Tribunal Criminal Tribunal for the Former Yugoslavia

Page 11597

 1                           Friday, 11 June 2010

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.10 a.m.

 5             THE REGISTRAR:  Good morning, Your Honours.  This is case

 6     IT-08-91-T, the Prosecutor versus Mico Stanisic and Stojan Zupljanin.

 7             JUDGE HALL:  Thank you, Madam Registrar.  Good morning to

 8     everyone.

 9             May we have the appearances, please.

10             MR. HANNIS:  Good morning, Your Honour.  Tom Hannis with case

11     manager Crispian Smith for the Prosecution.

12             MR. ZECEVIC:  Good morning, Your Honours.  Slobodan Zecevic,

13     Eugene O'Sullivan, and Ms. Tatjana Savic appearing for Stanisic Defence

14     this morning.  Thank you.

15             MR. PANTELIC:  Good morning, Your Honours.  For Zupljanin

16     Defence, Igor Pantelic, Dragan Krgovic, and our intern Mr. Miroslav

17     Cuskic [phoen].

18             JUDGE HALL:  Thank you.

19             If there is nothing that need -- yes, Mr. Hannis.

20             MR. HANNIS:  Your Honour, I can do it now or I can do it after I

21     finish my last question.  I have spoken with the Defence about certain

22     documents.  I have five payroll-type documents.  I think we have an

23     agreement that I can tender those without further questions to the

24     witness.  And then there are a series of documents that are called daily

25     bulletins of various types that I would propose to tender without any

Page 11598

 1     further questions to the witness.  There are three of them that I will

 2     show him because there are three different kinds of daily bulletins based

 3     on the source, where they come from, and I have agreed with Mr. Zecevic

 4     in order to do that that none of those that I'm tendering have a

 5     signature of Mico Stanisic.  Some have no signature.  Some have a

 6     typewritten Mico Stanisic with no signature.  Some have his typewritten

 7     name and a signature by somebody else, sometimes with the word "za" and

 8     sometimes not.

 9             JUDGE HALL:  Dealing with the daily bulletins first, I assume

10     from what you say has passed between you and counsel for the Defence that

11     the relevance of these is patent?

12             MR. HANNIS:  Your Honours, my primary purpose in offering these

13     is to show that there were contemporaneous reports about things that were

14     happening in the region at the time and to show that that communication

15     was -- went up and down within the MUP and outside the MUP.  The contents

16     of many of them aren't significant for me at this point, but to establish

17     the fact of communication, the regularity of communication, and the

18     persons with whom communications were made is the purpose in offering

19     this group of documents.

20             JUDGE HALL:  Is anything that the other side -- any comment that

21     the other side has to make?

22             MR. ZECEVIC:  Well, we have definitely a different view on the

23     subject, but I don't think that it would be appropriate at this point

24     that we -- that we state our position on that.  But in any case, we are

25     not objecting under the circumstances, as Mr. Hannis have said, that is,

Page 11599

 1     we don't have objection of -- we don't object that those are the

 2     authentic documents.

 3                           [The witness takes the stand]

 4             JUDGE HALL:  Thank you.

 5             MR. ZECEVIC:  Thank you very much.

 6                           [Trial Chamber confers]

 7             JUDGE HALL:  Mr. Zecevic, the -- in terms of the daily bulletins,

 8     do I understand your position to be that your -- your objection is not --

 9     you have no objection to the authenticity of them, but the secondary

10     question is whether there is any issue as to the fact of these

11     communications.  Because as I understand Mr. Hannis's explanation, he

12     isn't going to seek to argue that the content is particularly helpful;

13     it's merely the fact of the system of communications.  And I'm wondering

14     whether that is in controversy.

15             MR. ZECEVIC:  Well, Your Honours, as I said, the authenticity we

16     don't challenge.  The contents, we -- we want to rely on the contents

17     because the contents show what the ministry in fact knew about the facts

18     in the field.  It's very simple.  Of course we intend to rely on the

19     contents.

20                           [Trial Chamber confers]

21             JUDGE HALL:  In terms of the two categories of documents, we

22     would admit the bulletins, but not the payrolls because we're not

23     persuaded that those additional payrolls - bearing in mind that one was

24     admitted yesterday - are relevant.

25             MR. HANNIS:  Well, Your Honour, then I will perhaps try and make

Page 11600

 1     a bar submission later and point out the specific reasons why I think

 2     particular ones are relevant, and I'll move on and not bother to deal

 3     with it today.  Thank you.

 4             I will -- to save time I'll list the daily bulletin 65 ter

 5     numbers at the end rather than now.

 6             JUDGE HALL:  Yes, you've answered the question I was about to

 7     ask.

 8             MR. HANNIS:  Thank you.

 9             JUDGE HALL:  So long as we don't lose sight of something that has

10     to be done today.

11             MR. HANNIS:  No, I'll try and be sure and do it before I sit down

12     with this witness.

