130625ED

Page 13287

1 THE REGISTRAR: Your Honours, we're back in open session.

2 JUDGE ORIE: Thank you, Madam Registrar.

3 MR. LUKIC: [Interpretation]

4 Q. You said you went to the school in Rocevic and there you met

5 Popovic; right?

6 A. Yes.

7 Q. You came in a passenger vehicle.

8 A. Yes.

9 Q. Who was with you in the car?

10 A. I was alone. I came to Rocevic alone.

11 Q. From Malisic to Rocevic?

12 A. Yes.

13 Q. And back to Malisic. You claim nobody was with you?

14 A. Yes.

15 Q. Would it refresh your memory if I said Jovic Dragan travelled

16 with you?

17 A. No.

18 Q. Was he your driver in that period?

19 A. No. I told you Dragan used to be my driver before, but in that

20 period it was Goran Radic, and of course that can be verified and proven.

21 Q. Do you remember you sent Jovic to fetch a truck from

22 Mico Stanojevic?

23 A. No. I didn't send him. I've already explained in what way he

24 suggested to Popovic that he would be able to take one of these vehicles

25 from Stanojevic, because he was on good terms with Stanojevic.

Page 13288

1 Q. Is it right that Djoko Nikolic appeared at Rocevic with a small

2 truck?

3 A. Yes.

4 Q. Did he come on his own accord or on somebody's orders?

5 A. Probably somebody's orders.

6 Q. Do you know whose orders? Do you know it today?

7 A. I'll take some of your time concerning Djoko Nikolic. I have to

8 try to explain to you to what extent my memory serves me.

9 When Popovic ordered me that all drivers should be informed to

10 come to the school at Rocevic, all those mentioned by Dragan Jovic, in

11 fact, he tasked me with passing on that information. However, I tricked

12 him a bit. So I told Popovic that I needed to call these people by

13 phone, and after a while I told Popovic I could not reach them. They

14 were not at home, et cetera. They were on leave, while all the other

15 drivers were at the ready in their units because of all these events and

16 the circumstances at the time.

17 After all this, when I've told Popovic they were not at home,

18 Popovic was very displeased, and he was in a great hurry, and things were

19 not working out as he had imagined. He was pacing around the school and

20 I had to run after him, and we talked while he was going in and out of

21 offices and while he was giving some instructions to the soldiers

22 guarding the prisoners. Therefore, part of our conversation was

23 overheard by Dragan Jovic.

24 So coming back to an earlier part of our discussion, Dragan Jovic

25 said, "Why don't you tell him we have trucks too?" And then Popovic

Page 13289

1 tasked me to explain what kind of trucks we had, and then he cursed me,

2 saying, "Why didn't you tell me that before?" But I tried to explain to

3 him that those were not military trucks, those were civilian trucks used

4 for the purpose I've already explained to you. And then regardless of my

5 explanations, he ordered me to summon those drivers. And for all these

6 reasons, I believe I tricked him a bit, saying that the drivers were not

7 at home. And then a bit later, he ordered me personally to go and see

8 whether these people were at home. I can't maintain it with 100 per cent

9 certainty, but I believe I went to the addresses of these people, but I

10 can't be completely sure because it was a long time ago.

11 I warned those drivers, drivers Mico Lazarevic, Djoko Nikolic,

12 and Radivoje Jekic, that Popovic is looking for them and that they could

13 be used to transport prisoners. I talked to them very quickly. They all

14 lived near the school, 500 metres away from the school but not more than

15 1 kilometre, and I made it very clear to them that they had better make

16 themselves scarce. I believe Radivoje Jekic and Milivoj Lazarevic did as

17 I said, whereas Djoko Nikolic was too scared, and he did not dare take my

18 advice and follow the example of the two others. Instead, he came with

19 his vehicle to the schoolyard.

20 I've tried now to reconstruct these events, and maybe I've

21 overlooked something in the sequence because it's very difficult now to

22 remember all the details of things that happened 20 years ago.

23 Q. Thank you. At any rate, you did not carry out Popovic's order?

24 A. That's right, because if I had wanted to call up other drivers, I

25 could have called company commanders by Motorola, giving orders that all

Page 13290

1 the drivers, all the other drivers, should report immediately, but I

2 didn't do that.

3 Q. You were never held accountable for refusing to carry out the

4 order?

5 A. I was not. No one ever instituted any kind of proceedings

6 against me in that regard.

7 Q. I'll try to summarise some points from your three statements

8 provided to the Prosecution regarding certain changes which occurred in

9 your testimony.

10 In the Popovic case, several Defence counsel suggested to you

11 that in each following statement you added new parts to them. Do you

12 remember that?

13 A. Yes.

14 Q. You agreed with it, and you said that you recollected certain

15 things as conversations developed; correct?

16 A. Yes.

17 Q. In your first interview with the Prosecution, you did not mention

18 that you were asked to provide a platoon from your battalion which was

19 supposed to take part in the executions.

20 A. Which interview do you have in mind?

21 Q. There are several interviews you conducted with Bruce Bursik.

22 A. Yes.

23 Q. And you explained you were not asked about it; right?

24 A. Right.

25 Q. In your first statement you did not mention Vujadin Popovic. You

Page 13291

1 did not say that you met him one day after the prisoners were brought to

2 the Rocevic school?

3 A. No.

4 Q. Well, is what I am saying incorrect, or is it correct that you

5 did not mention Popovic?

6 A. I did not mention Popovic. I wanted to clarify, since it was in

7 the course of initial discussions. So if you assist me, perhaps it was

8 in 2001 or 2002.

9 Q. Yes.

10 A. Which means it was seven years after the events, and off-the-cuff

11 it was very difficult to recall everything immediately. There are some

12 other things which I explained later in my subsequent statements.

13 Q. Is it correct that in the Popovic trial you said for the first

14 time you asked Popovic to evacuate the people from the school in Rocevic

15 and that he called the brigade and asked for vehicles?

16 A. As far as I recall, although I'm not 100 per cent certain, but

17 this assertion of yours may be correct. I agree. I asked him to

18 transfer the prisoners to the Standard barracks where there were better

19 conditions to keep prisoners. That was the only reason. And I requested

20 either that or that they be returned from where they had come from.

21 Q. Never in any interviews to the Prosecution did you mention a

22 young man who was a volunteer, and it is also something you mentioned in

23 the Popovic trial for the first time; correct?

24 A. Yes.

25 Q. Also, just before the Popovic trial, for the first time you

Page 13292

1 mentioned the truck which arrived from your battalion?

2 A. Yes.

3 Q. Also, just before the Popovic trial you mentioned the fact that

4 there was another soldier from the 2nd Battalion there who told Popovic

5 that there were some other trucks in the 2nd Battalion that can be used,

6 and you said it for the first time; correct?

7 A. Yes.

8 Q. You also for the first time mentioned the fact that the soldier

9 in question returned with a truck and a member of the 2nd Battalion;

10 correct?

11 A. I don't understand.

12 Q. You mentioned the fact that the soldier you mentioned returned

13 with a truck and another member of the 2nd Battalion, and you mentioned

14 it for the first time?

15 A. No. He returned with the truck only. He returned alone.

16 Q. Briefly, then, because we have a number of facts that I will try

17 to recall.

18 MR. LUKIC: [Interpretation] Can we have 1D1063 for that purpose.

19 JUDGE FLUEGGE: Can I ask in the meantime one question?

20 Mr. Acimovic, you said a moment ago:

21 "I asked Mr. Popovic to transfer the prisoners to barracks where

22 there were better conditions to keep the prisoners."

