Tribunal Criminal Tribunal for the Former Yugoslavia

Page 35161

 1                           Wednesday, 6 May 2015

 2                           [Open session]

 3                           [The accused not present]

 4                           --- Upon commencing at 9.38 a.m.

 5             JUDGE MOLOTO:  Good morning to everybody in and around the

 6     courtroom.

 7             Mr. Registrar, can you please call the case.

 8             THE REGISTRAR:  Thank you.  And good morning, Your Honours.  This

 9     is case IT-09-92-T, the Prosecutor versus Ratko Mladic.

10             JUDGE MOLOTO:  Thank you so much.  Before we start, I just want

11     to place on record our apology for late starting.  It was due to

12     unforeseen and urgent personal matters for one of the Judges.  I hope we

13     can make up the time.

14             I'm told that the Prosecution has a preliminary matter to raise.

15     And before you do so, Madam Hasan, just to place on record also that due

16     to urgent personal matters Judge Orie is not sitting with us today, as he

17     mentioned yesterday.  And therefore Judge Fluegge and I have decided to

18     sit pursuant to Rule 15 bis of Rules of Procedure and Evidence.

19             Thank you, Madam Hasan.

20             MS. HASAN:  Good morning, Your Honours.  Good morning, everyone.

21     Yesterday during the cross-examination I raised the testimony of

22     Dragomir Keserovic and this is at transcript pages 351543 -- sorry, 35153

23     to 35154.  And after raising this with the witness, I made a comment and

24     I said:

25             "Keserovic says that this order was made on the evening of the

Page 35162

 1     16th of July."

 2             After which I immediately moved to another topic with another

 3     question.  And I wanted to clarify that comment I made because, in fact,

 4     Keserovic says in his testimony in this case that he received the

 5     verbal -- that he arrived at Crna Rijeka and the night of the 16th, he is

 6     certain of that, but that he may have received the order either that

 7     evening or the following evening.  And it is rather through his testimony

 8     documents and other witness testimony that it's our position that the

 9     order was received on the evening of 16 July.

10             So rather than saying, "Keserovic says," I should have been more

11     precise and accurate and said, "It's our position that Keserovic received

12     the order on the 16th of July."

13             JUDGE MOLOTO:  Thank you very much, Madam Hasan, for that

14     explanation.  It's on the record.  Do you feel there's any need for you

15     to correct that position with respect to the witness once he comes in?

16             MS. HASAN:  It didn't affect the questions that I asked as far as

17     my assessment -- as far as I assessed the transcript so I --

18             JUDGE MOLOTO:  And you said immediately thereafter you moved on

19     to another topic.

20             MS. HASAN:  Yes.

21             JUDGE MOLOTO:  Apparently the witness didn't comment on your

22     statement.

23             MS. HASAN:  No, not on that comment that I made.

24             JUDGE MOLOTO:  Okay, thank you so much.  Then it's on the record.

25             MS. HASAN:  Just one other minor matter.  The Defence had

Page 35163

 1     tendered into evidence D1046.  You will recall that's the 17 July order

 2     issued by General Mladic and I had raised that this was already in

 3     evidence as P1579 and we've -- both the Defence and Prosecution has taken

 4     a look at the documents and agree that it is the same document.  So we'd

 5     request that we just maintain the P1579 and it might be appropriate to

 6     vacate D1046.

 7             JUDGE MOLOTO:  Does the Defence confirm that?  Mr. Stojanovic.

 8             MR. STOJANOVIC: [Interpretation] That's right, Your Honour.

 9     Before we started this morning, we agreed that D1046 be left free and

10     that the document that we used remains under the number under which it

11     had already been used in evidence in this trial.  Our colleague told us

12     about this correction in relation to Keserovic, and we are not going to

13     deal with the matter further in our re-direct.  And I would like to thank

14     you her for her attitude.

15             JUDGE MOLOTO:  Thank you so much, Mr. Stojanovic.

16             Then the Court will then vacate D1046, and, Mr. Registrar, you

17     are asked to please vacate that number and reserve it for the next

18     Defence Exhibit and then that document will then stay in the record as

19     P1579.

20             Madam Hasan, are you ready to continue with your

21     cross-examination once the witness is in?

22             MS. HASAN:  Yes, I am.

23             JUDGE MOLOTO:  Thank you so much.  May the witness please be

24     brought in.

25                           [Trial Chamber and Registrar confer]

Page 35164

 1                           [Trial Chamber confers]

 2             JUDGE MOLOTO:  While we're waiting for the witness, I just want

 3     the record to show that the accused is not with us today as a result of

 4     an order that was made yesterday afternoon just before we adjourned for

 5     the day.

 6                           [The witness takes the stand]

 7             JUDGE MOLOTO:  Good morning, Mr. Trkulja.

 8             THE WITNESS: [Interpretation] Good morning.

 9             JUDGE MOLOTO:  Just to remind you that you're still bound by the

10     oath, the declaration you made at the beginning of your testimony to tell

11     the truth, the whole truth and nothing else but the truth.  Understand

12     that?

13             THE WITNESS: [Interpretation] Very well, I understand that.

14             JUDGE MOLOTO:  Thank you so much.  Madam Hasan will proceed with

15     her cross-examination.

16             Thank you, Madam Hasan.

17                           WITNESS:  NEDELJKO TRKULJA [Resumed]

18                           [Witness answered through interpreter]

19                           Cross-examination by Ms. Hasan: [Continued]

20        Q.   Good morning, Mr. Trkulja.

21        A.   Good morning.

22        Q.   You testified yesterday, both in direct and cross-examination,

23     that when you had arrived in Zvornik in the area of Baljkovica that there

24     had not been a break through, that the front line had not broken through,

25     that Obrenovic had told you there had been fighting at the front of

Page 35165

 1     Crni Vrh but that he managed to push back the enemy.  And I'm referring

 2     to transcript pages 35100 and 35103.  And that it was the following day,

 3     so you arrive on the 17th, and on the 18th, that is when the column, the

 4     Muslims who you say were in a ditch, were passing through.  And at

 5     transcript 35144, lines 6 to 9, you testified you had no idea there was a

 6     column, no idea, and then you later told us that Sladojevic was wrong

 7     when he said he knew before, when he left Crna Rijeka, that the Muslims

 8     had broken through the lines.

 9             And I'd like to take you to a 15 July 1995 interim combat report

10     from the Drina Corps.

11             MS. HASAN:  And this is 65 ter 4137.  If we could have that

12     displayed.

13        Q.   And you will see that this is a report from Krstic ...

14             MS. HASAN:  And if we turn briefly in the English to the second

15     page so we can see the stamp.  The document was received at 1945 hours

16     and processed at 2010 hours.  Now, this interim combat report - and we

17     can revert back to page 1 in the English - is to the Main Staff.

18        Q.   And I'm just going to read to you just the second paragraph:

19             "At about 0440 hours on 15 July ... the enemy started a heavy

20     artillery attack on the 4th, 6th and 7th Infantry Battalion line of

21     defence.

22             "The attack was carried out at about 0530 hours, but the enemy

23     continued with short intervals of artillery and infantry fire.  Three

24     soldiers were wounded in these attacks."

25             I'm going to skip down to the next paragraph:

Page 35166

 1             "During the transport towards Zvornik, the Turkish forces pulling

 2     out from Srebrenica towards Tuzla in the Planinica village sector opened

 3     fire on an ambulance and killed the driver Milos Tesic and paramedic

 4     Nenad Stevic."

 5             It goes on in the last major paragraph there:

 6             "The units are carrying out the blockade and destruction of

 7     Muslim forces which are pulling out of Srebrenica towards Tuzla."

 8             Now you were at the Main Staff on the evening of the 15th of

 9     July, weren't you?

10        A.   Yes.

11        Q.   So you would have received and reviewed this report that came in

12     from General Krstic.

13        A.   Yes.

14        Q.   So, in fact, on the night of the 15th, you were aware that there

15     was -- there were Muslim forces moving in the direction of Tuzla; isn't

16     that right?

17        A.   Yes.

18        Q.   And contrary to what you had said, which was nobody was blocking,

19     nobody forbid the Muslim formations to exit in the direction of Tuzla,

20     which you said at transcript page 35156 to -- line 25, to 35157, line 2,

21     in fact, the forces -- the Muslim forces were not free to pass to

22     Bosnian-held territory.  As Krstic says, they were blocking them and

23     destroying them; isn't that right?

24        A.   Madam Prosecutor, that is put in very general terms.  First of

25     all, these were groups.  It wasn't one axis.  I gave my statement only

Page 35167

 1     about the axis towards Crni Vrh because I'm not aware of any others.  I

 2     don't know them.

 3             Secondly, all of what I said pertained to that group that was

 4     moving towards Crni Vrh where I was present.

 5        Q.   I think what you testified to before is clear so let's move on.

 6             MS. HASAN:  I'd offer 65 ter 04137 into evidence.  04137.

 7             JUDGE MOLOTO:  04137 is admitted into evidence.  May it please be

 8     given an exhibit number, Mr. Registrar.

 9             THE REGISTRAR:  That will be Exhibit P7370, Your Honours.

10             JUDGE MOLOTO:  Thank you.

11             MS. HASAN:  All right.  So I'm going to turn now to 65 ter 04040.

12        Q.   And what this is, is the Main Staff report that's dated the

13     15th of July that went to the president of Republika Srpska, amongst

14     others.  So we're still on the same night, the night of the 15th.

15             MS. HASAN:  And if I could ask that we turn to page 4 in the

16     English and B/C/S, please.

17        Q.   You drafted this report; right?

18        A.   Yes.

19        Q.   Now, if we turn to page 3 in the English and the B/C/S, under

20     item 6 in the zone of the Drina Corps, a, where there's a summary of the

21     enemy, and midway through the paragraph, and this is your drafting, you

22     say:

23             "Their objective is to" -- sorry, I'll start a bit earlier.

24             "The remainder of the scattered Muslim formations from the former

25     Srebrenica enclave are moving towards Kravica and Konjevic Polje.  Their

Page 35168

 1     objective is to continue breaking through to Mount Udrc and from there to

 2     Tuzla and Zivinice.  During the course of today's day, several enemy

 3     groups have surrendered to VRS members.  In the zone of the Zvornik pbr,

 4     around 0440 hours, the enemy launched a strong artillery attack on the

 5     defence line of the 4th, 6th and 7th Infantry Battalion.  The attack

 6     ended around 0530 hours, but the enemy continued opening artillery and

 7     small-arms fire at short intervals."

 8             And then you go on to talk about Turkish troops pulling out from

 9     Srebrenica towards Tuzla opening fire on an ambulance in the Planinica

10     village sector, killing the driver of a vehicle and a paramedic.

11             This is the information that you got from Krstic's report we just

12     looked at; right?

13        A.   Yes.

14        Q.   And under "Situation in the corps," item b, you go on to say:

15             "The 1st Zvornik pbr with its reinforcements is carrying out

16     preparations to cut off and encircle enemy soldiers en route from

17     Planinica to Krizevici."

18             Just under "Situation on the territory," Roman numeral II:

19             "The Vlasenica-Zvornik road is unsafe due to the enemy groups

20     from Srebrenica which are trying to breakthrough to Tuzla."

21             So you were reporting to the president and to -- for the

22     information as well, of all the other units listed on this document of

23     what was going on, of the movement of the Muslim forms towards Tuzla,

24     towards Crni Vrh, Mount Udrc and the breakthrough that was expected to

25     take place that -- that you had understood they were attempting to do.

Page 35169

 1     Correct?

 2        A.   Well, it was from the report.  I just summarised what had was

 3     contained in the report.  Now it is the assessment of the corps

 4     commander.

 5        Q.   Yes, and you understood that this was his assessment?

 6        A.   Yes, yes.  His assessment.  Couldn't be mine.

 7             MS. HASAN:  I'd offer 65 ter 04040 into evidence.

 8             JUDGE MOLOTO:  04040 is admitted into evidence.  May it please be

 9     given an exhibit number.

10             THE REGISTRAR:  Exhibit P7371, Your Honours.

11             JUDGE MOLOTO:  Thank you.

12             MS. HASAN:

13        Q.   Now, moving on to 16th July, and I'm still addressing the

14     comment -- the testimony you gave yesterday that you had no idea what was

15     going on when you left for Zvornik and that you didn't know there was a

16     column and that there was no breakthrough.  Now you will recall that

17     Defence counsel showed you a report that -- the interim combat report

18     from Pandurevic that was dated the 16th of July.  This is P1513.  You

19     recall that report?

20        A.   I first saw and read that report in 2007 when the gentleman

21     there, the Prosecutor, showed it to me.  Until then, I hadn't seen it.

22             JUDGE MOLOTO:  So you do recall the report, don't you?

23             THE WITNESS: [Interpretation] I recall the report but I'm telling

24     when it was that I first saw it.

