Tribunal Criminal Tribunal for the Former Yugoslavia

Page 19641

 1                           Wednesday, 23 May 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.06 a.m.

 5             JUDGE ORIE:  Good morning to everyone.

 6             Madam Registrar, would you please call the case.

 7             THE REGISTRAR:  Good morning, Your Honours.

 8             This is the case IT-03-69-T, The Prosecutor versus

 9     Jovica Stanisic and Franko Simatovic.

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             Just a few procedural matters.

12             First, could I have the estimates from the parties on the

13     cross-examination of Mr. Vujovic.

14             MR. JORDASH:  Thirty-five to 40 minutes, Your Honour.

15             JUDGE ORIE:  Remaining.

16             MR. JORDASH:  Yes.

17             JUDGE ORIE:  Yes.

18             Ms. Friedman.

19             MS. FRIEDMAN:  Approximately two and a half hours, Your Honour.

20             JUDGE ORIE:  Which means that the cross-examination will be

21     concluded today, and perhaps even if re-examination doesn't take too much

22     time, we might even conclude the whole of the testimony of Mr. Vujovic.

23             The chances that the next witness will appear today are very

24     limited, I would say.

25             MR. PETROVIC: [Interpretation] Your Honour, our assessment

Page 19642

 1     tallies with your own.  The next witness will then be prepared to start

 2     testifying tomorrow morning.

 3             JUDGE ORIE:  Yes.  Then the next witness has been scheduled for

 4     how long, Mr. Petrovic?

 5             MR. PETROVIC: [Interpretation] Your Honour, the original

 6     assessment for him was three and a half hours.  However, the proofing

 7     will be done today, and I believe that the time required for

 8     examination-in-chief will be somewhat shorter.

 9             JUDGE ORIE:  Yes.  Well within a day; is that ...

10             MR. PETROVIC: [Interpretation] Yes, Your Honour.

11             JUDGE ORIE:  I'm asking you these questions because the witness

12     who will be re-called for further cross-examination would not be able to

13     travel any earlier than the 29th of May, if I understand well.  If he

14     would travel on the 29th of May, then there's a fair chance that

15     cross-examination of the next witness could be concluded on that same

16     29th of May, and that, as far as I understand, that the Prosecution is

17     ready to start cross-examining -- the further cross-examination of that

18     witness on the 30th of May.

19             MS. MARCUS:  That's correct, Your Honour.

20             JUDGE ORIE:  So if the parties could please keep in mind this

21     schedule:  Today, conclude Mr. Vujovic; tomorrow and Tuesday for the next

22     witness; and then the further cross-examination of Mr. Novakovic to start

23     at Wednesday.

24             MS. MARCUS:  Your Honour, I'll try and find information as to how

25     long we anticipate using in cross-examination of the next witness.  I

Page 19643

 1     think that would assist --

 2             JUDGE ORIE:  Yes.  If that -- the biggest risk would be that we

 3     could not start on Wednesday right at the beginning of the day but only

 4     in the course of that -- of that afternoon because we're scheduled to sit

 5     Wednesday, the 30th, in the afternoon.

 6             MS. MARCUS:  Yes, Your Honour.

 7             JUDGE ORIE:  VWS can be informed accordingly, Madam Registrar.

 8             Then could the witness be brought -- could Mr. Vujovic be

 9     escorted into the courtroom.

10             MS. FRIEDMAN:  Your Honours.

11             JUDGE ORIE:  Ms. Friedman.

12             MS. FRIEDMAN:  Just while the witness is being brought in,

13     there -- I'D just like to note for the record there may be a question

14     relating to a term that he used yesterday in relation to a specific task

15     that -- there is some question about the proper English term for

16     debugging; in other words, securing a location, removing listening

17     devices, and so there may be some question about that.  Perhaps it will

18     arise today.

19             JUDGE ORIE:  Yes.  Well, we have not many native English speaking

20     persons, but at least a few that's --  yes, Mr. Petrovic.

21             MR. PETROVIC: [Interpretation] Yes, Your Honour.  Yes,

22     Your Honour, it seems to me that that resolves the problem that we had

23     yesterday pertaining to the last question that was put by my colleague

24     yesterday afternoon.  That was it precisely.  That actually resolves the

25     problem.


Page 19644

 1                           [The witness takes the stand]

 2             JUDGE ORIE:  Good morning, Mr. Vujovic.  Please be seated.

 3             THE WITNESS:  Good morning, sir.

 4             JUDGE ORIE:  I would like to remind you that you're still bound

 5     by the solemn declaration you gave at the beginning of your testimony.

 6     That you'll speak the truth, the whole truth, and nothing but the truth.

 7                           WITNESS:  RADE VUJOVIC [Resumed]

 8                           [Witness answered through interpreter]

 9             JUDGE ORIE:  And Mr. Jordash will now continue his

10     cross-examination.

11             MR. JORDASH:  Thank you, Your Honours.

12                           Cross-examination by Mr. Jordash: [Continued]

13        Q.   Good morning, Mr. Witness.

14        A.   [In English] Good morning.

15        Q.   Let's return just briefly to the subject we left yesterday and

16     that's the issue of the work you did - excuse me - when you first met

17     Mr. Stanisic [Realtime transcript read in error "Simatovic"].

18             You were - is this correct? - assisting him with debugging a

19     premises, checking that --

20             MR. PETROVIC: [Interpretation] Your Honour, I think that it's

21     clear that in line 11, the name was misspelled or rather my learned

22     friend referred to another name, not the one in the transcript.

23             MR. JORDASH:

24        Q.   Let me start that again, just so that it's clear what I'm asking

25     you.

Page 19645

 1             I'm asking you about the work that you did when you first met

 2     Mr. Stanisic that we touched upon yesterday.  Is it correct that you were

 3     asked to assist the Serbian DB in relation to debugging a premises,

 4     checking that a premises was not bugged by another service?

 5        A.   [Interpretation] Yes, that is correct.  There was this particular

 6     facility, and I was there to help in checking that facility.

 7        Q.   Thank you.  Now, we concluded yesterday with a brief discussion

 8     about your relationship with Mr. Stanisic and the fact that you did not

 9     socialise with him, neither did you have a close professional

10     relationship with him; is that correct?

11        A.   I had no private contacts with him.  My only contacts with him

12     were professional, to the extent to which it was necessary, due to the

13     nature of our work; that is to say, the head of the service and someone

14     who was at a lower level.  That is to say, it was only a working contact.

15        Q.   Can you recall the last time you spoke to him?

16        A.   Well, I think it was official.  During hand-over of duty when

17     Mr. Stanisic was replaced, the new head of service had a collegium

18     meeting and Mr. Stanisic attended.  That was the last time.

19        Q.   I want to just be clear about this.  You -- you said:  "Well, I

20     think it was official."

21             Are we -- when -- sorry, let me start that again.

22             The last time you spoke to him, either professionally or

23     personally, was at the time when Mr. Stanisic was replaced in 1998;

24     correct?

25        A.   It was official.  After that, possibly we had a conversation

Page 19646

 1     because it so happened that we shared the same doctor who treated us.

 2     Perhaps we met under such circumstances, if you could call that a private

 3     conversation.  But there was nothing else.

 4        Q.   When might that have been?

 5        A.   It could have been 2000, 2001, roughly.  I cannot remember

 6     exactly.

 7        Q.   But before -- no, I'll leave that.

 8             You haven't been contacted by Mr. Stanisic's Defence team; is

 9     that correct?

10        A.   No.  No one talked to me.

11        Q.   I want to ask you just very briefly if you recall an incident or

12     a conversation you had with Mr. Stanisic in approximately 1993 or 1994

13     concerning your brother and his contacts with the Mira Markovic political

14     group.

15             Do you recall that conversation?

16        A.   Well, at the time, my brother had a private business, and he

17     actually worked in a company that was co-owned by one of the high

18     officials of the then-political party that was called Jul.  It was headed

19     by Mrs. Markovic.

20             As for speaking to Mr. Stanisic, well, generally speaking,

21     Mr. Stanisic insisted that at collegium meetings -- actually, he insisted

22     at collegium meetings that members of the service should not be involved

23     in political parties.  And when it came to me, I said that my brother was

24     involved in this private business and that I had no other contact with

25     that whatsoever.

Page 19647

 1        Q.   So basically you were concerned, weren't you, that your brother's

 2     contacts with Milosevic's wife and her political party was going to get

 3     you into trouble with Mr. Stanisic; is that correct?

 4        A.   Well, it's not that I was concerned.  I mean, I was outside all

 5     of that.  My brother was in business.  I did the work I did.  And I knew

 6     what the position of the service that I was in was.  And I personally

 7     agreed with that; namely, that people who were in this line of work

 8     absolutely should not be involved in any kind of political party

 9     activity, no matter what the name of that party may be.

10        Q.   Okay.  Let me put it a bit differently then.

11             You knew that Mr. Stanisic had a policy, had a strong position,

12     that members of the service should not be members of political parties or

13     associate with them; correct?

14        A.   Absolutely, yes.  And very often at collegium meetings, he

15     highlighted that.

16        Q.   So knowing that he held that position, you went along to him to

17     give him the information that it was your brother who was involved and

18     you had nothing to do with it; correct?

19        A.   Yes, exactly.

20        Q.   Do you recall what Mr. Stanisic would say at collegium meetings

21     concerning non-involvement with Milosevic's wife's political party, or

22     Milosevic's political party, or any political party?

23             What was his stated position and how did he put it?

24        A.   He put it very explicitly, and he spoke very clearly.  As I've

25     already said, in view of the times, very complicated times then, I think

Page 19648

 1     that he found it necessary to point that out at practically every

 2     collegium meeting so that members of the service would not, under any

 3     circumstances, be involved in activities of political parties, in any

 4     way.

 5             This was a very resolute position that he took, and I think that

 6     almost all of us absolutely agreed with that.

 7        Q.   In may be obvious, but just to finish this subject, why -- why

 8     was it agreed by absolutely everyone?  Why did you agree with that?

 9        A.   Well, because I believed then, and I believe now that the essence

10     of the activity of a security service is protection of the state and

11     people, not this or that regime or this or that political party.  It's

12     very simple.

13        Q.   Thank you.

14             Now, yesterday you spoke about the - and I think use your word -

15     "merger" of the Serbian State Security Service and the federal

16     State Security Service.  And you were asked at - Your Honours, page

17     19570, line 11 - whether anyone was expelled from the federal State

18     Security Service.  And you confirmed that everyone received a job offer.

19             How many people were in your department who were given a job

20     offer and took up the job with the Serbian State Security Service?

21        A.   As I said yesterday, each and every individual was given a job

22     offer to stay on; namely, to keep the jobs that they already had in the

23     State Security Service.  Quite literally everyone.  I'm not aware of

24     anyone from the entire DB, of the entire federal service, especially my

25     department, that was dismissed.  So I absolutely claim that I know of no

Page 19649

 1     such case.  Not everyone wanted to accept the job offers made to them

 2     though.

 3        Q.   Mr. Vujovic, let me just be specific.  How many people from your

 4     department took new jobs with the Serbian State Security Service?

 5        A.   That's just what I started explaining.

 6             From my service, eight people, I think.  Maybe it's one or two,

 7     more or less, did not accept these job offers.  And, at that time, the

 8     department had 112 people.