23 Which barracks are you referring to?

24 THE WITNESS: [Interpretation] The Standard barracks in Kozluk.

25 JUDGE FLUEGGE: Thank you very much.

Page 13293

1 JUDGE ORIE: Ms. Hasan.

2 MS. HASAN: Just on that point as well. In fact, the witness did

3 provide that information in his 2002 interview. So Popovic wasn't the

4 first time that he had raised that, and that's on page 28.

5 JUDGE ORIE: Mr. Lukic.

6 MR. LUKIC: I think my question was the first time before the

7 Popovic trial, just before the Popovic trial. It's page 13, line 19.

8 JUDGE FLUEGGE: And page 13, line 7 of today's --

9 MR. LUKIC: Yes --

10 JUDGE FLUEGGE: -- line 4 of today's transcript you asked the

11 witness:

12 "It is correct -- is it correct that in the Popovic trial you

13 said for the first time you asked Popovic to evacuate the people ..." and

14 so on.

15 That was your question today.

16 MR. LUKIC: I just said just before regarding this question I'm

17 asking now.

18 JUDGE ORIE: Let's --

19 MR. LUKIC: Let's --

20 JUDGE ORIE: These are two different matters. The first one,

21 whether or not the witness asked Popovic for a transfer; and the second

22 is whether he said anything about a truck arriving. These are two

23 different matters. And I think it's in relation to the latter one,

24 Mr. Lukic, that you referred to a statement given just before the Popovic

25 trial. The first time you mentioned the truck which arrived from your

Page 13294

1 battalion, whereas earlier you said:

2 "In the Popovic trial you said for the first time you asked

3 Popovic to evacuate the people from the school."

4 MR. LUKIC: I stand corrected then.

5 JUDGE ORIE: Please proceed.

6 MR. LUKIC: We need page 29 in this e-court document, and it

7 should correspond to page 13094 from the Popovic trial. We need lines 22

8 to 25. I will read in English so the witness gets the proper

9 translation.

10 Q. I quote:

11 "Q. Later on, you say, 'This soldier left and came back with the

12 truck and a driver from the 2nd Battalion.' This is the first time you

13 mentioned this to the Prosecution, this Sunday?

14 "A. Yes."

15 A. I really believe -- well, I still don't understand your question

16 or your conclusions. I think -- well, I'm not sure I understand what

17 it's about.

18 Q. [Interpretation] Just this: You confirmed today that the driver

19 returned with a truck?

20 A. Yes. He went to fetch a motor vehicle, that is to say the truck,

21 and he drove it there. He did not return with a driver. It has a

22 completely different meaning. You're trying --

23 Q. Just clear it up for us.

24 A. I'm trying to say that he didn't go and fetch both the driver and

25 truck, but as he suggested it to Popovic, he said that he was on good

Page 13295

1 terms with the man and that he could borrow the truck. You understand?

2 JUDGE ORIE: Let's try. I think Mr. Lukic is drawing your

3 attention to the fact that in the testimony he referred to that you

4 agreed that this soldier leaving and coming back with a truck was

5 mentioned for the first time the Sunday before you gave that evidence.

6 Mr. Lukic, that is what you had --

7 MR. LUKIC: Yes.

8 JUDGE ORIE: And I think let's just leave apart at that moment

9 whether it was the truck alone, but at least with the truck the soldier

10 returned.

11 Please proceed.

12 MR. LUKIC: Thank you, Your Honour.

13 THE WITNESS: [Interpretation] Yes.

14 MR. LUKIC: [Interpretation]

15 Q. Is it also correct that on that occasion, just before the Popovic

16 trial, you mentioned for the first time that it was you who suggested to

17 Popovic that the prisoners should be taken from the school to Kozluk?

18 A. I'm not sure whether it is was then that I said it for the first

19 time. I think I stressed it even before that, but I'm not 100 per cent

20 certain.

21 Q. Very well. From Rocevic you went to Kozluk; correct?

22 A. When?

23 Q. When you left the Rocevic school, around that time, to make a

24 telephone call.

25 A. Are you trying to say that it was on the first day, the 14th?

Page 13296

1 Q. Yes.

2 A. Yes.

3 Q. So the reason was to make a call?

4 A. Yes, certainly.

5 Q. Why didn't you call from Kozluk -- sorry, Rocevic?

6 A. Because I think at that time the school office was not available

7 for me to use the school phone. It was also my assessment that it was

8 far safer to discuss the topic, this topic we are now talking about, if I

9 resorted to a more secure, military line. In my mind it was quite

10 logical, given the fact that 15 to 20 minutes away by car, I acted

11 accordingly.

12 Q. Thank you. I asked you if you reported the fact that some of

13 your men took part in it. Can we conclude that individuals took part,

14 individuals from your unit, rather than your unit as a military

15 formation?

16 A. Yes, exactly as I stated.

17 Q. At some point you were accorded the status of a suspect?

18 A. Yes.

19 Q. When did you receive that status?

20 A. Could you read something out for me or jog my memory? I don't

21 recall. Do you have in mind the interviews back in Banja Luka in 2001

22 and 2002?

23 Q. I can tell you it took place during your last interview with the

24 Prosecution on the eve of the Popovic trial.

25 A. I agree with you.

Page 13297

1 Q. Concerning reporting, let me ask you this: Is it correct that

2 you informed neither the commander nor the duty operations officer in the

3 Zvornik Brigade?

4 A. I apologise, but you are putting unclear questions. I require

5 more precise questions, specific questions.

6 Q. At that time did you send a message or call the commander, the

7 Chief of Staff, or the duty operations officer of the Zvornik Brigade?

8 A. I think it is well known - and it is for the umpteenth time that

9 I have to say again - that I tried to reach them countless times. I

10 tried to reach the Chief of Staff and the brigade commander but was

11 unsuccessful because I was told they were unavailable. The duty

12 operations officer was informed by me about the events.

13 Q. When you say the "duty operations officer," do you mean to say

14 Drago Nikolic?

15 A. No. I told you already that at that time I didn't know who the

16 duty operations officer was.

17 If you allow me to suggest something. You asked me if I informed

18 anyone. By now you have sufficient information, and I told you that

19 Drago Nikolic tried to persuade me, or he tried to exert pressure for me

20 to accept the orders and implement them, and now you're asking me whether

21 I informed Drago Nikolic. It is the man who carried out such orders, who

22 actually issued such orders.

23 JUDGE ORIE: Mr. Acimovic, there's no need to comment on the

24 questions. If they're unclear, please ask for clarification, but whether

25 or not Mr. Lukic should ask certain questions, we leave it to him and to

Page 13298

1 the parties.

2 THE WITNESS: [Interpretation] I apologise.

3 MR. LUKIC: [Interpretation]

4 Q. We're near the end. I have a couple of questions left. On the

5 15th, when you called the duty operations officer in the Zvornik Brigade,

6 according to the documents we have the duty operations officer was

7 Drago Nikolic. Is it correct that on that occasion you did not recognise

8 Drago Nikolic's voice?

9 A. I don't know who the duty operations officer was. I always said

10 that it was either the duty officer or his assistant. I think with

11 Drago -- well, I don't know. I simply can't remember.

12 Q. What is confusing me is when you said that Drago Nikolic tried to

13 persuade you, so he must have been on the line.

14 A. I talked about the discussion which took place at 1.30 in the

15 morning.

16 Q. Yes. And on the 15th when you spoke with him again, you did not

17 recognise his voice?

18 A. On the 15th I asked countless times to speak to the commander or

19 the Chief of Staff so that the duty operations officer would put me

20 through. That's what I stressed thus far.

21 Q. Mr. Acimovic, thank you. This exhausts our questions for the

22 time being.

23 JUDGE ORIE: Thank you, Mr. Lukic.

24 Ms. Hasan, is there any need to re-examine the witness?

25 MS. HASAN: Yes, briefly, Mr. President.

Page 13299

1 JUDGE ORIE: Could you give us an indication as to how much time

2 you would approximately need?