25             JUDGE MOLOTO:  Thank you.  That was the question:  Do you recall

Page 35170

 1     the report?  "Yes" is a sufficient answer to the question.

 2             MS. HASAN:

 3        Q.   And this is the report that you said never reached you at the

 4     Main Staff, and this is at transcript page 35087, starting at line 10.

 5             MS. HASAN:  And just to refresh everyone's recollection, if we

 6     could pull up that document, P1513.

 7             And Mr. Stojanovic did read parts of this document.  So just as a

 8     reminder, it talks about the enemy has continued intensive attacks on the

 9     brigade's area along the entire front line with particular intensity in

10     the defence area of the 7th, 4th, 6th, and 3rd Infantry Battalion.

11             He goes on to describe that forces, Muslim forces, "fired almost

12     1.000 projectiles of varying calibre and that parts of Srebrenica 28th

13     Infantry Battalion, together with previously infiltrated groups, carried

14     out a synchronized Kamikaze attack against the 4th pb, our positions,

15     weapons, and other equipment from the Planinci and Potocari areas, using

16     their numerical advantage, they surrounded the 4th pb.  Counting soldiers

17     and civilians, armed and unarmed, all together 7.000."

18             Then he goes on to describe and I believe also Mr. Stojanovic

19     read this part about them capturing the 76-millimetre self-propelled guns

20     and seizing three of the VRS's trenches.  And he reports:

21             "The brigade's problem is that part of our forces is surrounded

22     in the Baljkovica area.  The enemy has suffered major losses, hundreds of

23     dead, but that has not prevented them from carrying out their

24     intentions."

25             And at the very last paragraph -- sorry, under item 3, this is

Page 35171

 1     where Pandurevic provides a justification for opening a corridor, and he

 2     says:

 3             "In view of the great pressure on the brigade's area of

 4     responsibility, the losses sustained, the inability of the surrounded

 5     forces to hold out for long, the abandonment of the Zvornik pbr command

 6     to deal as best ... it could with the Srebrenica Turks, coupled with the

 7     absolute determination of the Turks to save at least some lives,

 8     regardless of the losses and in order to prevent losses in our own ranks,

 9     I have decided, in view of the situation, to open a corridor ..."

10        Q.   Now I'm going to go to D1045.  And, Mr. Trkulja, this is -- this

11     is a report you were also shown and it's the 16th July report that was

12     sent to the president of the RS, among others, and we examined this

13     report as well during your direct examination.  And you testified that

14     you drafted this report and it bears your initials at the end of it, NT.

15             MS. HASAN:  And I'd like it turn to page 4 in the English and 3

16     in the B/C/S.

17        Q.   Under number 6 where there's a report on the Drina Corps zone of

18     responsibility, item a, this is your drafting, sir:

19             "On the Tuzla-Zvornik axis, the enemy regrouped large forces in

20     front of the 1st Zvornik pbr and used them early in the morning in a

21     strong artillery and infantry attack on our units' sector along the

22     Baljkovica-Rijeka-Pandurici axis.  They were co-ordinating with ...

23     forces pulling out from the former Srebrenica enclave.  They were able to

24     breakthrough the defence and capture three trenches in the Baljkovica

25     village sector, create a corridor for the pullout of civilian population,

Page 35172

 1     which was used by about 7.000 mainly unarmed civilians (men, women,

 2     children).  During this attack, the enemy attacked our units from behind

 3     the lines, irrespective of own losses.  Thus they captured three

 4     self-propelled guns by bodies - losing hundreds of soldiers.  We are

 5     currently negotiating with the Muslims with regard to freeing the

 6     captured policemen and Zvornik Battalion members and the duration of the

 7     corridor."

 8             Now --

 9             JUDGE FLUEGGE:  Ms. Hasan, it is really Zvornik Battalion or

10     Zvornik Brigade?

11             MS. HASAN:  Brigade, I'm sorry.  Brigade.

12             JUDGE FLUEGGE:  Thank you.

13             MS. HASAN:  I'm sorry.

14        Q.   Now, by the time you sat down to draft this report on the night

15     of the 16th of July, and this is before you leave to Baljkovica, you had

16     already received the information contained in Vinko Pandurevic's report.

17     You had received that from the Drina Corps, and this is why it appears

18     here in this report to the president?

19        A.   Partly, yes, because I went towards Crni Vrh and everything I

20     spoke about pertains to Crni Vrh.  Had there been more groups, more axes

21     or breakthrough, there were.  But I didn't explain any other axis.  I was

22     not present.  I don't know.  That can only be concluded on the basis of

23     the report.  I spoke about the place where I was myself, and that is

24     Crni Vrh.

25        Q.   Well, sir, let's get the story straight because you testified

Page 35173

 1     yesterday that you were present at the Main Staff on the 16th of July in

 2     Crna Rijeka and that you only left to Zvornik on the 17th of July.  This

 3     report you drafted on the night of the 16th.  So are you telling us that

 4     you were in the field on the 16th of July as well?

 5        A.   No.  I was not in the field.  I went on a field mission in the

 6     morning, on the 17th.

 7        Q.   So when you just testify, "yes, because I went towards Crni Vrh

 8     and everything I spoke about pertains to Crni Vrh," well, you hadn't gone

 9     to Crni Vrh yet to include this information in this report.  That only

10     happened after you drafted this report.

11        A.   That happened one day after this report.

12        Q.   So the information that we see here in this report that's

13     drafted -- you drafted the night of the 16th, is information you received

14     from the Drina Corps and it is based on the information provided by

15     Vinko Pandurevic in his interim combat report dated the 16th of July?

16        A.   What was used was the Drina Corps report.  I never saw

17     Pandurevic's report at the command post.  I first saw it when I arrived

18     here.

19        Q.   So --

20             JUDGE MOLOTO:  The issue really is that this report does not

21     contain any observations you may have made in Crni Vrh on the 17th,

22     because the report was written before the 17th, irrespective of whether

23     you -- the report is from the Drina Corps or from Pandurevic's report.

24             THE WITNESS: [Interpretation] Very well.  That's precisely the

25     case.  We did not have any information as to what was going on at

Page 35174

 1     Crni Vrh.

 2             JUDGE MOLOTO:  Thank you so much.

 3             MS. HASAN:

 4        Q.   And, Mr. Trkulja, to be very clear, the Drina -- you had seen a

 5     report from the Drina Corps which included the information that is

 6     provided in your report that you drafted to the president and which

 7     reflects the information Vinko Pandurevic provided in his interim combat

 8     report?

 9        A.   Yes.

10                           [Prosecution counsel confer]

11                           [Trial Chamber and Registrar confer]

12             JUDGE MOLOTO:  Madam Hasan ...

13                           [Trial Chamber and Legal Officer confer]

14             JUDGE MOLOTO:  Madam Hasan, how much more do you still need?

15     You've reached the end of your time.

16             MS. HASAN:  I'm sorry, I did not hear you very well.  I don't

17     think your microphone was on.

18             JUDGE MOLOTO:  I said, according to the Registrar, you have

19     reached the end of your time.  How much more time do you need?

20             MS. HASAN:  Your Honour, I actually do think I will need

21     20 minutes.

22             JUDGE MOLOTO:  Okay.  Try to squeeze it into 20 minutes.

23             MS. HASAN:

24        Q.   Very quickly, if we can -- given that you keep mentioning

25     Crni Vrh, if we could look at P1087.  This is the Srebrenica map book.

Page 35175

 1             MS. HASAN:  And if I could ask for the ERN page that ends 7949,

 2     please.  Page 19 in e-court.

 3        Q.   And you will see on the right border there --

 4             MS. HASAN:  I mean, if we could just zoom into the centre portion

 5     of this map.

 6        Q.   You see there's Karakaj and if we just there, by that red and

 7     black line, the border there.  And if we take a look at -- you see

 8     Zvornik there towards the bottom of the screen.

 9             MS. HASAN:  And if we go to the left, take a look at the left of

10     that map, okay, and scroll a little bit up.  That's fine.

11        Q.   You see those arrows, that's the movement of the Muslim

12     formations.  And just under the date there, 16 July 1995, Mr. Trkulja, do

13     you see Planinci that we keep referring to?  Do you see that there?

14        A.   I do.

15        Q.   And you see just to the left of that, where it says "Crni Vrh"?

16        A.   Yes.

17        Q.   So, in fact, Crni Vrh is just along where the Muslim formations

18     are moving near to -- to the lines there.  That's the -- that's the axis

19     of movement.

20             JUDGE FLUEGGE:  What is your question?

21             MS. HASAN:

22        Q.   Do you agree, Mr. Trkulja, that your references to Crni Vrh

23     are -- in fact Crni Vrh falls just along the line, the movement of the

24     Muslim formations and their movement up towards the front lines?

25        A.   Madam Prosecutor, the line that depicts the movement of Muslim

Page 35176

 1     forces is an imaginary line.  It was just a forecast.  One of the groups,

 2     possibly the biggest group, was actually moving towards Crni Vrh and not

 3     in the direction pointed by the arrow.

 4        Q.   Let's move on to other things, Mr. Trkulja.

 5             Now, you testified that -- at transcript page 35150, lines 1 to

 6     6, that when you arrived in Baljkovica on 17th of July, that the Muslims

 7     were in a ditch and that it was only on the 18th of July that they passed

 8     through by agreement.  You recall your testimony?

 9        A.   I do.  It is the truth, and there's no two ways around it.

10             MS. HASAN:  So let's look at P724, please.  This is a report

11     submitted by Ljubisa Borovcanin and it's dated 5 September 1995.  And he

12     reports on the combat engagement of the special police brigade and other

13     police forces in Operation Srebrenica 95 in the period from 11 to

14     21 July 1995.

15             And if we turn to page 4 in the English and B/C/S, please, he

16     provides an account of what happened on the 16th of July.  And he says:

17             "Today, there was fierce fighting with the Muslim forces in the

18     areas of Krizevici, Tisova Kosa, and Baljkovica.  The Muslim attack" --

19     and he goes on to say:

20             "The Muslim attack was very fierce and was backed by artillery

21     from Nezuk.  In the morning, the enemy captured 57-millimetre

22     self-propelled guns from members of the Army of Republika Srpska which

23     protected the left flank of the MUP forces.  Because of this, the

24     situation changed dramatically.  From a distance of 400 to 500 metres,

25     these self-propelled guns directly pounded our hardware, vehicles,

Page 35177

 1     ambulances, and the communications centre."

 2             And then he goes on to say:

 3             "There was danger that our forces would be completely cut off and

 4     surrounded."

 5             And the last sentence:

 6             "The Army of Republika Srpska had about 40 killed and more than

 7     80 wounded.  It was not possible to establish the exact number

 8     immediately.

 9             "At about 1500 hours" -- if we can turn now to page 5 in the

10     B/C/S:

11             "The bulk of the enemy column (about 2.500 soldiers) managed to

12     breakthrough to Nezuk."

13             If we turn to page 5 in the English, Borovcanin continues to say

14     that:

15             "At 1300 hours," and this is the 16th of July, "the commander of

16     the Zvornik Brigade, Vinko Pandurevic, and the commander of the Muslim

17     side, Semso Muminovic, agreed to open a 1-kilometre wide corridor in the

18     areas of Parlog and Baljkovica to allow all the Muslim soldiers to get

19     out."

20        Q.   You see that there?  Now --

21        A.   I don't have a map before me.

22        Q.   I don't think there's a need for a map at this point in time.

23     Now, so when you arrived on the 17th of July, what Borovcanin reports

24     here had already transpired the day before; right?

25        A.   It is possible, but on a different axis.  Not on the one where I

Page 35178

 1     was.  Baljkovica is not even close.

 2        Q.   Now, this is exactly -- Borovcanin is reporting what Pandurevic

 3     had also reported in his interim combat report.  And if we look, sir, to

 4     17th of July, Borovcanin says that:

 5             "In co-ordination with the intervention units of the Zvornik

 6     Brigade, the 5th Special Police Detachment closed the line in Baljkovica

 7     and combed the area towards Crni Vrh."

 8             So you had told us that you arrived on the 17th and that on the

 9     18th the corridor was opened and it was closed on the 18th and then you

10     left back to -- to Crna Rijeka.  Well, in fact, sir, you arrived on the

11     17th and then that is when the -- the corridor had already been opened

12     the day before, and it was on the 17th of July, the day that you arrived,

13     that it was closed.  So you've got your chronology wrong.  Isn't that the

14     case?

15        A.   It is not the case.  My chronology is absolutely correct.  You

16     found a report where the duty officer recorded when I arrived Zvornik,

17     when I left, and I told you exactly who was present.  I told you that at

18     10.00 on the 18th, they started withdrawing, and that's correct.

19             And now, for the fact that some people are lost in time and

20     space, well, that's their problem.

