Tribunal Criminal Tribunal for the Former Yugoslavia

Page 32583

 1                           Tuesday, 23 September 2008

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 2.16 p.m.

 6             JUDGE ANTONETTI: [Interpretation] Mr. Registrar, kindly call the

 7     case.

 8             THE REGISTRAR:  Good afternoon, Your Honours.  Good afternoon,

 9     everyone in and around the courtroom.  This is case number IT-04-74-T,

10     the Prosecutor versus Prlic et al. Thank you, Your Honours.

11             JUDGE ANTONETTI: [Interpretation] Thank you, Mr. Registrar.

12             Today is Tuesday, 23rd of September, 2008.

13             Good afternoon to the accused, to the Defence counsel, to

14     Mr. Scott and his team, and to all the people helping us out.

15             I'll first give the floor to the registrar.  He has an IC number

16     for us.

17             THE REGISTRAR:  Thank you, Your Honour.  The OTP has submitted

18     its objections to documents tendered by 1D through Puljic, Borislav.

19     This document shall be given Exhibit Number IC 00849.  Thank you, Your

20     Honours.

21             JUDGE ANTONETTI: [Interpretation] Thank you, Mr. Registrar.

22             Mr. Praljak will have the floor, he's ready, and I think he has

23     50 minutes left.

24             Good afternoon again.  You may proceed.

25             THE ACCUSED PRALJAK: [Interpretation] Thank you.  Thank you very

Page 32584

 1     much, Your Honours.

 2                           WITNESS:  ILIJA KOZULJ [Resumed]

 3                           [Witness answered through interpreter]

 4                      Cross-examination by the Accused Praljak: [Continued]

 5        Q.   Good afternoon, Witness.

 6        A.   Good afternoon.

 7        Q.   Well, yesterday we tried to shed some light on this problem of

 8     the provision of electricity and transformers.  I will be asking you some

 9     more questions about electricity and transformers in order to make this

10     quite clear in terms of some basic concepts about the provision and

11     distribution and generation of electricity.  Could you please tell me, do

12     you know that two large transformer stations, facilities in Cule, and

13     switching stations in Cule to the north of Mostar.  What was the name?

14        A.   Rastane.

15        Q.   Rastane, that at any rate in the Serb shelling in 1992 they were

16     almost completely destroyed, both the switching facility and the

17     transformer facilities.

18        A.   Yes, I do know that.

19        Q.   Could you please tell me, do you know that in Rudnik, a

20     neighbourhood in Mostar on the western bank of the Neretva River, this

21     provides electricity to a large section of the town, do you know that

22     this transformer was also destroyed in the shelling?

23        A.   Yes, I do know that.

24        Q.   Do you know that transformers that are of a greater power must be

25     out in the open because of cooling issues?

Page 32585

 1        A.   Yes, I do know that.

 2        Q.   Do you know that for cooling purposes the transformer has

 3     something that is known as transformer oil?

 4        A.   Yes, I do know that.

 5        Q.   Could you please tell us, Witness, how vulnerable is a

 6     transformer if a shell impacts nearby and then there are fragments?  What

 7     if it goes through the sheeting or the isolated cables or if it hits the

 8     area where there's transformer oil and so on?

 9        A.   Although a transformer appears to be a solid chunk of metal, it

10     is very vulnerable in fact, a vulnerable piece of equipment, because it

11     contains coils that must transfer the high-voltage electricity, the

12     coolant in the form of oil, and a number of elements switching to --

13     connecting elements and other equipment that protects the transformer

14     against sudden discharges such as those caused by lightning.

15        Q.   So if any part thereof is damaged, we can consider this

16     transformer to be out of order and out of use?

17        A.   Yes, definitely.  Now, we have to run some very thorough tests in

18     order to determine the scope of the damage.

19        Q.   If we're talking about damaged transformers, such as the one at

20     Cule, we will not be bothering the Trial Chamber with the power, things

21     like that, we don't want it to get too complicated.  Could you please

22     tell us how long does it take and what kind of blueprints and other

23     documents have to be in place, how much time, how much money, is needed

24     in order to install a transformer back in place and who should you apply

25     to do that, who should do that?

Page 32586

 1        A.   If we're talking about the Cule substation or transformer station

 2     which is close to Mostar, then we can say that it was one of the most

 3     complex transformer substations in the former Yugoslavia.  It is -- it

 4     covers a large area and it is full of all kinds of electrical equipment,

 5     all kinds of transformers of various sizes, switching facilities,

 6     measuring equipment, optical cables, electronic equipment, and other

 7     things like fuses and so on.  In order to build such a substation, you

 8     have to invest a large amount of money, tens of millions of euros, that

 9     would be the order of magnitude.  And I think that Cule cost around 20

10     million euro, that's off the cuff, I seem to recall this figure.  The

11     reason why I know that is because the -- in order to fix, to repair, such

12     a substation, you first need to do some thorough tests.  You have to do

13     the programme and also the project, how to do it, what needs to be done,

14     and in what order.  As far as the Cule substation is concerned, I know

15     that because I was interested in this, that it took eight years to

16     reconstruct the substation and that it cost approximately 10 million euro

17     to do it.  That's the information that I have at my disposal now, because

18     we're not talking about a single transformer, it's a series of

19     transformers of differing sizes used for various voltages in the

20     transformation process.

21        Q.   Thank you very much.  But let's take just one transformer.  Who

22     manufactures it?  Where do you order it?  And if you have the money, if

23     you have the -- all the blueprints and the project documents you go to

24     Siemens and how long does it take for them to deliver it?

25        A.   Well, transformer equipment is manufactured by a number of

Page 32587

 1     producers, but the most complex transformers for high-voltage systems

 2     have to be ordered especially and they're usually ordered abroad.  So

 3     smaller transformers are manufactured as standard equipment.  So you can

 4     get it sooner, but the larger the transformer -- it's a special-order

 5     equipment.  It has to be constructed in a special way and then there is a

 6     longer delivery time.  As far as I know, this transformer, the most

 7     complex one, the largest one, first of all let me say that those

 8     transformers in the former Yugoslavia were manufactured in several

 9     places, in Serbia, in Sarajevo, in Energoinvest, and they're still being

10     manufactured in Zagreb in Rade Koncar, their production plant, but the

11     most complex ones are brought abroad, usually from Germany, from Siemens.

12     The delivery time for such transformers is more than two years.  So it

13     takes you some time to define what you need and then to negotiate.  And

14     once the contract is signed, you need to wait two years for the delivery.

15        Q.   Thank you very much.

16             THE ACCUSED PRALJAK: [Interpretation] Could I please ask the

17     usher to take four documents to put them on the table and then we'll look

18     at the first one.

19        Q.   Before you get those papers, could you please tell me if we're

20     talking about smaller transformers, to 10 to 0.4 kilovolts, then the

21     electricity is distributed to households and elsewhere.  In Mostar how

22     was this done?  Was it done via underground cables or overhead cables?

23        A.   What we call the distribution grid.  When the last transformation

24     is done down to the 0.4 voltage, that would be 220 volts.  This is

25     usually done by cables in towns, but if you are not in a town, in other

Page 32588

 1     areas, it is usually done by aerial cables that are put on poles, wooden

 2     poles or concrete poles.  This was sometimes also -- this is sometimes

 3     done by wire also.  But in town it's usually done in urban areas, this is

 4     usually done via underground cables.  You have to bear in mind that this

 5     is more expensive so you can't always do that.

 6        Q.   Could you please look at the first image.  So this has nothing to

 7     do with what we would have drawn as engineers.  This is something that is

 8     done for the laypersons, to be able to see how gradually the voltage is

 9     reduced, we can see here from 220 to 110 kilovolts, then larger numbers

10     of transformers are switched on so that we can go down to what we need.

11     My question to you is:  For a town such as Mostar, which has its

12     population and also various businesses, to be supplied with electricity,

13     is there a whole network of transformers of various sizes and so on?

14        A.   Well, you picture this in a proper way.  Usually there are

15     substations, transformer stations in the outskirts of the towns, and they

16     transform the voltage from 2010 and 110 kilovolts to lower voltages.  Why

17     are they located on the outskirts of the towns?  Because electricity

18     needs to be brought there by high-tension transmission lines, and those

19     lines cannot be put around houses and inhabited areas.  So you need to

20     have corridors which are relatively unpopulated.  And we're talking about

21     high voltage which could lead to unwanted consequences.  So electricity

22     at a lower voltage, usually 35 kilovolts, is brought into the town and

23     then you have the distribution grid where the voltage is 35 kilovolts,

24     and then it is again transformed at the end-user point to lower voltages.

25        Q.   Thank you very much.  We will deal with just two more things.

Page 32589

 1     First, if an electricity power system is kept at the limit of its

 2     potential because there is not enough electricity and somebody switches

 3     on another transformer, is it possible for the grid to simply black out

 4     or parts of it to go down?

 5        A.   Well, it is highly possible because every substation, every piece

 6     of electrical equipment, has fuses in place that make it impossible to --

 7     make it possible to limit the consumption to a certain level, that's a

 8     fuse cut-out.  If it goes above this limit, then the fuses go out.  If

 9     the fuses -- if proper fuses are not installed, then this brings into

10     danger this piece of equipment, it is no longer protected by the fuses.

11     That is why every time consumers tap into the lines in an unauthorised

12     manner, and sometimes when they even cut themselves off from the grid,

13     this can cause problems on a wider scale, in a wider area, and sometimes

14     even complete black-out.  This is why power systems are always linked up

15     to cover the broadest possible area, and this is why the whole of Europe,

16     the whole grid in Europe, is linked up.  There are other reasons too,

17     synchronisation to ensure the quality of the grid.  This is also another

18     important reason why the grid is fully linked.  And the third important

19     reason is to be able to exchange power because you always have moments

20     where you have a surplus or a shortage of power, and then you can

21     exchange.

22        Q.   The last question related to electricity.  Let us assume that

23     somewhere on the transmission line leading to Stolac or somewhere else,

24     one or two transmission pylons were torn down because of the shelling,

25     for instance.  Can you explain to the Judges and everyone else in the

Page 32590

 1     courtroom, what does it take to repair it.  Who can do it?  What

 2     transportation do you use to get there, mules or vehicles, how difficult

 3     is it to splice together the lines.  How difficult is this in terms of

 4     technology and in terms of expense?

 5        A.   Well, if something like that occurs, if a transmission line pylon

 6     gets damaged, which means that the transmission line is cut, and often it

 7     is only one line that is down, it is necessary to get there to the scene,

 8     those high-tension lines are usually in rugged terrain and they are

 9     accessible only on foot.  And you have to carry all the equipment, all

10     the supplies, either using beasts of burden or just carrying there

11     yourself.  It is always necessary to have experts with you, to have all

12     the supplies and all the testing and measuring equipment, and to be able

13     to reach the site.  If this site is inaccessible, if mines are laid in

14     that area - and that was often the case - then you first have to secure

15     the area so that people could move around there, check for mines, demine

16     the area, and then move on and fix it.

17             Usually local companies have the capability to repair the

18     lower-tension transmission lines.  As for the high-tension power lines,

19     they're unable to repair them.  For example, if a pylon is damaged, it

20     needs to be procured from the supplier, you don't have these in reserves,

21     you have to purchase it, install it, and for this you need time and money

22     and also the technical staff.

23        Q.   Thank you very much.  Well, could you please - and this is the

24     usual practice in this Tribunal - place a date -- today's date and your

25     initials on this sketch that you have in front of you.

Page 32591

 1             JUDGE ANTONETTI: [Interpretation] Let us give an IC number.

 2             Mr. Registrar, please.

 3             THE REGISTRAR:  Yes, Your Honour, the diagram shall be given

 4     Exhibit Number IC 00850.  Thank you, Your Honour.

 5             THE ACCUSED PRALJAK: [Interpretation].

 6        Q.   Can you look at the second sketch now, please.  Again, I did the

 7     best that I could in the technical options that I had.  I sketched in

 8     Mostar and those towns that I was able to number which were part of the

 9     regular PTT Mostar network.  These cities, when phone calls were made

10     from them, the communications first went to Mostar and then further out.

11     So could you please explain to us how this functioned and then if we need

12     to add anything we will do that.

13        A.   Mostar, as one of the transit switchboards or centres, of which

14     there are four in Bosnia and Herzegovina, is linked with other transit

15     exchanges and then the main exchanges are connected to that.  In this

16     case, these are Livno and Trebinje, and those main exchanges are followed

17     by some node or end-user exchanges.  All of those exchanges are directly

18     connected to Mostar, and this is done by air.  It doesn't mean that each

19     location has a separate device.  You can dial Mostar-Trebinje and then

20     link Bileca with Mostar via Trebinje.  In principle, the connections are

21     overhead ones, aerial ones.  So if Mostar falls, all of them fall as

22     well; that is the idea.

23        Q.   Can you please initial this sketch and give it a number.

24             THE REGISTRAR:  Your Honour, the second sketch shall be given

25     Exhibit Number IC 00851.  Thank you, Your Honours.

Page 32592

 1             THE ACCUSED PRALJAK: [Interpretation].

 2        Q.   Let's look at the next sketch.  Yesterday, we had a little more

 3     complicated sketch yesterday.  We see how Mostar was linked with Sarajevo

 4     by coaxial cable, and as far as I know Sarajevo was connected with

 5     Belgrade and Zagreb also by coaxial cable, and then Mostar via those

 6     relays as we saw yesterday was linked with Split, Podgorica, and the

 7     radio systems as well as by electro-magnetic waves.  Is that correct?

 8        A.   Yes, it is.

 9        Q.   Can you tell me one more thing.  Let's clarify that do you know

10     that all the connections that went outside the country went through

11     Belgrade, the capital of the former Yugoslavia, all the connections to

12     Europe would first flow to Europe; and then from Belgrade they could be

13     transferred outside, farther out.  Is that correct?

14        A.   No, that is not quite correct.  There were international

15     connections, connections with foreign countries went via Belgrade and via

16     Zagreb and to a limited extent also via Ljubljana.

17        Q.   All right.

18        A.   Yes, yes, what I'm saying is the truth.

19        Q.   Yes, I understand.  Yes, that is in the transcript.  We're not

20     going to deal in detail why coaxial cable is important and how many

21     simultaneous telephone conversations you can conduct by using such a

22     cable.  We are going to talk about these radio relay system of

23     communication.  Can you please try to explain to the Chamber and the

24     Prosecutors what happens and what sort of electronic equipment you need,

25     what happens to human speech that needs to be transferred to a -- some

Page 32593

 1     sort of electronic signal, then you need to conduct this signal via

 2     oscillators, and so on.  You don't have to be overly expert on this, but

 3     can we find out how sensitive and complicated this and how expensive it

 4     is if there is any degree of destruction at any section of the network

 5     from the source of energy, antennas, the transformation of voice into the

 6     signal, and so on and so forth.

 7        A.   Well, this is quite complex.  I'm going to try to be as simple as

 8     I can, but in principle if we're talking about connections between

 9     specific telephone exchanges they are effected in two ways -- actually,

10     not in two ways.  There are two kinds of apparatus, one type is

11     transmission equipment and the other type are multiplex equipment.

12     Transmission equipment is used to convey a certain signal from one

13     location to another so that you can use just regular cable, symmetrical

14     cable, coaxial cable, or optical cable for these purposes, and you can

15     have radio connections, radio relay connections, and satellite

16     connections, so that is the transmission part.  And the transmission

17     equipment is also different according to its capacity.  They can only be

18     able to cover one telephone call or tens of thousands of telephone calls

19     simultaneously.  In order to have -- to be able to have several telephone

20     conversations at the same time, you have the so-called multiplex devices

21     where several speakers or speakers' telephone cables are connected to a

22     device, the device can mix them all, and at the out -- exit you have just

23     one cable where all of those are merged.  Then you have the analog system

24     and you have the digital system in this sense.

25             At that time we were still using the so-called analog system.

Page 32594

 1     Today this is an outdated system and the digital system, the multiplex

 2     and radio relay devices, are used; coaxial cable is not used so much;

 3     optical fibre cable is used now in order to be able to transmit at large

 4     distances.  I don't know if I answered.  I mean it took a while, but...

 5        Q.   No, no, it's all right.

 6        A.   Well, these are very sensitive, very complicated devices in all

 7     kinds of ways, and the radio relay cables are laid underground.  The

 8     coaxial cable that we're talking about is laid along the railway tracks.

 9     I worked in the PTT, and because of that, the fact that the cable is laid

10     down along the railway tracks, especially when the railway tracks are

11     supplied with electricity, then that is threatened in several ways

12     because of bridges, overpasses, underpasses, and different effects of the

13     currents that are -- can be found around those railway tracks.

