1 Thursday, 24 June 2010
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 9.08 a.m.
5 THE REGISTRAR: Good morning, Your Honours. Good morning to
6 everyone in and around the courtroom. This is case IT-08-91-T, the
7 Prosecutor versus Mico Stanisic and Stojan Zupljanin.
8 JUDGE HALL: Thank you, Madam Registrar.
9 Good morning to everyone. May we have the appearances, please.
10 MR. HANNIS: Thank you, Your Honour. On behalf of the Office of
11 the Prosecutor, I'm Tom Hannis along with Jasmina Bosnjakovic.
12 MR. ZECEVIC: Good morning, Your Honours. Slobodan Zecevic,
13 Slobodan Cvijetic, Eugene O'Sullivan, and Ms. Tatjana Savic, appearing
14 for Stanisic Defence.
15 MR. PANTELIC: Good morning, Your Honours. For Zupljanin
16 Defence, Igor Pantelic. Thank you.
17 MR. HANNIS: Good morning, Your Honour. Our first witness today
18 is Radovan Pejic. I would like to put one matter on the record before he
19 comes in. I have had the registrar hand around a hard copy of a portion
20 of Exhibit P1428. This is a log-book that came into evidence with the
21 witness Dragan Kezunovic earlier. And that document was previously 65
22 ter 2516, and originally in e-court it only had 50 pages of the B/C/S of
23 the log-book. Other portions of that same log-book were in e-court under
24 other 65 ter numbers but we've now moved into P1428 the entire 400 and
25 some pages of the B/C/S. So it's complete. I wanted you to know that.
1 The hard copy I've given to you is because I intend to show the
2 witness a few documents that I believe are listed in the hard copy
3 portion of this document, and I think it will be easier for us to have a
4 hard copy of the log-book while we put up on the screen copies of the
5 exhibits that pertain thereto. I think it will be easier for all of us
6 to work. That's why I've handed it around. I have also given it to the
7 Defence along with a copy for their client.
8 And with that, I'm ready to proceed.
9 JUDGE HALL: Mr. Hannis, perhaps if I'm here long enough I will
10 master this matter of entering exhibits and numbering them.
11 Do I understand the position to be, that this is a working copy
12 of -- of a -- of -- of a full Exhibit, that's my first question?
13 MR. HANNIS: That's correct. This is the first 50 pages of an
14 exhibit that is 420-some pages, I think, in the B/C/S original.
15 JUDGE HALL: My second question is whether the exhibit that has
16 been entered has unnecessary pages to -- to simplify it, which should,
17 for practical purposes, now be deleted to -- to tidy up the exhibit, as
18 it were.
19 MR. HANNIS: Your Honour I can take a look at that. I don't
20 recall now the ending date in the B/C/S but certainly as far as I'm
21 concerned anything after December 31st, 1992 or the first week in
22 January probably can be deleted. But as I stand here for the moment I
23 don't recall where 1993 ends. I know what you have before you takes us
24 up to I think, early August, 1992.
25 JUDGE HALL: So at some point we can anticipate, can we, that the
1 OTP who would have tendered this exhibit would perform the exercise, the
2 tidying exercise and the Registry and the Chamber and everybody else
3 would be put in the picture.
4 MR. HANNIS: Yes. And in relation to that I should indicate that
5 at this point the only English translation that has been done is of the
6 first ten or so pages. The 49 items that were listed under the portion
7 of the log-book that was kept for MUP headquarters in Vrace between the
8 20-something of April and the 13th of May, I believe.
9 But we will be obtaining an English translation of the portions
10 of the log-book for CSB Sarajevo from June something 1992 when it begins
11 through to the end of 1992. And then the rest we will remove or delete.
12 JUDGE HALL: Thank you.
13 So -- so you may call your - to borrow your words - first
14 witness. I don't know if that was a slip of the tongue.
15 MR. HANNIS: Thank you. Yes, Your Honour. We call ST-160,
16 Radovan Pejic.
17 [Trial Chamber confers]
18 MR. HANNIS: I'm sorry, I think I misspoke. For the record he's
19 ST-168, and it looks like I said 160, I misspoke.
20 MR. ZECEVIC: If I could be of assistance to my learned friend
21 and the Trial Chamber. The P1428 the last entry of 1992 is under number
22 1813. Thank you.
23 JUDGE HARHOFF: Is there a date for that last entry?
24 MR. ZECEVIC: 31 December 1992.
25 JUDGE HARHOFF: Thanks.
1 MR. ZECEVIC: But it has numbers from 1 until 1813 are the
2 entries for 1992.
3 JUDGE HARHOFF: Thanks.
4 [The witness entered court]
5 JUDGE HARHOFF: Good morning to you, Mr. Witness. Can you hear
6 me in a language you understand?
7 THE WITNESS: [Interpretation] Yes.
8 JUDGE HARHOFF: That's very good. Thank you for coming to the
9 Tribunal to give your testimony.
10 We will start by asking you to read the solemn declaration, which
11 is being shown to you.
12 THE WITNESS: [Interpretation] I solemnly declare that I will
13 speak the truth, the whole truth, and nothing but the truth.
14 JUDGE HARHOFF: Thank you, sir. You may sit down.
15 And, sir, could we begin by asking you to state your full name
16 and your date and place of birth.
17 THE WITNESS: [Interpretation] My name is Radovan Pejic. I was
18 born on the 22nd of August, 1956, in a place called Jelasica, Kalinovik
19 municipality, Bosnia and Herzegovina.
20 JUDGE HARHOFF: Thank you very much. And what is your ethnicity?
21 THE WITNESS: [Interpretation] I'm a Serb.
22 JUDGE HARHOFF: Thank you. And what's your profession today?
23 THE WITNESS: [Interpretation] I'm an inspector of the crime
24 police in a team belonging to the Ministry of Interior of Republika
25 Srpska for investigating war crimes.
1 JUDGE HARHOFF: And where are you posted at the moment?
2 THE WITNESS: [Interpretation] The team has its headquarters in
3 Pale, but in organisational terms it is directly linked to the cabinet of
4 the minister and the police director.
5 JUDGE HARHOFF: Thank you. Sir, what was your occupation in
7 THE WITNESS: [Interpretation] In 1992, I was an employee working
8 in the militia or police, and I worked in the communications centre and
9 the Security Services Centre until the tragic conflicts bloke out in
10 Bosnia-Herzegovina when I transferred to what is today the MUP of the
11 Republika Srpska in the communications centre of the MUP at Vrace.
12 JUDGE HARHOFF: So you were transferred to Vrace in April 1992;
13 is that it?
14 THE WITNESS: [Interpretation] Yes, that's right. And I worked as
15 a communications operative as a signalsman in the centre.
16 JUDGE HARHOFF: Did you say in Vrace throughout 1992?
17 THE WITNESS: [Interpretation] I stayed at Vrace. I was there in
18 1992, the beginning of 1992, and when the seat of the ministry moved from
19 Vrace to Pale, or, rather, to Mount Jahorina, I then requested the chief
20 of the Security Services Centre and the minister to allow me to remain in
21 the Security Services Centre so I continued to work there in the
22 department and for a relatively short period of time we stayed in Vrace
23 and then moved for security reasons to Lukavica.
24 JUDGE HARHOFF: Thank you very much.
25 Now, sir, is this your first testimony before this Tribunal?
1 Have you ever given evidence before in this Tribunal?
2 THE WITNESS: [Interpretation] This is the first time I'm
3 testifying. I've never testified before.
4 JUDGE HARHOFF: Have you testified in any domestic criminal
5 proceedings about matters relating to the war?
6 THE WITNESS: [Interpretation] No.
7 JUDGE HARHOFF: Very well. Let me then explain to you briefly
8 how the proceedings will unfold here.
9 You have been called as a witness by the Prosecution, who is
10 sitting to your right, and the Prosecution has asked for, all together,
11 two-hours to examine you in-chief. After that, the counsel for
12 Mr. Stanisic, sitting to your left, has asked for three hours to
13 cross-examine you. And when Mr. Zecevic is through with his
14 cross-examination, Mr. Pantelic, who is representing the other accused,
15 Mr. Zupljanin has asked for one and a half hours to cross-examine you.
16 And when Mr. Pantelic is through, we will give the floor back to
17 the Prosecution who will have a chance to put some final questions to
18 you, in light of the answers you have given through your
20 And after that, and in between, the Judges, may, at all times,
21 put questions to you.
22 So that will be the end of your testimony. We hope that we can
23 complete your testimony by tomorrow. Now, one practical matter. The
24 recordings here are taken on videotape, and the tapes have to be changed
25 every 90 minutes, so that means that every hour and a half we have to
1 have a break. These breaks are about 20 minutes and then we continue.
2 And the proceedings today will end at a quarter to 2.00 and then we will
3 resume tomorrow at 9.00 in this courtroom.
4 That's all I have to say except that I wish to remind you that
5 now that you have taken the solemn declaration you are obliged to tell
6 the truth, and I should remind you that there is a severe penalty for
7 providing false or incomplete testimony to the Chamber here.
8 Thank you very much. And I now give the floor to the
10 Mr. Hannis.
11 MR. HANNIS: Thank you, Your Honour.
12 WITNESS: RADOVAN PEJIC
13 [Witness answered through interpreter]
14 Examination by Mr. Hannis:
15 Q. Good morning, Mr. Pejic. Judge Harhoff has covered most of it
16 but I would like to ask you just a few further questions about your
17 background leading up to the conflict and some of your work since then.
18 Can you tell the Judges what your educational background was
19 before you got to work for the police? Just briefly.
20 A. I graduated from the secondary school for Internal Affairs at
21 Vrace in the second generation in 1974. And immediately after that, I
22 was sent to the Secretariat of the Interior in Novo Sarajevo, Sarajevo
23 where I worked until 1978 when I transferred to the youth organisation in
24 Novi Grad, a socio-political organisation, and there I occupied various
25 posts right up until 1991 or rather, the multi-party selections in Bosnia
1 and Herzegovina when I returned to the Security Services Centre in
2 Sarajevo and the department for encryption and communications.
3 During my regular schooling, in addition to gaining the necessary
4 training for a trainee policeman, I went to a specialist course for
5 photography or, rather, crime technology and within the framework of my
6 working activities I also attended an encryption course which allowed me
7 to take the professional examination and be sent to the security services
8 centre and communications centre of Sarajevo.
9 I have engaged in politics from the youth association and from my
10 youth association membership there, and then on I was executive secretary
11 member of the Presidency of various organisations and after the conflict
12 broke out in addition to communications I also dealt with analytics and
13 informatics, and for a time I worked as a journalist analyst. In the
14 meantime I graduated from the London school for media relations and was
15 deployed to the post of the head of the bureau for relations with the
16 public of the MUP of Republika Srpska.
17 Upon completion or after the elections for the new government and
18 the new minister I was sent back to the team to investigate war crimes
19 and that is something that we reached an agreed about.
20 Q. Thank you. And I understand from your answers to Judge Harhoff
21 that immediately before the conflict broke out in April 1992, you were
22 working in the communications centre of the -- the joint or the pre-war
23 MUP in Sarajevo; is that correct?
24 A. That is correct, yes.
25 Q. And when did you go to Vrace to work for the newly formed Serbian
1 MUP and later it was called the RS MUP?
2 A. I arrived at Vrace on the 6th of April. However, I would like to
3 explain something. One month prior to that, or maybe a little more, the
4 chief of the department for communications and encryption of the Security
5 Services Centre, of Sarajevo Mr. Zlatan Sehovic was his name and his
6 deputy Draskovic, Slavko, Slavko Draskovic held a meeting with all the
7 communications officers, and we were briefly told that there was certain
8 political events afoot and unrest and that most probably the ministry
9 would -- of the interior would be divided. That is to say, the minister
10 of the republic of BH divided into at least two parts, and we were told
11 that we shouldn't pay any attention to those events but that we should
12 act in a highly responsible and professional manner and conscientiously
13 carry out our tasks linked to communications and that the leaders would
14 see to other matters and take care that on the schedules and occupying
15 all posts in the communications department there would not be just a mono
16 ethnic composition but that we would all be represented, Serbs, Croats,
17 Muslims or rather, Bosniaks so that quite simply it didn't matter if the
18 ministry was split, if the MUP was split. It didn't matter which
19 minister was signing the documents, that all information had to be sent
20 out in a highly professional manner to the addressees, and at one point I
21 think it was between the 3rd and 4th of April, during the night, on the
22 night shift I remained alone on all the positions in the communications
23 and encryption department which was set up in various offices, on the
24 ground floor and on the first floor, and when I didn't know what to do, I
25 contacted the chief of the department, who was Zlatan, and he called me
1 to come to the teleprinter and encryption centre where he was, where he
2 came to, and then he explained to me that his colleagues allegedly
3 received information according to which that very night the municipal
4 SUP, which was where our seat was, would be targeted and that our
5 colleagues for that reason had left their job, left their work posts, and
6 then in front of me, he would call out the names of each one of them and
7 said, Now, if you received that kind of information, why didn't you
8 inform [indiscernible] but why did you leave him all alone? So he told
9 me that the safest thing for me to do was in the morning to spend as much
10 time in the encryption cubicle which was a safe place, secure place
11 specially built to cater to fire and untoward events, and so in the
12 morning when I finished my duty and shift, I was allowed to go home and
13 then at the entrance I saw that there were -- that none of my colleagues
14 were there anymore, no security details. And that the people who were
15 there then were people I didn't know, and that made me decide not go back
16 to work. I contacted Draskovic. He told me to report to the new centre
17 at Vrace.