13             JUDGE HALL:  And I'll remind the witness that he's still on his

14     oath.

15             Yes, Mr. Hannis.

16             MR. HANNIS:  Thank you.

17                           WITNESS:  DRAGAN KEZUNOVIC [Resumed]

18                           [Witness answered through interpreter]

19                           Examination by Mr. Hannis: [Continued]

20        Q.   Good morning, Mr. Kezunovic.  I'd like to start by showing you a

21     document that is 65 ter number 2516, and this is a rather lengthy

22     document so maybe I can hand you a hard copy of the B/C/S.  This is a

23     document that you will have looked at during proofing.  Can you tell us

24     what it says on the cover page of the B/C/S.

25        A.   It says security services centre, the acronym is there, CSB.

Page 11601

 1        Q.   Thank you.

 2             MR. HANNIS:  Now if we could go to the next page in B/C/S and

 3     keep the English page that's up on the screen.

 4        Q.   This in my English translation appears to be a list of sent and

 5     received dispatches, and column 1 says "sent by, number, and date."  And

 6     the first entry says "SMUP BiH ..."

 7             Is that the MUP headquarters?  What does that refer to?

 8        A.   That should mean the Serbian MUP of Bosnia-Herzegovina.

 9        Q.   And where on April 22nd and 23rd would that have been located?

10     Would that be in Vrace or Pale?

11        A.   This should have been in Vrace.

12        Q.   Okay.

13             MR. HANNIS:  If we could go to page 4 of the English.

14        Q.   And for you, Mr. Kezunovic, I need you to find the page that has

15     entry number 13 at the top.

16             MR. HANNIS:  In e-court I think it's two pages further on.

17        Q.   And can you recognise the signature that's at the far

18     right-hand -- in the far right-hand column for entry number 13?

19        A.   This should be Pejic R, standing for Radovan probably, because

20     there was a Radovan Pejic among the employees.

21        Q.   That wasn't my question.  I wanted to ask you if you knew a - I

22     thought it was Radomir - Radomir or Radovan Pejic who worked at the

23     communications for CSB Sarajevo?

24        A.   Well, if that's a signals man that is operator, that is Radovan

25     Pejic.

Page 11602

 1        Q.   And looking at this entry under the column where it says "reply

 2     received from -- reply received from who, number, and date," we see what

 3     appear to be a series of telephone numbers.  Do you recognise those

 4     numbers and what -- and know what they might be associated with?

 5        A.   I can only recognise network groups by the prefix.  For instance,

 6     I can say the first number belongs to Banja Luka, the second one

 7     Sarajevo, the third one to Bijeljina, this one to Trebinje, and the final

 8     one to Doboj because this is the prefix of the number, the calling code

 9     for the city.  As for numbers, the actual telephone numbers, I don't know

10     them.

11        Q.   Okay.  And you see in addition to the CSBs for Banja Luka,

12     Sarajevo, Bijeljina, Trebinje, and Doboj, this one was also sent to the

13     staff in Pale?  And what's the last one.  It does not appear to have been

14     put in the English translation, but in your B/C/S copy there's a last

15     entry next to a telephone number.  I'm sorry, that's -- I think that

16     refers to the next item, number 14.  Can you tell me what that -- what

17     those two entries are under number 14.  Is it Pale staff -- do you find

18     that?

19        A.   Yes.

20        Q.   What does that say?

21        A.   It says "staff Pale," but what kind of staff, I really don't

22     know.

23        Q.   And underneath that, what does that next one say?

24        A.   "Vlada," meaning government, but I can't see the rest.  It says

25     "government BH," but I can't see what comes first before that.  It could

Page 11603

 1     be SR.  It is probably SR.  "The government of the SR, Serbian Republic,

 2     of Bosnia-Herzegovina."

 3        Q.   Thank you.

 4             MR. HANNIS:  If we could zoom out.

 5             JUDGE HARHOFF:  Mr. Hannis.

 6             MR. HANNIS:  Yes.

 7             JUDGE HARHOFF:  Are we able to discern from this document the

 8     nature of the items that were received?

 9             MR. HANNIS:  Yes --

10             JUDGE HARHOFF:  Was it phone calls, or was it dispatches or

11     letters?  What was it?

12             MR. HANNIS:  Yes, Your Honour, I'm going to try and link up a

13     couple of these to help illuminate this.

14        Q.   Item number 13 we see is listed as 01-26 dated 26-04-92.  And the

15     summary of contents says it's the supplement memo 01-18/92 dated 20 April

16     1992 regarding reception of workers.

17             MR. HANNIS:  If we could go briefly and put up on the screen

18     Exhibit P1420 to see if we can make a connection between that entry and a

19     document.  And if we could zoom in on the top half.

20        Q.   Can you see that on your screen, Mr. Kezunovic?  This appears to

21     be 01-26/92, dated 26 April 1992, to the five CSBs.  And right below the

22     CSB heads it says:

23             "In accordance with:  Our act number 01-18/92 from 20 April ..."