14             As for the radio relay devices, they would need to be at

15     prominent positions.  They would need to have towers and these large

16     antennas need to be placed there, the dish antennas, which can be quite

17     large.  In order to cover a certain area you would need to have at tops

18     of hills or mountains some kind of relay station.

19        Q.   Yes, I wanted to hear this part about the signals entering at one

20     end and being mixed at the other and coming out as a single cable at the

21     other, and this is all a complicated process.  This is what I wanted to

22     hear.

23        A.   Yes, that is correct.

24        Q.   The second thing, when the signal is being transmitted from one

25     device to the other, it's very important to know here if there is the

Page 32595

 1     possibility of deviation or curvature of such a signal, can it curve

 2     around a hill depending on the type of waves that are being used?  Why is

 3     it essential to have optical visibility between one device that is

 4     transmitting the signal and the other one that would receive or amplify

 5     the signal?

 6        A.   For these purposes we're using devices that operated extremely

 7     high frequencies, these are ultra-short wave-lengths, also high-frequency

 8     waves which are measured in gigahertz, and in this case this idea of

 9     curvature is out of the question, there has to be absolutely --

10     visibility, optical visibility, between the two points that are being

11     connected and there has to be a short distance between these points.  The

12     greater the capacity, the distance is reduced.  In the case when we have

13     smaller capacities, then you can use, instead of the relay stations, some

14     kind of passive, what we call a mirror, which redirects the signal in the

15     same way that a mirror would redirect a beam of light.  So because you

16     have to have this visibility, if you want to go from Mostar outside, at

17     that time we found a relay station at a location near Stolac on a hill

18     called Hrgud at the Paric elevation, and that's where the base station

19     was built.  It was connected up and the connection from Mostar towards

20     Podgorica and towards Split was transmitted via that station.  At that

21     time the station was, let's say, in the Serb hands.

22             JUDGE ANTONETTI: [Interpretation] Witness, all this is very

23     technical, but I'm trying to bring this back to our problem, the problem

24     we'll have to solve and we'll have to decide on regarding military

25     issues.  When a military unit, ex-unit, for example, is on the field, and

Page 32596

 1     this military unit is supposed to contact its chain of command, the

 2     communications system of these military units through radio -- I believe

 3     that at the time unless you had satellite phones you communicated with

 4     radio systems.  So does this automatically imply the need for relay

 5     stations or these passive mirrors, as you called them?  In other words,

 6     when you have a military communications system, does that mean that in

 7     the territory covered you need to have relay stations?  Or is there a

 8     possibility for the military to use talkie-walkies or for another system

 9     to communicate from one unit to another without going through radio

10     waves?

11             THE WITNESS: [Interpretation] Mr. President, I spoke here about

12     the telecommunications system used by telecommunications companies, at

13     least at that time.  I didn't speak here about military uses or military

14     equipment that is used by units of the military in the field.  This is

15     completely different type of equipment, and I can say something about

16     that too if required.  But we talked about the telecommunications system

17     used by all citizens and the business community as well as some military

18     units to a certain extent in this period.

19             JUDGE ANTONETTI: [Interpretation] Very well.  I understand.

20     Thank you.

21             THE ACCUSED PRALJAK: [Interpretation] Your Honours, I also

22     focused here on the witness clarifying the three things that are in the

23     indictment, that the right side was responsible for cutting electricity

24     or that the HVO can be blamed for the television signal being cut or for

25     telephone lines being cut, and so on.  I think everything about that is

Page 32597

 1     quite clear.

 2        Q.   I want to ask you just one more thing.  The coaxial cable laid

 3     down next to the railway tracks - and we will look at the two bridges

 4     which were knocked down - how many places near Sarajevo were not either

 5     under the control of the HVO or the B&H army were places where these

 6     cables were laid?

 7        A.   Which period are we talking about?

 8        Q.   The period of 1992 and 1993.

 9        A.   If we're talking about the period before Mostar was, let's say,

10     liberated from the Yugoslav Army, then it can be said that from Mostar to

11     the north for a considerable distance the cable was in some way blocked

12     or threatened.  I just need to mention one more thing.  The coaxial

13     cable, it doesn't mean that you have electronic equipment in Mostar and

14     electronic equipment in Sarajevo.  It is of such a nature that you need

15     to have an amplifier each few kilometres, and these nodes need to be

16     supplied with electricity from the network.  In some sections the

17     electricity supply came from the end users, but in between it had to

18     receive an electricity supply from somewhere.  So the Sarajevo end did

19     receive electricity from the area that was closer to Mostar, but the area

20     that was immediately close to Sarajevo depended on the Serbian forces.

21     But we knew that it was not possible to provide electricity to Sarajevo

22     from Mostar.  This is something that we saw and that we knew.

23             JUDGE ANTONETTI: [Interpretation] Witness, let me go back to the

24     telephone systems.  Earlier we talked about electricity.  Let's talk

25     about the telephone system.  We have on the ELMO this drawing made by

Page 32598

 1     General Praljak on the telephone network.  I see that when you want --

 2     when you're in Mostar you want to call Zagreb, you have to go through

 3     Sarajevo.  If from Mostar you're calling Paris or Geneva, you have to go

 4     through Sarajevo and Belgrade.  Now, given this drawing, let's assume

 5     that Mostar is isolated suddenly; then, according to you, technically if

 6     someone in Sarajevo blocks the system or bypasses or derogates the

 7     system, I would like to know whether in Mostar it totally -- the

 8     communication is cut.  If someone in Sarajevo or, maybe also in Belgrade,

 9     decides to disturb or tamper with the telephone line, I'd like to know

10     whether it's technically possible.

11             THE WITNESS: [Interpretation] By your leave, I would like to

12     clarify this a little bit.  You can see that there is a large

13     telecommunications system in Mostar branching out in three directions:

14     Sarajevo, Podgorica, and Split.  At that time if the coaxial cable went

15     down in any way, whether it was -- it was switched off or out of order,

16     we had an alternative solution via the other two systems, Split or

17     Titograd, to communicate with the rest of the country or with abroad.

18     The only problem -- in fact, even if two segments were down, again we

19     were able to communicate with the whole area of the former Yugoslavia and

20     with abroad because, as I pointed out earlier, Zagreb also had links to

21     abroad.  The only problem was when all three segments were down, in that

22     case Mostar and the surrounding area was no longer connected with the

23     rest of the world.  And that's what happened to us.  It was not only

24     Hrgud that fell which caused disruption to the radio relay system towards

25     Split and Titograd, but there was another problem, the equipment in the

Page 32599

 1     building itself was damaged and so were the bridges, the bridges were

 2     knocked down, so we were completely cut off.

 3             JUDGE ANTONETTI: [Interpretation] Witness, does this mean that

 4     General Praljak's drawing is not comprehensive?  Because if you want to

 5     communicate with the rest of Europe or with the world from Mostar, if you

 6     can't go through Sarajevo or Titograd because they're down, you can go

 7     through Split.  So on this drawing, shouldn't he have also added world

 8     and Europe at level of Split and Titograd?  Isn't that missing from the

 9     drawing?  Unless I'm mistaken, but if I've understood you right, I

10     thought that if it doesn't go through to Sarajevo on the coaxial cable,

11     you've got a back-up system either through Split or through Titograd.

12     That's what I understood anyway.

13             THE WITNESS: [Interpretation] Mr. President, this sketch tells us

14     something about the situation in Mostar, but this is just a part of the

15     overall system.  At that time Split was linked with Zagreb, Zagreb was

16     linked with Belgrade, and Titograd had another link with Belgrade, so

17     there were all kinds of communication lines in place.  The schematic

18     would be much more complex.  I myself cannot now explain each and every

19     detail of it.  But since Mostar had only three systems in place:  Coaxial

20     cable towards Sarajevo and two wireless radio relay systems that went

21     through the relay station at Paric, and when we couldn't use Paric or

22     when the cable was down for whatever reason, on purpose, if it lost power

23     or if it sustained any damage, we in Mostar were cut off, not only Mostar

24     with the rest of the world but also Mostar with the region, the rest of

25     the region, we could not communicate.

Page 32600

 1             THE ACCUSED PRALJAK: [Interpretation]

 2        Q.   His Honour Antonetti asked you a somewhat different question.

 3     Assuming that Hrgud, where this relay station was located, that went then

 4     went on to the Biokovo relay station and on to Split; is that correct --

 5        A.   Yes, that's correct.  No, no, not Biokovo but near Plejin Vrh

 6     near Posusje.

 7        Q.   Near Posusje.  But assuming that Hrgud was not in Serb hands, as

 8     you indicated, even if Split could be reached, His Honour Antonetti asked

 9     whether the Split exchange had the ability to communicate with Europe or

10     if it had to go through Zagreb and some channels.  But I am doubtful

11     about the time when Zagreb was allowed to have direct links with abroad

12     by Belgrade because Madam Holjevac, a friend of mine, was in charge of

13     development there.  But can you tell me whether Podgorica and Split in

14     the former Yugoslavia had direct links with abroad or if it had to go --

15     well, let's say partially through Zagreb but mainly through Belgrade?

16        A.   Well, I can't really tell you that with any certainty, but at the

17     time when I worked in the PTT the communications with abroad - I know

18     that because I know that Zagreb fought really hard to be given the right

19     to communicate directly with at least some of the countries, but the

20     moment you have a direct link with any given country you can then

21     communicate with the rest of the world, but in the beginning Belgrade was

22     the only node from which you could communicate with abroad.  But later on

23     Zagreb was allowed to have some links, and so did Ljubljana, but to a

24     very limited scope.  But I want to say that Split had very good links

25     with Zagreb, Podgorica had very good -- a different kind of link with

Page 32601

 1     Belgrade through Serbia.  So for them, losing this communication line

 2     through Mostar did not mean losing contact with, let's say, Belgrade.

 3     The capacity was somewhat reduced, but they could still have the

 4     communication lines that they had.  If I knew that you would be asking me

 5     those questions, I would have prepared better and would have given you a

 6     better idea.

 7        Q.   No, no, this is quite enough, thank you very much, about the

 8     struggle to establish communication lines with abroad.

 9             JUDGE TRECHSEL:  Excuse me, Mr. Praljak.  In my view, it is not

10     quite enough because I would like to know at what moment Zagreb was

11     beginning to have contact with other countries.  You said first and then

12     you said later.  That's a bit vague.  Could you give an indication?

13             THE WITNESS: [Interpretation] Your Honour, I spoke about the

14     time-period while I was still an employee of the PTT.  That was before

15     1978.  At that time, at the time when I joined the PTT and I started

16     working there, we did not have any automatic exchanges in our area at

17     all, in Herzegovina.  It was set up gradually, and as it was being set up

18     the international lines were also set up.  The first international lines

19     were set up from Belgrade, but later on Zagreb managed to get some but

20     that was all before the 1980s.  At the time that we are now talking

21     about, Zagreb definitely had communication lines with the rest of the

22     world; I can say that.  So if we in Mostar were able to reach Split, we

23     were able to reach the rest of the world, provided their lines were up.

24     And as far as I know, throughout the war in Croatia and in Dalmatia, they

25     were able to maintain communication lines with Zagreb and were able to

Page 32602

 1     maintain the telephone traffic.  There were minor disruptions but it was

 2     functioning.

 3             JUDGE TRECHSEL:  Thank you very much.

 4             THE WITNESS: [Interpretation] You're welcome.

 5             THE ACCUSED PRALJAK: [Interpretation].

 6        Q.   Well, with these corrections, could you please sign this sketch,

 7     put a date on it, and can we please have the IC number.

 8        A.   Well, this sketch is quite clear to me, but if you're asking me

 9     if I'm being asked those questions, then somebody might say that this is

10     actually not very good.  I would need to make a proper schematic

11     actually.

12        Q.   Okay.  Then we'll just forget about it.  Could you please look at

13     the last sketch --

14             JUDGE ANTONETTI: [Interpretation] Mr. Registrar, we need a number

15     for this document on the Sarajevo-Belgrade-Titograd-Zagreb telephone

16     schematic.

17             JUDGE TRECHSEL:  Perhaps it's useful to assure you, Witness, that

18     when you sign this that does not mean that it is regarded as your

19     testimony; it is just a formality because you have looked at it.  That's

20     all.

21             THE REGISTRAR:  Your Honours, the third sketch shall be given

22     Exhibit Number IC 00852.  Thank you, Your Honours.

23             JUDGE ANTONETTI: [Interpretation] We have a question, please.

24             JUDGE MINDUA: [Interpretation] I have a question to Mr. Praljak

25     on the relevance of this document.  If I understood what our witness

Page 32603

 1     said, he was -- this was when he was working in the PTT and that was

 2     before 1980.  I would like to know whether this schematic can be applied

 3     to the relevant period in the indictment.

 4             THE WITNESS: [Interpretation] Thank you very much for this

 5     question.  There were no major changes in relation to this schematic in

 6     the period before the war.  It was only during the war and after the war.

 7     The whole of Bosnia and Herzegovina had a network of optic fibre cables

 8     put in, so now the situation is quite different.  But at that time this

 9     was new equipment that was functioning quite well that hasn't been

10     depreciated yet, so that was the situation.

11             JUDGE MINDUA: [Interpretation] Thank you.

12             THE ACCUSED PRALJAK: [Interpretation] Thank you very much.

13        Q.   We will agree that if we disregard the links with Belgrade and

14     Ljubljana and Zagreb and then abroad, that the essence here is the radio

15     links through Hrgud to Split and in whose hands those facilities were.

16     Could we please look at the last schematic.  This is a rough outline of

17     Mostar, eastern Mostar, the Neretva River, the western Mostar, and the

18     Spanish square, Tito's bridge, Sant iceva Street, and there at Bulevar

19     you can see the building where the telephone exchange was and all the

20     other facilities.  Is that correct?

21        A.   Yes, this is more or less correct.

22        Q.   Could you please take a pen or I can give you a pen, could you

23     please indicate how the coaxial cable was laid from the post building.

24     You can see the customs bridge here.  Could you please just draw this in.

25        A.   [Marks]

Page 32604

 1        Q.   So it crossed the customs bridge to the left bank of the river

 2     Neretva and then to the north then to the railway bridge and it folded

 3     back and went north.  My question to you is whether in 1992 whether those

 4     two bridges were blown up.  We're not going to be talking about other

 5     bridges.

 6        A.   In 1992 both of those bridges and other bridges were blown up.

 7        Q.   Yes.  Another question.  The other telephone installations from

 8     the post building, post office, to the eastern part of Mostar, did they

 9     go underneath the bridges?

10        A.   Yes, practically across every bridge in Mostar there were all

11     kinds of cables, with the exception of the Old Bridge.  As the city

12     developed, the larger cables were set up, larger-capacity cables, and

13     they were laid exclusively across the bridges.

14        Q.   And so once the bridges were torn down, this all collapsed too?

15        A.   Yes.

16        Q.   Thank you very much.  Could you please initial this.  This has no

17     meaning at all.  This does not mean that this is your testimony.

18        A.   [Marks]

19             JUDGE ANTONETTI: [Interpretation] Mr. Registrar, could we have a

20     number.

21             THE REGISTRAR:  Yes, Your Honour.  The fourth sketch shall be

22     given Exhibit Number IC 00853.  Thank you, Your Honours.

23             THE ACCUSED PRALJAK: [Interpretation]

24        Q.   Our last topic, it's television signal.  Let us assume that

25     Sarajevo Radio and Television has enough power and broadcasts a strong

Page 32605

 1     signal from its powerful aerials.  Now, can this signal be received in

 2     Mostar without any other equipment, relay equipment?

 3        A.   No, it cannot be seen in Mostar without relay facilities.

 4        Q.   Can you explain to the Judges what is the frequency of the

 5     signal, how strong must it be, is there any curvature, or does it need to

 6     be linear, whether the repeater at Velez was the prerequisite for the

 7     signal to be received in Mostar from Sarajevo, not only the one in Velez

 8     but the repeaters that were also in Serb hands.  So could you please

 9     explain all this to the Judges.

10        A.   The TV signal - and there's also the audio for the -- to coincide

11     with the video signal - requires a broad spectrum in order to be

12     transmitted, and the transmission has to be high quality because it is

13     such a broad spectrum.  And this can be transmitted using high-frequency

14     equipment.  The equipment is actually similar to the equipment used for

15     voice transmission.  Sarajevo did broadcast its signal to Bjelasnica.

