that they were not produced at

22     any later point in time, or were they still produced but were they old

23     fashioned as far as the technology was concerned?

24             THE WITNESS: [Interpretation] In our view and to my knowledge,

25     that device was produced at the time specified, and later they may have

Page 13493

 1     been still produced but to a less -- lesser degree, because the system

 2     had to be changed at all mountain tops of Yugoslavia if you wanted a

 3     completely new system.  That is why this system lived such a long time.

 4     It's a costly enterprise.

 5             JUDGE ORIE:  Please proceed.

 6             MR. IVETIC:

 7        Q.   Thank you.  And one clarification.  It's entered into the

 8     transcript, sir, that these devices would be working four hours a day.

 9     Did you say four hours or 24 hours a day?

10        A.   Twenty-four hours a day.

11        Q.   Thank you, sir.  Would you agree that the RRU 800 in 1995 that

12     worked out of a double exploitation period and had a maximum outgoing

13     strength that was about 70 per cent of the original value?

14             JUDGE ORIE:  Ms. Lee.

15             MS. LEE:  If this is a statement of fact, if that could be put to

16     the witness.  I'm not -- I'm wondering how this witness could answer that

17     question.

18             MR. IVETIC:  Since he testified to it in other trials.

19             MS. LEE:  Then can that portion be put to him or read to him?

20             JUDGE ORIE:  Well, I do not see why the witness couldn't answer

21     the question.  The witness is asked whether he agrees that the RRU 800 in

22     1995, that -- and that's the assumption, not yet been established,

23     although almost confirmed by the witness, that worked out of a double

24     exploitation period, there Mr. Ivetic apparently referred to the 40 or 50

25     years, and he apparently has in his mind that the exploitation period was

Page 13494

 1     approximately half of that, that as a result the maximum outgoing

 2     strength was about 70 per cent of the original value.

 3             Ms. Lee, I do agree with you that Mr. Ivetic includes in his

 4     question a series of assumptions, but at the same time, having listened

 5     to the evidence of this witness, there is at least some basis for such

 6     assumptions.

 7             Now, I have rephrased the question for you, Witness.  Could you

 8     tell us on the basis of all the assumptions included in this question

 9     whether you would agree that the strength of the original value had been

10     reduced to 70 per cent -- about 70 per cent?

11             JUDGE MOLOTO:  There may be -- may be an interpretation problem

12     here.  As I read the question as formulated by Mr. Ivetic, it doesn't

13     seem complete because of the conjunction "and," and this thing is

14     supposed to have -- be an RRU 800 in 1995 and worked out of double

15     exploitation and had maximum outgoing strength of 70 per cent value, so

16     what is the question after that?  These are all -- these are all

17     assumptions.  The question has not been put yet.

18             JUDGE ORIE:  These are all assumptions.

19             Mr. Ivetic, the way in which I rephrased the question, did that

20     reflect what you had on your mind --

21             MR. IVETIC:  Yes.

22             JUDGE ORIE:  -- but what you did not say.

23             MR. IVETIC:  Yes, it more eloquently stated the point.

24             JUDGE ORIE:  Well, more precisely I would say.  Eloquence is not

25     my strongest.

Page 13495

 1             Witness, have you followed the way in which I rephrased the

 2     question, and would you agree then that after 40 to 50 years that it

 3     would be 70 per cent which remains as, if I could say so, the power or

 4     the strength?  I think strength was the word used.

 5             THE WITNESS: [Interpretation] Mr. President, I think I recall the

 6     question being put in the Popovic case when Defence claimed that the

 7     devices were so old that they were only at half strength, and I said that

 8     in our view if the devices were used for 40 years that their strength was

 9     down to between 70 -- was down by 70 to 80 per cent, meaning that only 30

10     to 40 per cent were left, which is impossible.  That was the question put

11     in that case.

12             I still believe that two persons, one aged 20 and another aged

13     60, could not produce the same results.

14             JUDGE ORIE:  That's a mysterious answer for me.  Do you mean that

15     if something is older that does not necessarily mean that the capacity,

16     even if it's worn out quite a bit, that the capacity does not have

17     necessarily to have been substantially reduced?

18             THE WITNESS: [Interpretation] Not in any case or every case, but

19     in most cases we have to agree.  I'm not the same person I was 30 years

20     ago.  Defence claimed that all of the devices we monitored worked in the

21     middle of the war with a reduced strength, which is absurd.

22             JUDGE ORIE:  Yes.  Could I ask you is it the kind of discussion

23     if whether you drive an old car whether it loses maximum velocity,

24     maximum speed.  It may do a bit, a car which was produced for driving 150

25     kilometres might end up after 20 years in driving 140 kilometres or 130,

Page 13496

 1     but not necessarily much further down.  Is that the kind of thought that

 2     is behind your mysterious answer?

 3             THE WITNESS: [Interpretation] Precisely.  Wear and tear.

 4                           [Trial Chamber confers]

 5             JUDGE ORIE:  Please proceed, Mr. Ivetic.

 6             MR. IVETIC:

 7        Q.   Yes.  I'd like to ask the mysterious answer be clarified.  Sir,

 8     you said at temporary transcript page 43, lines 11 through 12:

 9             "And I said that in our view if the devices were used for 40

10     years, that their strength was down to between 70 -- was down by 70 to 80

11     per cent."

12             Could you please explain that answer in terms of -- first of all,

13     when you say "in our view," are you referring to the unit of the ABiH

14     that you participated in?

15        A.   Yes.  The officers and the people we discussed here, they were

16     probably people who were more familiar with the devices themselves.  If

17     something has been working for 40 years nonstop, of course it's a degree

18     of exploitation, its strength is different, and no one can claim

19     otherwise.  From the Popovic context, when we discussed about it, I

20     remember they said that all of the devices worked at only half strength

21     which is absurd.  This is what I meant.  If --

22             THE INTERPRETER:  Could the witness kindly repeat the end of his

23     question.

24             JUDGE ORIE:  Could you please repeat the last part of your

25     answer.  You said this is what I meant, and then you started another

Page 13497

 1     sentence.  Could you repeat that.

 2             THE WITNESS: [Interpretation] I said that from the context

 3     concerning the people we talked about -- talked with when discussing the

 4     manuals, it was concluded that a device working for 40 years has a

 5     difference in power and strength and that its strength is no longer the

 6     same.  The other side claimed that all of those devices in 1995 worked at

 7     half strength.  So if it used its exploitation strength in the height of

 8     the war when you depend on your communications, if they indeed worked at

 9     only half strength, then it would have struck me as illogical from a

10     military standpoint.  It would mean that they worked at one-third of

11     their strength, and which would mean that we couldn't even monitor such

12     devices because they could only transmit at very low strength.

13             JUDGE ORIE:  Do I understand you well that what you're saying is

14     that if the strength was so drastically reduced, it could not serve its

15     purpose as communication channels any further because it couldn't bridge

16     the distances?