21        Q.   And, sir, the day -- and let's leave aside the date.  But the day

22     that you watched -- that you were present when the corridor was closed,

23     Vinko Pandurevic was with you.  Isn't that the case?

24        A.   Yes.  I saw him in the morning on the 18th when Muslim forces

25     were supposed to start withdrawing.  There were a lot of officers in the

Page 35179

 1     evening as well but I can't remember that he was there.  My memory

 2     doesn't serve me well in that respect.  On the 17th, he was there and he

 3     issued an order in that part of the front line.  The Zvornik Brigade had

 4     a huge front line, some 20 or 30 kilometres long.  The road between

 5     Zvornik and Vlasenica was not safe.  So there were all sorts of

 6     possibilities.  I'm just telling you that in my statement everything is

 7     about what was going around Crni Vrh.  There were no MUP forces there is

 8     at all.

 9             JUDGE MOLOTO:  Mr. Trkulja, could you please slow down when you

10     speak because the interpreters are desperately trying to keep pace with

11     you.

12             THE WITNESS: [Interpretation] Thank you.

13             MS. HASAN:

14        Q.   Now, surely Pandurevic must have briefed you on what happened.

15     And you've told what you say Obrenovic had told you -- told you.  But

16     what did Pandurevic tell you?

17        A.   Pandurevic didn't tell me a thing.  I saw him in the morning.  We

18     greeted each other.  And we allowed the events to take their course, as

19     had been agreed.

20             JUDGE MOLOTO:  Madam Hasan, I note the time.

21             MS. HASAN:  Yes, Your Honour.  I will have a few more questions

22     after the break, if you will allow.

23                           [Trial Chamber confers]

24             JUDGE MOLOTO:  My colleague has just reminded me that Mr. Mladic

25     is not here, so we can go for another 30 minutes before we take the

Page 35180

 1     break.

 2             MS. HASAN:  Thank you.

 3        Q.   So, Witness, you are there to -- with two other colonels from the

 4     Main Staff, Sladojevic and Stankovic.  And you do not receive any

 5     information from Pandurevic about what is happening there?  You're sent

 6     by the Main Staff and you don't inquire about a corridor that was opened

 7     which you knew about?

 8        A.   A correction.  Colonel Stankovic was not with me.  There was a

 9     major whose name I can't remember, a member of the Drina Corps.  I didn't

10     know what the situation at Crni Vrh was.  Not even the duty officer with

11     whom the major had spoken knew.  If he had known, if somebody had told

12     us, we would have never gone there.

13        Q.   Sir, now, you had said that you were sent off with Sladojevic and

14     Stankovic, and the order that we saw from the 17th of July --

15        A.   Whom?

16        Q.   Sladojevic, Bogdan Sladojevic.  And Stankovic, Milovan Stankovic.

17     He was the chief of reconnaissance, sabotage in the intelligence

18     administration of the Main Staff.

19        A.   No.  He was there, as a matter of fact, but he didn't go with us.

20     You can read that in the telegram.  But he never joined us.  He didn't go

21     with us because we never complied with that telegram.  I went with

22     Sladojevic and with the major that I mentioned, the one from the

23     Drina Corps.

24             MS. HASAN:  Let's look at 65 ter 26085, please.  And this is the

25     OTP's interview of Sladojevic some 15 years ago in October 2000.  And he

Page 35181

 1     describes what Pandurevic said.  If we could get page 4 in the B/C/S.

 2     It's around line 24.  And the same page in the English.

 3             JUDGE MOLOTO:  While we're looking for the page, can you repeat

 4     the number of the 65 ter number, please.

 5             MS. HASAN:  Yes, Your Honour, 26085.

 6             JUDGE MOLOTO:  Thank you so much.

 7             MS. HASAN:  Okay.  Can we turn one page in the English, please.

 8     Okay.

 9        Q.   So he says and you can see it in the -- in your language at

10     line -- around line 24.  In the English we're looking at approximately

11     line 8.  So he says -- I'll just start a bit higher.  He asked:

12             "Where is the commander, what's going on here?  The commander

13     came maybe five minutes later, he didn't introduce himself but I drew a

14     conclusion that that was Lieutenant-Colonel Vinko Pandurevic.  And he

15     just briefly showed on which position Muslim artillery fired the day

16     before."

17             MS. HASAN:  If we could turn now the B/C/S page.

18        Q.   He goes on to say:

19             "There was a kind of an orchard with plum trees and the forest

20     and everything was scratched there.  They said that they attacked from

21     the front and also from the rear and that lasted for about two hours.  It

22     all happened the day before.  He said that he had 49 dead, 68 seriously

23     wounded.  I know that approximately he said that 120 of his people were

24     incapacitated.  20 minutes later, Lieutenant-Colonel Obrenovic came who

25     was at the time [sic] I think Chief of Staff.  When he came, he showed --

Page 35182

 1     he pointed at the self-propelled gun where these people form the column

 2     confiscated their machine-gun and their gun inflicted losses.  The column

 3     went towards Kladanj and Kalesija.  Vinko said that he managed to get in

 4     touch with the Muslim commander, he had contact -- that they exchanged

 5     the dead bodies and Stankovic asked him if he had any indication there

 6     will be another attack, attempt to take over Zvornik.  He said that there

 7     were no indications."

 8             And he goes on.

 9             Now, sir, that's indeed what Pandurevic and Obrenovic reported to

10     you that day, on the 17th of July?

11        A.   The late Mr. Sladojevic's statement is completely incorrect.  He

12     just got lost in time and space.  On the 17th, in the evening, it was

13     Obrenovic who reported to us.  He showed us the lines and everything

14     else.  He explained what had been agreed with regard to opening the front

15     line.  If he didn't speak to him privately, not officially, while we were

16     waiting for Muslim forces to pass through, there was nothing official.

17     There was no official report.  The military part was nothing that

18     Pandurevic did on the 18th in the morning.  Pandurevic was merely present

19     there.  Now, as to whether he had a private chat with Sladojevic, I don't

20     know.  I was the leader of that group, and if there was anything

21     relevant, he would have spoken to me.

22             Secondly, Obrenovic did not know whether there were casualties or

23     how many.  I mean, he didn't know that in the evening on the 17th.  At

24     10.00 they started coming out.  You can read that everywhere.  And now he

25     mentions a totally different time.  That's why I say that he was lost in

Page 35183

 1     time and space.  They started leaving on the 10th, they finished at

 2     12.00, and then we left.  And yesterday we spoke about the sanitisation

 3     process, but that is a matter for the organs of the rear, not the

 4     Main Staff.

 5        Q.   Mr. Trkulja, do you know of any other incident during the Bosnian

 6     war where VRS sustained the number of casualties referred to here in such

 7     a short period of time?  Are you aware of any such instance?

 8        A.   There was several.  On Ozren, on Majevica.

 9        Q.   But you would agree, Mr. Trkulja, that the number -- these --

10     these figures were significant losses for the Zvornik Brigade?

11        A.   Yes.

12        Q.   You accepted, didn't you, that it was military necessity that

13     drove Vinko Pandurevic to withdraw and to reach an agreement with the

14     Muslims so that he could save the lives of his soldiers?

15        A.   The same question was put last time.  But I don't agree with

16     that.  They were there with three tanks.  Our late Sladojevic forgot to

17     say that.  They used three tanks to push the Muslim forces to the ditch.

18     Pandurevic, had he wanted to destroy them, he would have done that within

19     two hours and nobody would have survived.  They didn't have the

20     anti-armour resources to defend themselves.  They were sitting ducks, if

21     you will.  Pandurevic decided to painlessly deal with the situation, to

22     let them leave, and he got two platoons from the positions on the 17th in

23     the evening.  All of this is incorrect.  All of this you have here is

24     incorrect.  On the 17th in the evening, he ordered those two platoons to

25     do that and they left.  That's the truth.  You see, 700 is mentioned and

Page 35184

 1     that's when we had breakfast at the monastery.  I didn't want to offend

 2     anyone, but I did say that he was lost in time and space.  And then --

 3             THE INTERPRETER:  Interpreter's note:  We did not understand the

 4     last sentence.

 5             JUDGE MOLOTO:  The interpreters didn't hear the last sentence,

 6     sir.  Can you mention the last sentence.

 7             THE WITNESS: [Interpretation] We started getting out at 10.00.

 8     It all ended at 12 and we left.  I mean, I and my team.  I and ...

 9             JUDGE MOLOTO:  Madam Hasan, please control your witness to keep

10     it to the tight schedule.  You have gone beyond your 20 minutes.

11             MS. HASAN:  I'll just end with one final question, if I may,

12     Your Honour.

13        Q.   When you returned to Crna Rijeka, you reported to Miletic, you

14     said.  What did you tell him?

15        A.   I just told him everything I said to you just now.  The journey

16     to Srebrenica, they weren't there, they went around in a circle, then

17     went to see the duty officer and --

18        Q.   I'm interested in what you reported to him in response to your --

19     the mission that you were sent on, what did you tell him about that?  Not

20     about your excursion to Srebrenica.

21        A.   About that task, actually it turned out completely different

22     since the Muslim forces had passed through -- actually, that the front

23     line was re-established.  I mean, I described to him what happened.

24             MS. HASAN:  I have nothing further, Your Honour.

25             JUDGE MOLOTO:  Thank you very much, Madam Hasan.  This may be an

Page 35185

 1     appropriate time to take the break.

 2             Sir, we'll take a break of 30 minutes.  Could you please be back

 3     in court at quarter past 11.00.

 4             MR. STOJANOVIC: [Interpretation] Your Honour, since I won't have

 5     any questions for Colonel Trkulja and if the Trial Chamber will not have

 6     any questions, perhaps this would be the right moment to thank

 7     Colonel Trkulja.  If you have questions, of course, it's an entirely

 8     different matter.

 9             JUDGE MOLOTO:  Thank you very much, Mr. Stojanovic, for

10     mentioning that.

11                           [Trial Chamber confers]

12             JUDGE MOLOTO:  Mr. Trkulja, Mr. Stojanovic just indicated that he

13     has no further questions to you.  The Bench also hasn't got any further

14     questions for you so this brings us to the end of your testimony.  I take

15     this opportunity to thank you for coming all the way to come and testify

16     and answer all the questions put to you by both parties and the Bench.

17     You are now excused.  You may follow the usher.  Travel well back home.

18             THE WITNESS: [Interpretation] Thank you.

19             JUDGE MOLOTO:  Thank you so much.

20                           [The witness withdrew]

21             JUDGE MOLOTO:  We'll take a break and come back at quarter past

22     11.00.

23             Court adjourned.

24                           --- Recess taken at 10.45 a.m.

25                           [The accused entered court]

Page 35186

 1                           --- On resuming at 11.16 a.m.

 2             JUDGE MOLOTO:  Before we continue, I just place it on the record

 3     that Mr. Mladic has joined us in court today now.

 4             Mr. Stojanovic, or Mr. Ivetic, are we ready to call the next

 5     witness?

 6             MR. IVETIC:  We are, Your Honours.  The Defence would call

 7     Tihomir Stevanovic.

 8             JUDGE MOLOTO:  Thank you so much.

 9             May the witness please be brought into court.

10                           [The witness entered court]

11             JUDGE MOLOTO:  Good morning, Mr. Stevanovic.

12             THE WITNESS: [Interpretation] Good morning.

13             JUDGE MOLOTO:  The Rules require that before you give your

14     testimony you must make a declaration, a copy of which is being handed

15     over to you.  Would you please make the declaration.

16             THE WITNESS: [Interpretation] I solemnly declare that I will

17     speak the truth, the whole truth, and nothing but the truth.

18                           WITNESS:  TIHOMIR STEVANOVIC

19                           [Witness answered through interpreter]

20             JUDGE MOLOTO:  Thank you very much.  You may be seated.

21             You'll first be examined by Mr. Ivetic.  Mr. Ivetic is counsel

22     for Mr. Mladic, and he's standing to your left.

23             Mr. Ivetic.

24             MR. IVETIC:  Thank you, Your Honours.

25                           Examination by Mr. Ivetic:

Page 35187

 1        Q.   Sir, I would like to first ask you to set forth your full name

 2     for purposes of the record.

 3        A.   My name is Tihomir Stevanovic.

 4        Q.   And, sir, could you also tell us where and when you were born.

 5        A.   I was born on the 20th of January, 1950, in the village of

 6     Lijesanj, in Zvornik, Bosnia and Herzegovina.

 7        Q.   And, sir, have you testified as a witness in the courtroom in any

 8     other legal proceedings before today?

 9             JUDGE MOLOTO:  You mean before the Tribunal.

10             MR. IVETIC:  At all.

11             JUDGE MOLOTO:  In any court?

12             MR. IVETIC:  In any court, yeah.

13             THE WITNESS: [Interpretation] I was in a situation to testify in

14     a misdemeanours court in my place of residence.  I did not testify here.

15     However, I was announced as a witness for Radivoje Miletic.  I stayed

16     here for nine days and for justified personal reasons, I gave a statement

17     and went back home.

18             MR. IVETIC:

19        Q.   Could you briefly detail for us your civilian educational

20     background, first of all.

