Tribunal Criminal Tribunal for the Former Yugoslavia

Page 10257

 1                           Monday, 1 March 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness takes the stand]

 5                           --- Upon commencing at 2.20 p.m.

 6             JUDGE MOLOTO:  Good afternoon to everyone in and around the

 7     courtroom.

 8             Mr. Registrar, would you please call the case.

 9             THE REGISTRAR:  Good afternoon, Your Honours.  Good afternoon to

10     everyone in and around the courtroom.  This is case number IT-04-81-T,

11     The Prosecutor versus Momcilo Perisic.

12             JUDGE MOLOTO:  Thank you so much.

13             Could we have the appearances for today, starting with the

14     Prosecution, please.

15             MR. SAXON:  Good afternoon, Your Honours.  Dan Saxon,

16     Barney Thomas, and Ms. Carmela Javier for the Prosecution.

17             JUDGE MOLOTO:  Thank you very much, Mr. Saxon.

18             And for the Defence.

19             MR. LUKIC: [Interpretation] Good afternoon, Your Honours good

20     afternoon to everyone in the courtroom.  I'm Novak Lukic, and

21     Gregor Guy-Smith, Tina Drolec, and Boris Zorko are part of the team

22     representing General Perisic with me here today.

23             JUDGE MOLOTO:  Thank you so much, Mr. Lukic.

24             Good afternoon, Mr. Simic.

25             THE WITNESS: [Interpretation] Good afternoon, Your Honours.  Good

Page 10258

 1     afternoon to everyone in the courtroom.

 2             JUDGE MOLOTO:  Thank you.  I hope you had a restful weekend and

 3     ready to move this afternoon.

 4             Just to remind you, that you are still bound by the declaration

 5     you made at the beginning of your testimony to tell the truth, the whole

 6     truth, and nothing else but the truth.

 7             Mr. Saxon.

 8             MR. SAXON:  Thank you, Your Honour.

 9                           WITNESS:  MIODRAG SIMIC [Resumed]

10                           [Witness answered through interpreter]

11                           Cross-examination by Mr. Saxon: [Continued]

12        Q.   And, good afternoon, once again, Mr. Simic.

13             MR. SAXON:  Your Honours, we are still within the realm of what

14     is now Prosecution 65 ter XN-132, which is -- falls within the term of

15     art "fresh evidence," and that's where we will probably continue for a

16     large part of this particular session.

17             MR. GUY-SMITH:  And I believe we remain within the same

18     discussion as regards fresh evidence, which is being offered for purposes

19     of impeachment only, which is the reason why I'm asking the question --

20             JUDGE MOLOTO:  It doesn't have to be stated every time we talk

21     about it Mr. Guy-Smith.  Once it has been stated that it is tendered for

22     purposes of impeachment only --

23             MR. GUY-SMITH:  Perfect.

24             JUDGE MOLOTO:  -- that's enough.

25             Yes, Mr. Saxon.

Page 10259

 1             MR. SAXON:  Yeah, I think there are certain things that don't

 2     always have to be mentioned at certain times, but be that as it may.

 3             MR. GUY-SMITH:  Thank you, Your Honour.

 4             JUDGE MOLOTO:  You're welcome.

 5             MR. SAXON:

 6        Q.   I am -- we need the second Drina binder to be provided to

 7     Mr. Simic.

 8             And for now, I am going to skip tab 9.

 9             And, Mr. Simic, if you could turn to tab 10 in your binder,

10     please.  It's page 33 in e-court.

11             MR. SAXON:  If I could just have a moment, Your Honour.

12                           [Prosecution counsel confer]

13             MR. SAXON:  So we should now be in seeing in XN-1 --

14             THE INTERPRETER:  Microphone, please.

15             MR. SAXON:  We should now be seeing XN-132, e-court - hopefully -

16     page 33.

17        Q.   And, General Simic, if we can just focus on the first page,

18     please.  We see "People's Defence, state secret" at the top, the word

19     "Drina," and then this says "copy number 1," does it not?

20        A.   That is correct.

21        Q.   And this is an excerpt from the directive on the use of the army

22     of Republika Srpska, is that right, is that what the title says in the

23     middle of the page?

24        A.   Yes.

25        Q.   It's dated December 1993.  The bottom of the page we see the

Page 10260

 1     stamp of the VRS Main Staff.  It says "copy number 1" at the top.  Is

 2     that because the -- this was found -- this particular document was -- was

 3     found in the possession of -- or came from the binder of the Drina Corps.

 4     So would the original stay with the VRS Main Staff?

 5        A.   The question is quite unclear to me.  It's unclear to add to it.

 6     I'm being pointed -- connected with the Drina Corps, and I'm seeing the

 7     cover page which states excerpt from the directives for the use of the

 8     army of Republika Srpska.

 9             So I'm not sure what this is.

10        Q.   My mistake, General, if my question was wasn't clear.  This came

11     from a binder or folder marked "Drina Corps."  This is what we looked at

12     this last week.

13             My question for you, sir, is:  Copy number 1, can you explain

14     what that means?

15        A.   I said that documents are done in two copies.  One copy is kept

16     for distribution, and the other one should go to the command which should

17     carry out the task.

18        Q.   Okay.  And if you turn to the last page, General --

19             MR. LUKIC:  Excuse me, Your Honour.

20             JUDGE MOLOTO:  Yes, Mr. Lukic.

21             MR. LUKIC: [Interpretation] Excuse me, Your Honours, I'm not sure

22     that the interpretation, the witness said for the -- for the person who

23     is working it out.  It's not distribution.  Perhaps the interpreters

24     could explain.

25             Perhaps the witness could explain what he means exactly by this

Page 10261

 1     term "razradjivac" because this term is quite specific.

 2             JUDGE MOLOTO:  Can you help us, Mr. Saxon.

 3             MR. SAXON:

 4        Q.   Perhaps the second part of your last response requires a bit more

 5     explanation, Mr. Simic.  You said that one copy is kept for distribution.

 6     And the other one should go to the command which should carry out the

 7     task.

 8             So does this extra extract that we see in front of us, is this a

 9     copy sent to a particular command so that the task is carried out?

10        A.   Sir, Mr. Prosecutor, this document was developed in the

11     Main Staff of the army of Republika Srpska, and one copy remains at the

12     Main Staff, and the second copy is sent to the subordinates for the

13     implementation of the assignment.

14             Last time, I used the term razradjivac meaning the person who

15     developed this document.

16             MR. SAXON:  Does that satisfy Your Honour and Mr. Lukic?  I see

17     him nodding his head.  Very well.

18             JUDGE MOLOTO:  I have nothing to be satisfied with.

19             MR. SAXON:  I'm glad then, Your Honour.

20             And if we can please go to page 49 in e-court.

21        Q.   We see when the document should be implemented by, the 28th of

22     December, 1993, and signed by Commander Ratko Mladic, and the stamp of

23     the VRS Main Staff.

24             Do you see that, General?

25        A.   Absolutely.

Page 10262

 1        Q.   Okay.  Now, if we can then turn to page 50 in e-court.  And if

 2     you could turn to the next tab in your binder, which, I believe, is a

 3     black and white copy.

 4             MR. SAXON:  And on e-court, will see, Your Honours, it's not so

 5     easy to read.  I have brought colour hard copies, one of which I have

 6     given already to the Defence.  If could I ask the usher's assistance,

 7     please, to give a copy to Mr. Lukic.  And I've got three copies for the

 8     Bench as well, to make it easier for the Bench to follow along.

 9             Mr. Lukic already has his?  Yes.

10             I'm sorry, one for the witness and three for the Judges.

11             I have an additional copy if the Chamber or the Chamber's legal

12     officer would like one, Your Honour, I'm in your hands.  I see the legal

13     officer nodding, so there we are.  And if we --

14             MR. LUKIC: [Interpretation] There is just one copy.  But if there

15     is one, a spare one, perhaps it would be good to provide one for

16     General Perisic who was not able to see that.

17             MR. SAXON:  Well, now I don't have any additional copies.

18             MR. LUKIC: [Interpretation] It's all right, never mind.  We will

19     look at it together at the break.

20             MR. SAXON:  All right.  Next time I will bring at least one more

21     copy.

22        Q.   General Simic, you will see this is a map.  What does it say in

23     the middle at the top, please?

24        A.   Sir, it states:  Excerpt from the decision on the use of the army

25     of Republika Srpska.

Page 10263

 1        Q.   We see this map has been signed and approved by Ratko Mladic in

 2     the upper left-hand corner.  And in the bottom right-hand corner, we see

 3     that it's been signed by General Milovanovic.  Is that correct?

 4        A.   Correct.  To be precise, I just would like that add in the upper

 5     left-hand corner it states, Approved by the commander, Ratko Mladic.  And

 6     in the right hand bottom corner, Processed by the Chief of Staff,

 7     Manojlo Milovanovic.  This is essential in all our correspondence and

 8     working through of a document.  I'm thinking about the procedure for

 9     documents in the Army of Yugoslavia.  And they adopted the same method of

10     work, according to the directions from the former JNA.  We continued to

11     apply the same instructions until we developed new -- a new set of

12     instructions.

13        Q.   Thank you for that, General Simic.

14             And remaining with the signature of General Milovanovic in the

15     bottom right-hand corner, you mention that this shows it has been

16     processed by General Milovanovic.  By "processed," would it be fair to

17     say that General Milovanovic signed off on the final version of this map

18     that was forwarded to General Mladic for his approval?

19        A.   The final draft, yes.

20        Q.   And approximately how many men --

21             THE INTERPRETER:  Microphone, please.

22             MR. SAXON:

23        Q.   Approximately how many officers get involved in the drafting, in

24     the production of a map like this, for a directive like Drina?

25             JUDGE MOLOTO:  Yes, Mr. Lukic.

Page 10264

 1             MR. LUKIC: [Interpretation] Well, just to avoid the objection

 2     that the witness was speculating, I would like more precision when a

 3     question of this type is being put.  Either is how many people would be

 4     -- a project like this where he worked, or in principle how many people

 5     would be employed on a project like this.

 6             This is just out of caution so that the witness would not be put

 7     the position to speculate.

 8             MR. SAXON:

 9        Q.   Mr. Simic, I don't want to you speculate.  But in your knowledge

10     and experience, and on Friday, you talked about particular documents that

11     required the input of a number of officers.  And I'm just wondering,

12     whether, for example, pursuant to your knowledge and experience, does a

13     map like this take the input of one or two officers or more?

14        A.   Sir, all that I'm telling you, you're asking me about the

15     documents of the army of Republika Srpska and I'm answering on the basis

16     of my experience in the Army of Yugoslavia.  But, in view of the fact

17     that we completed the same schools, I assume that the same practice was

18     continued.  And let me answer the question specifically.  When this type

19     of key documents are drafted, such as a decision by the Main Staff, the

20     whole staff and all the assistants and -- of the commander of the

21     Main Staff and other assistants are involved in the drafting of such a

22     document.  But I would be able to state that with full responsibility

23     when we're talking about documents such as this map.

24        Q.   Very well.  And can you tell us, please, in summary form, what

25     does -- what does this map depict?  What are we seeing here?

Page 10265

 1        A.   This map depicts the concept or decision of the Main Staff about

 2     the use of the army of Republika Srpska over a longer period of the war.

 3     If you look in the lower left-hand corner, it states "key," and then

 4     below that it says first stage of the operation and second phase of the

 5     operation.  The operations are carried out over a longer period of time.

 6        Q.   We see on this map -- first of all, we see some different

 7     colours.  We see some areas that are shaded in sort of a light -- a

 8     yellowish light green colour; we see broken red lines; up towards the top

 9     of the document, we appear to see some broken black lines.

10             Can you explain what these different colours and lines indicate?

11        A.   Sir, I've read the key with a specific purpose.

12             In the first phase, there is one sub-colour, which corresponds to

13     the sub-colour on the map.  Then we have the second phase, with another

14     sub-colour, which corresponds to the activities of the army of

15     Republika Srpska in this second face.  That is exactly what this marks.

16             These broken lines that you asked about with an arrow mean that

17     the forces of the army of Republika Srpska should attain those positions

18     at that particular stage or phase of the operation.

19        Q.   All right.  And because many of us in this room are unable to

20     read this document in your language, when you refer to the key in the

21     bottom left-hand side, indicating the two phases and the colour, which

22     colour refers to the first phase, and which colour refers to the second

23     phase, please?

24        A.   The yellow colour represents the first phase, and this

25     reddish-orange colour would stand for the second phase.  But let us be

Page 10266

 1     clear here:  All the units do not have to take part in each of the

 2     phases.  Some of the units can participate in both phases while some

 3     units can only participate in one of the phases.

 4        Q.   Speaking of different units depicted on this map, in the middle

 5     of the map, a little bit below the halfway point, we see the word

 6     "Sarajevo."

 7             Which units are depicted around Sarajevo?

 8             MR. SAXON:  We have another map for General Perisic.  I'm

 9     grateful for Ms. Javier for organised that.

10             THE WITNESS: [Interpretation] Sir, it's hard for me to read this.

11     This is too small for me to be able to read it.

12             MR. SAXON:

13        Q.   If we see what appears to be a flag on this map, and there appear

14     to be a number of flags, what -- what does the flag or a banner indicate?

15        A.   Each flag has the unit number in it, and it stands for the

16     command post of that particular unit.  And as for the previous thing that

17     you asked me about, I've read here the first Herzegovina Infantry

18     Brigade.  I made a special effort to be able to read that.  If you notice

19     the rectangle is there, and it contains the -- information about the

20     command post of each of the units.

21        Q.   And, General, are you able to see -- well, I think that is too

22     small for everyone.

23             Are you able to see the enclave of Gorazde on this map, on the

24     right-hand side, going towards the bottom?

25        A.   Certainly.

Page 10267

 1        Q.   So if the greenish-yellow colour indicates the positions of units

 2     during the first phase, and then here we see some red lines with arrows

 3     towards the town of Gorazde, does that indicate that essentially -- the

 4     army of Republika Srpska forces will have the objective of -- of moving

 5     closer around Gorazde?  Is that how we would read that?