17             THE WITNESS: [Interpretation] I'm only repeating the claims made

18     by the Defence when we discussed this issue.  They claimed that these

19     already old devices, 40-year-old devices, were working at only half

20     strength, meaning with a loss of 50 per cent of their original capacity.

21             JUDGE ORIE:  Making them unfit to perform what they were supposed

22     to perform.  Is that what I understand would be the result of such a

23     claim?

24             THE WITNESS: [Interpretation] Precisely.  Precisely,

25     Mr. President.

Page 13498

 1             JUDGE ORIE:  Mr. Ivetic, I'm looking at the clock.  Before we

 2     take a -- yes.  Judge Moloto has one question.

 3             JUDGE MOLOTO:  Just one question.  Now, because I didn't -- your

 4     answers were not very clear to me, and apparently they were described as

 5     mysterious, I just want to ask you:  You say the opposite side in the

 6     Popovic case claimed that [indiscernible] equipment worked at 50 per cent

 7     strength.  In your view, at what strength did they work?

 8             THE WITNESS: [Interpretation] In our opinion, it was working with

 9     a 70, 80 of -- per cent of its original capacity, as new.

10             JUDGE MOLOTO:  Thank you so much.

11             JUDGE ORIE:  Then we first move into closed session, and resume

12     after the break in closed session so as to allow the witness to leave and

13     enter the courtroom.

14                           [Closed session]

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 13499











11 Page 13499-13501 redacted. Closed session.















Page 13502

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4                           [Open session]

 5             THE REGISTRAR:  We're in open session, Your Honours.

 6             JUDGE ORIE:  Thank you, Madam Registrar.

 7             Mr. Ivetic, you may proceed.

 8             MR. IVETIC:  Thank you, Your Honour.

 9        Q.   Now, sir, so that we can explain to persons who may not have

10     experience with military-grade or professional-grade radio equipment, am

11     I correct that for such equipment there is more than merely a power

12     on-off switch, but there is also a power modulation knob that allows you

13     to adjust the power setting for that particular radio transmitter?

14        A.   If you mean professional military equipment, yes.

15        Q.   And in respect specifically to the RRU 800 professional military

16     equipment, that device has or had a power variable knob allowing the

17     operator to decrease the power output to that machine to something less

18     than 100 per cent of its capacity; is that correct?

19        A.   Yes.

20        Q.   Would you agree with me, sir, that in the JNA radio operators

21     were trained and, in fact, it was part of an obligatory

22     counter-electronic protection method of the JNA that when operating a RRU

23     800 over ranges shorter than its guaranteed maximum, the power settings

24     would be reduced so as to limit the opportunity for opposing forces to

25     intercept those communications?

Page 13503

 1        A.   In principle, yes.

 2        Q.   And would you also agree with me that in terms of covering the

 3     shorter relay radio sections such as Vlasenica installation to Veliki Zep

 4     of approximately 15 kilometres, Zvornik installation to Crni Vrh

 5     installation approximately 10.5 kilometres, and Cer location to Crni Vrh

 6     installation of 28.2 kilometres, RRU 800 devices would only need to

 7     operate at approximately 50 per cent of their maximum power to accomplish

 8     covering those short distances?

 9        A.   I would agree with you in one part but not in another.  I don't

10     know with what strength they were working.  All I know is that we were

11     listening to them.  Whether they used 50, 70, or 100 per cent of their

12     capacity, I don't know, but we listened to them, and all that we heard is

13     written.

14        Q.   Do you agree with me about the technical capabilities and the

15     method trained by the JNA for the use of the device that to cover those

16     shorter ranges the operator would reduce the power output and that would

17     be sufficient to cover those shorter ranges?

18             JUDGE ORIE:  Mr. Ivetic, the witness has answered this question

19     by, in principle, yes, and then he explains that he didn't know what was

20     done and that, of course, that keeps you apart.  The witness thinking in

21     terms of what he knows rather than in theory, and he explained that what

22     was the case he doesn't know, he only knows that that was listened.  But

23     I think he already agreed that this was part of the training, that this

24     was the principle, the theory.  So therefore -- and I see the witness is

25     nodding yes, so apparently he agrees with that.

Page 13504

 1             THE WITNESS: [Interpretation] Yes, yes.

 2             JUDGE ORIE:  He confirms it by saying, "Yes, yes."  So the

 3     witness has answered at that question.

 4             MR. IVETIC:  Thank you.

 5        Q.   You -- we sort of went off track to talk to the specifics of the

 6     RRU 800.  We left off also talking about one more advice -- device which

 7     you had identified which was the FM 200, which your unit could not

 8     intercept, and just to make sure we're talking about the same device and

 9     understand each other, is the FM 200 the device that was obtained by the

10     JNA in 1975 to begin replacing the RRU 800 produced by the west German

11     firm of Siemens and Telefunken?  Let's start with that as the first

12     question.

13        A.   I cannot give you a precise answer.  I can only suppose.  You

14     should ask someone from the General Staff of the Army of Yugoslavia.  I

15     know that a replacement should have been done.  Whether it was at that

16     stage FM 200 or some other device, it's a frequency modulated signal,

17     whereas the RRU was analogue.  That's why we were able to listen to it.

18     RRU had a modulated signal, and we didn't have the equipment to monitor

19     it.

20             THE INTERPRETER:  Sorry, interpreter's correction:  FM had a

21     modulated signal and that's why we didn't have the equipment to monitor

22     it.

23             MR. IVETIC:

24        Q.   Thank you, sir.  And the FM 200 also required optical and radio

25     visibility and had a factory -- factory guaranteed range of 50

Page 13505

 1     kilometres?

 2        A.   I really wouldn't like to go into detailed technical

 3     specifications.  You can find that on the internet.  But all radio relay

 4     devices require optical visibility.

 5        Q.   Thank you.  Now, if we could briefly go into private session I

 6     have some questions that relate specifically to the locations of the

 7     stations.

 8             JUDGE ORIE:  We move into private session.

 9                           [Private session]

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 13506

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8                           [Open session]

 9             THE REGISTRAR:  We're in open session, Your Honours.

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             As a general guidance to the parties, if we're talking about

12     distances, take a map and a cup of tea and a cup of coffee and establish

13     what the distances are.  Please proceed.

14             MR. IVETIC:

15        Q.   Now I wish to focus on the equipment or actually -- pardon me,

16     the antenna that were at the various listening posts that were used by

17     the ABiH both the northern and the southern positions, and I'd like to do

18     the southern position first.  Am I correct that this location had four

19     monitoring posts that used the following devices:  First, two ICR 100

20     attached to a logoperiodic antenna; one ICR 100 attached to a parabolic

21     antenna; and one AR 3000A attached to a parabolic antenna?

22        A.   Approximately.  That was approximately what was needed to cover

23     the equipment we had.  I cannot remember every specific unit now.