 9             So eight or nine people did not accept.

10        Q.   And the people who accepted job offers, they came from a variety

11     of tasks within the federal State Security Service; is that correct?

12        A.   No.  These eight or nine persons I mentioned already.  I'm

13     talking about the 8th Administration.  In my administration, out of 112

14     employees, eight of them, or nine of them, did not want to accept this

15     job offer.  So I'm talking about the 7th Administration.

16             In other administrations of the federal DB, there were also a

17     number of people, again, a very small number of people, mainly

18     Montenegrins, did not accept these job offers and did not sign.

19        Q.   You said yesterday there was a merging of your department with

20     the State Security Service department.  Was there any changes to the job?

21        A.   Well, practically the MUP, or, rather, the state security of

22     Serbia, blended into the work of the 7th Administration of the federal

23     MUP.

24             I said at one point yesterday that we went on, that is to say,

25     the basic activity continued normally, but our obligations were increased

Page 19650

 1     because now we had to work with the centres of security and in view of

 2     the technology that was there.  However, before the merger, the federal

 3     security did not have that obligation.

 4        Q.   So did you take over part of the documentation that was

 5     already -- sorry, let me put it differently.

 6             The documentation that had been part of the federal service then

 7     transferred to the state security of Serbia's possession; correct?

 8        A.   I would not use that term, "transferred."  Everything stayed on

 9     the same premises.  Everything was brought together.  It's just the

10     personnel that came to the 7th Administration.  But all the documentation

11     remained where it had been.

12        Q.   Thank you.  You spoke yesterday at page 19573 about the decision

13     that was required by the president of the Supreme Court in order to apply

14     operative methodology.

15             How do you know that this decision worked in practice, or this

16     process worked in practice?

17        A.   There's a procedure that was carried out by the operative line of

18     work.  They had to give detailed explanations to the president of the

19     Supreme Court, explaining why they wanted that measure to be applied,

20     vis-a-vis a particular person.

21             As far as operative technology is concerned, the president of the

22     Supreme Court had to reach a decision, and we would apply these measures

23     only on the basis of such a decision.

24             As for the procedure, that took place outside our technical

25     service.  That was done apart from us.  But the basis for everything that

Page 19651

 1     was done was a decision made by the president of the Supreme Court.

 2        Q.   And how do you know that?  I want to understand how you know this

 3     was put into practice, in reality, rather than just being a rule which

 4     everyone ignored.

 5             Do you follow me?

 6        A.   No, I absolutely follow that.  As head of the department, I would

 7     not have acted on any of this had there not been the proper documentation

 8     because that would have been illegal.

 9             We received these requests from an appropriate line of work where

10     it said that the measure had to be applied on the basis of a decision

11     reached by the president of the Supreme Court made on such and such a

12     date, registered under such and such number, so it was a proper document,

13     and we would act only on that basis.

14        Q.   And just so that we're clear, you saw this practice from the time

15     you joined the Serbian State Security Service throughout the whole of the

16     time Mr. Stanisic was the chief; correct?

17        A.   Absolutely, yes.

18        Q.   You said yesterday at page 19574 that:

19             "Pursuant to Mr. Stanisic's decision, in our building, there was

20     an extra --" sorry, "an ex-territorial space, as it were.  There was an

21     office to which only the president of the Supreme Court had a key.  He

22     had his office, and he had his documents there, and he was the only

23     person who could independently avail himself of that space."

24             Again, how do you know, first of all, that that was pursuant to

25     Mr. Stanisic's decision; and, secondly, how do you know that he was the


Page 19652

 1     only person who had the right to enter that office?

 2        A.   How do I know?  I was told that that's how things were organised,

 3     that that was a room with an extra territorial [as interpreted] status

 4     and that only the president of the Supreme Court could enter it, and that

 5     if they requested additional papers, additional documents, that we should

 6     help them -- or, rather, help him in his decision-making process.

 7        Q.   So that you were told -- and you were told that, We should help

 8     him, the president.  Was this common knowledge, or do you recall who told

 9     you, or do you recall, in fact, providing additional information for the

10     president to make his decision?

11        A.   At one of the collegium meetings it was said officially what the

12     status of the room was.

13             Mr. Stanisic told us that, officially.  And we were told that we

14     should respect that procedure and that the president of the court had to

15     be helped, if he needed help.  And that was communicated officially, and

16     those who were sitting at that collegium meeting were those who had to

17     know that.

18        Q.   Thank you.

19             MR. JORDASH:  Can we go into private session, please.

20             JUDGE ORIE:  We move into private session.

21             [Private session] [Confidentiality partially lifted by order of the Chamber]

22             THE REGISTRAR:  We're in private session, Your Honours.

23             JUDGE ORIE:  Thank you, Madam Registrar.

24             MR. JORDASH:  Thank you.

25        Q.   Mr. Vujovic, just dealing with the issue of radio monitoring from

Page 19653

 1     Pajzos and the other locations, excuse my simplicity, but you were

 2     listening into telephones of everyone or targeted telephones of people of

 3     interest?

 4        A.   The part of the radio spectrum, if it so happened, if we

 5     intercepted a telephone link, the control of the radio spectrum is the

 6     least of that in its scope.  And when it came to deciding on what was

 7     important and what is not, came from the intelligence line of work.  We,

 8     as those who handled the equipment and who were physically involved in

 9     intercepting those conversations, did not have a say in that.

10        Q.   Sorry, just -- I think I might have mixed up a couple of things

11     here.

12             You were monitoring radios, correct, and you could also pick up

13     telephone communications; correct?

14        A.   The monitoring of telephone communications was organised in a

15     different way, generally speaking.  And the control of the radio

16     spectrum, if you are able to intercept links between two different points

17     which also involved wireless telephone communication, you could also

18     control some of the telephone communications, obviously if there was

19     interest in doing so.

20        Q.   So am I correct, then, you -- you actually cannot testify as to

21     whose communications were being monitored?

22        A.   You always focus on an area, and then, in the part of the process

23     that is referred to radio monitoring, you also try to identify who the

24     people are.  In principle, you don't know in advance who will be

25     intercepted and what means of communication they will use.  But in

Page 19654

 1     operative sense, you do what we call triage in order to conclude whether

 2     things are worth monitoring, whether they can be monitored or not, and

 3     the decision lies in the hands of the intelligence line of work.  And as

 4     for whether it can be monitored, that's up to us.  We were the ones who

 5     decided on whether it was possible.  But what I'm saying is that when you

 6     start monitoring a certain area, you don't know what you're going to

 7     intercept and whose conversations you're going to intercept.

 8        Q.   But you, or at least your department, then, would receive

 9     instructions concerning the type of material that the intelligence line

10     of work was interested in; correct?

11        A.   Of course.

12        Q.   You were not privy to those instructions?

13        A.   No, no.  As head of administration, I had to organise work, and

14     for the rest, it was arranged directly between the intelligence line of

15     work and the surveillance equipment operators.  There was no need for

16     anybody else to get involved in that.

17        Q.   Thank you.

18             Now, just one last subject, if I may:  The JATD and your dealings

19     with Tepavcevic.  You testified yesterday at page 19620 that when it came

20     to receiving orders in relation to the JATD, you received them from --

21     for the most part, from Tepavcevic.

22             What kind of orders did you receive from Tepavcevic in relation

23     to your work in the JATD?

24             Let me be specific.  What kind of orders, if at all, relating to

25     logistics, did you receive?

Page 19655

 1        A.   We, in the 7th Administration, provided logistical support to the

 2     JATD in the command facility in Lipovica.  I already spoke about that

 3     yesterday, and the support that we provided was putting in place some

 4     technical equipment, like satellite television, security systems,

 5     cameras, telephone lines that had to be re-routed, and the requests we

 6     received from them concerned only such things.  I don't remember any

 7     other requests; requests of a different nature, that is.

 8        Q.   Sorry, how did it work then?  Are we talking about your

 9     administration going through Tepavcevic in order to get these various

10     logistics to supply to the JATD?

11        A.   I don't know if that was all of the logistics.  I can only talk

12     about our work.

13             The 7th Administration was the only --

14        Q.   No, sorry to -- I -- I'm probably -- I still probably haven't

15     woken up yet.

16             Let me try to be as specific as I can.  As far as you're

17     concerned, you went to Tepavcevic if you needed these types of

18     logistics - is that correct?  - like satellite TV, like items for a

19     security system.  Things that you had been asked to provide to the JATD,

20     you went to Tepavcevic; is that right?

21        A.   No, no.  It was much simpler than that.

22             Tepavcevic would simply dial the number of my office and he would

23     tell me, Send some men over there.  Things need to be done.  They will be

24     told over there what needed to be done.

25             It was done in that way all the time.  It was us, helping them

Page 19656

 1     with certain things.  That's the kind of support we provided to them.

 2        Q.   So, as far as you could see, from your -- well, let me start that

 3     again.

 4             How -- how often were you privy to Tepavcevic taking these

 5     logistical and organisational steps?  Is it daily, weekly, monthly?

 6        A.   It was not on a daily basis, I'm sure.  It was done as needed.

 7     Things would be done once, and then there was no need to do them again.

 8     A request would come once in two or three months.  Very rarely those

 9     requests for assistance would come our way.

10        Q.   But, as far as you were concerned, when they did come, they came

11     directly from Tepavcevic; correct?

12        A.   Yes.

13        Q.   Nothing further.  Thank you, Mr. Vujovic.

14             MR. JORDASH:  Thank you, Your Honours.

15             JUDGE ORIE:  Thank you, Mr. Jordash.

16             Ms. Friedman, are you ready to cross-examine the witness?

17             MS. FRIEDMAN:  Yes, Your Honour.  Thank you.

18             JUDGE ORIE:  Mr. Vujovic, you'll now be cross-examined by

19     Ms. Friedman.  Ms. Friedman is counsel for the Prosecution.

20             And since we are still in private session, we first move into

21     open session again.

22             MS. FRIEDMAN:  Actually, I will --

23             JUDGE ORIE:  Oh, you would like to start in private session.

24             MS. FRIEDMAN:  Yes, I will make use of the private session.

25             JUDGE ORIE:  Yes.  Then we leave it as it is for the time being.

Page 19657











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Page 19658

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22                           [Open session]

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

24             JUDGE ORIE:  Thank you, Madam Registrar.

25             MS. FRIEDMAN:


Page 19659

 1        Q.   Mr. Vujovic, you testified that while the

 2     Socialist Federal Republic of Yugoslavia existed, the operations

 3     equipment of the federal service was best equipped; correct?

 4        A.   Yes, that is correct.

 5        Q.   It is also -- is it also the case that the federal MUP had secure

 6     communication networks with the MUPs of the republics?

 7        A.   There was a communications administration in the federal service,

 8     and they were in charge of the communications system.  There was a system

 9     of special communications between the republican services and the federal

10     service.

11        Q.   I take it this system was more expensive than the networks and

12     capabilities between the republican MUPs, the republic services?

13        A.   I'm afraid I don't understand your question.

14             What system do you have in mind?  You said that it was more

15     expensive, but what system are you talking about?

16        Q.   I think that was a miscommunication.  I intended that it was more

17     extensive.  In other words, more elaborate.  The federal MUP could

18     communicate with each of the republics, and I'm putting to you that they

19     must have had a better, more integrated system than the individual

20     republics did.