 6        A.   Based on the map, yes.

 7        Q.   Okay.  In the -- in the centre -- we see a stamp.

 8             General Simic, could you turn your focus to the upper right-hand

 9     corner, please.  And can you tell us what is written in the top

10     right-hand corner in large letters in the Cyrillic alphabet.

11        A.   Mr. Prosecutor, sir, the upper right-hand corner reads:

12             "All People's Defence, state secret, quotation marks, Drina, R

13     attachment, number 1, copy number 1."

14        Q.   Very well.  Okay.  I'd like to leave this map now.

15             And if we could please turn to the next page in e-court, which is

16     51.  And if you could turn to the next page in your binder,

17     General Simic.

18             General Simic, you'll see at the top it says:

19             "People's Defence, state secret, Drina, attachment 6, copy number

20     1?"

21             And then in the middle, I believe it says:

22             "Extract from the plan of communications of the VRS Main Staff

23     for the Drina Corps command."

24             I'm sorry, it's tab 12.

25        A.   It's a little different here.  At least the order is, but I think

Page 10268

 1     I manage to the find my way around.

 2        Q.   Okay.  And tab 12, the title of this document is:  Extract from

 3     the plan of communication of the VRS Main Staff for Drina Corps command,

 4     does it not?  Is that correct?

 5        A.   That's right.

 6        Q.   We see at the bottom of that page, December 1993.  And then the

 7     seal of the Drina Corps Command.

 8             MR. SAXON:  Could we go to the next page, please -- excuse me, we

 9     saw the seal of the VRS Main Staff.  I don't want to misspeak.

10        Q.   And if you take a look at this page, General Simic, this is a

11     list of documents for communication from the VRS Main Staff to the

12     Drina Corps Command.  Isn't that -- is that correct?  Am I reading it

13     correctly?

14        A.   A list of documents of the communications plan delivered to the

15     Drina Corps Command.

16        Q.   And we see in the upper right-hand corner:

17             "People's Defence, state secret, Drina, attachment 6, copy

18     number 1."

19             And if you could move your eyes down this list to item number 9.

20             Item number 9 says:

21             "Secret call-signs for Command Staffs, units, and institutions."

22             Is that right?

23        A.   That's right.  Code-names is what we used to call them.

24        Q.   All right.  And we're going to look at that in a moment.

25             We see the seal of the VRS Main Staff at the bottom.

Page 10269

 1             MR. SAXON:  Could we go to the next page, please.

 2        Q.   Again, we see Drina at the top, "copy number 1."  And this is an

 3     order for communications, is it not?

 4        A.   That's right.

 5        Q.   And if you could -- if we could move forward two more pages,

 6     please, and scroll down to the bottom of this page, please, there we see

 7     that this order was signed by General Milovanovic.  Are you with me?

 8        A.   Yes.

 9        Q.   And the other signature on -- on the page, on the bottom, on the

10     left-hand side, Radomir Prole.

11             In what capacity was he signing this document, if you know?

12        A.   Sir, Mr. Prosecutor, it reads chief of communications,

13     Colonel Radomir Prole.  He was chief of communications in the Main Staff

14     of the army of Republika Srpska.  That's what it means.

15        Q.   So Colonel Prole would have the task of working on such a plan of

16     communication; is that right?

17        A.   Well, yes.  I -- I never disputed that.  The chiefs of branches

18     would normally be busy working on such documents, each within their own

19     speciality field.

20        Q.   Thank you.

21             MR. SAXON:  Can we move to the next page, please.

22        Q.   The next page is a chart of radio communications from the

23     Main Staff of the VRS.  And if we scroll down, we see the stamp on the

24     bottom.

25             Can we go to the next page, please.

Page 10270

 1             On the next page, we see the overview of the time of changing

 2     frequencies.  Is that correct, General?

 3        A.   You're asking me a question that is too technical for me to

 4     explain.

 5             I'm unable to confirm this with certainty.  I see that there are

 6     devices here with varying degrees of certainty, depending on the command

 7     they belonged to.

 8        Q.   General I'm very, very sorry, could you move one page forward,

 9     please.  I'd like to focus on this page for the time being.  And please

10     correct me if I'm wrong, in the centre, this -- we see a chart.  And this

11     chart or table represents the -- the times for which radio frequencies

12     should be changed.  Is that right?

13        A.   Sir, that is right.  But if you're trying to tie this up with

14     your previous question, the interpretation I got was the power of these

15     devices, and that is what I find myself unable to confirm.  Nevertheless

16     it is quite true that the times were noted here when frequencies were

17     switched or changed, in order to make it impossible for the enemy to

18     monitor our radio communications.

19        Q.   Very well.  Thank you.

20             MR. SAXON:  Could we turn to the next page, please.

21        Q.   Here, again, we see a -- a chart depicting the analogue radio

22     relay communications.  We see in the upper right-hand corner:

23             "People's Defence, state secret, R, Drina, attachment number 2,

24     copy number 1."

25             And again we've seen a similar document previously so this

Page 10271

 1     particular document shows the connections between different units and --

 2     or -- and the different radio relay stations that they use.  Is that

 3     right?

 4        A.   That's right.  But there is one thing I need to set straight.

 5             We were looking at that previous chart or diagram which

 6     represented the radio communications, and this is now the radio relay

 7     communications of the VRS.

 8        Q.   Okay.  Thank you.  Thank you.

 9             MR. SAXON:  If we could turn to the next page, please.

10        Q.   General Simic, this is a chart of encrypted communications, is it

11     not?

12        A.   Yes, that's right.

13        Q.   In the middle, at the -- at the top, we see a seal.  And then

14     below that we see a circle with a banner, a flag, which stands for the

15     Drina Corps; do you see that?

16        A.   Yes.

17        Q.   On the upper left-hand side, we see the words "Belgrade" with a

18     flag attached to it.  And then on the upper right-hand side, we see a

19     circle with the word "Pale" with a flag, "SRK."  That would be the

20     Sarajevo Romanija Corps, would it not?

21        A.   Indeed.

22        Q.   Are you able to tell us in -- actually, let me take a moment,

23     please.

24             We also see on the left-hand side, left from the centre, a

25     rectangle with the word Han Pijesak.  Are you able to tell us in general

Page 10272

 1     terms what kind of information is depicted on this chart?

 2        A.   This chart shows the radio relay communications for which

 3     encrypted channels were used.

 4        Q.   Okay.  So this chart actually indicates the encrypted channels

 5     themselves?  Is that what we see here?

 6        A.   From a technical perspective, you can see the protected or

 7     encrypted channels used for the kind of communication that needed

 8     shielding from any enemy de-scrambling equipment.  So that's what I mean

 9     when I say an encrypted channel.

10        Q.   Okay.  Thank you for that.

11             MR. SAXON:  Can we move to the next page, please.

12        Q.   We see on this page, on the upper left-hand side, some words, and

13     I believe this says - please, correct me, General, if I'm wrong, but I

14     believe it says, Cryptological information from the Main Staff of the VRS

15     for the Drina Corps.

16             Am I correct in that?

17        A.   Certainly.

18        Q.   All right.  And we see, again, the word "Drina" on the right

19     side, a stamp of the Main Staff in the middle.

20             MR. SAXON:  Can we go to the next page, please.

21        Q.   General, this document is entitled:  A -- an extract of an

22     overview of special documents for encrypted communications for the

23     Drina Corps; is that correct?

24        A.   Correct.

25        Q.   All right.  Again, we see the VRS Main Staff stamp.

Page 10273

 1             Could you turn to the next page, please.

 2             General Simic, on this page, bears ERN 04336632, it says:

 3     "Overview of secret call-signs."

 4             Is that right?  This is page 62 in the e-court.

 5             Says:  "Overview of secret call-signs."

 6             Correct?

 7        A.   Correct.

 8        Q.   And you see in item 1, the first item is the General Staff of the

 9     VJ command post; is that right?

10        A.   Yes.

11        Q.   And we see its call-sign "Alan," to the right.

12             Item 2 we see General Staff of the VJ, rear command post; is that

13     correct?

14        A.   Yes.

15        Q.   And we see its call-sign to the right, "Golija."

16             What do the two columns on the right-hand side depict?

17        A.   Column number 4, depicts the situation in which communications

18     equipment is used to establish communication.  By virtue of a line of

19     communication being established, it doesn't mean that this same person is

20     normally at one end of this conversation.  Rather, this is a code-name

21     that this person uses or a password, so they need to say 7590, and then

22     the other side knows that they've just got through to the right person.

23        Q.   Okay.  Item number 3, that refers to the first --

24             JUDGE MOLOTO:  Sorry, Mr. Saxon.  Do we now know what the other

25     column talks about?  You asked about the two last columns, now he's put

Page 10274

 1     an answer to one.

 2             MR. SAXON:  Thank you for your intervention, Your Honour.

 3        Q.   How about column number 5?

 4        A.   That's what I said.  This is my ID caller number, which I used to

 5     identify myself to whoever happens to be at the other end of the

 6     communication line.

 7        Q.   Let me ask another question, General.

 8             You described column number 4 as depicting the situation in which

 9     communications equipment is used to establish communication.

10             Can you explain that a little bit, please.  I think those of us

11     who are following in English are having a hard time understanding.

12        A.   I can't get more technical than this, since I'm no expert on

13     communications equipment.  What I'm telling you is my general knowledge,

14     and I'm afraid that's as far as can I go.

15        Q.   All right.

16             JUDGE MOLOTO:  Yes, Mr. Lukic.

17             MR. LUKIC: [Interpretation] What you find unclear and which

18     follows from the witness's answer, perhaps because the permutation, it

19     might be good for the witness to read number 4 and number 5, and then the

20     interpreters can do their job, by which time I think you will have

21     understood what the columns mean exactly.

22             MR. SAXON:  All right.  Thank you, Mr. Lukic.

23        Q.   If could you read the title of column 4, General Simic, out loud,

24     please.

25        A.   Mr. Prosecutor, column number 4 reads abbreviated KFHX, and then

Page 10275

 1     number 5, 7590.

 2        Q.   Mr. Simic, it's my fault because my question was not clear.

 3             Could you read the title of number 4, which is just above the

 4     number 4, and the title of number 5, which is just above the number 5 at

 5     the top there.

 6        A.   Column 5, right above it, telegraph communications, call-sign,

 7     telegraph switchboard -- telegraph station.

 8        Q.   And that's actually at the top of column 4; right?

 9        A.   That's right.

10        Q.   Okay.

11        A.   Column 5, it reads:  "ID information."  And then in the brackets,

12     "(plate number)."

13        Q.   Very well.  Item 3 on this list refers to the 1st Army of the VJ;

14     is that correct?

15        A.   Yes.

16        Q.   Item 4, the 2nd Army?

17        A.   That's right.

18        Q.   Item 5, the 3rd Army of the VJ?

19        A.   That's right.

20        Q.   Item 6, the air force and anti-aircraft defence of the VJ?

21        A.   Correct.

22        Q.   Item 7, the navy?

23        A.   Yes.

24        Q.   And if you could focus your attention to item number 18 - if we

25     could scroll down, please, on e-court - item 18, for example, refers to

Page 10276

 1     the Pristina Corps of the Army of Yugoslavia; right?

 2        A.   Yes.

 3        Q.   So we see that this document went down to the corps level of the

 4     VJ.

 5             MR. SAXON:  Can we turn the page, please.  Go to the next page in

 6     e-court, please.  And can we focus on the top.

 7        Q.   If you take a look at the top of this page, General Simic,

 8     item 22, that refers to the Main Staff of the Army of Serbian Krajina,

 9     does it not?

10        A.   Yes.

11        Q.   And below that, item 23, reflects the call-signs of the

12     Government of the Republic of Serbian Krajina; is that correct?

13        A.   That's what it says.

14        Q.   Very well.  I'm going to move on from this document now -- from

15     this -- those pages now.

16             And, General, if you could turn to tab 13, please.

17             MR. SAXON:  And if we could see on e-court, page 71 of this

18     document.

19        Q.   General, this is a VRS Main Staff plan for security measures, is

20     it not?

21        A.   This is a plan for security measures of the VRS for both defence

22     and attack, to be perfectly specific.

23        Q.   And it has been approved by General Mladic; isn't that right?

24        A.   Yes, that's right.

25        Q.   Can we turn to tab 14, General, and go forward two more pages in

Page 10277

 1     e-court, page 73 in e-court.  This document is entitled; anti-electronic

 2     combat, am I right?

 3        A.   Absolutely.

 4        Q.   We see the word "Drina" at the top, attachment 8, copy number 7.

 5     What is the purpose of this document?  Can you tell us.

 6        A.   The purpose of each document is to protect ourselves from any

 7     electronic operations by the enemy.  The header itself reads:

 8     "Anti-electronic combat."

 9             That means keeping the enemy out of our electronic

10     communications.

11        Q.   Can you turn to the next tab, General.  And this would be page 76

12     in e-court.

13             General, at the top of this page, it says:  "Plan of electronic

14     warfare."

15             How does this document relate to the previous document?

16        A.   These are two compatible documents.  One is saying that I should

17     protect myself from any electronic action by the enemy; and the other is

18     saying exactly the on opposite, that I should take some electronic action

19     against their devices.

20        Q.   This document that's in front of us now entitled:  "Plan for

21     electronic warfare."  Does that mean that this document would describe

22     how the army of Republika Srpska is going to jam the electronic

23     communications of the enemy, putting it in layman's terms?

24        A.   Are you most certainly right.

25        Q.   Okay.  If we could move to the next tab, General, number 16,

Page 10278

 1     which is page 80 in e-court.

 2             This document, General, you'll see it says, "Engineering support

 3     order" at the top, does it not?

 4        A.   The order for engineering support of the army of Republika

 5     Srpska.  This is what it says, word for word.

 6        Q.   In the upper right-hand corner we see Drina, attachment

 7     number 10, copy number 7.

 8             If we turn to the next page, General, you will see the signature

 9     of Ratko Mladic, the signature of the Main Staff.

10             JUDGE MOLOTO:  The signature of the Main Staff?

11             MR. SAXON:  I apologise, Your Honour.  We see the seal of the

12     Main Staff; I spoke too quickly.

13        Q.   If you turn to the next page, the last page in this document -

14     can we go one more page in e-court, please - General, are you able to

15     help us with the notations on this -- on this page?  What is being

16     described here.