16     There was a relay station there and it had a very, very strong TV signal

17     transmitter that covered this whole area.  As for Mostar itself, it was

18     covered from Velez but that was not sufficient because Mostar is in the

19     shadow of Velez so to speak so that only parts of western Mostar received

20     the signal from Velez, which is why even before the war there was a small

21     station, Planinica which was where the TV signal was broadcast into

22     Mostar.  Similar small relay facilities were set up in other areas to

23     ensure the reception of the video signal throughout Bosnia and

24     Herzegovina.  So the moment when the signal at Velez was out, Mostar lost

25     its feed, video feed, from Sarajevo.

Page 32606

 1        Q.   First question:  How tall was the tower at Velez with all the

 2     dishes as they're colloquially known?  There were quite a few things up

 3     there.  How tall was it, to your knowledge?

 4        A.   Well, at that time I worked in the PTT when this facility was

 5     being constructed.  It is a very tall tower.  I can't give you the exact

 6     figure now, but I think that it is at least 35 metres tall.  But it's a

 7     really massive tower.  It was done -- it was built using steel, it's

 8     tubular design, and it had to be done like that because Bjelasnica and

 9     Velez relay stations are at very great height, Velez is about 2.000

10     metres and Bjelasnica even more than that.  So in winter-time, the

11     conditions there are quite impossible, wind, ice, snow.  So the aerials

12     on Velez were actually protected using special equipment.

13        Q.   Yes, and you have to have power sources?

14        A.   Yes, definitely.

15        Q.   Do you recall when you no longer could see the tower at

16     Velez - and you will agree that Velez is the mountain that goes up on the

17     east side of Mostar?

18        A.   We stopped seeing it in June or maybe July 1992, that was the

19     time when the Yugoslav forces pulled out.

20        Q.   So we can say that when they lost the battle, when they were in

21     retreat, that the -- after that time this tower was no longer there.

22     Tell me something else, if we take as a hypothesis that Velez remained in

23     place and that Bjelasnica was gone, we agree then that sometime in July

24     or June 1992 this was torn down, this was destroyed, this tower?

25        A.   Yes, we could no longer see it.

Page 32607

 1        Q.   Another question.  Now let us take as a hypothesis that all this

 2     equipment at Velez for the reception of the signal to the western side,

 3     and then you had to put something in place for the eastern side because

 4     it was in the shadow although it was above Mostar, although there can be

 5     no curvature if you have such a high-frequency signal; if the buildings

 6     are in the shadow they cannot receive the signal.  Is that correct?

 7        A.   Yes, that is correct.

 8        Q.   Let's assume that everything is all right at Velez, but, for

 9     example, that Bjelasnica is in the Serb hands, the Army of Republika

10     Srpska, and had any kind of strong signal been broadcast could this

11     signal have been received at Velez?

12        A.   No, it could not have been.  The only possibility was that

13     possibly it could be sent from some other elevation, but right now I

14     cannot say that any elevation existed.  The Velez location received its

15     signal from Bjelasnica, the antennas were directed towards Bjelasnica so

16     it was not simple just to turn them somewhere else.

17        Q.   Thank you very much.  Let's look at three more documents and then

18     we will be done, document 1D 02670, 1D 02670.  You saw the document

19     yesterday and the sketch that you signed is something that accompanies

20     this document.  I would just like you to look together with me at the

21     document.  We see that it was signed by Enes Santic, an electrical

22     engineer, and can we look at the first page of the Croatian text where it

23     says that Mostar was a key communications centre before the war and that

24     it had experts for design and construction and that it was possible to

25     set up a certain connection with the help of experts.  Is it possible

Page 32608

 1     that all those connections with the technical and financial generous help

 2     of Republic of Croatia -- that's how it was done, that all those

 3     connections were set up with the technical and financial help?

 4        A.   Yes.  It's true that at that time when Mostar lost its

 5     connections with western Herzegovina, it was essential to link the

 6     locations in western Herzegovina to Split; and this could have been done

 7     by using existing equipment and by changing the location of that

 8     equipment to a certain extent.  Also, the reserve equipment could be used

 9     that was at the disposal of the PTT and the spare equipment of UNIS PTT

10     which relocated its equipment from the factory, transferred it to western

11     Herzegovina, and had some options to do something in that regard.  The

12     HPT Zagreb, the Croatian PTT, especially the telecommunications centre at

13     Split, at that time did assist for all of that to be finished and

14     completed.

15        Q.   I'm going to read just a couple of things for you.  It says:

16     "According to the estimates, the damage on PTT elements systems and

17     equipment only in Mostar are valued at $28 million US."

18             Would you agree with this estimate?

19        A.   This report was written by Mr. Enes Santic.  At the time we were

20     not even able to go about attempting to assess the actual situation, but

21     it's a fact that a telephone exchange of 14.000 connections was

22     completely burned.  There was not a single part of it that could be used.

23     The antennas were completely destroyed, the antenna poles were destroyed.

24     As for the rest of the equipment, we didn't know what state it was in.

25     It was damaged and it would have required months of work by qualified

Page 32609

 1     personnel, qualified personnel, it's something that we could not have

 2     done without the help of the Ericsson factory in Zagreb, the Nikola Tesla

 3     factory, which installed those exchanges.  As for other equipment we

 4     needed UNIS's assistance and the help of other suppliers like Italian,

 5     German suppliers like Siemens, Nera from Norway, and so on and so forth.

 6             JUDGE ANTONETTI: [Interpretation] Mr. Praljak, you have used one

 7     hour and five minutes already.  I suppose, therefore, that the other

 8     Defence teams won't have any questions for this witness.  Please

 9     continue.

10             THE ACCUSED PRALJAK: [Interpretation] Yes, Your Honour, no others

11     will have questions so I'm going to finish quickly with a couple of more

12     documents.

13        Q.   The next document in the series is 1D 02671, also signed by

14     Santic whom you said that you know.  He says in the first sentence:  "The

15     telecommunications building in Mostar was severely damaged after a number

16     of days of bombing.  Scores of missiles or shells that fell on this

17     building and close to the building caused damage to the roof and side

18     walls ..." and so on and so forth.

19             In the fourth paragraph it says:  "The telecommunications systems

20     suffered complete damage," which you confirmed.

21             And then on page 2 in the Croatian text he says in Article C:

22     "We are currently working to set up telephone communications with Siroki

23     Brijeg, and for that purpose we are assembling a 12-channel device.  Via

24     Siroki Brijeg it will be possible to establish the connection with

25     western Herzegovina and Dalmatia."

Page 32610

 1             Can you please tell us, is it correct that a coaxial cable was

 2     installed overhead towards Mostar, and then that supported an entire

 3     exchange?

 4        A.   I'm going to explain very briefly.  At that point in time, Mostar

 5     lost all communications because of major damage with its neighbours and

 6     with the world.  The only option we had at the time was to lay coaxial --

 7     actually, regular cable, it wasn't even coaxial cable at the time, from

 8     Siroki Brijeg to Mostar, and we had to use wooden poles and surface

 9     ground to lay this cable.  We had no time to dig it in.  It was not

10     possible to do it either because at the time there was still the danger

11     of shelling.  So in this way Mostar was secured with first just temporary

12     connections, we installed a manual telephone switchboard, we returned 40

13     years back, and connected this manual switchboard to Siroki Brijeg and

14     connected it also to a private house telephone exchange of the Ministry

15     of the Interior.  And we set up the most essential connections in that

16     way, and then we proceeded step by step to improve this system on a daily

17     basis.  I'm just talking about the sequence of events now.

18        Q.   Thank you very much.  Can we look at the last document 1D 02672,

19     it's a report of the 30th of June, 1997.  This is what I can see, 07, so

20     1997.  On the first page at the bottom, in the last third of the Croatian

21     text, it says:  "In order to provide for any kind of communications,

22     aerial telephone cable was laid down quickly in the direction

23     Mostar-Siroki Brijeg ..." and so on and so forth.

24             And then it says:  "At the time the only possibility of

25     communicating with the world was via Split through a specially built

Page 32611

 1     system and mobile stations of the telecommunications system from Croatia

 2     that could have been used in limited areas covered by the signal from

 3     Biokovo."

 4             You already testified about that.  I think there's nothing

 5     disputable about that.  Is that correct?

 6        A.   Yes, that is correct.

 7        Q.   And at the bottom it says:  "The Split telecommunications centre

 8     donated a telephone switchboard with a capacity of 480 connections, which

 9     was installed in a truck."

10             Are you aware of this?

11        A.   Yes, I am.

12        Q.   On page 2 towards the end of the first third on the text on the

13     page it says:  "By persistent work and efforts of the staff and with the

14     help of the UNIS Mostar and Nikola Tesla staff, and especially the

15     telecommunications centre Split, we managed to establish

16     communications ..." and so on and so forth.

17             Do you also agree -- well, we have no reason --

18        A.   Well, I actually wrote that.

19        Q.   All right.  Just one more thing, please.  The Nikola Tesla

20     factory which manufactured most of the telecommunication equipment parts

21     before the war began and during the war only had business and technical

22     cooperation with Ericsson.  Ericsson was not an owner of Nikola Tesla; is

23     that correct?

24        A.   Yes, it is.

25        Q.   So Ericsson became the owner of a major part of the Nikola Tesla

Page 32612

 1     capital only after the war in Croatia ended; is that correct?

 2        A.   Yes, that's correct.

 3             THE ACCUSED PRALJAK: [Interpretation] I have no further questions

 4     for this witness.

 5        Q.   Sir, thank you very much.  We tried to clarify things a little

 6     bit and I thank the Trial Chamber.

 7        A.   Thank you.

 8             JUDGE ANTONETTI: [Interpretation] Very well.

 9             Well, the best thing to do would be to have the usual break now,

10     following which the Prosecutor can start with his cross-examination.

11     Let's have a 20-minute break.

12                           --- Recess taken at 3.33 p.m.

13                           --- On resuming at 3.57 p.m.

14             JUDGE ANTONETTI: [Interpretation] The court is back in session.

15             Mr. Scott, you may proceed.

16             MR. SCOTT:  Good afternoon, Mr. President, each of Your Honours,

17     good afternoon.  And to all those in and around the courtroom.

18                           Cross-examination by Mr. Scott:

19        Q.   And good afternoon, Mr. Kozulj.  You've already been asked

20     questions by Mr. Karnavas, so you are familiar with the format, if you

21     will, in terms of when we speak different languages there will often be a

22     bit of a pause, perhaps, in the courtroom between the two of us speaking

23     waiting for translation to catch up with each of us.  My pause is not

24     necessarily an invitation for you to speak more, but we just have to

25     allow the interpreters to catch up with both of us.  I also will be

Page 32613

 1     showing you exhibits in the same way that Mr. Karnavas was showing them

 2     to you.  The two binders have already been made available to you.  I will

 3     also be making reference to some of the Defence exhibits that were used

 4     yesterday, the so-called 1D exhibits, and we'll have to figure out the

 5     easiest way for you to find those, if you want to use the same notebook

 6     that Mr. Karnavas provided to you yesterday or some other means, or of

 7     course we always have e-court.  But I hope that in every instance you

 8     will be able to find the document that I'm referring to and the usher

 9     will also be assisting us.

10             Mr. Kozulj --

11             THE INTERPRETER:  The Presiding Judge is kindly requested to

12     switch off his microphone.

13             MR. SCOTT:

14        Q.   Mr. Kozulj, I'd like to go straight to the topic of the

15     Special-Purposes Council.  For these purposes you may wish to have in

16     front of you Exhibit P 00190, which is in binder 1, the Prosecution

17     binder.  They should all be -- in the Prosecution binders you should be

18     able to find them -- all the exhibits in numerical order I hope.

19     Generally, at least in the Prosecution binder - no offence

20     intended - you'll find the English document or translation on top and the

21     Serbo-Croatian document following it.  So if you could please look at

22     P 00190.

23             Now, I think everyone in the courtroom has seen this before.

24     This is when you and a number of other persons were appointed to this

25     thing called the council for special purposes and on the 7th of May,

Page 32614

 1     1992.  Just briefly, do you recall any discussion leading up to the

 2     formation of that counsel?  And I'm not asking now for the circumstances

 3     about the war.  I think we all have a pretty good idea of what was

 4     happening in May of 1992 at this point with the JNA and with the Serb

 5     forces in the Mostar vicinity.  So I'm not talking about those

 6     circumstances.  I'm just asking if you can assist the Judges with any

 7     information about the discussion or debate or dialogue that went on

 8     around this time about the formation of this body called the

 9     Special-Purposes Council.

10        A.   I don't know if there was a discussion about it or not.  All I

11     know is that I personally did not participate in such a discussion.

12        Q.   So --

13        A.   I was dealing with technical matters at the time to help people

14     working in telecommunications to prepare for what was evidently coming.

15        Q.   All right.  And you may have mentioned this but it wasn't

16     entirely clear to me then.  So how was it then that you came to know that

17     you were on this council?  Did someone hand you this document or give you

18     a phone call or come to your office?  How did you find out that,

19     Mr. Kozulj, you are now on the Special-Purposes Council?

20        A.   The majority of these people were people that I met on a daily

21     basis.  At the time I didn't have an office because my office in Mostar

22     was located on the east side, and at the time the east side of Mostar was

23     already a place where it was very difficult to move around.  I received

24     this information, I don't know exactly from whom, but from someone from

25     this list.

Page 32615

 1        Q.   And the people that are on the list, besides yourself, starting

 2     at the top of the list with Mr. Tomic and Mr. Prlic and others, is there

 3     anyone on that list that you had not had prior substantial dealings with?

 4        A.   I knew all these people from before.  I'm not sure about

 5     Mr. Vidan Raspudic, I'm not sure if I knew him earlier.  As for all the

 6     others, I know them all very well.

 7        Q.   Now, let me just go back again to your coming on this board.  So

 8     do I understand correctly - and if I'm wrong, please correct me or

 9     elaborate - that you -- just someone came to you on the street as best

10     you can remember and you found out that you had been placed on this body.

11     Did anyone ask you if you were interested in serving or said, We'd like

12     to invite you to come on this board?  Or can you tell us anything more

13     about that?

14        A.   At the time I openly made it known to all the people that I

15     encountered that I was placing myself at the disposal and with my

16     knowledge and experience I would like to help considering the situation

17     that Mostar found itself in.  This was something that everyone knew, and

18     it was probably the reason why somebody put my name forward and why

19     Mr. Tomic appointed me to this body.

20        Q.   All right.  Now, let's talk about the -- another document that

21     you saw, and it may be that we don't have to look at all these documents

22     because you've seen them just yesterday.  One is the document that I

23     think you looked at which was the 15th of May, 1992, decision to create

24     the Mostar Municipal Staff, and the -- or coming out of -- the one that

25     was disbanding the earlier Crisis Staff, P 00209.  But you may recall you

Page 32616

 1     were asked some questions yesterday about particular language in that

 2     document, and I don't want to talk about the whole document because I do

 3     want to try to move fairly quickly.  But in paragraph 3 of that order, it

 4     talks about the fact that:  "Until the government referred to in

 5     paragraph 2 of this order is formed, the Special-Purpose Council of the

 6     Mostar Municipal Staff of the Croatian Defence Council shall administer

 7     the entire functioning of the city and care for its citizens."

 8             And I recall when you were discussing this yesterday, Mr. Kozulj,

 9     that you indicated that you thought that was unrealistic, that mandate,

10     if you will, as discussed in item 3, that the Special-Purpose Council

11     would take this on was unrealistic.  I put it to you, please, whether it

12     was realistic or not is not so much the issue, but is that not in fact

13     the instructions that were given in the decision of the 15th of May,

14     1992, those responsibilities would fall to the Special-Purpose Council,

15     realistic or otherwise?

16        A.   I didn't explain a little bit earlier, even though you don't

17     allow me to explain the situation in town, but I would like to say this.

18     I read many books about war and --

19        Q.   Sir, that's not my question --

20        A.   -- and only from two of them I understood what the war actually

21     is.

22        Q.   [Previous translation continues]...  my question to you - is not

23     about the war, we've heard a lot about that, we've heard two years of

24     that - my question is:  That's what the document marked as that exhibit

25     and that decision, that's what it says, did it not.  Whether you thought

Page 32617

 1     it was realistic or not -- maybe it was realistic, but that was the

 2     mandate given to the Special-Purposes Council; correct?  If I'm reading

 3     the language wrong or you think it's been mistranslated, tell me.  That's

 4     what it says.

 5        A.   It's true that that is what it says and that is so in this order,

 6     but also I understand it to mean that we were obliged to do this job or

 7     to propose a way that it should be done and this is what we did.  This is

 8     what I take from this order.