21        A.   You are asking me about the communications system.  The

22     7th Administration had nothing whatsoever to do with that system.  So I

23     can only talk in principle as an engineer.  I can talk about things being

24     more or less complicated.  But if you want me to talk about that from the

25     perspective of my job, that was outside of the scope of my work

Page 19660

 1     obligations.

 2        Q.   So the area of securing communications was not within your work

 3     obligations?  Is that your evidence?

 4        A.   There was a special unit.  Its name was the administration for

 5     communications and encryption.  And it was that administration's

 6     responsibility to provide secure and stable communications at the top of

 7     the state and communications between the state security sector, the

 8     federal service, and the services of the republics.

 9        Q.   Okay.  And the technical equipment that you worked with as well

10     as this technical equipment, if you can comment, those became part of the

11     Serbian MUP after they took over; is that correct?

12        A.   Of course.

13        Q.   You testified that this takeover by the Serbian MUP was actually

14     a merger between the two services.

15             My understanding of your evidence is that it appeared to you as a

16     merger because you and all the members of your department continued to do

17     the same work at the same location after it happened.

18             Have I understood your evidence correctly?

19        A.   That was just the formal part of what I think.  The essence of

20     the merger was this:  There were no longer two services in one territory.

21     That was the essence of that merger.  In practice, this meant that none

22     of us changed their jobs.  We remained in the same place doing the same

23     work.  The essence of the merger was that there were no longer two

24     services involved in the same kind of work in one area.

25             That was the essence of that thing.

Page 19661

 1        Q.   And you were not present during the actual takeover of the

 2     building; is that correct?

 3        A.   You mean physically present at a certain point in time?  Of

 4     course not.  On that day, I arrived at my workplace in the morning.  I

 5     entered the perimeter of the building.  I was authorised to do that.  I

 6     entered my office.  And, as every day, we had our first coffee and -- the

 7     collegium meeting, and then the chief informed us that the merger had

 8     taken place and that we should now look at the possibilities of

 9     accommodating new people and things like that.  Nothing dramatic took

10     place.

11        Q.   Thank you, Mr. Vujovic.  And I'm just going to ask you to please

12     try to focus on my question because, to some extent, you're repeating

13     information, and I will ask you if I need more detail, okay?  So, if

14     possible, please just try to answer with a yes or no, if the question

15     requires that.

16             So my next question is whether or not you were present at any

17     meetings or planning sessions before that morning.  I take it that you

18     were not?

19        A.   No.

20        Q.   So you personally do not have information about the actual reason

21     for the takeover, other than what you surmised after the fact; correct?

22        A.   I believe that what I've just told you is the essence of the

23     whole matter.  I don't know of any other reasons or ...

24        Q.   Thank you.  And you did not work in the federal MUP archives, did

25     you?

Page 19662

 1        A.   No, never.

 2        Q.   And when you moved to the Serbian MUP, again, you did not have a

 3     role in maintaining the archives or the filing system, did you?

 4        A.   Absolutely not.  But maybe I can be allowed to explain.

 5             As operations equipment staff, we maintained technical

 6     documentation.  The technical documentation was not filed.  It was our

 7     obligation to file it - if this is what you could call archives -

 8     because technical documentation is living archives.  It's not a proper

 9     archives, as the rest of the documents that were filed.

10             So that technical documentation was kept by us, always.

11        Q.   Okay.  And you testified that you did not know Milorad Davidovic;

12     correct?

13        A.   No.

14        Q.   And do you recall that you were shown a document that he

15     compiled.  And when you were asked about that document, you stated:

16             "It is unusual that someone from the lower structures in the

17     service writes a report and says, Personally to the minister.  That is

18     impossible."

19             Now, I understood that you based your answer on your own

20     experience in writing your reports; is that right?

21        A.   Of course, I based that on my own experience.

22             However, when you communicate with the minister, only the inner

23     circle of the chief of the federal service, i.e., his assistants and

24     chiefs of administrations, could use those words, To the minister

25     personally.

Page 19663

 1        Q.   However, in relation to this report, I'd like to put to you that

 2     you do not have any personal or direct knowledge about it, so you would

 3     not know if there was any reason why would it -- why it would not have

 4     followed the usual reporting line; is that correct?

 5        A.   I cannot speak about reasons.  I don't [as interpreted] know what

 6     was the normal way of communicating with the chief of service.

 7        Q.   I would now like to ask -- to ask you more --

 8             JUDGE ORIE:  Mr. Petrovic.

 9             MR. PETROVIC: [Interpretation] Your Honour, the last sentence in

10     the answer was uttered in the B/C/S without a negation, without -- in a

11     different form.

12             JUDGE ORIE:  Perhaps I read to the witness how it appears in the

13     transcript.

14             Your last answer was translated and transcribed in the following

15     way, and please correct me when it does not reflect exactly what you

16     said.  You said, when asked whether you would know at all what may have

17     been the reasons not to follow the usual reporting line, you said:

18             "I cannot speak about reasons.  I don't know what was the normal

19     way of communicating with the chief of service."

20             Is that what you said or ...

21             THE WITNESS: [Interpretation] No.  I said that I know what the

22     normal way of communicating was.

23             JUDGE ORIE:  That's hereby corrected.

24             Please proceed, Ms. Friedman.

25             MS. FRIEDMAN:  Thank you, Your Honour.


Page 19664

 1             May we go into private session.

 2             JUDGE ORIE:  We move into private session.

 3             [Private session] [Confidentiality partially lifted by order of the Chamber]

 4             THE REGISTRAR:  We're in private session, Your Honours.

 5             JUDGE ORIE:  Thank you, Madam Registrar.

 6             MS. FRIEDMAN:

 7        Q.   I would like to find out some more information about the various

 8     locations where the 7th Administration established posts.

 9             Now, the Pajzos facility that you testified about yesterday, when

10     was that set up?

11        A.   May I just say something before that?

12             These are not the premises of the 7th Administration - please -

13     Pajzos, the Pajzos facility, to the best of my knowledge, started working

14     in 1991 or 1992, and we got involved only in 1993, the

15     7th Administration, when we set up the third department.

16             But I know there were activities before that from 1991 onwards.

17     I know that when I talked to the group that had been involved beforehand.

18        Q.   Okay.  So you know of activities at that location from 1991

19     onwards.  And you arrived in 1993; is that correct?

20        A.   From 1993, especially 1994, people started going to this location

21     as well.

22        Q.   And you testified that there were about -- just under ten people

23     at Pajzos in terms of those surveilling and those providing translation

24     and interpretation; is that correct?

25        A.   Yes, that's right.

Page 19665

 1        Q.   And about a dozen more people securing the facility.  That's

 2     correct?

 3        A.   I did not mention a dozen of -- or so.  I don't know.  There must

 4     have been that many involved in the physical security of the location.

 5        Q.   Yes.  This was from your testimony yesterday in response to

 6     questions by His Honour Judge Orie.

 7             JUDGE ORIE:  Well, Ms. --

 8             MS. FRIEDMAN:

 9        Q.   Perhaps you don't --

10             JUDGE ORIE:  Let me put this very clear:  In the context in which

11     you asked it, Ms. Friedman, it suggests that the testimony was that there

12     was about a dozen more people securing the facility; that is, I put to

13     the witness.  That's not entirely accurate.

14             And the witness then says, "I did not mention a dozen ... or so."

15     That is not accurate either.

16             What the witness said, when I asked him about security, he said:

17             "I can't tell you exactly ... I would be speculating.  I don't

18     have any idea about the number of men who were involved ... I suppose

19     that there may have been a dozen or ten people in one shift, but this is

20     pure speculation because I really don't know."

21             To present that as testimony that there were a dozen is not

22     accurate.

23             But, Mr. Vujovic, you mentioned a dozen, although not as a firm

24     number you could tell us.  That is what happened yesterday.

25             Please proceed.

Page 19666

 1             MS. FRIEDMAN:  Thank you.

 2        Q.   And the Licko Petrovo Selo facility, that was also in Croatia;

 3     correct?

 4        A.   Yes.  It's a location under Pljesevica.

 5        Q.   And when were people from the 7th Administration deployed there;

 6     and approximately how many, if you know?

 7        A.   People from the 7th Administration were not present in

 8     Licko Petrovo Selo.  In terms of the distribution of work, that location

 9     was manned by the group that we call the amateurs, the ham radio

10     operators.

11        Q.   Okay.  And do you have knowledge of how many people were there?

12        A.   Well, I cannot say.  But there must have been, say, three to five

13     people, due to the nature of the work involved.

14        Q.   And just to clarify, my understanding was that those people, the

15     amateurs who handled the ham radios, came under this

16     3rd Administration and were -- were paid by the 8th -- sorry.  Came under

17     the third department of the 7th and were paid by the 8th Administration;

18     is that right?

19        A.   Formally they were never in the 7th Administration.

20             As for plans for their involvement, we worked on that together

21     with the intelligence line.  So there was always co-ordination,

22     synchronisation, where this group would go, where that group would go and

23     so on.

24        Q.   And two more posts were set up on the border between Bosnia and

25     Croatia and Mount Pljesevica and Petrova Gora, is that right, or near the

Page 19667

 1     border, I should say.

 2        A.   I don't know what you meant when you said between Bosnia and

 3     Croatia.  Did you mean Licko Petrovo Selo?  Well, yes, Petrova Gora was

 4     there, yes.

 5        Q.   And Mount Pljesevica as well?

 6        A.   Yes.

 7        Q.   And I believe you testified that Petrova Gora had an average of

 8     seven men, perhaps, there?

 9        A.   I said specifically from five to seven.

10        Q.   And fewer at Mount Pljesevica?

11        A.   Conditions were far more difficult at Pljesevica; for people to

12     stay there and work there, that is.

13        Q.   Now, isn't it the case that there were also posts set up in

14     Bosnia in Bijeljina and Kozara?

15        A.   I know that there were posts in Bijeljina as well, but I don't

16     know about Kozara.

17        Q.   Okay.  Now, just to let you know, some of this information, the

18     reason it is -- I just need to confirm is that it was provided in

19     anticipation of your testimony by the Simatovic Defence saying that this

20     was what you would testify to, and we just need to confirm whether it is,

21     indeed.

22             MR. PETROVIC: [Interpretation] Your Honour.  Your Honour, the

23     Simatovic Defence, after several proofings with Mr. Vujovic, stated quite

24     clearly that Mr. Vujovic didn't know anything about Kozara.  And this

25     information was forwarded to the OTP as well.  That is quite clear.

Page 19668

 1             MS. FRIEDMAN:  Your Honours, I would just respond briefly.  It's

 2     not -- it is the basis for my questions.  It is something like an

 3     evolving statement.  If there's an original statement that this is what

 4     the witness will testify to and then a subsequent saying maybe he doesn't

 5     know a lot, I'm still entitled to follow up.  It's the bare notice that

 6     we get.

 7             MR. PETROVIC: [Interpretation] Your Honour.

 8             JUDGE ORIE:  Yes.

 9             MR. PETROVIC: [Interpretation] By your leave, there is no

10     statement here.  There was a summary that was compiled under the

11     conditions under which it was compiled, when the witness was here and

12     when we talked to him, then we compiled a note about what the witness

13     would be testifying about.  That would be it.