24             Would you agree that this appears to be the document that is

25     referred to in item number 13 of the log?

Page 11604

 1        A.   Yes, it is.

 2        Q.   Thank you.

 3             MR. HANNIS:  I would ask to go to page 10 of the English.

 4        Q.   And for you, sir, on your hard copy, if you could go to the

 5     last -- item number 49.  You'll see on -- and I'm not sure what page that

 6     is in the B/C/S in e-court, but you'll see that --

 7             JUDGE HARHOFF:  Mr. Hannis.

 8             MR. HANNIS:  Yes.

 9             JUDGE HARHOFF:  Before we leave this document.

10             MR. HANNIS:  Yeah.

11             JUDGE HARHOFF:  To -- is this -- was this document received at

12     the CSB or was it sent?

13             MR. HANNIS:  Your Honour, I'm hesitant to say certain things in

14     front of the witness, but we've seen that this says it was sent by --

15     from the ministry and the dispatch is sent to --

16             JUDGE HARHOFF:  Right, right.  So it was sent from the ministry?

17     That's the way we should understand this?

18             MR. HANNIS:  Yes, and you'll see the fax header on this

19     particular document is "Srpska Republika BiH MUP."

20             JUDGE HARHOFF:  Right.  It was just because I was led to believe

21     that the log-book was of the log-book -- the CSB Sarajevo log-book.

22             MR. HANNIS:  I'm --

23             JUDGE HARHOFF:  So why would --

24             MR. HANNIS:  I'm getting right to the point to try to explain

25     that, Your Honour.  That's why we're going to item number 49.

Page 11605

 1        Q.   You see item number 49, Mr. Kezunovic, appears to be the last in

 2     a series of entries of documents that were sent by the MUP headquarters

 3     or from MUP headquarters, and there's a line drawn across the last three

 4     rows that seems to indicate that that's being closed out in some fashion.

 5     Would you agree with me about that?

 6             MR. HANNIS:  I think we need one more page in the e-court, one

 7     page further on.  And if we could go to the bottom -- oh, I'm sorry, one

 8     more page.

 9        Q.   Did -- I'm sorry, did you answer my question?

10        A.   No, I was waiting.

11        Q.   Okay.

12        A.   I was waiting for my turn.  I agree that this has been underlined

13     and that it ends with a period, and that on the following page a new

14     chapter is being opened for the SB CSB, and it should be -- mean

15     "next" -- or rather, that this book was used up until this period where

16     the line is drawn as a log-book of the communications centre, which was

17     also the communications centre used by the Ministry of the Interior and

18     the CSB of Sarajevo.  And that from that time on it was divided and

19     continued to function as the log-book of the CSB.  This probably relates

20     to the initial period at Vrace, where there was one communications centre

21     catering to two organisational units, the ministry and the CSB.

22             But I'd like to make another mention here and that is that in the

23     heading, in the title, it says "sent and received dispatches."  Now, in

24     the communications centre separate log-books are kept for sent dispatches

25     and received dispatches, both coded and open ones.  And in that first

Page 11606

 1     period we did not have the same types of books or one book where the

 2     communications centre such as Vrace were functioning.  So somebody found

 3     one of these protocol books and used it, put it to use good use, and kept

 4     the records with this type of book.  So that was at the beginning, in the

 5     first period.  We have log-books which differ if you look at the columns

 6     inside.  It was only at the end of the year that we managed to print a

 7     united, single log-book, a uniform log-book, that we sent out to all the

 8     centres.  So at the beginning there might have been these different

 9     books, but that's the reason.

10        Q.   I think I don't have the correct B/C/S page in e-court to show

11     you what I want to show you.

12             Witness, can I ask you to read out at the top of that page you're

13     looking at, there should be an eight-digit number that's printed or

14     typed.  Can you read that page for us so I can get the computer on the

15     right page?

16        A.   You mean on my translation?

17        Q.   Yes, yes.  Do you see --

18        A.   0339-2387.

19             MR. HANNIS:  That's page 10, as I understand it.

20             THE WITNESS: [Interpretation] Yes, that's right, it is page 10.

21             MR. HANNIS:

22        Q.   And does it appear that these first 49 entries in this book are

23     actually dispatches that were sent?  None of them are received items but

24     they're all sent items?

25        A.   Well, yes I would say so, I would say that too.  That's why I

Page 11607

 1     told you that it says in the title.

 2             "Sent and received," but in actual fact it relates to those sent.

 3        Q.   And the last entry number 49 in this part of it is dated 13 May

 4     1992; correct?

 5        A.   The 13th of May, 1992, yes.

 6             MR. HANNIS:  If we could go to the next page in e-court.

 7        Q.   And, Witness, your next page shows just simply CSB Sarajevo?

 8        A.   Yes.

 9        Q.   And the following page for you, the next page in e-court, please,

10     in both English and B/C/S -- well, I think that's the end of English

11     because we only translated those portions relating to MUP headquarters.