18 Q. If you could -- I appreciate that you wanted to explain all that
19 to us, but can you try and -- and keep your answers short, limit them to
20 my question.
21 If you do need to add more, I certainly am willing to let you do
22 that if you advise me.
23 JUDGE HALL: And also, could you show down because what you say
24 has to be interpreted. Thank you.
25 MR. HANNIS:
1 Q. Yes. I only have two hours for my time so that's why I have to
2 try and limit you. Also I think the interpreters are requesting that you
3 slow down because you're speaking pretty rapidly for them. Okay?
4 A. Okay.
5 Q. So, Slavko Draskovic is the one who told you to report to Vrace.
6 When you went there on April 6th, who did you speak to? What did you do?
7 A. On the 6th of April, in the communications centre, I met my
8 colleague, Mr. Trifkovic, and then on the following day, I had
9 conversation with the chief of administration or assistant minister for
10 communications, Mr. Kezunovic.
11 Q. Obrad Trifkovic is the colleague you meant?
12 A. That's right. Communications officers who had worked in the
13 Republic of Bosnia-Herzegovina MUP from before.
14 Q. And Kezunovic was Dragan Kezunovic?
15 A. That's right, Dragan Kezunovic. He was assistant of the minister
16 for communications and encryption.
17 Q. And when you arrived at Vrace on the 6th of April, 1992, what --
18 what communications equipment did you -- did you find available to use at
19 that location?
20 A. At the time, there was only one functional phone that was
21 connected to the switchboard but the switchboard wasn't functioning
22 because of the large number of local links that were short-circuited.
23 There was some damage to the system we have had, also one fixed radio
24 station, and some mobile radio stations that were part of the equipment
25 of the special and traffic brigade from Vrace. And the remainder of
1 material we got only later, and we also had some field telephones that
2 were connected to the guard posts.
3 Q. Did you have any teletype machines?
4 A. There was a teletype machine, but it wasn't operational because
5 the node for its function was located in the CSB in Sarajevo, and they
6 had been made unoperational, at least for the area that belonged to MUP
7 of RS.
8 Q. We've heard the terms KT, which I think translates into English
9 as short wave and UKT ultra short wave. Can you explain, first of all,
10 for me, the difference between KT and UKT?
11 A. High frequency stations HF work on high frequencies have big
12 range. There is no need to use repeaters, they have their own antennas
13 for transmission. This antenna is just taken to an appropriate place,
14 then one makes a calculation in order to see how far it needs to reach
15 and it can actually send messages, as we say, to the other part of the
17 The HF or very high frequency radio stations are divided into
18 fixed and mobile. They use very high frequencies, ultra high
19 frequencies, and what they need is to have connection with places which
20 are visibly visible to them. If they hit some kind of obstacle the wave
21 changes directions and they cannot be used for communication. To make
22 them operational, one needs repeaters. In this case they were at
23 Trebevic, but that was not something that could be done through the CSB
24 because it could be done only after a code was typed in the base. Why?
25 Because in the UHF frequency we have communication using two lines, one
1 for transmission, the other one for reception, except when one is using
2 the Simplex principle, when you have to have optical visibility. In
3 semi-Duplex, you need to have optical visibility only to the repeater.
4 Q. And if I understand correctly, you said the repeater was located
5 on Trebevic?
6 A. Yes.
7 Q. And was that -- and in April 1992, was that an area under control
8 of the Serbian side?
9 A. Physically, yes, Trebevic was under our control.
10 Q. And were you able to use that -- that relay station or repeater
11 for your communications from Vrace in April, May, June, 1992?
12 A. For the first few days, yes. But after that date, my colleagues
13 from the centres, very often, would, when we would be using this link,
14 switch off the repeaters and in attempts to find a good solution we went
15 to Trebevic myself and a colleague of mine, and we switched off the
16 repeaters and instead of the repeaters we introduced the most reliable
17 mode of communication, a man, who used two station to -- with one station
18 repeat -- receive the communication and then the other one to send the
19 message. In order to prevent any kind of incursions into our system we
20 set up a code table, and we could also recognise the person by the voice
21 and then we could say, This voice is something that may be transferred.
22 Our colleagues from the CSB immediately noticed what we had done and they
23 used the so-called war reserves. I knew about the existence of the
24 equipment. They put the antennas of their repeaters on the high
25 buildings and started using them.
1 We worked in such a way that somebody had to -- a person had to
2 be there next to the repeater to maintain it. However, this
3 communication functioned only for the region of Sarajevo, rather, for the
4 area where there is optical visibility between the repeater's antenna and
5 the user. For instance, towards Zvornik, Han Derventa, there was an
6 evaluation. Beneath that was Ilidza, Hadzici, Ilijas. This was what we
7 could cover but nothing further than the region of Sarajevo.
8 Q. How about contact with Pale? What kind of communication links
9 did you have between Vrace and Pale in April, May, June of 1992?
10 A. In addition to the UHF link and I don't remember when this was, I
11 think maybe in late April or early May, at the time of our transfer to
12 Lukavica we also got VHF communication. These two modes of
13 communications with Pale were reliable but we also used phone lines when
14 there was electricity in Lukavica or in Pale which was more often the
15 case in Pale, and the phones were an efficient means of communications
16 only after the phone switchboard at the school of economics was made
18 In addition to that, before the airport was transferred to the
19 international forces or the United Nations, we managed to put three
20 telephone lines from Ilidza and connect them because they were something
21 that we also used in the CSB. We started obtaining fax machines or
22 started using the ones that were there at Vrace. We also received some
23 from various companies or if someone had tried to steal such a machine
24 then police at their check-points would seize it from them and that
25 equipment would also be used.
1 Q. Thank you. Do you recall how many fax machines you had at Vrace
2 in April, May, and June of 1992?
3 A. No. But if one's talking about dispatch communications, that was
4 registered, but there wasn't much of that kind of correspondence because
5 the fax machine in the Department of Interior Affairs is something that
6 not an official mode of communications between organs of the interior
7 because, according to regulations, information should be sent through
8 dispatch communication means, meaning the teletype machine, which was put
9 into function only later.
10 Q. Do you recall approximately how much later that happened?
11 A. The first VHF devices equipment in our centre, we received them
12 in late April/early May. But they were used mostly for the training and
13 for the checkups, to see how things will work. Some of the stations that
14 did not move their seat, such as Ilidza, Ilijas, and Vogosca, also had
15 VHF equipment, and after several days of checkups, we could start using
16 open communications. However, not the encrypted or closed protected
17 communications. We waited for additional equipment, the so-called TG
18 devices that could be linked up with VHF equipment and teletype machines
19 and in such way one would be able to send written communications both in
20 open and closed form, and only later other police stations in the area
21 got the equipment but the communication with MUP was functioning,
22 providing, of course, there was electrical power because not all the
23 centres had generators. We got that only in June or July.
24 Q. In addition to this various kinds of equipment and means of
25 communication, did you also, when necessary, make use of human beings as
1 couriers when you weren't otherwise able to transmit a message by phone
2 or fax or teleprinter, or radio?
3 A. Of course. An order was issued that if anyone's coming to the
4 area of the CSB must report to the communications centre, and then we
5 would give them envelopes with all the dispatches we've failed to send
6 until that time, because the courier is the most reliable means of
8 But that mode of communication also implied delays because
9 physically speaking from Lukavica to Ilidza it is necessary only to pass
10 by the airport. However, because that route was closed, it was necessary
11 to go first to Rajlovac then Vogosca all the way around Pale and Trebevic
12 before reaching Lukavica, which is about 160 or 170 kilometres off a
13 route, and the other way it would have been only about 10 kilometres.
14 Q. I understand, thank you. I'd like to show you now an exhibit.
15 MR. HANNIS: This is P573.
16 Q. And this is a document dated the 29th of June, 1992. It's a
17 performance report for the period April to June 1992 for the Ministry of
18 the Interior. And you see the cover page there.
19 I would like to go to page 13 in the B/C/S in e-court. And
20 that's page 8 of the English.
21 Mr. Pejic the part I'd like you to look at is the full
22 paragraph in the middle of the page, immediately above the number 2.
23 I'll read from my English translation and ask you a question. It
25 "At this point" - 29 June, I guess - "the minister of the
1 interior had its headquarters in Pale uses public telephone and telefax
2 communication systems to maintain contact with the Security Services
3 Centres in Banja Luka Bijeljina and Sarajevo. And short wave systems for
4 contact with Trebinje and Sarajevo CSBs."
5 I'll skip a sentence. It says:
6 "An ultra short-wave link has been established with the Sarajevo
7 CSB because technical conditions existed for that."
8 Does that conform with your memory of the situation at the end of
9 June 1992?
10 A. Yes. I believe that this is a true account of the conditions in
11 the communications centre of the CSB centre.
12 Q. When did the RS move offices or headquarters from Vrace to Pale?
13 Do you remember approximately when that took place?
14 A. I think it was in late May or early June when the preparations
15 started, and, after that, was when MUP moved and the CSB moved to
16 Lukavica about ten days after that. I cannot give you exact dates. This
17 is to the best of my memory. But I think it was -- I know it was in late
18 May or early June, because we didn't have proper working conditions at
19 Vrace although we were in the facilities of the Ministry of the Interior.
20 Q. And at Lukavica, I take it that's where you went when the move
21 took place. You didn't go to Pale, right?
22 A. I did not. As I've already explained, thanks to the
23 understanding of the minister and the chief of the CSB, my request was
24 approved and the chief proposed to the minister that I be appointed the
25 chief of encryption and communication in CSB, and immediately after my
1 appointment I started preparing the facilities.
2 Lukavica is only several kilometres away from Vrace. We were not
3 immediately at the demarcation lines or combat lines, unlike Vrace.
4 Q. Your CSB chief was Mr. Cvetic?
5 A. Yes. Late Zoran Cvetic, whom I met upon my arrival in Vrace.
6 Q. And at Lukavica, what -- what equipment did you find available to
7 be used when you moved there? Just briefly and generally.
8 A. We moved high frequency and ultra high frequency equipment we had
9 at Vrace, and we also set up phones, because, by then, the school of
10 economics switchboard was already functional. We made sure that we had
11 sufficient number of phone lines for fax and mediation needs. Also, for
12 a time, we used several phones that belonged to the other side but they
13 would very soon detect us doing it and they would switch them off. We,
14 for a while, had three federal numbers, but as soon as they would realize
15 there was a lot of communication using those lines, because they were
16 listening in, they would realize that it's us using it and they would
17 switch it off either by switching it off or cutting the lines. We had a
18 reliable phone line, or, rather, two numbers which went from Ilidza to
19 Lukavica, from the post office switchboard at Ilidza, since this area was
20 throughout the period under the RS MUP control.
21 Q. Okay. We've seen a payroll document from May 1992 where there's
22 a Radovan Pejic listed as working in the analytical section. Is that
24 A. Yes. And to avoid any misunderstanding, this is the very period
25 when I, as a communications officer, based on the order by the minister
1 and his assistant, was charged with some analytical tasks, and that's
2 when I had medial co-operation with Mr. Petar Vujicic. Once we would get
3 the bulletins in the morning as a communications officer, I could have
4 done it on my own but formally speaking analysts were to do that work,
5 and then I compiled a bulletin that was then through the ministry sent to
6 the highest leaders in Republika Srpska but because the distribution in
7 the CSB was already underway, it was clear that the request would be
8 granted. There was a, in principle, agreement between the officials and
9 that's why I could be found on both lists because the list was not done
10 at the end of the month but in the -- very first day of the following
12 Q. How long did you remain in your position as -- as chief of
13 communications for the Sarajevo CSB?
14 A. Until our move to Ilidza. And I think that was in 1994. In
15 1994, I was sent to Ilidza to start the preparations for the transfer of
16 CSB into the premises of the SJB at Ilidza. Upon arrival in Ilidza, I
17 worked in the encryption and communication unit of the station and
18 prepared for the arrival of other services.
19 Q. Thank you. I understand at the beginning of the conflict in
20 early April when the separation occurred that you had a shortage of
21 qualified communications people on the Serbian side; is that right?
22 A. That's right.
23 Q. [Previous translation continues] ...
24 A. Some of our colleagues failed to leave in time, and later, when
25 they wanted, they could not. Vrbarac Srdjan confirmed that who joined us
1 in the department in only 1995. They didn't simply expect things to
2 develop so -- and were unable to reach the MUP of Republika Srpska. They
3 stayed working down there for a long time, but once the conditions were
4 ripe, they also left. But there were very few of us that were in our
5 area that was under our control and the same applies to the people who
6 were in charge of maintenance of the communications. But, initially, in
7 the seat at least, the situation was slightly better than with the
8 maintenance people.
9 Q. To make up for this shortage, did you hire new employees to fill
10 the gap?
11 A. Yes.
12 Q. [Previous translation continues] ... personally as a chief of
13 coms in CSB Sarajevo, or did it require higher approval?
14 A. The procedure is very specifically prescribed. In case of
15 communications officer, there are some -- more specific requirements. I
16 could identify the person who was capable of being a communications
17 officer, the person would first be interviewed. Then I would make a
18 proposal with an explanation and pass it on to the chief of centre, who
19 would then pass it on to the minister, asking for a person to be
20 appointed to such and such a position and such and such a department.