14             JUDGE ORIE:  What's our problem at this moment, in order to --

15             Ms. Friedman brings something to the attention of what she

16     learned, and then we start a debate, and what is the effect?  What is

17     the ...

18             MS. FRIEDMAN:  My only -- I think my question was proper and

19     that's all.

20             JUDGE ORIE:  Yes.  But was anyone, at that moment, objecting

21     against your question?

22             MS. FRIEDMAN:  I presume that's why Mr. Petrovic stood.

23             JUDGE ORIE:  Let me ...

24             So you anticipated --

25             MS. FRIEDMAN:  I have no need to pursue further.


Page 19669

 1             JUDGE ORIE:  -- that it's -- let's -- let's move on.  The

 2     question has been put to the witness.  The witness has answered the

 3     question.  There has been some communication between the parties which

 4     have raised some expectations which may not be fully -- may not have

 5     materialised fully.  Okay, that's it.  Let's move on.

 6             MS. FRIEDMAN:  Okay.

 7             MR. JORDASH:  May we take the break, Your Honour, please.

 8             JUDGE ORIE:  Yes.  Yes, we'll not move on but take a break.

 9     That's what is suggested.

10             We take a break and resume at a quarter to 11.00.

11                           [The witness stands down]

12                           --- Recess taken at 10.17 a.m.

13                           --- On resuming at 10.53 a.m.

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19670











11 Pages 19670-19679 redacted. Private session.
















Page 19680

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 2   (redacted)

 3   (redacted)

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 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24        Q.   Okay.  And -- but these would be all the ones that you know about

25     in -- outside the territory of Serbia?  Let me put it that way.

Page 19681

 1        A.   Yes.

 2        Q.   And do you think if you had -- you have a pen at your desk, do

 3     you think you would be able to locate approximately the two in Serbia?

 4             JUDGE ORIE:  Could the usher assist the witness.

 5             MS. FRIEDMAN:

 6        Q.   If it's this -- I realise that it might not be possible on this

 7     map, and, in any event, it -- it can be used for Croatia and Bosnia only.

 8     But if it is possible, you're -- I'd like to add that.

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19682











11 Pages 19682-19683 redacted. Private session.
















Page 19684

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11             Mr. Petrovic, anything to --

12             MR. PETROVIC: [Interpretation] No, Your Honour.  I agree with

13     what you have just decided.

14             JUDGE ORIE:  Yes.  Well, that's good.

15             Ms. Friedman, if there's need to remain in private session, we'll

16     remain in private session.  If not, please tell us.

17             MS. FRIEDMAN:  Actually, just one more question and then we'll

18     move into public session.

19        Q.   In case -- just for complete clarity, my understanding is that

20     these were the locations that you know about in relation to the

21     7th Administration or intelligence posts of the 2nd, but you had said

22     yesterday that there were more people deployed in other locations.  So

23     this is not a totality but it's the ones that you have some knowledge

24     about; is that right.

25        A.   I don't understand your question.

Page 19685

 1        Q.   Sorry.  I should say these are surveillance posts that you have

 2     some knowledge about, and the -- there are additional intelligence posts

 3     that we have not discussed; is that right?

 4        A.   When it comes to other intelligence posts where staff and

 5     equipment for radio monitoring might have been engaged, I don't know

 6     anything about those.

 7        Q.   Okay.  Thank you.

 8             MS. FRIEDMAN:  And we'll -- we can move back into public session.

 9             JUDGE ORIE:  We move into open session.

10                           [Open session]

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

12             JUDGE ORIE:  Thank you, Madam Registrar.

13             MS. FRIEDMAN:

14        Q.   Now, Mr. Vujovic, I -- the purpose of these posts was to be able

15     to gather intelligence that would be of assistance to Serbia and that

16     would assist the Bosnian and Croatian Serb leadership and military in

17     securing and expanding the Serb-held land.  Isn't that the purpose?

18        A.   The intelligence posts, any intelligence posts, are established

19     in order to gather intelligence.  That's the key bit of information.  And

20     this is done based on the requests and the needs of the intelligence line

21     of work.

22             As to how the intelligence was subsequently used, I wouldn't know

23     because that was not my job.  I was not in the business of knowing that.

24        Q.   You must be able to say, though, that the overall goal was to

25     secure and expand the territory held by the Serbs.


Page 19686

 1        A.   This is the first time ever I heard of such a goal from the point

 2     of view of the service.

 3             The service gathered intelligence.  Every intelligence service in

 4     the world has the legitimate right to do that.  Intelligence serves the

 5     leadership of a country in setting up their policies, and I was not

 6     involved in the creation of policies.

 7             Our task was to put in place conditions for gathering

 8     intelligence, and then when the intelligence was gathered, we submitted

 9     that to the intelligence line of work.  And that's where our job ended.

10        Q.   Okay.  And these posts, these antenna, these personnel, they

11     were -- you were located outside of Serbia in Bosnian and Croatian

12     territory; correct?  Or in the RS and RSK, I should say.

13        A.   Well, intelligence is normally gathered outside of one's

14     territory.  That's why you call it intelligence.  All over the world,

15     intelligence services work outside of their own countries, and that's why

16     the information which is gathered is called intelligence.  When you're in

17     your own state, what you do is you gather counter-intelligence, and this

18     applies across the board.  This applies to all the intelligence services

19     in the world.

20        Q.   But you were setting up large antennas in a territory outside

21     your country which you said were highly visible; is that correct?

22        A.   Where the conditions allowed us to do that, we erected antennas

23     at these posts.

24        Q.   I put to you that the conditions that allowed it is that there

25     was no barrier from the leadership of the countries you were in; is that

Page 19687

 1     right?

 2        A.   I don't know if there were objections or not.  When it came to

 3     engaging my staff, my staff from the 7th Administration, the only thing

 4     that we were concerned with was the safety of the men and the equipment;

 5     in other words, whether people were safe if they went to work there.

 6        Q.   And the information you gathered, just a couple more points, it

 7     would have been useful, though, to -- for example, the information you

 8     gathered in Pajzos was presumably useful for the government of the SBWS

 9     and its -- and the armed forces in the area.

10             JUDGE ORIE:  Mr. Petrovic.

11             MR. PETROVIC: [Interpretation] Now the question has been

12     completely interpreted.

13             THE WITNESS: [Interpretation] The main objective of the

14     intelligence equipment and personnel is to gather information.

15             Now, as to where the information is sent to, how that information

16     is going to be used, this is not the job of operatives and the

17     intelligence-gathering staff.  While collecting intelligence by way of

18     radio monitoring and when that intelligence is sent out of the

19     7th Administration, we are in no way in a position to know what's going

20     to happen to that intelligence.  The 7th Administration was not in the

21     business of knowing that, of follow -- of following up that intelligence.

22             MS. FRIEDMAN:

23        Q.   I understand.  I would like to ask if you could just address the

24     question.  If -- if you did overhear, if you know the content of any of

25     the surveillance, would you say that it would be useful to the government

Page 19688

 1     of the SBWS and to the armed forces in the area?

 2        A.   You're asking me a very general question, if I may say that by

 3     way of a comment.  Now whether some information would be useful to

 4     someone.  Any information can be useful.  Now whether that information is

 5     was sent to the body that you call that, I do not know.

 6        Q.   Okay.  Leave that there.

 7             JUDGE ORIE:  Could I ask you, the -- gathering intelligence with

 8     technical means, as were used by you, that is, intercepting any

 9     communication which is in the free area, if I could say so, or radio

10     communications, could you give us any idea on -- on what type of

11     information you got through these methods, and whether that would also

12     include military-relevant information.

13             THE WITNESS: [Interpretation] Well, there was certainly diverse

14     information about this communication between leading politicians of these

15     countries.  Some political, God knows, activists.  There must have been

16     communication about the presence of foreign forces in the area, so this

17     is an entire conglomerate of communication.  Specifically, what is being

18     monitored, what is of interest for monitoring in order to be used

19     further, that was decided upon by the intelligence line of work.  So they

20     said, If Izetbegovic talks to Sacirbey we are going to monitor that but

21     we're not going to waste time on other things, equipment, or personnel.

22             So this information was diverse.  And it went from the

23     intelligence line of work.

24             JUDGE ORIE:  Is there any reason why you didn't answer the last

25     part of my question?

Page 19689

 1             I asked whether this would include military-relevant information.

 2     And I did not have on my mind, as you may have understood, only foreign

 3     forces; Croatian forces, for example?  Or were you not interested in any

 4     way in that kind of information?  Was it excluded from your task?

 5             THE WITNESS: [Interpretation] I personally did not receive this

 6     information.  I was not made aware of them by the very nature of things.

 7             However, in principle -- now this is speculation on my part.  I

 8     think this was primarily information related to politics and the presence

 9     of the foreign factor in that area.

10             JUDGE ORIE:  You earlier explained what kind of information there

11     was.  Did that personally reach you or -- I mean, what you said,

12     political activists of communication about the presence of foreign, I

13     think you said, forces.  But I'm -- where you -- did you become

14     acquainted with the content of that intelligence you obtained from these

15     radio communications?

16             THE WITNESS: [Interpretation] No, no, not the content.  I was not

17     made aware of that in any situation practically.

18             The essence was that we were supposed to generate information and

19     send it on, but then the head of the department was not aware of that.

20             JUDGE ORIE:  Now, when I asked you about information about

21     Croatian forces, you said:

22             "I personally did not receive this information.  I was not made

23     aware of them ... in principle -- now this is speculation on my part."

24             When you were talking about all the other matters, intelligence

25     matters you obtained through these post, you didn't make any reservation

Page 19690

 1     as that it did not personally reach you.  You did not make any

 2     reservation as far as whether it was speculation or not.  You put it as

 3     facts.  And when I asked you about Croatian forces, you do not put it as

 4     facts; and when further asked, you say that what you said earlier is not

 5     facts either, would be just as much for the content be speculation.

 6             Is that well understood?

 7             THE WITNESS: [Interpretation] May I explain?

 8             JUDGE ORIE:  I --

 9             THE WITNESS: [Interpretation] If my comment was --

10             JUDGE ORIE:  I first -- of course, you may explain.  But if you

11     would please focus on my question, whether I understood that well.

12             So then you may explain, no problem.  But ...

13             THE WITNESS: [Interpretation] In principle, yes.  In principle,

14     yes, your understanding was correct.

15             And now may I just explain how come?

16             Professionally, we were very satisfied if we managed to intercept

17     information at that high level.  So when people could come back from the

18     field when reporting in general terms, they said, there was this, there

19     was that, and we managed to intercept this, for instance, at one point in

20     time, of course, without going into the content.

21             So, therefore, I know that this information was being followed,

22     monitored, that they managed to intercept things that belonged to that

23     category too.

24             Let me put it this way.  That is tangible, professional success

25     for that group that was there in that period of time.  So, therefore, as

Page 19691

 1     you had put it, Your Honour, I'm saying that I have information for this

 2     and not for that, but that is the only reason, yes.

 3             JUDGE ORIE:  Please proceed, Ms. Friedman.

 4             MS. FRIEDMAN:  Thank you, Your Honour.

 5        Q.   Now, the decision to establish these listening posts outside of

 6     Serbia, that would have had to be approved by the chief of the

 7     Serbian DB; correct?

 8        A.   Absolutely.  I absolutely agree.  No such thing can be done

 9     without the head of the service knowing about it.