3 MS. HASAN: I would say ten, ten minutes.

4 JUDGE ORIE: Ten minutes would be exactly the time for the break,

5 Ms. Hasan, so that fits perfectly well to the schedule. Please proceed.

6 Re-examination by Ms. Hasan:

7 Q. Okay. Witness, you mentioned at transcript, page 8, today you

8 mentioned speaking to Trbic, and you had told him what had happened in

9 Rocevic. Who is Trbic that you're referring to? Can you give us the

10 full name and tell us who he is?

11 A. Milorad Trbic, one of the assistants of Drago Nikolic at the

12 Zvornik Brigade. He was in charge of intelligence. We're talking about

13 Milorad Trbic.

14 Q. All right. And this conversation that you had with him, do you

15 recall where and when that took place?

16 A. After all those events around Srebrenica, I don't know after how

17 much time, certainly it went to days or more later, I think I talked to

18 him in his office at the Zvornik Brigade.

19 Q. And do you recall, sir, telling us about the conversation you had

20 with him and that he had informed you about what he had been asked to do?

21 Do you recall him telling you that?

22 A. Yes.

23 Q. Can you tell us what he told you?

24 A. Well, I have to make an introduction so you really understand the

25 gist. While I was at Rocevic, when I headed for Malisic, Popovic called

Page 13300

1 the duty operations officer and said they must send him urgently to

2 Rocevic one of the two men who had been in Orahovac or in Petkovci, that

3 one of them must urgently come to Rocevic. When I told Trbic about it

4 during that conversation, he said that Popovic probably meant him

5 personally or Miomir Jasikovac, commander of the Military Police Company.

6 Q. Okay. And did he inform you about his role anywhere else besides

7 Rocevic?

8 A. Well, briefly he said he was in close contact with the prisoners.

9 I'm not sure whether it was about Orahovac or Petkovci, but he avoided it

10 by leaving that location in a truck of the engineering unit that was

11 going towards the brigade, something like that. That's all I remember.

12 Q. Do you have any recollection --

13 A. Also, that day when Popovic wanted him, he found some other

14 business to avoid going to Rocevic, and to the best of his knowledge it

15 was Jasikovac who went instead.

16 Q. Okay. And, sir, perhaps this can refresh your recollection: Do

17 you recall Trbic -- are you telling us that Trbic had told you that Beara

18 had pressured him to participate in the killings at Orahovac and that he

19 had been asked by Beara to organise the killings there? Do you recall

20 that?

21 A. I really can't remember these details now about Milorad Trbic,

22 but if I said that in one of my statements, it's probable that he had

23 been sent to those locations on some business related to the prisoners.

24 What I understood from him was that he avoided doing that by removing

25 himself from these locations, Orahovac and Petkovci.

Page 13301

1 I did not have access to information related to goings-on in

2 other units, but that's what I understood from Trbic, from what he told

3 me that time.

4 Q. Okay. Let's move on then. At transcript page -- today's

5 transcript page 7, at about line 22, you were asked about certain

6 individuals who were members of your brigade and who were involved in the

7 transportation of prisoners. And then again at page 11 you were asked --

8 you discussed your proposal -- sorry, that Popovic was looking for these

9 drivers to transport the prisoners. Could you clarify for us where these

10 prisoners were be transported to?

11 A. Well, you see, at that moment when Popovic made his decision and

12 asked for these drivers to transport the prisoners to Kozluk, I could not

13 be sure what he really wanted, whether he had already decided to take

14 those prisoners to the barracks at Kozluk or he intended something else,

15 but I left Rocevic hoping that Popovic had, after all, decided to take

16 the prisoners to the barracks at Kozluk to save them from what was going

17 on at Rocevic and that he had listened to me, because I could not accept

18 the alternative. I couldn't accept anything else that might happen with

19 those prisoners, because that was contrary to all human dignity, all

20 humane principles. I just could not imagine that there would be another

21 outcome, although there were indications already at that time that

22 Popovic had different intentions, as I have already explained. And I was

23 hoping when Popovic accepted to transport the prisoners to Kozluk that

24 this thing could certainly not be carried out in Kozluk, because there

25 were institutions there. There was the police station. And it would

Page 13302

1 have been very inconvenient to do that in Kozluk and very hard to keep it

2 from the public eye.

3 So all this told me that the prisoners would, after all, be taken

4 to the barracks at Kozluk.

5 Q. Okay. Just a couple of things arising from that. You -- first

6 of all, the prisoners, were they in fact taken to a barracks?

7 A. I've already said that I left. I was not at Rocevic outside the

8 said school when the prisoners were transported, but I learned later that

9 the prisoners ended up in the way they ended up, in the way it was

10 established.

11 MS. HASAN: Mr. President, I have a couple more questions. Shall

12 I continue or shall we take a break?

13 JUDGE ORIE: Well, that depends on how much time they will take.

14 If you say it's -- three, four minutes would be enough, then we could

15 consider to continue. If you say it would take another 10 or 15 minutes,

16 then your initial assessment was rather optimistic.

17 MS. HASAN: I can try and -- try and wrap this up in a few more

18 minutes.

19 Q. Now, Witness, when you refer to -- to barracks, whose barracks

20 are those, which unit, the barracks in Kozluk?

21 A. [No interpretation]

22 THE INTERPRETER: Could the witness please repeat.

23 JUDGE ORIE: Could you please repeat your answer; the

24 interpreters did not catch it.

25 THE WITNESS: [Interpretation] It was the barracks belonging to

Page 13303

1 the Drina valley detachment of special forces.

2 MS. HASAN:

3 Q. Okay. And you refer -- you've referred to them as the

4 Standard barracks?

5 A. Yes. Yes. Before the war it was a shoe factory called Standard.

6 Q. One other thing. Is it not the case that you had a conversation

7 with one of the soldiers at the school, and this is a soldier who was

8 standing pretty close to you when you were having your conversation with

9 Lieutenant-Colonel Popovic, and that he had told you that these prisoners

10 were to be taken somewhere nearby, near the school, and that they should

11 all be killed in Rocevic. Do you recall that?

12 A. It was Popovic who said that.

13 Q. And this is something you had overheard?

14 A. I did not overhear it. I heard it. He had the time schedule, he

15 had the intention, and he just wanted soldiers from me to carry it out.

16 I just could not believe that something like that could really be done,

17 because it runs counter to all notions of a Serb soldier's honour.

18 Q. And, sir, this was after your conversation with Popovic when he

19 told you they were to be exchanged; isn't that correct?

20 A. Yes.

21 MS. HASAN: I have nothing further, Mr. President.

22 JUDGE ORIE: Thank you, Ms. Hasan.

23 Mr. Lukic, any questions remaining?

24 MR. LUKIC: Just briefly, Your Honour.

25 JUDGE ORIE: And you'd prefer to do that so that we can have the

Page 13314

1 first step, which was a prerequisite, really, was to secure equipment.

2 We mainly used radio amateur and ham radio equipment from amateur radio

3 clubs, and we procured such equipment for the reason that we wanted to

4 intercept and follow VRS communication. Once that stage was completed,

5 the first step would then be to search the frequency bands like someone

6 would do if sitting in a car searching for a station one wanted to listen

7 to.

8 The next step would be to eliminate all such frequencies and

9 stations which were not of any interest, so selection in short.

10 The third step was to pinpoint those channels or stations that

11 were to be followed and that were then followed. Since there was no

12 possibility for one person to do it, we used reel-to-reel recorders.

13 Following the process of recording, the tapes were then listened

14 to and conversations transcribed into notebooks. The next step,

15 depending on the degree of urgency, was to have the communication taken

16 to the cryptographic unit so that they would be assigned their respective

17 numbers. The last step was to draft reports and send them in encrypted

18 form to our superior command. In our case, it was the intelligence

19 department of the 2nd Corps.