21 And once the conditions were there, we abided by this procedure and, no,
22 I could not hire anyone but I could influence in my proposal who is --
23 who should be appointed.
24 So also before the minister has approved it, the assistant for
25 communications and encryption also has to approve the person. The
1 minister wouldn't sign anything without the approval, prior approval of
2 the assistant.
3 Q. And this -- this system that required approval of the minister,
4 was that true only for communications employees or for all MUP employees;
5 if you know?
6 A. According to the law, people can be hired and appointed into the
7 service only by the minister. There is prescribed procedure and
8 conditions under which people can be hired by MUP. At certain point,
9 members of the reserve police force were, based on their work time
10 assignments, included into the MUP stations, and these issues were only
11 later resolved by either appointing these people into the ministry or
12 dismissing them. The practice is even now like that, namely the director
13 of the police is also entitled to sign some of the appointment decisions.
14 Q. Thank you. When you went to Vrace on the 6th of April, during
15 that first month in April, who -- who else was there in the Serbian MUP?
16 Who were the senior staff, if any, present at Vrace?
17 A. Very often when he was not somewhere in the field or elsewhere,
18 the minister of the interior was at Vrace and his assistants as well and
19 deputies, unless, of course, they were somewhere out in the field,
20 because the official seat of the ministry at the time was at Vrace and
21 all the accompanying services were being set up at that location. There
22 was also the special police unit located there under the command of
23 Mr. Karisik. In addition to the ministry seat, there was the centre's
24 seat and the police station.
25 Q. Centre, CSB Sarajevo?
1 A. At the time it was called Sarajevo-Romanija-Birac centre because
2 we covered considerably larger area than the one of the Sarajevo region.
3 We had Zvornik, Sarajevo -- Bratunac, Visegrad, and Foca under our area.
4 The organisation didn't match the earlier peacetime organisation.
5 It was extended to a larger period, and it covers larger period than it
6 covers today, because at the time we had to take over some of the
7 stations that are now linked up with Bijeljina. Then we took over all
8 the stations of the CSB Gorazde that were in the hands of the Serbs.
9 Q. Do you recall was Momcilo Mandic in Vrace in April 1992 when you
10 were there?
11 A. Momcilo Mandic, as far as I remember, wasn't an employee of the
12 MUP then. He worked for the Ministry of Justice. The seat of that
13 ministry was not at Vrace, but, rather at Kula or Pale where the
14 government was, but he did come to Vrace occasionally. I would see him
15 there, but he didn't have his workplace there.
16 Q. We've seen some evidence suggesting that Mr. Mandic became
17 minister of justice in mid or late May 1992. You're not aware of him
18 holding a position in the RS MUP before that, in April 1992?
19 A. I don't know what position he had in the MUP at that time. I
20 know that in the RS UP he was one of the top executives of the crime
22 Q. Thank you. While at Vrace, I think you told us that you worked
23 as a communications officer, and I understand that part of your duties
24 involved sending and receiving dispatches. Did you also work on the
25 telephone, answering the phone?
1 A. As there were only two of us working, depending on how much we
2 could stand, we would work all the time and take shifts. Of course, I
3 did everything needed. I sent out and received dispatches and I was in
4 charge of UHF and phone communications because the switchboard was not
5 functional at the very beginning. So this was a huge burden because if
6 anyone wanted to speak to the minister he had to go and fetch him
7 personally. Only later were we able to get the switchboard working so
8 that we could put calls through.
9 Q. Okay. Thank you. In connection with that, I would like to show
10 you a couple of exhibits already in evidence and ask you a question.
11 MR. HANNIS: The first is P1146, which is at tab 8.
12 Q. I think this is a document that you've seen before. It's a
13 transcript of an intercepted telephone conversation on the 23rd of April,
15 Speakers listed are Radovan Pejic and Radovan Karadzic.
16 You recognise that as a transcript you looked at before?
17 A. Yes, I've seen it before. And I heard the audio recording. So I
18 can certify that this conversation is authentic. I, indeed, spoke to the
19 president then.
20 Q. And you were in Vrace at the time of this conversation?
21 A. Yes.
22 Q. Do you know where Mr. Karadzic was calling from?
23 A. At that time, we were not able to identify incoming calls. Only
24 later was the switchboard equipped to do that. But I can suppose that it
25 was an incoming call from Pale to Vrace. I believe that Pale was the --
1 was the place from which the call originated.
2 Q. Thank you. As I understand it, you said that it was necessary,
3 in the early days, to leave the switchboard and go upstairs in the
4 building to get the minister or others to come down, because there was
5 not an internal phone connection. Is that right?
6 A. That is right. Only later were we able to equip the switchboard
7 to do that. And that is probably why the president was talking to me
8 here rather than to the minister because everybody knew what the
9 conditions of work at Vrace were like.
10 Q. Thank you. I'd like to show you 65 ter number 2399 now.
11 This is at tab 2. Mr. Pejic, this relates to the issue of
12 telephone links and telephone communications. This is a document that
13 you've seen before, and it purports to be a pre-war schematic diagram of
14 the telephone links within the pre-war MUP.
15 Do you recognise that?
16 A. Yes. And the schematic shows our functioning before the war
17 broke out.
18 Q. And as I understand it, when the war broke out, the link in
19 Sarajevo were broken because much of the confrontation line was running
20 throughout and around Sarajevo, right?
21 A. Yes. And the main hub was also at the RSUP.
22 Q. Do you know what the situation was in Banja Luka centre with
23 regard to its telephone links with subordinate SJBs as shown on this
24 chart? Do you know whether that remained intact in 1992, after the war
1 A. I have no precise information, but I suppose that provided they
2 had power in there, then they could have internal communications, but as
3 for other communications, no. That is, from the centre toward the
4 stations, in my assumption, unless there were other technical problems
5 from the purely technical side communication was possible. Of course,
6 all the other preconditions had to be met that the -- all the devices had
7 to have, power supply, uninterrupted power supply, and -- but most of the
8 stations remained linked in Banja Luka. However, I'm not familiar with
9 the exact state of affairs in that centre.
10 Q. Thank you.
11 MR. HANNIS: Your Honours I'd like to tender 2399.
12 JUDGE HALL: Admitted and marked.
13 THE REGISTRAR: As Exhibit P1471, Your Honours.
14 MR. HANNIS: Thank you.
15 Q. Mr. Pejic, I have a question for you. There's been some evidence
16 that pre-war during a one-year period there may have been hundreds of
17 thousands of dispatches sent out by the MUP headquarters. And in the
18 annual report for the RS MUP, which we'll look at later, the number is a
19 very much low number.
20 Just in general terms, can you tell me, during the war time
21 conditions in the RS MUP, there were certain categories of dispatches
22 which had been commonly sent in the pre-war period that were no longer
23 being sent as dispatches during 1992 in the war period?
24 Do you follow my question?
25 A. Yes. And I think that the information that you put forward can
1 be interpreted as a conservative assessment. Because before the war,
2 dispatches that went from the RSUP towards the centres and the police
3 stations could include 100 or 200 dispatches in one packet, because
4 dispatches are used to inform the relevant institutions of all security
5 relevant events, such as stolen vehicles and what have you, whereas --
6 dispatches relating to lower-level operative matters were not so numerous
7 in war time.
8 But it was to be expected that the number of dispatches about security-
9 relevant events would be much greater, and in my view, had the communication
10 lines functioned well, it would be at least equal to the quantities in
11 peacetime, if not greater. Such information was however mostly transmitted
12 by phone or in direct contact between the officers, and dispatches were used
13 only when necessary although that wasn't strictly in accordance with the
14 rules, but events happened so fast that almost on an hourly basis there would
15 have had to be dispatches arriving to the Center, and then from the Center to
16 the MUP, dispatches about combat activities or other security-relevant
17 events. But I believe that the officers in charge compensated for that
18 through telephone communication or through other types of contact.
19 Q. Thank you. We asked you to generally describe for us the procedure in
20 the communications centre that MUP headquarters in Vrace and in your CSB
21 Sarajevo later on, can you briefly describe the procedure for how dispatches
22 is drafted and sent out? Can you go through the steps that take place?
23 Say the minister wants to send some kind of decision or order to
24 the CSBs and all the SJBs, how would that take place?
25 A. When a dispatch is drafted, and it must include all the elements
1 such as the prescribed form, the heading, the indication of urgency and
2 the indication of confidentiality, who was supposed to receive it. Then
3 somebody receives the dispatch, be it the courier or the secretary
4 inspects the dispatch but not the content, they check the upper right
5 corner where the chief and the dispatch distribution centre has to sign,
6 and the urgency indication. And then they are ordered in the sequence of
7 urgency. The last ones to be dealt with were the ones marked O, for
8 open. And the MUP is duty-bound to -- to -- transmit them to the
9 recipients but through the CSBs. If the dispatch was to be sent to all
10 police stations, that is SJBs, then the communications officer at the CSB
11 will register that dispatch as received and forward it to the stations.
12 That is, the communications centre of the MUP cannot communicate directly
13 in that case with an SJB but has to go through the communications centre
14 of the CSB. The same applies to the communications from the police
15 stations to the MUP of the RS. Exceptionally when there is a dispatch
16 attended only for one SJB we can relay it directly as an intermediary.
17 But, as a rule no dispatch would go to an SJB without the CSB being
18 informed. That is why everything went through the CSB because one copy
19 is kept there for information of the management of the centre. Because
20 the MUP of the RS, even then - and now, too - was a centralised
21 organisation, a hierarchical organisation.
22 Q. Thank you. Concerning the levels of urgency I think we heard
23 before that a designation very urgent --
24 JUDGE HARHOFF: Mr. Hannis.
25 MR. HANNIS: Yes.
1 JUDGE HARHOFF: As usual, when witnesses tell us how the system
2 should work, it's always useful to ask if it actually did work.
3 And my question to you, Mr. Pejic, is, if you can tell us just
4 briefly, if the system which you have now described to us, how did it
5 work in practice in the period between April and July 1992?
6 Are you able to shed some light over this?
7 THE WITNESS: [Interpretation] Depending on the circumstances, we
8 often had to wait for days for a dispatch to be transmitted to far away
9 police stations or newly established police stations, such as Milici,
10 until we put in place VHF devices. Those dispatches would most times
11 wait for couriers. But we did whatever we could to transmit them as soon
12 as possible, but remote police stations did have to wait for weeks, and
13 then the information would mostly be obsolete.
14 But we tried to be resourceful and have a vehicle going in that
15 direction, carry it, or if the phone lines could be used and we used
16 them, but the facts about the dispatch communications confirm what I
17 said. In April and May, the situation was worse, was the worst but when
18 we introduced teleprinters then it got better. Then -- we -- the
19 communication lines were more stable from that time on. Of course, all
20 provided that there was uninterrupted power supply. All systems would go
21 down when the power plant was -- broke down and the generator only could
22 work for 24 hours because these switchboards were from before the war, so
23 you can imagine what this situation was like with the switchboards in
24 Pale and Ilidza which were even older.
25 If I compare that with the conditions -- with the pre-war
1 conditions, our compatibility of efficiently transmitting information
2 wasn't even 10 per cent of our capability before the war. If I had a
3 dispatch to be sent out to all police station, I had to get -- establish
4 contact with that police station physically whereas before the war it was
5 enough to depress 20 or 30 buttons and no matter -- whether they were
6 communicating with each other I would interrupt that communication and
7 send out everything to all of them at the same time. Now the workload
8 was 20 times greater. When the dispatches were of the open type we
9 sometimes had to dictate the text to the recipient and especially if the
10 dispatch was drafted by somebody who was not versed in that and it wasn't
11 brief, but was put in the -- everything was explained at great length,
12 and sometimes we will to use the most -- the simplest code which is S1.
13 JUDGE HARHOFF: Thank you very much.
14 MR. ZECEVIC: I'm really sorry, I would ask my learned friend to
15 instruct the witness to talk slowly because I have -- I have identified
16 at least ten mistakes in the transcript what he says. That happened on
17 page 24, 25, now it happened in his last answer. Because he -- in his
18 answers he is giving so many details and it's impossible, I understand it
19 is impossible for the interpreters to cover each and every -- each and
20 every thing that the witness said.
21 I will clarify this during the cross-examination, I just wanted
22 the record to show that there is -- because we can ask for the
23 verification request, but I don't want to complicate because I know what
24 the witness said, and I will clarify that in my cross.
25 Thank you.
1 JUDGE HARHOFF: Thank you, Mr. Zecevic.
2 And, Mr. Pejic, this will be yet another forceful reminder to you
3 to speak slowly. I have also noticed that you actually speak very fast,
4 but it's no good if the interpreters cannot follow you.
5 So, please, bear in mind that you have to speak slowly and
6 distinctly. Thank you.
7 Back to you, Mr. Hannis.
8 [Trial Chamber confers]
9 JUDGE DELVOIE: Mr. Zecevic if you allow me, we all have to bear
10 in mind that it is an interpretation and not translation that we are
11 dealing with.
12 MR. ZECEVIC: I understand, Your Honour, but the point of the
13 matter is I'm not -- I'm not saying that -- that each and every word
14 needs to be interpreted but -- but instead of what -- what witness said
15 one thing instead of that something else was recorded in the transcript.
16 That -- and there are distinct things and it really makes the transcript
17 very unclear, and it's not what the witness said. That is what I had in
19 JUDGE DELVOIE: Okay. I understand. Thank you.
20 MR. HANNIS:
21 Q. Mr. Pejic, perhaps it is partly because of your background as a
22 communications worker, but I'm also told sometimes I talk too fast.