12     But for the first page after CSB Sarajevo we see now the numbers start

13     with the number 1 and the first item is dated 14 June it looks like; is

14     that correct?

15        A.   Yes.

16        Q.   From your earlier answer I understood you to be telling us that

17     in the beginning April and early May, MUP communications centre in Vrace

18     shared space with the CSB Sarajevo communication people; is that right?

19        A.   That's only in formal terms.  The communications centre was one,

20     the same people working in it, whereas the function, that is to say to

21     whom that centre served, as I said we shared it with MUP and the CSB of

22     Sarajevo.  So there was one centre, the same installations, the same

23     people working for two organisational units, distributing dispatches and

24     receiving dispatches from two organisational units.

25        Q.   Thank you.  And it appears that after May sometime this log-book

Page 11608

 1     was taken over and used exclusively by CSB Sarajevo communications

 2     people?  You'll have to answer out loud.

 3        A.   Yes.

 4        Q.   And when did you in the MUP headquarters communications personnel

 5     move to Pale approximately and set up business there?

 6        A.   Well, I can't give you an exact date, but I can give you the

 7     sequence of events chronologically.  A decision was taken, first of all,

 8     that the security centre should relocate from Vrace to Lukavica, and at

 9     the time those of us who belonged to the MUP returned to Pale.  As I say,

10     I can't give you a date.  I don't remember, but chronologically speaking

11     that's how things evolved when that decision was taken.  That's when the

12     employees of the CSB moved to Lukavica and those of us who were in the

13     MUP returned to Pale.

14        Q.   And apparently after 13 May you must have had a different

15     log-book you were using for sent dispatches?

16        A.   You mean the MUP headquarters?

17        Q.   Yes.

18        A.   Then we continued to receive and send out dispatches through the

19     communications centre, which was at Pale.  Because as I said earlier on,

20     almost half of the leading people in that official period was at Pale and

21     the other half were at Vrace --

22        Q.   I'm sorry --

23        A.   -- and as I say, that's how the Pale centre in Pale came to be

24     formed, and then it continued working for the requirements of the MUP.

25        Q.   I think we had a miscommunication.  My question was:  After May

Page 11609

 1     13th then when you were working in Pale you must have had a different

 2     log-book in which to enter sent and received dispatches?

 3        A.   Physically speaking, this book in physical terms, the book we

 4     have in front of us, the one you're pointing to, was transferred to a new

 5     location which was the CSB.  And the line was drawn under that and CSB

 6     was written, security services centre, and then they continued to use

 7     that book in the centre exclusively as a book of records of the

 8     communications centre of the security services.  Now, the book that was

 9     physically used at the MUP in Pale functioned normally.  It was just that

10     the users, those from the MUP who were at Vrace, joined up and sent their

11     dispatches via that centre at Pale too.  But what you asked me about the

12     exact date when I transferred, I don't know, and here's why I don't

13     know --

14        Q.   I'm --

15        A.   -- as somebody who was -- all right.

16        Q.   I'm sorry, I need to stop you.  I'm -- I have limited time and so

17     I need to move on.  Thank you for that.

18             MR. HANNIS:  I would like to tender this document.  I just gave

19     one example where we matched up an entry in the log-book with some

20     documents that we already have in evidence.  There are others, but I --

21     unless Your Honours require, I can indicate them to you or I can do that

22     later.  But I need to try and move on and get some of the other things in

23     I want.

24             JUDGE HALL:  Yes, so it's -- admitted and marked, the -- that's

25     the --

Page 11610

 1             MR. HANNIS:  That's the log-book --

 2             JUDGE HALL:  -- log-book, thank you.  The name has escaped me.

 3             MR. HANNIS:  The 65 ter --

 4             THE REGISTRAR:  As Exhibit P1428.

 5             JUDGE DELVOIE:  Can we have the 65 ter or the tab number, please.

 6             MR. HANNIS:  That was 65 ter 2516.

 7             JUDGE DELVOIE:  2516, thank you.  Oh, yeah, tab 1.

 8             MR. HANNIS:  Tab 1.

 9        Q.   Thank you, Mr. Kezunovic, I want to ask you next just about a

10     question about Sokolac.  Did you know a man named Dusko Malovic?

11        A.   Yes, I did.

12        Q.   And were you aware of a unit that was referred to as the Sokolac

13     unit or the police platoon from Sokolac of which Mr. Malovic was the

14     commander?

15        A.   I just know about the police station at Sokolac and the policemen

16     working in that police station.

17        Q.   Do you know about Mr. Malovic and a group of men he commanded in

18     1992?

19        A.   I know the following about him, that he originated from the area,

20     he was born there, he worked in the army, and he did service somewhere in

21     Croatia.  That's what I heard -- not from him, but that's what people

22     said.  And that after the withdrawal from Croatia he was in

23     Bosnia-Herzegovina.  Now, who he belonged to exactly, I really can't say.

24        Q.   Did you --

25        A.   I mean in organisational terms.

Page 11611

 1        Q.   Did you not see him in and around Pale in 1992 when you were

 2     working there?

