Tribunal Criminal Tribunal for the Former Yugoslavia

Page 12105

 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.

Page 12106

 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

Page 12107

 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.

Page 12108

 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.

Page 12109

 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

 6     1992?

 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?

Page 12110

 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

19     cross-examination.

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

Page 12111

 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

 9     Prosecution.

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

Page 12112

 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

Page 12113

 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

Page 12114

 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:

Page 12115

 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

Page 12116

 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

16     world.

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

Page 12117

 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.

Page 12118

 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

17     functional.

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.

Page 12119

 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

Page 12120

 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

 7     communications.

 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

24     says:

25             "At this point" - 29 June, I guess - "the minister of the

Page 12121

 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

Page 12122

 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

23     you?

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

Page 12123

 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

11     month.

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

Page 12124

 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

Page 12125

 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?

Page 12126

 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

21     police.

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?

Page 12127

 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,

14     1992.

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 --

Page 12128

 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

25     started?

Page 12129

 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

Page 12130

 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

Page 12131

 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.

Page 12132

 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

Page 12133

 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.

Page 12134

 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

18     mind.

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

Page 12135

 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.

Page 12136

 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

Page 12137

 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

Page 12138

 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

 5     minister.

 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

Page 12139

 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

Page 12140

 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

Page 12141

 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,

 7     monthly?

 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

Page 12142

 1     Interior.

 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?

Page 12143

 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

Page 12144

 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

 3     signature.

 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

 8     latest."

 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

Page 12145

 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

Page 12146

 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 --

Page 12147

 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

21     anything.

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

Page 12148

 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

23     Honour.

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

Page 12149

 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

Page 12150

 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

17     1992?

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.

Page 12151

 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

 3     communication.

 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.

Page 12152

 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

Page 12153

 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

17     evidence.

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.

Page 12154

 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

23     colleagues.

24             But for this document -- I'm not offering this particular

25     document to show communication between headquarters [Overlapping

Page 12155

 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.

Page 12156

 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

 9     before?

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

Page 12157

 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

Page 12158

 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

18     Vlasenica.

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.

Page 12159

 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.

Page 12160

 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

14     01-127/92.

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.

Page 12161

 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

 5     that?

 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.

Page 12162

 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.

Page 12163

 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

Page 12164

 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];

 8     correct?

 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

24     Herzegovina.

25        A.   Yes.  In police, generally speaking, this was observed,

Page 12165

 1     especially with regard to the communications officers.  That service --

 2     efforts were made for that service to be manned by members of all

 3     ethnicities.

 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

12     expected.

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

21     problem.

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.

Page 12166

 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,

Page 12167

 1     right?

 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

Page 12168

 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

16     officer.

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

Page 12169

 1     working.

 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

25     correct?

Page 12170

 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

10     said?

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

Page 12171

 1     without stopping, right?

 2        A.   Yes.  And that year the intensity of dispatch sending was even

 3     greater.

 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

11     right?

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

19     right?

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

25     right?

Page 12172

 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

16     improvisation."

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,

Page 12173

 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

Page 12174

 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

Page 12175

 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

11     further.

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.

Page 12176

 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

Page 12177

 1     question.

 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

 7     so.

 8        Q.   When we're talking about the Doboj CSB, the situation was even

 9     worse?

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.

Page 12178

 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

24     right?

25        A.   Yes, you are right.  There was no specific courier service.  It

Page 12179

 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.

Page 12180

 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

Page 12181

 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

Page 12182

 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.

Page 12183

 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?

Page 12184

 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

 3     document.

 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

Page 12185

 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

23     question.

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

Page 12186

 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

 5     registered.

 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.

Page 12187

 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.