17        A.   I am not able to help you, because I don't know what this is

18     about.  I really cannot really see it or read it, about 50 per cent of it

19     is illegible.  The arrest, if I were to read it, it would be just

20     numbers.  But I cannot really tell what exactly they refer to.

21        Q.   That's fine, General.  Can you turn to the next tab, please.  Can

22     we go one page forward.

23             General, this is the plan for moral and psychological activities.

24     You will see it has been approved by General Mladic, and if you turn to

25     the last page, you'll see -- again, this is -- and this is page 85 in

Page 10279

 1     e-court, the last page.  You will see this is the plan that General Gvero

 2     signed which we looked at last week.  Do you recall?

 3        A.   Yes.

 4             MR. SAXON:  Can we turn to the next document, please.

 5        Q.   Tab 18 in your binder, General.

 6             MR. SAXON:  Can we go forward in e-court, please.  One more page,

 7     please.  One more page.  One more page, please.  Thank you.

 8        Q.   General Simic, this is a plan for the use of the air force and

 9     air support of the army of Republika Srpska, is it not?

10        A.   Yes.  But the word "plan" is not there.  It's says:  "The use of

11     forces of anti-aircraft defence and air support."

12        Q.   Very well.  Thank you for correcting me.

13             MR. SAXON:  Your Honour, the next document has already been

14     admitted as P158.  So I'm not going -- well, we'll look at for a moment.

15             Can we bring up P2158, please.

16             JUDGE MOLOTO:  Just a second.  When you say the next document has

17     been admitted as P158, it is it still part of XN-132, or are you done

18     with XN-132?

19             MR. SAXON:  Your Honour, there is a document that is part of

20     XN-132 that has already been admitted into evidence as 2158.

21             JUDGE MOLOTO:  2158.

22             MR. SAXON:  Yes, Your Honour.  If we could look at the next

23     document in e-court, please.

24             JUDGE MOLOTO:  And that's P2158.

25             MR. SAXON:  Yes.

Page 10280

 1        Q.   And this attachment, General, relates to logistical support, does

 2     it not, for the VRS Main Staff?

 3        A.   That is correct.

 4        Q.   Thank you.

 5             MR. SAXON:  Your Honour, at this time, I would seek to tender

 6     marked for identification 65 ter XN-132, with the exception of page 32 in

 7     e-court, Your Honour.  I would seek to tender the remainder of XN-132,

 8     marked for identification.

 9             JUDGE MOLOTO:  It's admitted XN-132, minus page 32 in e-court.

10     May it please be given an exhibit number.

11             THE REGISTRAR:  Your Honours, this document becomes

12     Exhibit P2894, marked for identification, thank you.

13             JUDGE MOLOTO:  Marked for identification, thank you.

14             MR. SAXON:

15        Q.   General, can you turn to the next tab in your binder.  It should

16     be tab 20.  And now I'd like to look at what is XN-133 in e-court.  These

17     are documents pertaining to the Sarajevo Romanija Corps.

18             MR. SAXON:  Can we ...

19             Is this XN-133 that we're looking at?

20                           [Prosecution counsel confer]

21             MR. SAXON:  One moment, please, Your Honour.

22                           [Prosecution counsel confer]

23             MR. SAXON:  Your Honour, I apparently gave incorrect information

24     to the Chamber on Friday.  The documents related to the Sarajevo Romanija

25     Corps begin with XN-137.

Page 10281

 1             And so if we can call up what is XN-137, please.

 2             JUDGE MOLOTO:  Yes, Mr. Guy-Smith.

 3             MR. GUY-SMITH:  If I understand Mr. Saxon's intent we're now

 4     moving on to a new series of documents.  If such is the case, then we

 5     need an offer of proof with regard to those documents.  I don't know

 6     whether these documents are being offered for the same purposes as

 7     previous documents, those being Drina Corps documents for impeachment

 8     only, or whether or not Mr. Saxon is taking a different position with

 9     regard to these documents.

10             When we had our last discussion he was focussed on the

11     Drina Corps documents.  Now he is dealing with a different set of

12     documents.  So I think we need to have an understanding from the

13     Prosecution as to what their position is with regard to these documents

14     under the decisional law.

15             JUDGE MOLOTO:  Mr. Saxon.

16             MR. SAXON:  Your Honour, on Friday, I sought leave from the

17     Chamber -- I believe I sought leave from the Chamber for -- to use with

18     this witness, documents related to the Drina Corps, Sarajevo Romanija

19     Corps, and the 1st Krajina Corps.

20             And it was my understanding that I had received permission from

21     the Chamber to use these documents for the particular purpose that we had

22     described.  I thought we had gone -- we had discussed each set of

23     documents.

24             MR. GUY-SMITH:  If that is Mr. Saxon' position and if that's his

25     representation to Court for each of those documents, I don't understand

Page 10282

 1     why he is being particularly coy here, using the language for the

 2     particular purpose, it's relatively simple what he's doing here.  If

 3     that's Mr. Saxon's representation and that's what the Office of the

 4     Prosecutor is to be bound by with regard to these documents, then

 5     obviously they have met their threshold, and I have no objection.

 6             JUDGE MOLOTO:  Just so the record is very clear, you're using

 7     them for the purpose of impeaching.

 8             MR. SAXON:  Yes, I am, Your Honour.

 9             JUDGE MOLOTO:  Thank you.  You may proceed.

10             MR. SAXON:  Thank you, Your Honour.

11             If we look at 65 ter 137, and it should be under tab 20,

12     General Simic, this document is --

13             JUDGE MOLOTO:  Sorry, Mr. Saxon.  Is this 65 ter 137, or is it

14     XN-137.

15             MR. SAXON:  It is XN-137, Your Honour.

16             JUDGE MOLOTO:  Thank you.  You withdraw -- you have withdrawn

17     XN-133.

18             MR. SAXON:  Yes, Your Honour.  What we see now is XN-137.

19        Q.   Mr. Simic, at the upper left-hand corner, we see a stamp from the

20     Command of the Sarajevo Romanija Corps, do we not?

21        A.   Yes.

22        Q.   And if we look in the middle of the -- of the page at the top, it

23     says:

24             "List of documents of the Sarajevo Romanija Corps, submitted to

25     the Main Staff of the VRS."

Page 10283

 1             Is that right?

 2        A.   That's right.

 3        Q.   And on the upper right-hand corner, which see the word "Drina."

 4             Do you see that?

 5        A.   I see much more.  National defence, state secret, R, Drina, copy

 6     number 1.

 7        Q.   And at the bottom of the page, we see the seal, or the stamp, of

 8     the Sarajevo Romanija Corps; is that right?

 9        A.   That's correct.

10        Q.   If you could turn to what is tab 21 in your --

11             JUDGE MOLOTO:  Before you turn, is there any reason why this

12     document is not signed and not dated?  It's just for 1994.

13             MR. SAXON:

14        Q.   Are you able to help us with Judge Moloto's question.

15        A.   I am not able to help.

16             JUDGE MOLOTO:  Thank you.

17             MR. SAXON:

18        Q.   Can you turn, please, to tab 21, General.  And this is -- we are

19     now in the realm of 65 ter XN-138.

20             JUDGE MOLOTO:  I'm getting a little lost, Mr. Saxon.  I thought

21     these XNs were batches of documents that you were dealing with and -- and

22     then when are you done with a particular batch, you then ask for its

23     admission, like you've just done with XN-132.

24             MR. SAXON:  Point taken, Your Honour.  That was also my

25     understanding on Friday afternoon when we discussed this.  I have just

Page 10284

 1     seen that these documents now relating to the Sarajevo Romanija Corps,

 2     there are six of them, actually each of them have a separate XN number.

 3     That is the only change, Your Honour.

 4             JUDGE MOLOTO:  Okay.

 5             MR. SAXON:  And if we could -- if I could ask to tender, marked

 6     for identification, the last document that we saw, which was XN-137,

 7     please.

 8             JUDGE MOLOTO:  That is why I asked the question.  Because I was

 9     wondering now what we do with that one.

10             MR. SAXON:  Thank you.

11             JUDGE MOLOTO:  XN-137 is admitted into evidence, marked for

12     identification.  May it please be given a number.

13             THE REGISTRAR:  Yes, Your Honours, this document shall be

14     assigned Exhibit P2895, marked for identification.  Thank you.

15             MR. SAXON:  Your Honour, I note the time.  Does the Chamber wish

16     to take the first break at this time?

17             JUDGE MOLOTO:  If it is convenient for the Prosecution.

18             MR. SAXON:  We can do it, Your Honour.

19                           [Trial Chamber and Registrar confer]

20             JUDGE MOLOTO:  We'll take a break, and come back at 4.00.

21             Court adjourned.

22                           --- Recess taken at 3.33 p.m.

23                           --- On resuming at 4.00 p.m.

24             JUDGE MOLOTO:  Yes, Mr. Saxon.

25             MR. SAXON:  Thank you, Your Honour.

Page 10285

 1        Q.   General Simic, if you have the document in tab 21 in front of

 2     you, and we're looking now at what is 65 ter XN-138, General, up in the

 3     upper left-hand corner of this document it says:  "Command of the

 4     Sarajevo Romanija Corps."

 5             Does it not?

 6        A.   That's correct.

 7        Q.   And it refers to the command post in Pale, dated the 26th of

 8     January, 1994; is that right?

 9        A.   That's right.

10        Q.   In the right-hand corner, we see People's Defence, state secret,

11     R, Drina, copy number 1; is that correct?  Or is that attachment

12     number 1?

13        A.   Correct.

14        Q.   Okay, that's copy number 1.

15             And, General, this is an order for the use of the Sarajevo

16     Romanija Corps, is it not?

17        A.   That is correct.  I apologise, I had to look at the last page to

18     check the signature and the stamp.  That's why it took a little bit of

19     time.

20        Q.   That's fine.  And again, if you're focussed on the last page,

21     there we see the signature of Commander General Stanislav Galic and the

22     seal of the Sarajevo Romanija Corps; is that right?

23        A.   Correct.

24        Q.   And this order would be -- this order from General Galic would be

25     addressed to all the units of the Sarajevo Romanija Corps?

Page 10286

 1        A.   I don't know.  It doesn't state to whom it was delivered.

 2             I assume, on the basis of practice, that that's how it should

 3     have been.

 4        Q.   All right.  And the purpose of such an order at the level of a

 5     corps would be what?

 6        A.   A directive at the strategic level, in this case for the

 7     Main Staff of the Army of Republika Srpska, is a command by the corps

 8     commander to subordinate units for the execution of their assignments.

 9        Q.   Very well.  And can you please -- actually, I would --

10             MR. SAXON:  I would seek to tender this document, XN-138,

11     Your Honour, marked for identification, please.

12             JUDGE MOLOTO:  XN-138 is admitted and marked for identification.

13     May it please be given an exhibit number.

14             THE REGISTRAR:  Your Honours, this document shall be assigned

15     Exhibit P2896, marked for identification.

16             JUDGE MOLOTO:  Thank you so much.

17             MR. SAXON:

18        Q.   MR. Simic, can you turn to the next tab, please, that would be

19     tab 22.

20             MR. SAXON:  And if we could bring up on e-court what is XN-139,

21     please.

22                           [Trial Chamber and Registrar confer]

23             JUDGE MOLOTO:  It has just been brought to my attention that this

24     specific exhibit, P2896 does have translation.  Is there any reason why

25     it should be marked for identification?  Any other reason?

Page 10287

 1             MR. SAXON:  If we have an English translation, Your Honour, then,

 2     no.  It -- I don't see the need to have it marked for identification.

 3             JUDGE MOLOTO:  Then it will be admitted fully.

 4                           [Prosecution counsel confer]

 5             MR. SAXON:

 6        Q.   General, the next document says at the top:

 7             "People's Defence, state secret, Drina, attachment number 3, copy

 8     number 1."

 9             And the title of the document is, "Use of anti-aircraft forces

10     and air force."

11             Is that correct?

12        A.   Absolutely.

13        Q.   And if we look at number 1 below the title, the subtitle refers

14     to the first phase of operations, doesn't it?

15        A.   That is correct.

16        Q.   And what does the paragraph numbered with -- with little number

17     (a) tell us?

18        A.   As it states in the title, sir, use of forces against -- use of

19     forces of the anti-aircraft and aircraft defence.  Then it talks also

20     about the army, anti-aircraft, and anti-aircraft [as interpreted] who

21     organise a system of unique unified system of anti-aircraft defence in

22     the territory of the SRK.  Also, to form air support, in order to provide

23     air force support.  I don't have to continue to read what it says here.

24        Q.   No, thank you.  And if you could just turn your eyes towards the

25     bottom of the page, we see the number 2.  Then do we have additional

Page 10288

 1     instructions for the second phase of the operation?  Is that what that

 2     says there, that subtitle 2?

 3        A.   Yes, that's what it states.  But we just need to throw out the

 4     word "subsequent."

 5             What is provided for is the use of those forces in the first

 6     phase of the operation and in the second phase of the operation; not

 7     their use subsequently.

 8        Q.   Okay.  Thank you.  And at the bottom of this page and the

 9     following page, we see the seal of the Sarajevo Romanija Corps; is that

10     correct?

11        A.   Absolutely correct.

12             MR. SAXON:  Your Honour, I would seek to tender this document,

13     marked for identification, please.

14             JUDGE MOLOTO:  The document is admitted into evidence.  May it

15     please be given an exhibit number and will be marked for identification.

16             THE REGISTRAR:  Your Honours, this document shall be assigned

17     Exhibit P2897, marked for identification.  Thank you.

18             JUDGE MOLOTO:  Thank you so much.

19             MR. SAXON:

20        Q.   General Simic, could you please turn to tab 23 in your binder,

21     and I believe this is 65 ter XN-139 -- excuse me, 140.

22        A.   I don't have that marking, XN, what you just -- that you referred

23     to.  But I am managing to find my way around.

24        Q.   Consider yourself lucky, General, that you don't need to be

25     thinking about that, please.