 3        A.   Yes, I did.

 4        Q.   And what kind of uniform did he wear?

 5        A.   Well, I think it was some kind of camouflage uniform.

 6        Q.   Was there anything unusual about the particular camouflage

 7     uniform that he wore that distinguished it from other camouflage uniforms

 8     you saw in Pale?

 9        A.   I seem to remember that when I first saw him on one occasion he

10     was wearing the customary type of uniform, our uniform - and when I say

11     "our," I mean the one that was used from before.  Now, later on he had

12     this kind of camouflage uniform which -- well, what can I say?  It was a

13     sort of combination of black, grey, white, I don't know how to describe

14     it actually.  Perhaps a uniform suited to winter conditions, let's say,

15     although I have seen those same uniforms on television of late in police

16     forces throughout the world in different areas, the same or very similar.

17        Q.   Okay.  Let me ask you now about tab 84.  This is 65 ter 3218.  I

18     can hand you a hard copy of this one as well.  Thank you.

19             This appears to be another sort of log-book.  I just have a

20     couple of questions about this one.  The left column which is entitled in

21     my English translation "postal number and date" has a series of numbers

22     beginning with 10-2/92.  Can you tell us anything about that series of

23     numbers, what that would refer to?

24        A.   Well, in principle, yes.  It's the number from the document that

25     we mentioned yesterday, the nomenclature, and how all the internal

Page 11612

 1     organisational units of the Ministry of the Interior were designated;

 2     that is to say, the document originates from some of those organisational

 3     units or a organisational unit that had that number to designate it,

 4     number 10-26 probably in line from 1993.

 5        Q.   1993?

 6        A.   Well, if it says dash 93 and if it's all 1993 then I assume

 7     that's what it is in that whole column, the date sent, 21st of March,

 8     1993, et cetera.

 9        Q.   I'm sorry, the page that I'm looking at, the first row is

10     scratched out.  Is that what is on your hard copy?

11        A.   Yes, that's right.

12        Q.   And number 2, 10-2/92, my date says 09-November-92?

13        A.   No.  In my copy it says 10-26/93.

14        Q.   Can you see the computer screen.  I may have handed you the wrong

15     page.  Can you see on the computer screen that these appear to be all

16     1992 entries, 1992?

17        A.   Yes, that's right.

18        Q.   If I could have the hard copy back and see what I've handed him.

19     I see.  It was upside down.  You had the last page first.  And if you

20     could go to item number 24.  I think it's maybe the third page for you.

21     You see in the far right there are a series of signatures.  Are you able

22     to recognise any of those signatures as anyone you know or worked with?

23        A.   These are the signatures of the operators in the communications

24     centres.  I never received anything in writing from them for me to be

25     able to follow their signatures and see their signatures, but at all

Page 11613

 1     levels if the last level was the CSB they had their team leader and he

 2     communicated on their behalf so that I really can't recognise their -- I

 3     don't know their signatures.  If I knew which organisational unit this

 4     belonged to and remembered some of the names, then perhaps I might be

 5     able to recognise the signatures and read them.  But just looking at the

 6     signatures without knowing whose book this is, what organisational unit

 7     it belonged to, I really can't.  It's practically impossible.

 8        Q.   Okay.  I understood in proofing that you -- I thought you

 9     understood that you were able to read some of the names.  Even though you

10     might not recognise the signature, you were able to read the handwriting

11     and identify that as a person that worked in your communications centre;

12     is that correct?

13        A.   What I'm saying is this.  For example, I can see "Zoka."  "Zoka"

14     can only be Zoran.  Now, which Zoran is another matter.

15        Q.   And how about item number 30, Todor C.  And Zoka?

16        A.   Zoka, yes, same thing, Zoka.

17        Q.   Todor?  All right.

18        A.   I don't know.  It says "Todor."  It does say "Todor."

19        Q.   Let me ask you to go back to the first page and just a couple of

20     questions about some abbreviations or acronyms.  On the first page item

21     number 3, it says "dispatch 'SS-W-U.'" Can you tell us what those letters

22     stand for?

23        A.   The SS is, in fact, a teleprinter mark for the S diacritic Sh

24     letter, and the other is very urgent.