 9        Q.   Would you go next, please, to 1D -- this will be a Defence -- it

10     won't be in that binder, sir, you'll have to go to one of the -- either

11     on the e-court or the Defence binder, 1D 02743.  It may be in our -- let

12     me just double-check.  You have that, sir, and it seems to me that

13     looking over in your direction you do.  This is a document around the

14     same time-period concerning the creation of these -- or the performance,

15     if you will, of these various services and functions.  And it says that:

16     "The Special-Purpose Council of the Municipal Staff of HVO Mostar, at the

17     sessions held on 15 and 19 May 1992, in considerations about the

18     functioning of essential services in the town and municipality, has

19     concluded that the vital services of the state administration and

20     functioning of the town have not been adjusted, in terms of quality, to

21     the war conditions in Mostar."

22             I'm not going to read the entire thing to you, sir, because

23     everyone in the courtroom, including you, has it in front of you.  Next

24     paragraph, among other things, refers to the municipal executive bodies.

25     Aren't all those things, sir, the essential services, the administration,

Page 32618

 1     and functioning of the town, the municipal executive bodies, aren't those

 2     the things that we call government?

 3        A.   First of all, I would like to say this about this document.  This

 4     document is not signed.  This is a rough draft that one of us in the

 5     Special-Purpose Council made on the basis of the discussion we had

 6     regarding the task that we were given according to the decision by Jadran

 7     Topic.  We absolutely knew that we were not able to do it, and that is

 8     why we discussed a proposal for President Topic, how the civilian

 9     authority in the town of Mostar could be organized in those conditions.

10     This is a rough draft and it's an impetus to him and his associates to

11     shape that into some kind of decision --

12        Q.   So you would agree with me then, sir, that this document

13     describes the functions of the government of this town of Mostar,

14     essential services, administration and functioning of the town, municipal

15     executive bodies, those are the functions of government?

16        A.   I have a correction.  This document is just thoughts on paper on

17     how the municipal authority in Mostar could function.  This is just our

18     thinking.  It's not a document that was adopted -- I don't know, we have

19     some other documents later which define ways in which the authority was

20     ultimately constituted.

21        Q.   If you'll go next, please, to 1D 02715.  This is, I believe -- is

22     and again, many of these, sir, you will have seen and I'm just taking you

23     back through them to ask some, if you will, follow-up questions.  This is

24     the document which was appointing you a member in fact of the

25     Special-Purposes Council, and it's an appointment issued over the name of

Page 32619

 1     someone called Jasmin Jaganjac who is described here as commander.  And

 2     if I'm not mistaken, you described him yesterday as a military commander;

 3     is that right?

 4        A.   Yes, he was the commander of the HVO staff in Mostar.

 5        Q.   Did you consider that this was a military appointment?

 6        A.   I consider this appointment of the commander of the HVO of me as

 7     a person to help the command in matters which are my professional

 8     expertise.

 9        Q.   So did you consider yourself by this appointment to be acting in

10     a military capacity?

11        A.   No.

12        Q.   When Commander Jaganjac issued this appointment naming you to the

13     Special-Purpose Council, did you understand that Mr. Jaganjac was acting

14     in a civilian role or as a military role?

15        A.   I think that Mr. Jaganjac was acting here in his military

16     capacity and that he engaged me as a civilian.

17        Q.   And in fact, sir, we saw a number of documents yesterday, and I'm

18     not going to turn to them but just in case anyone's curious, I have in

19     mind as examples 1D 02714, 1D 02666, which again were described as

20     orders.  I think most of us tended to think of them -- if someone issues

21     an order, tend to think of that as a military matter.  Is it common in

22     your experience around this time that when these types of instruction or

23     appointments were made it was the order coming from people like

24     Mr. Jaganjac?

25        A.   Well, this terminology was normally used because it was a war, so

Page 32620

 1     this term was used regardless of who was actually issuing the document

 2     because there was a need to stress that the task in question had to be

 3     done.  In wartime, that's at least -- that's my experience and that's how

 4     I see it.  There are no recommendations or no advice, there are only

 5     tasks that are given.

 6        Q.   Let me ask you please to next look at 1D 00906.

 7        A.   I found it.

 8        Q.   Sir, this is again around the same time-period, 20 May 1992, it

 9     is also described as an order issued by someone named Mladen Zulj, which

10     I believe is a name that we've heard before and we will hear again in

11     connection with the PTT.  In this order which Mr. Zulj says for the HVO,

12     chief coordinator of PTT services of Herceg-Bosna, Mr. Zulj issues an

13     order to -- it says PTT units in Grude, Ljubuski, and following.  And in

14     item number 1:  "All PTT units shall, according to given (present) number

15     of channels, secure an unobstructed communication between PTT Centres

16     according to the wartime technical criterion of PTT connections, namely

17     in the ratio of 1:5 (one channel =  five subscribers).

18             "2.  Directors of PTT units shall arrange the disconnection

19     according to this criterion through the HVO command ..."

20             Let me stop there for a moment.

21             If we look at the top left corner of the document or in the

22     letterhead, if you will, we see again this is coming from HVO main

23     headquarters on the 20th of May, 1992.  Did you understand Mr. Zulj to

24     have military powers to be able to issue orders for the HVO issuing from

25     the HVO main headquarters?

Page 32621

 1        A.   Mr. Zulj was appointed the coordinator for post and

 2     telecommunications by the president of the HZ HB.  He was a civilian.  He

 3     did civilian work.  This is an order that pertains to the civilian sphere

 4     of those activities, but this was probably done pursuant to an approval

 5     of the president of the HZ HB that we had in writing, that Mr. Zulj

 6     issued this kind of order, which in my opinion was a necessity at the

 7     time.  And if you allow me, I would like to explain.  At that time when

 8     the state was in disarray, when Bosnia and Herzegovina had broken down,

 9     when there was a great deal of damage to the telecommunications

10     capacities in Mostar, something needed to be done in order to establish

11     the telecommunication lines and to maintain them.  Order -- orders had to

12     be issued because some managers in PTT units, which were deep in the free

13     territory, acted in such a way that they did not want to assist others

14     who found themselves in difficulties.  So there was this necessity for

15     somebody to issue an order to them to do something in light of solidarity

16     with others to switch off some of their capacities.

17        Q.   All right.  We're going to come back and I'll tell everyone in

18     the courtroom - including Your Honours - that we're going to come back to

19     the content of the order in a few minutes.  But right now I'm focusing

20     more on the order, it's the fact of the order itself and where it came

21     from, but you agree with me, sir, that this order was issued by Mr. Zulj

22     describing himself as acting for the HVO and issuing from the HVO main

23     headquarters?  You agree with me on that, don't you?

24        A.   Yes, I agree because that's what it says here --

25        Q.   And in fact --

Page 32622

 1        A.   -- but at that time the HVO was both civilian and military

 2     authority.

 3        Q.   Well, that was exactly the point that I was coming to, sir.

 4     Isn't the effect of what you were telling us yesterday and what you've

 5     told us again these last few minutes that the situation in Mostar, in

 6     Herzegovina, at that time was we are talking about a mixed

 7     civilian/military war-time government, weren't we?

 8        A.   Well, I can't now say whether it is this thing or the other.  I

 9     just know that at that time initiative had to be taken by people

10     themselves, taking initiative, doing things on their own.

11        Q.   [Previous translation continues]...

12        A.   For me it was the most important thing.

13        Q.   My apologies, again it's probably a problem with the

14     interruption -- with the translation, my apology.  But, sir, you just

15     said a moment ago the HVO was both civilian and military authority, and

16     then you said Well, people were taking it on their own initiative.  Sir,

17     I've just shown you a number of documents, they were orders, they were

18     orders, and you just said a few moments ago, I believe you said, that

19     everyone had to act in these conditions, and whether it was Mr. Jaganjac

20     acting in a military capacity or a civilian capacity, these things had to

21     be done because it was war-time conditions; correct?

22        A.   That's the way you phrase it.  Jaganjac was acting in the

23     military aspect and Zulj in the civilian aspect.

24        Q.   And in this situation --

25        A.   That's the way I understand it.

Page 32623

 1        Q.   And in that situation, sir, and what you've again described to us

 2     the last few minutes, wasn't it the case that many of the distinctions

 3     which might exist in a more peacetime environment between the civilian

 4     government and the military, those distinctions were blurred, weren't

 5     they, and some people were exercising both civilian and military power?

 6        A.   Well, if you ask me for a specific person, whether they were

 7     military or civilian, I can give you my opinion.  I don't know whether

 8     some of them were both.  That's not what I was dealing with.  Throughout

 9     the war what I wanted to do was to commit myself to helping people in the

10     areas where I had the expertise.  Now, whether the order to do so came

11     from a military person or a civilian person or whether no orders had come

12     at all because I did lots of things on my own initiative.

13        Q.   So are you telling the Judges, sir, that you didn't care whether

14     the order came from a civilian or a military person or both, it didn't

15     really matter to you and you didn't make a distinction?

16        A.   Well, you can't say that I didn't care.  It just didn't matter so

17     much to me.  What mattered to me was the task that I was given.

18        Q.   Will you look next, please, at 1D 02716, 1D 02716.  This is a

19     certificate issued on the 9th of May, 1992, by the HVO -- it's actually

20     described here as the Herceg-Bosna Main Staff.  Did you know Mr. Zadro,

21     who apparently issued this certificate?

22        A.   I didn't know Mr. Zadro before this order was issued.

23        Q.   Did you come to know him later?

24        A.   No.  I met him because Mr. Zulj, who was the coordinator,

25     authorised such by the president of the Croatian Community of

Page 32624

 1     Herceg-Bosna, asked me to assist and wanted me to meet Mr. Zadro.

 2        Q.   Did you?

 3        A.   Yes.

 4        Q.   All right.  And when you received this certificate from

 5     Mr. Zadro, he was an officer in the HVO military; correct?

 6        A.   Yes.

 7        Q.   So again, did you consider this certificate to be a military

 8     order, had you been given this permission by the military, or was

 9     Mr. Zadro acting in some other capacity?

10        A.   This certificate is important because it accords me freedom of

11     movement.  I am issued a certificate to the effect that because of -- but

12     for the purpose of establishing communication lines, I am allowed to move

13     freely in the territory controlled by the HVO.

14        Q.   Now, if you will please go back to the document we started with,

15     and that is P 00190, the Special-Purposes Council document, in the

16     Prosecution binder, P 00190, the first binder.

17             If I can direct your attention, please, to the fourth numbered

18     paragraph where it says:  "Work shall be coordinated through

19     Messrs. Neven Tomic, Jadranko Prlic, and Borislav Puljic, exclusively

20     with the president of the HVO Mostar Municipal Staff, Mr. Jadran Topic."

21             Could we correctly understand this, sir, is that of this

22     Special-Purposes Council, that Mr. Tomic, Mr. Prlic, and Mr. Puljic,

23     formed or acted as a sort of executive committee?

24        A.   Well, yes, you could take it to mean that they were coordinators

25     in the Special-Purpose Council and that they coordinated the work of all

Page 32625

 1     of us, the rest of us.

 2        Q.   And it says that they should conduct this activity exclusively

 3     with the president of the Mostar HVO -- excuse me, Municipal Staff,

 4     Mr. Topic.  Do you know why that was?  What was the purpose of apparently

 5     making this very clear if that was to be exclusively with Mr. Topic?

 6        A.   No, I don't know that.

 7        Q.   Well, was there some other body that potentially was -- had some

 8     sort of a parallel organization or making other similar efforts to do

 9     these things?  Was there something about that that Mr. Topic wanted to

10     make it very clear that these people would deal only with him?

11        A.   Well, I've already told you that I don't know why he said it that

12     way.  He probably wanted to have some insight into what we were doing.

13        Q.   Can I ask you to next go, please, to the Exhibit P 00578 in the

14     Prosecution binder, first binder.  Do you have it, sir?

15        A.   Just a moment, I'm still looking.

16        Q.   Sir, this appears to be the minutes of a meeting of the HVO HZ HB

17     held on the 14th of October, 1992, with such people in attendance,

18     Mr. Prlic, president; Mr. Zubak; Mr. Buntic; Mr. Stojic; Mr. Tomic; and

19     others.  And if you will turn to -- for the English readers in the

20     courtroom it will be on page 6 of the English document.

21             If you can find part of the document, sir, I'm trying to assist

22     you which it says item 6.  It isn't item 6 that I'm looking for now, but

23     if you find item 6 and you go directly below that item, after that

24     numbered item, until you see it, a discussion where it says:

25     "Mr. President proposed adopting a decision to appoint acting director,

Page 32626

 1     president, and members of the managing board of the HZ HB PTT ..."

 2             You see that now?  I believe it's the fourth page of the

 3     Serbo-Croatian version.  Do you have it, sir?

 4        A.   Are you talking about item 7?

 5        Q.   It follows after item 6, sir.  Unfortunately, it's a part of the

 6     minutes that doesn't particularly flow well in terms of the numbering.  I

 7     don't believe it is item 6, but it follows after item 6 and above a

 8     section called "conclusions."  It should be on page 4 of the

 9     Serbo-Croatian document, sir.  And if I'm mistaken, I'm sorry, but it's

10     on page 6 of the English document.  You may find it on the bottom of page

11     3 I'm told now.

12        A.   Yes, yes.

13        Q.   Now, it says that -- thank you.  It says that:  "Mr. President

14     proposed adopting a decision to appoint" these persons, and under that we

15     see Mr. Mladen Zulja as nominated to be acting director of the

16     Herceg-Bosna PTT.  I take it, sir, that is in fact the same Mladen Zulja

17     that we saw on the document a few minutes ago?

18        A.   Yes.

19        Q.   And then following that is the nomination of the president and

20     members of the managing board.  You are nominated as president and then

21     the following four individuals are proposed as members of the -- other

22     members of the managing board; correct?

23        A.   Correct.

24        Q.   Now, in terms of Mr. Zulja, it says that he was being named at

25     that time acting director.  Is there any particular reason why he was

Page 32627

 1     being named acting director as opposed to director?

 2        A.   Yes.  This is a public company, post and telecommunications,

 3     established pursuant to a government decision, the Government of the

 4     Croatian Community of Herceg-Bosna.  And it is usual practice to appoint

 5     the board of directors to appoint the acting director, and then they go

 6     on to draft the statute of the company; and then this statute is

 7     submitted to the founder, which in this case is the Government of the

 8     Croatian Community of Herceg-Bosna, for its approval.  Only then is the

 9     director formally appointed.

10        Q.   Now, the translation that we're getting in the last few minutes

11     about this was a public company, but just so there's no confusion, was

12     the PTT that's being formed here, is that something that we've also

13     described in the last couple of days as a public enterprise?  Is that

14     accurate?

15        A.   "Javno poduzeca," public company or enterprise.  I don't know how

16     you could translate it best, but that is what it is.

17        Q.   And it was -- was Mr. President or Mr. Prlic who was making these

18     proposals, according to the top of this page 6, and again do you recall

19     whether Mr. Prlic had approached you sometime prior to the 14th of

20     October, 1992, to ask you, Are you interested in doing this?  I'm going

21     to put your name forward at the next government meeting?  How did that

22     happen?

23        A.   I don't recall having discussed this with Mr. Prlic, but I did

24     discuss it with Mr. Vlado Soljic.  In the Government of the Croatian

25     Community of Herceg-Bosna, he was the minister of industry and economy.

Page 32628

 1     We talked about a need to establish public companies and we agreed that

 2     in this public company, the post and telecommunications of the HZ HB, I

 3     should become the chairman of the board of directors and I accepted that.

 4     And probably then Mr. Soljic discussed this with President Prlic and they

 5     tabled this proposal.

 6             MR. KARNAVAS:  Just -- if I may just interrupt and I apologise.

 7     Perhaps Mr. Scott misspoke, but if you do look at the document it says

 8     that the president proposed adopting a decision; it does not say, not

 9     that there's anything nefarious in it, that the president proposed the

10     particular names.  He proposed adopting the decision.  How the names were

11     placed on that decision, that's something else.  So I just want to make

12     sure that that's clarified.

13             MR. SCOTT:

14        Q.   If you look down further into the minutes below the names of the

15     four other individuals nominated for the board other than yourself, in

16     addition to yourself, you'll see that another member of the government,

17     Mr. Kvesic apparently objected to this procedure and did not feel that

18     this was an appropriate way to make appointments.  Did that issue ever

19     come to your attention?  Did anyone ever tell you around this time that,

20     Well, an issue was raised at the government meeting about how we should

21     do this and whether you should be appointed and how that should be done?

22             MR. KARNAVAS:  Excuse me, sir, again I'm going to object.  If you

23     look very closely, he objects because... and then he says, according to

24     the information he has, keeping in mind that Kvesic, in his position, he

25     was minister of the interior at the time -- the head of the department of

Page 32629

 1     interior at the time, and of course he probably had some information as

 2     to why those two individuals should not be appointed.  Again, I'm going

 3     to ask that if we're going to be posing questions that we be somewhat

 4     precise with the language that's in the text.