Page 10289

 1             JUDGE MOLOTO:  What is it, XN-140?

 2             MR. SAXON:  Yes, Your Honour.  Yes.

 3        Q.   We see at the top of this document the seal of the Sarajevo

 4     Romanija Corps on the upper right-hand corner:  Drina, attachment

 5     number 6, copy number, I believe it's a 1.  I might be mistaken.

 6             And, General on the upper left-hand corner, does it not:

 7     "Approved by the commander, Major-General Stanislav Galic."

 8             Is that right?

 9        A.   Yes, that is right.

10        Q.   And the title of this document, on that page at the top, I

11     believe is:  "Plan for moral, psychological activities and information

12     for the Sarajevo Romanija Corps."

13             Am I reading that correctly, or have I made a mistake?

14        A.   Absolutely correct.

15        Q.   Thank you.  And if we could turn -- if we could go forward two

16     pages in e-court.  And if you could go forward two pages, General, we see

17     that this document has been signed by the assistant commander

18     Colonel Kosovac; is that right?

19        A.   That's what it says, yes.

20        Q.   Very well.  And if you move forward three more pages, through a

21     series of tables.

22             MR. SAXON:  And if we could go in e-court to the last page,

23     please.

24                           [Prosecution counsel confer]

25             MR. SAXON:  May I have your indulgence to check one thing,

Page 10290

 1     Your Honour.

 2                           [Prosecution counsel confer]

 3             MR. SAXON:  All right.

 4             Your Honour, at this time, I'd like to tender what is XN-140,

 5     marked for identification, please.

 6             JUDGE MOLOTO:  The document is admitted.  May it please be given

 7     an exhibit number, and marked for identification.

 8             THE REGISTRAR:  Yes, Your Honours.  This document shall be

 9     assigned Exhibit P2898, marked for identification.  Thank you.

10             MR. SAXON:  And can we see what is XN-141, please.

11        Q.   Please stay on the same document, General Simic.  You should see

12     some tables.  And you'll see, General, that these tables were related to

13     the plan that we just saw.

14             And if we could go to the last page of this document, please.

15     And you should see, General, again the signature of Colonel

16     Ljuban Kosovac.  Do you see that, with the seal of the Sarajevo Romanija

17     Corps?

18        A.   Yes.

19        Q.   Are you able to tell from the different abbreviations here what

20     Colonel Kosovac's position was?

21        A.   Well, I'll try not to interpret but rather to just to read back.

22     Assistant commander for moral guidance and psychological and political

23     work.

24        Q.   Very well.

25             MR. SAXON:  Your Honour, I would seek to tender XN-141, please,

Page 10291

 1     marked for identification.

 2             JUDGE MOLOTO:  It is admitted.  May it please be given an exhibit

 3     number and marked for identification.

 4             THE REGISTRAR:  Yes, Your Honours, this document shall be

 5     assigned exhibit P2899, marked for identification.  Thank you.

 6             MR. SAXON:

 7        Q.   And, General Simic, if you move to tab 24, please, and if we

 8     could pull up on e-court what is XN-142.

 9             General Simic, on the far right-hand side we see:

10             "People's Defence, state secret, Drina, attachment number 5, copy

11     number 1."

12             And I believe this document is entitled: "Plan for security

13     measures of the Sarajevo Romanija Corps."  Is that correct?

14        A.   That's correct.

15        Q.   And on the upper left-hand side, this document has been approved

16     by Major-General Galic; is that right?

17        A.   That's what it says.

18        Q.   And we see there the seal of the Sarajevo Romanija Corps.

19        A.   Yes.

20        Q.   General, could you please move forward three more pages.

21             MR. SAXON:  If we could go do what should be the last page in

22     e-court.  We see a series of tables, different items.

23        Q.   And, General, here we see the signature of Colonel Marko Lugonja,

24     with the seal of the SRK Command.

25             Are you with me?  I'm sorry, are you following me?

Page 10292

 1        A.   Absolutely.

 2        Q.   Okay.

 3             MR. SAXON:  Your Honour, I would ask that this document be given

 4     a number, marked for identification.

 5             JUDGE MOLOTO:  The document is admitted.  May it please be given

 6     an exhibit number and be marked for identification.

 7             THE REGISTRAR:  Yes, Your Honours, this document shall be

 8     assigned exhibit P2900, marked for identification.  Thank you.

 9             JUDGE MOLOTO:  Thank you.

10             MR. SAXON:

11        Q.   General Simic, if you could turn to tab 25, please.

12             MR. SAXON:  And if we could pull up XN-143 on e-court, please.

13        Q.   General, does the title of this document say:

14     "Intelligence plan"?

15        A.   Yes.

16        Q.   We see in the upper right-hand corner: "Drina, state secret" --

17     excuse me, we don't see the word "Drina."

18             We see: "People's Defence, state secret, attachment 4, copy

19     number 1."

20             It says:  "Approved by General Galic" on the upper left-hand

21     side.

22             Do you see that?

23        A.   Yes, I see that.

24        Q.   And could you turn to the last page, please.  And, again, we see

25     the signature of Colonel Lugonja, is that right, and the seal of the SRK?

Page 10293

 1        A.   Yes.

 2        Q.   Thank you.  Very -- excuse me.

 3             General, if you turn to the next -- excuse me.

 4             MR. SAXON:  Your Honour, I'd ask that this be given an exhibit

 5     number, XN-143, marked for identification, please.

 6             JUDGE MOLOTO:  It's admitted.  May it please be given a number

 7     and marked for identification.

 8             THE REGISTRAR:  Yes, Your Honour, this document shall be assigned

 9     Exhibit P2901, marked for identification.  Thank you.

10             JUDGE MOLOTO:  Thank you so much.

11             MR. SAXON:

12        Q.   General Simic, if you could turn to the document in tab 26 of

13     your binder, please.

14             MR. SAXON:  And if we could call up on the screen what is

15     Exhibit P1556.  And we have an English translation of this document.

16             JUDGE MOLOTO:  It is admitted already.

17             MR. SAXON:  Yes, Your Honour.  I'm just waiting for the B/C/S

18     now.  I'm sorry, I'm waiting for the English to come up.

19        Q.   General Simic, you'll see this document is entitled: "Order for

20     logistics."

21             In the upper right-hand corner it says:  "National defence, state

22     secret, R, Drina, attachment number 7, copy number 1."

23             Are you following me?

24        A.   Yes.

25        Q.   The upper left-hand corner we see "Sarajevo Romanija Command" in

Page 10294

 1     the first line.  And then below that, "Pale, PKM."

 2             Does PKM stand for rear command post or alternate command post?

 3        A.   That is exactly right.

 4        Q.   Very well.  And --

 5             JUDGE MOLOTO:  Wait a minute.  What is -- is it alternate or

 6     rear?

 7             MR. SAXON:

 8        Q.   The abbreviation, or acronym, PKM, General, can you tell us,

 9     please, in your words, what does it stand for?

10        A.   Each command of an operative or strategic level normally breaks

11     down into two different command posts:  Basic command post, rear command

12     post, and reserve command post.  This is the rear command post in this

13     case, that of the Sarajevo Romanija Corps, at Pale.

14        Q.   Thank you.  And we see in the first two lines: "Information on

15     the enemy, number 1.

16             And then number 2 it says:  "Organisation of the logistical

17     support."

18             And I'd like you, General, if you could, to help us with

19     something that is on the seventh page in the English version, and the --

20     I shall find it for you in your version.  If you move forward, General,

21     to the fourth page in your version, please, page 4.  If we could move

22     forward three more pages in B/C/S, please.  And if we could focus on

23     section number 8, which begins about halfway down the page.  And will you

24     see, General, that there is a section entitled: "8. Transport support."

25             Do you see that?

Page 10295

 1        A.   Yes.

 2        Q.   And I'm wondering whether you can help us, please, with something

 3     in the second paragraph of this section, which says the following in

 4     English:

 5             "The 27th Logistics Base is in charge of the plans for movement

 6     and transportation of material supplies, organisation with the VJ, both

 7     en route Rogoj - Trnovo, Pale, Sokolac, and further on towards the

 8     destinations in the Federal Republic of Yugoslavia."

 9             Can you explain, General, this phrase about organisation and the

10     VJ, what -- what is the significance of this phrase?

11        A.   I can't explain the intention of whoever wrote this, simply

12     because I wasn't involved in this specifically.

13             My answer can be of no relevance.

14        Q.   Very well.  We will now -- if we just move to -- we will move

15     from this document.  It's been admitted.

16             MR. SAXON:  Your Honours, those are the documents from the

17     Sarajevo Romanija Corps that we wished to show the witness.  The last

18     series of documents are from the 1st Krajina Corps of the Army of

19     Republika Srpska.

20             And ... if will you give me one moment to be sure I'm giving you

21     the proper 65 ter number, please.

22                           [Prosecution counsel confer]

23             JUDGE MOLOTO:  These documents that are coming, are also for the

24     same purpose for impeachment.

25             MR. SAXON:  Yes, Your Honour, and we left these for today to give

Page 10296

 1     the Defence time to review them over the weekend.

 2             All right.  We have already looked at -- I think I will start --

 3             If we could please provide to General Simic the binder labelled:

 4     Volume 1 Drina, please.

 5             And ...

 6                           [Prosecution counsel confer]

 7             MR. SAXON:

 8        Q.   General Simic, could you turn to tab 11 in your binder, please.

 9             MR. SAXON:  And we'll be starting, Your Honour, with 65 ter

10     number XN-144.

11             And if we could bring that up on e-court, please.

12        Q.   General Simic, in the upper left-hand corner of this document it

13     says:  "Command of the 1st Krajina Corps."

14             Does it not?

15        A.   My apologies, I haven't found the document yet.

16             Yes, that's right.  The 1st Krajina Corps Command.

17        Q.   It's dated the 21st of January, 1994.  We see in the upper

18     right-hand corner:  "People's Defence, state secret, Drina."

19             And it says:  "Copy number 1."

20             There's a seal in the upper right-hand corner.  Is that the seal

21     of the 1st Krajina Corps?

22        A.   That's what it says.

23        Q.   Can you read to us the title of this document.

24        A.   Mr. Prosecutor, the document is entitled:  "Order for

25     defensive/offensive operation."

Page 10297

 1        Q.   And this document would be an order sent from the command of the

 2     Krajina Corps down to subordinate Krajina Corps units; is that right?

 3        A.   Mr. Prosecutor, sir, we skipped the list.  This is a single copy.

 4     The command of the 1st Krajina Corps, and I'm talking about their

 5     documents, in terms of being forwarded to their superiors.  This is now

 6     being forwarded to the Main Staff of the VRS, which is stated in the

 7     previous part of this joint document.

 8        Q.   Well, then, just to make things clear, let's leave XN-144 for a

 9     moment, and if you could move back one document in your binder, please.

10             MR. SAXON:  And if we could see what is P1562, please.  I'm going

11     to come back to this document in a moment; I just want the record to be

12     clear.  I'm just waiting for it to come up on the computer screen.

13        Q.   There we see again this, General, from the command of the

14     1st Krajina Corps.  This is it P1562.  And as you -- as you pointed out,

15     this is a list of 1st Krajina Corps documents submitted to the

16     General Staff of the Army of Republika Srpska.  Is that right?

17        A.   That's right.

18        Q.   And we see here a list of 14 separate documents.  And the

19     document that we looked at just a moment ago, that was the order for

20     defence attack operations, correct, number 1 on the list?

21        A.   Mr. Prosecutor, I'm looking at number 1, and the order is not --

22     the word here is "naredjenje;" the word is "zapovest."  Both translate

23     into English as "order."  But there is an important difference between

24     the two.

25        Q.   [Microphone not activated] Can you please explain the difference

Page 10298

 1     between the two.

 2        A.   "Zapovest" is more complex document which regulates a very

 3     complex use for units in a certain area over a longer period of time.

 4     The word "naredjenje," which might also be translated as command, is also

 5     command document, but it is normally briefer encompassing no more than

 6     two or three details of something to be done on that particular day or

 7     over the following days, that being the essential difference between the

 8     two.

 9        Q.   All right, so a "zapovest," would also then require more time an

10     effort to prepare, is that right, that a "naredjenje," usually?

11        A.   Yes.  Unless a command is attached to the order.  For example,

12     there is a command for logistics, for the rear, or something like that,

13     normally tends to be a little more complex.

14        Q.   Well, now can we leave this document, please.  And could you turn

15     to the next tab in your binder, and could we look again on e-court at

16     XN-144.

17             So here, General, we see a "zapovest," the more complex form of

18     order for offensive/defensive operations.  That's the stamp of the

19     1st Krajina Corps in the upper right-hand corner, is it not?

20        A.   That's what it says.

21             MR. SAXON:  And can we please turn to the last page in e-court.

22        Q.   And if you could go to your last page, General.  And, General, if

23     you could please focus on the last page in subsections 8 and

24     subsection 9.

25             Subsection 9 is a list of attachments, is it not?

Page 10299

 1        A.   I'm sorry, I've lost track.  This is the last page.  I have page

 2     number five as the last page.  And there is no subsection 8.  What I see

 3     is 4, 5, 6, and 7.

 4        Q.   All right.  I'm going give you my copy, because I suspect that my

 5     copy is more complete than your copy.

 6        A.   Sir, I wasn't the one who produced this document, so ...

 7        Q.   I know.  It is completely -- it is completely our fault.  Please,

 8     it is no problem.

 9                           [Prosecution counsel confer]

10             MR. SAXON:

11        Q.   Mr. Simic, are you looking at tab 11 of your binder or tab 12?

12        A.   Thirteen, command for the intelligence security.  Is that the

13     one?

14        Q.   No.  I apologise.  Could you turn back to tab 11 in your binder,

15     please.

16             Do you have a longer document now, in tab 11?  Should be about --

17        A.   Sir, I have the order that we started discussing a minute ago,

18     order for defence and attack.

19        Q.   Very well.  And can you turn to the last page, please.  And on

20     that last page, you should see, among other things, a section 8 and a

21     section 9.

22        A.   That's right.

23        Q.   Can you explain to us what section 8 is telling us.

24        A.   The wording itself speaks for itself.  Name - code, the plan for

25     the use of the 1st Krajina Corps.  "The plan for the use of the

Page 10300

 1     1st Krajina Corps is to be executed under code-name Drina."