25        Q.   And what would Sh be, the SS, what would that be?

Page 11614

 1        A.   Coded, encrypted, "sifrovano."

 2        Q.   Thank you.  I don't have any further questions about that.

 3             MR. HANNIS:  Can we mark this for identification, Your Honours?

 4     I think I might be able to tie it up with a future witness.

 5             JUDGE HALL:  So marked.

 6             MR. HANNIS:  Thank you.

 7             THE REGISTRAR:  As Exhibit P1429 marked for identification,

 8     Your Honours.

 9             MR. HANNIS:

10        Q.   I think the last thing I want to ask you about, Mr. Kezunovic, is

11     yesterday we were talking about some of the meetings you attended where

12     Mr. Stanisic was speaking, and I asked you about one where paramilitaries

13     were discussed.  You talked about a group that was in Zvornik and by whom

14     you were actually stopped on one occasion when you were travelling that

15     route, and you couldn't remember the name of the group.  I have a copy of

16     a portion of your tape recorded interview with the Prosecution in 2004,

17     where you're talking about that.  If I could hand it to you and ask you

18     to take a minute or two to read it, the portion that I've marked, I will

19     ask you a question when you finish reading it.  Don't tell me what it

20     says.  Just tell me when you've read it and then I'll ask you a couple of

21     questions.

22             JUDGE HALL:  Mr. Hannis, while we are waiting, we would alert you

23     that you would exhaust your time when we take the break at 10.25.

24             MR. HANNIS:  Your Honour, I intend to be done before that with

25     any luck.

Page 11615

 1        Q.   Now that you've had a chance to read it, did that refresh your

 2     memory about the name of the group that you encountered in Zvornik, just

 3     yes or no?

 4        A.   I think that I could remember the man better if you described

 5     him, or rather, the man in -- at the head of that unit -- well, actually

 6     I could remember him better.  He had very specific hair, whether it was

 7     blond, sort of golden blond or russet coloured.  Anyway, they called him

 8     Zuco.  Now whether that's the man, I don't know, or if that's the group

 9     because I saw him on an elevation on a hill above the road with the sun

10     behind him, so I don't think I could remember his face either, but I do

11     remember this characteristic hair colour.

12        Q.   But apart from that, having read that, did that refresh your

13     memory about what the name of Zuco's group was or what they were referred

14     to as, yes or no?

15        A.   Well, look, someone who dealt with this problem -- I mean, I read

16     hear "ose," wasps, but I cannot claim anything for a fact because I

17     didn't know any one of them and I didn't know the group as a group.  If

18     you have a witness who knows --

19        Q.   Thank you --

20        A.   -- that such a group operated in that area, it's possible.

21        Q.   Let me turn now and show you Exhibit Number 36.

22             MR. HANNIS:  And, Your Honours, and my learned friends, what I'm

23     going to do is show three different types of daily reports just to show

24     the difference between three kinds that are within the bunch I hope to

25     tender when I finished.

Page 11616

 1             JUDGE HARHOFF:  [Microphone not activated]

 2             MR. HANNIS:  Three types of daily reports varying according to

 3     the source basically.  So the first one is 65 ter 952, it's located at

 4     tab 36.

 5        Q.   Mr. Kezunovic, do you know the person whose name appears at the

 6     bottom of this document, Spasoje Camur?

 7        A.   I know that a man like that existed, but I had no particular

 8     relationship with him.

 9        Q.   Do you know whether or not he worked in the department for crime

10     prevention?

11        A.   Well, judging by the title indicated in the heading, he did.

12        Q.   Were you aware of the crime prevention department issuing daily

13     reports in 1992?

14        A.   I can't say for sure that I was aware.  It's possible that

15     between them they introduced this practice, but I really don't know.  If

16     you mean only that department and that line of work, it's possible that

17     they introduced this practice because even I in certain periods that were

18     critical for communications introduced at one point the practice that

19     certain centres should send daily reports as long as the problem

20     persisted.

21        Q.   Let me show you next --

22             JUDGE HARHOFF:  Mr. Hannis.

23             MR. HANNIS:  Yes.

24             JUDGE HARHOFF:  Is this a daily report from the State Security

25     Service of the MUP or of CSB Sarajevo?

Page 11617

 1             MR. HANNIS:  Your Honours, I believe this is from the crime

 2     prevention department in the MUP headquarters, an internal type of daily

 3     report.

 4             JUDGE HARHOFF:  And who were the addressees of these reports?

 5             MR. HANNIS:  Your Honours, I don't know.  I see none on this

 6     document so I can't tell you.

 7             JUDGE HARHOFF:  Why don't we ask the witness and see -- I mean,

 8     the interesting issue, of course, is whether Mr. Stanisic received this

 9     report.

10             MR. HANNIS:  Yes, I understand.

11        Q.   I can ask him but I assume -- do you know who this document would

12     have been sent to?

13        A.   I don't know.  You're right that there is no addressee indicated,

14     although every document should indicate the name of the sender and the

15     addressee.  The heading should indicate who created the document, and in

16     the subheading, which in this case is bulletin, there should be an

17     indication of for whom.

18        Q.   Let me move on to another --

19             JUDGE HARHOFF:  Mr. Kezunovic, do you know if these daily

20     reports, which I assume would come out every day, whether they were

21     sent -- whether they were sent up to the minister's office?