21        A.   I completed elementary school in my place of birth, the village

22     of Lijesanj and Drinjaca combined, four plus four, because there weren't

23     eight grades in Lijesanj.  Then I graduated from the secondary military

24     school in Belgrade.  It's a four-year school.  Communications, that

25     what's I studied.  Then I completed a course from 1970 -- no, 1980 -- no,

Page 35188

 1     1976, for encoding, at the school centre for communications in Belgrade.

 2     In 1987, I graduated from the Military Academy.  I studied part-time, and

 3     I completed a school for encoders.  It was a nine-month course.

 4        Q.   And if you could just tell us how long the course in encoding

 5     lasted or [B/C/S spoken] I think is the words you used?

 6        A.   The first training as an organ for cryptographic data protection

 7     that only pertained to NCOs of the former JNA lasted three months, and I

 8     was trained for encoding and partial encryption and decryption of encoded

 9     telegrams.

10        Q.   Okay.  Now, in relation to your time in the military, can you

11     briefly chronicle for us the positions and ranks that you held at various

12     times during your professional career up to the outbreak of the war in

13     the former Yugoslavia.

14        A.   Since I graduated from a school for NCOs with top marks, I was

15     entitled to choose where I would serve and I chose Bijeljina.  As a

16     sergeant I was a squad leader.  In 1972 I went to Sarajevo, to the

17     garrison there, and I was commander of a platoon in the 7th Army.  In

18     1987, when I received my commission, I worked in the communications organ

19     of the 7th Army for three years.  And then I was transferred to the

20     4th Battalion of communications at the Lukavica barracks as company

21     commander.  I carried out those duties until operations started.  Excuse

22     me.

23        Q.   And you say when operations started.  What specific post did you

24     hold at the time the war in the former Yugoslavia started?

25        A.   When the war started in the former Yugoslavia, I was commander of

Page 35189

 1     the 2nd Mixed Company at the 4th Battalion for communications at the

 2     Lukavica garrison.

 3        Q.   Okay.  And where were you living and where was your family living

 4     when the war broke out in the former Yugoslavia?

 5        A.   My family lived in Sarajevo, in the neighbourhood of Ciglane.

 6        Q.   And did your family remain living there when the war broke out in

 7     the former Yugoslavia?

 8        A.   We have to go back to 1991, when my older son went to the JNA,

 9     and my younger son and my wife stayed on in Sarajevo, until it broke

10     out -- actually, until possibilities were created for leaving Sarajevo

11     because it was critical.  It was hard to stay there.

12        Q.   What made it hard to stay in Sarajevo?

13             MR. McCLOSKEY:  Could we get a time-frame?

14             MR. IVETIC:

15        Q.   Sir, what time-frame are you talking about, first of all?

16        A.   It was the end of March, beginning of April, 1992.

17        Q.   And then could you give us some idea of what you mean when you

18     say:  "... it was critical.  It was hard to stay there"?

19        A.   Well, already at that time, in 1991, the leadership of the SDA

20     there, then-president Alija Izetbegovic, something was issued that was

21     not an order, it was a suggestion, not to serve in the JNA.  Part of the

22     Serb population in Sarajevo did not accept that, and we sent our children

23     to do their military service.  The Muslims didn't do that, but it wasn't

24     all of them.  Some still went to do their military service.  Those who

25     accepted call-up papers and sent their children to do their military

Page 35190

 1     service were not well liked in Sarajevo, and they were exposed to

 2     provocations, including myself and my family.  We were exposed to that

 3     too.

 4        Q.   Okay.  And where did your family go?

 5        A.   My family, that is to say, my son and my wife who stayed on --

 6     first my son left through Butmir airport, went to Belgrade.  And my wife

 7     moved from Ciglane where we had lived and where she was seriously taunted

 8     because I moved to the barracks because of the heightened alert.  She

 9     moved to Grbavica.  And there was another lady there, the wife of my

10     colleague, and together with her she went to Rajlovac and again through

11     the airport she went to Belgrade and then from there to Zrenjanin and so

12     on.

13        Q.   Did you have occasion to join the Army of Republika Srpska, and

14     if so, when?

15        A.   Since I was in the 4th Battalion for communications of the

16     4th Corps, I was already in the Lukavica barracks.  Immediately when the

17     2nd Military District left the barracks on the square of the 6th of

18     April, around the 6th of May, on orders, I established a unit that was

19     reinforced from the 1st Company and from my own company, manpower and

20     equipment included, left -- so we left Sarajevo with a column and

21     soldiers to the Tvrdimici neighbourhood where I established a

22     communications centre at the command post of the then-4th Corps.

23     Immediately after the centre was established, the corps commander,

24     General Vojislav Djurdjevac arrived.  In this way I automatically joined

25     the Army of Republika Srpska, although it wasn't called the Army of

Page 35191

 1     Republika Srpska at that time.  Because my unit was a mixed unit.

 2             Officially, as for the Army of Republika Srpska, I joined on the

 3     19th of May, the same year.

 4        Q.   When you say your unit was a mixed unit, what do you mean?

 5        A.   Well, it's simple.  In my unit, I then had mixed ethnic

 6     backgrounds, Serbs, Macedonians, Hungarians, who were from different

 7     republics; Macedonia, Serbia, and Montenegro.  At the time while I was at

 8     Tvrdimici I didn't have any Muslims.

 9        Q.   Okay.  Now, during this time-period, did you have knowledge of

10     the withdrawal of other JNA personnel from the town of Sarajevo?

11        A.   Again we have to go back to the Lukavica barracks and link that

12     to my stay in the Lukavica barracks.  Because I was a member of the

13     communications battalion of the 4th Corps, one of the tasks of my units

14     was following the withdrawal of units from the Sarajevo garrison and the

15     transfer to Serb-controlled territory -- or actually not that, it was

16     safer at the time, safer territory.  And that was the Lukavica garrison.

17             So I was in a position to follow the withdrawal of the column

18     from Zenica with General Sipcic, who was a colonel then, then the Marsal

19     Tito barracks, then the auto battalion from Alipasa's bridge and the

20     command of the 2nd Military District from the 6th April Square in

21     Lukavica.

22        Q.   Could you describe for us by what means were you able to follow

23     with -- the withdrawal of these units that have you identified for us.

24        A.   This is the truth.  At that time, when units were withdrawing,

25     JNA units were withdrawing from garrisons, the ones that I already

Page 35192

 1     mentioned, I think the reason is already well known, because they were

 2     exposed to constant attacks and there was a high degree of intolerance,

 3     so they couldn't stay on in these settings.  So we communicated with

 4     these units and we regulated the following.  We used RUP-12s and PRCs

 5     that had the same capabilities and they were in the so-called small staff

 6     command vehicles and units had these resources.  At the head in the back

 7     of the column, they had such equipment and such vehicles.  And we, from

 8     the Lukavica barracks, followed their departure, their march, and their

 9     arrival at the Lukavica garrison, which was their destination.

10             I can add that Miroslav Micic, who was then a sergeant, worked on

11     these communications.

12        Q.   In the course of the withdrawal of the various units or -- or

13     formations that you said you were involved in following, did you recall

14     any problems or incidents that arose in relation to the same?

15        A.   Sorry, there's one thing I didn't say, and that is that we

16     followed the withdrawal of the military police battalion from the

17     Viktor Bubanj barracks so that's included too.

18             I do remember.  Let us start with the auto battalion that was at

19     Alipasino Polje, no Most, Alipasin Most.  When the column set out, it was

20     sometime in the morning.  We had communication with the front end and the

21     back of that column.  However, immediately as soon as they were supposed

22     to set out, there were certain problems because part of the Muslim forces

23     called the Green Berets tried to infiltrate the column and to cut it in

24     two and that was prevented at the very outset.  The column continued its

25     March from Alipasin Most to Lukavica.  However, soon after they left the

Page 35193

 1     barracks compound, again the unit was -- or, rather, the column was cut

 2     in two because we lost communication with the back of the column.

 3             The personnel at the back of the column, in this vehicle for

 4     communication, pointed out to us that it's possible that it was cut in

 5     two, the column, which proved to be true.  In half an hour or 40 minutes,

 6     the head of the column and that half of the column that had left Alipasin

 7     Most arrived, and then they were directed to Sarajevo -- or, rather, the

 8     Green Berets took those vehicles, seized them, the ones that we never got

 9     back.  That goes for that barracks.

10             As for the Marsal Tito barracks, that was the centre for training

11     infantry recruits with a complete infrastructure, and everything else

12     that is required by institutions of higher learning of a military nature.

13     There were no problems with withdrawal there, and the unit left without

14     any problems and went on to Belgrade.  Of course, the -- the personnel

15     there were of mixed backgrounds and I don't know what happened

16     afterwards.

17             JUDGE FLUEGGE:  Mr. Ivetic, that was a real long and very

18     detailed answer, and the previous answers were also quite long.  You

19     indicated, first, that you would need for examination-in-chief one and a

20     half hours.  You increased the time for two hours.  Is it because you

21     realised that the witness is giving detailed answers far beyond some of

22     the questions you have put to him?  Or what is the reason for that?  I --

23             MR. IVETIC:  The reason was additional information that was not

24     known to me, Your Honours --

25             JUDGE FLUEGGE:  I would --

Page 35194

 1             MR. IVETIC:  -- that was a part of the proofing note, that I then

 2     have additional questions to ask the witness, additional areas to explore

 3     with the witness.

 4             JUDGE FLUEGGE:  Yes.  But at the moment we are dealing with

 5     matters which are -- were dealt with in some detail with previous

 6     witnesses.  You should try to keep it short and not to -- to make sure

 7     that the witness is really focusing on your questions and not expanding

 8     too much.

 9             MR. IVETIC:  I will endeavour to do so, Your Honour.

10        Q.   Sir, was there any other of the withdrawals that resulted in any

11     incidents or problems that you have knowledge of?

12        A.   Very well, I'll keep it short, no problem.

13             The Viktor Bubanj barracks, there were no problems in the

14     withdrawal of the personnel there.  One should not ignore the case of the

15     murder of a soldier in the barracks before the troops' departure.  There

16     was, however, a lot of problems in another area.  The problems were of

17     the same nature as those when the Alipasin Most barracks were being

18     closed and the troops withdrawing from there.  There were casualties

19     there and you know about that already.  Those casualties were on the side

20     of the withdrawing unit.

21        Q.   Which unit was withdrawing because that has not come into our

22     transcript?  Which -- the withdrawal of which unit or entity are you

23     speaking of where there were casualties?

24        A.   The command of the 2nd Military District was withdrawing.  The

25     officers and the accompanying soldiers or escorts who worked within the

Page 35195

 1     facility or provided services for the command.  I'm talking about the

 2     command of the 2nd Military District, they were withdrawing.  They were

 3     headed by General Kukanjac.

 4        Q.   Okay.  Now, sir, either during your time as a JNA officer or

 5     afterwards when you became a VRS officer, did you have occasion to have

 6     some information or insight into the placement of ABiH military forces or

 7     installations within the city of Sarajevo?

 8             MR. McCLOSKEY:  Objection.  Can we get a time-frame?  That's so

 9     broad that -- given the information we have that he's been all over the

10     place.

11             JUDGE MOLOTO:  Mr. Ivetic.

12             MR. IVETIC:  Absolutely.

13        Q.   Subsequent to March of 1992, did you occasion to have some

14     information or insight into the placement of ABiH military forces or

15     installations within the city of Sarajevo?

16        A.   As all the other officers of the VRS, I did have certain

17     information about the locations of their forces or at least some of their

18     forces.  In view of the fact that the barracks had been abandoned on the

19     6th of April, the barracks in Bascarsija, that's where I had been in

20     service, the Marsal Tito barracks --

21             MR. McCLOSKEY:  I'm sorry to interrupt but the question was

22     answered and now we're going off into a narrative.  He did have

23     information.

24             MR. IVETIC:  Okay.

25        Q.   Did you have information of any locations of a civilian nature

Page 35196

 1     where the Army BiH had military troops or installations located?

 2             JUDGE MOLOTO:  I think that's a leading question, Mr. Ivetic.

 3             THE WITNESS: [Interpretation] I did have direct --

 4             JUDGE MOLOTO:  Just a second, sir.  Just a second, Mr. Witness.

 5     I think that's a leading question.

 6             MR. IVETIC:  Well, my prior question was open-ended and he

 7     started giving an answer and I had objection from the other side, so they

 8     wanted me to --

 9             MR. McCLOSKEY:  Nobody [overlapping speakers] --

10             JUDGE MOLOTO:  That's no justification for giving a leading

11     question next.  You still have to ask a non-leading question.

12             MR. McCLOSKEY:  Where there were locations might -- has not been

13     asked yet.

14             MR. IVETIC:  Okay.

15        Q.   At the risk of opening up a narrative, where were their locations

16     located in Sarajevo?