 5             MR. SCOTT:  Your Honour, I was -- it's a fair -- absolutely a

 6     fair reading of the document.  The document is in front of everyone.  It

 7     says that he objected as against the decision to appoint the board,

 8     especially but -- to the whole board, and then he goes on to say in

 9     principle he does not accept this method of election.  So I don't want to

10     be accused of mis-characterizing the document.

11        Q.   Sir, did this issue ever come to your attention, that there had

12     been some dispute about this?

13             JUDGE ANTONETTI: [Interpretation] Please continue, the

14     Trial Chamber will find it --

15             THE WITNESS: [Interpretation] Well, nobody said anything to me or

16     needed to say anything to me about it.

17             MR. SCOTT:

18        Q.   And how soon after the 14th of October did you find that you had,

19     in fact, been appointed the managing director of the -- or president, if

20     you will, president of the managing board?  Did someone call you later

21     that same day or how did you find out that this action had been taken?

22        A.   I haven't seen this -- these minutes before, and from what I can

23     see that's written there is that the appointment of the president and the

24     members of the managing board of the public enterprise PTT HZ HB is being

25     left for the next meeting of the Government of Herceg-Bosna.  I or the

Page 32630

 1     others did not see this, but nobody needed to inform me about it or let

 2     me know about it.  When I was actually appointed, that's when I was

 3     informed of it and that's when I began to carry out those duties.

 4        Q.   And my question, sir, was:  When was that?  When did you find out

 5     that you had been placed in this position?

 6        A.   I don't remember.

 7        Q.   You don't remember when you took up these responsibilities?

 8        A.   This is a formal question.  The entire time from the moment the

 9     situation deteriorated in our area, I worked together with people, helped

10     them, made suggestions, and in some way tried to help --

11        Q.   Sir --

12        A.   -- so it was just a formal appointment, the official appointment,

13     it wasn't that important to me.  I really don't remember when it was.

14        Q.   Sir, you mentioned several times you were trying to do things to

15     help people and no one's questioning that at this point.  But I just want

16     to be clear on this, so you considered this appointment a formality; is

17     that what the Judges should understand?

18        A.   No, that is not correct.  Please.  I -- well, the appointment to

19     this post implies a certain kind of work.  There was a duty at the time

20     as well as a responsibility.  Up until then, all I had were some -- some

21     duties, but I didn't have any real responsibilities.  I had a kind of

22     advisory role to help people to work.  From the point in time when I was

23     appointed president of the management board, I then was given

24     considerable duties and then it was no longer a formal matter.

25        Q.   Now, in going forward then with your work on behalf of or as the

Page 32631

 1     managing president of the board, excuse me, did you in fact work with

 2     Mr. Zulja as director and did he then, as you said a few moments ago, did

 3     he also become the director as opposed to acting director?  If not, what

 4     happened?

 5        A.   Yes, I continued to work with Mr. Zulj, and when the managing

 6     board was appointed I was its president and Mr. Zulj was appointed the

 7     director.  He was no longer acting director but the director of the PTT

 8     of the Croatian Community of Herceg-Bosna company.

 9        Q.   Did you continue to then be the president of the board, of the

10     managing board, and Mr. Zulja the director throughout the time that you

11     were in that position until approximately mid-November 1993 when you

12     became a minister in the Croatian Republic of Herceg-Bosna?

13        A.   That is correct.  I was the president of the managing board.

14     That's when I became that by a government appointment.  I think at one of

15     the subsequent meetings of the Government of the Croatian Community of

16     Herceg-Bosna this is what happened, Herceg-Bosna, Zulj was the director

17     of that public company and he was that until the point in time when a

18     vacancy announcement was made public and a new director of the company

19     was elected.

20             JUDGE ANTONETTI: [Interpretation] Witness, in these public

21     companies who has power in reality?  Is it the president of the managing

22     board or is it the director of this public company?  At the time, I'm not

23     talking about now, but at the time who has real power, is it the

24     president of the managing board or is it the director?

25             THE WITNESS: [Interpretation] Your Honour, that is a very complex

Page 32632

 1     question.  I said before --

 2             JUDGE ANTONETTI: [Interpretation] But I'm asking that question.

 3             THE WITNESS: [Interpretation] [Previous translation continues]...

 4     explain.  What it means is that a public company is founded by some

 5     socio-political community, the municipality, a regional organization such

 6     as the HZ HB or the state of Bosnia and Herzegovina.  The public

 7     enterprise or its managing board, together with the director and the

 8     services, prepares a statute of the company.  The statute of the company

 9     precisely defines the tasks to be performed by the managing board, to be

10     performed by the administration, and which jobs need to be given to the

11     founders, the socio-economic community, so it is very clearly laid out

12     who is in charge of what.  So the managing board here has the obligation

13     to adopt a plan, to adopt a report, especially the financial report, to

14     adopt the organization of the company, the resolution of major issues

15     such as investments, and then the administration carries out other

16     matters, technical questions, employment, the allocation of staff.  This

17     is how these things were organized.

18             JUDGE ANTONETTI: [Interpretation] Thank you.

19             MR. SCOTT:  Thank you, Mr. President.

20        Q.   Just to follow-up on that, it actually flows from -- or at least

21     I think it was related to that question.  Who then -- who were you

22     accountable to as the president of the managing board?  Who did the board

23     and you as the head of that board, who were you accountable to?

24        A.   The managing board was responsible to the founder, and in this

25     case this was the HZ HB government and it's primarily responsible to the

Page 32633

 1     minister, Mr. Soljic.

 2        Q.   And can you tell us, did you have any particular office locations

 3     or places where you and Mr. - perhaps separate or it may have been the

 4     same location, perhaps not - you and Mr. Zulja worked during this period

 5     from approximately October 1992 to November 1993?

 6        A.   Mr. Zulj is the director of the company and he is an employee of

 7     the company and he had an office.

 8        Q.   Where was that located?  Sir, where was it located, please?

 9        A.   The office was in Mostar.

10        Q.   Approximately where in Mostar, can you give us an approximate

11     location or address?

12        A.   It was at the Zrinski Sports Society Stadium in Mostar, because

13     the premises of the PTT in Mostar at that time were unfit for use.

14        Q.   And where -- did you have an office, sir, in connection with your

15     function as the president of managing board?

16        A.   The president and members of the managing board are not employed

17     in the company, they are not employed in the company.  They don't have

18     the duty of turning up to work every day, and they do not receive a

19     salary for that like the employees do; they only work through meetings.

20        Q.   So where were you -- did you have a business location or office

21     that you went to during that time-period then in Mostar in -- from

22     October 1992 to November 1993?

23        A.   I didn't have an office.  I didn't have an office, I didn't need

24     an office.  All the PTT public company offices of the HZ HB were at my

25     disposal.  But as I said before, the managing board worked through

Page 32634

 1     meetings.  The president does not have any particular powers, he's one --

 2     the first among equals and the materials for the meetings are prepared by

 3     the administration headed by the director, Mr. Zulj, and they are the

 4     ones who prepare everything that is required.

 5        Q.   Where were you residing during this time, sir?  If you didn't

 6     have an office, where were you residing during the time October 1992 to

 7     November 1993?

 8        A.   At the time I was residing at my apartment in Mostar.

 9        Q.   And what was approximately that location or address, please?

10        A.   At the time the street was called the street of Petar Drapsin,

11     number 37, 88.000 Mostar.  The street today is called Fra. Franjo

12     Milicevica, Father Franjo Milicevic, 37, 88.000 Mostar.

13        Q.   All right.  Now --

14        A.   I can see in the translation that it is Petar Trapcin.  Actually

15     it is Petar Drapsin, D-r-a-p-s-i-n.

16        Q.   Now, turning to the topic -- that whole topic of telephone

17     service in particular, Judge Trechsel made a comment at some point along

18     the way yesterday about -- I'm not saying this is an exact quote, so I

19     hope you won't hold it against me if I'm not exactly dead on point, but

20     something to the effect, was there a distinction between what might be

21     called privileged communicators versus the general civilian population.

22     Where I want to go from that, sir, isn't it correct that there was

23     telephone service in Mostar and the surrounding area, it was just a

24     question of how that service was allocated?  Isn't that true?

25        A.   Mostar was without communications -- I mean, it depends what

Page 32635

 1     period we are talking about -- oh, well, I'm sorry.  I have to start from

 2     the beginning.  Up until the time of the destruction of Mostar, Mostar

 3     had normal communications, they are --

 4        Q.   Sir, we don't have the time -- sir --

 5        A.   Can I answer you?

 6        Q.   My question --

 7             MR. SCOTT:  Your Honours, we have limited time --

 8             MR. KARNAVAS:  Okay, but there was no specificity in the question

 9     as to the time.

10             MR. SCOTT:  Then I'll restate the question.  Thank you, counsel.

11             MR. KARNAVAS:  Okay.

12             MR. SCOTT:

13        Q.   Sir, after the time where you say -- and it's been indicated that

14     in approximately May of 1992 that the PTT building in Mostar was shelled

15     and at least I believe what you've told us, if I'm not mistaken, is that

16     between approximately May of 1992 and April of 1994 Mostar and Sarajevo

17     were cut off in terms of telephone communication.  So after that, after

18     May 1992, I'm challenging you, sir, very transparent about that, it would

19     be correct to understand, wouldn't it, that in fact during that

20     time-period, though, just so we understand, there was telephone service

21     and it existed in Mostar and the surrounding areas.  You could call a lot

22     of places in Bosnia, maybe Sarajevo or not.  But it was a question of

23     allocating the existing telephone service; correct?

24        A.   I'm going to try to explain briefly.  For a very brief time

25     Mostar did not have any communications, then gradually we set up

Page 32636

 1     communications and increased the number --

 2        Q.   [Previous translation continues]...

 3        A.   -- this time that you are talking about.  Before that Mostar

 4     had --

 5        Q.   Sir, the problem we had yesterday was that there was no -- often

 6     no specification of time-period.  So you say there was a time when there

 7     was no communication in Mostar.  So please tell us the time, give us

 8     dates.  From when to when?

 9        A.   Well, let's say that the shelling of the PTT building as far as I

10     can recall was on the 14th of May, 1999 -- no, 1992.  We set up first

11     communications some days after that, let's say a week after that, we

12     established communications with the outside world.  The first telephone

13     exchange of a capacity of only 1 per cent of what we actually had before

14     the war arrived in the form of a donation of the Split communications

15     centre, and its capacity was 480 numbers.  This was sometime in August

16     1992, if I remember correctly.  It was summer in any case.

17        Q.   Let me ask you to go, please, to Exhibit --

18        A.   And then these --

19        Q.   Let me ask you to go to 1D 00566.  1D 00566, and I'll appreciate

20     it, sir, if we can try to move as efficiently as possible because, again,

21     my time is also limited.  It's also on the screen, it may be faster for

22     you.  You saw this document yesterday -- you saw this document yesterday.

23     Now, this relates to -- admittedly, this relates to electrical power, but

24     this was the allocation of existing power-supply, who was to get it, on

25     the -- as of the 19th of June, 1992, and you would agree with me, would

Page 32637

 1     you not, that some locations, government buildings, government

 2     facilities, military facilities, were given priority and in many

 3     instances on the list it says they would permanently have power.  Do you

 4     see that?

 5        A.   Yes.

 6        Q.   For example, about two-thirds of the way down or a little below

 7     halfway down the list you have Municipal Staff, and the Municipal Staff

 8     would have power permanently; do you see that?

 9        A.   I see that.

10        Q.   And a couple -- several lines down, just as one more example, I

11     notice that the ham radio operators at Rondo, they had permanent power.

12     Do you recall why the ham radio operators at Rondo had permanent power?

13        A.   In war conditions ham radio operators have enormous importance

14     where communications are concerned between people.

15        Q.   Now -- so going back to telephone service, sir, what -- didn't

16     the same exact process apply to the allocation of telephone service, you

17     had 480 -- at least one point in time, soon after during the summer of

18     1992, you had something like at least 480 numbers or lines, and weren't

19     those allocated in essentially a similarly way, essential offices,

20     government functions, the military, were allocated telephone service;

21     correct?

22        A.   Correct.

23        Q.   And if I can ask you to please go to P 06807, Prosecution binder,

24     the first binder, binder number 1.  If we can look at e-court, please.

25     Can you look on the -- if you can't find it -- all right.  Thank you very

Page 32638

 1     much.

 2             Sir, if you have P 06807, this is an order over the name of Bruno

 3     Stojic, at least the typed name of Bruno Stojic.  There is no date on the

 4     document, but I submit to you the best we can do is that the number of

 5     the document bears a reference to 1992.  But in this document, Mr. Stojic

 6     raises issues that says:  "Based on the previous situation regarding

 7     telephone lines that are not satisfying our needs, and in order to

 8     improve them, especially for the needs of the "Main Staff" HVO and its

 9     units, as well as the Government of the Croatian Community of

10     Herceg-Bosna.

11             "I order:

12             "To reduce the number of telephone connections on the telephone

13     central (connections that are in private houses)."

14             Mr. Stojic in point 3 goes on to make it clear that the

15     Herceg-Bosna defence department, in fact, is the exclusive owner of all

16     telephone connections, et cetera.  Do you see that?  That accurately

17     states the affairs at that time, does it not?  An effort was being

18     made -- perhaps the average person, if you will, living on the street

19     didn't have telephone service, but the government leaders, the government

20     and the military, did, didn't they?  Mr. Stojic, among others, was making

21     sure of that; correct?

22        A.   I think that -- well, I haven't seen this before, but I think I

23     know what it's about.  The public company, the HZ HB PTT, has its prices

24     at which it operates and it charges for its services and --

25        Q.   Sir, I apologise to you.  My question is not about price --

Page 32639

 1             MR. SCOTT:  Excuse me, Your Honour, unless the Chamber will allow

 2     me more time, my question has nothing to do with price; my question has

 3     to do with the allocation of lines.

 4             MR. KARNAVAS:  Your Honour, perhaps if Mr. Scott was a little

 5     more precise in his questions he would get more precise answers.  But if

 6     he asks wide questions, he's going to get a wide answer, and the

 7     gentleman is entitled to provide explanations, especially since he's

 8     being asked to comment on a document that he hasn't seen before.  Now,

 9     yesterday there were at least two, maybe three, interventions by Judge

10     Trechsel where he wanted to know whether the gentleman had seen the

11     document before, and I assume there were reasons for asking those

12     questions, maybe because those documents are not going to be introduced

13     when the Defence tries to introduce them, I don't know.  But here he

14     hasn't seen the document, he's being asked to give an opinion.  He's

15     trying to give his opinion.  Now, I don't know what Mr. Scott wants.

16     Either he should limit the question -- but he can't be asking an opinion

17     then cut the gentleman off in the middle of an explanation.

18             MR. SCOTT:  I didn't ask for an opinion.  I think my question --

19     I'll be happy to restate it.  I think my question was quite clear and it

20     had nothing to do with price.  The question was the allocation of phone

21     lines, and my question specifically was:

22        Q.   Isn't it in fact the case that in the summer of 1992 and

23     thereafter there was phone service, you mentioned yourself a few moments

24     ago, 480 lines and at least some of these lines were allocated in fact as

25     described by Mr. Stojic in the opening paragraph, the HVO military

Page 32640

 1     including the Main Staff and the Government of the Croatian Community of

 2     Herceg-Bosna.  That's true, correct?  And my question has nothing to do

 3     with price.  They had telephone service?

 4        A.   Excuse me, I have to express my disagreement.  The document has

 5     to do with prices and charging for services.  If you permit me, I will

 6     explain; and if you don't, well let us then just say that I disagree with

 7     your opinion.

 8        Q.   All right.  This document was copied to --

 9        A.   If you permit me, I will explain.

10        Q.   No, sir --

11             MR. KHAN:  Well, Your Honour, I think the question of the witness

12     is properly addressed to the Bench.  It's for the Bench to give

13     permission.  I think a document's been put to the witness.  He's seeking

14     to explain it, and, Your Honours, I do think it may clarify matters if

15     he's allowed a couple of minutes to --

16             MR. SCOTT:  Excuse me, Your Honour, let me respond --

17             MR. KHAN:  I'm grateful.

18             JUDGE ANTONETTI: [Interpretation] One moment, Witness.

19             I too am trying to understand both questions and answers.  We

20     have a document from Mr. Stojic who at the time was in charge of the

21     defence department.  Based on this, there could be a military dimension

22     to this document.  It includes six points.  The first is to reduce the

23     number of telephone connections linked up to the telephone central.