23 We'll both try to slow down, and we only have three minutes before the
24 first break.
25 Let me ask you, with regard -- you mentioned not having teletype
1 or teleprinter capability in many locations in the beginning of the
2 conflict. If, in April or May you needed to send a coded dispatch
3 somewhere and you did not have the teletype/teleprinter connection or
4 capability, what means would you use to send a coded dispatch? Could you
5 do it by radio or Morse code or on the telephone speaking, using some
6 kind of common code? What would you do?
7 A. The dispatches rated as -- as strictly confidential in April were
8 coded by the so-called S1 encryption system. That is the oldest
9 encryption system where every character of a word is represented by five
10 characters in the code. So it is not important when you're doing that,
11 whether you will transmit to -- that dispatch to the other side on the
12 phone or not because whoever listens in does not have the code table and
13 doesn't know what any character stands for.
14 Another way we used was the so-called code book, which -- in
15 which words are --
16 THE INTERPRETER: Could the witness please repeat this technical
17 explanation. We can't follow.
18 MR. HANNIS:
19 Q. I'm sorry. I need to stop you because the interpreters have just
20 intervened and asked if you can repeat but I see it is almost the time
21 for the break, maybe we should break and I'll ask the question again when
22 we resume.
23 JUDGE HALL: Yes. We return in 20 minutes.
24 [The witness stands down]
25 --- Recess taken at 10.26 a.m.
1 --- On resuming at 10.51 a.m.
2 [Trial Chamber confers]
3 [The witness takes the stand]
4 MR. HANNIS: Thank you.
5 Q. Mr. Pejic, your last answer, in part, mentioned the so-called S1
6 encryption system which I understand to be a system where each letter of
7 the plain text is represented by a code assisting of five symbols for
8 that one letter, five for one substitution system. Is that correct?
9 A. Yes, that's right.
10 Q. And then you started to mention that you also used the so-called
11 code book. Could you slowly tell us what that was?
12 A. It's a table, code book or code table, which sets out the main
13 words, and surrounding that you have numbers and letters. And by
14 crossing numbers which, when we send out this to each other, if anybody
15 unauthorized were to come in they could make no sense of it. And then we
16 provide a key so that when one of our colleagues receives a message of
17 that kind he knows where to start. He has the key. He knows how to read
18 it, how to read from left onwards or the top of the table or whatever.
19 And when on the left-hand column at the top he sees an A, if there's a
20 number 5 crossed with those two lines, he would get a word. When he puts
21 all the words together, all that's needed is to correct the text in the
22 sense of any grammatical or case variations. And there was the old
23 principle of encoding too. People who knew this knew that coding system
24 was rather old, out of date. Because it was too slow, in actual fact.
25 Not because it was not reliable but because it was too slow and
1 encryption has gone far ahead and it's easier to work with.
2 But, any way, closed communication, the system of closed
3 communication in the Ministry of the Interior implies that when
4 information is forwarded or conveyed, it should not be detected and
5 uncovered by others. For example, the very next day, the minister can
6 repeat that in his report publicly, or make a public announcement, but
7 when it is sent out, nobody must know the contents of such a message.
8 Q. Thank you. You mentioned earlier the -- the urgency ratings.
9 And I've understood that very urgent is the highest level of urgency for
10 sending messages; is that right?
11 A. Yes, that's right. Very urgent, according to the rules governing
12 the system of encryption in the MUP, which we inherited from the RSUP or,
13 rather, the federal SUP of the former Yugoslavia, implied that from the
14 moment of reception of such a dispatch in the communications centre in
15 the space of 30 minutes that dispatch would have to have been sent out to
16 the addressee, as a rule.
17 Q. And apart from the situation where you have urgent circumstances
18 like your police station being attacked, who, in the MUP, had the
19 authority to send messages -- or draft messages as being very urgent?
20 Could anybody in the MUP do that, or was it limited to certain positions?
21 A. The rules govern that, when you have a very urgent dispatch, it
22 is only the minister or the individual he authorises, with the exception
23 of cases -- well, since the rules were taken over from peacetime
24 conditions, when there's an aggression, for example, against Yugoslavia,
25 then in that case, the leader of the organisational unit which noticed
1 this phenomenon happening or a piece of interesting security information
2 going to the minister could use the very urgent code. Usually it
3 refers -- it is placed -- very urgent is placed to secure -- to matters
4 of great interest to security and so on and so forth going to the
6 Q. Could your CSB chief designate a message as being very urgent?
7 A. Yes, in exceptional circumstances. If, for example, there was an
8 attack on Vrace or something like that. But as far as I remember, the
9 chief of the centre, the CSB chief, did not use that marking but used the
10 code tables and he could also orally via those code tables, convey the
11 information in the proper way. But officials lower down the pecking
12 order in Republika Srpska such as the assistant minister, the chiefs of
13 the Security Services Centre and so on and so forth, they would use
14 something else and that was DD. It was also a very precise mark which
15 meant from one hour to a maximum of three hours that was the leeway given
16 for forwarding, and it was used most frequently because all the chiefs
17 were well-acquainted with the possibilities and capacities of the
18 communications centre and that is why they avoided using too many --
19 sending out too many dispatches of that kind.
20 Q. Related to that, I have a question about the process. The
21 situation where maybe you get a dispatch that's coded DD and either you
22 don't have enough time to get it sent within the required limit or the
23 line is not functioning, you have no power or the line's been cut or the
24 operator on the other end is not answering the radio, what was the
25 process within the communications centre in such a circumstance where you
1 were unable to deliver a message as requested? What were you supposed to
2 do under the rules?
3 A. Under the rules within a certain deadline we would resort to all
4 means possible to have the dispatch forwarded to the addressee
5 stipulated. And then we would record that in our log-book of received
6 and sent-out dispatches. Similarly, either on the back page or the front
7 page, if there's enough space, we would record that on the original
8 dispatch as well that arrived at the communications centre, and we would
9 write down the time, the hour and the minute, when the dispatch was
10 handed over.
11 Let me give you an example. To the police station of Ilijas.
12 Now, if we failed to send it to the Ilidza police station, then we would
13 write down a note, a remark, saying that it had been copied, put into an
14 envelope and was waiting for a courier, and then a copy of the dispatch
15 in that way would be returned to the author once the deadline expires and
16 then the author -- it is up to the author to decide what he is going to
17 do, whether he is going do send it out late, by courier, or if the
18 time-limit has expired and it is no longer topical, then, he will tell
19 the person who returns the dispatch to him to withdraw all the copies
20 that were prepared for the courier, or to write on those copies that it
21 is just by way of information, a piece of information so that the person
22 opening the envelope knows that it's out of date but, nevertheless, it
23 provides a certain amount of information which might be relevant.
24 Q. I guess, to ask the question that Judge Harhoff would ask.
25 You've described this as how it was supposed to work under the rules. Is
1 that how it actually worked in real life when you worked at Vrace and
2 when you were in the CSB communications centre for Sarajevo?
3 A. Yes. Precisely the way I've described it, but most of those
4 dispatches were left to be dispatched by courier. We succeeded in
5 transmitting most of them by other forms of communication -- we were not
6 successful in transmitting them by other means of communication much, but
7 mostly by courier.
8 Q. Thank you. In terms of reporting within the RS MUP, did the SJBs
9 have an obligation to report up to headquarters through the -- through
10 the centres information about police activities, in particular, police
11 involvement in combat activities in 1992?
12 A. Upon arrival at Vrace, we would, at least in the communications
13 centre, and later on, as I worked as an analyst as well, we would apply
14 documents from peacetime which related to the specific area we were
15 dealing. However, because of the new cadres coming into the police
16 stations, we realized that many of the people coming in did not have any
17 knowledge of this, didn't know how to do it, so as far as I remember, as
18 soon as necessary conditions were created a large instructive dispatch
19 was sent out, a dispatch with instructions stating what needed to be done
20 on a daily basis, what needed to be done on a weekly basis, monthly basis
21 and so on, half-year, one-year, et cetera, how to report back to the
22 centre, and once the centre had collected all these reports it would send
23 out a report to the MUP headquarters.
24 Later on this dispatch with instructions was translated, if I
25 remember correctly. Well, it became instructions called instructions on
1 obligatory daily, weekly, reporting and reporting within various time
2 spans according to the different areas about the situation -- the
3 employee situation, about combat, about regular police affairs and the
4 like, other important information.
5 Q. Do you recall what the requirement was regarding reports about
6 combat activity? Was that required to be reported daily, weekly,
8 A. Combat reports or reports on combat activity were sent out at all
9 those times, daily, weekly and sometimes monthly, et cetera, and that
10 implied that the centre would be informed of how many police members were
11 at what positions of defence and how many had taken part in combat, how
12 much time they had spent up at those positions, whether there were any
13 wounded or killed, whether there were any movements in the lines, if the
14 lines were attacked, and whether or not control -- they managed to regain
15 control of the lines if there was shifting.
16 Now, as a rule, as far as I know, our members in the special
17 units, special police units, took part -- they came from all
18 organisational units and went as re-enforcements to the Army of Republika
19 Srpska where needed on a regular basis. And very often they also had to
20 be deployed in providing assistance where the defence lines were under
21 threat, and the policemen then were withdrawn from their regular duties
22 and sent out as reenforcements to the army units, where needed. And in
23 the bulletin, which was sent out in the morning, the centre would have to
24 be informed about all this and then we would collect up all the
25 information for our given area and then send it on to the Ministry of the
2 Q. Do you know whether or not request from the -- the SJBs or
3 subordinate units request to engage police members in combat activity had
4 to be sent to the CSBs in 1992?
5 A. No. I think that, especially when the system of communications
6 functioned poorly, the decisions had to be made by officers in those
7 police stations, by the chiefs of the police stations, and the requests,
8 if I understood some reports from the stations correctly, they would get
9 them either from the army directly or through the Crisis Staffs which had
10 been established in the municipalities. And let me emphasise once again,
11 if I understood the information we received correctly because I read the
12 reports as somebody working as an analyst, in part. I say this because a
13 communications officer never looks at the contents of information. He
14 doesn't deal with the contents. He ex officio is not interested
15 in context. All his job requires is for him to forward the information,
16 so I'm saying this from the aspects of my job as an analyst, and it
17 follows that the Crisis Staffs in their respective areas without the
18 knowledge of the ministry could engage them but, of course, the junior
19 commander was duty-bound as soon as conditions were ripe to inform the
20 centre and then the centre would inform the ministry, up the chain.
21 Q. If I understand correctly, then, in your position in 1992, you
22 did see reports from subordinate police organisational units such as SJBs
23 coming into the CSB, and these reports were about requests from either
24 the army or the Crisis Staff for the engagement of police units in
25 combat, right?
1 A. Yes. It said in the reports. For example, that at the request
2 of the Crisis Staff of Ilidza, for instance, because of an attack on
3 Nedzarici at such and such a period of time, so many policemen were sent
4 as reenforcement to the reserve police force in Nedzarici and that they
5 took part in the defence of that particular territory. Now whether they
6 managed to do that the same day while the attack was ongoing, and that
7 was rarely possible, then it was done as soon as the attacks stopped, or
8 rather, as soon as conditions permitted and that you had the time to
9 write out information and reports.
10 Q. And I understand that the CSBs had a requirement to send daily
11 reports to MUP headquarters. Yes?
12 A. Yes, that's right. That was done in keeping with the dispatch
13 with instructions coming from the ministry through the so-called bulletin
14 of daily events.
15 Q. And did those daily reports from the CSBs include information
16 about the combat activities in the subordinate SJBs? That's the type of
17 information you would include and forward to the ministry.
18 A. Yes, it did include that. And at the end of the bulletin, it
19 always stated from what public security stations information did not come
20 in for that particular day.
21 Q. Okay. Thank you. I want to go -- I'm going to jump around a
22 little bit. I want to show you a few documents and ask you some specific
23 questions about them.
24 MR. HANNIS: The first one is 65 ter number 360. It's at tab 16.
25 Q. Mr. Pejic, this is a document dated 20 May 1992. It's addressed
1 to all security service centres, to the chief. It has the stamped title
2 and -- and name of minister of the interior Mico Stanisic and somebody's
4 My question relates to the last sentence. It's a request for
5 certain kinds of information to be broken down by public security station
6 about the number of police, the number of stations, et cetera. And the
7 last line says: "Information to be submitted by courier by 5 June at the
9 Is this unusual to have a request from the minister to send
10 information by courier instead of by dispatch or some other means?
11 A. In this particular case if we look at what is being requested
12 then it is not unusual because although this document does not have a
13 confidentiality rating, the answers to the questions posed would present
14 the top security rating and would have to be top secret or strictly
15 confidential. Because, quite simply, somebody -- some unauthorised
16 person -- if it fell into the hands of some unauthorised person - these
17 answers, I mean - then the person would gain complete insight into
18 cadres, organisation, and so on of the MUP of the Republika Srpska, all
19 its potential. And it would not be possible for one centre to summarise
20 all this information for all the centres and units and compile a report
21 which could be sent out in dispatch form. And that is why, I think, that
22 this was resorted to in this case that it was decided to send a courier,
23 send it by courier, and quite possibly, this document did not go through
24 the communications centre, or even if it did, it might have been sent by
25 regular post; but it could also go as an open dispatch because it was
1 common knowledge that a leader, a -- who wanted to establish or build up
2 an institution would necessarily have to know all the data set out here.