20 So that would be a very brief explanation of the steps that were

21 undertaken at the facilities.

22 Q. Witness, you just said that your unit would be searching for a

23 frequency, and did your unit have the ability to intercept telephone

24 lines, PTT telephone lines, used by the VRS?

25 A. Our unit did not have the ability to wiretap directly the PTT

Page 13315

1 lines, but they could be picked up by radio relay communication. So we

2 could listen in that way. We couldn't tap directly into the PTT lines

3 though. We also couldn't follow, monitor, certain bands such as SMC 120,

4 HVT 1, and FM 20 -- FM 200 used by professional military radio equipment

5 for relay communication, and we could not monitor those.

6 MS. LEE: May I please have 65 ter number 20973C on e-court, and

7 it's not to be broadcast to the public since it's under seal.

8 Q. Witness, have you seen this document before in preparation of

9 your examination here today?

10 A. I think I have, although I've seen a zillion such reports before.

11 Q. Okay. Let's -- let's see the heading. It says the "Army of

12 Republic of Bosnia and Herzegovina," and below that it has the name of

13 the northern -- the northern location, and it says "Strictly

14 Confidential," followed by numbers "11/13795," and it is dated the 13th

15 of July, 1995. Do you see that?

16 A. Yes, I do.

17 Q. Does this report in the form that it's in, does this look

18 familiar to you?

19 A. Yes.

20 Q. And can you tell us what the numbers 11/13795 indicate?

21 A. This would be the standard heading of an official report sent

22 from the northern facility. The digits mean the following: "Strictly

23 confidential," of course, designates the level of secrecy, and it was

24 sent from the northern facility. Number 11 means that it was the 11th

25 report produced or sent on the 13th following midnight. 3795 is the

Page 13316

1 date, so 13795. It was the simplest way to designate it. And just below

2 we have the full date, which is 13/7/1995.

3 Q. And was there any standard procedure as to the number of reports

4 that would be sent in a given day during -- in July of 1995?

5 A. Neither in July nor in any other month was there any kind of

6 standard procedure to send P3820 [as interpreted]. Reports were sent

7 unselectively as required by the communications traffic and depending on

8 the amount of information. At following midnight we would start

9 assigning numbers to the reports starting with the number 1. It could

10 conclude with 15, 18, or 25 reports in a single day depending on the

11 radio traffic of the opposing side. We also concluded each day with 00

12 hours, 00 minutes. Then the last report of the day would be included.

13 Q. Now, let's look at this document, the intercept recorded below

14 and it has a heading and it starts with 785.000. And then it has channel

15 11, and it has 17 hours and 30 minutes. What does this mean?

16 A. To easily navigate the working map and have a visual map of the

17 situation, it actually meant the following: The main frequency that this

18 conversation was intercepted was at 775.00 megahertz, and it is the

19 frequency of the RRU 800 device working up to 950 megahertz, and we used

20 it the most. It was intercepted on the -- on channel 11. So there were

21 two subgroups. The first one had 12 channels, and the second either 8 or

22 12 channels depending on the number of number of channels assigned to the

23 unit by the command. The figure next to it is the time when it was

24 recorded, then we have the axis, meaning that the signal was received

25 from south-east, looking from the location of the facility where the

Page 13317

1 conversation was intercepted.

2 Q. Below it says "Participants," and if we look at the intercept, it

3 says:

4 "X: Is it possible for us to send about a dozen buses from

5 Bijeljina?"

6 And then it says:

7 "Y: Call them to come immediately. There are now about 600 of

8 these."

9 And then X continues and says:

10 "Fit for military service."

11 And Y says:

12 "Quiet, don't repeat."

13 Now, who are X and Y here in the intercept? Can you identify

14 them?

15 A. As part of certain steps in the procedure, there were a number of

16 rules that were applied, one of them being applied here. We intercepted

17 this conversation, and those listening in could not overhear the

18 participants introducing themselves, whether they used their names, code

19 signs, or numbers. The X means that the person was unknown to those

20 eavesdropping, and the same goes for the person -- for person Y who was

21 on the other end of the line. So we have two interlocutors whose names

22 are unknown.

23 JUDGE ORIE: Before we continue, Ms. Lee, the witness said that

24 the conversation was intercepted at 775 megahertz, whereas the document

25 as you read it was 785. Is that just a mistake that you made, or is

Page 13318

1 there any reason why you refer to 775 rather than to 785? If the witness

2 could clarify.

3 THE WITNESS: [Interpretation] Perhaps I made a mistake. I'm a

4 bit removed from the screen, so perhaps it's sometimes difficult to read.

5 If I said so, it's my mistake. It should be 785 megahertz.

6 JUDGE ORIE: Please proceed.

7 MS. LEE:

8 Q. Witness, were there instances where participants would be

9 identified?

10 A. There were, many a time. They would introduce themselves,

11 talking to each other, or on occasion one of them would introduce

12 himself, the other would not. It all depended.

13 Q. And would those have all been recorded by the intercept

14 operators?

15 A. All conversations, irrespective of the fact whether someone was

16 introduced or not, were recorded.

17 MS. LEE: Now, can we -- if we could scroll down the B/C/S

18 version to the bottom of the page and go to page 3 of the English

19 version.

20 Q. Witness, you see at the bottom -- at the bottom right corner

21 "ZB/ZB." What do these letters represent?

22 A. If I recall correctly, these are the initials of the person

23 encoding the telegram.

24 MS. LEE: Your Honours, the Prosecution tenders 65 ter number

25 20973C into evidence under seal.

Page 13319

1 MR. IVETIC: No objection to this one.

2 JUDGE ORIE: Madam Registrar.

3 THE REGISTRAR: Your Honours, 20973C receives number P1615 under

4 seal.

5 JUDGE ORIE: P1615 is admitted under seal.

6 Now, Ms. Lee, one additional question to the witness.

7 You said the letters ZB/ZB represent the initials of the person

8 encoding the telegram. Now, it would surprise me if there were two

9 persons ZB - of course it could be coincidence - but do you have an

10 explanation as to why we have the same initials before and after the

11 dash?

12 THE WITNESS: [Interpretation] I do, Your Honour. At the time it

13 meant, and I believe I can even recall the person's first and last name,

14 it means that the person in question both encrypted and typed out the

15 conversation from the notebook into the computer and when it was sent.

16 Sometimes you will encounter numbers as well, but those were assigned

17 internally.

18 JUDGE ORIE: So two functions here performed by the same person.

19 THE WITNESS: [No verbal response]

20 JUDGE ORIE: Thank you.

21 Please proceed.

22 MS. LEE: May I please have 65 ter number 21063A on e-court, not

23 to be broadcast to the public.

24 Your Honour, the record shows that the witness -- the witness's

25 answer does not appear on the record. He has nodded, but if he could

Page 13320

1 just answer --

2 JUDGE ORIE: He nodded in the affirmative. That's hereby on the

3 record.

4 MS. LEE:

5 Q. Witness, do you recognise the document on the screen as the one

6 that you have seen in preparation of this -- of your testimony today?

7 A. Yes, I do.

8 MS. LEE: And, Your Honours, I have the original notebook

9 containing this intercept, and I would like to show it to the witness

10 and, if possible, put it on the ELMO afterwards.

11 JUDGE ORIE: Yes. You may proceed, and Mr. Ivetic has no

12 objections. He nods as well in the affirmative.

13 I think it was requested to be put on the ELMO.

14 MS. LEE: Yes. But before that, if Your Honours would like to

15 look at it as well, if it assists Your Honours.