 2        Q.   And section 9 is a list of an attachments to this -- to this

 3     particular plan or to the order that we're looking at?

 4        A.   That's right.

 5        Q.   I'm sorry.  So the subsection 9 refers to a list of attachments

 6     to the plan itself.

 7        A.   Yes, that's right.  All these attachments go up to -- go to make

 8     up a plan that is eventually used.

 9        Q.   Very well.  And on that last page at the very bottom we see the

10     signature of the Momir Talic, the commander of the 1st Krajina Corps, and

11     it's sealed.

12             MR. SAXON:  Your Honour, I would seek to tender XN-144, marked

13     for identification, please.

14             JUDGE MOLOTO:  It's admitted, marked for identification.  May it

15     please be given an exhibit number.

16             THE REGISTRAR:  Yes, Your Honours.  This document shall be

17     assigned exhibit P2902, marked for identification.  Thank you.

18             MR. SAXON:

19        Q.   Could you please turn to tab 12, General Simic.

20             MR. SAXON:  And if we could please see XN-145 on the screen.

21             General Simic, if we focus now on the first page of this

22     document, there is a seal of the 1st Krajina Corps on the upper

23     right-hand side; is that right?

24        A.   That's right.

25        Q.   We see the words: "Drina, attachment 2, copy number 1."

Page 10301

 1             And then I believe the title says:  "Order to protect

 2     intelligence."

 3             Is that correct?

 4        A.   That's right.

 5        Q.   And can please turn to the last page of this document.  And we

 6     see there the signature of General Talic again with the seal of the

 7     Sarajevo Romanija Corps.

 8             So such an order would normally be sent by the corps commander to

 9     his assistant for intelligence.  Is that how this would be used?

10        A.   This command is part of the plan for the overall use.  The

11     previous order has some attachments which you were asking me about a

12     while ago, what we enumerated a minute ago.  This is a command for

13     intelligence security, one of the documents that were part of the plan on

14     how to use that corps.

15        Q.   Very well.

16             MR. SAXON:  Your Honour, I would ask that this be given an

17     exhibit number, please, and marked for identification.

18             JUDGE MOLOTO:  Admitted into evidence.  May it please be given an

19     exhibit number and be marked for identification.

20             THE REGISTRAR:  Yes, Your Honours.  This document shall be

21     assigned Exhibit P2903, marked for identification.  Thank you.

22             MR. SAXON:

23        Q.   General Simic, could you turn to tab 13, please, and I believe we

24     are up to XN-146.

25             General, this document -- well, I'll ask you, please.

Page 10302

 1             Can you please tell us what this -- what this document is

 2     entitled, please.

 3        A.   Sir, the title is: "The plan for intelligence security."

 4        Q.   And below those capital letters at the top, there are some

 5     smaller letters.  Can you tell us what that says, please.

 6        A.   I apologise.  I didn't understand.  I didn't read the entire

 7     heading.

 8             The entire heading states:

 9             "Plan of intelligence security for the execution of the defence

10     and attack operation of the 1st Krajina Corps."

11        Q.   And on the upper right-hand side we see:

12             "People's Defence, state secret, Drina, attachment 3, copy

13     number 1."

14             On the left-hand side, General, we see it says:  "Approved by

15     General Talic."

16             Does it not?

17        A.   That is correct.

18        Q.   We see the seal of the 1st Krajina Corps.

19             Can you please move to the last page of this document.

20             MR. SAXON:  If we could see the last page in e-court, please.

21        Q.   And we see a signature at the bottom.  We see the stamp at the

22     upper right-hand corner.  And this document was signed by Colonel Djuric.

23     And he was the assistant to the chief of intelligence.  Is that correct?

24        A.   That's what it says.

25             MR. SAXON:  Your Honour, could this be given an exhibit number,

Page 10303

 1     please, marked for identification.

 2             JUDGE MOLOTO:  Given an exhibit number, please, and be marked for

 3     identification.

 4             THE REGISTRAR:  Yes, Your Honours.  This document shall be

 5     assigned Exhibit P2904, marked for identification.  Thank you.

 6             JUDGE MOLOTO:  Thank you so much.

 7             MR. SAXON:

 8        Q.   Can you turn, please, to 65 ter -- excuse me.  Can you turn to

 9     tab 14, General.

10             MR. SAXON:  And can we please see XN-147, please.

11        Q.   General Simic, this document is entitled:  "Plan for camouflage;"

12     is that correct?  Or do I need to be more precise?

13        A.   Not for my sake.  But for the transcript, yes, it states, "Plan

14     of operations tactical camouflage."

15        Q.   Very well.  On the upper right-hand side we see:

16             "People's Defence, state secret, Drina, attachment number 4, copy

17     number 1."

18             On the left-hand side, it says:  "Approved by the Commander,

19     Momir Talic."  Is that right?

20        A.   That's right.

21        Q.   And if we just look in column 2, at the very top, the title of

22     that column.  It says:  "Taskings for operative camouflage.

23             Is that correct?

24        A.   Correct.

25        Q.   Could you move, please, to the last page of the document.  And on

Page 10304

 1     the bottom right-hand corner we see the seal of the 1st Krajina Corps.

 2     And then below that, the signature of Colonel Stanimir Stanimirovic.  And

 3     colonel Stanimirovic was the chief of operations and training for the 1st

 4     Krajina Corps.  Is that correct?

 5        A.   That's right.

 6        Q.   So when this plan was produced it was Colonel Stanimirovic who

 7     signed off on it and sent it up to General Talic; is that how it worked?

 8        A.   I'm sorry, but could you repeat your question, please.

 9        Q.   We see that this document is signed at the end by

10     Colonel Stanimirovic, so he would have been the officer in the 1st

11     Krajina Corps who signed off on this plan at the end when it was

12     produced, in order to provide it to General Talic for his approval.

13        A.   I have to give a broader explanation, if you permit, sir.

14        Q.   Please.

15        A.   Colonel Stanimirovic was the chief for operations and training of

16     the corps, and he participated in the development of the overall plan for

17     use of forces.  This is something that is done at the command post in the

18     operations room; it's a team effort.  And when he drafted it, he

19     submitted it to his commander for approval.

20        Q.   Very well.  Thank you.

21             JUDGE MOLOTO:  And who was his commander?

22             THE WITNESS: [Interpretation] Your Honour, the commander was

23     Momir Talic.  That is what it states in the document.  But we are looking

24     at a document -- we're looking at individual documents that comprise the

25     overall plan of use.

Page 10305

 1             JUDGE MOLOTO:  Thank you so much, Mr. Simic.

 2             Yes, Mr. Saxon.

 3             MR. SAXON:  Your Honour, could this document please be given an

 4     exhibit number, marked for identification, please.

 5             JUDGE MOLOTO:  It is given an exhibit number.  May it please be

 6     marked for identification.

 7             THE REGISTRAR:  Yes, Your Honour, this document shall be assigned

 8     exhibit P2905, marked for identification.  Thank you.

 9             JUDGE MOLOTO:  Thank you.

10             MR. SAXON:

11        Q.   General Simic, could you please move to tab 15 in your binder.

12     And could we please see on e-court XN-148, please.

13             General, it says "plan" at the very top of the page.  Can you

14     read to us, please, the rest of the title that is underneath the word

15     "plan."

16        A.   Sir, it states:

17             "Plan of security measures of the 1st Krajina Corps for the

18     defence and attack operation."

19        Q.   Thank you.  In the upper right-hand corner we see:

20             "People's Defence, state secret, Drina, attachment number 5, copy

21     number 1."

22             General, in the upper left-hand side again we see -- this has

23     been approved by the commander of the corps, Momir Talic; has it not.  If

24     you look at the first page, please.

25        A.   That's correct.  That's correct.

Page 10306

 1        Q.   Can we turn to the last page, please.  We see the seal of the

 2     Sarajevo -- excuse me.  We see the seal of the 1st Krajina Corps at the

 3     top.  And below, we see a signature, and this plan was signed by the

 4     chief of the security department, Colonel Bogojevic.  Is that right?

 5        A.   Yes, that's what it says, sir.

 6             MR. SAXON:  Your Honour, could this document please be given an

 7     exhibit number, marked for identification.

 8             JUDGE MOLOTO:  The document is admitted.  May it please be given

 9     an exhibit number and marked for identification.

10             THE REGISTRAR:  Yes, Your Honours, this document shall be

11     assigned Exhibit P2906, marked for identification.  Thank you.

12             MR. SAXON:

13        Q.   General Simic, could you please turn to tab 16 in your binder.

14             MR. SAXON:  And could we please call on e-court, XN-149.

15        Q.   General Simic, this is a plan for anti-electronic combat; is that

16     right?

17        A.   That's what it says.

18        Q.   Does that mean jamming, or does that mean -- does that mean

19     jamming the communications of the enemy, or counter-jamming the

20     communications of the enemy?  Can you explain.

21        A.   I cannot answer until I look at the entire document.  There's

22     electronic surveillance.  Then there is EO, electronic jamming,

23     anti-electronic combat, and anti-surveillance protection.  So what you

24     have asked me is actually part of electronic surveillance.

25        Q.   Okay.  What does anti-electronic combat mean?  What does that

Page 10307

 1     mean?

 2        A.   The word itself, anti-electronic combat, means that we would be

 3     monitoring the communications of the enemy, finding out their intentions

 4     and protecting our own communications from enemy surveillance.  That is

 5     it, simply put.  And if you permit me to say, for the sake of

 6     clarification, the column of assignments, it says, Electronic

 7     surveillance, uncover and monitor radio communications of special and

 8     other forces which preparing, and so on and so forth.  I don't want to

 9     take up any more time by reading the entire thing.

10        Q.   No, that's fine.  Thank you.  But when you refer to the

11     particular column of assignments, can you just tell us which column

12     you're looking at.  Where is it?  Is it the first column on the left?  Or

13     is it the column that says "zadaci," and then it has a number 2 below it?

14        A.   "Zadaci," assignments.  That is that column that I'm thinking of.

15        Q.   Thank you for correcting me.

16             Can you please turn to the last page of this document,

17     General Simic.

18             We see the seal of the 1st Krajina Corps, and the signature,

19     again, Stanimirovic, Stanimir.  And then we see two words which are

20     difficult for me.  "Nacelnik," and then it is either a word or an

21     abbreviation.  Can you tell what that stands for?

22        A.   That is the chief of the organ for operations and training.  That

23     is where we -- earlier we saw the chief of the section, and now we have

24     the chief of the organ of operations and training, which means that this

25     is at a higher level than the previous one.

Page 10308

 1        Q.   Thank you, sir.

 2             MR. SAXON:  Your Honour, may this be given an exhibit number

 3     marked for identification, please.

 4             JUDGE MOLOTO:  May it please be given an exhibit number and be

 5     marked for identification.

 6             THE REGISTRAR:  Yes, Your Honours, this document shall be

 7     assigned Exhibit P2907, marked for identification.  Thank you.

 8             JUDGE MOLOTO:  Thank you.

 9             MR. SAXON:

10        Q.   General Simic, can you please turn to what is tab 17 in your

11     binder.

12             MR. SAXON:  And can we please pull up in e-court XN-150.

13        Q.   General Simic, this document is entitled - I hope I'm correct,

14     and you'll correct me if I'm not - "Order for electronic surveillance and

15     jamming."

16             Is that right?

17        A.   Correct.

18        Q.   And we see in the upper right-hand corner:

19             "People's Defence, state secret, Drina, attachment 7," it looks

20     like "copy 1," and then the seal of the 1st Krajina Corps.

21             Can you just take a moment to look at this document, and can you

22     explain to us how does this document relate to the previous document that

23     we just looked at, which had to do with anti-electronic combat, or what's

24     the difference between the two, if you can explain?

25        A.   This plan of anti-electronic combat is a plan approved by the

Page 10309

 1     commander.  It was developed by the person who developed it, and the

 2     commander approved it.

 3             Out of that would result a command for those who were meant to

 4     execute this plan, or, better said, a command --

 5        Q.   Sorry to interrupt.  So this document here is -- is the command

 6     that was produced, is that right?  According to the plan.

 7        A.   Sir, you're asking me as if I was the one who developed this

 8     programme.  I'm just talking on the basis of my experience.  An operative

 9     officer developed a plan and the plan was approved by the commander.  On

10     the basis of that plan, tasks would be pulled out and drafted in the form

11     of a command for those who were meant to implement certain actions as

12     part of the overall plan.

13        Q.   Thank you very much.  Could you turn to the last page, please.

14             We see on the last page this document has been signed by

15     Commander Momir Talic.  We see the seal of the 1st Krajina Corps.  Is

16     that right?

17        A.   That's right.

18             MR. SAXON:  Your Honour, I would ask that this document be given

19     an exhibit number, marked for identification.

20             JUDGE MOLOTO:  The document is admitted into evidence.  May it

21     please be given an exhibit number and be marked for identification.

22             THE REGISTRAR:  Yes, Your Honours, this document shall be

23     assigned Exhibit P2908, marked for identification.  Thank you.

24             MR. SAXON:

25        Q.   General Simic, could you please turn to the document that is in

Page 10310

 1     tab 18 of your binder.

 2             MR. SAXON:  And can we please see on e-court XN-151, please.

 3        Q.   General Simic, what is this document?

 4        A.   The heading on the document states:  "Plan of electronic

 5     surveillance and jamming."

 6        Q.   Very well.  It's been approved, on the upper left-hand corner by

 7     General Talic; is that correct?

 8        A.   That's what it says, sir.

 9        Q.   Upper right-hand side we see Drina, attachment 8, copy 1.  Could

10     you please turn to the last page, General.

11             We see the seal of the 1st Krajina Corps in the upper right hand.

12     And towards the bottom we see the signature of Colonel Djuric, and is he

13     signing this document on behalf of the intelligence branch?  Is that what

14     we see there?

15        A.   It states in the document that he signed it as assistant chief of

16     intelligence, because surveillance is part of the intelligence activity.

17        Q.   Thank you, General.

18             MR. SAXON:  Your Honour, could this document be given an exhibit

19     number, marked for identification, please.

20             JUDGE MOLOTO:  The document is admitted.  May it please be given

21     an exhibit number and marked for identification.