24     Second item, it seems to have to do with expenses and charging for the

25     service or for the telephone lines.  Third item, which seems rather novel

Page 32641

 1     to me, the defence department seems to be the owner of all the telephone

 2     connections.  So this document raises a series of questions not tackled

 3     specifically by the Prosecutor but in a general way, and I would like to

 4     know whether as of the date of this document there was some intervention

 5     by the defence department, maybe because of the wartime conditions, in

 6     order to control telephone lines or reduce their number and better

 7     control the expenses.  Because this document seems to say that the

 8     defence department is the exclusive owner of all these telephone

 9     connections.

10             You at the time, you were involved in this telephone system.  As

11     far as you know back then, did the defence department claim to be the

12     owner of these 480 numbers - Because we know that number of 480 - and as

13     an owner, did they exercise their right of control?

14             THE WITNESS: [Interpretation] Defence department did not have any

15     connections that were under the management of the PTT HZ HB public

16     company, but the defence department and the commanders and soldiers used

17     the telephone services of the public company, and they were in the

18     offices, in the apartments, and other places were subscribers to the

19     public service for which the public service sent them bills.  Director

20     Zulj and we from the board insisted that these services be paid, that

21     they be paid equally by individual civilians and soldiers and commanders

22     all equally.  They could either pay it themselves or the ministry could

23     pay those bills for them.  We needed money in order to renew the

24     telecommunications system, and so the sense here is to limit the number

25     of users, military personnel, and to limit the number of impulses that

Page 32642

 1     they could use.  Because I know, I remember, that there was resistance,

 2     the soldiers wanted to get a free telephone service and we asked that the

 3     telephone services be paid for --

 4             JUDGE ANTONETTI: [Interpretation] Witness, why is the defence

 5     department interested in the issue?  Why is it interested in private

 6     telephone lines?  Look at item 1, private lines are mentioned.  So why is

 7     the defence department interested in this?  Is it for reasons connected

 8     to defence or for other reasons?  Why are they interested in this because

 9     this is an order?  Can you answer this?

10             THE WITNESS: [Interpretation] Command to military personnel.

11     This is how I am experiencing it.  So military personnel had telephones

12     in their private home, and that telephone was something that they were

13     not paying for, in the belief that the Ministry of Defence should be the

14     one to pay for this service.  We asked from the Ministry of Defence to

15     say who had the right to this free service and who did not, whose

16     telephone bills they will pay and whose they will not.  Those whose bills

17     would not be paid by the Ministry of Defence needed to pay their bill

18     themselves.  So I see this letter as restriction of telephone service use

19     for military personnel.  This is how I understand it.  Perhaps I am

20     wrong.

21             JUDGE TRECHSEL:  I would like to make a statement of my personal

22     legal view on the dispute that has arisen.  I am of the firm opinion that

23     when a party is questioning a witness, that party determines the

24     questions and it's not for the witness to say what he would like to talk

25     about.  And when there's a document, normally there are several issues

Page 32643

 1     that could be raised, it is for the party that puts the question to

 2     determine which are to be discussed because otherwise that party loses

 3     control over the time.  The Defence often - and

 4     understandably - complains about lack of time.  I think if the

 5     Prosecution does so there's no reason to treat it in a different way.

 6     Thank you.

 7             MR. KHAN:  Your Honour, it's always enlightening and I am

 8     grateful for your personal opinion, and I would concur completely that

 9     it's for the party to decide the questions.  But my intervention relates

10     to the answer, and the witness -- the overriding objection --

11     responsibility, as you know, is to ensure a fair trial.  This document,

12     of course, is important to the Prosecutor, which is why my learned friend

13     put it to the witness.  The only reason why I rose is that I did think,

14     and I think the questions by the Presiding Judge, were very helpful to

15     cast a light on this document which is put forward by the Prosecution.

16     Of course the aim is to get to the truth, and I think the additional

17     questions have served a very useful purpose.  But, Your Honour, I agree

18     with the underlying premise of Your Honour's underlying view of the

19     control of the witness.

20             JUDGE ANTONETTI: [Interpretation] Very well.

21             Please proceed, Mr. Scott.  The witness has told us that this

22     document has to do with military telephone lines.

23             MR. SCOTT:  All right.  Thank you, Your Honour.  I do appreciate

24     the Chamber's questions and they were similar to the ones that I was

25     about to get to.

Page 32644

 1        Q.   Sir, just to hopefully shed further light on this, would you go,

 2     please, to 1D 00905, 1D 00905.  Sir, this -- relating back to this issue

 3     and the same Mr. Zulj that we've been talking about this afternoon, this

 4     is a document entitled:  "Empowerment" over the name President Mate

 5     Boban, issued from the main headquarters, Grude, 4 May 1992, empowering

 6     Mr. Zulj to carry out work on the necessary PTT connections in the

 7     territory, as Mr. Karnavas will say, I give emphasis to that, in the

 8     territory of the Croatian Community of Herceg-Bosna, with the purpose of

 9     defending of the Croatian Community of Herceg-Bosna.  And then we saw the

10     document a few moments ago, sir, and we'll go back -- I told you we would

11     go back to it again, if you could go to 1D 00906, 1D 00906, it should be

12     the next one but if you don't have it we'll find it.

13             Sir, this is the document we looked at a few moments ago, and I

14     said we would come back to the content of it.  This document dated the

15     20th of May, 1992, again by Mr. Zulj again raises the issue of the

16     allocation of communication lines, and he talks about:  "According to the

17     wartime technical criteria of PTT communications, namely in the ratio of

18     1:5 (one channel = five subscribers).

19             "Directors of PTT units shall arrange the disconnection according

20     to this criterion through HVO command."

21             Item 4: "Special commission on behalf of the main headquarters

22     shall control the execution of this command."

23             The military, sir, minister of -- ministry of defence, the

24     department of defence, was controlling the telephone system during this

25     time-period, correct?  It was a matter of defence.

Page 32645

 1        A.   Again, I don't read it the way you do, that's not my

 2     understanding, and I have to explain this --

 3        Q.   No, sir, I'm sorry, time does not allow.  It talks about the

 4     criterion, the wartime criterion.  Wartime technical criterion of PTT

 5     connections 1:5, where did that criterion come from?

 6        A.   One telephone exchange, a thousand numbers has about a hundred

 7     connections.  And at that time we never went to full capacity.  In

 8     wartime conditions there is an increase in demand, more phone calls are

 9     placed, and in order to make sure that this traffic can be sustained, it

10     was necessary to reduce the number of subscribers.  Now we're talking

11     about the telephone exchanges that were not destroyed, that were still

12     operational.  The number of subscribers had to be reduced in order to

13     make sure that the other priority users could use telephones without any

14     obstructions.  It is quite clear that staff in some municipality - I'm

15     talking about the HVO - could set those priorities.  In cooperation

16     between the PTT and the staffs, it was necessary to determine whose

17     telephone lines could be disconnected, who no longer resided there, who

18     no longer needed to have a telephone line, so that the telephone lines

19     that were at the disposal could then be allocated to priority users,

20     those who really had to have a phone line.

21        Q.   Priority users being the military and the government, correct,

22     among others perhaps?

23        A.   The military, the government, the services, hospitals, utilities,

24     and so on.

25        Q.   And if you'll go, for example, to Exhibit 1D 00624, and we'll

Page 32646

 1     provide it to you, sir, if you can't find it.  1D 00624.  Sorry, here's

 2     one.  If we can look on e-court, please, if it assists.  Sir, this is

 3     a -- I just want to point this out to you as an example.  Here is a

 4     document in September of 1992 where a telephone line is being allocated

 5     to the University of Mostar.  So is that an example of a priority user?

 6        A.   For some reason -- well, this is an example of a non-priority

 7     user because at that time the university was not used to provide

 8     education; it was used by other services for the purposes of the defence.

 9        Q.   If you can go, please, to Exhibit 1D 02670, 1D 02670.  We'll

10     assist you, sir.  Sir, this is a report that you discussed yesterday and

11     you gave it a date -- when asked about this one yesterday, you gave it a

12     date of the summer of 1992, and I want to move quickly, please.  The end

13     of the first long paragraph says the following, it's talking about:

14     "Thanks to early" -- well, that whole long sentence.

15             "Thanks to early preparations, the prompt action taken by

16     experts," et cetera, et cetera, at the end of that long sentence, "...

17     some lines for the most essential needs have been established and fairly

18     successfully maintained," correct?  That's a report that you wrote.

19        A.   I don't see it here.  It's -- I can't see this part that you're

20     reading.

21        Q.   Under the title:  "Introduction," there is a long block of text

22     and at the end of that particular block of text there is a talk about:

23     "Thanks to early preparations, the prompt action taken by experts, the

24     existence of the UNIS Telekom factory, Mostar, which makes

25     telecommunication equipment and has experts for design and installation,

Page 32647

 1     the help from the Croatian Post and Telecommunications, Centre Split, and

 2     the Nikola Tesla factory in Zagreb," as a result of all of that, "some

 3     lines for the most essential needs have been established and fairly

 4     successfully maintained."

 5             Now, have you found it yet?

 6        A.   Unfortunately, I think I have a different document.

 7        Q.   1D 0267 --

 8        A.   Can you please show it here up in the screen.  Would you please

 9     show it on my screen.

10        Q.   02670.  Just I'm looking at --

11        A.   I have the document but I can't find this text that you're

12     reading.  Sir, I just can't find this text that you're reading.

13             JUDGE TRECHSEL:  I have the same problem, Mr. Scott.

14             MR. SCOTT:  All right.  Then maybe my numbering is wrong, Your

15     Honour, and I apologise if it is.

16             MR. KARNAVAS:  It's the very first paragraph of the first page

17     under "introduction" --

18             MR. SCOTT:  Correct.

19             MR. KARNAVAS:  So you have to go down about six or seven lines --

20     seven, and it's sort of on the right hand:  "Thanks to early

21     preparations ...," that's the part.

22             JUDGE TRECHSEL:  Thank you.

23             MR. SCOTT:

24        Q.   Sir, have you found it, please?

25        A.   Yes, yes, now I found it.

Page 32648

 1        Q.   That's a report that you wrote, too; correct?

 2        A.   Yes, I drafted this report.

 3        Q.   Down under the heading that's titled:  "UNIS Telekom," you

 4     describe that enterprise Mostar, and we're not going to again go through

 5     the whole thing, but you describe there the equipment made, and it's

 6     halfway down through the paragraph, sir.

 7             "The equipment made and installed by this enterprise can be found

 8     across the Republic of Bosnia and Herzegovina and further afield,

 9     although the aggressor occupied the factory for several months, the

10     enterprise maintained its production and services during the war because

11     semi-finished equipment, some reproduction materials and parts and most

12     of the manufacturing equipment, which could have been dismantled and

13     relocated, had been relocated in time."

14             So isn't it correct, sir, that throughout this time-period,

15     1992/1993, the Herceg-Bosna government, the HVO, had a substantial

16     advantage in having this working telecommunications factory located in

17     Mostar; correct?

18        A.   That's correct.  They did have a great value in that.

19        Q.   Now, one specific question in terms of some of these relay

20     stations that have been discussed.  Do you recall when the relay station

21     was established and operational at Cubren near Kiseljak?

22        A.   Cubren.

23        Q.   Yes, if I'm pronouncing it wrong my apologies, but near Kiseljak,

24     Cubren?

25        A.   Yes, that's correct, Cubren.

Page 32649

 1        Q.   Can you tell me when that radio station -- excuse me, my

 2     apologies, the relay station was established and operational at that

 3     location?

 4        A.   Well, as far as I can remember, it was in late 1993.

 5        Q.   Now, in connection with Sarajevo and Mostar being -- your

 6     statement that they were cut off, I believe I heard you say several times

 7     yesterday that there were times -- there did come a time, in fact, that

 8     you were able - you, the Herceg-Bosna apparatus, the HVO - was able to

 9     establish telephone links or communication links with Central Bosnia.  Do

10     you recall when that occurred?

11        A.   In 1993, throughout that year we gradually dealt with the

12     communication lines with the enclaves in Central Bosnia; some may have

13     been done later, but most of the work was done in this period.

14        Q.   So can we understand, sir, that at various times in 1993

15     communication links were established from Mostar to Central Bosnia by

16     telephone?

17        A.   That's correct.  And I can say that this relay station at Cubren

18     was also used for that purpose.  Some communication was set up with

19     Kiseljak through it, and later on it was possible to connect also towards

20     Sarajevo.

21        Q.   Which in fact was my next question.  I think you've said several

22     times that you got -- you - and again, I'm speaking collectively, the

23     HVO - got very close to Sarajevo, to making a connection, I think you

24     said you could see Sarajevo.  When did that occur?  When did you get so

25     close -- when did this system get so close to Sarajevo that you could see

Page 32650

 1     Sarajevo?

 2        A.   First of all, I think that at this time it was the Government of

 3     the Croatian Republic of Herceg-Bosna, not the HVO.  The PTT Herceg-Bosna

 4     public company did this work, and it dealt with the issues related to

 5     linking up all the places that were under the HVO control.  And in this

 6     respect there were several --

 7        Q.   [Previous translation continues]...

 8        A.   -- stages --

 9        Q.   [Previous translation continues]...  able to see Sarajevo in

10     connection with -- in making a telecommunications connection or a

11     communication connection with it?  My question asks for a date.

12        A.   In early 1994.

13             THE INTERPRETER:  Interpreter's note:  Speakers are kindly asked

14     not to overlap.

15             MR. SCOTT:  My apologies to the interpreters.

16        Q.   Sir, you were asked some questions by Judge Trechsel yesterday

17     to -- again to be more clear about when this state of "non-communication"

18     ended.  And for counsel this dialogue appears at pages 21 and 22 of

19     yesterday's transcript.

20             And you said:  "From that time on," you're referring to when it

21     started in May of 1992, "from that time on we put in intensive efforts to

22     set up various communications systems in the areas that we had access to,

23     and in this manner we were able to set up communications not only within

24     Herzegovina itself but using those points that we had access to we were

25     able to establish links between Central Bosnia and Sarajevo, and likewise

Page 32651

 1     at a point from which you could see Sarajevo we've made it possible for

 2     Sarajevo to link up with this network; in other words, for Sarajevo to be

 3     linked up with Mostar."

 4             And Judge Trechsel says:  "And at what time was that?"

 5             And you said:  "I think in April of 1994."

 6             And Judge Trechsel's next question, and this is really where I

 7     was wanting to get to, Judge Trechsel's next question:  "And did you do

 8     that via directional-beam aerials, did the dish antennas go point to

 9     point?"

10             And you said:  "Yes, yes, that's how we did it."

11             So when was this directional -- these directional-beam aerials,

12     when were those put in place?

13        A.   The moment when communications were -- began to be set up between

14     the PTT Herceg-Bosna public company and the PTT company headquartered in

15     Sarajevo was when this meeting was held in Sarajevo.  We said that the

16     meeting was held between the 27th and the 29th of April, 1994.  At that

17     time, we asked all the PTT units and all the technical personnel in the

18     PTT company to establish links with the other side wherever it was

19     possible, and in some areas this was done quickly and in other areas it

20     took a long time.  As far as I know, there were no problems on our side.

21     The same kind of communications had to be set up on the side of Mostar

22     and that's what we did.  So it was a process.  And I think that we

23     gradually improved both our relations and the communications themselves.

24             MR. SCOTT:  Mr. President, I'm told that this might be the time

25     for the next break.

Page 32652

 1             JUDGE ANTONETTI: [Interpretation] Absolutely.  It's 20 to 6.00.

 2     We'll now break for 20 minutes, so we resume at 6.00 p.m.

 3                           --- Recess taken at 5.40 p.m.

 4                           --- On resuming at 6.01 p.m.

 5             JUDGE ANTONETTI: [Interpretation] Mr. Scott.

 6             MR. SCOTT:  Thank you, Your Honour.

 7        Q.   All right.  Staying on some questions that were raised by --

 8     again by Judge Trechsel yesterday, but after moving on from the

 9     directional-beam aerial, Judge Trechsel also asked you about the

10     possibility of short-wave or long-wave radio communication.  And you got

11     into a discussion, sir, of the differences between short-wave and

12     long-wave and ultra short-wave, but I'm not sure we ever got a clear

13     answer to Judge Trechsel's question.  It's correct, is it not, that radio

14     signals and radio communications between Sarajevo and Mostar were

15     possible and in fact was going on; correct?

16        A.   I said that radio communications - in other words, Radio

17     Sarajevo - could be received in Mostar if the medium-range transmitter

18     working, at I think 612 kilohertz was operational, and it appears that it

19     too was in an area where it was at risk from the Serb forces.  I don't

20     know that because I didn't really follow that.  I know that we could

21     receive this radio intermittently in Mostar during the war.