16 JUDGE ORIE: Well, if there's any need, we'll do that after it be

17 put on the ELMO. Can we put it be the ELMO? Can it be made public?

18 MS. LEE: Yes. Yes, Your Honours.

19 JUDGE ORIE: Okay. Any specific page?

20 MS. LEE: Just the cover of it.

21 JUDGE ORIE: Just the cover of it.

22 MS. LEE: Now may I please have 65 ter number 29010.

23 Q. Witness, is this document a copy of the notebook that you see on

24 the -- that you have just seen?

25 A. Yes, it is.

Page 13321

1 MS. LEE: Your Honours, I would like to tender 29010 as an

2 exhibit, as a public exhibit.

3 JUDGE ORIE: Mr. Ivetic.

4 MR. IVETIC: No objection.

5 JUDGE ORIE: Madam Registrar, the number would be?

6 THE REGISTRAR: Your Honours, 29010 receives number P1616.

7 JUDGE ORIE: And is admitted into evidence. Under seal or not?

8 No need to have it under seal. Then as a public exhibit.

9 MS. LEE: Now, may I please go back to have 21063A on e-court,

10 and the notebook could be removed from the ELMO and given to the witness.

11 Q. Witness, if you could turn to the page where the red tab is

12 located on the notebook. It's the following page.

13 JUDGE ORIE: What page is it in e-court, Ms. Lee?

14 MS. LEE: In e-court it's the same page, 0 -- it's the page that

15 is shown on e-court.

16 JUDGE ORIE: Yes, but for the Appeals Chamber later, if it ever

17 comes to that, red tabs are not visible to them. They do not know what

18 is on our screen at this moment. So therefore --

19 MS. LEE: I would ask then that page of the notebook to be placed

20 on the ELMO.

21 JUDGE ORIE: That doesn't help us out. Is it -- let me just see.

22 It's a two-page document in e-court.

23 MS. LEE: Oh, sorry.

24 JUDGE ORIE: We're on the first page.

25 MS. LEE: We're on the first page in e-court, yes.

Page 13322

1 JUDGE ORIE: First page of that document. Yes.

2 MS. LEE: And I have -- I am now asking the witness to verify

3 whether or not that first page corresponds to the page in the notebook

4 where the red tab is shown, and if that first page only could be placed

5 on the ELMO for Your Honours to see as well.

6 JUDGE ORIE: Is there any dispute about these being -- that what

7 we have in e-court is the reproduction of what -- there seems to be no

8 problem there, so -- Ms. Lee, so it's a rather complex exercise you

9 engage in.

10 MS. LEE: Yes.

11 JUDGE ORIE: Whereas - I'm looking at you, Mr. Ivetic - you could

12 just work on the basis of the e-court English and original. Is that --

13 MR. IVETIC: Well, I don't know what counsel wants to ask --

14 JUDGE ORIE: No, no --

15 MR. IVETIC: -- but definitely we don't have a dispute as to that

16 this is a reproduction of a particular page in that book.

17 JUDGE ORIE: Yes. Then perhaps he could have a look at the book

18 and the Chamber would have a look at the book so that to know what it

19 looks like and then you just proceed.

20 MS. LEE:

21 Q. And, Witness, do you recognise this notebook to be one that would

22 originate from your unit?

23 A. As far as I can see, I believe so. Yes, it is from our unit.

24 MS. LEE: Your Honours, I would like to tender 65 ter number

25 20973 -- 20973A as the next exhibit under seal.

Page 13323

1 MR. IVETIC: No objection.

2 JUDGE MOLOTO: Sorry, Madam, the -- you're recorded on the regard

3 as "20973A." Did you want to say 2 --

4 MS. LEE: 21063A --

5 JUDGE MOLOTO: -- 3A.

6 MS. LEE: Yes, Your Honours.

7 JUDGE ORIE: This number being corrected, Madam Registrar, it

8 would receive number?

9 THE REGISTRAR: Your Honours, 21063A receives number P1617.

10 JUDGE ORIE: P1617 is admitted. No reason to have it under seal?

11 MS. LEE: The document on the second page there is an initial and

12 a signature that appears on it, and this is the reason why I would like

13 to have it under seal.

14 JUDGE ORIE: In the original then it is admitted under seal.

15 MS. LEE: Now, may I please -- I would like to keep P1617 in the

16 B/C/S version on the screen, and I would like to call up P1581 that's

17 marked for identification in e-court and have the B/C/S version of that

18 document beside P1617.

19 Q. Now, Witness, do you recognise the printed document that's

20 appearing on the right to be one that was generated by your unit?

21 A. Yes.

22 Q. And is the intercept contained in the notebook similar to the

23 intercept contained in the report?

24 A. Well, yes.

25 JUDGE FLUEGGE: I think that should not be broadcast. That was

Page 13324

1 not requested.

2 MS. LEE: And now that's added, can we keep P1581 marked for

3 identification on the screen and have the first page of both English and

4 B/C/S. I would like to remove P1617 off the screen. And have both

5 English and B/C/S.

6 Now, Your Honours, this document was tendered during the

7 testimony of Witness Keserovic, during which the mark -- the document was

8 marked for identification pending information on the authenticity and the

9 origin of the document, and at that time an English -- a revised English

10 version of the document was ordered to be uploaded, and so the

11 Prosecution now moves to admit P1581 marked for identification as the

12 next evidence under seal.

13 MR. IVETIC: No objection to I guess changing the status of the

14 document.

15 JUDGE ORIE: P1581 is now admitted under seal.

16 MS. LEE:

17 Q. Now, Witness, in the -- in this document itself, there's a word

18 that's appearing on the -- in the first line. It says "Badem." Can you

19 tell us what Badem stands for?

20 A. In this specific case Badem is the code-name. I don't want to

21 play smart, but I really remember it well. It's the code-name of the

22 Bratunac Brigade, and we have another interlocutor, somebody Micic, with

23 an unidentified interlocutor, X. I'm telling you the code-name of the

24 Bratunac Brigade from 1995.

25 Q. Thank you.

Page 13325

1 MS. LEE: Now may I please have 65 ter number 21069E on e-court,

2 and it's not to be broadcast to the public.

3 JUDGE FLUEGGE: Can we keep these documents for a moment on the

4 screen. In the English version we see on the bottom of the page instead

5 of M and B always question marks. In the B/C/S version, I think we see B

6 and X and M instead of. Ms. Lee, could you explain why that appears in

7 the translation?

8 MS. LEE: Have we called 21069E yet or are we still on the other

9 one?

10 JUDGE ORIE: We're still with the previous one, and Judge Fluegge

11 asked for a clarification, a difference between the English text where

12 question marks appear. Could we go back to the --

13 JUDGE FLUEGGE: We just had it on the screen. We want to stay

14 with it. I guess I realise we had the wrong English version on the

15 screen. Now we should have the right one. Perhaps that --

16 Madam Registrar could indicate which document is on the screen.

17 THE REGISTRAR: Your Honours, currently we have P1581 on the

18 screen.

19 JUDGE ORIE: Yes. What explains the other version which we had

20 on our screen a second ago? Where did it come from, and --

21 MS. LEE: This is the translation -- English translation that we

22 received from the CLSS, and where they are -- question mark is I believe

23 they were not -- they could not make out what the handwriting version

24 was.

25 JUDGE MOLOTO: I still have a question. Now, what we have now on

Page 13326

1 the screen, on -- on the B/C/S side exactly where Judge Fluegge was

2 asking, we do have an M as an interlocutor, an X, and a B. We don't have

3 a B on the English side.

4 JUDGE FLUEGGE: If we can move further down on the English

5 page -- or go to the next page. Can we go to the next page in English.

6 There we have the B again.

7 JUDGE MOLOTO: Thank you very much.

8 MS. LEE: May I please have 65 ter number 21069E on e-court, and

9 it's not to be broadcast.