3 So -- and nothing that is being requested here in this form is a secret,
4 because the other side was organised in similar fashion, identically, and
5 they were well aware of the fact that this was how the MUP of RS was
6 organised although they might not know the number of police stations, for
7 example, or the number of regulars or reservists without going into
8 further details contained in this document.
9 Therefore, using this specific example it is not unusual to
10 submit the information by courier. But, as I said, the establishment
11 system provides for this possibility because the couriers would take
12 regular post which did not go through the communications centres.
13 Q. Thank you.
14 MR. HANNIS: I'd like to tender that document, Your Honours.
15 JUDGE HALL: Admitted and marked.
16 THE REGISTRAR: As Exhibit P1472, Your Honours.
17 MR. HANNIS: Thank you.
18 Q. Next, Mr. Pejic, I'd like to show you a log-book.
19 MR. HANNIS: This is 65 ter number 2577, and it's at tab 18.
20 Q. I think you saw a hard copy of this before. And my question was,
21 if you were able to identify where this log-book would be from, based
22 on -- on the contents in terms of what the messages are and to whom
23 they're delivered.
24 Do you recall looking at this one?
25 A. I do recall, and I think that during the proofing for today I
1 managed to identify with a degree of reliability that this is the
2 log-book of the Ilijas SJB; I think their mark was 17-7. But, based on
3 some names mentioned in the log-book, I think I can say that this is
4 about the area of Ilijas because the surname, Popic and Subotic, hail
5 from there. And I think the employment lists are being sent for this
6 organisational unit because who else would be doing that? So, yes, I
7 think it's the Ilijas Public Security Station.
8 Q. Thank you.
9 MR. HANNIS: I'd like to tender 2577, Your Honours.
10 [Trial Chamber confers]
11 JUDGE HALL: What Mr. Hannis is the effect of this document in
12 your submission?
13 MR. HANNIS: Your Honours, Ilijas is one of our listed
14 municipalities, communication continues to be a contested issue in this
15 case. There are certain entries where there are references to document
16 numbers that we think we're able to link up with other documents which
17 are in or will be in evidence later on, and we think it's part of our
18 burden of proof to show that there was communication with the Ilijas SJB.
19 JUDGE HALL: Well, I think that was obvious with the last two
20 exhibits. This ... this was a supplemental -- what you are saying is
21 this is supplemental to ...
22 MR. HANNIS: Your Honour, the -- this is a particular police
23 station, we haven't got a lot of witnesses about Ilijas, and what this
24 [indiscernible] necessary to show the communications link with this
25 municipality we --
1 JUDGE HALL: Admitted and marked.
2 MR. HANNIS: Thank you.
3 THE REGISTRAR: As Exhibit P1473, Your Honours.
4 MR. HANNIS:
5 Q. Next, Mr. Pejic, I'd like to show you 65 ter 2914.
6 MR. HANNIS: This is at tab 23, Your Honours.
7 Q. This is another one you will have looked at before. It is dated
8 18 June 1992 from the Ministry of Defence, addressed to ministries of the
9 government indicating that the communications centre at Pale can send
10 telegrams to the Serb Autonomous Region of Bosanski Krajina and to other
11 Serbian Autonomous Regions.
12 Did you see this document in 1992?
13 A. I didn't receive this document in official form, either from
14 Ministry of Defence or the Ministry of the Interior. It is possible that
15 I have seen it in my contacts with my colleagues in the military
16 communications centre of the RS in Lukavica because by that date, I
17 already worked in the communications centre of the CSB, and I can say
18 that that particular communications centre was not using this form of
19 communication. Now, whether some other organs of the ministry may have
20 used it through Kalovita Brda location at Pale, of that I don't know
22 So I do not know whether MUP of Republika Srpska used this
23 possibility of communication at all. Communication with Bosanski
24 Krajina, if we needed to establish communication with them, we, as the
25 centre, could achieve by sending them first to the MUP communication
1 centre, now whether they would simply forward it or use the military
2 communications systems, I don't know. In the period when I was working
3 in the period of April and May, when I was working in the MUP
4 communications centre, we didn't have this option. We did not send a
5 single dispatch in that period or forward any dispatch at the time, any
6 dispatch towards Krajina. And here I'm referring to the Vrace
7 communications centre.
8 Q. Thank you. Now, were -- even though you didn't do that were you
9 aware of the possibility, the offer of the use of those communication
10 facilities to the MUP where that was a possible alternative means that
11 was available?
12 A. As a chief of department in the Security Services Centre, I did
13 not. But assistant minister would have known about this, and he would
14 probably use it. We could not communicate in this form, but whether
15 Mr. Kezunovic had used the -- this form or this way of communicating, I
16 don't know. And we, from the communications centres, shouldn't have even
17 known about this, because the dispatch would go to the MUP communications
18 centre, and then they would, if necessary, use this possibility.
19 It is possible that I have seen this document in my contacts with
20 my military communications officers, my colleagues.
21 Q. Thank you.
22 MR. HANNIS: I'm not going to tender that at this time, Your
24 I would now like to next show the witness 65 ter 2513.
25 Q. Mr. Pejic, this is a -- this appears to be a -- a document, a
1 request for certain information about means and types of communication
2 from -- from the CSB and then a response to that from Vogosca.
3 You're just looking at the first page now.
4 MR. HANNIS: Could we show the witness the next page.
5 Q. Do you recall having seen that before today?
6 A. Yes.
7 Q. Can you tell us what it is.
8 A. It is already July of 1992, and because of un-uniformed type of
9 equipment that the police stations and communications centres had --
10 communications centres within the CSBs, it was necessary to make a full
11 review of the equipment at our disposal and to try to either regroup the
12 different devices and to use then uniform equipment. That was the
13 purpose of this proposal. Or, alternatively, to make sure that, in the
14 following period, just as it was before the war, communication devices
15 would be obtained from one type and one brand only, because the engineers
16 and technical staff that were in charge of the maintenance of the system
17 had pointed to us that lack of uniformity of our devices makes it
18 difficult to maintain them or even to obtain the right type of batteries,
19 for instance for radio stations, so this was a review to see what is it
20 that we need for our further work.
21 Q. And if we could go to the last page. This appears to be the
22 responding information. Do you recognise the signature at the bottom,
23 who that person is?
24 A. Yes, I can recognise it. He worked in the public security
25 station at Vogosca. I do know the name of Rajko Dragicevic. He is
1 responding to the lists of questions I may have asked most probably for
2 some additional information, because this response is not complete. We
3 can see under number 2 that neither the type nor the make of the radio
4 station is listed.
5 Q. Thank you.
6 MR. HANNIS: Your Honours I'd like to tender this. I note that
7 the English translation the first name of the signer here is translated
8 as Gojko with a question mark. But I would defer to the witness's
9 identification of the known person. And tender it now.
10 JUDGE HALL: Admitted and marked.
11 THE REGISTRAR: As Exhibit P1474, Your Honours.
12 MR. HANNIS: Thank you.
13 Q. Mr. Pejic, do you recall whether Zvornik SJB was a subordinate of
14 the Sarajevo CSB in 1992?
15 A. Yes, it was.
16 Q. Did you have a direct communications link with Zvornik SJB in
18 A. Providing there was electrical power available and providing
19 their postal and telephone switchboard was functioning, then we had phone
20 communication, until the high frequency system started functioning
21 against, because before the war, they had been linked up with another
22 node, so although they did have the equipment available, Sarajevo could
23 not have direct communication with Zvornik. Instead, it would have been
24 done at the time through the Sarajevo communications centre which
25 remained in the -- federation part.
1 MR. ZECEVIC: 46, number -- line 8 and 9, I believe the witness
2 said: We had a phone communication but we didn't have some other kind of
4 So if can you just clarify that.
5 MR. HANNIS:
6 Q. Did you hear from my learned friend Mr. Zecevic said, and can you
7 help us out with that?
8 A. When I was referring to the phone communication, the Zvornik
9 switchboard, if they had power supply, then the phones in Zvornik would
10 be functioning normally. If one phone would be operational, one phone
11 that we had at our communications centre, if that phone could get long
12 distance line or so-called Pale line, we could, at the time, providing
13 that the federal line was not interrupted, we could use phone lines to
14 get in touch with Zvornik. Teletype, not even in conditions of peace,
15 could not be used because we would have to use the service of the
16 teletype node central, either located in -- the one locked in Tuzla or
17 the one located in Sarajevo because before the war Zvornik was part of
18 that centre and not the Sarajevo centre. So we did not have direct
19 communication with them.
20 The UHF communication could not be heard through Trebevic, so we
21 couldn't establish contact UHF with them, so it wasn't functioning in the
22 relevant period, the period we're talking about, but immediately once the
23 name book was established and frequencies set, we were able to have that
24 kind of communication with Zvornik as well.
25 Q. Thank you.
1 MR. HANNIS: Next, could we have a look at Exhibit 65 ter 3229.
2 This is at tab 36, Your Honours.
3 Q. Mr. Pejic, this is a document dated 30 August 1992. This has the
4 stamp and the typewritten name of Minister Mico Stanisic. Do you
5 recognise the signature?
6 A. Yes. I believe this is the minister's signature.
7 Q. Okay. Do you have -- you see there's a reference to a person
8 named Rajko Kusic that was supposed to be involved in this requested
9 exchange of prisoners.
10 Do you know who that Rajko Kusic was?
11 A. I'm seeing this document yesterday, and I am convinced this
12 refers to late Rajko Kusic from Pale who was a police official and a
13 judoka sportsman who took part in international competition and who had
14 died while returning from a competition.
15 It is possible that his colleagues, Judo sportsmen, got in touch
16 with him in relation to an Anes Bucan and that this man may have used his
17 authority especially because one can see mention of bodies of four
18 Serbian fighters at Colina Kapa. I'm certain that these couldn't have
19 been fighters that were under other Kusic, the guy from Rogatica. They
20 must have been either from Pale or Sarajevo.
21 Q. That was my question, if you were aware of another Rajko Kusic
22 who was from Rogatica and commanded some -- some armed unit there? And
23 you believe it is not the Rajko Kusic from Rogatica because why?
24 A. What's referred to here is three Serbian families and bodies of
25 four Serbian fighters at Colina Kapa. As far as I know, up until the
1 period in question, members of the army that were under the command of
2 Kusic Rajko from Rogatica did not man the defence lines along Trebevic,
3 specifically at Colina Kapa. Rather, it was army members from Pale, east
4 new Sarajevo and so on who manned those lines. The place where one can
5 find the bodies of these four Serbian fighters is an indicator to me that
6 this is not the Rajko Kusic from Rogatica.
7 Q. Thank you.
8 A. And also because is he a policeman and he used his MUP lines.
9 Q. Okay. And by the way, did you know who the prisoner named is,
10 Anes -- did you know who he was?
11 A. I do not know of this person. I assume it's someone from
12 Sarajevo who is in some way related to sports.
13 MR. HANNIS: I'd like to tender 3229 at the time.
14 JUDGE HARHOFF: Mr. Hannis.
15 MR. HANNIS: Yes.
16 JUDGE HARHOFF: I'm not sure why we should admit this into
18 MR. HANNIS: Your Honour, if there is no issue as to authenticity
19 and he has identified the signature and it appears regular in form, one
20 of the issues that we have in this case is the minister's knowledge about
21 prisoner exchanges, and here we have a direct example of the minister
22 making a request, that a prisoner exchange be carried out. So we think
23 it is very pertinent to that issue.
24 JUDGE HARHOFF: So it is not to prove that the minister was
25 communicating and was able to communicate.
1 MR. HANNIS: Well, for.
2 JUDGE HARHOFF: Because I think --
3 MR. HANNIS: That always because the communication is directed to
4 the Kula prison and the Ministry of Justice.
5 JUDGE HARHOFF: My concern is that if you want to prove that
6 there was, in fact, communication between the MUP and the CSB and from
7 the CSB to the SJBs, then, I mean.
8 MR. HANNIS: This --
9 JUDGE HARHOFF: It will be no good to just tender all the letters
10 and all the dispatches that you have been able to assemble during your
11 investigations because that wouldn't -- I mean, it wouldn't give the
12 right impression of to what extent the communication was possible.
13 So you have to deal with the issue of -- of proving the lines of
14 communication between the centre and the periphery in another way than by
15 overwhelming us with all these dispatches because in the end I'm not sure
16 that we will be able to -- to use that evidence in -- for -- for the
17 purpose that you want to prove.
18 MR. HANNIS: Well, Your Honours, I think you and I have a
19 disagreement about that at this point, but I would like to reserve that
20 for later because that's the argument that we'll be making at the end of
21 the case, and I hope with everything that is in by that time that I am
22 going to be able to make a persuasive argument to you and your
24 But for this document -- I'm not offering this particular
25 document to show communication between headquarters [Overlapping
1 speakers] ...
2 JUDGE HARHOFF: [Overlapping speakers] ... I understand and we
3 will admit it but ...
4 MR. HANNIS: Thank you.
5 THE REGISTRAR: This will become Exhibit P1475, Your Honours.
6 JUDGE HALL: Mr. Hannis, when we take the break at 12.05, that
7 would be your -- you would have exhausted your time.
8 MR. HANNIS: Yes, I'm aware of that. I'm going try to finish
9 before then. Thank you.
10 The next one I'd like to show the witness is -- it's P1428,
11 actually. It's the log-book. And with the usher's help, if I could hand
12 the witness a copy.