24             MR. IVETIC:  Well, if we could be perhaps fair to the witness,

25     I'd like to not broadcast but call up in e-court 1D1081.

Page 13507

 1        Q.   And, sir, as I ask you these questions, I can -- I can refer you

 2     to this document that is dated the 15th of February, 1995, and I believe

 3     that you are familiar with the document.

 4             MR. IVETIC:  And we -- I think we only have this one in B/C/S so

 5     perhaps -- oh, we do have the translation.  I apologise.  But we may need

 6     to go to the last page to allow the witness to identify why he might

 7     recognise this --

 8        Q.   Well, actually, do you recognise this document, sir?  The sender

 9     and the recipients are the same.

10        A.   Yes.  Yes.

11        Q.   And if we go back to the first page.  Here it is recorded, sir,

12     that the unit in question had -- that both parabolic antenna had an SO 42

13     converter attached to them, and I want to ask you in respect to the SO 42

14     converter, is it correct that such a converter is not generally needed

15     nor used for frequencies ranges below 1 gigahertz?

16        A.   I would not agree with you.  These converters that we had were

17     mainly handmade, and they were used -- it's a bit technically difficult

18     to explain.  Our equipment was not professional.  First of all, we had to

19     raise frequency to 16.000 megahertz, I believe, to use as a 0 baseline.

20     So it's not the same baseline for our devices and military devices.  We

21     had to raise the signal.  These are all makeshift converters.

22        Q.   So when this document says that the SO 42 converters were

23     attached, it is not, in fact, what is in the industry generally

24     acknowledged as an SO 42 converter.  Is that your testimony?

25        A.   Roughly speaking, yes.

Page 13508

 1             JUDGE ORIE:  Mr. Ivetic, you put the question to the witness.

 2     Could you explain to this Chamber exactly what it is that you asked?  So

 3     the witness apparently understood it, but for the Chamber, you are

 4     referring to a certain -- you said the SO 42 converters were attached but

 5     they were not, in fact, what in the industry generally acknowledge as an

 6     SO 42 converter.  Could you tell us what is in the industry is generally

 7     acknowledged as an SO 42 converter and what does that mean?

 8             MR. IVETIC:  Your Honours, an SO 42 converter is an addition or

 9     an add-on to an existing antenna array that allows you to convert signals

10     that are in excess of 1 gigahertz so that you can listen to them on

11     devices that do not go in that range.

12             Now, the Defence position, Your Honours, is that since all the

13     devices that we've talked about that were used by the JNA, that were used

14     by the VRS, are all under 1 gigahertz, that the addition of this

15     converter was not anything that would assist these antenna to intercept

16     these devices and these signals.

17             JUDGE ORIE:  Yes.  So therefore we should ask the witness first

18     of all whether he agrees with you that what is generally acknowledged as

19     an SO 42 converter is that that applies only or exclusively to add-ons

20     which allow to convert signals that are in excess of 1 gigahertz.  So you

21     can listen them on devices that do not go to that range.  Is that your

22     understanding of what an SO 42 converter is as explained by Mr. Ivetic?

23             THE WITNESS: [Interpretation] Mr. President, it's a bit

24     complicated to explain these technical things.  This converter was not

25     exactly outside by the antenna.  These converters were behind the device

Page 13509

 1     and the preamplifiers.  The preamplifiers were used to increase the

 2     signal, and the converters were used to adapt to the frequency.  They

 3     were not -- because our devices were not calibrated the same as military

 4     equipment.  I don't know how else to explain it, although I know the

 5     function.

 6             JUDGE ORIE:  I appreciate your explanation, but my question was

 7     the way -- because this Chamber, of course, is not familiar with SO 42

 8     converters as they are produced in the normal industry, whether you

 9     agreed with Mr. Ivetic that you were talking about the same as he was

10     talking about, and that's the reason why I asked him to explain what he

11     understood to be an industrial, not your ones but the industrial SO 42

12     converters, being add-ons which are used if the frequency is above 1

13     megahertz I think it was -- gigahertz, and to reduce that.  Is that

14     usually the -- what you understand industrially as an SO 42 converter?

15     Again, not your ones, but as produced normally.  Is that an accurate

16     description of what an SO 42 converter is, the description given by

17     Mr. Ivetic?

18             THE WITNESS: [Interpretation] I think he found this information

19     from legitimate sources, some authorities, so to that extent I would

20     agree, but in this case the function the converter is different.

21             JUDGE ORIE:  But that is the general understanding of what an

22     SO 42 converter is, the way in which Mr. Ivetic explain that.  Again, not

23     yours, but in general.

24             THE WITNESS: [Interpretation] Yes.

25             JUDGE ORIE:  Please proceed.

Page 13510

 1             Mr. Ivetic, for the Chamber to understand the technicalities, and

 2     we try hard, it's good to -- to use such terms that are understandable

 3     and not only code-names.  What an industrial SO 42 converter is may be a

 4     shared secret between you and the witness, but if you want the Chamber to

 5     pay attention to it, just try to translate it in ordinary terms.

 6             MR. IVETIC:  Thank you, Your Honour.  I'll try.  And of course,

 7     I'm trying to be as precise as possible so that the witness has the

 8     ability to answer and then provide the clarification.

 9             JUDGE ORIE:  Please proceed.

10             MR. IVETIC:

11        Q.   Sir, now, the AR 3000A which is attached to the parabolic antenna

12     at this location, first of all we're talking about one of the receivers,

13     one of the radios that operators would be listening on; is that correct?

14        A.   Yes.

15        Q.   And am I correct that it is used for canvassing the UVF range 70

16     centimetre bandwidth?

17        A.   Yes.

18        Q.   And does this radio listening device also have a modem attached

19     that would allow it to cover teleprinter traffic if such traffic were

20     being transmitted?

21        A.   I think that this technical option exists, and it says here we

22     had one device, M 8000, a device that was able to capture teleprinter

23     traffic, but only if the operators make a mistake and send an open

24     telegram.  If they were transmitting encrypted telegrams, we would not be

25     able to capture it.

Page 13511

 1        Q.   Thank you.  That's -- that's correct.  And now what I want to ask

 2     you is in terms of a factual question, did either of your stations in the

 3     course of 1995, July 1995, actually intercept any unencoded teleprinter

 4     traffic transmitted by the VRS?

 5        A.   I really cannot remember whether it was intercepted in this

 6     period, but I know we had a few cases when we intercepted open text

 7     telegrams.  They should have been encoded, but they were transmitted in

 8     open text by mistake, and I believe in one case it was a report from one

 9     of the Doboj brigades, and in another case -- and I'm not saying it's the

10     same period from the radio station at Kozara when they were sending a

11     report to Belgrade.  That's what I know.

12        Q.   And on those occasions, and again I'm not going to hold you that

13     these were the only two, but on those occasions when it was a telex that

14     was intercepted, would the report that was generated identify this

15     differently as being a telex rather than an audio conversation that was

16     being intercepted?