17        A.   The Presidency of the Republic of Bosnia-Herzegovina, one of the

18     brigades, according to the information of our security organ.  I can give

19     you his name, Colonel Milorad Bukva.  I also know indirectly that they

20     were also located in the Kosevo hospital, the military hospital.  That's

21     where they opened fire from.  There was some individual locations in the

22     tunnel, in the brick-works.  That's where they had heavy weaponry and

23     they opened fire from it there.

24        Q.   You have identified the Kosevo hospital and the military hospital

25     as places where the ABiH opened fire from.  What is the basis of that

Page 35197

 1     knowledge or information that you have?

 2        A.   That man, who is my relative, still lives in Sarajevo.  I need to

 3     protect him.  He was in Sarajevo throughout the war and he was treated at

 4     Kosevo hospital and then in military hospital.  He told me that, for

 5     example, in the military hospital, fire was opened from the balcony.

 6     Mortar fire was opened from there.  And the patients were sheltered in

 7     the basement because they knew that there would be retaliation, that fire

 8     would be returned.  They opened fire from the Kosevo hospital, from the

 9     park, because the hospital is surrounded by greenery.  They entered the

10     hospital's perimeter and they opened fire from there.  Also in view of

11     the fact that person resided in the military field in Djordje Andrejevic

12     Kun Street, leaning on Nedzarici, that's where our unit was, and the

13     settlement was called Vojnicko Polje.  Often heavy weaponry would be

14     brought by the police commanded by Vikic and fire was opened from there.

15             MR. McCLOSKEY:  Objection -- objection.

16             JUDGE MOLOTO:  Yes, Mr. McCloskey.

17             MR. McCLOSKEY:  He's asked for the basis or the knowledge and we

18     have apparently a friend who he doesn't want to name and now he has just

19     gone into a narrative without any basis.  And you know, we've been here a

20     long time, to be getting unnamed, second- and third-hand sources, if he

21     is serious about this, we can go into private session.  But to me this

22     is -- has very little probative value.

23             JUDGE MOLOTO:  Mr. Ivetic.

24             MR. IVETIC:  Your Honours, I would be happy to go into private

25     session with Your Honours' leave.

Page 35198

 1             JUDGE MOLOTO:  May the Chamber please move into private session.

 2                           [Private session]

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23                           [Open session]

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

25             JUDGE MOLOTO:  Thank you very much.

Page 35199

 1             We are now in open session, Mr. Stevanovic, so be careful what

 2     you say now.

 3             JUDGE FLUEGGE:  May I put one question to the witness, please.

 4             You mentioned a relative of yours.  Is that the only source of

 5     your knowledge in the information you gave earlier about location of ABiH

 6     forces in Sarajevo?

 7             THE WITNESS: [Interpretation] I can tell you more about that, but

 8     I can see that you will not allow me to expand.

 9             In view of the nature of my work that I carried out --

10             JUDGE FLUEGGE:  Sorry, I would like to interrupt you.  I asked

11     you if he is the only source.  Yes or no?

12             THE WITNESS: [Interpretation] No.

13             JUDGE FLUEGGE:  What other sources do you base your knowledge on?

14             THE WITNESS: [Interpretation] My personal knowledge and the

15     knowledge of the security organs of my unit, and by that, I mean the

16     4th Corps.

17             JUDGE FLUEGGE:  Mr. Ivetic.

18             MR. IVETIC:  Thank you.

19        Q.   Do you have any knowledge as to the departure of civilians from

20     parts of the city of Sarajevo which were not controlled by the JNA or the

21     VRS?

22        A.   From the very beginning of the war; i.e., when the security

23     situation became tense, my family and myself and then all of my friends

24     and later a lot of other people left Pofalici.  Pofalici was under a lot

25     of pressure and under that pressure the people caved in and they

Page 35200

 1     abandoned the neighbourhood.  I saw that personally some of those men

 2     joined my unit in Trebevic.

 3        Q.   [Microphone not activated] Let's break this down.  Tell us what

 4     part you saw personally of what was going on in Pofalici.

 5        A.   Between 8.00 and 9.00 in the morning, and I don't remember the

 6     date, it was a long time ago, right?  The Pofalici settlement, where 80

 7     to 85 per cent of the population were Serbs, came under an attack and you

 8     could see that with the naked eye from the command of the 4th Corps where

 9     I was at the time.  You could also observe the situation through the

10     binoculars.  You could observe the situation better through binoculars.

11     There was an attack and then the houses were torched and those houses and

12     facilities were property of the Serbs.  And then people started arriving

13     in the territory of Vogosca, Ilidza, Lukavica, Tilava.  All those areas

14     were controlled by Serbs.

15        Q.   Okay.  Now who was attacking the settlement of Pofalici that you

16     observed?

17        A.   Muslim forces.

18        Q.   And now earlier you also said "some of those men joined my unit

19     in Trebevic."  Who was it that later joined your unit in Trebevic?

20        A.   I apologise, sir, not Trebevic but Tvrdimici.  My unit was in the

21     village of Tvrdimici.  That's where the command post was as well.  Those

22     were mostly drivers by trade, common folks, who were militarily

23     able-bodied.  My unit was a special unit and the only people who could

24     join it were communications men and drivers.  There were some

25     communications guys, not many of them.

Page 35201

 1        Q.   But from where did they men come to join you at Tvrdimici?

 2        A.   From the settlement of Pofalici.

 3        Q.   Okay.

 4        A.   They were assigned to my unit, in practical terms.

 5        Q.   Okay.  Now, you earlier also mentioned -- you said something

 6     about Bascarsija.  What was in Bascarsija?

 7        A.   Above Bascarsija - and Bascarsija is about 100 to 150 metres as

 8     the crow flies from the Jajce barracks where I had served for 14 years -

 9     their battalion of military police was billeted there.  And since you

10     could see that area from the area controlled by the Serbs, we suffered

11     daily fire being opened on our positions from there.

12        Q.   Okay.  Now, sir, can you tell us did you remain in the Sarajevo

13     area the entirety of the war or did you transfer to some other unit or

14     formation?

15        A.   As needed, when the company was fully established and when it was

16     moved together with the command post from the village of Tvrdimici to

17     Pale, to the tourist hotel there where the command post of the 4th Corps

18     was, at the beginning of March 1993, on the order of the commander of the

19     Main Staff of the VRS and at the proposal of the communications organ of

20     the Army of Republika Srpska, I was reassigned to Crna Rijeka to the

21     communications regiment.

22        Q.   Before we continue with the communications regiment, I'm not sure

23     if you identified who was in the barracks at Jajce as the transcript does

24     not record that element.  So I would ask for you to please repeat for us

25     who was quartered in the Jajce barracks.

Page 35202

 1        A.   You mean during the war?  During war activities?

 2        Q.   Yes.

 3        A.   The military police of the Muslim military.  It was a battalion

 4     of the military police.  That was their strength.

 5        Q.   Now, coming back to your transfer to the communications regiment,

 6     what were your precise duties within the communications regiment when you

 7     first arrived in March of 1993?

 8        A.   I'll try and keep it short.  I was appointed as the company

 9     commander for the communications garrison.  That was in the rank of a

10     communications battalion.  That was my duty.

11        Q.   Can you tell us how long you stayed in this position?

12        A.   Until March 1995.  And then I became a member of the

13     communications department of the Main Staff of the VRS.

14             MR. McCLOSKEY:  Could we get ranks.

15             MR. IVETIC:

16        Q.   What rank did you hold at the time that you were appointed to the

17     communications regiment in March of 1993?

18        A.   Captain first class.

19        Q.   What rank did you have when you joined the communications

20     department of the Main Staff?

21        A.   Major.

22        Q.   And what specific position did you have at the Department of

23     Communications of the Main Staff?

24        A.   I was the desk officer for cryptographic protection in the

25     communications department of the Main Staff of the Army of

Page 35203

 1     Republika Srpska.

 2        Q.   While you were at this position in the communications department

 3     of the Main Staff, who was your immediate superior?

 4        A.   My immediate superior was Colonel Radomir Prole.

 5        Q.   Now moving backwards to the first position that you held at the

 6     Main Staff within the communications regiment, where were you physically

 7     located during the time of performance of your duties?

 8        A.   I apologise, in order to answer your question, I have to say that

 9     the communications company had a relay platoon which was quartered at

10     Veliki Zep.  It had a telephone platoon, the ATC platoon, and the

11     maintenance squad.  The last three units were quartered at the Goljak 1

12     feature where I was also quartered.

13        Q.   And the Goljak 1 feature, what kind of a feature or structure was

14     that?

15        A.   It depended on the unit formations and their changes.  First it

16     was --

17             THE INTERPRETER:  Could the witness please slow down.

18             MR. IVETIC: [Interpretation]

19        Q.   Just a moment.

20             [In English] The interpreters have asked that you speak more

21     slowly, sir.  Could you please restart your answer.

22        A.   Very well.  According to the first and original version, the

23     Goljak 1 structure was intended for the rear command post of the former

24     7th Army.  When that was disbanded, its purpose was to serve as the rear

25     command post of the corps.  And when the war broke out, that's where the

Page 35204

 1     Main Staff of the Army of Republika Srpska was quartered.

 2        Q.   And what kind of building was Goljak 1?

 3        A.   Goljak 1 was a sub-terrain facility featuring all the necessary

 4     equipment for the stay and work of a command, the size of the

 5     then-Main Staff.

 6        Q.   What --

 7        A.   It could go on working uninterruptedly for 75 days.

 8        Q.   What can you tell us about the staffing levels that you

 9     experienced at the communications regiment when you arrived there?

10        A.   Just like all the other units, the communications regiment was

11     understaffed.  It had two battalions.  It had a company for garrison

12     communications and a rear platoon.  When it comes to my company, it was

13     supposed to have -- I can't remember exactly what it would have been

14     according to establishment, but it should have been 130 men.  When I

15     arrived there, I found between 60 and 70 men in the unit.

16        Q.   Now going back to your second position that you held after

17     March of 1995, when you were a desk officer for cryptographic protection,

18     could you tell us what were the precise duties that this position

19     entailed?

20        A.   The duties of a desk officer for cryptographic data protection in

21     the Main Staff of the VRS was to organise cryptographic data protection

22     at the level of the VRS, to secure technical equipment and means, as well

23     as all the necessary documents that were needed for the normal

24     functioning of cryptographic data protection at all levels of the VRS.  I

25     inherited that position from Lieutenant-Colonel Miroslav Radakovic.

Page 35205

 1        Q.   How long did you stay in this position?

 2        A.   Until the end of the war and then I continued in peacetime.

 3        Q.   Okay.  When did you retire from active military service?

 4        A.   In 2003.

 5        Q.   What rank did you have at the time of retirement?

 6        A.   Lieutenant-colonel.

 7        Q.   Okay.  Now, you've identified for us Goljak 1.  Were there any

 8     other buildings or structures that made up the Main Staff facility at --

 9     command facility?

10        A.   Within the perimeter of Crna Rijeka, there was Goljak 1, the

11     so-called Barake [phoen] settlement.  The Veliki Zep feature which was a

12     radio-relay facility.  The buildings and commands of the 65th Motorised

13     Regiment and the communications regiment, their commands were in wooden

14     huts, and the troops were in dugouts.  There was also the G2, or

15     Goljak 2, feature which was very close but it was not secured and there

16     was nobody there.  Within the complex of those features, there was also

17     the Goljak 3 facility, which was located some 7 to 10 kilometres further

18     away, near Han Pogled mountain pass on the Han Pijesak-Vlasenica road.

19        Q.   Now I would like to ask you to tell us what means of

20     communication made up the communications network available to the

21     Main Staff of the VRS at Crna Rijeka.

22             MR. McCLOSKEY:  Can we get a time-frame or ...

23             JUDGE MOLOTO:  Mr. Ivetic.

24             MR. IVETIC:

25        Q.   During the time-period that you were there, from March of 1993

Page 35206

 1     until the end of the war in 1995, could you give us an overview of the

 2     means of communications that were -- that made up the communications

 3     network of the Main Staff of the VRS at Crna Rijeka.

 4        A.   From the point of view of the duties that I performed, I have to

 5     give the following answer, which is professional.

 6             The Main Staff of the Army of Republika Srpska used an integrated

 7     system of communications that consisted of radio communications,

 8     radio-relay communications, wire communications, and courier

 9     communications.

10        Q.   Okay.  I'd like to break that down a bit, and I would ask you to

11     describe for us which type of radio-relay devices were utilized by the

12     VRS Main Staff for communications with its subordinate corps?

13        A.   The Main Staff of the Army of Republika Srpska used the following

14     radio-relay devices that were positioned at Veliki Zep; namely, SMC, RR

15     radio-relay device, RRU, FM-200, RRU-9.  RRU-800 not so often.  Then

16     RRU-1 which has a single channel.

17             That is what I have to say about radio-relay devices.

18        Q.   Before we continue, Your Honours, I think that we started at

19     15 after.  We're on a different schedule today.