13 Q. While that's coming around, Mr. Pejic, I'll tell you this is --
14 this is a copy of a document that you've seen before.
15 A. Yes.
16 Q. [Previous translation continues] ... this is not the whole thing.
17 This is a copy of a part of it. But you've seen the original. Can you
18 tell us what this is from?
19 A. This is a document from the Vrace communications centre.
20 Confirmation of that can be found in the first few pages. Up until
21 number 49 it is stated that is MUP communications centre, the seat --
22 this is a very big log-book. In the beginning with -- of the war we
23 didn't have enough forms. It was with the approval of the minister.
24 This log-book of received and sent dispatches remained in the CSB and
25 starts with the date of 14th of July under number 1.
1 Q. [Previous translation continues] ... the first part which appears
2 to have been used in Vrace in early -- or in late April and early May,
3 can you look at entries 1, 2, and 3, and 8, 9, and 10, and tell us if you
4 recognise the signature in the far right column for those entries.
5 A. These are my signatures.
6 Q. And on entries 21 and 22, do you recognise the signature there?
7 A. Obrad Trifkovic.
8 Q. [Previous translation continues] ... co-worker you told us about
10 A. Yes. Who arrived in Vrace, I think, a day before I did. I'm not
11 sure though. He used to work in the communications centre of Bosnia and
12 Herzegovina republican SUP.
13 Q. And at the next page, entries 24, 28, and 29. Those signatures?
14 A. Signature under number 24 belongs to a communications officer
15 who, true, was just there to assist us Jovica Todorovic. As an engineer
16 he was more in charge with maintenance and establishing -- his field of
17 expertise was in very high frequency radio stations. So but because of
18 the shortage of staff, he also helped us, assisted us as a communications
19 officer operator.
20 Q. And then the portion of this log-book that starts after the first
21 49 entries, was that used in your CSB Sarajevo?
22 A. Yes.
23 Q. And the first number, item number 1, is dated something in June?
24 A. Yes, the 14th of June, 1992.
25 Q. And to help me and the Judges understand how -- how it worked and
1 how entries were made, I'd like to walk -- or have you walk us through
2 two or three of the entries. And the first one I want to show is you
3 item number 127. I think that's page 34 in e-court.
4 Did you find that one? It's at the top left of a page.
5 A. Yes.
6 Q. Can you tell us what's in that first column to the right of 127.
7 What does that say? It looks like an abbreviation and a date.
8 Can you read that out for us.
9 A. Did you say to the right or to the left?
10 Q. Immediately to the right, number 1 of the number 127. What's in
11 that column?
12 A. This reads VL, which means "own." The 27th of July, 1992, that's
13 the date of reception.
14 Q. And "own" means a document from your CSB?
15 A. Yes.
16 Q. [Previous translation continues] ... column which is -- is it
17 summary of the content?
18 A. It says that this is strictly confidential, and it is document
19 10-14/92. So this dispatch deals with the contents of that document.
20 Or, actually, forwards it in its original form.
21 Q. Okay. And to whom was it forwarded?
22 A. To all SJBs.
23 Q. Now if we could put up in e-court on the screen, in both English
24 and B/C/S, Exhibit P1073.
25 And, Mr. Pejic, I'll ask you to look at that document. P1073 is
1 at tab 46.
2 You see the cover page here is 01-127/92. Is that a reference to
3 this entry in the log-book?
4 A. Yes, it is. This is it.
5 MR. HANNIS: Could we go to the next page, please.
6 Q. And this -- can you tell us what this is? It appears to be a
7 document from your CSB.
8 A. Yes, it is from the CSB where I work -- or worked at the time.
9 And it is clear that a document of the ministry; namely document
10 10-14/92, is forwarded to all SJBs. Here the CSB forwards this MUP
11 document to the SJBs mentioned here and these were actually all the SJBs.
12 Q. Okay. If we could go next -- pardon me. If we could go next in
13 the log-book to item number 198.
14 Did you find that, Mr. Pejic?
15 A. Yes, I did.
16 Q. In the first column it makes reference to a number 09-120-105/92.
17 A. Yes. There is an equal sign here. This is about the SJB of
19 Q. Okay. If we could -- pardon me. And in the next column, there's
20 a reference to 01-136.
21 A. This means that this document has to do with the one that was
22 sent to them under this number and has to -- is connected with document
23 01-136/92 dated the 28th of July, 1992. That was the identification mark
24 of the document received from the SJB of Vlasenica and they are replying
25 to that document.
1 Q. Okay. If could you page back in your log-book in your hard
2 copies, please, to item number 136, which appears to be another "own
3 document," meaning a document from the CSB dated the 28th of July, 1992.
4 Isn't that the document -- isn't that the document that's referred to in
5 198 that we were just looking at? The 01 --
6 A. You said 126?
7 Q. No, 136.
8 A. Yes.
9 Q. Now, if we could see on the screen in e-court, P857.
10 And, Mr. Pejic, if you'll return to item number 198. This
11 relates to that.
12 A. Yes.
13 Q. You see on your computer screen a document from Vlasenica Public
14 Security Station dated the 10th of August number 09-120-105/92. And
15 under the heading, which is about disbanding of the special unit, it
16 makes reference to your document number 01-136/92. Would you agree
17 that --
18 JUDGE HALL: Mr. Hannis, we have been remind by the Registry this
19 document is confidential, so you should be careful the way that you --
20 that you deal with it.
21 MR. HANNIS: I understand, Your Honour, and we can -- I -- okay.
22 Q. I'll just ask him if the document that's on the screen in front
23 of him appears to be the document that's referred to here in the
24 registry, item number 198?
25 A. Yes.
1 Q. Okay.
2 A. That's what I said, as soon as I saw the log-book.
3 Q. Thank you. And one last one, Mr. Pejic. If you'll bear with me,
4 one more, at item 218.
5 MR. HANNIS: If we could show on e-court 65 ter number 2609,
6 which is tab 44.
7 Q. You see in the log-book number 218 makes reference to a document
8 that is 17-7.
9 A. Yes. And it continues, strictly confidential, 8/92, dated 11
10 August 1992, a document of the SJB of Ilijas. Because the indication up
11 there shows -- or, rather, the character up there points toward the line
12 above where the name of the station can be found.
13 Q. Yes. And in the third column it has reference to a number
15 MR. HANNIS: If we could --
16 A. That means that this is a document that is a reply to that
17 previous document. It came from the MUP and through the centre it was
18 forwarded to the stations. And now we can see the document on the screen
19 and this actually confirms what I said about the entry in the log-book.
20 This the reply of the SJB of Ilijas. You can see the number. And it was
21 entered in line 218 in this log-book of received dispatches and sent
22 dispatches. And we see that the commander in charge forwarded that to
23 the Department of the police.
24 Q. Thank you. And, Your Honours, the English translation under the
25 addressee says: Re your document strictly confidential number 01/127.
1 It has date July 1997 but looking at the original it is clear that it's
2 July 1992.
3 Mr. Pejic, there's a handwritten number at the top between the
4 document number and date and the strictly confidential. Can you read
6 A. There's a number 01-127. That's the number of the dispatch from
7 the large log-book. Because, you see, in the upper right-hand corner you
8 can see the name of the man who was in charge of the police.
9 Q. Mirko was in charge of the police where?
10 A. At the CSB. He was one of the inspectors.
11 Q. The handwritten number 01-218/92, do you see that there? That's
12 written on the document on the screen?
13 A. 01, I can see the number, and I can tell by the handwriting from
14 line 218 that this was entered by the communications operator and
15 somebody else, probably the chief of the centre, wrote the name Mirko up
16 there. And the handwriting is that of the communications operator and
17 the number is that under which he received the reply.
18 So this isn't a number which was assigned at Ilijas, but, rather,
19 at the CSB.
20 Q. The number 218.
21 A. Yes.
22 Q. Thank you.
23 MR. HANNIS: I'd like to tender that document.
24 And with that, I have no further questions for the witness.
25 JUDGE HALL: Admitted and marked.
1 THE REGISTRAR: As Exhibit P1476, Your Honours.
2 JUDGE HALL: So we take the break, to resume in 20 minutes.
3 [The witness stands down]
4 --- Recess taken at 12.05 p.m.
5 --- On resuming at 12.31 p.m.
6 [Trial Chamber and Legal Officer confer]
7 JUDGE DELVOIE: Mr. Zecevic just one moment -- well, the witness
8 is not in yet.
9 Mr. Hannis, you were referring to tab documents, tab 44 and
10 tab 46. And on the document list we have has only 43 tabs, so we're
11 missing possibly a revised list.
12 MR. HANNIS: Yes, I know. My Case Manager prepared a revised
13 list I think the day before yesterday. And --
14 JUDGE DELVOIE: I checked. We didn't get it.
15 MR. HANNIS: I'll check and see where it is and send it to you.
16 MR. DELVOIE: Okay. Thank you.
17 [The witness takes the stand]
18 MR. ZECEVIC: I lost the LiveNote, Your Honours.
19 JUDGE DELVOIE: [Microphone not activated] Me too.
20 [Defence counsel confer]
21 MR. ZECEVIC: Your Honours, if it pleases the Court I can start
22 my cross-examination. I am informed that it will be returned in five
23 minutes. I don't know if it creates a problem for everybody else but ...
24 JUDGE HALL: Yes, if you can start Mr. Zecevic, please do so.
25 MR. ZECEVIC: Thank you.
1 Cross-examination by Mr. Zecevic:
2 Q. [Interpretation] Good afternoon, Mr. Pejic.
3 A. Good afternoon.
4 Q. Please make a pause between my question and your answer for the
5 interpreters to be able to interpret and please answer slowly.
6 A. All right. I understand.
7 Q. At the beginning of your examination-in-chief this morning, you
8 explained to the Prosecutor that, in 1991, you returned to the MUP of the
9 Socialist Republic of Bosnia and Herzegovina; namely, to the CSB of
10 Sarajevo, of the then-MUP of the Socialist Republic of BiH.
11 A. Yes. That return was defined by a social agreement about the
12 implementation of personnel policy.
13 Q. You returned to the Department of Communications and Encryption
14 of the CSB of Sarajevo?
15 A. Yes.
16 Q. The chief of that department at the CSB of Sarajevo was Zlatan
17 Sehovic; is that correct?
18 A. Yes.
19 Q. Mr. Zlatan Sehovic is a Muslim by ethnicity, right?
20 A. Yes.
21 Q. His deputy --
22 MR. ZECEVIC: May I continue, Your Honours?
23 JUDGE HALL: [Microphone not activated] yes, please.
24 MR. ZECEVIC:
25 Q. [Interpretation] His deputy, that is the deputy of Mr. Zlatan
1 Sehovic, who was chief of the communications and encryption service of
2 the CSB of Sarajevo was Mr. Draskovic, a Serb, right?
3 A. Yes, Slavko Draskovic, a Serb.
4 Q. And at the very beginning, you spoke about a meeting which was
5 held at the level of the communications and encryption service of the CSB
6 of Sarajevo and said that it must have been about a month before the 4th
7 of April, 1992, that is, roughly in early May 1992 [as interpreted];
9 A. Yes. Whether it was the beginning of March or somewhat earlier
10 I'm not sure, but certainly not less than a month before the conflict
11 broke out.
12 MR. ZECEVIC: [Interpretation] On page 59 line 13 I said early
13 March 1992 and not early May as it has been recorded. This is just for
14 the transcript.
15 Q. And at that meeting, which I suppose was chaired by the chief and
16 his deputy, you were told that the MUP would be split. You were informed
17 that this could occur. And you were also told that, as far as the
18 communications and encryption service, it would probably remain a single
19 service, to cater for both MUPs, if the MUP should be split, right?
20 A. Yes, that is correct.
21 Q. That means that at that meeting the chief was a Muslim, his
22 deputy a Serb, and the staff were of various ethnicities. They were
23 members of all peoples and ethnicities who lived in Bosnia and
25 A. Yes. In police, generally speaking, this was observed,
1 especially with regard to the communications officers. That service --
2 efforts were made for that service to be manned by members of all
4 Q. So if I may summarise, the division of the MUP in early
5 April 1992, when it was divided into the MUP of the RS, on the one hand,
6 on the MUP of the Federation, on the other hand, did not come as a
7 surprise to you and your colleagues; in fact, your entire department at
8 the CSB of Sarajevo. Correct?
9 A. The information about the agreement about the division of the MUP
10 did not surprise us. The more so since we were convinced that nothing
11 would be changed in communication system because a conflict was not
13 MR. ZECEVIC: [Interpretation] Your Honours, I see that LiveNote
14 is still having trouble, still not working, and more than ten minutes has
15 gone by. So I don't know ... what are we going to do?
16 [Trial Chamber confers]
17 JUDGE HALL: I understand it's partially back.
18 [Trial Chamber and Registrar confer]
19 MR. ZECEVIC:
20 Q. [Interpretation] I apologise, Witness, we have a technical
22 [Trial Chamber and Registrar confer]
23 JUDGE HARHOFF: Do you have it, Mr. Zecevic?
24 MR. ZECEVIC: Yes, I do, Your Honours.
25 JUDGE HARHOFF: Let's proceed.
1 MR. ZECEVIC: Thank you very much.
2 Q. [Interpretation] Sir, you, if I understood you correctly, spent
3 most of 1991 right until April working in the communications centre of
4 the Security Services Centre of Sarajevo, the former MUP of the Socialist
5 Republic of Bosnia-Herzegovina. That's right, isn't it?
6 A. Yes, right up until 6th of April, 1992, when I was transferred to
7 Vrace and communications there with the MUP of the Republika Srpska.
8 Q. The fact is that under the rules which were in force for the MUP
9 of the Socialist Republic of Bosnia-Herzegovina and, consequently,
10 subsequently in the MUP of Republika Srpska, the public security stations
11 were duty-bound to ensure that every security-related event of interest
12 was reported to the Security Services Centres in the area where they
13 existed, right?