22             THE REGISTRAR:  Yes, Your Honours.  This document shall be

23     assigned Exhibit P2909, marked for identification.  Thank you.

24             JUDGE MOLOTO:  Thank you.

25             MR. SAXON:

Page 10311

 1        Q.   General Simic, could you please turn to tab 19 in your binder.

 2             MR. SAXON:  And if we could please see on e-court XN-152, please.

 3        Q.   General, this is an order for engineering support; is that right?

 4        A.   That's right.

 5        Q.   We see on the upper right-hand corner:

 6             "People's Defence, state secret, Drina, attachment number 9, copy

 7     number 1."

 8             And we see the seal of the 1st Krajina Corps.  And could you

 9     please take a look at the last page, please.

10             MR. SAXON:  And can we scroll down, please, in e-court.

11        Q.   And we see here that this order is signed by General Talic and

12     it's been sealed -- it has the seal of the 1st Krajina Corps; is that

13     correct?

14        A.   Correct.

15             MR. SAXON:  Your Honour, could this document please be given an

16     exhibit number, marked for identification.

17             JUDGE MOLOTO:  The document is admitted.  May it please be given

18     an exhibit number and marked for identification.

19             THE REGISTRAR:  Yes, Your Honours.  This document shall be

20     assigned Exhibit P2910, marked for identification.  Thank you.

21             JUDGE MOLOTO:  Thank you.

22             MR. SAXON:

23        Q.   General Simic, could you please turn to tab 20, please.

24             MR. SAXON:  And if we can call up on e-court, XN-153.

25        Q.   General Simic, if you could focus on the first page for now of

Page 10312

 1     this document.  The title is: Plan for morale and psychological

 2     activities an information.  But can you tell me what the last part of the

 3     title says because I'm not able to read it.

 4        A.   Sir, it states:  "In units of the 1st Krajina Corps."

 5        Q.   Okay.  Thank you.  We see this plan on the upper left-hand corner

 6     has been approved by Momir Talic.  We see the seal of the 1st Krajina

 7     Corps.  In the upper right-hand corner, we see the words:

 8             "People's Defence, state secret, Drina, attachment number 10,

 9     copy number 1."

10             Could you turn to the last page of this document, General.

11             At the bottom right-hand corner of this table, we see the seal of

12     the 1st Krajina Corps, and then we see a signature of Colonel -- I

13     believe it is Vukelic.  And we see a series of abbreviations above his

14     name.

15             Are you able to tell us what his position was?

16        A.   I cannot give you an answer.  I can just read what it states.  I

17     don't know all of those people.  I didn't know all the people who were in

18     the Army of Yugoslavia, to be able to tell who was who at lower ranks.

19        Q.   Sure.  But my question is a little -- and I understand that

20     limitation.  But my question was a little bit different.  Just from the

21     acronyms that we see above the word "Colonel," are you able to tell us

22     what the gentleman's position was?  For example, is there a reference to

23     moral and religious affairs, for example?

24        A.   Sir, I'm reading, assistant commander for moral guidance,

25     religious issues and political and propaganda affairs.  I am not familiar

Page 10313

 1     with their precise establishment structure to be able to tell you more.

 2     That was not one of my assignments.

 3        Q.   Fine, thank you very much?

 4             MR. SAXON:  Your Honour, if this document could be given an

 5     exhibit number, please, marked for identification.

 6             JUDGE MOLOTO:  The document is admitted.  May it please be given

 7     an exhibit number and marked for identification.

 8             THE REGISTRAR:  Yes, Your Honours.  This document shall be

 9     assigned Exhibit P2911, marked for identification.  Thank you.

10             JUDGE MOLOTO:  Thank you.

11             MR. SAXON:

12        Q.   Could you please turn, General, to tab 21 of your binder.

13             MR. SAXON:  And can we please see XN-154, please.

14        Q.   General Simic, this is an order for anti-aircraft defence, is it

15     not?

16        A.   That is correct.

17        Q.   And we see, after -- the acronym PVO, we see some other acronyms

18     in smaller letters.  Can you tell us what that means, Op.Br.1?

19        A.   The heading literally states:

20             "Order for anti-aircraft defence, operational number 1."

21        Q.   Thank you.

22             And that is the seal of the 1st Krajina Corps next to the title?

23        A.   That is correct.

24        Q.   We see the word:  "Drina, attachment 11, copy number 1."

25             Could you turn to the last page of this document, please,

Page 10314

 1     General.

 2             And this document has been signed by Colonel Milosevic,

 3     Petar Milosevic, and according to his title here with the -- above --

 4     above the word "Colonel," he was the chief for anti-aircraft and

 5     artillery.  Is that right?  For the 1st Krajina Corps.

 6        A.   Not quite.

 7        Q.   Okay.  Please -- please clarify.

 8        A.   It is correct that that is the chief of the artillery and rocket

 9     units of the anti-aircraft defence of the Krajina Corps.

10        Q.   Okay.  Thank you very much for that.

11             MR. SAXON:  Your Honour, can this please be given an exhibit

12     number, marked for identification, please.

13             JUDGE MOLOTO:  It is so given an exhibit number.  May it please

14     be marked for identification.

15             THE REGISTRAR:  Yes, Your Honours, this document shall be

16     assigned Exhibit P2912, marked for identification.  Thank you.

17             MR. SAXON:

18        Q.   Can you please turn to tab 22 of your binder, General.

19             MR. SAXON:  And can we please see XN-155, please.

20        Q.   General, this is a list of documents related to the plan of

21     communications for the 1st Krajina Corps; isn't that right?

22        A.   This is a list of documents of the plan of communications of the

23     command of the 1st Krajina Corps.

24        Q.   Okay.  We see at the top right-hand corner, People's Defence,

25     state secret, Drina, attachment number 12, copy number 1.

Page 10315

 1             At the bottom of the page --

 2             MR. SAXON:  If we could scroll down, please.

 3        Q.   That's the seal of the 1st Krajina Corps, is it not?

 4        A.   Correct.

 5             MR. SAXON:  Can we move forward two pages, please.

 6        Q.   And this is an order for communications.  Am I right?

 7        A.   Absolutely.

 8        Q.   And we see the word "Drina" up top, "attachment 12, copy 1."

 9     Number 1, it says:  "Communications centres."  Towards the top of the

10     first page.  Is that what it says?

11        A.   Communication centres, yes, you are quite correct.

12        Q.   And if you could move forward two more pages.

13             MR. SAXON:  And scroll down.

14        Q.   We see this particular order came from Major-General Kelecevic.

15     Do you see that?

16        A.   Yes, I do.

17        Q.   And that's the seal of the 1st Krajina Corps?

18        A.   Yes, you're correct.  But it states the Chief of Staff of that

19     corps.  It states:  "Chief of Staff, Major-General," and then below that

20     "Kelecevic."  So he has a communications organ in his staff.

21        Q.   Very well.  Thank you.

22             And if you turn the page, General - if we go forward one more

23     page in e-court - we see here a chart for radio communications of the

24     1st Krajina Corps.  Correct?

25        A.   A chart for radio communications of the 1st Krajina Corps

Page 10316

 1     Command.

 2        Q.   Thank you for clarifying that.

 3             And in the upper right-hand corner we see:

 4             "People's Defence, state secret, Drina, attachment 1, copy 1."

 5             Below that we see the seal of the 1st Krajina Corps.  Do you see

 6     that?

 7        A.   Yes.

 8        Q.   Can you move forward one page, please.

 9             JUDGE MOLOTO:  How many more pages are you going to be moving

10     forward, Mr. Saxon?

11             MR. SAXON:  Six, Your Honour.  If you prefer, we can break now.

12             JUDGE MOLOTO:  If that is convenient for you.

13             MR. SAXON:  That's fine, Your Honour.

14             JUDGE MOLOTO:  We will take a break and come back at a quarter to

15     6.00.

16             Court adjourned.

17                           --- Recess taken at 5.20 p.m.

18                           --- On resuming at 5.47 p.m.

19             JUDGE MOLOTO:  Yes, Mr. Saxon.

20             MR. SAXON:  Thank you, Your Honour.

21        Q.   We're still looking at XN-155.  And, General Simic, if you could

22     focus on the document in front of you.

23             This document is an overview of times when frequencies must be

24     changed; is that right?

25        A.   That's right.

Page 10317

 1        Q.   And we see in the upper right-hand corner, it says:

 2             "People's Defence, state secret, Drina, attachment 1a, copy

 3     number 1."

 4             At the bottom we see the seal of the 1st Krajina Corps Command;

 5     is that right?

 6        A.   That's right.

 7        Q.   Thank you.

 8             MR. SAXON:  Can we please move to the next page, please.

 9        Q.   The next page, Mr. Simic, we see at the top centre, the seal of

10     the 1st Krajina Corps Command.  And this is a chart of radio

11     communications, is it not?

12        A.   That's right.

13        Q.   So this would show radio communications of -- between different

14     units of the 1st Krajina Corps.

15        A.   Between the 1st Krajina Corps Command and its subordinate units.

16        Q.   Thank you.

17             MR. SAXON:  Can we go to the next page, please.

18        Q.   On this page, we see - and if we could focus in on the top line

19     for a moment - this is a chart of coded communications for the Command of

20     the 1st Krajina Corps; correct?

21        A.   That's right.

22        Q.   And, first of all, we see in the middle of the page a series of

23     lines connecting circles and rectangles.  And then below that we see

24     additional rectangles with different items going down vertically.

25             This represents the fact that within coded communications there

Page 10318

 1     are different machines and different networks that are used.

 2        A.   Yes.

 3        Q.   And we see the seal of the 1st Krajina Corps Command at the

 4     bottom.  We see Drina at the top, attachment number 5, copy number 1.

 5             MR. SAXON:  Can we turn to the next page, please.

 6        Q.   This page is an overview of secret call-signs for the Command of

 7     the 1st Krajina Corps; is that right?

 8        A.   It is not entirely right.  We see what it says, overview of

 9     code-names for the 1st Krajina Corps Command.  But these are also

10     code-names of their subordinate units.

11        Q.   Okay.  And if we look over to the left-hand side, just beneath

12     the seal of the 1st Krajina Corps Command, in the second column we see a

13     list of commands, don't we?

14        A.   We see all of the participants in the chain of command of the

15     Krajina Corps and its superior, starting with the President of

16     Republika Srpska; number 2, the Government of Republika Srpska, and so on

17     and so forth.

18             The Main Staff of the VRS command post, the Main Staff of the VRS

19     rear command post.  So this relates to all of the participants from the

20     Krajina Corps Command down to their subordinates and also those above

21     them, their superiors, when communicating with them, they use encryption.

22        Q.   Okay.  Thank you for that.  If you move your focus toward the

23     right side of the page, we also see there, first of all, call-signs for

24     the Republika Srpska Krajina, is that right, and their corps?

25             JUDGE MOLOTO:  Which -- which side of the -- which column on the

Page 10319

 1     right side of the page, Mr. Saxon?

 2             MR. SAXON:  Your Honour, I'm referring to the second full column

 3     from the right edge of the page.

 4             JUDGE MOLOTO:  Thank you.

 5             MR. SAXON:

 6        Q.   And you see there across two columns at the top it says:

 7     "Republika Srpska Krajina."

 8             So in that section, General, we see the Government of the

 9     Republika Srpska Krajina and -- then followed by the Main Staff of the

10     Army of Srpska Krajina followed by the different corps of the Army of

11     Srpska Krajina; right?

12        A.   That's right.

13        Q.   Below that we see the words running across the two columns "Army

14     of Yugoslavia" or "Yugoslav Army."

15        A.   That's right.

16        Q.   And below that we can see the command of the VJ General Staff,

17     below that, the command -- the rear command of the VJ General Staff, and

18     a number of units below that.  Is that correct?

19        A.   Not entirely.

20        Q.   [Microphone not activated] Okay.  Please explain.

21        A.   You said the command, but that's not what it says.  It says the

22     General Staff of the Army of Yugoslavia, command post.  And then the

23     General Staff of the Army of Yugoslavia, rear command post, and so on.

24     That would be the exact translation.

25        Q.   Thank you very much for clarifying that.  Thank you.

Page 10320

 1             And if we go to the next page, please.

 2             The next page contains the telephone information or -- of

 3     particular officers; is that right?

 4        A.   Yes.

 5        Q.   Very well.  And we see in the upper left-hand side the seal of

 6     the 1st Krajina Corps.

 7             MR. SAXON:  Your Honour, I would seek to tender what is XN-155,

 8     marked for identification, please.

 9             JUDGE MOLOTO:  It's admitted into evidence.  May it please be

10     given an exhibit number and marked for identification.

11             THE REGISTRAR:  Yes, Your Honours.  This document shall be

12     assigned exhibit P2913, marked for identification.  Thank you.

13             JUDGE MOLOTO:  Thank you.

14             MR. SAXON:

15        Q.   General Simic, since Friday, we've looked at a lot of documents

16     related to the so-called Drina Plan, which is more formally titled the

17     directive for use of the Yugoslav Army, the Republika Srpska army, and

18     the Serb army of Krajina.  And you and I have looked at documents

19     produced by the VRS Main Staff that were sent to the corps level of the

20     VRS.  And we've looked at a number of documents produced by the

21     1st Krajina Corps and by the Sarajevo Romanija Corps.

22             The -- the preparations of these documents that we've looked at,

23     it would require thousands of man hours, wouldn't it?

24        A.   I can hardly say.  There were different levels at which this was

25     done.  I don't know how many levels exactly.  I can't be very specific

Page 10321

 1     about that, but it probably took some time, with many people involved, at

 2     different levels of command.

 3        Q.   When you say "it probably took some time," it probably took, at a

 4     minimum, a number of weeks of time; isn't that right?

 5        A.   Depending on the level of command.  It's very difficult for me

 6     say specifically.  I was not involved in producing these documents

 7     myself.  Therefore, I can hardly be expected to provide an adequate

 8     answer.  It depends on the level of training and all sorts of things.

 9     Someone might take two-hours to draft a document, another person might

10     take three hours for that same document.  That is what makes it

11     impossible for me to answer your question with a greater degree of

12     specificity.

