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
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
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
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
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
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;
25 A. It was official. After that, possibly we had a conversation
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
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
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.
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
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
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
1 such case. Not everyone wanted to accept the job offers made to them
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
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
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
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
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
1 Pajzos and the other locations, excuse my simplicity, but you were
2 listening into telephones of everyone or targeted telephones of people of
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
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
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?
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
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
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.
11 Page 19657 redacted. Private session.
22 [Open session]
23 THE REGISTRAR: We're in open session, Your Honours.
24 JUDGE ORIE: Thank you, Madam Registrar.
25 MS. FRIEDMAN:
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
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
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.
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
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
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;
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
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
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
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.
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.
1 Q. And about a dozen more people securing the facility. That's
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
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.
1 MS. FRIEDMAN: Thank you.
2 Q. And the Licko Petrovo Selo facility, that was also in Croatia;
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
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
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,
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.
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.
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.
11 Pages 19670-19679 redacted. Private session.
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.
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.
11 Pages 19682-19683 redacted. Private session.
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.
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.
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
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
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?
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
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
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.
11 Page 19692 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.
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
1 any further unless we are in private session, which we are not at this
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
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
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
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.
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.
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
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
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
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
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
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.
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
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.
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
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.
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
13 So perhaps I should -- should ask her to rephrase or repeat her
15 MS. FRIEDMAN: I will quote from yesterday's transcript.
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."
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
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.
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
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
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
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
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
24 JUDGE ORIE: Last year-- a reference to last year is usually to
25 the previous year, Mr. Petrovic.
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
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
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,
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.
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
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.
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?
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
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
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;
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
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
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
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
25 THE WITNESS: [Interpretation] Our per diems were very small. The
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,
1 Your Honours.
2 JUDGE ORIE: Thank you, Madam Registrar. I hear of no
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]
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
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
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
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
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
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
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
25 JUDGE ORIE: Mr. Jordash, how much time would you need?
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.
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 --
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.