17        A.   I don't know if you're going to understand me, but this was

18     written information.  It was not talk.  It was written, encoded at

19     teleprinter, and transmitted through the communication system.

20        Q.   Yes, I do understand you and that's exactly what I was asking.

21     Thank you, sir.

22             MR. IVETIC:  Now, if we can call up in e-court, and this can be

23     broadcast, 65 ter number 05293.

24        Q.   Sir, this will be a photograph from one of the locations, and I'd

25     like to ask if you could identify which specific parabolic antenna we're

Page 13512

 1     looking at.  I believe, but I could be wrong, that this would be the one

 2     that was attached to the AR 3000A, that is to say, that was at the

 3     southern location, but I defer to you.

 4        A.   You're right.  You see the pine trees around.  It is a handmade

 5     parabolic device as far as I can see, and it is the one on the southern

 6     facility.

 7             MR. IVETIC:  Your Honours, I would tender this as the next

 8     available exhibit, an open exhibit.

 9             JUDGE ORIE:  Madam Registrar.

10             THE REGISTRAR:  Document 05293 receives number D308, Your

11     Honours.

12             JUDGE ORIE:  And is admitted into evidence.

13             MR. IVETIC:  If we could now have document number 05294 up in

14     e-court.  And again, it can be broadcast.

15        Q.   Sir, we're going to see another picture which I also believe to

16     be from the southern location, and I believe is this -- and focusing on

17     the one that is the green pipe with the flat back to it and cables coming

18     out of the back, can you tell us what type of antenna this was and if it

19     indeed it is one of the ones at the southern location?

20        A.   I can only suppose that this is in the northern -- in the

21     southern location.  It is a makeshift helicoidal antenna.  The base is a

22     piece of tin with a tube, 100 millimetres, and copper wiring.  So this is

23     a handmade antenna.

24             MR. IVETIC:  And if perhaps -- perhaps to short-circuit and make

25     it easier, if we could have 05295 brought up alongside this photograph,

Page 13513

 1     then I would have some questions about these.

 2        Q.   And, sir, I believe now what would be shown is a different view,

 3     that is to say a view of the -- of the other antenna that's on the left.

 4             MR. IVETIC:  Do we have 05295?  Yeah.  There we go.  Nope.  Well,

 5     that's -- yeah, that's fine.  That's fine.

 6        Q.   Is -- if we could just -- are both of these antennas, sir,

 7     helicoidal type antennas that were used by the unit in question?

 8        A.   Yes.

 9        Q.   And are both of these makeshift or homemade?

10        A.   They should be.  I can't see.  For a while we put the wiring

11     inside -- outside, and later on they were placed elsewhere for ease of

12     manufacture, but I think both are homemade.

13        Q.   And from the -- from the documentation we just looked at from

14     February of 1995, only two devices were hooked up to logoperiodic or

15     helicoidal antenna, and only one of those had a recorder attached to it.

16     Is that accurate, sir?

17        A.   It depended on the number of functioning reel-to-reel devices.  I

18     can't say precisely.  At the work station, there should have been two,

19     but I don't know whether both were operational at the time.

20        Q.   Let me clarify it.  In the southern location, am I correct that

21     at one point in time one of discs on the reel-to-reel UHER 4000 device

22     malfunctioned leading that device to become inoperable?

23             JUDGE ORIE:  Ms. Lee.

24             MS. LEE:  Yes.  If this is a fact that he's putting to a witness,

25     I think the source of that information or document should be shown to the

Page 13514

 1     witness in fairness.

 2             JUDGE ORIE:  Well, not necessarily always.  But first of all,

 3     it's a composite question.  Could you split it up, Mr. Ivetic.

 4             MR. IVETIC:  Yes, I could try.

 5        Q.   Sir, first of all, am I correct that the UHER 4000 is the

 6     reel-to-reel recording device that was used at both facilities or one of

 7     the types of recording devices that was used at both facilities?

 8        A.   The UHER were the reel-to-reel recorders that we used the most,

 9     in particular the UHER 4000.

10        Q.   Do you recall, sir, that the southern location at some point in

11     time had one of the discs damaged on one of the UHER 4000s such that it

12     could no longer be used?

13        A.   I can only say that while I was there at both facilities

14     malfunctions were frequent.  It is normal and it didn't include only one

15     recorder.  There was one mechanic going round fixing things nonstop.  I

16     don't know whether it was, as you put it, at that particular moment.

17        Q.   And so when --

18             JUDGE ORIE:  In the question the reference to the disc, I think

19     it was, Mr. Ivetic, could you -- one of the discs damaged.  We have discs

20     in two entirely different connotations here.  The one is the parabolic

21     discs, the other one is the discs within electronic devices.  It's

22     unclear to me what you refer to, what disc would have been damaged.

23             MR. IVETIC:  I'm not talking about the antenna.  I'm talking

24     about the recorder device, the UHER 4000 that would have been the

25     reel-to-reel magnetic recording device that would record on magnetic tape

Page 13515

 1     and that disc being one of the spindles that would spin the reel-to-reel

 2     tapes was damaged rendering that device no longer functioning.

 3             JUDGE ORIE:  So it's mechanical.

 4             MR. IVETIC:  Mechanical.

 5             JUDGE ORIE:  Thank you.  Please proceed.

 6             MR. IVETIC:  And just to be fair to the witness.

 7        Q.   You followed what I said.  Is that how you understood my question

 8     to be?

 9        A.   Yes, I understand it that way.

10             JUDGE ORIE:  The Chamber also has to understand not only the

11     questions but also the answers.  Please proceed.

12             THE WITNESS: [Interpretation] Some sort of rollers.  That's what

13     I would call them.

14             JUDGE ORIE:  Yes.  A disc maybe, but let's say apparently the

15     system that makes it run.  That's -- please proceed.

16             MR. IVETIC:  Okay.

17        Q.   Now, you say that these are -- or you believe that both are

18     makeshift or homemade devices.  Can you confirm for me, sir, that in fact

19     the homemade helicoidal antenna that were used at the facility were

20     fabricated out of refuse traffic signs and a refuse sewage pipe?

21             JUDGE ORIE:  Do you have any knowledge, Witness, about the

22     materials from which it was produced?

23             THE WITNESS: [Interpretation] I'll be brief.  Since we did not

24     have the necessary material at the base that the tube is mounted on,

25     well, that usually came from traffic signs along the road.  We would cut

Page 13516

 1     them down to the right size and mount a plastic sewage pipe 10

 2     centimetres in diameter.  Depending on the resonance we wanted to achieve

 3     to be equivalent to the frequency we wanted to monitor, we had to match

 4     our antenna and the antenna of the VRS, and it depended on whether we

 5     wanted 750 megahertz, 850, or 650.  We also used coils around the tube

 6     made of copper.  So we would make a calculation of the number of coils

 7     necessary in order to pre-amplify the antenna which could pick up quality

 8     communication by the VRS.