10        Q.   And you testified that some individuals on their own initiative

11     began listening and then were eventually incorporated and paid by the

12     8th Administration.  That decision, I take it, would have also had to

13     have been approved by the chief of the service; correct?

14        A.   Of course.  Of course, yes.

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19692











11 Page 19692 redacted.















Page 19693

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4             MS. FRIEDMAN:  And could I just seek clarification from

 5     Your Honours.  I just have one more question after -- in a moment that is

 6     going to refer to Petrova Gora which I think is not a matter of secret at

 7     this stage.  Would that be okay for --

 8             JUDGE ORIE:  If it were, we would need another redaction for this

 9     observation.  But I think Petrova Gora has been mentioned hundreds of

10     times in public, including, I think, technical -- technical people being

11     there.  So I think that it would -- we can talk about Petrova Gora

12     without any further problems, yes.

13             MS. FRIEDMAN:  [Microphone not activated] Thank you, Your Honour.

14             JUDGE ORIE:  Mr. Petrovic.

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22                           [Trial Chamber confers]

23             JUDGE ORIE:  The -- Mr. Petrovic, it is not fully clear what you

24     actually wanted to say in addition to what was already the decision; that

25     is, to take out the two questions.  But, of course, you cannot explain it


Page 19694

 1     any further unless we are in private session, which we are not at this

 2     moment.

 3             Therefore, if you consider it relevant, then we have to move into

 4     private session.  At this moment, the redaction stands as it was ordered

 5     by the Chamber; that is, for the last two questions, the line we

 6     indicated earlier, to start there, up to your intervention.

 7             And perhaps in view of the -- your later submissions that we

 8     extend it up to this very moment, if you insist, Mr. Petrovic, then we

 9     move into private session.  If you say we can proceed, then we leave it

10     as it is.

11                           [Trial Chamber and Registrar confer]

12             MR. PETROVIC: [Interpretation] Your Honour, perhaps just for a

13     moment, if we could move into private session just for a moment so that I

14     could try to explain this very briefly.

15             JUDGE ORIE:  Yes.  We move into private session.

16             [Private session] [Confidentiality partially lifted by order of the Chamber]

17             THE REGISTRAR:  We're in private session, Your Honours.

18             JUDGE ORIE:  Thank you, Madam Registrar.

19             Mr. Petrovic.

20             MR. PETROVIC: [Interpretation] Your Honours, the witness who is

21     before you here today is an employee of the 7th Administration.  There's

22     a reference to the location where the 7th Administration was involved,

23     that is to say, Petrova Gora, which is different from what we heard about

24     this so far.

25             So his knowledge is a lot more direct, a lot more specific, and

Page 19695

 1     it seems to me that they -- that his knowledge belongs to this general

 2     category that we talked about; namely, the locations that were used by

 3     the department that he worked for should not be mentioned in open

 4     session.

 5             That is my understanding of that position; namely, that the

 6     locations that were used by the administration and where the personnel

 7     and equipment of the administration that this witness worked in would

 8     only be referred to in private session.

 9             I think that the reference to Petrova Gora necessitates -- makes

10     private session necessary.

11                           [Trial Chamber and Registrar confer]

12             JUDGE ORIE:  Now, isn't it true that, until now, the main issue

13     was that locations used by the RDB were protected.  Now, a lot have been

14     said about Petrova Gora, and -- including technicians being there.  Is it

15     now specifically that it was the 7th Administration that is -- because,

16     until now, we have not made that distinction.  But perhaps I

17     misunderstood you.

18             MS. FRIEDMAN:  Your Honour.

19             JUDGE ORIE:  Yes, Ms. Friedman.

20             MS. FRIEDMAN:  If I may, the main -- the issue is the reason that

21     for a number of witnesses we have provisional private session is because

22     of the idea of -- because of the interests of national security for the

23     Republic of Serbia and that certain information could jeopardise it, and

24     that's the starting point, not which administration is where.  And so

25     we've taken -- we've expanded the bounds a little bit in order to be

Page 19696

 1     overly cautious and the Prosecution does support that approach; however,

 2     in some instances when the facts are already so clearly in the public

 3     knowledge, it is hard to image how this particular information could

 4     somehow jeopardise ongoing intelligence activities.

 5             JUDGE ORIE:  Mr. Petrovic.

 6             MR. PETROVIC: [Interpretation] Your Honour, Your Honour, if you

 7     allow me.

 8             The degree of detail and the specific facts referred to by the

 9     witness would justify this.  However, I don't want to spend any more time

10     on this.  I, of course, leave this to the Trial Chamber to decide on, but

11     I believe that these two matters justify asking for this to be kept in

12     private session.

13             JUDGE ORIE:  Could you tell us what details you have on your mind

14     which would then endanger the national security?

15             MR. PETROVIC: [Interpretation] Your Honour, for instance, details

16     that have to do with the equipment that was deployed in the area and that

17     was used.

18             JUDGE ORIE:  What was said about the equipment which is so

19     specific that if someone would know that, we would ...

20             MR. PETROVIC: [Interpretation] Your Honour, I don't know in which

21     direction my learned friend will proceed.  She asked about Petrova Gora.

22     If we're moving in that direction, it is quite likely that she is going

23     to put these questions.  If not, then there's no need.

24             JUDGE ORIE:  Okay.  You're anticipating on questions of detail on

25     equipment to be used.

Page 19697

 1             Ms. Friedman, would you please inform the Chamber if you move

 2     into that area.

 3             MS. FRIEDMAN:  Yes, Your Honours.

 4             JUDGE ORIE:  Yes.  Then we move back into open session,

 5     Mr. Petrovic, but your request to hear all evidence, if related to

 6     Petrova Gora, is -- to hear that evidence in private session is denied.

 7             Please proceed.

 8             Yes.

 9             MS. FRIEDMAN:  Your Honour, I should actually say out of caution

10     my questions don't ask about the equipment, but perhaps the answers will.

11     So we should just be in private session at the moment.

12             JUDGE ORIE:  Then we stay in private session.  Let's move on in

13     private session.

14             MS. FRIEDMAN:

15        Q.   So I was asking you about the communication between the different

16     posts of the 7th Administration, Mr. Vujovic, and you had explained that

17     it depended on the season.  So can you clarify, please, was there a means

18     of direct communication and was that by phone line, by radio, or -- or

19     how?

20        A.   I have to correct you.  I did not say that.  Your question was

21     whether there was communication between the posts.  As far as the

22     technical side of things is concerned, I said no.  And then you asked me

23     about specific communication between Pljesevica, Licko Petrovo Selo, and

24     Petrova Gora.  All of that is nearby.  And then there had to be

25     communication, information that was collected from the top of

Page 19698

 1     Mount Pljesevica.  But it is certain that this could only be used by

 2     sending information to Petrova Gora by secure channels because the

 3     actually -- the actual post is passive where the crew is with -- with the

 4     antenna and so on.  They should not do anything which would make it

 5     possible to detect them.  Licko Petrovo Selo is at the foot of the

 6     mountain, and I don't know how they sent information further on to

 7     Petrova Gora, by courier, I assume, but I don't know.

 8        Q.   Okay.  Did any of the other posts have secure communications with

 9     each other?

10        A.   No, no.  As far as I know, no.  Posts did not need to communicate

11     mutually, but every post covered a certain territory, a certain area.

12             How do I put this?  That's as far as operative technical

13     equipment is concerned.  They had no need to have mutual communication.

14        Q.   So -- and is it your evidence that they would communicate with

15     Belgrade also by courier, or was there a direct line of communication?

16             MR. PETROVIC: [Interpretation] Your Honour --

17             THE WITNESS: [Interpretation] You asked me about the posts

18     themselves.

19             MR. PETROVIC: [Interpretation] I would like a clear distinction

20     to be made in questions.  Is the reference being made to the line of work

21     of this witness or other lines of communication?  This way, it is

22     ambiguous, whether it is the lines of communication of the

23     7th Administration or some other lines of communication that were

24     possible, that may have existed.

25             JUDGE ORIE:  Ms. Friedman, I think it's important to know whether

Page 19699

 1     we're talking in more general terms about communications between these

 2     posts and --

 3             MS. FRIEDMAN:  Yes.  I think that was in my question, and I am

 4     following up with additional locations.

 5             JUDGE ORIE:  Yes.

 6             MS. FRIEDMAN:

 7        Q.   So is it that the -- all right.

 8             So my understanding is that the technical operatives you would

 9     supply information to others in the -- in other administrations such as

10     the 2nd Administrations and they would communicate onwards.  So you would

11     hand over that information in person or send it by courier; is that how

12     it was?

13        A.   At each post, when operatives obtained intelligence, they would

14     send it to the operative along the intelligence line of work, who was in

15     charge of that and who was -- some were there.  That intelligence was not

16     sent to the base of the 7th Administration in Belgrade.  The intelligence

17     stayed there.  It was processed and sent to the intelligence line.  For

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22             There was always an operative, a member of staff, who was there,

23     and that's why those people were there in the first place, to speed

24     things along, in order to avoid wasting time and effort.  That's how

25     things were organised.

Page 19700

 1        Q.   Would they use, though, if intelligence --

 2             JUDGE ORIE:  Mr. Jordash.

 3             MR. JORDASH:  Sorry, may we take a break, please, Your Honour.

 4             JUDGE ORIE:  We'll take a break, and we'll resume at 12.30.

 5                           --- Recess taken at 12.02 p.m.

 6                           --- On resuming at 12.40 p.m.

 7             JUDGE ORIE:  Ms. Friedman, you may proceed.

 8             MS. FRIEDMAN:  Thank you, Your Honour.

 9             I just wanted to note, first of all, that I've used only

10     49 minutes of my time.  I have inquired with the Court Officer, so I've

11     tried to cut some material, and I will do my best but I'm not sure if I

12     will conclude in this session.

13             JUDGE ORIE:  Try to do your utmost best.

14             MS. FRIEDMAN:  Yes.  Thank you.

15        Q.   Mr. Vujovic, we left off talking about communication between

16     essentially people in the -- operatives in the field outside of Serbia.

17     So let me ask you first:  Did members of your department also have as

18     part of their role assisting others in engaging in communication?

19        A.   When it comes to communications between the different parts of

20     the service, the administration for communications and encryption was in

21     charge of that.  I don't know if the 7th Administration was ever involved

22     in some of those tasks.  Perhaps they were, but you wouldn't know.  In

23     any case, the main responsibility for that lay in the hands for the

24     administration for communications and encryption.

25        Q.   And you worked alongside intelligence officers.  Were you able

Page 19701

 1     to -- do you have personal knowledge of how they communicated with other

 2     intelligence officers in the field?

 3        A.   No, not personally.

 4             JUDGE ORIE:  Ms. Friedman, you would tell me when we could return

 5     into open session.

 6             MS. FRIEDMAN:  Yes.

 7             JUDGE ORIE:  Because I think we're still in private session.  Or

 8     again in private session.

 9             MS. FRIEDMAN:  Yes.  Let me just check for one moment.

10             Let me ask one more question and then I think we can move back.

11             JUDGE ORIE:  I'll wait for your message.

12             MS. FRIEDMAN:  Thank you, Your Honour.

13        Q.   Mr. Vujovic in relation to Petrova Gora you stated that there

14     would be about four to five technicians, one or two translators and

15     then -- and this is in yesterday's transcript, and when Judge Orie asked

16     you about whether it was seven people on average, you stated:

17             "I believe that ... you can put it that way, at least for this

18     particular part of the whole exercise."