22             THE WITNESS: [Interpretation] I don't know that, but since you

23     see in the heading "crime prevention department," it sounds the most

24     logical that he was reporting to his administration; and then perhaps the

25     chief of that administration would report that to the minister because he

Page 11618

 1     must have known why he had ordered these bulletins to be made.

 2             JUDGE HARHOFF:  Thank you.

 3             MR. HANNIS:  Thank you.

 4             If we could next look at 65 ter 953, it's at tab 38.

 5        Q.   Mr. Kezunovic, this is a different type of daily report.  You'll

 6     see this one's dated the 13th of May, 1992, and it says "Serbian Republic

 7     of BH Ministry of Interior, Sarajevo, operations duty."

 8             MR. HANNIS:  And if we could go to the second page in both

 9     English and B/C/S.

10        Q.   It appears that this comes from a duty operations officer named

11     Nedo Sevo.  Do you know who he was?

12        A.   Operative duty officer.

13        Q.   Do you know where he worked?

14        A.   I know.

15        Q.   Where?

16        A.   I know before the war he worked in that school, the police school

17     in Vrace.

18        Q.   Okay.

19        A.   And I used to see him there in the early days of the war while I

20     was at Vrace.

21        Q.   And you'll see that the distribution on this daily report is

22     listed as going to MUP staff and archives.  Who was MUP staff as referred

23     to here?

24        A.   I was just about to ask you -- because you frequently refer to

25     the MUP staff looking over these past few documents.  I don't know about

Page 11619

 1     any MUP staff.  I know that there is the seat of the ministry where there

 2     is an operations duty officer who handles dispatches that they need to

 3     send somewhere, but there is no such thing as the MUP staff.  There was

 4     only at the staff of the special brigade later when the special brigade

 5     was established.  A staff is something that is established in

 6     extraordinary situations in the MUP and a staff exists in the army, but

 7     not normally in the police.  So I don't know what you're referring to.

 8        Q.   Did you as head of the administration for communications receive

 9     these types of daily reports from the operations duty people?  Do you

10     know?

11        A.   I was chief of administration, that is to say assistant minister,

12     and I did not receive this.

13        Q.   And the last one I want to show you is 65 ter 951.  It's at tab

14     37.  And it's dated the 12th of May, 1992, Serbian Republic of BH,

15     Ministry of Interior, Sarajevo, daily report.  And on the last page we'll

16     see it has Minister Stanisic's typewritten name and there's a signature

17     but it appears to be "za."  It appears to be for him by someone else.  By

18     chance do you recognise that signature?

19        A.   No.

20        Q.   Okay.  Did you receive or see these kinds of daily reports?

21        A.   No.

22        Q.   Now, if I could go back to the -- the log-book that we looked at

23     at the beginning of your testimony this morning.  Just one question about

24     those types of daily reports.

25             MR. HANNIS:  And I forget what exhibit number we gave this.  I

Page 11620

 1     think it's 1428.

 2        Q.   Just in terms of where those bulletins were sent.

 3             MR. HANNIS:  Could we look at two pages further on I think in the

 4     English.  I need to see entry number 10.

 5        Q.   Can you see that?  Entry number 10 is the 25th of April, 1992,

 6     daily events bulletin number 6.  You see it is listed as being sent to

 7     "SRNA."  What was "SRNA?"

 8        A.   Serbian News Agency.

 9        Q.   And SNA, do you know what that was?

10        A.   It must be an acronym.  The Serbian News Agency, "SRNA."

11        Q.   Okay.  Thank you.  And "Pale CB."  What does CB stand for, if you

12     know?

13        A.   Security centre.

14        Q.   Thank you.  I don't have any further questions about that.

15             [Microphone not activated]

16             THE INTERPRETER:  Microphone, please.

17             MR. HANNIS:  Sorry.

18             I don't have any further questions for the witness at this time.

19     I want to read out the list of proposed daily bulletins I'd like to

20     tender at this time.  I can do it while he's in the courtroom or while

21     he's out - as you please, Your Honour.

22             JUDGE HALL:  Well, whatever's the most efficient way that the --

23                           [Trial Chamber and Registrar confer]

24             JUDGE HALL:  Mr. Hannis, how many are there?

25             MR. HANNIS:  17, I think.

Page 11621

 1                           [Trial Chamber and Registrar confer]

 2             JUDGE HALL:  The Registry would assign the numbers if you would

 3     provide them with a list.  That seems to be the most efficient way to

 4     deal with it.

 5             MR. HANNIS:  I'll provide a list.  Thank you.

 6             JUDGE HALL:  Yes, Mr. Zecevic.

 7             MR. ZECEVIC:  Thank you, Your Honours.

 8                           Cross-examination by Mr. Zecevic:

 9        Q.   [Interpretation] Good morning, Mr. Kezunovic.

10        A.   Good morning.

11        Q.   Tell me, Mr. Kezunovic, in the MUP, the Republic MUP of the

12     Socialist Republic Bosnia-Herzegovina, you spent most of your career as

13     man number one in the administration for communication and cryptographic

14     protection; right?