 9             On this photograph you see a plain TV antenna that would be used

10     very well to monitor RRU 1 frequencies on the left-hand side picture.

11     Anyone can try that for themselves, and that is so.  There's a number of

12     TV channels that are transmitted at the same frequency.

13             JUDGE ORIE:  I think Mr. Ivetic was mainly focusing on the

14     traffic signs and the sewage pipe.  Next question, please, Mr. Ivetic.

15             MR. IVETIC:  If I could tender this -- these -- what's on the

16     screen.  Is it possible to tender this as one exhibit now, these two

17     pictures perhaps?

18             JUDGE ORIE:  It may have been -- it may have to be uploaded

19     together.  So it should then be re-uploaded, the two pictures together

20     under one number.

21             MR. IVETIC:  Or it might be just easier then to do the two as

22     separate exhibits.

23             JUDGE ORIE:  Madam Registrar, the first number would be?

24             THE REGISTRAR:  Document 05294 receives number D309, and document

25     25295 receives number D310, Your Honours.

Page 13517

 1             JUDGE ORIE:  D309 and D310 are admitted into evidence.

 2             MR. IVETIC:

 3        Q.   And --

 4             JUDGE ORIE:  Perhaps I should have been clearer.  It's D309 and

 5     D310 are admitted into evidence.

 6             Please proceed.

 7             MR. IVETIC:  Yes.

 8        Q.   Sir, in answering the Judge's question you indicated that these

 9     devices would be cut down and fabricated according to the specific

10     resonance, that is to say the specific frequency that you were trying to

11     intercept.  Can we take from that, sir, then, that these antenna would

12     not be capable or suitable for intercepting frequencies above or below

13     that specific frequency that it was manufactured to collect?

14        A.   According to our calculations, yes.  They were made to cover the

15     entire range we monitored more or less.

16        Q.   One more from this set, I think.  Number 5296.  I think this is

17     the one I was looking for earlier.

18             JUDGE ORIE:  Let me first seek to clarify the previous answer,

19     because there seems to be a bit of a -- you said according to your

20     calculations yes.  Now, the question had been whether these antenna would

21     be capable or suitable for intercepting frequencies above or below --

22     below that specific frequency.  Do I understand that you designed it for

23     a certain range of frequencies and that therefore it could not intercept

24     anything outside that range?  Is that --

25             THE WITNESS: [Interpretation] Mr. President, you understood it

Page 13518

 1     excellently.  They could pick up certain signals below or higher than the

 2     frequency but not in quality terms.  They were only foreseen to capture

 3     the signal within the range we wanted to listen in on.

 4             JUDGE ORIE:  Mr. Ivetic, I sought this clarification because you

 5     were talking about a specific frequency, whereas the witness was talking

 6     about the frequency range.  That is what caused me to seek this

 7     clarification.  Please proceed.

 8             MR. IVETIC:  Thank you.

 9        Q.   If you recall, sir, what specific frequency range were these

10     makeshift antenna calibrated to receive?

11        A.   I can't be precise, but they were made to monitor the range of

12     frequencies used for the communication we monitored.

13        Q.   If we could call up and we can broadcast number 5296.  As I was

14     saying, I think this is the picture that I wanted earlier that shows a

15     better close-up of the one antenna which I think would -- you'll confirm

16     is precisely the type that you were talking about with the traffic sign

17     attached to a plastic sewage pipe.

18             Sir, does this -- can you confirm that this was one of the

19     makeshift antennas that you were referring to previously that was made

20     from traffic signs that would have been cut down to a particular size?

21        A.   It is one of the antennae.

22             MR. IVETIC:  Your Honours, if we could tender this as the next

23     exhibit, public exhibit.

24             JUDGE ORIE:  Madam Registrar.

25             THE REGISTRAR:  Document 05296 receives number D311, Your

Page 13519

 1     Honours.

 2             JUDGE ORIE:  And is admitted into evidence.

 3             Mr. Ivetic, perhaps you could explain sooner or later why this

 4     one gives information more than the ones we had already.

 5             MR. IVETIC:  The stop sign [Overlapping speakers] on the back.

 6             JUDGE ORIE:  Oh, the stop sign.  Yes, yes.  Yes, I think the

 7     witness confirmed that already.

 8             MR. IVETIC:  Yes.

 9             JUDGE ORIE:  So therefore to see it perhaps the next one for the

10     one-way traffic sign --

11             MR. IVETIC:  No, Your Honours.

12             JUDGE ORIE:  Okay.

13             MR. IVETIC:  This is just a close-up of the one that was visible

14     in the first image that we looked at on the left-hand side.  Partly

15     visible.  And I wanted to -- that's where I originally was going and the

16     other picture kind of fell in the middle.

17             JUDGE ORIE:  Please proceed and keep in mind what we need to

18     understand the testimony and what doesn't add that much to what we know

19     already.

20             MR. IVETIC:  Okay.

21        Q.   Sir, I'd like to look at a document, and this one we should not

22     broadcast, 1D1082.  And I think this one -- I think this one we only have

23     a B/C/S.  So if we can have it zoomed so the witness can view it

24     normally.  I believe you'll recognise this document as being from the

25     24th of February, 1995, in relation to the other northern station of the

Page 13520

 1     unit.  Is that correct, sir?

 2        A.   It is a document from that unit, but I think as far as I can see,

 3     it comes from a facility in the north.  This document and the previous

 4     one were the result of certain measures we undertook.  They had to send a

 5     report like this every evening as to the situation with their equipment.

 6        Q.   And according to this report, of the three monitoring positions,

 7     they all used the same amplifier; is that correct?

 8        A.   They were all handmade amplifiers.

 9        Q.   But if they're all using the same amplifier, then the settings

10     can only be manipulated once to either amplify or reduce the modulation.

11     Is that correct, sir?

12        A.   An amplifier may look the same from the outside, but there's a

13     two-way, three-way, four-way amplifier, which means the multiplication of

14     strength.  The amplifier has no function in terms of modulation.  It only

15     amplifies the signal.

16        Q.   Thank you, sir.  And we see here that the antennae in question --

17     pardon me, the devices in question had 150 and -- 150/18 megahertz

18     converters located on them, and could you explain for us what was the

19     purpose of these converters given the frequencies you were looking at

20     were in the range of 235 to 270 megahertz and 620 to 960 megahertz?

21        A.   I tried to explain a moment ago.  It says converter, and that's

22     its function.  They raised the signal to 18 megahertz and then it would

23     be converted to hearing frequencies, meaning down to 150.  That's why we

24     used the converters since we did not have professional military

25     equipment.

Page 13521

 1        Q.   Thank you.  And from this document we see that -- that two of the

 2     devices use the same UHER 2000 recorder.  Am I correct they both use the

 3     same one recorder?