22        Q.   And apart from radio in terms of commercial radio, and by that I

23     mean perhaps news and music radio stations, there could also be radio

24     communication between Sarajevo and Mostar in terms of voice and data

25     communication by radio; correct?

Page 32653

 1        A.   As far as I know, it was not possible.  As far as the public

 2     telecommunications system is concerned, it was not possible.  As for ham

 3     radio operators, they were able to communicate throughout Bosnia and

 4     Herzegovina and in the world, but this was not telephone communication.

 5     It's a completely different thing.

 6        Q.   All right.  So for example, those ham operators that were working

 7     at the Rondo, they were in radio communication with Sarajevo or anywhere

 8     else; correct?  Correct?

 9        A.   Ham operators, when their equipment was working could communicate

10     with anyone.

11        Q.   Now, satellite telephones --

12             MR. SCOTT:  Yes.

13             MR. KOVACIC: [Interpretation] Your Honours, just one remark.  I

14     know that you're fed up with those problems.  In our language ham radio

15     operators are people who work their radio stations as amateurs.  In

16     English it is translated as ham operators.  At this Tribunal I don't know

17     whether the sense of amateur is preserved, ham operators, and this is

18     lost here.  From the answers that we got here, I'm not sure that the

19     translation you received tells you that these are amateurs, not part of a

20     structure.

21             JUDGE TRECHSEL:  Mr. Kovacic, I can assure you, if one -- I've

22     looked it up on LEO and ham operator is translated into the equivalent of

23     German of amateur radio operator.  So it's exactly.

24             MR. KOVACIC:  I appreciate very much --

25             JUDGE TRECHSEL:  You're welcome.

Page 32654

 1             MR. KOVACIC:  But I remember that there were some problems with

 2     that --

 3             JUDGE TRECHSEL:  I hope I will not be understood as testifying or

 4     as taking over from the interpreters.

 5             MR. KOVACIC:  Thank you so much.

 6             MR. SCOTT:  Thank you.

 7        Q.   Just to be clear on that, though, whatever the status,

 8     professional or amateur, of the person, the human being, sitting at the

 9     machine, the technology existed and the technology established

10     communications between Sarajevo and Mostar; correct?

11        A.   I have to say once again that it depends on what kind of

12     communication you want to have.  As regards the public company, the

13     postal communications that the PTT public company was providing, there

14     was no communication.  There was this commercial radio as you call it,

15     which could be received intermittently in Mostar, and there were ham

16     radio operators.  As I said yesterday, there were some satellite

17     communications too, but I don't know how that functioned.

18        Q.   [Previous translation continues]...

19             JUDGE ANTONETTI: [Interpretation] Just a minute, Witness.  Let's

20     go back to ham radios.  I assume that these ham radio operators had

21     equipment to communicate between them, a ham operator in Mostar and

22     surroundings can contact another ham operator in London, for example.

23     And he would do this using short waves.  So at this moment these ham

24     operators, do they automatically have to go through the PTT relay

25     stations or could you tell us whether their own system is totally

Page 32655

 1     independent from the PTT infrastructure?

 2             THE WITNESS: [Interpretation] Mr. President, ham operators have a

 3     system that is independent from any other.

 4             JUDGE ANTONETTI: [Interpretation] That was my question.  Thank

 5     you.

 6             Mr. Scott.

 7             MR. SCOTT:  Thank you, Mr. President.

 8        Q.   And you were about to say, sir, about satellite phones which was

 9     the next item I wanted to come back to.  Mr. Karnavas certainly asked a

10     number of questions about satellite phones and some phones that were

11     apparently available to Mr. Izetbegovic or others.  So that technology

12     did exist at the time and apparently was used in Bosnia-Herzegovina

13     during the 1992-1994 time-period; correct?

14        A.   This technology did exist at the time.  If the documents that

15     were presented yesterday are correct, then it was used in Bosnia and

16     Herzegovina.

17        Q.   And are you suggesting, sir, that technology was only -- for some

18     reason only available to the Muslims and not available to the Croats or

19     the HVO?

20        A.   I think that it was available both to the HVO but somebody needed

21     to sign a contract, obtain the equipment, and sign a usage contract,

22     meaning that that -- that they would have to then pay for the services

23     provided by the telephone company.

24        Q.   [Previous translation continues]...

25        A.   I was never informed that anyone in the area of HZ HB obtained

Page 32656

 1     such telephones; perhaps they did, I don't know.

 2        Q.   Your testimony, sir, is you don't know; correct?

 3        A.   Yes.

 4        Q.   [Previous translation continues]...  you said -- in one of your

 5     reports, and if you forgive me I'm not going to pull out every document

 6     that we looked at in the last two days, but I'll represent to you that in

 7     one of your reports you talked about the mobile telephone network.  What

 8     was the status of mobile telephones in 1992/1993?  I know they weren't as

 9     prevalent as they are today, but they were around and they were used,

10     weren't they?

11        A.   In our region, I'm talking about the Herceg-Bosna area, we didn't

12     have the capacity for mobile telephones at that time.  But the mobile

13     phone network in Croatia, the so-called analog mobile telephones which

14     are quite different from such phones today, did exist.  There was a very

15     high hill in Croatia, in Dalmatia, the hill is called Biokovo, where the

16     device transmitting these signals was installed and that covered

17     partially the Herzegovina area, and that is how it was possible to use

18     these phones for the most essential purposes.  These were analog system

19     mobile telephones.

20        Q.   Now, sir, if we could go on to some examples -- what I'm going to

21     put to you at least as examples of some communications that were going on

22     around this time, and I believe that probably for the balance of the

23     evening hopefully it will be a bit simpler, these will all be P exhibits

24     in the first binder, binder number 1.  So if you can turn first of all to

25     P 00237, P 00237.

Page 32657

 1             Sir, I'd appreciate very much your cooperation in moving through

 2     these documents as efficiently as we both can.  I'm not so much

 3     interested in the content as the -- as opposed to what they indicate in

 4     terms of communication.  So if you have P 00237, this is an order going

 5     out over the name Milivoj Petkovic on the 3rd of June, 1992, to Livno,

 6     Tomislavgrad, and Citluk.  Item number 1:  "Send an aggregate daily

 7     report as you have done up to now, in writing and by courier.

 8             "2.  Immediately report all enemy actions and activities by

 9     telephone, giving the following information ..."

10             Would you agree with me, sir, that apparently when

11     Mr. Petkovic --

12        A.   I agree.

13        Q.   -- or someone on his behalf signed this, he thought telephone

14     service was available; correct?  Correct, sir?

15        A.   Yes.

16        Q.   And if you will go, please, to Exhibit P --

17        A.   Just one moment, just one moment, please.  You can see here

18     Livno, Tomislavgrad, and Citluk.  There was no destruction there and

19     that's where the network or the communications were working.

20        Q.   All right.  Well, perhaps -- perhaps you can assist us, and if

21     you can I'm sure everyone will be grateful.

22        A.   Yes.

23        Q.   What you've come here then to talk about is then -- you're

24     talking about the civilian communications that operated through --

25     directly through the PTT system, but you're not telling us -- you haven't

Page 32658

 1     told us anything about the communication facilities used by the military.

 2     Is that what you're telling us now?

 3             MR. KARNAVAS:  I'm going to object again, Your Honour.

 4     Perhaps -- perhaps there's a -- something is being lost in translation

 5     and I'll try to be as measured as I possibly can.  The gentleman came

 6     here to testify about matters related to communications, PTT, whether

 7     civilian or military.  He was shown a document.  He indicated that for

 8     those reasons there was an ability to communicate.  Perhaps -- perhaps it

 9     might be better, and we could save some time, if he was simply asked,

10     where he was able -- in which areas you were able to communicate and in

11     which areas you were not.  And then if he wants to be impeached further,

12     if he can, fine; otherwise, I believe the gentleman has indicated

13     yesterday that at times there was a -- they were able to communicate

14     within certain locations.  He has never testified otherwise.  The

15     question I would imagine now for the Prosecution that might be

16     interesting is where.  I think that's the real issue.  There's no real

17     contention, and I don't think there's a need to take somewhat of a

18     confrontational tone.

19             MR. SCOTT:  Thank you.

20             JUDGE ANTONETTI: [Interpretation] Mr. Scott.

21             MR. SCOTT:  Your Honour, Mr. President, perhaps the courtroom

22     will be shocked for me to say that I fully agree with Mr. Karnavas on

23     this occasion, and that's really what I intended to go, the direction I

24     intended to go in, but that's not the way my question came out.

25        Q.   So let me restate it, sir.  What I meant to say, and I admit I

Page 32659

 1     didn't put it well, perhaps you can assist us rather than going through a

 2     large number of documents, can you confirm to the Judges, sir, that

 3     throughout large parts of Herzegovina, including Livno and Tomislavgrad

 4     and Citluk and Stolac and Capljina and Siroki Brijeg, for examples, there

 5     was telephone service available, at least to the military and the

 6     government, throughout -- from mid-1992 to the end of 1993 and 1994?

 7        A.   I can confirm that the Mostar telecommunications centre in Mostar

 8     was shelled in May 1992, and all the installations under the control of

 9     the HVO were functioning very well but the communications -- external

10     communications -- actually, internal connections between different places

11     functioned very well, but the communications with the outside world,

12     abroad, were functioning with difficulties because we had a reduced

13     number of communications towards Croatia, i.e., the world.

14             At this moment when this is being written, the communications

15     were quite good.  When the shelling began, very quickly the free

16     territories in Herzegovina, the free territories which were under the

17     control of the HVO, very quickly had reduced communications, proceeding

18     with difficulty, and they had to be satisfied to give precedence to

19     priority users, but the communications did exist.

20             MR. KARNAVAS:  [Previous translation continues]...  correction.

21     On page 76, line 13, the gentleman indicated that up until the shelling

22     of May 1992 all the installations that were under the control of the HVO

23     were functioning.  So that was my understanding from my colleague, and

24     then -- the rest of the answer is fine.  He's repeated this on earlier

25     occasions as well.

Page 32660

 1             MR. SCOTT:

 2        Q.   Sir, my question was -- to you was -- again, I think everyone in

 3     the courtroom, we're trying to see if we can make some -- move

 4     efficiently.  And the question -- my question to you was not what

 5     happened before the shelling of the PTT building in Mostar in May 1992.

 6     I think we've all heard about that about 15 or 20 different times, but

 7     after that, from mid-1992 to the end of 1993 into 1994, in the

 8     Herzegovina region - and I named a number of locations - perhaps what you

 9     can call internal communications, throughout that time-period, subject to

10     some disruptions from time to time, can the Judges understand that there

11     was telephone communication, at least among the so-called priority users?

12        A.   Absolutely.

13        Q.   And based on that we'll cut out about eight or nine or ten

14     exhibits.

15             Would you please go next to, just as one example, P 07541.  If

16     you have that, sir, this is a list of prisoners of war dated the 10th of

17     January, 1994, and out of the ones that I just literally flipped through

18     to try to cut down the number of exhibits, if you look at the top of the

19     B/C/S original, Serbo-Croatian original, of that document, would you

20     agree with me, sir, that the top of that document appears to have what we

21     call a fax information, a line of fax information, indicating that it was

22     faxed and it went apparently to the 058-521-771?  Do you have it, sir?

23     That's P 07541.  Do you have it?  Do you see the line on top, sir?

24        A.   I do.

25        Q.   Would you agree with me that that is what most of us consider to

Page 32661

 1     be an indication that a document has been faxed?

 2        A.   Yes.

 3        Q.   Now, would you look, please, next at Exhibit P 01572, P 01572.

 4        A.   Yes.

 5        Q.   Sir, do you see that this is in fact a telephone directory of the

 6     HVO Main Staff for March 1993, essentially a telephone book for the HVO

 7     Main Staff and various HVO units throughout Bosnia-Herzegovina, do you

 8     see that?

 9        A.   I can see it, but I haven't found the Croatian version yet.

10        Q.   I'm sorry, it should be behind --

11        A.   I found it.

12        Q.   Just for an example, on the first page under department of

13     defence HZ HB you see the name for Mr. Bruno Stojic, and you see I think

14     three telephone numbers associated with his name.  Do you see that?

15        A.   I see it.

16        Q.   All right.  We won't go through it.  There's no point in going

17     through others I think.  Would you look at Exhibit P 0 --

18             JUDGE TRECHSEL:  I'm sorry, Mr. Scott --

19             MR. SCOTT:  Yes.

20             JUDGE TRECHSEL:  -- I have not found a date for this document and

21     I would be interested to know --

22             MR. SCOTT:  Yes, of course, Your Honour.  On the top of the front

23     page -- at the bottom of the front page I think you will find the date

24     March 1993, the cover of the directory, if you will, do you have it, Your

25     Honour?

Page 32662

 1             JUDGE TRECHSEL:  Yes.

 2             MR. SCOTT:  Thank you.

 3        Q.   If you could go next of all -- as just another example to

 4     P 03053, P 03053.

 5        A.   Yes.

 6        Q.   And you see again, this is a document that was put out sometime

 7     in 1993.  I'm afraid that we just have a blank 1993, once again a list of

 8     telephone numbers for various HVO units.

 9        A.   Yes.

10        Q.   And if you could next go, please, to P 01818.  Now, sir, I

11     realize you may or may not have seen this document before today, but

12     given what the international observers and different organizations were

13     trying to do in Bosnia-Herzegovina during 1992 and 1993, 1994, would it

14     surprise you that as part of their work they would prepare a list of

15     telephone numbers to use in carrying out their work?  And if I can direct

16     your -- there is a second heading, number 2, Government of Herceg-Bosna

17     HVO, and you'll see a number of individuals, officials, President Mate

18     Boban, general secretary; president of HV government, Jadranko Prlic; a

19     number of telephone numbers.  Is that right?

20        A.   I see it.

21        Q.   Would it surprise you, sir, if I told you that in fact one of the

22     witnesses who came and testified here still had some of these same

23     telephone numbers on his cell phone when he came to the courtroom?

24        A.   No.

25             THE INTERPRETER:  The interpreter did not understand what the

Page 32663

 1     witness said.

 2             MR. SCOTT:

 3        Q.   If you could next go, please, to P 02172 --

 4             JUDGE TRECHSEL:  I'm sorry.

 5             MR. SCOTT:  Yes.

 6             JUDGE TRECHSEL:  The witness said something which the

 7     interpreters had not heard.

 8             Witness, could you please repeat your last answer what you have

 9     said; the interpreters did not hear it.

10             THE WITNESS: [Interpretation] The Prosecutor said that one of the

11     witnesses today still has these numbers in their mobile telephone, and I

12     said he probably did not update his mobile telephone directory.

13             MR. SCOTT:  I thank Your Honour about that, sir.

14        Q.   You could be right.  If we could go to P 02172.  Turning a bit

15     from telephone, if I can just ask you, you have that, sir.  This is a

16     document that seems to indicate the existence and operation of a

17     telephone network in giving a set of numbers, ID numbers, stations, the

18     persons or units with that radio location or call-sign, and a code or

19     call-sign for each of the people.  The first one is for May 1993.  The

20     second page is for June 1993.  The third page is for July 1993.  Do you

21     see that?

22        A.   [No interpretation]

23        Q.   And if you possibly just have a moment -- well, I won't say it.

24             Number 1 for May 30, the code-name for the chief of the HVO Main

25     Staff was Atila in May 1993; is that correct?

Page 32664

 1        A.   Yes.

 2        Q.   Can you go, please, to P 03866.  If you have that, sir -- now,

 3     this talks about the organization of packet radio communications.  In the

 4     course of your work with communications in this time-period,

 5     1992/1993/1994, did you ever hear of or become familiar with a form of

 6     radio communication called packet communication?

 7        A.   Yes.

 8        Q.   And would it be fair to say that that's something like -- a bit

 9     like a field fax, a text -- typed text is entered in, it is sent by a

10     radio signal, and then you get a text print-out at the other end?

11        A.   This is a radio network for data transfer.  You can receive a

12     fax.

13        Q.   All right.  I thank you for that, sir.  We have been able to move

14     more quickly.  I do appreciate it.

15             JUDGE ANTONETTI: [Interpretation] Regarding the last document,

16     Witness, which is a military-type document, this type of communication,

17     packet radio communication, I see telephone numbers and I see always that

18     they start with 058.  In other documents that we saw before, these three

19     figures were the same for basically all the numbers.  This would seem to

20     indicate that at least in August 1993 telephones were working.