13        Q.   Very well.  Thank you.

14             JUDGE MOLOTO:  Mr. Saxon, just before I forget, looks like you're

15     going to move to a new topic.  What do you plan to do with XN-133?

16             MR. SAXON:  I am --

17             JUDGE MOLOTO:  It has not been admitted.

18             MR. SAXON:  I ...

19                           [Trial Chamber and Registrar confer]

20             JUDGE MOLOTO:  Let me just check that this explanation accords

21     with your position.  I have been told that it was withdrawn because it

22     was a whole set of Drina Corps documents and because they were now

23     admitted separately, that is why it was withdrawn.

24             Is that it?

25             MR. SAXON:  In a nutshell that is correct, Your Honour, it has

Page 10322

 1     been withdrawn.

 2             JUDGE MOLOTO:  That's correct.  So I can write "withdrawn"

 3     against it.

 4             MR. SAXON:  Yes, Your Honour.

 5             JUDGE MOLOTO:  Thank you.

 6             MR. SAXON:

 7        Q.   I'd like to discuss with you, General Simic, part of the

 8     discussion that you had with Mr. Lukic last week.

 9             On page 10056 of the transcript, starting at line 25, to 10058,

10     line 2, you explained your position that the VJ, the VRS, and the SVK

11     were always separate and equal armies.

12             Do you remember that testimony?

13        A.   As I said, these were three different armies.  There is no

14     subordination there, no superiors and no subordinates, if that's what's

15     been recorded.

16             MR. SAXON:  Can we please show the witness P1896.  And so if he

17     could be given the binder that says P and D, please, and find the

18     tab P1896.

19        Q.   Take a moment to look at that document, please, General Simic.

20     These are the minutes from the official talk about transfer to the VRS

21     that were recorded on the 11th of September, 1994, in the office of the

22     Drina Corps Command, recruitment and personnel affairs section chief on

23     the occasion of transfer of Lieutenant-Colonel Erak, to the 30th

24     Personnel Centre.

25             And if you will follow me, General, you will see in the first

Page 10323

 1     full paragraph, it says that:

 2             "During the official talk, the above mentioned Erak was shown a

 3     written notice that his wife Zlata requested from a VJ senior in charge

 4     to return him to the service in the Zrenjanin garrison from which he was

 5     dispatched to the Republika Srpska Army ..."

 6             Do you see that?

 7        A.   Yes.

 8        Q.   And it continues:  "And so he also needed to express his opinion

 9     about his transfer ..."

10             And then with subletter (a) below that, subparagraph (a), we see

11     that Lieutenant-Colonel Erak said the following:

12             "No one asked me for opinion regarding my transfer to

13     30th Personnel Centre.  I have been transferred seven times so far, and I

14     am of the opinion that in accordance with Article 34 of the

15     above-mentioned decree, I should not have been transferred to VRS without

16     my personal consent; I have refused to be transferred ..."

17             Do you see that, General?

18        A.   Yes, I'm following you every step of the way, sir.

19        Q.   And then subparagraph (b) says:

20             "I have been transferred to the Army of Republika Srpska in

21     accordance with Article 58 of the Law on the Army of Yugoslavia.  And on

22     the same ground, I should not have and could not have been transferred to

23     the 30th Personnel Centre."

24             MR. SAXON:  And if we could please go to the next page in

25     English, please, and the next page -- if you could turn the page in your

Page 10324

 1     version.  And next page in English -- in the B/C/S version in e-court,

 2     please.

 3        Q.   And, General, if you focus on subparagraph (f), it says:

 4             "Based on the above-mentioned, I request to be returned to the

 5     Zrenjanin garrison from which I had been transferred to the Army of

 6     Republika Srpska as soon as possible ..."

 7             And then below that we see section 3:  "Conclusion of the senior

 8     who conducted the official talk."

 9             And, General, just to help us, the term "senior" here refers to

10     the senior officer who conducted the official talk; right?

11        A.   Yes.

12        Q.   All right.  And if we take a look at the conclusion of that

13     senior officer, it says -- first of all, it says:

14             "The corps command does not possess the personnel [sic] record of

15     the above-mentioned Erak, and so they could not confirm all of his

16     assertions."

17             JUDGE MOLOTO:  Not personnel record, personal record.  That's

18     what is written on the document.

19             MR. SAXON:  You're right, Your Honour, I stand corrected.  Thank

20     you.

21        Q.   After that, it says:

22             "The corps command senior personnel is manned with 23 per cent of

23     its capacity, so every senior is precious for performing duties."

24             Do you see that?

25        A.   I'm following you every step of the way, sir.

Page 10325

 1        Q.   And a few lines below that, it says:

 2             "He has been in the Army of Republika Srpska since

 3     13 December 1993 until now."

 4             And then it says:

 5             "Most of the seniors," that is, senior officers, "have various

 6     problems.  And if everyone's requests were granted, we would have no more

 7     seniors.  Should the request of the above-mentioned Erak be granted, we

 8     request that another senior be deployed here."

 9             General Simic, doesn't -- don't these conclusions of the senior

10     officer suggest that the VRS had a certain dependence on the VJ for

11     senior officers?

12        A.   I don't think that would be my conclusion.

13        Q.   Does -- doesn't this suggest a strong connection between the

14     senior officer corps of the VJ and the senior officer corps of the Army

15     of Republika Srpska?

16        A.   What sort of connection do you have in mind?

17        Q.   That members of the officer corps of the VJ are -- are filling

18     the senior officer positions of the Army of Republika Srpska.

19        A.   You're asking me about an area in which I'm no specialist.  I

20     don't want my answer to lead the Chamber to conclude something that is

21     erroneous.  There are persons that are witness who actually dealt with

22     this sort of issue.  I believe they will be better placed than I am to

23     provide a valid answer to that query.

24        Q.   You see, General Simic, you testified that these were separate

25     armies.  So, you see, it was you, actually, who provided your opinion,

Page 10326

 1     and that's what -- that's what I'm trying to explore with you.  And my

 2     question is, how separate, really, were they if they were sharing the

 3     officer corps?

 4        A.   I said at one point that there were three different armies.  Now

 5     that was not just my opinion.  It is an explicit assertion on my part.

 6     There are three different armies and three different chains of command.

 7             MR. SAXON:  I'd like to show the witness, please, P399.

 8             THE WITNESS: [Interpretation] I can't seem to track that down.

 9             MR. SAXON:  Can the usher please assist the witness to find the

10     tab that says P399.

11        Q.   If you could take a moment, General, to familiarise yourself with

12     this document.  It's from the General Staff of the Army of

13     Republika Srpska.  It has a number, confidential number 21/32-21, dated

14     the 3rd of February, 1994, and it's signed by Commander

15     Lieutenant-general Ratko Mladic.

16             And in the preamble it says the following -- in your version,

17     General, you will see General Mladic's signature on the bottom of the

18     second page.

19             And in the preamble it says:

20             "Pursuant to Article 26 of the Rules on travel and other expenses

21     in the VJ and in connection with the implementation of the decision

22     identifying tasks and territory of service under difficult (special)

23     conditions, the General Staff VJ, the sector for operations, confidential

24     number 1296-I of 19 October 1993, I hereby adopted the following decision

25     on compensation for military service in difficult (special) conditions."

Page 10327

 1             Let's just stick with the preamble for a moment, please, General.

 2     What General Mladic is saying in the preamble is that he adopted a

 3     decision as the commander of the Main Staff of the Army of

 4     Republika Srpska, based on the Rules of the Army of Yugoslavia and a

 5     decision of the General Staff of the Army of Yugoslavia?

 6             Doesn't that suggest that the VJ and the VRS were not so

 7     separate?

 8        A.   I find the question a little ambiguous.

 9        Q.   Well, we have a preamble from the commander of the VRS Main Staff

10     based on rules of the Army of Yugoslavia and a decision of the

11     General Staff of the Army of Yugoslavia.  Doesn't that suggest that these

12     two armies had some pretty strong connections?

13             You said they were separate armies.

14        A.   I said it, and I'm still saying it.  They were separate armies,

15     in terms of chain of command.

16             As for what you are asking about, my administration drafted a

17     command by the chief of the General Staff, saying that those officers

18     working under difficult circumstances would be paid a supplement.  Given

19     the fact that this went through the personnel centres and officers went

20     to join the VRS of their own free will, there was a need to deal with

21     their rights, given their status, and this was how it was done.  This

22     certainly in no way implies a chain of command.

23             Let me try to be even more specific.  If a chain of command was

24     implied here, then the documents from the Army of Yugoslavia would be

25     worded as commands to be dispatched to both Main Staffs, yet that is not

Page 10328

 1     the case.

 2        Q.   Well, just so that I understand your position, sir, in your

 3     previous testimony, you said, "The VJ, the VRS, and the SVK were always

 4     separate and equal," at page 10056 of the transcript to 10058.  And your

 5     position is now that they were separate armies in terms of chains of

 6     command; right?

 7        A.   You're asking me the same question in two different ways.

 8             I am not sure about how the word "equal" was interpreted the way

 9     I got it.  If you could explain what you mean by "equal," perhaps I can

10     go on and answer your question.

11        Q.   Well, I can't explain what you meant.  I can only read what is in

12     the transcript.  It was your testimony that -- that was translated as

13     "separate and equal."

14        A.   If I was misunderstood the first time around, let me try and

15     explain it now.

16             These are three different armies.  Each of these armies has its

17     own chain of command.  They are on an equal footing and on an equal

18     level.  There is no subordination in the sense of there being no

19     superiors or indeed subordinates.  I'm not sure if I'm making myself any

20     clearer now.

21        Q.   I think understand your testimony.  I want to focus on what you

22     just said, these are three different armies.

23             There were strong connections between the VJ, the VRS, and the

24     SVK; isn't that right?

25             JUDGE MOLOTO:  Yes, Mr. Lukic.

Page 10329

 1             MR. LUKIC: [Interpretation] I think the Prosecutor should explain

 2     what exactly he means by "strong connections."

 3             MR. SAXON:  Very well.

 4             MR. LUKIC: [Interpretation] In order to allow the witness to

 5     answer without being confused.

 6             JUDGE MOLOTO:  The first point I would like to raise is, haven't

 7     you asked this question already?

 8             MR. SAXON:  If I have, I shall move on, Your Honour.

 9             JUDGE MOLOTO:  I thought you did, actually.  Let's see if we can

10     get where you said it.  I don't want to gag you.

11             Okay, I'm not finding it quickly enough, so you might as well

12     answer the question.  And then Mr. Lukic wants to understand what you

13     mean by "strong connection."

14             MR. SAXON:  I'm going to rephrase.

15        Q.   At many different levels, General Simic, for example, the VJ and

16     the VRS had very strong relations; isn't that right?

17        A.   I'm not sure what you mean by "strong relations."

18             What exactly do you have in mind?  In an army, there can be

19     cooperation, there can be coordination, and there can be subordination.

20     There is no third -- no fourth kind of relationship.

21        Q.   Well, I -- I think I want to explore that with you a little bit

22     more.

23             JUDGE MOLOTO:  The strong connections were mentioned at page 69,

24     line 17.  Question was:  "Well, we have a preamble for the commander of

25     the VRS Main Staff based on the rules of the Army of Yugoslavia and a

Page 10330

 1     decision of the General Staff of the Army of Yugoslavia.  Doesn't that

 2     suggest that these two armies had some pretty strong connections?"

 3             MR. SAXON:  Yeah.

 4        Q.   I'm going to move on to -- if we can show the witness what is

 5     P741, please.

 6             MR. SAXON:  Actually, I am going to --

 7        Q.   If we take a look at this document, General -- do you have it in

 8     front of you?  P741?

 9        A.   Yes, sir, Mr. Prosecutor, I've got that, and I'm exceptionally

10     familiar this.  This was produced by my administration, and you will see

11     my initials there.

12        Q.   Very well.  And so this was the decision on determining the tasks

13     and territory where service is performed under difficult or (special)

14     conditions; right?

15        A.   That's right.

16        Q.   Okay.  And this is dated 22nd of March, 1994.  And, of course,

17     the second paragraph -- second full paragraph, after "Decision:  It

18     includes the territory where members of the 30th and 40th Personnel

19     Centres are in service."

20             MR. SAXON:  Can we now please show the witness P1810, please.

21             Can we assist the witness to find tab P1810.

22        Q.   This document is from Military Post 3001, Belgrade, that was the

23     30th Personnel Centre.  Correct, General?

24        A.   I assume so.  It has been a long time.  I can't be certain, but I

25     assume that that is the case.

Page 10331

 1        Q.   All right.  It's dated the 12th of May, 1994.  And it's a

 2     decision, says in the preamble:

 3             "Pursuant to Article 156 of the Law on of Army of Yugoslavia,

 4     published in the Official Gazette and in relation to the decision of the

 5     Army of Yugoslavia, chief of the General Staff, regarding the determining

 6     of tasks and territories where service is carried out under aggravated

 7     (exceptional) conditions, hereby issues the following ..."

 8             So it refers to the document that we saw a moment ago, which was

 9     P741, and then we see the decision:

10             "Mladic, son of Nedjo, Ratko, lieutenant-general, serving with

11     the military post 3001 Belgrade," that is the 30th personnel centre, "is

12     herewith entitled to compensation for service under aggravated

13     (exceptional) conditions as follows ..."

14             And so, subparagraph (a):  "In the amount of 20 per cent of his

15     basic salary.

16             And then subparagraph (b), it says:

17             "Increase of compensation mentioned under (a) in the amount of

18     blank per cent of the basic salary ... and the decision of the Commander

19     of Military Post 3001, Belgrade," and that would have been General Mladic

20     himself, "number 21/32-21, dated 3 February 1994."

21             And that last document mentioned there was Exhibit P399, which

22     was the decision of General Mladic from the Main Staff of the Army of

23     Republika Srpska that I showed you a moment ago, on compensation for

24     military service in difficult or (special) conditions.

25             So we see this document in front of us.  It's a document from the

Page 10332

 1     Army of Yugoslavia, from the 30th Personnel Centre.  It refers to the

 2     decision that you helped draft, regarding the determining of territories

 3     where service is carried out under aggravated conditions; that was P741.