 4        A.   If it's what's in the document, then it is so.  It was in

 5     February 1995.  Malfunctions occurred more frequently during the winter

 6     because of great cold and the balancing of voltage and because of such

 7     changes malfunctions occurred regularly, as I've explained.

 8        Q.   Are you familiar from your days in the JNA --

 9             MR. IVETIC:  We can get rid of this document.  I don't need it

10     any more.

11             JUDGE ORIE:  Can I ask one question?

12             MR. IVETIC:  Sure, go ahead.

13             JUDGE ORIE:  Witness, you said the converter raised a signal to

14     18 megahertz and then it would use -- then it would be converted to

15     hearing frequencies, meaning down to 150.  What exactly does this 150

16     stand for in terms of hearing frequencies?  One hundred and fifty is, I

17     take it, within the range of what you can hear.

18             THE WITNESS: [Interpretation] Kilohertz.  Kilohertz.

19             JUDGE ORIE:  Yes.  And you say that is within the range what a

20     human being can hear.

21             THE WITNESS: [Interpretation] Precisely.

22             JUDGE ORIE:  Thank you.

23             MR. IVETIC:

24        Q.   Sir, in your days with the JNA are you familiar with the

25     technique taught and utilised and referred to as operational masking?

Page 13522

 1        A.   That method is used to everyone, even to those who are not

 2     signalsmen.  Signalsmen, however, have to be trained, at least to some

 3     extent in that regard.

 4        Q.   And in relation to this method or technique that was used by

 5     everyone, including signalsmen, am I correct that for radio

 6     communications it meant that persons would oftentimes send false

 7     information with the aim of causing misinformation upon the enemy forces

 8     or perhaps fear among the enemy forces that would be intercepting those

 9     communications?

10        A.   It is all possible.

11        Q.   Thank you.  Now, sir, I want to cover a few more areas with you,

12     and first of all I want to put it to you that some people say that your

13     two stations operating the equipment that we have gone through could not

14     have intercepted all of the intercepts that you claim to have intercepted

15     but, rather, that they were given to you by some other entity, whether an

16     intelligence service of foreign countries, NATO, UNPROFOR, or somebody

17     else.  Can you tell us, is there any truth to that?

18        A.   People would say all sorts of things.  They said we couldn't, and

19     it was proven we could.  In order to prove something, one needs to carry

20     out an experiment.  Back in 1998 when people came, I offered to conduct

21     an experiment so that they could hear it for themselves.  No one from

22     anywhere -- no one ever gave us any kind of papers or documents ever.  If

23     you look at the documents, you can see for a while that there was only

24     one channel that was followed from one device and it happened from time

25     to time, but it is not difficult to ascertain or verify.

Page 13523

 1        Q.   Now, in relation to your unit, did -- did the unit or the

 2     revamped unit that became a different designation after 1995, did either

 3     of those have contacts with any NATO countries' intelligence organs

 4     during the time time-period 1995 until the notebooks were turned over to

 5     the Prosecutor of the Tribunal in 1998/2000?

 6        A.   I responsibly claim that the unit, while I was in command, had no

 7     contact with any troops or UNPROFOR forces except that on occasion

 8     UNPROFOR forces came to check the armaments at the facilities in

 9     intervals of between three and five months.  It depended.

10        Q.   Thank you.

11             JUDGE ORIE:  Mr. Ivetic, I'm looking at the clock.  We're close

12     to the point where we should take a break.

13             MR. IVETIC:  We should then, Your Honours.

14             JUDGE ORIE:  Yes.  Then before we do so, I have one final

15     question for you.  You earlier explained to me that 150 stood for 150

16     kilohertz, which was within the range of the human ear.  Now, thinking

17     back to my own secondary school time, but I don't know whether my

18     recollection is right, I seem to remember that I learned that the range

19     of the human ear is between 20 hertz and 20.000 hertz, that is, 20

20     kilohertz, which makes it difficult for me to understand, if I'm not

21     mistaken, how 150 kilohertz would be within the range of the human ear.

22             You remember there was the conversion.  It was 150-18 megahertz.

23     And you said the 150 stood for kilohertz within the human ear range.

24     Perhaps you could think about it during the break.

25             THE WITNESS: [Interpretation] There's no need.  It's not

Page 13524

 1     specified exactly in the document, but I also recall that the human ear

 2     ranges between certain figures in terms of kilohertz, although not every

 3     ear has the same frequency.  Some people react to one kilohertz, others

 4     at 1.5.  So that's the best range.  I can't recall this precisely.  Maybe

 5     this was decomposing the channels.  I don't know what the issue on hand

 6     is, Mr. President.  I may have been a bit hasty in my answer.

 7             JUDGE ORIE:  Thank you.  We turn into closed session, and then

 8     the witness can leave the courtroom, and we stay in closed session as

 9     well in order to allow him to re-enter the courtroom.

10                           [Closed session]

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20                           [Open session]

21             THE REGISTRAR:  We're in open session, Your Honours.

22             JUDGE ORIE:  Thank you, Madam Registrar.

23             MR. IVETIC:

24        Q.   Sir, I would like to now talk with you about some of the

25     transmittal frequencies.  Am I correct that both in the handwritten

Page 13525

 1     log-book entries and in the typed-up reports that would have been

 2     generated later, for each intercept the frequency that was being listened

 3     in on should have been recorded if the operatives were following standard

 4     operating procedure?

 5        A.   Yes, you're right.

 6        Q.   And now bear with me if this seems too simple, but I want to make

 7     it clear for everyone:  The frequency that a transmission is sent out

 8     from by the sender on the VRS side should correlate exactly to the same

 9     frequency that the receiver is listening in on and thus receives the

10     message whether it's a VRS intended receiver or an army of BiH intercept

11     receiver.

12        A.   The frequency of transmission by the VRS is fixed, and that is

13     the carrying signal, the vehicle signal.  I suppose I understand what you

14     want to ask me.  Are there any discrepancy between the frequency as

15     written down in the in the Army of Republika Srpska relative to the

16     frequency on which we were listening.  Is that what you mean?

17        Q.   I would ask it this way:  If one had the VRS tables or

18     information about the frequencies that were being used at the various

19     relay stations during the same time period, they should match up

20     identically to those that your unit in the army of BiH listened in and on

21     and recorded in our various reports and notebooks; isn't that correct?

22        A.   Generally, yes.

23        Q.   And can you confirm for me that the two posts of the -- the two

24     posts, the northern and the southern position that we've been talking

25     about, that they very rarely were able to intercept any communication

Page 13526

 1     purporting to have General Mladic as a direct participant?  Is that

 2     accurate?

 3        A.   From where I'm sitting, I can't say either yes or no, but from

 4     what I remember, and please don't take it as a cut and dry fact, from

 5     what I've read and what I think, General Mladic was on the line less

 6     frequently than the other commanding officers.

 7        Q.   Do you know if in relation to the events in Srebrenica July 1995,

 8     did your service intercept any intercepts dealing with General Mladic

 9     directly?