19             By "whole exercise," do you mean that this location on

20     Petrova Gora included not only the listening part that you were involved

21     in and intelligence part, but it was also the command post for Pauk; is

22     that correct?

23        A.   No.  What I meant were the obligations in respect of the

24     intelligence posts and people -- and the people who worked there.

25     Primarily the operatives who handled the equipment.

Page 19702

 1        Q.   But isn't Pauk a location that was actually in --

 2             MS. FRIEDMAN:  I --

 3             JUDGE ORIE:  Yes, Mr. Petrovic.

 4             MR. PETROVIC: [Interpretation] Your Honours, I apologise for

 5     interrupting.

 6             The witness said specifically what people he had in mind when he

 7     mentioned the numbers, and it doesn't seem to be clearly recorded.

 8             JUDGE ORIE:  Did you, in your last answer, refer to any numbers

 9     when you were talking about people who worked there?  Primarily

10     operatives who handled the equipment, and how many were there?

11             THE WITNESS: [Interpretation] Well, those people who were

12     discharged documents pertaining to the 7th Administration, in different

13     periods of time, there were, on average, seven of them.

14             JUDGE ORIE:  Mr. Petrovic, this resolves the dilemma?

15             MR. PETROVIC: [Interpretation] Yes, Your Honour.  Yes, thank you.

16             JUDGE ORIE:  Please proceed.

17             MS. FRIEDMAN:

18        Q.   What I'd like to know is, being at Petrova Gora, surely you knew

19     that there was also a system of communication there in place?

20        A.   No, I was never there.  I was never on Petrova Gora.

21        Q.   Okay.

22             MS. FRIEDMAN:  Can we move into open session, please.

23             JUDGE ORIE:  We move into open session.

24                           [Open session]

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


Page 19703

 1             JUDGE ORIE:  Thank you, Madam Registrar.

 2             MS. FRIEDMAN:

 3        Q.   You testified yesterday that some of the defensive measures you

 4     would use were measures against interception.  That's at T19572.

 5             Now, does that include the use of cryptographic data protection?

 6        A.   I don't remember answering any of the questions in that way.

 7             MR. PETROVIC: [Interpretation] Your Honours.

 8             JUDGE ORIE:  Mr. Petrovic.

 9             MR. PETROVIC: [Interpretation] Your Honours, I believe that we

10     have a problem, and the problem may be related either to the

11     interpretation or to the way my learned friend is quoting from the

12     transcript.

13             So perhaps I should -- should ask her to rephrase or repeat her

14     question.

15             MS. FRIEDMAN:  I will quote from yesterday's transcript.

16             Question:

17             "And now, what about defensive measures?  What would be the

18     defensive measures of operative work?"

19              And to that you answered:

20             "It is a range of measures which is within the purview of the

21     State Security Department, and it applies to the protection of facilities

22     and individuals, as prescribed by law.  That's measures against

23     interception, against biological, chemical protection, technical

24     security, electronic security, mechanical security.

25             "So those would be defensive measures."

Page 19704

 1             Mr. Vujovic, I'd like to know, based on this description, it

 2     appears that you would have knowledge of electronic security and

 3     protection against interception, and my question is whether it involves

 4     encrypting; cryptographic data protection specifically.

 5        A.   It was the 4th Administration of the RDB that was involved in

 6     cryptographic data protection.  The title of that administration was the

 7     administration for communications and cryptographic data protection.

 8             The 7th Administration was involved in deciphering, or breaking

 9     up the codes that were collected.  So we were not involved in protecting

10     documents by means of cryptographic data protection.  We, on the other

11     hand, were involved in trying to decipher the cryptographic data that we

12     intercepted.

13        Q.   And what about when you became the head of the security

14     institute?  Was that an institute run by the Serbian DB?

15        A.   The security institute, from the moment it was set up until the

16     moment the BIA was set up in 2001, was an independent body which operated

17     and functioned based on defining common interests of all security

18     services.  When I say that, I mean in the republics and autonomous

19     provinces.  In practical terms and formal terms and legal terms, the

20     institute became part of the RDB in 2001 when the RDB was reorganised and

21     when the security and intelligence agency, the BIA, was set up.

22        Q.   And when you became head of it, did you then end up working in

23     this -- or having knowledge of the secure methods of communication?

24        A.   During that period of time, we did not have any people in the

25     institute that would be dealing with those issues.

Page 19705

 1             JUDGE ORIE:  Mr. Petrovic.

 2             MR. PETROVIC: [Interpretation] Your Honours, I believe that it

 3     would be of some benefits for the Trial Chamber if my learned friend

 4     could specify the time-frame.  It is not very clear from the record,

 5     which is why I think that it will not be of much use to the

 6     Trial Chamber.

 7             JUDGE ORIE:  Ms. Friedman, time-frames usually are very relevant.

 8             MS. FRIEDMAN:  Yes.  The witness testified yesterday to his

 9     background and that he became head of the security institute when he

10     rejoin BIA, and I think that was in 2001 or 2002.

11             JUDGE ORIE:  Mr. Petrovic, even without further questions to the

12     witness, does this -- gives the background you think the Chamber would

13     need?

14             MR. PETROVIC: [Interpretation] I believe that in some parts of

15     his answers, the witness has referred to the time preceding that year.

16     This is my impression, and I may be wrong.  My impression may be wrong,

17     and if that is the case, I would like to apologise to you, Your Honours,

18     and everybody else in the courtroom.

19             JUDGE ORIE:  I'm not going to give you any ruling on it, but

20     would you please keep it in the back of your mind.

21             MS. FRIEDMAN:  Yes.

22             JUDGE ORIE:  Please proceed.

23             MS. FRIEDMAN:

24        Q.   So we just -- essentially just to repeat to you, sir, my

25     understanding is that you were the chief of the department for

Page 19706

 1     application of technical measures at the federal MUP; then chief of the

 2     7th Administration of the Serbian MUP; later, deputy chief for operative

 3     equipment; and finally the chief of the security institute.  And it was

 4     based on -- on something in there that -- I expected you to have some

 5     information about communications.  But is it your information that you

 6     only dealt in all this time with surveillance?

 7        A.   This is a compound question, is it not?

 8             So I will try to understand your question the way I understood

 9     it.

10             When I became the chief of the security institute, which was in

11     2001 and up to the time when I was pensioned off, the institute was not

12     involved in the development of any specific communications systems or

13     protected communications systems or any such thing.

14             The second question was whether the institute was ever involved

15     in that.  Yes.  Prior to my arrival, the institute this facilities and

16     departments that were involved in that.  In the meantime, that would --

17     that was discontinued, so when I joined, it did not exist.

18             And the third question that I recognised in your compound

19     question was about what I did.  So what I did throughout my career was

20     intercepting other people's communications.  I obviously knew what the

21     administration for communications was involved in, and their main task

22     was to provide secure communications wherever those secure communications

23     were needed.

24        Q.   Okay.  Now, I would ask for the Court Officer to please call up

25     P2615.

Page 19707

 1             Mr. Vujovic, just maybe have a quick look at it and let me know

 2     when you're ready to proceed.

 3        A.   Yes.

 4        Q.   Okay.  Now, the document relates to -- or states that the

 5     Serbian MUP provided some Land Rovers with RAKEL radio devices for use in

 6     the Krajina SUP in April 1991.

 7             Can you explain what the RAKEL radio devices are?

 8        A.   It's RAKEL.  And it's a very well-known British-based company.

 9     They produced professional communications equipment.  So this is just a

10     notification to the effect that the communications administration was

11     provided with a vehicle with that equipment and also there are some

12     details of the whole set, of the whole equipment.

13        Q.   Okay.  And did this kind of -- the adjusted Land Rovers that you

14     had at Pajzos that you talked about, did they also have these kinds of

15     RAKEL devices?

16             JUDGE ORIE:  [Microphone not activated] Mr. Petrovic.

17             MR. PETROVIC: [Interpretation] Your Honours, my learned friend

18     says this document refers to April 1991.  I may be mistaken, but I really

19     can't see how she came to the conclusion that this document relates to

20     April 1991.

21             The only thing we see on the document itself is 7th of May, 1992.

22             I apologise, Your Honours.  Your Honours, I withdraw my

23     objection.

24             JUDGE ORIE:  Last year-- a reference to last year is usually to

25     the previous year, Mr. Petrovic.

Page 19708

 1             Ms. Friedman, please proceed.

 2             MS. FRIEDMAN:

 3        Q.   Yes.  So did you have these devices in Pajzos as well?

 4        A.   No.  There was no need for that.  The purpose of this equipment

 5     is not the same as the purpose of the equipment at Pajzos.

 6             RAKEL devices are used in communications between ourselves.  And

 7     Pajzos had the equipment that was used to intercept any kind of other

 8     people's communications.

 9        Q.   Now, about halfway down the page, the communications commander

10     who authored the report states:

11             "After approximately two months, there was a need for Land Rover

12     vehicles, and pursuant to an order by Frenk, the chief representative of

13     the Serbian MUP, I dismantled the entire equipment from two of the

14     vehicles and moved them to two Lada Niva vehicles ..."

15             My first question is whether you knew that Franko Simatovic was

16     in the Krajina before being in Pajzos?

17        A.   No.

18        Q.   And a little further down, the document states:

19             "The emptied Land Rovers were used to tow mortars and transport

20     the crews in the area of Velika Glava."

21             Mr. Vujovic, you'll agree that this indicates involvement in --

22     in something other than gathering intelligence.

23        A.   I don't know that.  I don't know if Mr. Franko was involved in

24     something else on the territory.

25             My communication with him, my obligations, the obligations of my

Page 19709

 1     administration were to collect intelligence.  As for Franko Simatovic,

 2     whether he did something else, and when he did it, if he, indeed, was

 3     involved in something else, I really don't know.

 4        Q.   Now, you testified that when you -- that you arrived Pajzos.

 5     Now, did you say -- I believe you said it was 1993.  And can you explain

 6     how long you stayed there at first?

 7        A.   It was just a simple working meeting.

 8             Now, as to how much time can that take, whether it was an hour or

 9     a couple of hours, I can't remember.  But I spent perhaps a couple of

10     hours at Pajzos.

11        Q.   So you were never -- is it -- were you never posted there on a

12     more permanent or semi- -- temporary basis?

13        A.   You mean me?

14        Q.   Yes.

15        A.   If you mean me, personally, no, never.

16        Q.   And you stated that you returned to Pajzos later.  Specifically

17     you said:

18             "I went there in 1994 and 1995, 1996.  During that period, I was

19     there twice, I believe.  I really don't know exactly."

20             That's at T19601?

21             And I just want to clarify, was it -- if you can provide any more

22     information.  When you were there during the two periods, was it, again,

23     just a meeting, or were you there for a little longer?

24        A.   I believe that you misquoted me.  I said that I had been at

25     Pajzos, as far as I can remember, only two times.  To a question put to

Page 19710

 1     me by the Defence, or whoever it was who asked me when that was, I said

 2     that it may have been either in 1994 or 1995, or 1996.  I am not sure.