14 A. Yes. Those were the rules on mutual communication.
15 Q. So that means that every event of interest to security, which was
16 to have been reported to the Security Services Centre, provided a broad
17 span of events. That is to say, there was a broad area that had to be
18 reported to the Security Services Centre.
19 A. Yes. From traffic accidents to the very serious events such as
20 attacks against persons and property and so on and so forth, and
21 everything else that was of interest to the police and related to
22 security, the public interest, and public property.
23 Q. In any event, these security-related events of interest, which,
24 as a rule, were supposed to be reported to the Security Services Centre,
25 meant the engagement of the police and how they were to be deployed,
2 A. Yes. We -- we had to send out detailed reports, how many people
3 there were, working on what jobs. In peacetime, this even included
4 information about how many persons were stopped and asked for their ID.
5 Of course, that wasn't possible in these extraordinary circumstances.
6 Q. So, in addition to what I've set out and said about the
7 information concerning any police involvement of any type, the other
8 thing was that every crime perpetrated on the territory of a particular
9 public security station had to be reported, right?
10 A. Yes.
11 Q. Also under the rules, the public security station in each and
12 every case, when they detained people, in keeping with the law of a
13 period of up to three days held them in detention because they were
14 suspected of having committed a crime were duty-bound to inform the
15 Security Services Centre about that, right?
16 A. Yes, that's right. And set out the reasons for detention.
17 Q. And it is also a fact, is it not, that your experience in 1991 up
18 to the 6th of April, 1992, in the MUP of the Socialist Republic of
19 Bosnia-Herzegovina in the communications centre where you worked was such
20 that the number of incoming and outgoing dispatches depended on the
21 situation on the ground. What I mean to say is the number of events
22 which took place in the territory covered by your Security Services
23 Centre, right?
24 A. Yes, that's right.
25 Q. Then it would be logical to conclude that the greater number of
1 event, the greater number of dispatches would be received in the
2 communications centre of the CSB, right?
3 A. Yes. On condition that the centre was functioning properly.
4 Functioning at all.
5 Q. Now, in 1991 until the 6th of April, 1992, there weren't any
6 major upsets, were there, in which the CSBs in Sarajevo where you worked
7 did not function, was not operational?
8 A. That's right it functioned properly without a hitch.
9 Q. Now in the Security Services Centre, and let's stick to the
10 period of 1991 to the 6th of April, 1992, you had four people in a shift
11 and they worked round the clock, 24 hours, in the CSB Sarajevo
12 communications centre, right?
13 A. Yes. That would be the minimum number of people during the night
14 hours because there were four positions in the communications centre, and
15 these positions had to be manned at all times with a communications
17 Let me explain. It was operating the 92 telephone, the emergency
18 line, where citizens could report emergency events. Then there was the
19 telephone switchboard which communicated all the special departments
20 within the centre and within the RSUP. And the third post or position
21 was the open dispatch traffic which, at the time, was manned or had ten
22 teleprinters, and the fourth position or post was the so-called a cage or
23 encryption cage and teleprinter, and that officer, if there were only
24 four men working, then that officer would cover the KT devices too, short
25 wave. And at peek periods there would be even eight and ten people
2 Q. Very well. As we've seen and as my learned friend showed you a
3 number of documents dating back to the times of the MUP of Republika
4 Srpska and I mean the incoming and outgoing telegrams or received and
5 sent out telegrams and you looked at similar -- or you were duty-bound to
6 keep similar log-books in the communication centre of the CSB of Sarajevo
7 up until the 6th of April while you were working there, is that right?
8 A. Yes, they were identical books, log-books.
9 Q. When there is a large number of events taking place and when the
10 dispatch traffic was accelerated, whether it was open or encrypted, open
11 or closed, when there was dense traffic, then you would fill in this
12 whole log-book of incoming and outcoming -- outgoing dispatches in the
13 space of a week, right, you would fill it up in the space of a week?
14 A. Yes, a week to ten days.
15 Q. So -- well, you explained to us how the package with dispatches
16 being sent from the MUP that this would last for hours from the MUP
17 through the SCBs [as interpreted] towards the public security stations,
18 this passage and route would take several hours, so I'm not going to ask
19 you anything about that again. You have already explained that to us.
20 But what I'm interested in now is this: If I put it to that we
21 have certain information telling us that the total number, the average
22 total number of open and closed or encrypted dispatches in the MUP of the
23 Socialist Republic of Bosnia and Herzegovina was approximately 300.000
24 per year, would you agree -- well, do you agree with that? Is that
1 A. I think that that figure is correct, and I would even say that in
2 some years the figure was far greater.
3 Q. Now here, of course, we keep speaking about peacetime conditions
4 and circumstances, but in case of war, or a war conflict, and this is
5 something my learned friend asked you as well, and you explained this to
6 us, a number of less important dispatches -- well, they would be reduced,
7 but the number of essential, vital dispatches, in your opinion, would
8 increase during a case of war or war conflict.
9 Did I understand your testimony correctly? Is that what you
11 A. Yes, I think you have understood it because it is only to be
12 expected that the number of dispatches increases during those times.
13 Q. If I were to tell you that it would be logical to expect the
14 number of dispatches during war time, the total number of dispatches
15 should increase by 30 per cent, would you agree with that or not?
16 A. In these realm of security and security-related events, yes.
17 Q. Well, these security related events, as you've already told us,
18 all the security stations were -- had the obligation of informing the
19 CSBs about events like this, and that was done through the dispatch
20 system, right?
21 A. Yes. Wherever the system was operational.
22 Q. I'm still referring to the period between 1991 to the 6th of
23 April, 1992, so I assume that the dispatch system in these communications
24 service of the SCB [as interpreted] in the MUP of the Socialist Republic
25 of Bosnia-Herzegovina that the teleprinter system worked round the clock
1 without stopping, right?
2 A. Yes. And that year the intensity of dispatch sending was even
4 Q. When, on the 6th of April, you arrived at Vrace and came to the
5 centre, something that should have been a communication centre of the MUP
6 of Republika Srpska, you explained to us in deal, I believe, what you
7 encountered when you arrived. That was to say, equipment that was not
8 functioning properly or equipment that couldn't be used because there
9 were -- wasn't the proper communications system set up, and I believe you
10 said that you only had a single telephone when you arrived. Is that
12 A. Yes. And in that connection I'd like to say it was a small
13 communications centre, which, before the war, served to meet the
14 requirements of the school of Internal Affairs. That is to say, it was
15 not intended for communication of any kind with other organs except for
16 the MUP and internally within the school circle.
17 Q. Thank you. Now, you also said that at the beginning it was only
18 Mr. Trifkovic and you who worked in the communications centre; is that
20 A. Yes. Just the two of us.
21 Q. You also spoke about how you collected or went about collecting
22 telephone -- private telephone numbers from your neighbours there. But
23 as soon as you noticed that there was more traffic then the people at the
24 switchboard in Sarajevo would disconnect those telephone lines. Is that
1 A. Yes. And when we noticed that this was happening we would look
2 at the telephone directory and then everybody who was in the vicinity of
3 Doboj street, living in the vicinity of Doboj street where the school was
4 located, were disconnected. The Serb telephone lines were disconnected.
5 So that with the arrival of --
6 Q. So you didn't have that option either anymore?
7 A. That's right, but we tried to bring in connection lines from
8 other places.
9 Q. In your interview with the Prosecution, in Sarajevo, on the 23rd
10 of November, 2007, and this is 1D034161, on page 10, in response to a
11 question about how the system of communication functioned in the MUP of
12 Republika Srpska you said the following. You said:
13 "The overall communication system, according to all the rules, in
14 my opinion, started functioning only sometime towards the end of June and
15 beginning of July. Up until then, in my view, everything was
17 Do you stand by what you said in 2007?
18 A. Yes. That was fact, and all the documents point to that fact, to
19 that being so.
20 Q. Well, it is also a fact, is it not, that this was the result of
21 circumstances or, rather, the fact that the system of communications of
22 the MUP of Republika Srpska started to be built up by you in April 1992
23 from scratch. You started from scratch, right?
24 A. Yes. And that was the result of, first of all, the relations
25 between Sarajevo -- or, rather, Sarajevo's attitude to that whole issue,
1 that the network in the Security Services Centre of Sarajevo did not
2 disconnect the existing teleprinters. They did not disconnect our
3 telephone lines or special telephone lines that were internally collected
4 to the whole republic. Well, had that not happened we wouldn't have been
5 in the situation of that kind, had they not done all that, and therefore,
6 we had to start from scratch because they did disconnect them.
7 Q. Sir, you're a professional in your line of work. That is quite
8 certain. But we have to try and make things as clear as possible.
9 When you say the node of communications was severed,
10 disconnected, it is the nucleus from which all connections are tied up
11 from one part to the other parts, to other territories, right? In
12 layman's terms would that be right, this node, or not?
13 A. Yes. If we remember the schematic we looked at, that the
14 Prosecutor showed us, then we can clearly see whether these hubs were,
15 and with the exception of the only hub in Banja Luka, the single hub in
16 Banja Luka, then all the others were not under the control of the MUP of
17 Republika Srpska so that the specials that didn't have a dial on them
18 were no longer used, I mean, the special telephones, that's what I'm
19 referring to, without the dials. So that means ...
20 Q. So the task of the technicians and the administration for
21 communications and encryption of the MUP of Republika Srpska was, first
22 of all, to bridge the gap and to somehow tie up and connect the CSBs and
23 their area stations first and foremost amongst themselves and then the
24 CSBs with the MUP. Is that right?
25 A. Yes. And we had to rely on civilian connections to do that at
1 least for the Sarajevo area and -- because you couldn't rely on police
2 communications anymore.
3 Q. Sir, in essence, the communications within MUP, as a rule, and
4 also in practice, the most important element is the dispatch traffic.
5 That's the heart of traffic in any Ministry of Interior.
6 A. Yes. Any police service anywhere in the world would -- and does
7 recognise that as the only system.
8 Q. Sir, this crucial system, dispatch system, telex system was
9 something that in the territory of the CSB Sarajevo started functioning
10 in relation to area SJBs that were closer to the centre only in
11 July 1992, right?
12 A. Yes. One can say that for that segment, the conditions were
13 stabilized, at least partly, but not even then were they functioning all
14 the time.
15 Q. And in relation to SJBs in Eastern Bosnia, such as Vlasenica,
16 Milici, Zvornik, and Sehovici, all the public security stations that were
17 under the CSB Sarajevo the dispatch communication with them was
18 established in late 1992, if in 1992, at all. Am I correct?
19 A. For some of them, it was established, yes, in late 1992, when the
20 short wave devices started being operational. However, Milici got linked
21 up later because before the war there was no public security station
22 there. They really had to start from scratch. I think only 1993 they
23 had a centre of their own and until the formation -- until the
24 establishment of this Milici centre it was Zvornik which was the closest
25 to them with -- would function as a mediator, and they would have a
1 courier bring in the dispatches.
2 Q. Could you please just focus and give me answers precisely to what
3 I'm asking you.
4 The other means of communications, such as phone, ultra high
5 frequency, high frequency started functioning in the communication centre
6 of the Sarajevo CSB where you worked also only in July 1992 at the time
7 when you moved to Lukavica. Is that correct?
8 A. Yes.
9 Q. Only then, in July 1992, was this interim switchboard set up at
10 the school of economics which enabled you to establish communication
12 A. Well, actually, it was postal and telegraph switchboard that was
13 located at the school of economics. It was then when they managed to
14 become independent of the main Sarajevo postal and telegraph switchboard
15 when they got their number and code.
16 Q. In addition to the fact that at the school of economics there was
17 this provisional switchboard, that didn't mean that immediately you had
18 unhindered communication with the public security stations because there
19 was still problem with communication cables being cut off, interrupted.
20 There were power shortages and so on. Am I right?
21 A. Yes.
22 Q. You were shown document P573, page 6. It -- in the Serbian
23 version, it's page 13; page 8 in the English version.
24 MR. ZECEVIC: [Interpretation] Can we please look at that document
25 and comment it again.
1 Q. While we're waiting for the document, sir, it is a fact, isn't
2 it, that the National Security Service was using almost exclusively the
3 dispatch system that was encoded.
4 A. Yes.
5 Q. Because of the nature of information that the National Security
6 Service was transmitting.
7 A. Yes. And even in the earlier period, in the State Security
8 Service of the time, again, communications were of closed type.
9 Q. I was looking for page 13 of the Serbian text that was shown to
10 the witness by Mr. Hannis. Yes, this page. However, I read in the
11 transcript that it was page 8 in the English, 13 of the Serbian. Yes,
12 yes, that's the one.
13 My learned friend read to you this paragraph where your -- where
14 it is stated in this report that the ministry can establish communication
15 through public system with centres in Banja Luka, Bijeljina, in Sarajevo
16 and then using the short wave system for the other centres. It is a
17 fact, isn't it, that what is discussed here is a public, open, system,
18 namely, phone and telefax system, not the dispatch system. Am I right?