20             JUDGE MOLOTO:  Yes, we're trying to configure the hours because

21     we spent one and a half hours this morning, so if we can go until 25 past

22     12.00.

23             MR. IVETIC:  That's fine.

24        Q.   Sir, were any of these -- were any of the routes covered by this

25     radio-relay communications equipment you've just identified for us able

Page 35207

 1     to carry encrypted communications?

 2        A.   Yes, briefly.  That's a brief answer, yes.  And I can explain

 3     how, if necessary.

 4        Q.   First of all, which routes could be encrypted?

 5        A.   Could have and had to have been encrypted.  All of those going to

 6     the 1st Corps, the Herzegovina Corps, the Eastern Bosnia Corps, and the

 7     air force and air defences, the Sarajevo-Romanija Corps, the Presidency,

 8     all of them were encrypted, protected.

 9        Q.   What about with the Drina Corps?

10        A.   I'm -- I'm sorry, I apologise if I omitted that.  It was by

11     accident.  Yes, the Drina Corps too.

12        Q.   Could you please tell -- describe for us the types of encryption

13     devices that were in use in relation to the radio-relay communications

14     between the Main Staff and these other parties that you have identified

15     where encrypted communications went?

16        A.   Since these are radio-relay devices and that kind of protection,

17     the two basic devices for cryptography protection of speech that went

18     through these systems is KZU-71 and KZU-61.  Let me make a distinction

19     here so that would be clear.  The KZU-71 had the possibility of

20     protecting a group of telephone channels, speech channels, transmitted by

21     this system; whereas KZU-61 could protect only one channel.

22        Q.   And what about for -- you identified that these are for speech.

23     Were there any encryption devices for written communication?

24        A.   Yes.  Cryptographic protection referred to written information

25     and spoken information.  For written information there were several

Page 35208

 1     systems.  The safest and most often used one was R-7.  Then 31.  They

 2     were used for the protection of written information along with T-G4 or,

 3     rather, KZU-31.

 4        Q.   Could you tell us, first of all, how the KZU-71 and the KZU-61

 5     devices performed their encryption function?

 6        A.   I do apologise.  This is English, but it's not R-7.  It's S-7.  I

 7     see this in this text although I don't understand English.  So now let me

 8     go back to the answer.

 9             KZU-71 was placed between the radio-relay device and AMD-310.

10     They could have been from -- they could have had four, eight or 32

11     channels.  Usually it was between eight and 16 channels.  And all

12     information that was open arrived in KZU-71.  And when exiting KZU-71,

13     moving towards a radio-relay device, this information became encrypted.

14     For KZU-71 to secure encryption of information that is arriving, before

15     that it was necessary to carry out certain preparations by inserting a

16     key for encryption or, rather, decryption.

17        Q.   I'm going to --

18        A.   Please go ahead.

19        Q.   If I can you to be precise.  When you say "a key," what kind of

20     key is that?  Is that a physical key?

21        A.   No, no.  This is a coded tape that is put into this key -- no,

22     no, into the device itself.  It is read into it, into its electronic

23     system, and it is valid for 15 days up to a month, and I would usually

24     change it every 15 days.  That was my practice.

25        Q.   Okay.  Could you go on then and complete telling us how the

Page 35209

 1     KZU-71 and 61 devices functioned.

 2        A.   Well, this electronic system --

 3             THE INTERPRETER:  Interpreter's note:  Could the witness please

 4     speak more clearly.  Thank you.

 5             MR. IVETIC:  The interpreters have asked that you speak slowly

 6     and try to speak more clearly, perhaps with the microphone closer to you,

 7     so that they can better follow you.

 8             THE INTERPRETER:  Interpreter's note:  It is not a question of

 9     the microphone.  Could the witness please speak clearly.  Thank you.

10             THE WITNESS: [Interpretation] Sorry, I thought that I was even

11     speaking too loud.

12             So it was open speech that came into KZU-71, and the key that was

13     inserted before that into the electric electronic system, the electronic

14     system of the KZU-71 made it possible to scramble this speech so when

15     leaving that device and then further on through radio relay, it would be

16     transmitted in an encoded way, a single tone, namely, so nothing could be

17     understood.  And there could be no decryption or, rather, there couldn't

18     be any interception therefore.

19        Q.   Are there any major differences between the way that the KZU-61

20     encryption device worked?

21        A.   Yes, KZU-71 is a more modern piece of communication -- piece of

22     equipment and it enables the kind of communication we have now, whereas

23     61 is a device that encoded speech.  However, it required very slow

24     speech so that it could be transmitted to the other side.  Its abilities

25     were modest, in terms of transmission capacity.

Page 35210

 1        Q.   Did either of these encryption devices need to be activated or

 2     turned on in order to function when someone was using a radio-relay

 3     device?

 4        A.   As soon as there is radio-relay communication and as soon as

 5     telephone channels get through and as soon as quality is tested, KZU-71

 6     is put in and it works all the time and it does not require any kind of

 7     activation at a further point.  It is activated throughout.  And it

 8     reacts to speech, and then speech is encoded afterwards.  So it doesn't

 9     have to be switched on afterwards.  It's on all the time.

10             MR. IVETIC:  Your Honour, I see we're at the 26-minute mark.

11             JUDGE MOLOTO:  [Microphone not activated] We'll take a break and

12     come back at quarter to 1.00.

13             Could you please follow the usher.

14                           [The witness stands down]

15             JUDGE MOLOTO:  We'll take a break at come back at quarter to

16     1.00.

17             Court adjourned.

18                           --- Recess taken at 12.25 p.m.

19                           --- On resuming at 12.46 p.m.

20             JUDGE MOLOTO:  While we're waiting for the witness,

21     Mr. Stojanovic, the Chamber received information that the Defence would

22     like to address a scheduling issue for the week 18th to the 22nd of May.

23     I'm not asking that you do that now, just indicate whether -- are you

24     going to do it or ...

25             MR. STOJANOVIC: [Interpretation] We will do that, Your Honour.

Page 35211

 1     We expect to be able to do that tomorrow morning, concerning the last

 2     working week this month.

 3             JUDGE MOLOTO:  Thank you so much.

 4                           [The witness takes the stand]

 5             JUDGE MOLOTO:  Mr. Ivetic.

 6             MR. IVETIC:  Thank you, Your Honours.

 7        Q.   Sir, in relation to these keys for the encryption devices that

 8     were changed every 15 to 30 days, where did these keys come from?

 9        A.   I provided those keys to the units.

10             THE INTERPRETER:  Interpreter's note:  We did not understand

11     whether the witness said that he can or cannot say where the key was

12     made.

13             MR. IVETIC:

14        Q.   Could you repeat the last part of your answer.

15        A.   If necessary, I can say where it was made, and I'm the one who

16     provided them to the units.

17        Q.   If you could also then tell us where they were manufactured.

18        A.   The keys for encoding written and spoken information were made at

19     the Institute of Applied Mathematics and Physics in Belgrade.

20        Q.   Thank you.  Now, could somebody with the same radio-relay

21     communications equipment and the same encryption device but without a key

22     for the encryption device listen to the voice communications that were

23     transmitted via such a device?

24        A.   No.

25        Q.   Now I'd like to move to radio devices.  What radio devices did

Page 35212

 1     the VRS Main Staff have at their disposal?

 2        A.   When I was speaking about the communications used by the

 3     Main Staff of the Army of Republika Srpska, I said radio communications

 4     as well.  The radio communications used by the Main Staff of the Army of

 5     Republika Srpska were very powerful pieces of equipment and they were

 6     used exceptionally, seldom, very rarely.  Only in situations when it was

 7     absolutely necessary.  Also, radio devices that were short-range,

 8     Motorolas, were used, as well as radio telephone equipment in the

 9     vehicles of the commander and the Chief of Staff.

10        Q.   Okay.  First of all, on what types of occasions would radio

11     devices be exceptionally used?

12        A.   If all radio-relay communications with subordinate units were

13     down.  That did not happen until our radio-relay facilities were bombed

14     or, rather, our node centres.  They were just used for conveying short

15     orders, written information.  One kilowatt, RTP, 1 kilowatt - that's the

16     device - they make it possible to encode and decode information and

17     transmit such written information because they include teleprinters as

18     well.

19        Q.   And now you also mentioned, I believe, Motorolas and

20     vehicle-based radio equipment.  What was the range of the same?

21        A.   Radio communication in vehicles was only based on repeater links.

22     The range was short and it depended on the configuration of the terrain.

23     So they were not always successful.  I can state with responsibility that

24     these communications were used seldom.

25        Q.   Now I want to focus for a bit on the types of radio or

Page 35213

 1     communications devices that were available to the vehicles that were used

 2     by General Mladic.  Could you first identify for us who was in charge of

 3     setting up and maintaining such equipment in the vehicles of

 4     General Mladic?

 5        A.   It was the technical --

 6             THE INTERPRETER:  Interpreter's note:  Could the witness start

 7     again, speaking clearly and slowly.  Thank you.

 8             MR. IVETIC:

 9        Q.   Can you please start your answer again and speak more slowly and

10     clearly so that the interpreters can catch every word.

11        A.   Very well.  Radio telephone devices that were installed in

12     vehicles that were used by the commander of the Main Staff of the Army of

13     Republika Srpska were maintained by professionals from the logistics

14     platoon of the communications regiment of the Main Staff of the Army of

15     Republika Srpska.

16        Q.   These radio telephone devices, based on what technology did they

17     operate?  What type were they?

18        A.   Electromagnetic waves.  But the range was short.  And it depended

19     on repeaters only, their range depended on that, that is.

20        Q.   On what type of vehicles of General Mladic were these devices

21     installed?

22        A.   On Puchs.  It's a vehicle called Puch.

23        Q.   What type of a vehicle is a Puch?

24        A.   It's a terrain vehicle and that's a vehicle that usually

25     commanders had.

Page 35214

 1        Q.   What -- what about civilian vehicles that were used by General

 2     Mladic at the Main Staff?  What type of equipment for communications

 3     would those vehicles have?

 4        A.   In civilian vehicles that were used by General Mladic there was

 5     no communications equipment that he could use.

 6        Q.   Now I'd like to move to written communications.  Could you please

 7     first tell us what is the difference between an act and a telegram?

 8        A.   I do apologise.  This word that you used, "ukaz," did you mean

 9     "act"?

10        Q.   Yes, I meant "act."

11             MR. McCLOSKEY:  Objection.  Can we have a foundation before we --

12     I haven't heard these words even used by the witness.

13             JUDGE MOLOTO:  Mr. Ivetic.

14             MR. IVETIC:  Is counsel saying he doesn't know what a telegram

15     is?  I'm confused by the objection.

16             JUDGE MOLOTO:  Counsel says he hasn't heard the witness talk

17     about act and telegram, and doesn't know what "act" means.  Part of the

18     objection is simply that the question is leading and then -- and then

19     you're introducing something that the witness has never talked about.  I

20     don't know what an act is because you said first "act," which I thought

21     was an English word, and when you said "act," I didn't know what you're

22     talking about.

23             MR. IVETIC:  Let's take it a step backwards.

24        Q.   Could you please describe for us the process by which written

25     communications are initiated and sent by one end in the network to

Page 35215

 1     another end in the network, telling first what technology and what the

 2     steps in the process are.

 3        A.   Yes.  In order for communication to be transmitted, written

 4     information, first of all, that information has to be typed up on a

 5     typewriter on an A4 piece of paper.  That information has to bear a

 6     letterhead, a heading, brief text, the address of the addressee, the

 7     addressee, then written text from which one is supposed to see what one

 8     wishes to have done by way of this information.  At the end of the text,

 9     there has to be -- there have to be the initials of the person who

10     processed this; namely, the person who typed this, then a signature, and

11     a stamp.

12             Such a document is packed in an envelope, is sent by courier in a

13     locked bag to the facility number 1.  It is handed over to the encoder.

14     The encoder takes over the document, sees who it is addressed to, places

15     his own stamp there, sending stamp, and records the time when the

16     document was received at the encoding station.

17             Then the telegram is encoded, using a certain encoding system.

18     Then the time is registered as to when the telegram was encoded, and then

19     there is a tape that comes out of the teleprinter within this system.

20     Then, according to the log-book there, it is sent to the teleprinter

21     station, and then it is sent to the address that is noted there.

22             Once the teleprinter operator receives confirmation of receipt,

23     such a telegram -- receipt of such a telegram, then information is

24     provided to the encoder.  Then on the sending stamp, the time of receipt

25     is recorded.  The document is placed in an envelope and, again, through a

Page 35216

 1     courier, it is returned to the person or organ that had sent it.

 2             The tape is guarded for 24 hours, the encryption tape.  If he

 3     doesn't receive a request for repetition, the encryption tape and the key

 4     that had been used to encode that telegram is destroyed by fire.  That

 5     completes the telegram-sending process.