 3     In any case, I went to Pajzos only twice.  Both of the times I attended

 4     meetings there.

 5        Q.   And does that include -- just to revise, then, is this -- it was

 6     only two times, even from 1993 when you first joined?

 7        A.   Including that, yes.

 8        Q.   Okay.  And was it a whole day each time, or half a day, a

 9     couple -- can -- can you give us some indication?

10        A.   I just told you a minute ago.  It could not have been even half a

11     day, let alone a whole day.  We're talking perhaps a couple of hours at

12     the most.

13        Q.   Okay.  So, in total from 1992 when the post was set up until

14     1996, you were maybe there for a couple of hours in total?

15        A.   Yes.  Me, personally.  Only a few hours.  Not more than that.

16        Q.   So when you said that -- you also said that the post was secured

17     by people in an anti-terrorist unit, or I believe you confirmed that it

18     was the JATD.

19             This was information that you got when you were there or were you

20     told at some other time?

21        A.   When I was there, I can't remember the circumstances, but I

22     believe that in a conversation with somebody, I was informed that it was

23     the anti-terrorist unit, our own anti-terrorist unit, that provided

24     security for the facility.

25             MS. FRIEDMAN:  [Microphone not activated] Sorry, Your Honours,

Page 19711

 1     can I just have a moment to confer.  Okay.  Can I please have

 2     65 ter 6535.  And I have a hard copy to be handed to the witness.  And

 3     this should not be broadcast.

 4             And just for -- we have only partial translations uploaded as of

 5     now.  They will be completed.

 6        Q.   Sir, these are some -- yesterday my colleague Mr. Petrovic showed

 7     you a JATD payment list, and you were able to identify three individuals

 8     whom you said were engaged in communication activities.

 9             Do you recall that?

10        A.   It was not a payment list or a payroll.  I was shown a document

11     that had to do with the payment of per diems, and these are two different

12     things.  And there were two men there who had been involved in that work.

13        Q.   Yes.  And --

14             JUDGE ORIE:  Has the witness sufficiently clarified, I take it,

15     Mr. Petrovic.

16             MS. FRIEDMAN:  There was --

17             JUDGE ORIE:  Payment is an ambiguous expression but it is clear

18     what was shown to the witness yesterday.

19             Please proceed.

20             MS. FRIEDMAN:  Yes.

21        Q.   And as for the two people Judge Orie had questioned further, and,

22     Mr. Vujovic, I don't know if you recall that you also identified an

23     additional person at the -- who was number 1 on the list.

24        A.   Yes.

25        Q.   Okay.

Page 19712

 1             MS. FRIEDMAN:  And just right before we get to yours, I'll

 2     just -- to these new lists, I'll note for Your Honours that the payment

 3     list shown to the witness were -- was Exhibit P458 and it was discussed

 4     at T9607 -- sorry, 19607 to 19608, and I would call the Chamber's

 5     attention in this respect to Exhibit P441, paragraph, 93, and P454, page

 6     23, as it relates to the evidence of that exhibit.

 7        Q.   Now, Mr. Vujovic, what you see in front of you are seven payment

 8     lists on which you appear from 1993 to 1995, which the Prosecution

 9     received pursuant to a Request for Assistance from the Serbian MUP.

10             Now these payment lists in which you appear are not JATD payment

11     lists; correct?

12        A.   I can neither confirm nor deny that because, as far as I can see,

13     all these payment lists are personalised.  There are names and surnames

14     there.  Now, whether somebody is a member of the JATD, I really cannot

15     say.

16        Q.   Okay.

17             JUDGE ORIE:  Mr. Petrovic.

18             MR. PETROVIC: [Interpretation] Your Honour, I have a problem with

19     the presentation of this document by my learned friend; because when we

20     look at the bottom of this page, we see something that is different from

21     what she seems to suggest through her question.  I don't want to say what

22     that is in front of the witness.  But the document is not the way she had

23     interpreted it.

24             JUDGE ORIE:  Well, most important is that the witness looks at

25     what the Prosecution wants to show.

Page 19713

 1             And, Ms. Friedman, apparently, there's a problem in the way you

 2     described the document.  If you would try to do that as neutral as

 3     possible, it would be appreciated.

 4             A list containing names and amounts of money, because that's --

 5             MS. FRIEDMAN:  Yes.  I believe it is entitled:  List of payroll

 6     documents to be entered.  That's --

 7             JUDGE ORIE:  If you read literally from the document, then

 8     Mr. Petrovic will not have any concerns.

 9             MS. FRIEDMAN:

10        Q.   Mr. Vujovic, for the time-periods that were paid for, you were

11     not specifically connected to JATD operations; correct?

12        A.   The question seems to be a bit unclear to me.  Linking this list

13     to whether I was part of the JATD, well, the JATD was established in

14     1993.  I've already explained that we, as the 7th Administration, as far

15     as our obligations towards the JATD were concerned, they were minimal,

16     and they ended at the level of some kind of logistic support.

17             So that is the beginning and the end of it, as far as the

18     7th Administration and the JATD is concerned.

19        Q.   Well, that was -- that was my question.  It wasn't saying that

20     you were part of the JATD on the basis of this list.  It was quite the

21     opposite, saying that this is a generic list that does not say anything

22     about an anti-terrorist unit.  It's a list of the Serbian DB, where you

23     worked, the 8th department which dispensed funds and payment, and you're

24     on this list, and I take it from this list that your payment here is not

25     for activities in connection to the JATD?

Page 19714

 1             JUDGE ORIE:  Mr. Petrovic.

 2             MR. PETROVIC: [Interpretation] Your Honour, please.  This is

 3     already the second time that my colleague is repeating that this list has

 4     nothing to do with the ATD.  Please take a look at number 20 ...

 5             JUDGE ORIE:  Ms. Friedman.

 6             But ...

 7             MS. FRIEDMAN:  I think --

 8             JUDGE ORIE:  Where you said it does not say anything, that might

 9     be not entirely correct in view of what Mr. Petrovic just said.

10             But why not put the questions in a very practical way.  That is,

11     Mr. Vujovic, whether he has any recollection of this amount of money,

12     which was apparently recorded here as either to be paid to him or paid to

13     him and in what connection that was.  Because that's what apparently

14     you're seeking to establish.

15             MS. FRIEDMAN:  Yes.  I think I'll just take a moment.

16                           [Prosecution counsel confer]

17             MS. FRIEDMAN:  Yes.  I think Mr. Petrovic also was referring to

18     something else on the list, not what -- at least not what appears in the

19     transcript, and I think it's amounting to testimony, and that I can put

20     my case to the witness and we can discuss it further afterwards.

21        Q.   But the case is this:  That you were on this list, that you were

22     paid by the 8th Administration, as can you see on this list, and that it

23     was not within the category of ATD or JATD?

24        A.   What I can say is the following:  This is a list that was

25     generated by the 8th Administration for the sake of payment.  It has to

Page 19715

 1     do with the payment of certain monies.  I recognised some of the persons

 2     on this list.  The dominant motive is to have a justification for the

 3     money that was paid out.  Now, whether there was someone from some

 4     particular organisational unit, all of it is mixed up here.  I looked at

 5     it very carefully on each and every page; because, basically, the

 6     8th Administration when it is paying per diems, it doesn't really have to

 7     particularly focus on whether a person is from this or that

 8     administration.  It simply has to do with the right of any employee to

 9     have a per diem if they travel.  I really cannot say.  I mean, I just

10     knew the deputy commander and no one else.

11        Q.   And ATD actually appears separately on this list at number 25.

12     Are any of the other individuals that you recognise on the first list

13     people that you knew to be providing assistance to the JATD?

14        A.   Perhaps I could give comments only in respect of persons from my

15     administration, whether any of them assisted the JATD at some point in

16     time, in the context that I already referred to.  Of course, I cannot say

17     anything about others.

18             So, from my administration, it is number 17, myself, and then 18,

19     Miladinovic, Vlatko; and then that person -- is also from the

20     7th Administration; 19 is Ramus, Slobodan, also from my administration.

21             Now, on the basis of what we are on this list, this -- and this

22     particular date, we did something in September 1993 and we received

23     per diems on account of that.  I mean, I'm looking at all these names.

24     This is totally mixed up.  I mean, all these different structures.  And

25     it's certain that not all the persons on this list -- I mean, this is

Page 19716

 1     just payment of per diems.  It is not whether it has to do with the JATD

 2     or something else.  It's just per diems.  Nothing more than that.

 3        Q.   And if your services for which you were paid had been

 4     specifically at that time-period for the benefit or on behalf of the

 5     JATD, you would have likely been listed on a JATD payment list

 6     specifically rather than this more general Serbian DB payment list;

 7     correct?

 8             JUDGE ORIE:  Mr. Petrovic.

 9             MR. PETROVIC: [Interpretation] Your Honour, I object.

10             The witness has been testifying for two days, and he has not

11     provided any services to the JATD.

12             What is this question based on?

13             JUDGE ORIE:  You're giving evidence, Mr. Petrovic.  He has been

14     testifying for two days, and he has not provided -- that's improper.

15             The Prosecution is entitled to explore with this witness lists of

16     payment issued by the 8th Administration on which the witness, his name

17     appears, separate from an entry which refers to the anti-terrorist

18     operations.

19             You can further re -- in re-examination, you can deal with the

20     matter in further detail.

21             Please proceed, Ms. Friedman.  But it would be appreciated if you

22     put clear questions to the witness, rather than to -- whether he would

23     have likely been on other lists or that -- that's -- try to put questions

24     such as whether he remembers that this money was paid to him, and what he

25     may have done for that on the 20 -- in that period of time, what it was

Page 19717

 1     that he got daily travel allowance for.  Then we focus on the facts,

 2     rather than on how the administration could have been different, if the

 3     situation would have been different, and that's not very helpful.

 4             Please proceed.

 5             MS. FRIEDMAN:

 6        Q.   Do you have any recollection of where you were posted or what you

 7     were doing during these time-periods?

 8        A.   Of course I don't remember.  I'm on several of these lists.

 9     Every time I travelled out of town meant that I was entitled to a

10     per diem.  It wasn't only me.  Any employee of the service had that

11     entitlement.

12             Now I really cannot say.  I mean, I really cannot say what this

13     travel was.

14        Q.   Okay.

15             JUDGE ORIE:  For my understanding, Ms. Friedman, a 928 million,

16     that refers to what currency, dinar?

17             THE WITNESS: [Interpretation] Dinars.  Dinars.

18             JUDGE ORIE:  Could you give us an indication, otherwise we may

19     have ways to find out, what approximately 928 million dinars was in

20     September 1993 in deutschemarks because that was the currency you used in

21     practice, from what I understand?

22             THE WITNESS: [Interpretation] No, I cannot recall.  I cannot say.

23             JUDGE ORIE:  What was the amount you got per diem when you were

24     travelling?

25             THE WITNESS: [Interpretation] Our per diems were very small.  The

Page 19718

 1     order of magnitude was, say, let's put it in euro if that's easier now,

 2     20 or 25 euro, present-day euro.  That was the per diem then.

 3             JUDGE ORIE:  What was your salary at that time in present-day

 4     euros?  Well, let's say, per month.