19 A. Yes. But what's referred to here is just one communication
20 channel, centre -- MUP in centre and the SJB. That doesn't mean -- when
21 I get an information from MUP that is relevant for all SJBs, doesn't mean
22 that I will successfully distribute the message further on to the others.
23 This is about MUP -- the connection between MUP and centre and centre to
24 the MUP. It does not include public security stations. It's not stated
25 in there and that's what I confirmed in my answer to the previous
2 Q. It is a fact, sir, isn't it, that the CSB in Banja Luka was, in
3 fact, cut off up until the corridor was open in 1992?
4 A. That's correct. And I cannot find an example that we managed to
5 send any information to Banja Luka using dispatch system. We, at Vrace.
6 I don't know whether our colleagues from Kalovita Brda managed in doing
8 Q. When we're talking about the Doboj CSB, the situation was even
10 A. That's correct.
11 Q. It is also a fact that the CSBs in Trebinje and Bijeljina were
12 very often disconnected from you.
13 A. Yes. In early April 1992.
14 Q. I have a daily report here that I can show to you relating to the
15 month of May 1992. And in them it is stated that Trebinje, Bijeljina,
16 and Doboj failed to send in their daily reports, which means that there
17 was no communication with them.
18 A. That's right. Be it because of the equipment or - and I think
19 that's the more important reason - namely, also because of power
20 shortages, and they simply didn't have generators that would provide them
21 with electricity, but I think that every daily report needed to include
22 information about such and such centres not submitting their reports.
23 Q. I presented this to you only because you, in your response, said
24 in early April. What I want to say is that the problem appeared in May,
25 June and even July.
1 A. Yes. But in May, I was already working in a different centre so
2 I'm not very familiar with this segment of their work.
3 Q. Thank you. Can you please tell me, and I think you confirmed
4 this during the questioning by Mr. Hannis, namely, in essence, all public
5 security stations in their communication with the Ministry of the
6 Interior or specific administrations within the ministry, would implement
7 through the CSB communications centre.
8 A. Yes. Because they themselves don't have the equipment.
9 Q. So an outgoing dispatch or information coming from the SJB goes
10 to the CSB and then from the CSB to MUP, and then back the same route.
11 A. Yes.
12 Q. So when the CSB has difficulties in communicating with some local
13 public security station, it means that a dispatch that should reach such
14 a station will have to wait until conditions are met for it to be sent?
15 A. That is correct. I think I did explain that we would then
16 prepare the copies and then hand them into the courier, unless, of
17 course, technical means would be established before the courier could
18 take them.
19 Q. The couriers, the courier service, it was not an organised
20 courier service. It was something that all members of MUP coming from
21 any security station to the CSB, they were duty-bound, weren't they, to
22 come to the communications centre as well and see whether there is some
23 mail that can be brought to the relevant public security station. Am I
25 A. Yes, you are right. There was no specific courier service. It
1 was done by, let's say, a driver of the chief of centre, who was doing
2 some other chores.
3 Q. And if no one from a specific public security station within a
4 period of, let's say 15 days, would not come to the CSB, a dispatch that
5 was not sent, due to problem with communications, would be waiting for 10
6 or 15 days in your offices; is that correct?
7 A. Yes.
8 Q. Sir, I will show you document 1D034282.
9 It is a CSB Sarajevo-Romanija-Birac list that has its seat in
10 Sarajevo. This document is from May 1992. And we can see, in the last
11 administration that is mentioned in the list. We can find it on the
12 second page of the English translation. So, there, it's the
13 communications department that's discussed. We can see Pejic Radovan, we
14 see your signature, we see your salary. Does this mean that you were the
15 only person who was working for the communications department of the
16 Sarajevo CSB in May 1992?
17 A. Yes. That was during the period of preparations for our move to
18 Lukavica and establishment of the CSB department there because MUP was
19 moving to Jahorina.
20 Q. And this is your signature?
21 A. Yes. And this is related to the period when an agreement was
22 reached between the minister and chief of centre that that will remain.
23 MR. ZECEVIC: [Interpretation] Unless there is an objection, I
24 would like to tender this document.
25 MR. HANNIS: No objection.
1 JUDGE HALL: Admitted and marked.
2 THE REGISTRAR: As Exhibit 1D331, Your Honours.
3 MR. ZECEVIC:
4 Q. [Interpretation] It is a fact, sir, is it not, that daily
5 reports, because if I understood you correctly during -- in addition to
6 the tasks you were dealing with in the communications centre you also
7 dealt with issues related to analytics?
8 A. Yes, that's correct.
9 Q. Daily reports drafted by the CSB to be submitted to MUP consisted
10 of, in fact, daily reports received by the CSB from the public security
11 stations in the area covered by the centre. Am I right?
12 A. Yes. But it is not just their statements put together. It
13 included processing of the information. Our daily reports. You
14 mentioned MUP's daily report. We also had a column where it would be
15 stated that the bulletins of daily events were not submitted by such and
16 such organisational units that had failed to do so. In the month of May,
17 we had a lot of such incidents.
18 Q. When something special has happened, when there was a particular
19 incident, and you, that is, the CSB get information from the SJB in
20 the -- in the territory in question, then you, generally speaking,
21 transmit that information to the ministry without editing it. Possibly
22 shorten it just a bit, right?
23 A. The commander of the police station, if he stated that the
24 dispatch is for the CSB, then we won't forward it to the ministry.
25 However, if the dispatch also mentions the MUP of the RS, or an
1 organisational units in MUP HQ as the recipients, then we will forward
2 the dispatch to those also.
3 We only process such dispatches that are addressed to the CSB
4 only without the MUP.
5 I feel I must explain this part. Under the regulation on mutual
6 information, it is clearly defined which dispatches have to go to the
7 ministry, even if only for information purposes.
8 Q. All right. Let us focus.
9 I understood you to say that if an SJB sends a dispatch to the
10 CSB, that dispatch stays there; correct?
11 A. Correct.
12 Q. If an SJB wants a dispatch to be transmitted to the MUP also,
13 then that dispatch is forwarded to the MUP without editing; correct?
14 A. Yes.
15 Q. My question was: As part of the daily reports, if you received
16 specific information from an SJB, you mostly transmitted it in the
17 original form, except for shortening it and leaving out unessential
18 parts. And that is then a report from the CSB that goes to the MUP?
19 A. Correct. To avoid misunderstanding, you are now referring to the
20 bulletin of daily events.
21 Q. All right. Sir, the Prosecutor showed you 65 ter 2914?
22 MR. ZECEVIC: [Interpretation] Can we see it again, please.
23 Q. It's a document dated 18 June 1992 where the minister of defence,
24 Colonel Bogdan Subotic, informs government ministries that the
25 government's communication centre, which is under his authority, as of 18
1 June, can transmit telegrams to the SAO Krajina and the other SAOs. And
2 he says that this channel of communication can be used for information
3 purposes and for requests. Can you see it?
4 A. Yes.
5 Q. You said that this document is not familiar -- or does not look
6 familiar to you, that you don't know it.
7 A. Yes.
8 Q. It's a fact, sir, isn't it, that this communications centre for
9 the government was not used for the MUP; correct?
10 A. I said that the CSB has never used this channel of communication.
11 Whether the MUP did, I don't know. I have never received a dispatch from
12 the MUP by this route.
13 Q. If the MUP headquarters had their communications centre which it
14 did --
15 A. Yes.
16 Q. -- and you communicate with that communications centre --
17 A. Only that communications centre. I have nothing whatsoever to do
18 with the communications centre mentioned in this document.
19 Q. Well, this is exactly what I'm saying. The MUP HQ has a
20 communications centre which is intended exclusively for the needs of the
21 MUP, due to the nature of its business, right?
22 A. Yes.
23 Q. This communication centre, under the authority of Mr. Bogdan
24 Subotic, is used for information purposes and requests of ministries and
25 administrative bodies in the territory; correct? We can see it here.
1 A. Yes, it clearly stated here.
2 Q. Thank you. Sir, you mentioned the term instruction. So I'll
3 show you a document.
4 MR. ZECEVIC: [Interpretation] 1D51.
5 Q. So we can see if we're talking about the same thing. It's an
6 instruction about urgent, current statistic reporting in the bodies of
7 the Ministry of Interior, and it's dated October 1992. Can you see it?
8 You commented with Mr. Hannis and explained that the system and
9 the regulations resulted in these instructions on -- instructions on
10 reporting. Did you mean this which we see?
11 A. Yes. This was preceded by the dispatch containing instructions,
12 but this document here more clearly defined the rules.
13 Q. You are familiar with this document?
14 A. Yes. I worked in analysis, so I know what it's like.
15 MR. ZECEVIC: [Interpretation] Could we please show page 3 of the
16 Serbian text to the witness. I suppose it's the same page in English.
17 Q. Sir, you can see here in the chapter about urgent notifications,
18 and this is what you spoke about, to Mr. Hannis about urgent
19 notifications. Do you remember?
20 A. Yes.
21 Q. It says in item 3:
22 "Urgent reporting is done as a rule by dispatch on the same day
23 when information is received about an event or occurrence regulated in
24 this instruction as requiring to be urgently reported to a ministry."
25 This is a general rule, isn't it?
1 A. Yes, it's a general rule. And it stems from other documents
2 which clearly outline the value of a dispatch as a communications
4 MR. ZECEVIC: [Interpretation] In order to explain to the Trial
5 Chamber what this is about, I would like to show page 5 to the witness,
6 page 5 in Serbian. I suppose it's also page 5 in English. Paragraph 9.
7 The page in Serbian is correct. Let us wait for the English translation.
8 Here it is.
9 Q. It says here in item 9:
10 "The local agencies of the Internal Affairs are duty-bound to
11 report urgently apart from information contained in item 7 especially on
12 the following ..."
13 From the area of combat activities, and then it mentions under 1,
14 2, 3, 4, 5, bullet point 5, war crimes about which questionnaires are Z
15 and RZ1 must be submitted.
16 So if I understand this correctly, and I would like you to
17 confirm, a war crime was considered a piece of information about which
18 the MUP had to be informed urgently; correct?
19 A. Yes.
20 Q. Thank you. In order not to complicate things, for the sake --
21 with e-court, you will certainly remember that enclosed herewith there
22 were some forms. Some lists or overviews about some specific types of
23 events, right?
24 A. Yes. This item only mentions RZ and RZ1 but there was also the
25 complete set of forms for statistics covering all areas. From combat
1 activities through public law and order, through traffic, through general
2 crime, white-collar crime and so on.
3 Q. Sir, I'm really only interested in one thing. I'm holding the
4 KRIM 1 form, which is enclosed with this instruction. The page number is
5 00903533, I'm not sure about the page reference in e-court but I'm
6 exclusively interested in the following.
7 This is a form for SJBs or rather all MUP members to fill out and
8 they must fill in data on the injured parties. And under number 39.3,
9 next to gender and citizenship, the ethnicity of the injured party is
10 explicitly required.
11 Do you remember that this -- this piece of information ethnicity
12 of the injured party was also included in the reporting?
13 A. Yes. Than was the practice even before the conflict. All forms
14 from KRIM 1, through KRIM, I don't know which number, with filled out by
15 operatives who either received criminal reports or -- or by those persons
16 who attended the onsite investigation, or those whose duty it was to
17 resolve the criminal offence committed.
18 Q. Thank you.
19 A. And if necessary, I can explain. Based on this, the analyses and
20 IT department processed this data, which contributed to a more efficient
21 uncovering of the perpetrators of crimes.
22 Q. Sir, I am interested in something else, and I'll ask you a direct
24 The MUP of the RS, as far as you know, did it ever have
25 instructions to the effect that crimes committed against victims who were
1 not Serbs should not be reported?
2 A. No.
3 Q. Do you know that there were instructions that such crimes that
4 were committed against people of other ethnicities should not be
6 A. No. The instructions were to the contrary: All war crimes must
7 be documented as soon as the conditions to do so can be met. There was
8 no separation along those lines.
9 Q. I'm not directly referring to war crimes now. I'm asking whether
10 there were instructions for any criminal offence committed against
11 non-Serbs, that is, against a person who was not of Serb ethnicity, for
12 such a criminal offence not to be registered and that there should be no
13 information about it.
14 A. There has never been such instructions in the MUP of the RS. I
15 know that for sure because I would have had to see it in the system when
16 I worked on communications, but especially later then I was transferred
17 to analyses where all the information comes in.
18 MR. ZECEVIC: [Interpretation] [Previous translation continues]
19 ... two more documents and I think six to eight questions, and I
20 believe -- can I do it now, but I see the time. Maybe ...
21 JUDGE HALL: In as much we have to return tomorrow in any event,
22 it would be easier and simpler that you wait until tomorrow and take the
23 adjournment now.
24 MR. ZECEVIC: I understand. Thank you, Your Honours.
25 Q. [Interpretation] Thank you, sir. We shall continue tomorrow.
1 A. You're welcome.
2 JUDGE HALL: Before we adjourn, I would remind the witness that
3 having been sworn in as a witness, until he's released, that you cannot
4 have any communication with counsel from either side, and should you
5 speak with anyone outside the Chamber, you can't discuss your testimony.
6 So we will resume in this courtroom tomorrow morning at 9.00.
7 Thank you.
8 [The witness stands down]
9 --- Whereupon the hearing adjourned at 1.45 p.m.,
10 to be reconvened on Friday, the 25th day of June,
11 2010, at 9.00 a.m.