 6        Q.   If we can go back to the original that has to have a stamp, a

 7     signature, and then is sent by a locked courier bag to the encoder to be

 8     encoded and sent to the receiver, what is the name in the military

 9     parlance of that type of document, the original?

10        A.   A document, an enactment.

11        Q.   And --

12        A.   May I be allowed to explain that?

13        Q.   Go ahead.

14        A.   If a document was processed and intended for sending by telegram,

15     all the data it contains are on the left-hand side.  The person who

16     drafted the document, a short content, who dictated, who typed it, a

17     signature, and a stamp, a round stamp, all that is on the left-hand side.

18             A document which is intended for courier dispatch, i.e., a

19     document that is to be personally delivered to the recipient, is signed

20     on the right-hand side.  That's the difference.

21        Q.   Now --

22             JUDGE MOLOTO:  Just for my own clarification, I keep hearing the

23     witness talking of "act."

24             MR. IVETIC:  Yes.

25             JUDGE MOLOTO:  Which of these words that are on the transcript

Page 35217

 1     here is the equivalent of "act."

 2             MR. IVETIC:  I think it would be better for the translators to

 3     perhaps answer that question so I'm not giving evidence.

 4             JUDGE MOLOTO:  Sir, can you tell us what an act is?  Let the

 5     interpreters interpret.

 6             THE WITNESS: [Interpretation] Written information typed up,

 7     original, not encoded, without any cryptographic data protection.  That's

 8     a document.

 9             JUDGE MOLOTO:  Thank you.

10             MR. IVETIC:

11        Q.   And the -- what is received on the other end and what is

12     processed and decoded, what is the name for that recipient's copy of the

13     written communication?

14        A.   I will use the kind of terminology that exists both in the

15     military and civilian structure.  It is a received telegram or an

16     incoming telegram.  The coder has to decode it to turn it back into its

17     original telegram form, the incoming telegram, that is.

18             If necessary, I can explain the whole procedure.

19        Q.   Let me see if I can work through some parts first.

20             Once the original act has been presented for transmission to the

21     encryptions officer, can that encryptions officer change any of the text

22     in that original act before sending it?

23        A.   A decoder is forbidden from changing anything in the original

24     text.  He can't even delete a comma or a full stop or a single letter.

25        Q.   Now, you've described for us this tape that comes out of the

Page 35218

 1     teleprinter.  How does that tape function on both ends; that is, on the

 2     encoding and on the decoding side?

 3        A.   For a telegram to be encrypted or encoded there's a key and there

 4     is an open text.  First you draft a text and then there is a reader of a

 5     special cryptographic machine, a tape of the open text is placed there,

 6     and then there is a second reader where you place a key tape also

 7     [indiscernible].  As a product you receive an encrypted telegram in the

 8     form a tape with holes.  And there's also a heading which contains the

 9     address of the recipient.

10        Q.   Now, I believe you identified that for [sic] 24 hours both the

11     tape containing the encoded telegram and the key are destroyed by fire.

12     If --

13        A.   Yes.

14        Q.   If the key for a particular telegram is destroyed, can that tape

15     where the telegram is written ever be decoded again?

16        A.   No.

17        Q.   By what means would a signal carrying an encrypted telegram be

18     transmitted?

19        A.   That telegram can be sent by an open or public communication

20     means.  Because it is already encoded, it doesn't have to be further

21     protected.  It can be sent by a teleprinter machine without any

22     additional encoding.

23        Q.   Is it transmitted by radio, radio relay, or by other means?

24        A.   Both radio and radio relay means.  What we had was mostly

25     radio-relay communication means and the integrated telephone means

Page 35219

 1     because radio relay and integrated telephone means are a whole.

 2        Q.   Now while a telegram is being transmitted, what are the operators

 3     at both the sending and receiving side doing?  Is it an automated

 4     process?

 5        A.   It's an automatic procedure, yes.  They can do other things at

 6     the same time because telegrams kept on coming constantly.

 7        Q.   Could someone else with the same equipment, the same device,

 8     listen in on the transmission of a telegraph, and then essentially get

 9     that telegraph and be able to decrypt and read it?

10        A.   First of all, let me tell you that it would be somewhat hard for

11     anybody to get a hold of all the necessary equipment to intercept such

12     communications because our radio-relay routes went across the territory

13     under the control of the Army of Republika Srpska, save for some routes,

14     for example, Vlasic that went via Travnik.  And even if the enemy side

15     had managed to secure the receipt of such signals, they would not have

16     been able to decode such a telegram.  In order for them to be able to do

17     that, they would have had to have the appropriate equipment which they

18     could have because those equipments were left behind on the other side.

19     They would have had to have the key as well, and the key - as the word

20     says - is the key of everything.

21        Q.   And, again, where did these keys come from?  Where were they

22     supplied from during the war?

23        A.   All units of the VRS, before my arrival, were supplied by the

24     communications organ of the Main Staff of the VRS, i.e., the desk officer

25     for cryptographic data protection, Lieutenant-Colonel Radakovic.  As of

Page 35220

 1     March 1995 onwards, I did that.  As I have already told you, those keys

 2     were produced you know where.

 3             I have to say something important.  They were not mailed or

 4     sent by a third person or anything like that.  They were sent by secure

 5     means and under arms protection.  Let me say that all telegrams were

 6     processed, i.e., they were encoded and decoded, in a Faraday's cage that

 7     all the units of the corps rank and sometimes even brigade had.  That

 8     procedure excluded any unwanted source of radiation.

 9        Q.   When you say "that procedure," are you talking about the

10     Faraday's cage or something other?

11        A.   I did not understand you, sir.  What do you mean?  Oh, yes, yes,

12     we're talking about the encoding and decoding procedure.  That took place

13     in a Faraday's cage, all of that.

14        Q.   Now I want to take a look at some telegrams that were sent during

15     the time-period of July 1995.

16             First of all, sir, can you tell me where you were --

17             MR. McCLOSKEY:  Could we learn what a Faraday's cage is.

18             MR. IVETIC:  Is that going to be counted against my time?  Okay.

19     I'll ask it.

20        Q.   What is a Faraday's cage, sir?  Could you please repeat what a

21     Faraday's cage is.

22        A.   Yes, I can, of course.  A Faraday's cage was named after a

23     scientist, Faraday.  He made a room or a space, in practical terms, a

24     cage, with a lot of conduits to encapsulate all the radiation within a

25     space without letting it out of that space.  I'm referring to the

Page 35221

 1     electromagnetic waves that are created every time a teleprinter is

 2     switched on and starts working.

 3        Q.   And what would be the function or purpose behind operating a

 4     teleprinter within such a Faraday's cage?

 5        A.   The purpose is this.  When a -- an original text is typed, if the

 6     enemy side would happen to have the same kind of technology and

 7     capabilities to come to a distance of 300 metres from the place where

 8     such a telegram is processed, they could receive those signals by just

 9     following the typing on the teleprinter and that's how they could obtain

10     the contents of the open-sourced text.

11        Q.   And then how did the Faraday's cage prevent that from happening?

12        A.   The signal is lost within the conduits which enclose the wall of

13     such a Faraday's cage.

14        Q.   Now I want to take a look at some telegrams that were sent during

15     the time-period of July 1995.

16             First of all, can you tell me where you were located during the

17     first half of July 1995?

18        A.   You mean from the 1st to the 15th?  In the month of July, I was

19     in Crna Rijeka, save on 13th and 14th of July when I wasn't in Crna

20     Rijeka, I was in the place I was born.

21        Q.   And what about the days after the 15th, how long were you at Crna

22     Rijeka for the days after the 15th?

23        A.   I was there all the time.  I was absent from time to time, if I

24     needed to do something in the vicinity of that location.

25        Q.   And where specifically in Crna Rijeka were you and what were you

Page 35222

 1     doing?

 2        A.   I was in Goljak 1 or in the wooden huts.

 3        Q.   Okay.

 4             MR. IVETIC:  And I'd like to look at P2109.

 5        Q.   While we wait for the document, I can say that it's dated 11th

 6     July 1995.  First of all, sir, have you seen this document before today?

 7        A.   I have.  During the preparations for this testimony.

 8        Q.   And if we could turn to the last page in both languages, based on

 9     what you have just told us, would this be an act or a telegram?

10             MR. McCLOSKEY:  Objection.  Leading.

11             JUDGE MOLOTO:  Your response, Mr. Ivetic.

12             MR. IVETIC:  Has the last 30 minutes been in vain, Your Honours?

13             JUDGE MOLOTO:  Could you please respond to the objection without

14     asking further questions.

15             MR. IVETIC:  Yes, Your Honours.  I base it upon his prior

16     testimony.  I said:  "Based on what you have just told us, would this be

17     an act or telegram," so it is basing it back on the discussion that we

18     had, a rather lengthy discussion, about what documents are called "acts"

19     and what documents are called "telegrams."  So I don't really know what

20     the -- I don't know how else to phrase this question basing it on

21     the prior testimony that we've had now.

22             JUDGE MOLOTO:  A non-leading phrasing of the question is:  What

23     is this?

24                           [Trial Chamber confers]

25             MR. IVETIC:  Then can I get a ruling?

Page 35223

 1             JUDGE MOLOTO:  The objection is denied.

 2             MR. IVETIC:

 3        Q.   Sir, is this that we have before us, based upon what you've

 4     described for us, would it qualify as an act or a telegram?

 5        A.   This is a document.

 6        Q.   Can you tell us how we can know that it is act rather than a

 7     telegram?

 8        A.   It's very simple.  This was a written on a typewriter, not a

 9     teleprinter.  It has a round stamp and there is an indication of the

10     command that received it.

11        Q.   Now, if we look at the initials "S.R." that are handwritten next

12     to General Mladic's name, what would that denotation normally stand for

13     or mean?

14        A.   The answer to your question would be, this doesn't mean anything.

15     When I say that it doesn't mean anything, that -- what I'm saying is

16     this -- this was not signed by General Ratko Mladic.  This is an original

17     document, so his signature should be there if he had ever signed the

18     document.

19        Q.   Okay.  And if an original act had a signature, is the signature

20     itself transmitted to the receiving party to become part of the telegram

21     received on the other end?

22        A.   The original signature cannot be transmitted by telegram.

23        Q.   What are the obligations of an encryptions officer receiving an

24     original that is unsigned?  What can they do?

25        A.   He has to transmit it because it was brought to him by somebody

Page 35224

 1     who has the authority to send telegrams.

 2        Q.   Okay.

 3             MR. IVETIC:  Now, if I can look at P2125, and this will be dated

 4     15 July 1995.

 5             JUDGE MOLOTO:  Mr. Ivetic, you're left with about ten minutes

 6     according to our estimates.  I don't know how far you are still.

 7             MR. IVETIC:  I'm looking at about 12 minutes, based on my

 8     questions.

 9             JUDGE MOLOTO:  Thank you very much.

10             MR. IVETIC:  So we should be able to comply.

11        Q.   Sir, this is dated 15 July 1995.  Based on your knowledge, was

12     General Mladic present in Crna Rijeka at that time?

13        A.   No.

14        Q.   And, again, based upon your definitions and testimony, is this an

15     act, original, or a telegram?

16        A.   This is a telegram.

17             JUDGE MOLOTO:  Mr. Ivetic, I'm sorry to do this to you.  Could we

18     go back to the previous document.

19             MR. IVETIC:  Sure.  That would be ...

20             JUDGE MOLOTO:  2109.

21             MR. IVETIC:  Yes, 2109.  Do you perhaps need them both on the

22     screen?

23             JUDGE MOLOTO:  Both -- both versions.  Could we see the last

24     page, please.

25             If you look at the original, Mr. Stevanovic, could you tell us

Page 35225

 1     what date that is at the bottom of -- just below the signature?

 2             THE WITNESS: [Interpretation] Below the signature, in the stamp,

 3     the 15th of July.

 4             JUDGE MOLOTO:  15th of July.  The English says "13th,"

 5     Mr. Ivetic.

 6             MR. IVETIC:  Ah, I did not note that.  Thank you.

 7             JUDGE MOLOTO:  Then it should be -- we should know what the

 8     correct date is, and I suppose it's the one on the original, and we will

 9     needed an amended translation uploaded.

10             MR. IVETIC:  I trust my colleagues on the other side will do that

11     since it's their exhibit.

12             If we can go back then to P2125.

13        Q.   And if we look at the upper left hand part of the document, what

14     does the string of numbers after confidential or confidential number, I

15     guess, is the abbreviation, what does that 04/12-302 tell you about this

16     document?

17        A.   04/12, you mean, and the rest?  Since we're talking about a

18     radio-relay communication, this is the number that was assigned to the

19     communications organ of the Main Staff of the VRS and he uses this number

20     every time he sends documents to regulate cryptographic communications of

21     the VRS.  This document was created in the Main Staff of the VRS, and I

22     know that for a fact because I worked in that department myself.