10 Q. Now, Witness, we have just seen the same report of the

11 intercepted communication at 1220, but if you could now go to page 2 of

12 this report in B/C/S.

13 JUDGE FLUEGGE: Sorry, in the English I see 1244.

14 MS. LEE: Yes, Your Honour. Because this specific 65 ter number

15 only deals with the intercept time at 1244, I believe the CLSS --

16 JUDGE FLUEGGE: We can see that now B/C/S, thank you.

17 MS. LEE: Thank you, Your Honour.

18 Q. Now, Witness, in looking at this intercept on page 2 of this

19 document, the intercept at 1244, there is no reference to any date other

20 than the time of the intercept. Why is that?

21 A. Well, that's because the date is already in the header, and these

22 are reports already compiled in a set, conversations typed up the same

23 day, one after another.

24 Q. Thank you. Now -- so this appeared to be the third intercept of

25 this report. Was there any standard procedure as to how many intercepts

Page 13327

1 would be included in a typed report?

2 A. There was no standard procedure. There could be five, six, seven

3 conversations. It all depended on the length. As soon as we recorded

4 one conversation or two or three, we would take them to the KZ, the

5 encrypting unit, where it would be typed up. So it could not -- it

6 didn't have to go to one single -- from one single workplace. People

7 would take a tape as soon as it was full, whether it was two or three

8 conversations or five or six, but they were all from the same date as

9 long as they are under the same header, just different periods during the

10 day.

11 Q. Thank you. Now, just looking at this intercept then at 1244, if

12 you wanted to know the date of it, where would we have to look for it?

13 Where do we have to look for the date?

14 A. We will look for the date on the official typed-up report, in the

15 header, because in our understanding a report becomes official once it's

16 typed up and encrypted. We can also find it in the notebooks, because

17 when an entry is begun, the date is written, and then you write

18 conversations in their sequence until the end of the day, until 2400

19 hours.

20 MS. LEE: Can we go to the first page in the B/C/S version.

21 Q. On the top of the page there is the header, and is this the only

22 time the header would be shown in a report?

23 A. This is only page in the ninth report that day where you see the

24 header, so it was before eight. Later on, there's probably more.

25 Q. Now, if we could back to the second page of the B/C/S at 1244.

Page 13328

1 Witness, in the middle of this intercept there is reference to Zlatar 01.

2 Do you know what that means, Zlatar 01?

3 A. I think I know from the document, not from the VRS, but

4 communications documents of the Army of Yugoslavia. This was the

5 code-name for the command of the Drina Corps, and the commanding

6 officers, according to rank, received numbers. This should be a

7 commander or somebody from the command telephone Zlatar 01, the first

8 man, man number one in the Drina Corps, whereas Zlatar without any number

9 was the telephone exchange or the code-name of the unit. The operator of

10 that particular telephone would pick it up.

11 MS. LEE: Now, Your Honours, I would like to tender this

12 intercept as the next exhibit under seal.

13 MR. IVETIC: Your Honours, the B/C/S and the English do not

14 correlate to one another, so I think that we have to have a new, I guess,

15 translation because the entirety of the B/C/S is not translated in the

16 English translation that is in e-court.

17 JUDGE ORIE: Yes. Now, I do understand that the Prosecution did

18 not want to change the original document and has explained in quite some

19 detail where the header at the beginning of the day first, at least

20 before the first intercept, is translated on the top of the English and

21 then it continues partial translation. So I do understand that you only

22 rely on the header and on the 1244 communication, but you did not want to

23 manipulate the original B/C/S one, but you do not rely on any of the

24 other conversations which are not translated, if I understand you well.

25 MS. LEE: Yes, Your Honours.

Page 13329

1 JUDGE ORIE: With this explanation, Mr. Ivetic, still objection?

2 MR. IVETIC: Your Honours, an objection is just pointing to the

3 standard procedure that's been in this case that you have made us re-do

4 exhibits if the part that we're relying upon and that is translated is

5 not the entirety of the exhibit. So I'm just asking for instructions

6 from the Chamber.

7 MS. LEE: If I may respond, Your Honour.

8 JUDGE ORIE: Please do so.

9 MS. LEE: This 65 ter number you'll see in the description that

10 it only relies on the intercept communication at 1244, and so the exhibit

11 itself has been translated because the portion that we're relying on has

12 been translated, and that's the only portion that we are relying on under

13 the 65 ter number.

14 JUDGE ORIE: The objection is denied. The document is admitted

15 into evidence.

16 Madam Registrar, the number it would receive is?

17 THE REGISTRAR: Your Honours, 21069E receives number P1618 under

18 seal.

19 JUDGE ORIE: Exhibit P1618 is admitted under seal. Please

20 proceed -- not -- please do not proceed I would say because it's time for

21 a break.

22 Witness, we'll take a break of 20 minutes. We would like to see

23 you back after the break. We have -- first the curtains should be down

24 for you to leave the courtroom. So we first move into closed session,

25 and we resume in closed session after the break and then to turn into

Page 13331

1 Q. Witness, when you look at this intercept, it says participants, X

2 and Trbic. And I would like to know how did the intercept operators

3 identify the participants?

4 A. I'm sorry, what I'm seeing is -- oh, here it is. You can repeat

5 the question, please.

6 Q. It says participants X and Trbic, and I would like to know how

7 the intercept operators identified the participants. Generally, not

8 specifically in relation to this intercept, but generally how did the

9 intercept operators identify participants when they were listening in to

10 conversations?

11 A. There were several ways. The first, the worst one, is when the

12 interlocutors do not say their names. They do not even say the

13 code-name, so you put X and Y. The second way is when the interlocutor

14 introduces himself. The third way is to identify them by their personal

15 characteristics. Everybody has their own voice modulation and other

16 personal features. You can also identify them from the locations they're

17 calling or they would reveal their identity by calling for Zlatar 01, and

18 we know who Zlatar 01 is, we know it from the code list. So there are

19 several ways, but one thing that's sure is that the interceptors never

20 wrote down a name that has not been verified or confirmed.

21 MS. LEE: Thank you. May I please have 65 ter number 21135B on

22 e-court.

23 THE REGISTRAR: Your Honours, if the Prosecution could release

24 the translation of the document. Thank you.

25 MS. LEE:

Page 13332

1 Q. Witness, the document on your left screen, do you recognise this

2 document as a document that would have originated from your unit?

3 A. I apologise again, but there's nothing on my screen.

4 MS. LEE: Could the witness be assisted.

5 JUDGE ORIE: Could the usher assist.

6 JUDGE MOLOTO: I'm not sure whether we have the English

7 translation, Madam Lee, on the screen.

8 THE WITNESS: [Interpretation] Is that it?

9 MS. LEE: I think Ms. Stewart says it has been released. The

10 English translation has been released on e-court.

11 JUDGE ORIE: But what we see this moment the left part of the

12 screen, the time indications are different from what we see on the right

13 part of our screen. I see 1304 and I see 1334.

14 MS. LEE: Yes. I believe the English translation is that from

15 the previous exhibit, which was P1618 that has not been removed from the

16 screen.

17 Can I have the -- okay. I see the --

18 JUDGE ORIE: 1304, Colonel Cerovic seems to be both in English

19 and in B/C/S. B/C/S in handwritten -- in handwriting on our screen. I

20 think we are there.

21 MS. LEE: Thank you, Your Honours.

22 Q. Witness, do you recognise this document to be one that would have

23 come from your unit?

24 A. I think it is.

25 MS. LEE: Now, may I please have -- may I please keep the B/C/S

Page 13333

1 version on the screen and have 65 ter number 21135F on the right side of

2 the screen.

3 Q. Witness, do you recognise the document on the right to be a

4 report that would have been generated from your unit?