 5             THE WITNESS: [Interpretation] Yes, yes.  I'm trying to remember.

 6     Well, it certainly wasn't more than, say, 500, 600 euro.

 7             JUDGE ORIE:  So the per diems, if you would be travelling, would

 8     be approximately the same as your salary?

 9             THE WITNESS: [Interpretation] I don't understand what you're

10     saying, Your Honour.

11             JUDGE ORIE:  Well, if there's a per diem, which literally means

12     "per day," if that is 20 or 25 euro, if you would in a month be

13     travelling all the time, that would be 20 -- a little bit over 20 times

14     20 to 25 euros which amounts to anything between 450 and 600 euros, so

15     approximately the same as your regular salary was.

16             THE WITNESS: [Interpretation] Yes.  But if it would be an absence

17     of 20 days, or more, of permanent absence, well, then, yes.

18             JUDGE ORIE:  Yes.  But you said it was very small.  It was

19     approximately the same amount being absent.

20             You may proceed, Ms. Friedman.

21             MS. FRIEDMAN:  Thank you, Your Honour.

22             I'd like to tendered these lists into evidence, under seal.

23             JUDGE ORIE:  Lists.  Yeah.

24             Madam Registrar, the number ...

25             THE REGISTRAR:  Document 6535 will receive number P3161,


Page 19719

 1     Your Honours.

 2             JUDGE ORIE:  Thank you, Madam Registrar.  I hear of no

 3     objections.

 4             P3161 is admitted into evidence, under seal.

 5             MS. FRIEDMAN:  And can we go into private session.

 6             JUDGE ORIE:  We move into private session.

 7                           [Private session]

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19720

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13                           [Open session]

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

15             MS. FRIEDMAN:

16        Q.   Mr. Vujovic, you described how, when Mr. Stanisic was removed in

17     1998 -- well, you referred to it as a shake-up, but it was also when

18     Mr. Stanisic was removed from office, and at that point you were

19     offered -- you were removed from your position and offered a different

20     one.  Now, do you believe that that happened because of your affiliation

21     with Mr. Stanisic?

22        A.   In services of this kind, generally speaking, when the chief of

23     service is changed, especially in such a forceful manner, it is only

24     natural that the package would include dismissal of the head of

25     department for operative equipment.  That would be the only reason.  I


Page 19721

 1     don't see any other reason in the context of your question.

 2        Q.   And did you refuse the new position out of an allegiance?

 3        A.   My personal motive for resigning was my thinking of -- along the

 4     following lines, because the replacement had been carried out in such a

 5     way and the people who were brought in were simply people I was convinced

 6     could not bring the results that a state service is supposed to yield.

 7     The key factor -- or, rather, the camel that -- the straw that broke the

 8     camel's back was when Rade Markovic was brought in.  I can say that

 9     straight away.

10             He held this short briefing with the chiefs of departments, and

11     he said that everyone should keep their jobs for the time being, and he

12     ended the meeting with the following words.  This is verbatim:  I expect

13     full loyalty from you to the president, the state, and the party.

14             All of us who had worked in the previous period, while

15     Jovica Stanisic headed the service, were taken aback, astounded to hear

16     the chief of service stay -- say at the very beginning that he would

17     require that from the people who would stay on, full loyalty to the

18     president, state, and party.  Which party?  I personally took this -- I

19     mean, it wasn't only me, but I personally took this as a terrible

20     degradation of the service itself because absolutely in the previous

21     period - and I underline this word, "absolutely" - we had not been linked

22     to any party whatsoever.

23        Q.   And, I don't know if you're aware, there was a report in

24     February in 2002 of a "Blic" source that said that you were a person who

25     still maintained some power from behind the scenes, and it mentioned only

Page 19722

 1     four people:  Stanisic, Simatovic, Milorad Ulemek and you.

 2             Do you know why you were singled out to be on this list?

 3             MR. JORDASH:  Well, perhaps the witness could be shown and the

 4     rest of us could be shown the report so we all know what we are dealing

 5     with.

 6             MS. FRIEDMAN:  At 65 ter 6530.  It's a second-hand report.

 7        Q.   And I just want to know if the witness had heard of this before.

 8             MR. PETROVIC: [Interpretation] Your Honours --

 9             MS. FRIEDMAN:  Second page.

10             MR. PETROVIC: [Interpretation] Your Honours, my learned friend

11     said that it had been published in the "Blic" newspaper.  I am interested

12     to see the original from the "Blic" daily.  Because what we are looking

13     at the moment is some computer-generated copy.

14             JUDGE ORIE:  I think that's what you said, Ms. Friedman, isn't

15     it?

16             MS. FRIEDMAN:  Yes, yeah.

17             JUDGE ORIE:  Ms. Friedman said that it's a second-hand reference.

18             MS. FRIEDMAN:  Yes, it's just in the last paragraph and it just

19     says a "Blic" news source.  I did not call it up or intend to tender it,

20     actually, because it is only the basis for my question.  I don't --

21             JUDGE ORIE:  Whether -- of course, the witness could comment on

22     it, whether it was or was not published in "Blic," whether that's a

23     reliable reference is another matter.  But I think that for Ms. Friedman

24     it's not most important whether it was in "Blic" or in the

25     "New York Herald," or wherever, but that this kind information was

Page 19723

 1     published.

 2             Could you tell us where this was published, Ms. Friedman.

 3             MS. FRIEDMAN:  This is in the VIP news source which is a

 4     collection quoting other -- other news source.

 5             JUDGE ORIE:  I'm familiar with VIP.  But if --

 6             MS. FRIEDMAN:  Published in Belgrade.

 7             JUDGE ORIE:  Okay.  That's the source, Mr. Petrovic.

 8             Please proceed, Ms. Friedman.

 9             MS. FRIEDMAN:  Yes.

10        Q.   I was just -- Mr. Vujovic, do you -- were you aware of this

11     before?  Do you know what could have caused this rumour?

12        A.   I've never seen this before.  And a perfunctory look tells me

13     that the context is co-operation between Serbia and Israel.

14             The author of this text says that a lobby was set up to do

15     something with regard to the co-operation between Israel and Serbia and

16     other things.  Me, personally, I think this is sheer nonsense.  What year

17     did you say that that was published?  2000?

18        Q.   2002.

19        A.   2002.  I was assistant chief of the RDB Serbia.  I was appointed

20     to that position with Prime Minister Djindjic's consents.  So this story

21     is sheer nonsense.

22        Q.   Okay.

23             MR. FRIEDMAN:  Now, I would just like to note for Your Honours

24     that actually concludes my questions, but on Pajzos, since we expected

25     the witness to have spent more time there but didn't, I'm just going to

Page 19724

 1     refer Your Honours to the evidence demonstrating the continuity of the

 2     Serbian DB unit and it's --

 3             JUDGE ORIE:  Are you -- at this moment, are you cross-examining

 4     the witness or are you arguing what, although the witness could not

 5     testify about -- what we should look at.

 6             MS. FRIEDMAN:  I would like to put on the record six documents to

 7     look at.

 8             JUDGE ORIE:  I think, as a matter of fact, that that should not

 9     be done.  If you say the witness could not confirm this and then --

10     either you may draw our attention to what is in evidence in relation to

11     this evidence but not a continuity of Pajzos in general terms.  That's

12     seems to be inappropriate to bring to our attention now.  I'm not saying

13     that it would, under all circumstances, be inappropriate in the future or

14     when we will hear argument.

15             MS. FRIEDMAN:  Okay.  Well, then, I have no further questions.

16             JUDGE ORIE:  You have no further questions.

17             Mr. Petrovic --

18             MR. PETROVIC: [Interpretation] Your Honours.

19             JUDGE ORIE:  Yes.

20             MR. PETROVIC: [Interpretation] Your Honours, I have just a few

21     questions.  It will take me no more than a few minutes to put them, but I

22     believe my learned friend from the other Defence team has also got a few

23     questions.  But I believe if I start now, we can finish today, in any

24     case.

25             JUDGE ORIE:  Mr. Jordash, how much time would you need?


Page 19725

 1             MR. JORDASH:  I was hoping for ten minutes.

 2             JUDGE ORIE:  That's fine.  Then we have to do it tomorrow.

 3             Mr. Petrovic, I'm always a bit suspicious if you say that you can

 4     finish in four minutes.  I hope you will not blame me for that.  But

 5     let's see how far we come.  Four minutes are left.

 6             Mr. Vujovic --

 7             MR. JORDASH:  It's me first.

 8             JUDGE ORIE:  Oh, it's you first.  Yes, you are right.  That's --

 9     my apologies.  Four minutes for you -- three and a half by now.

10             MR. JORDASH:  Thank you.

11                           Further cross-examination by Mr. Jordash:

12        Q.   Just, can I pick up quickly on your alleged affiliation with

13     Mr. Stanisic.  You were shown a document where you were given a financial

14     reward, and it actually says statement of reasons:  The deputy head of

15     the department has proposed to give the financial reward.  Who was the

16     deputy head of the department at the time who proposed to give -- or at

17     the time.  Leave it there.

18        A.   I believe that it said either assistant chief or deputy chief.

19     Let's be precise.  I believe that I read the text well.

20        Q.   Let's -- let's have it up on the screen.  06527, please, I think

21     not to be shown to the public.

22             MR. JORDASH:  Perhaps we should move into private.

23             JUDGE ORIE:  We move into private session.

24             [Private session] [Confidentiality lifted by order of the Chamber]

25             THE REGISTRAR:  We're in private session, Your Honours.

Page 19726

 1             JUDGE ORIE:  Thank you, Madam Registrar.

 2             MR. JORDASH:

 3        Q.   We can see there underneath the statement saying statement of

 4     reasons.  And it states that the deputy head of the department has

 5     proposed the financial reward, and that's ...

 6             The English translation says "deputy."

 7        A.   [In English] deputy.

 8        Q.   What does the -- how do you read it, please?

 9        A.   [Interpretation] Assistant head.

10        Q.   Okay.

11        A.   And that's what I'm reading in the text.

12        Q.   And who was the assistant head in May of 1998, please?

13        A.   At that moment, the assistant head of the department for

14     equipment was Vojkin Cvetkovic, who was my immediate superior.

15        Q.   Thank you.  Now, my learned friend also suggested that you left

16     your post because of your affiliation with Stanisic.  Am I correct that

17     when Stanisic left and when you left, many members of the

18     State Security Service were replaced by members of Milosevic's political

19     party; is that correct?

20        A.   Yes, you're absolutely right.

21             Mr. Stanisic was removed from his position on the

22     27th of October, 1998.  And I, myself, was removed on the 30th of

23     October, 1998.  That meeting took place at night, starting at about

24     1000 p.m. at -- that same people, together with me, three other heads of

25     services were removed from their positions --


Page 19727

 1             JUDGE ORIE:  Whether it was day or night is -- was not part of

 2     the question.

 3             But we have to conclude for the day.  Tomorrow we'll need a

 4     little bit more time, Mr. Vujovic.  I again instruct you that you should

 5     not speak or communicate in any other way about your testimony.

 6             And we adjourn until tomorrow, the 24th of May, at 9.00 in the

 7     morning, in this same courtroom, II.

 8                           [The witness stands down]

 9                            --- Whereupon the hearing adjourned at 1.47 p.m.,

10                           to be reconvened on Thursday, the 24th day of May,

11                           2012, at 9.00 a.m.