10        A.   I really don't know.  It would be much easier if I had all these

11     reports before me to read through or leaf through.  I could give you a

12     better answer.

13        Q.   Well, let's -- let's talk about the notebooks.  And to make sure

14     we're talking about the same notebooks, I'd like to call up number 4725

15     in e-court.

16             JUDGE ORIE:  While waiting for that, could I ask one question,

17     Witness.  You said that the person listening should listen to the same

18     frequency as the one sending.  That's what you confirmed.  Now, how

19     precise is that if someone is sending at, well, let's say at 96

20     megahertz, if I would tune in on 95.9 would I still hear some?  Is it a

21     range or is it a clearcut figure?

22             THE WITNESS: [Interpretation] It's the former.  It's a range.

23     Like you are scanning for a station, you start hearing it with a little

24     bit of noise and interference until you adjust it to the exact right

25     frequency.  It's like a motorway with many lanes.  On some of them there

Page 13527

 1     is traffic, on others there isn't.  That's it.

 2             JUDGE ORIE:  So the quality is best if the hear -- the person

 3     intercepting or hearing and the person sending are exactly on the same

 4     frequency, but outside that you could still catch whatever is said or

 5     played within certain limits.

 6             THE WITNESS: [Interpretation] Absolutely.

 7             JUDGE ORIE:  Thank you.

 8             Please proceed.

 9             MR. IVETIC:

10        Q.   And in terms of the bleed-over of the signal onto neighbouring

11     frequencies either above or below the transmittal frequency where there

12     would be some transmission with some static background noise or other

13     imperfections, can that be determined, that potential range that you're

14     talking about?  Are we talking about several megahertz, several hundred

15     megahertz, 50 megahertz, a difference there can be?  If you know.  If you

16     can answer; if not, we can move on.

17        A.   It's one thing to listen to a radio channel and quite another

18     thing to listen to a radio relay channel.  For example, the radio relay

19     device RRU 1 has only one working channel, and it's enough to adjust the

20     frequency where it's clearest and then we can listen very well.  The

21     radio relay device RRU 800 is of a different type.  In the documents you

22     write the carrying channel.  It has a certain range with a certain number

23     of channels below and other channels which have a jump of 100, 150

24     kilohertz.  For instance, in some places you will see written on the map

25     785.000 kilohertz, and the working channel is 784.650.  It's like a

Page 13528

 1     motorway with eight lanes.  In some lanes there are cars; in others there

 2     aren't any.  And the same in both directions.  And we set up our devices

 3     to jump the difference up and down by that width, depending on whether

 4     they work with 12, 8, or 24 channels.  So they -- they go across this

 5     range and stop at the channel where they find traffic.

 6        Q.   Thank you.  Now we have the picture in front of us, and we see

 7     here I believe several of the intercept notebooks that would have been

 8     generated by the units in question, and we see that on all of them they

 9     appear to be notebooks of the type that children would have used in

10     school during the relevant time period, and there are some -- some

11     sequential numbers written upon these in black marker, and in respect to

12     these numbers that are written upon these notebooks in black marker, the

13     sequential numbers that we see here, 97, 98, 99, et cetera, am I correct

14     that as far as these black marker numbers are given -- are concerned,

15     these were not originally put on the books in 1995, but, rather, were

16     generated and placed on the book by members of the unit together with

17     members of the Office of the Prosecutor of this Tribunal in 1998 when

18     these books were being handed over to the Tribunal.  Am I right about

19     that?

20        A.   Yes.  With all due respect, these large numbers are my handwork.

21             MR. IVETIC:  If we could tender this document as the next

22     available public exhibit number.

23             JUDGE ORIE:  Madam Registrar.

24             THE REGISTRAR:  Document 04725 receives number D312, Your

25     Honours.

Page 13529

 1             JUDGE ORIE:  And is admitted into evidence.

 2             MR. IVETIC:

 3        Q.   And in this case, sir, for the sake of --

 4             JUDGE ORIE:  Could I ask for one clarification.  You said the

 5     large numbers, I take it the handwritten numbers, is your handwork.  When

 6     did you put those numbers on those notebooks?

 7             THE WITNESS: [Interpretation] We placed these numbers when we

 8     were handing over these notebooks to the OTP.  I believe in 1998.

 9             JUDGE ORIE:  Thank you.

10             Please proceed, Mr. Ivetic.

11             MR. IVETIC:  Thank you.

12        Q.   And the sequence of numbers -- strike that.  If a notebook were

13     to have disappeared or a new notebook were added to the collection at any

14     point in time from 1995 to 1998, we would not be able to know that

15     relying upon the sequential numbers written in black marker on the

16     covers.  Is that accurate?

17        A.   I've already said these numbers were written in 1998 when they

18     took them -- when we took them out of the safe book -- safe box to record

19     this documentation.

20        Q.   And the question I have is what about the notebooks that were

21     only given to the Tribunal in 1999 and 2000?  Were those numbers written

22     in 1998 or in 1999 and 2000?

23        A.   I believe we always wrote it at that moment, because these are

24     simply ordinal numbers of the documents that were handed over.  The

25     numbers were written at the moment when they were handed over.

Page 13530

 1             MR. IVETIC:  And if we can have number 4726 up in e-court, and

 2     that -- to be on the safe side, perhaps we shouldn't broadcast that.  I'm

 3     not sure if there's any information about the entity or the location on

 4     the cover page, so we should probably not broadcast.

 5        Q.   And, sir, now we have a close-up of books number 232 and 231 from

 6     the set.  232 on the left I think we saw yesterday with the bumblebee on

 7     the cover, and the other with the -- some sort of creature in overalls.

 8     The writing that is written at the top of the one on the left and on the

 9     top right on the one on the right, when would that have been input into

10     the notebooks?

11        A.   These notes in the top corner, apart from the white one, were

12     written at the time when the notebook started to be used.  So at the top

13     we see the type of device, the type of communication, the date.  On the

14     left handbook we see when the note was started and when it was concluded.

15     So this was written in 1995 at the work station in one of the locations.

16             The same goes for the other one on the right.  We see when it was

17     opened, 26 June, finished on 11 -- I can't see the rest.  So that was

18     written in 1995.

19        Q.   And would it have been standard procedure to mark as we see on

20     the left one it identifies the ICR 100 receiver with the TS 450.  I

21     believe that would have been the -- either the converter or recording

22     device.  I don't have the notes in front of me.  And the RRU 800.  Would

23     that have been standard procedure to mark what particular device was the

24     source for the particular notebook?

25        A.   That should be the usual procedure.  We always insisted on that.

Page 13531

 1     However, people are human.  They make mistakes.  Somebody forgets to

 2     write it down.  But it's easy by looking at the frequency and the other

 3     information we would know easily during the monitoring who wrote what.