 4             It refers to General Mladic as serving in Military Post 3001,

 5     that is, the 30th Personnel Centre.

 6             And then in subparagraph (b), it also relies on the decision of

 7     the Commander of Military Post 3001, Belgrade, which was actually

 8     General Mladic's decision issued by the VRS Main Staff.  That was P399

 9     that I showed you a few minutes ago.

10             So it seems, General, that this document show -- we have a VJ

11     decision about compensation to be paid to Ratko Mladic that's partly

12     based on a VRS decision issued by Ratko Mladic and partly based on a

13     decision of the VJ General Staff.

14             And my question for you is, doesn't this contradict your

15     proposition that these were two separate armies?

16        A.   Absolutely not.

17        Q.   I'm going to move on.

18        A.   Permit me to explain.

19        Q.   Please.

20        A.   We adopted a decision for certain compensation for work under

21     difficult circumstances, and the personnel administration of the 30th

22     Personnel Centre had the superior officer go to Republika Srpska, and the

23     chain of command in the Yugoslav Army was severed and that person became

24     a member of the chain of command of Republika Srpska, but their rights

25     stemming from the employment had to be resolved because of their families

Page 10333

 1     that had stayed in the territory of the Federal Republic of Yugoslavia.

 2     And from that point of view, we cannot mix up the chain of command with

 3     the exercise of certain rights and application of certain entitlements.

 4        Q.   Well, first of all, you told us earlier that -- I was asking

 5     about an area in which you're not a specialist but you seemed to be

 6     willing to get into that area for a moment at least.

 7             If I understand you -- you see, what I don't understand from your

 8     response, if we stick with the documents that we've been looking at,

 9     because I haven't asked you about a chain of command, I just don't

10     understand how, if you have a single document, and in this sense, in this

11     situation right now, we have a document issued by the Army of Yugoslavia

12     that incorporates in it -- and that document is referring to an officer

13     who is ostensibly serving in a position in the Army of Yugoslavia, but,

14     in reality, he is serving in a position in the Army of Republika Srpska,

15     and that same VJ document relies on a decision issued by that same

16     officer, which he issued in his capacity as an officer of the Army of

17     Republika Srpska, doesn't it suggest that, really, these two armies were

18     very mixed up together, rather than separate?

19             JUDGE MOLOTO:  Yes, Mr. Lukic.

20             MR. LUKIC: [Interpretation] I think that this is a really complex

21     question than Mr. Saxon would need to simplify it.  It's a question that

22     begins on page 25 [sic], line 10, and goes to line 21.

23             MR. SAXON:  I will simplify it.  I think that's a fair point.

24        Q.   Doesn't the document that you have in front of you indicate that,

25     really, the VJ and the VRS were really mixed up together, rather than

Page 10334

 1     separate?

 2        A.   No, that does not mean that, and I cannot really explain anymore

 3     this document.  I said that I was not an expert.  I've told you what I

 4     know.  I'm sure there are persons who are more qualified to explain.  I

 5     am not really able to give you any more detailed explanations.

 6        Q.   Very well.  Thank you.  I'm going to move onto another topic now.

 7             During your direct examination, you -- you described and you

 8     discussed with Mr. Lukic the work of the operations centre of the

 9     VJ General Staff, and you also talked about the daily reports issued by

10     that operation centre, and I just want to make sure that I understand

11     what your position is.

12             We saw a number of reports issued by that operations centre.  The

13     daily reports that I believe would have gone up to the chief of the

14     General Staff.

15             But my question for you is:  Is it your position that the

16     universe of information available to Momcilo Perisic when he was the

17     chief of the General Staff was limited to the contents of the daily

18     reports from the operations centre?

19        A.   I didn't understand whether you meant overall informations or

20     daily combat reports.  I would just like you to clarify that.

21        Q.   Okay.  I'll try to use your language.

22             Was that the only -- was the information contained in the daily

23     reports from the operations centre the only information available to

24     General Perisic about what was happening in the FRY in the conflict

25     areas?

Page 10335

 1        A.   No.

 2        Q.   All right.  And, so, for example, can we take look, please, at

 3     D200?

 4             MR. SAXON:  I think it might be helpful if we could assist -- do

 5     you have D200 there?  No, it's fine, General, do not worry.

 6             THE WITNESS: [Interpretation] Yes, if that is the document, D202.

 7                           [Prosecution counsel confer]

 8             MR. SAXON:  It was 65 ter -- it was 65 ter 1114D.  So that would

 9     be in another binder.  It's now Exhibit D200.

10                           [Prosecution counsel confer]

11             MR. SAXON:  I'm going to -- I'm going to try to do this another

12     way.

13        Q.   The 2nd Administration would send reports to the chief of the

14     General Staff, would it not?

15        A.   I explained that earlier, and if you allow me, when I said that

16     daily combat reports were not the only source of information, he also

17     received reports from the 2nd Administration, the Security

18     Administration, the Ministry of Interior, from State Security, from

19     certain government ministries and other sources, from the superiors

20     there.  These were sources of information for him.

21        Q.   Very well.

22             MR. SAXON:  Can we -- actually, I have hopefully hard copies.  I

23     do.

24             If we can please call up D222 on the ELMO, and I have a hard copy

25     for the witness.  If this could be given to him, please.

Page 10336

 1             JUDGE MOLOTO:  Have you now abandoned D200?

 2             MR. SAXON:  I have abandoned it, Your Honour.

 3             If we could see D222 on the screen, please.

 4        Q.   And you saw this, I believe, it was on Thursday, during your

 5     direct examination, General Lukic [sic].  It's discussed at pages 10094

 6     to 10095 of the transcript.

 7             And if you could please direct your attention to the first

 8     paragraph.  It's the intelligence report dated the 13th July, 1995.  And

 9     you will see it begins with information about how VRS units have routed

10     the 28th Division of the Muslim army from Srebrenica.

11             And if you'd please look at the last sentence of that paragraph,

12     it says the following:

13             "So far, about 50 per cent of Muslim residents" -- the last

14     sentence of that paragraph, General:

15             "About 50 per cent of Muslims residents have been evacuated from

16     the Srebrenica area; the evacuation of the remaining residents is made

17     difficult by a shortage of vehicles."

18             Do you recall that?

19        A.   I saw that report.

20        Q.   Absolutely.

21             MR. SAXON:  Now can we please show the witness what is

22     Prosecution Exhibit P855.  I have a copy for the witness.  If you could

23     show that to Mr. Lukic, please.

24             JUDGE MOLOTO:  I'm told these are confidential exhibits.

25             MR. SAXON:  Thank you, Your Honour.  If we could move to private

Page 10337

 1     session, please.

 2             JUDGE MOLOTO:  May the Chamber please move into private session.

 3                           [Private session]

 4   (redacted)

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 7   (redacted)

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10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

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22   (redacted)

23   (redacted)

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Page 10338

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Page 10339

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10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14                           [Open session]

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

16             JUDGE MOLOTO:  Thank you so much.

17             Yes, Mr. Saxon.

18             MR. SAXON:  Can we please see Exhibit P2169, please.  And that

19     should be in the witness's binder.

20             Actually, could we please go to -- no, I will stay with this

21     document for a moment.

22             If we could -- thank you.

23        Q.   This document is from the 5th of May, 1995.  And early May 1995,

24     General, that was the time of Operation Flash in Western Slavonia; is

25     that right?

Page 10340

 1        A.   Correct.

 2        Q.   Okay.  And we see that this particular document -- it's from the

 3     Main Staff of the Army of Republika Srpska.  And it's submitted to a

 4     number of corps, and the Main Staff of the -- a number of corps of the

 5     Army of Republika Srpska.

 6             And then in the second paragraph, in the second line, we see that

 7     it's submitted to the Main Staff of the Yugoslav Army.

 8             You see that?  Second line of the second paragraph.  Or it may --

 9        A.   Yes.

10        Q.   Thank you.

11        A.   Yes.

12               MR. SAXON:  And if we could move down the page, please.

13        Q.   We see that:

14             "The concern is that due to the new situation in the RSK and a

15     suspicion that the documents of the communications plan in Western

16     Slavonia have fallen into the hands of the enemy, the existing code-names

17     of the units and commands shall be changed, according to the

18     following ..."

19             And then we see a list of units, commands and different

20     code-names.  This particular document shows an ongoing relationship of

21     communication, doesn't it, between the Army of Yugoslavia, the VRS, and

22     the SVK?

23        A.   I did not dispute that there were communications there, no.

24        Q.   And this relationship was close -- so close that the VJ would

25     have the code-names of all of the units and commands of the VRS and the

Page 10341

 1     SVK; right?

 2        A.   The close relationship was a friendly relationship arising from

 3     the interest of the Army of Yugoslavia for the sake of its security to be

 4     constantly informed about what was going on in that area.  And to take

 5     timely measures in the Army of Yugoslavia in order to prevent any

 6     possible surprises or any threats to its own security.  From that aspect

 7     were these documents also in our possession.

 8        Q.   Thank you for that.

 9             And following up on the point that you just made, can we move

10     into private session, Your Honour, please.

11        JUDGE MOLOTO:  May the Chamber please move into private session. 

12     [Private session]      [Confidentiality lifted by order of the Chamber]

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

14             JUDGE MOLOTO:  Thank you very much.

15             Yes, Mr. Saxon.

16             MR. SAXON:  Can we show the witness what is Exhibit P2764,

17     please.  He might need the help of the usher to find that particular tab.

18     And I'm very grateful to the usher for her support today.

19                           [Prosecution counsel confer]

20             MR. SAXON:  I have just been informed it is not in the binder.  I

21     will check to see if I have a hard copy, which I do not.

22             I will skip this document.

23             If we could move back into public session, please.

24             JUDGE MOLOTO:  May the Chamber please move into open session.

25                           [Open session]

Page 10342

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

 2             JUDGE MOLOTO:  Thank you so much.

 3             Yes, Mr. Saxon.

 4             MR. SAXON:  Can we please show the witness P1824.

 5             This is not the ... this is not the document that I was expecting

 6     to see.  Is this P1824?  I'm asking -- this is P1824.  Then I'm going to

 7     move again away from this document.  I will try again.

 8             Can we please see P1933.

 9             Okay.  And if we could focus on the first half of this document,

10     please.

11        Q.   If you take a look at this document, General Simic, you'll see

12     that it is entitled:  "Situation and activities of the Serbian army of

13     Krajina, VRS, and VJ."

14             And then under number 1, we see:  "General features of the

15     situation and status of the activities."

16             Followed by the line:  "General Perisic's visit to the SVK 1st

17     Corps."

18             And in the first sentence of the first paragraph it says that on

19     the 8th and 9th of July, Momcilo Perisic visited the area of

20     responsibility of the 11th East Slavonian corps in an official capacity.

21     After he visited units of Baranjska Division on July 9th in the morning,

22     he convened a meeting of the 11th Corps Command and then left for Aljmas

23     accompanied by General Dusan Loncar, commander of the 11th Corps.  There

24     he met with Milan Milanovic, also known as Mrgud, assistant minister of

25     defence of the RSK."

Page 10343

 1             And then below that we see:  "The purpose and the main topic of

 2     these visits and meetings were to boost combat readiness of the Serbian

 3     army of Krajina in the occupied territories of Eastern Slavonia and

 4     Baranja, as well as to ascertain direction of further cooperation with

 5     the SVK and assistance to be provided to the Army of Yugoslavia."

 6             JUDGE MOLOTO:  To be provided --

 7             MR. SAXON:  "... by the army of Yugoslavia."  Thank you

 8     Your Honour.

 9             And again -- if we could stick with the first sentence of that

10     paragraph, General, if you help us understand, please, why was it

11     General Perisic's business to boost of combat readiness of the SVK?

12             JUDGE MOLOTO:  Mr. Lukic.

13             MR. LUKIC: [Interpretation] I would just like to ask, I don't

14     know if the witness was able to look at the whole document to see whose

15     document that was.  I don't think that we can see that from the first

16     page.  Perhaps before the General answers, he could look at the whole

17     document or perhaps the Prosecutor could tell him who actually generated

18     this document.

19             MR. SAXON:

20        Q.   Would you like do take a moment and look at the next page, if you

21     haven't had a moment to do that, General Simic?  Okay.

22        A.   I don't know who send the document.  It says here "intelligence

23     information," and then there's a number, class 8040895, then there's the

24     register number 512-06-06.  We don't use this kind of marking system so

25     this is why I'm asking where the document comes from.

Page 10344

 1        Q.   Well, I can only say that the document speaks for itself.  The

 2     document says what it says.

 3        A.   Well, it's not quite like that, sir.  If the document came from

 4     the intelligence administration of the other side, perhaps deliberately

 5     misrepresented the situation, so -- as to the contents of the document,

 6     so this is why I'm asking you who generated the document because it does

 7     not seem to be in Serbian.

 8             JUDGE MOLOTO:  Can we see the last -- the last page of this

 9     document in the English version, please.

10             MR. SAXON:

11        Q.   Chief Davor Domazet.  So this would have been generated by a

12     Croatian officer then.  I'm just trying to answer your inquiry.

13        A.   Croatian officer, yes.  I could tell by the style, by the

14     language, that that was that.  That's the style.

15             So if you understood me, that the intelligence administration

16     could be planting some information, then it's possible that that was so,

17     but I cannot know whether Perisic was there or not.  It's something that

18     I cannot confirm.  I does not have to be accountable to me.  I am the one

19     who is accountable to him.

20        Q.   Thank you.

21             MR. SAXON:  Your Honour, I see the time.  Shall we stop there for

22     the day?

23             JUDGE MOLOTO:  Indeed, we shall.

24             Once again, sorry, Mr. Simic, I am going to be saying this for as

25     long as you are in that witness seat; you may not discuss the case with

Page 10345

 1     anybody, and especially not with your lawyers.

 2             We come back court, sir, tomorrow again at quarter past 2.00,

 3     Courtroom I, same court.

 4             Court adjourned to quarter past 2.00, Courtroom I, tomorrow

 5     afternoon.

 6                            --- Whereupon the hearing adjourned at 7.06 p.m.,

 7                           to be reconvened on Tuesday, the 2nd day of March,

 8                           2010, at 2.15 p.m.

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