5 A. Yes. It's easier now. It's a report that came from the

6 installation in the north.

7 Q. And looking at the date, the frequency number, and the time, does

8 the report correspond to the intercept contained in the notebook?

9 A. Yes. We see here that it's the sixth report in sequence of the

10 21st of July, 1995. The connection on RRU 1 was monitored, and the

11 participants are Colonel Cerovic and an unidentified general, recorded at

12 1304.

13 Q. Thank you.

14 MS. LEE: Now, may I please have the handwritten notebook

15 removed, so 21135A removed, and have 65 ter number 21135D right beside

16 the printed report.

17 Q. Now, looking at the report on the left, can you tell us what that

18 is?

19 A. This report on the left is not our report, but judging from the

20 title, it was sent by the CSB or the State Security Service; and that

21 day, on the 21st of July, 1995, they took this over from us. It's the

22 same interlocutors and the same time. It's the result of a co-operation

23 we had in order to cover as many channels as possible.

24 When I joined this effort, I established this co-operation and

25 collation of information. So they shared their information with us and

Page 13334

1 vice versa. This comes from a report of our men from the north which

2 they sent to their own base.

3 Q. And, Witness, you have previously -- you have previously

4 testified that there was sharing of information between the units. Would

5 this be an example of that occasion?

6 A. I remember it well that I stated earlier that there was no

7 quality co-operation. I asked from our superior that co-operation be

8 established because our ability was modest, whereas the ability to

9 monitor SDB networks were even more modest, was even more modest. They

10 worked with only one or two people at the most to cover it. The superior

11 command -- then the competent command approved, and we started not in

12 July but as early as March or April, and this is a result of such

13 co-operation.

14 MS. LEE: Now, may I have the -- the document on the left removed

15 and have 65 ter number 21135B on the screen, the B/C/S version of it. I

16 apologise. I think I meant to say 2113A -- 35A on the screen.

17 Q. Witness, looking at the notebook, do you recognise this to be one

18 that would have come from your unit?

19 A. I have said already that it is difficult without a heading, but

20 this notebook did originate from our unit. I see the signature as well.

21 I think it is a notebook from the southern location. The conversation is

22 the same as the one that was intercepted at the northern facility. The

23 time is different though, because here it says 1305, and in the northern

24 facility intercept the time is 1304. The participants are the same. The

25 difference is, though, that due to the proximity of the southern facility

Page 13335

1 in relation to the source, they were able to recognise the other

2 interlocutor, and it is stated that it is General Krstic.

3 MS. LEE: Your Honours, I would like to tender 65 ter numbers

4 21135A, 21135B, 21135D, and 21135F as exhibits all under seal.

5 MR. IVETIC: No objection.

6 JUDGE ORIE: Madam Registrar, the numbers would be?

7 THE REGISTRAR: Your Honours, 21135B receives number P1619 under

8 seal.

9 JUDGE ORIE: And is admitted under seal.

10 THE REGISTRAR: 65 ter number 21135F receives number P1620 under

11 seal.

12 JUDGE ORIE: And is admitted under seal.

13 THE REGISTRAR: 65 ter number 21135D receives number P1621 under

14 seal.

15 JUDGE ORIE: And is admitted under seal.

16 THE REGISTRAR: And 65 ter number 21135A receives number P1622

17 under seal.

18 JUDGE ORIE: And is admitted under seal.

19 May I can take it and may I hope that there's no confusion,

20 because the numbers are so similar, the one 211 as a start and the other

21 213, but apparently it has been verified. Because the similarity of the

22 numbers could easily create confusion, but it being verified, we can

23 proceed.

24 MS. LEE: Thank you. May I please have 65 ter number 29017 on

25 the screen, please. It does not need to be under seal.

Page 13336

1 Q. Witness, do you recognise this document as a document that you

2 have seen in preparation of your testimony here today?

3 A. Yes.

4 Q. And there are 20 items listed on this document. Did you have a

5 chance to look at all of these items, most of which were intercepts?

6 A. Yes.

7 Q. And can you confirm to us that all documents appearing on this

8 list originated from your unit?

9 A. Yes.

10 MS. LEE: Your Honours, I tender this document as the next public

11 exhibit.

12 MR. IVETIC: I think it should be under seal. No objection. It

13 lists the locations.

14 MS. LEE: Thank you. This should be under seal.

15 JUDGE ORIE: Madam Registrar, the number of this chart would be?

16 THE REGISTRAR: Your Honours, 29017 receives number P1623 under

17 seal.

18 JUDGE ORIE: And is admitted under seal.

19 MS. LEE: Your Honours, I would like to tender all the

20 intercepts, all the documents appearing on this document. However, if I

21 could reserve to do that after the testimony of this witness.

22 JUDGE ORIE: We'll hear from you then. Please proceed.

23 MS. LEE: May I please have 65 ter number 04744 on e-court.

24 Q. Witness, do you recognise this map appearing on your screen

25 before you?

Page 13337

1 A. Yes.

2 Q. And I see several lines presented on this map. Can you tell us

3 what those lines represent?

4 A. First of all, this map is a copy of the working map pertaining to

5 the summer of 1995 and July of that year. The black lines represent the

6 radio relay axes used by the VRS and the VJ to maintain their

7 communications by radio relay.

8 Q. And can you tell us who created this map?

9 A. In a way, I was the person in charge, but several people worked

10 on it as well.

11 Q. Were -- were the people from -- the people who had worked on this

12 map, were they all from your unit?

13 A. They were people, officers from the intelligence department. We

14 were creating this map in early 1998, relying on the information of

15 analyses of intercepted communication from 1995.

16 MS. LEE: Now may we please zoom on the bottom right corner of

17 this map where there is some sort of -- where all the lines are joining.

18 Q. Witness, the lines where all the point -- the location where all

19 the lines are joining, do you recognise this location?

20 A. Yes.

21 Q. And what is that location?

22 A. It is the radio relay hub at Veliki Zep used by the VRS, and they

23 inherited it from the JNA. It was one of the most important

24 communications hubs in Bosnia-Herzegovina.

25 JUDGE FLUEGGE: Can we zoom in a bit further. Thank you.

Page 13338

1 MS. LEE: It's clear. Your Honours, may I tender this map as the

2 next -- as the next Prosecution exhibit?

3 MR. IVETIC: No objection, Your Honours.

4 JUDGE ORIE: Madam Registrar.

5 THE REGISTRAR: Your Honours, 04744 receives number P1624.

6 JUDGE ORIE: And is admitted into evidence.

7 MS. LEE: Yes, as a public exhibit.

8 JUDGE ORIE: As a public exhibit.

9 Please proceed.

10 MS. LEE: Thank you.

11 May I please have 29005 on e-court.

12 Q. Witness, do you recognise this map as the one that you've marked

13 and during your testimony in Tolimir?

14 A. I believe it is.

15 Q. Now, on this map there are triangles. Can you tell us what those

16 triangles represent?

17 A. Well, for you to understand better, I'll mention this: In the

18 former JNA, home forces were red, whereas the enemy was marked in blue.

19 Communications systems were usually marked in black. The triangles

20 represent radio relay stations depending on their function, whether it is

21 the end point or a hub or simply a radio relay station. The symbols used

22 came from the former JNA.

23 Q. And there are numbers contained in some of these triangles.

24 Looking at the one that's in the middle beside the letters V and Z, there

25 are two numbers. There is number 800 and 1 in it. Can you tell us what

Page 13339

1 those numbers represent?

2 A. There should also be SMC included, but the SMC communications

3 system is something we couldn't intercept, so it is mentioned here that

4 from that facility RRU 800 and RRU 1 were used, the devices of the JNA

5 that we could monitor.