 4        Q.   Well, if we look at the one on the right-hand side with the

 5     dinosaur riding a bicycle, it only seems to list the number 3 and then a

 6     RRU-8.  Does that provide enough information for you to identify from

 7     which particular monitoring post at either of the two locations this

 8     particular notebook would have originated from?

 9        A.   Well, for us at that moment it was enough, because inside we had

10     entries specifying the signal, the operator, et cetera.

11             MR. IVETIC:  Your Honours, I would tender this as the next

12     exhibit, and I believe it could be a public exhibit number.  I've looked

13     now at the two covers, and I don't believe there's any information that

14     identifies the source.

15             JUDGE ORIE:  Madam Registrar.

16             THE REGISTRAR:  Document 04726 receives number D313, Your

17     Honours.

18             JUDGE ORIE:  D313 is admitted into.

19             MR. IVETIC:  One last picture of the notebooks I'd like to go

20     through is number 25534, and this is under seal, so please don't

21     broadcast the same.

22        Q.   And, sir, I believe this is the notebook numbered 84 and appears

23     to have a bear or a raccoon, I can't tell, on the cover, and has here a

24     stamp from the manufacturer, that is to say, pre-existing on the cover of

25     this book of I GEN 2001.  And this is something that you were asked about

Page 13532

 1     during the Tolimir trial with the suggestion that this book dated from

 2     2001, and you stated that you don't have any explanation or information

 3     for this.  Is that still -- is that right, first of all?

 4        A.   Well, somebody insisted that these were produced in 1991.  We

 5     filled them in in 1995 and handed them over in 1998, and this message

 6     typed inside the notebook they said had nothing to do with the date of

 7     when the notebook was generated.

 8             JUDGE ORIE:  Could I first ask the witness.  You said somebody

 9     insisted that these were produced in and what year did you then mention?

10             THE WITNESS: [Interpretation] They said the notebooks were

11     produced at a time based on this date here, in 2001.  That's what they

12     insisted on in -- in a prior case.

13             JUDGE ORIE:  Yes.  Thank you.

14             Ms. Lee, this may deal with the matter you wanted to raise.

15             Please proceed, Mr. Ivetic.

16             MR. IVETIC:  Thank you.

17        Q.   Now, sir, now I'd like to move ahead, and I hope we can get this

18     in in the time that we have left, but I have to ask you:  Have you ever

19     accepted payment from the Office of the Prosecutor of this Tribunal to

20     assist them to challenge and rebut Defence theories on the very same

21     technologies and intercepts that you have testified about this week?

22        A.   I did receive something to cover regular expenses.  Somebody, I

23     can't remember the name, made an analysis where he presented his theory

24     about the feasibility or unfeasibility of monitoring communications.

25     They called me up.  I did not feel for a moment as any kind of assistant

Page 13533

 1     or advisor.  I was just asked to sit down with my colleagues, study it,

 2     and provide our opinion.  We did not get anything special.  Just our

 3     expenses were paid.  It was not more than 1500 Deutschmark.  Just my

 4     expenses while I was here.

 5             MR. IVETIC:  If we could tender the document that is on the

 6     screen now before moving onto the next document.  I'd forgotten to do

 7     that.

 8             JUDGE ORIE:  Madam Registrar, the number for the present document

 9     will be.

10             THE REGISTRAR:  Document 25534 --

11             MR. IVETIC:  Under seal.

12             JUDGE ORIE:  One second.

13             Ms. Lee.

14             MS. LEE:  Well, I have an objection with this document in the

15     manner in which it was portrayed.

16             JUDGE ORIE:  Well, how it was portrayed.  Do you have any

17     objection against admission?  The way in which --

18             MS. LEE:  No.

19             JUDGE ORIE:  -- it is portrayed is --

20             MS. LEE:  No.

21             JUDGE ORIE:  -- how Mr. Ivetic presents it and the description

22     will be given by Madam Registrar in neutral terms.

23             MS. LEE:  The --

24             JUDGE ORIE:  And if there's any dispute about how it should be

25     portrayed, we can deal with that.  The matter now is objections against

Page 13534

 1     admission, yes or no.

 2             MS. LEE:  Well --

 3             JUDGE ORIE:  If you want to consult with Mr. McCloskey.

 4             MR. IVETIC:  If I can assist, it's a document on their list, I

 5     believe, and the description is one that they provided, Your Honours.

 6             JUDGE ORIE:  If it's inaccurate, it will being corrected anyhow.

 7             MS. LEE:  This is not on our exhibit list.

 8             JUDGE ORIE:  Apparently it is.

 9             MS. LEE:  Apparently it is.  I apologise.

10             MR. IVETIC:  And it should be under seal.  I apologise, I've

11     forgotten that.

12             JUDGE ORIE:  No objections --

13             MS. LEE:  No objections.  [Overlapping speakers].

14             JUDGE ORIE:  -- I then take it, after these consultations.

15             THE REGISTRAR:  Document 25534 receives number D314, Your

16     Honours.

17             JUDGE ORIE:  And is admitted under seal.

18             Mr. Ivetic, we are at the point where we have to adjourn.

19             MR. IVETIC:  Okay.  We could take up then in the morning, I --

20     the question would take probably two minutes, three minutes, this

21     particular question with this document.

22             JUDGE ORIE:  And would that be then your last question?

23             MR. IVETIC:  No, it would not.  I have one other area.  Yeah.

24             JUDGE ORIE:  Then we'll hear that question tomorrow.

25             May I take it that you'll finish in the first session tomorrow?

Page 13535

 1             MR. IVETIC:  Absolutely.  It won't even take the full first

 2     session.

 3             JUDGE ORIE:  Thank you for that.

 4                           [Trial Chamber confers]

 5             JUDGE ORIE:  Could you already tell us, Ms. Lee, how much time

 6     you would need for in re-examination including all the megahertz and

 7     gigahertz.

 8             MS. LEE:  At this moment, I would like to say around 45 minutes.

 9             JUDGE ORIE:  Around 45 minutes.

10             We'll adjourn for the day.  Witness, I'd like to instruct you

11     that you should not speak or communicate in whatever way - being an

12     expert in communications, you certainly will understand what I mean - in

13     no way to communicate with whomever about your testimony, whether already

14     given or whether still to be given, and we'd like to see you back

15     tomorrow morning at 9.30, and we'll conclude your testimony tomorrow

16     morning.

17             We already formally adjourn in open session, and I inform

18     everyone that we'll resume tomorrow, Friday the 20th of June, in this

19     same Courtroom I at 9.30 in the morning, and we -- before really

20     adjourning we go into closed session so as to allow the witness to leave

21     the courtroom.  We turn into closed session.

22                           [Closed session]

23   (redacted)

24   (redacted)

25   (redacted)

Page 13536

 1                           --- Whereupon the hearing adjourned at 2.17 p.m.,

 2                           to be reconvened on Friday, the 28th day

 3                           of June, 2013, at 9.30 a.m.