23        Q.   Okay.

24             JUDGE MOLOTO:  And when you say "he uses it," who is the "he"?

25             THE WITNESS: [Interpretation] The communications organ of the

Page 35226

 1     Main Staff of the VRS.

 2             JUDGE MOLOTO:  Thank you.

 3             MR. IVETIC:

 4        Q.   Now --

 5             JUDGE FLUEGGE:  Can I put another question.

 6             We see on the original after the name Ratko Mladic again this

 7     abbreviation, S.R.  What does that stand for?

 8             THE WITNESS: [Interpretation] That's supposed to mean "svojo

 9     rucno [phoen]," in his own hand, signed by General Mladic personally.

10     And that is obviously not the case here.

11             JUDGE FLUEGGE:  Thank you.

12             MR. IVETIC:

13        Q.   And you earlier had said that General Mladic was not in Crna

14     Rijeka on this date.  Do you --

15        A.   Yes.

16        Q.   Do you recall if any orders personally originating from General

17     Mladic came to the Main Staff from him while he was wherever he was on

18     15 July or the day after?

19        A.   No.

20        Q.   During the time-period of 14 July through 17 July 1995, did you

21     note any orders that were sent by the Main Staff to subordinate units

22     ordering the commission of crimes?

23        A.   No, absolutely not.

24        Q.   What about incoming telegrams from subordinate units?  Do you

25     recall any that were out of the ordinary in relation to Srebrenica?

Page 35227

 1        A.   Since I usually did not read telegrams but in view of

 2     developments and throughout the war when some major developments are

 3     concerned some important combat operations, I would read some telegrams.

 4     I remember one of these telegrams.  It arrived from the Zvornik Brigade

 5     and it so happened that it arrived directly to the Main Staff rather than

 6     the Drina Corps, which meant that it was just forwarded from the

 7     Drina Corps directly to the Main Staff.

 8        Q.   Okay.

 9        A.   With the signature of the commander of the Zvornik Brigade,

10     Vinko Pandurevic.

11        Q.   And was that the normal means of transmission of telegrams from

12     the Zvornik Brigade?

13        A.   It was an exceptional case.  The usual thing would be for a

14     telegram from the Zvornik Brigade or any other brigade from the

15     Drina Corps, it would have to arrive in the Drina Corps.  It would have

16     to be processed and only then with the command -- with the signature of

17     the commander of the Drina Corps, it could only then be sent to the

18     Main Staff.

19             MR. IVETIC:  I'd like to look at P1513.

20        Q.   And when that comes up, sir, I'd like to have you take a moment

21     to look at that and tell us if you recognise that document.

22             JUDGE FLUEGGE:  I assume it's a P number.

23             MR. IVETIC:  Yes, I apologise.  P1513.

24             JUDGE FLUEGGE:  It was not recorded.

25             MR. McCLOSKEY:  And is that on your list?

Page 35228

 1             MR. IVETIC:  It was on the e-mail proofing note that was sent, I

 2     believe, Monday evening at 4.00, approximately.

 3        Q.   Sir, looking at this document - and perhaps if you need the

 4     second page, please let us know - do you recognise this document?

 5        A.   I do.  And I remember it very well.

 6        Q.   What is this?

 7        A.   This is the commander of the Zvornik Brigade informing the

 8     Drina Corps about the situation in his area of responsibility or, rather,

 9     the situation in the area where the 28th Division is trying to break

10     through to Tuzla.  Parts of the 28th Division.

11        Q.   And -- okay.

12        A.   And -- and about what he did.  That's what he speaks of.

13        Q.   And what do you recognise this document to be, in relation to

14     what you've been telling us?

15        A.   This is a telegram.

16        Q.   How does this relate to the one telegram that you told us came in

17     with the signature of Mr. Pandurevic that was done exceptionally?

18        A.   Well, that's the telegram, I think.

19        Q.   Okay.  Almost done.  Last two questions.

20             How often did you have an occasion to interact with General

21     Mladic at Crna Rijeka?

22        A.   I met General Ratko Mladic on the 9th of May at Tvrdimici when he

23     landed with General Kukanjac at the command post of the 4th Corps.  From

24     then until arriving in the Main Staff of the Army of Republika Srpska, I

25     did not see him.  When arriving in the communications regiment, that is

Page 35229

 1     to say, Main Staff, and arriving Goljak and placing all of that under my

 2     own responsibility, from then onwards I saw him very often and I

 3     contacted with him.

 4        Q.   What are your --

 5             JUDGE FLUEGGE:  You mentioned the 4th of May.  Which year?

 6             THE WITNESS: [Interpretation] If I mentioned the 4th of May

 7     then --

 8             JUDGE FLUEGGE:  No, sorry -- no, it was my mistake.  9th of May.

 9     Which year?

10             THE WITNESS: [Interpretation] I cannot say exactly whether it was

11     the 8th or 9th of May, but it was 1992.

12             JUDGE FLUEGGE:  Thank you very much.

13             MR. IVETIC:

14        Q.   Sir, what are your impressions, as a career military officer, of

15     General Mladic as a military officer?

16        A.   A highly professional officer, fair but stern.  A person who does

17     not take defeat, does not like defeat.  A person who respected all

18     peoples and exceptionally liked his own people and protected his own

19     people.  And he and his family became victims of such views and such

20     work.

21        Q.   If you could just explain the last part of your answer as I'm not

22     following and I suspect others are not.  When you say:  "He and his

23     family became victims of such views and such work," I don't know what you

24     mean.

25        A.   Well, I think -- I think that it is well known that

Page 35230

 1     Mr. Ratko Mladic during the war lost his daughter who had a degree in

 2     medicine and then he fell ill himself.  No greater tragedy is needed.

 3        Q.   Okay.  Sir, I thank you for answering my questions.

 4             MR. IVETIC:  Your Honours, we have no further questions for this

 5     witness.

 6             JUDGE MOLOTO:  Thank you, Mr. Ivetic.

 7             Are you ready for cross-examination?

 8             MR. McCLOSKEY:  I can certainly get started.  What time do we

 9     break?

10             JUDGE MOLOTO:  Given the way we sat today, we planned to stop at

11     about five to.

12             MR. McCLOSKEY:  Okay.

13             JUDGE MOLOTO:  We've covered the 15 minutes this morning.

14                           Cross-examination by Mr. McCloskey:

15        Q.   Sir, do you believe that many thousands of Srebrenica sons and

16     husbands were summarily executed shortly after the fall of Srebrenica?

17        A.   I really do not know the exact number, but I do know that a

18     certain number were executed.  The exact number I really don't know.  I

19     am saying all of this in all sincerity.

20        Q.   I didn't ask you for the exact number.  I don't know where you're

21     getting that.  Many thousands, do you believe many thousands were

22     summarily executed?

23        A.   I really do apologise to you, but when you say "many thousands,"

24     it could have been 20.000 then.  That's the question.  I mean, I really

25     don't want to offend you, but the question is not phrased properly.  You

Page 35231

 1     know what "many thousands" means.  I cannot give an answer that would

 2     just amount to no.

 3        Q.   Roughly how many people do you think were summarily executed by

 4     General Mladic's troops at the fall -- after the fall of Srebrenica?

 5     Just rough.  Rough figure.  You were in the Main Staff.

 6        A.   I was in the Main Staff, but since this is a very serious matter

 7     and one should not calculate, I do apologise, but I cannot give you an

 8     answer.

 9        Q.   More than ten?

10        A.   I repeat:  If it had to do with personal weapons I could say

11     approximately.  However, since I honour victims, my own and those of

12     others, I cannot give just an approximate answer.  I apologise once

13     again.

14        Q.   You won't give my any answer about the number of Srebrenica

15     victims you believe happened?

16             MR. IVETIC:  Your Honours, I object.  It misstates the evidence.

17     The witness has now on three occasions answered the exact same question

18     that keeps being posted to him by saying he cannot give a exact figure.

19     So after the witness says "I cannot give an exact figure," to ask him

20     three more times to give an exact figure is inappropriate and is

21     considered badgering the witness in my jurisdiction.

22             JUDGE MOLOTO:  Objection denied.

23             MR. McCLOSKEY:

24        Q.   Sir, another chance.  Do you want to give us some idea of how

25     many victims you're willing to acknowledge, just rough, your roughest

Page 35232

 1     idea, as a serious officer of the VRS attached to the Main Staff?

 2             MR. IVETIC:  I'd like to object to this question as being vague.

 3     Now he has changed the question, talking about victims.  Victims of what?

 4     If he is talking about something that was from direct, I would like to

 5     know what it is from direct he's talking about.  If he is talking about a

 6     specific incident, he should talk about a specific incident.  If he's

 7     basing it on a prior answer of a witness, he should base it on the prior

 8     answer of a witness.

 9             MR. McCLOSKEY:  We can simplify it.  Victims of summary

10     execution.

11             MR. IVETIC:  Is that a question for me?  I'd like to continue and

12     finish my response.

13             MR. McCLOSKEY:  I'd object to his badgering the Court.

14             MR. IVETIC:  We're getting at cross purposes, Your Honour.  I

15     think I have -- I think you get the gist of my objection --

16             JUDGE MOLOTO:  I do --

17             MR. IVETIC:  -- so I will hold it to that.

18             JUDGE MOLOTO:  I do.  And I guess Mr. McCloskey's response that

19     the victims of the executions does answer that objection.

20             MR. McCLOSKEY:

21        Q.   Sir, one more time.  Can you give us your roughest belief of how

22     many people were summarily executed after Srebrenica?

23        A.   My family upbringing, then the upbringing I received during my

24     education and schooling does not allow me to exchange in that kind of

25     trade.  As for all the victims in Srebrenica and all others, I do not

Page 35233

 1     want to give mere estimates, approximations, since I really do not know

 2     what the exact figure is regarding these executions, and that is the

 3     reason I mentioned in my introduction as well.

 4        Q.   Okay.  Sir, you've testified that you were away on 13 and

 5     14 July to your birth place.  You started your testimony by telling you

 6     were born in Zvornik.  Were you -- were you in the Zvornik area on the

 7     13th and 14th of July?

 8        A.   Yes.

 9        Q.   What village?

10        A.   Lijesanj, the village I was born in.

11        Q.   And what -- how close is that to the Petkovci dam?

12        A.   The Petkovci dam?

13        Q.   Yes.

14        A.   About 40 kilometres.  On the other side.  Petkovici is after

15     Zvornik, Lijesanj before Zvornik on the northern side, on the left bank

16     of the Drinjaca river.

17        Q.   And how close is to the village of Orahovac?

18        A.   Roughly the same.

19        Q.   So you knew when you were in Zvornik on the 13th and 14th of

20     July that thousands of Muslim prisoners were brought up to the Zvornik

21     area.  It's a small area.  You knew that, didn't you?

22        A.   I did not.

23        Q.   Never heard one word about those thousands of Muslims that were

24     brought up and put in schools, scattered from Orahovac, Petkovci, Kuzla

25     [phoen], Rocevic.  They were at the Standard barracks in Karakaj.  They

Page 35234

 1     drove from Kula Grad all the way up through town to all those places, you

 2     never heard one word about any Muslim prisoners?

 3        A.   The first information about all of this, the first information, I

 4     mean, I'm speaking under oath and I'm telling the truth, the first

 5     information I received through the mass media of the Federation of

 6     Bosnia-Herzegovina.  I'm saying this in all sincerity.  I did not know a

 7     thing about any of that at that time.

 8        Q.   Did you see on TV that was played on Serb television on the 14th

 9     horrible pictures of dead and mutilated Serbs that was being played for

10     the public consumption on the 14th of July?

11        A.   I didn't see that either.

12             MR. McCLOSKEY:  If we could take the break now, I'd appreciate

13     it, Mr. President.

14             JUDGE MOLOTO:  Sir, we've come to the end of the day for today.

15     We would start again tomorrow morning at half past 9.00.  But before you

16     leave, let me just warn you that you are not allowed to speak to anybody

17     about any part of your testimony that you have given or that you still

18     have to give tomorrow, until you're excused from further testifying.

19             Is that clear?

20             THE WITNESS: [Interpretation] Clear.

21             JUDGE MOLOTO:  Thank you very much.  You may follow the usher,

22     and we'll see you tomorrow at half past 9.00 in the same courtroom.

23                           [The witness stands down]

24             JUDGE MOLOTO:  We adjourn for the day, and we'll convene tomorrow

25     morning, the 7th of May, 9.30 in the morning, in this same courtroom.

Page 35235

 1             Did you want to say something?

 2             MR. McCLOSKEY:  Mr. President, I just wanted to inform -- I

 3     should be less than an hour tomorrow.  I don't anticipate a lot of

 4     questions.  I just wanted everyone to know that.

 5             JUDGE MOLOTO:  Thank you so much, Mr. McCloskey.

 6             We stand adjourned.

 7                            --- Whereupon the hearing adjourned at 1.54 p.m.,

 8                           to be reconvened on Thursday, the 7th day of May,

 9                           2015, at 9.30 a.m.