21             THE WITNESS: [Interpretation] Mr. President, I was shown these

22     documents, but I did not get a question so I don't know why they were

23     shown to me.  First of all, I can speak in some detail about

24     communications that were part of the public telecommunications system

25     because that's what I worked on, that's what I knew about.  Of course

Page 32665

 1     there were military communications systems that were used by military

 2     units.  They used radio equipment to communicate, including packet radio

 3     and voice transmission network.  Of course those communications existed

 4     and they were used.  I think that the question here is -- well, I did not

 5     contest the fact that some places in Herzegovina had communications at

 6     all times.  Sometimes they were better, sometimes they were worse.

 7     Mostar itself was cut off for one or two days, but some minimum level of

 8     communications was re-established quite soon.

 9             Now, the question is where the 058 appears.  At that time,

10     because we were unable to solve it in any other way, we had some direct

11     connections to the Split exchange and priority users availed themselves

12     of that.  That is so-called remote user, a subscriber, a subscriber that

13     is connected let's say from Citluk to Split, but that's not unusual at

14     all.

15             So I couldn't really speak in any detail about military

16     communications.  You need to call a witness who deals with those issues

17     because this is not something that I've ever dealt with in my life.  But

18     as far as the civilian, public, telecommunications system, I consider

19     myself an expert.

20             JUDGE ANTONETTI: [Interpretation] Please look at the document

21     under item 4, it is in your language at the top of page 3.  In group 4 we

22     can see that there is HVO Mostar, GSS Mostar, and then under number 6 I

23     can see that it is the office of the president of HZ HB, and there is

24     088/662-760, that's the number.  What do you have to say to that?

25             THE WITNESS: [Interpretation] Could you please tell me what

Page 32666

 1     document because several documents were mentioned now.

 2             JUDGE ANTONETTI: [Interpretation] Wait a minute, it is 3866.

 3             THE WITNESS: [Interpretation] Fine.  And 0 --

 4             JUDGE ANTONETTI: [Interpretation] Please go to page 3 in your

 5     language, top of the page.  You can see "grupa," look under 6.

 6             THE WITNESS: [Interpretation] Yes.

 7             JUDGE ANTONETTI: [Interpretation] You can see that there is a

 8     number, 088/662-760.

 9             THE WITNESS: [Interpretation] Yes.  Well, before the war every

10     larger town had its area code.  Mostar's code was 088, Split was 058,

11     Livno was 080, Central Bosnia was 071, and so on.  And during the war the

12     area codes remained the same.  It was changed later.  Now we have a

13     different area code for those areas, but this was -- these were the area

14     codes that were in use before the war and remained to be used during the

15     war.

16             JUDGE ANTONETTI: [Interpretation] But at the date when this

17     document was made, on the 1st of August, 1993, with regard to the office

18     of the president, did it have a telephone line?  That's my question.

19             THE WITNESS: [Interpretation] At that time, for sure it did,

20     August 1993.  At that time our communications were pretty much regular.

21     It was in August 1992 that the communications were quite bad, but by

22     August 1993 they were already up to the very good level.

23             JUDGE ANTONETTI: [Interpretation] Mr. Scott.

24             MR. SCOTT:  Thank you, Mr. President.

25        Q.   And while we're on that document, sir, before you move on and

Page 32667

 1     perhaps I was a bit too hasty.  But on P 03866, in addition to the number

 2     that the President has focused on, would you please also look at in group

 3     number 1 -- the first one starts with HVO Main Staff, number 1, but as

 4     you continue down the list do you see number 6, Central Bosnia operative

 5     zone Vitez; number 7, Bosnian Posavina; number 8 Ban Josip Jelacic

 6     Brigade, Kiseljak; number 10, Novi Travnik; number 11, Zepce; number 12,

 7     Vares; 13 Busovaca; 14, Vitez again; and 15, Sarajevo.  Do you see the

 8     packet communication links listed for all of those locations?

 9        A.   Yes, I see that.

10             JUDGE TRECHSEL:  As we are with this document, Witness, in the

11     English text on the bottom of page 3, and in the B/C/S text I think it's

12     on page 3, the first paragraph after the list of six numbers.  There is

13     reference also to short-wave radio, KV short wave set.  Would that be

14     something like ham radio, technically?

15             THE WITNESS: [Interpretation] It's different.  I think it's

16     different.  To be quite frank, I'm not all that familiar with this type

17     of equipment because I have never dealt with military communications.

18     Ham operators have transmitters and radio stations that can transmit over

19     a huge area, and that is their purpose, to transmit over the whole world.

20     And there is a special period of day when the signal can be transmitted

21     very clearly and very far, and that's when they work.  I would say that

22     these are short-distance radios that cover a very broad area around the

23     repeater, in particular because they have encryption equipment so that

24     they cannot be intercepted, and everybody can intercept conversations

25     over ham radio equipment.

Page 32668

 1             JUDGE TRECHSEL:  But they also use short wave, don't they?

 2             THE WITNESS: [Interpretation] You mean ham radio operators?

 3             JUDGE TRECHSEL:  Yes.

 4             THE WITNESS: [Interpretation] Yes, yes, short wave.

 5             JUDGE TRECHSEL:  Thank you.

 6             Mr. Karnavas.

 7             MR. KARNAVAS:  Just a correction, on page 83, line -- page 84,

 8     line 21, he didn't say "broad area" but short area, small area, something

 9     to the -- but it was the opposite of broad.  Short-distance radios that

10     cover a very short area, that's how my colleague heard it, but we can ask

11     for a clarification.

12             JUDGE TRECHSEL:  Could you clarify that, Witness, what did you

13     say?  A short-distance and ...

14             THE WITNESS: [Interpretation] If you're talking about military

15     radio equipment, there are different kinds.  Usually they cover a very

16     narrow area --

17             JUDGE TRECHSEL:  Thank you.

18             THE WITNESS: [Interpretation] -- a short distance.  Radio ham

19     operators, they cover broad areas.

20             JUDGE TRECHSEL:  Thank you.

21             JUDGE ANTONETTI: [Interpretation] Just a few more seconds on

22     this.  Please look at page 4 in this document, right at the bottom of the

23     document, you can see a stamp with some indications, various indications,

24     regarding the stamp.  You keep in mind that you had the HVO GS, telegram

25     5320, 31st of August, 1993, and then the time is indicated, and you can

Page 32669

 1     see some acronyms, TLP, TGR, TLF, RRV, ZV, and RV.  So TLF, I suppose,

 2     stands for telephones; TGR, telegraphs; TLP, that stands for teleprinter;

 3     RV, I suppose that's radio communications.  The documents of the 1st of

 4     August, 1993, that was sent to all operational areas looks as though it

 5     was sent by radio communication because you have RV that is underlined.

 6     The very fact that there is a stamp in which telephone, TLF, is

 7     indicated, does it show that back then there were various

 8     telecommunication systems available to the entities sending messages.

 9     Here this time it came from the Main Staff and it was sent to the

10     operational areas, but it was sent by a packet radio.  I'm interested in

11     the fact that a TLF is mentioned in the stamp, which may indicate that in

12     August 1993 telephones were working too.

13             What do you think of this?

14             THE WITNESS: [Interpretation] If it is your task to send a

15     document, you can send it in a number of ways.  It depends on the level

16     of confidentiality.  The military will probably use the type of

17     communications that allows encryption, and as far as I know packet radio

18     does make it possible.  Of course there are other types of

19     communications, but it doesn't mean that they existed all over the place.

20     The military probably provided radio communications and packet radio

21     communications wherever it was operating, where its units were operating.

22     It couldn't send a unit out unless that unit had communications equipment

23     that worked.  I keep telling you that I'm an expert in public

24     communications.

25             JUDGE TRECHSEL:  I'm sorry, Mr. Witness, it occurs to me when

Page 32670

 1     looking at the stamp that the second T in PTT traditionally means

 2     telegraph, and it is one means of communication we have not touched upon

 3     at all yet.  Normally it would have been within your realm and

 4     competencies.  Can you tell us anything about communication by telegraph,

 5     particularly 1992/1993?

 6             THE WITNESS: [Interpretation] Well, the only thing I can tell you

 7     is that at times it was a widely used network, the telegraph network in

 8     public communications.  But when Telefax appeared, this type of

 9     communication was set aside and in recent times telephone lines were used

10     for telegraph communications but by those who needed it.  To my

11     knowledge, those are financial institutions.

12             JUDGE TRECHSEL:  Excuse me, Witness, I have simply misspoken.  I

13     wanted to ask about telegram because that is mentioned here.  This is

14     apparently a telegram and it's nowadays it doesn't exist anymore I think,

15     but at that time it was still one possibility and what was the situation

16     for that in Mostar in 1992/1993?

17             THE WITNESS: [Interpretation] Telegrams are a different thing.

18     Telegrams are received by post offices.  Post offices received letters

19     and telegrams, and then they deliver it in any way they can, by telephone

20     or by fax or by teleprinter.  But military organizations probably used

21     this type of service more often.

22             JUDGE TRECHSEL:  But was it possible in a different way than what

23     we have already spoken about, you do not have to repeat all that, to

24     communicate by telegram between Mostar and Sarajevo?

25             THE WITNESS: [Interpretation] You have to understand that

Page 32671

 1     telegrams are transmitted over telephone lines.  So if you don't have

 2     telephone lines, then this kind of communication is impossible.  There is

 3     not a separate network for the transmission of telegrams.

 4             JUDGE TRECHSEL:  Thank you.

 5             THE WITNESS: [Interpretation] You're welcome.

 6             MR. SCOTT:

 7        Q.   All right, sir, if we could move forward in the last few minutes

 8     here and see if we can again make some progress.  I would like you to

 9     turn your attention to - and this is a separate binder - the entire

10     binder was marked as Exhibit 10633, 10633, it's titled for the record and

11     for the usher:  "Examples of communications with Central Bosnia including

12     Sarajevo."  And I do have -- you will see -- look at the schedule, sir,

13     and I had the impression that you at least read English based on various

14     things that you've said, but I also -- if you look behind -- I think at

15     least as to the last column, the column on the right, the far right,

16     you'll find a Serbo-Croatian version in your binder I hope.  And, sir,

17     what I've done here, we can go -- well, if we had enough time we could go

18     through all 48, I suppose, I think it's 48 -- I'm sorry, 46.

19             Various communications that these documents seem to indicate on

20     the dates indicated are between Sarajevo and other places outside of

21     Sarajevo, including large -- in instances Mostar and Grude or in some

22     places in Herzegovina.  Perhaps just to give you some examples so

23     everyone in the courtroom knows the process involved here.  In the binder

24     there's a separate set of tab numbers, and if you can go, please, to

25     P 00346, P 00346.  It should be the third document in the binder.

Page 32672

 1             You will see I think, sir, if you have that, this is a letter

 2     dated the 26th of July, 1992, from Mr. Markesic secretary general of the

 3     HDZ BH, and says:  "Reference:  Your letter number U 46/92 of 22nd July

 4     1992."

 5             And again, sir, my purpose of showing you these documents is not

 6     to discuss the content of the document, but doesn't that document

 7     indicate it is in response to a document coming from a response -- it's

 8     going to the constitutional court, excuse me, indicating that a letter

 9     had been received to which this letter is responding between the 22nd of

10     July and the 26th of July, 1992?

11        A.   [No interpretation]

12        Q.   Yes.  Would you please look at the very next document, I'll to

13     keep it as simple as possible --

14             MR. KARNAVAS:  Your Honour, just for point of clarification, we

15     should understand that this is within Sarajevo, so it's Sarajevo to

16     Sarajevo as I understand it.  So -- and that's the whole point --

17             MR. SCOTT:  If --

18             MR. KARNAVAS:  -- that's the whole point, and I'm going to be

19     hitting hard at this issue at some point that when they claim notice they

20     give notice to HDZ Sarajevo.

21             MR. SCOTT:  If I --

22             MR. KARNAVAS:  This is the constitutional court.  If they were

23     really interested, they would be directing it someplace else.  So if

24     we're going to use this as an example, it's a poor example, bad one,

25     choose another one.

Page 32673

 1             MR. SCOTT:  Well, excuse me, Mr. Karnavas, it may be a bad

 2     example; if it was, my apology, and there is no reason to get too worked

 3     up about it.  If I'm mistaken, if we selected -- my apologies to both the

 4     witness and the courtroom.

 5        Q.   Perhaps if you could go to P 00391, just as a different process,

 6     this concerns a meeting that was held in -- according to the top of the

 7     document, and I apologise, it's getting late in the day, these are

 8     minutes from a meeting in Grude on the 14th of August, 1992.  And when we

 9     look at the persons in attendance there seem to be people from many parts

10     of Central Bosnia, Gornji Vakuf, number 13; number 15, Novi Travnik;

11     number 22, a man from Vares; number 29, Dario Kordic from Busovaca;

12     number 30, three men from Sarajevo; et cetera; Perica Jukic from Central

13     Bosnia HVO.

14             It appears to indicate, does it not, that these people were able

15     to travel to Grude for purposes of this meeting; correct?

16        A.   I was not there, but they probably did get there.

17        Q.   All right.  Well, I'm not trying to force anything on to you.

18     I'm just saying that that's what the document would appear to indicate,

19     doesn't it?  Taking the document on face value.

20        A.   Yes.  Well, they either went there or they were there all the

21     time.

22        Q.   And if you could look at one -- in the same binder and there's

23     also a mixture of P and D, but if you can please find 1D 01182, I believe

24     this is a document we've seen in the courtroom before, 1D 01182.  It's

25     probably well down into the binder.  I also had trouble finding that one,

Page 32674

 1     sir, I'm sorry.

 2             All right.  On the e-court, thank you.  Again, sir, this appears

 3     to be a document of minutes of a meeting on the 27th of February, 1993,

 4     and just as an example I think if you go down to paragraph number 4 of

 5     the document -- paragraph numbered 4, it's at the bottom of the page 2 in

 6     the English, I'm not sure about the -- let me see.  Either number -- you

 7     have it there, page 2 of the Serbo-Croatian version.  It's again

 8     reference to an exchange of letters or correspondence between Mr. Prlic

 9     and someone named Mahmutcehajic.  Do you see that?

10        A.   Yes, I can see that.

11        Q.   Sir, we're at the end of the time for today, and I simply

12     illustrate to you the process that went into the selection.  Mr. Karnavas

13     has absolutely, it appears, to have caught one, that's my error, and we

14     will remove it from the binder, but, sir, you didn't -- in talking about

15     communications between Mostar and Sarajevo, just to be clear, you didn't

16     mean to suggest to the Chamber that there was no communications between

17     Mostar and Sarajevo; correct?

18             MR. KARNAVAS:  Your Honour, the gentleman never suggested that.

19     He never suggested that yesterday at all, and we'll concede the point

20     that he indicated at times you would send through a courier that would

21     have to go through the tunnel, but there has never been any suggestion

22     and he can pose the question again.  But I want to make it clear and I

23     invite the Chamber, any one of you, to point to the transcript where the

24     gentleman did indicate there was no communication.  It depends on what

25     period, what time, what type.

Page 32675

 1             MR. SCOTT:  But --

 2             MR. KARNAVAS:  But I think we need to be -- let's be fair to the

 3     gentleman --

 4             MR. SCOTT:  I --

 5             JUDGE TRECHSEL:  I was in fact going to intervene because this

 6     makes reference to a letter.

 7             MR. SCOTT:  Yes.

 8             JUDGE TRECHSEL:  I have not studied the document as well as you,

 9     no doubt, have.  But can you point out where the means of transport of

10     the letter is indicated because it might be by courier.  It --

11             MR. SCOTT:  I wasn't communicating -- I wasn't for this purpose,

12     Your Honour, suggesting anything to the contrary.  Again, the broad

13     point -- in response to Mr. Karnavas's point, and again I don't think

14     there's any reason for anyone to be short with anyone else, simply I want

15     to be very clear given some of the rather, what I thought, categorical

16     statements by the witness about communication, make it very clear that

17     the Chamber wasn't left with the impression that the statement was in

18     fact broader than apparently Mr. Karnavas has indicated it is.  There

19     were -- and I will put to the witness, that there were in fact, and he

20     apparently agrees -- and again I'll be corrected tomorrow if I'm wrong,

21     there were various methods of communication between Sarajevo and Mostar

22     including courier throughout this time-period.  That was my point, Your

23     Honour.  If that's not disputed, then so much the better.

24             JUDGE ANTONETTI: [Interpretation] Very well.  It is 7.00.

25     Mr. Scott, you have used two hours so far.  You have one hour left.  As

Page 32676

 1     you know, we shall convene tomorrow at 2.15.

 2             Witness, you will be back in this courtroom tomorrow.  Have a

 3     good evening.  I wish a good evening to all of you.  Thank you.  See you

 4     tomorrow.

 5                           --- Whereupon the hearing adjourned at 7.01 p.m.,

 6                           to be reconvened on Wednesday, the 24th day of

 7                           September, 2008, at 2.15 p.m.