6 Q. And right beside this triangle there's -- it says "Panorama 99."

7 What does Panorama 99 represent?

8 A. Panorama 99 in this case means that it was the code-name of that

9 communications hub. Panorama without any digits is the code-name of the

10 General Staff of the VRS.

11 Q. And the triangle beside it it's written Uran, U-r-a-n. What did

12 that represent?

13 A. I mentioned it already in the previous cases. It was the end

14 point radio relay station established for the operations of mopping up

15 Zepa, and it used radio relay equipment 1. At the time we believed that

16 the station had been transferred from Pribicevac when the Srebrenica

17 operation was completed and was taken to the area of Zepa.

18 MS. LEE: Thank you. And now if we could zoom out from the --

19 from the screen a little bit. Thank you.

20 Q. Now, there's a line joining Zlatar, which is on the left top

21 corner of the map, and Panorama that we've just seen, and beside it there

22 are numbers, 785.00 megahertz and 834.250. What do these numbers

23 represent?

24 A. Those numbers are the frequencies at which RRU 800 was used to

25 establish communication between the command of the Drina Corps with their

Page 13340

1 superior command and their subordinate units through the Veliki Zep hub.

2 MS. LEE: Your Honours, I would like to tender this map as the

3 next public exhibit.

4 MR. IVETIC: No objection.

5 JUDGE ORIE: Madam Registrar.

6 THE REGISTRAR: Your Honours, 65 ter 29005 receives number P1625.

7 JUDGE ORIE: And is admitted into evidence.

8 MS. LEE: May I please have 29007 on e-court, and if you could

9 blow it up and then move -- show the right side of the document.

10 Q. Witness, there are two -- there are two circles on the right-hand

11 side. The one on the bottom has Z beside it, and it says "Palma." What

12 does Palma represent?

13 A. This is also from 1995. Palma was the code-name for the

14 Zvornik Brigade.

15 Q. And on top of that there is another triangle with number G beside

16 it, and it says the word Brana 99. What does Brana represent?

17 A. Brana 99 was established for the needs of the Zvornik Brigade.

18 It was at mount -- or Gucevo hill in Serbia. It was a radio relay

19 station, and it was its code sign.

20 Q. And this hub, Gucevo, did it have any particular importance?

21 A. In this case the units from the area of Zvornik and further up

22 north, it was very important from the aspect of establishing radio relay

23 communication. There was an area without any communication between Zepa

24 and Zvornik, so no direct communication could be established between

25 Zvornik and the Veliki Zep hub. The route actually went via Gucevo to

Page 13341

1 Cer, and from Cer directly by SMC to Veliki Zep. Both Cer and Gucevo are

2 in Serbia.

3 Q. And, Witness, you just mentioned the name Cer. Do you see Cer on

4 this map?

5 A. I see it. It is a mountain in Serbia known for the Cer battle

6 from World War I. On the map it is in the upper right-hand side corner.

7 Q. And is that the one with KA and Avali on it?

8 A. Yes. The rest of the letters mean that the route goes on further

9 afield in the direction of Belgrade and the General Staff of the VJ.

10 MS. LEE: Your Honours, I would like to tender this map.

11 MR. IVETIC: No objection.

12 JUDGE ORIE: Madam Registrar.

13 THE REGISTRAR: Your Honours, 65 ter 29007 receives number P1626.

14 JUDGE ORIE: P1626 is admitted.

15 MS. LEE: Your Honours, I understand I'm almost out of time. I

16 have one more document to show the witness.

17 JUDGE ORIE: Please show it to the witness.

18 MS. LEE: May I please have 65 ter number 05300 on e-court.

19 Q. Witness, do you recognise this document as a document that you

20 have seen during -- during your preparation for your examination here

21 today?

22 A. I do recognise it as such.

23 MS. LEE: Can we go to page 2 of this document. And page 3 in

24 the English version of the document.

25 Q. Witness, there are two names appearing on the bottom of the

Page 13345

1 answers are the most direct and truthful answers to those questions. Is

2 that understood, sir?

3 A. Yes.

4 Q. And I also want to tell you if at any time you feel that we need

5 to go into private session for you to fully and truthfully answer one of

6 my questions, that you can you please ask me and I will accommodate your

7 request. Is that understood, sir?

8 A. Yes.

9 Q. And one last thing before we begin with my questions. If at any

10 time one of my questions is unclear to you, sir, I would ask that you

11 bring that matter to my attention and I will try to clarify my question

12 for you. Is that understood, sir?

13 A. Yes.

14 Q. Thank you. Now, before moving to the main part of my

15 examination, I'd like to briefly touch upon a few matters that you've

16 discussed with the Prosecution counsel here today.

17 MR. IVETIC: If we can call up Exhibit P1622 under seal and not

18 broadcast the same.

19 Q. Now, sir, in your direct examination you were asked about this

20 document on the left-hand side of the screen, and you were comparing it

21 in relation to other documents, I believe which were -- that emanated

22 from the MUP and also from the other station. And you indicated, I

23 believe, that this station because of its proximity was able to identify

24 both speakers, and here we see that the entry in question lists the

25 participants as Colonel Cerovic and General Krstic, but there's a

Page 13346

1 notations "Could not be heard."

2 So I wanted to ask you, sir: How is it that the ABiH

3 surveillance units were able to identify General Krstic as a participant

4 in this conversation if, in fact, they could not hear him?

5 A. It is stated here "Could not be heard," but still they have their

6 assumption.

7 Q. That part I understood, sir. And I don't understand your

8 testimony of how they were able to identify General Krstic if he could

9 not be heard, and I'm asking you: How were the operatives able to

10 identify General Krstic as a participant in this conversation if he

11 cannot be heard and there's not a single word that's emanating from him

12 in this conversation? Please explain that.

13 A. This is a supposition based on the rest of the conversation. You

14 should better put this question to the young man signed below. This is

15 not based on one conversation. This was a process that lasted three

16 years. People were so well-versed in these things that they had many

17 different ways of getting a very good idea. But it is stated here "Could

18 not be heard," and in our analysis we do not take it into account. But

19 since this concerns Colonel Cerovic and the particular problems they are

20 dealing with, this is an assumption that should be taken into account.

21 Q. Thank you, sir, and I understand it was a process over three

22 years and as you testified in direct, people got used to voice

23 modulations and mannerisms of speaking. And I'm asking you: How does

24 that take into account --

25 JUDGE ORIE: Mr. Ivetic, if you'd just put your questions so as

Page 13347

1 that it doesn't hurt our ears at this moment.

2 Witness, if you can't hear someone and therefore the text of the

3 words spoken does not appear, how could you possibly then identify a

4 person? Because you can't put it in the context if you do not know what

5 he says, isn't it?

6 THE WITNESS: [Interpretation] No.

7 JUDGE ORIE: Pleased proceed, Mr. Ivetic.

8 MR. IVETIC:

9 Q. And so now I want to ask you, sir, what is the bases for this

10 document being generated and identifying General Krstic as a participant

11 in the conversation?

12 A. I've already said that the identity of General Krstic is not

13 established here; it is assumed, supposed.

14 JUDGE ORIE: Mr. Ivetic, the point you apparently want to make is

15 perfectly clear to the Chamber.

16 MR. IVETIC: Thank you.

17 If we can have P1625 up on the screen, and I believe it's a

18 public exhibit, so that it may be broadcast.

19 Q. Sir, this is a map. Now if we could zoom in, it's one version.

20 Sir, this is a map that you were asked about in your direct

21 examination, and you testified, I believe, that the numbers followed by

22 the symbol MHz, or megahertz, were frequencies that were utilised on

23 these communications axes. And the one thing I want to ask you, sir, is

24 first of all: Who generated this map?

25 A. It was generated by a team from the intelligence department