15        A.   Yes.

16        Q.   And that post of man number two in this administration you

17     occupied until mid-1991?

18        A.   That's correct.  Moreover, from the multi-party elections until

19     mid-1991, I was even acting chief of administration, so I was practically

20     number one.

21        Q.   That means from sometime in 1990, that is, the multi-party

22     elections until mid-1991 you were acting chief?

23        A.   Correct.

24        Q.   You've told us, I believe it was yesterday, that your post

25     according to this agreement among the political parties was assigned to

Page 11622

 1     the SDA?

 2        A.   Yes.

 3        Q.   Then a certain Akif Sabic arrived and told you that from that

 4     moment on your services were no longer needed in the Ministry of the

 5     Interior and that you should go?

 6        A.   That's right.  To be more precise, the day when he arrived,

 7     assistant minister for staffing affairs Hilmo Selimovic, invited me to

 8     his office, informed me that that man was appointed chief of

 9     administration, that I should take him for a tour and make him meet the

10     people, show him the equipment.  And a few days after that tour, the man

11     invited me to his office and told me that within an hour I should be gone

12     but that I should first inform him where I was going.

13        Q.   You have more than 20 years of service in the MUP of

14     Bosnia-Herzegovina?

15        A.   From the 1st of March, 1978.

16        Q.   That is 13, 14 years?

17        A.   14.  I was into my 15th year.

18        Q.   Tell me, such behaviour -- I mean, the conduct of this

19     Akif Sabic, was not appropriate to the institution where you were working

20     or any laws or regulations.  It was his personal insistence that you

21     should pack up and go look for another job?

22        A.   Of course it was not appropriate.  First of all, it was not up to

23     him to decide such things or to enforce them.  Only the minister could

24     properly make a decision, and even then stating reasons why I should be

25     removed from the ministry.  And the minister could do that only if I was

Page 11623

 1     guilty of a serious breach or violation of regulations.  And that is why

 2     I had such a violent reaction to what he said, and we almost got into a

 3     fist-fight because I was really fed up by that time.  It was less than a

 4     year from the multi-party elections, and people had been appointed during

 5     that period without any professional qualifications only because the

 6     party wanted them in a certain post.  And then when somebody was

 7     appointed chief of something, they would bring his own equally

 8     unqualified people, and it became a conveyer belt.  It was happening

 9     every day.  You would wake up and find a new colleague and somebody would

10     just tell you who they were.  We were constantly living in some sort of

11     uncertainty, anxiety, thinking what could possibly come next, and it also

12     concerned my personal life and my family.  And that's why I went then to

13     the head of personnel, telling him that I want to hear what's going on.

14     I want it said to my face.  And the chief of personnel told me, "Don't

15     you worry, you just do your job and stick to it," but I had nothing to

16     stick to.  Nobody gave me any work, nobody asked me for anything.  I was

17     just sitting there idly, drinking coffee.

18        Q.   So to sum up, although you remained in the MUP you were

19     practically sidelined and completely excluded from all operational work?

20        A.   Of course during all that time I was completely marginalised.  I

21     had no information about what was going on, and I was not alone in that

22     position.  There were several of us in the same position who discussed

23     this among us, and I can't say I was totally in the dark; on the

24     contrary, I had informal but very good information about what was going

25     on.

Page 11624

 1        Q.   This completely disrupted situation in the MUP of Bosnia and

 2     Herzegovina began, if I understood you correctly, just after the

 3     multi-party election, and every national party was in a tug of war with

 4     the others?

 5        A.   Yes, but not all of them with equal strength.  Some had a

 6     stronger pull, and people did things in different ways.  Some were

 7     sneakier than others.

 8             JUDGE HALL:  Mr. Zecevic, if you're moving on to something else

 9     perhaps we should take the break at this point.

10             MR. ZECEVIC:  Yes.

11                           --- Recess taken at 10.25 a.m.

12                           --- On resuming at 10.50 a.m.

13             JUDGE HALL:  Mr. Zecevic, do you, as presently advised, consider

14     that you would need the full four hours that you had requested for this

15     witness?

16             MR. ZECEVIC:  Well, Your Honours, I believe I might be a bit

17     shorter, but I cannot say at this point because I'm just entering the

18     cross-examination.  It depends on how the witness will -- you see that

19     the witness tends to give longer answers.  So I will try to control him

20     as much as I can and finish within three hours, but I cannot promise

21     that.  Thank you.

22             JUDGE HALL:  We understand.

23                           [The witness takes the stand]

24             JUDGE HALL:  It seems -- the reason for asking is whether we are

25     likely to be going into Monday with this witness, and that seems to be

Page 11625

 1     the case.

 2             MR. ZECEVIC:  Yeah, that is -- I discussed with Mr. Hannis and my

 3     colleague Mr. Krgovic, and it is definitely going to be a case that we

 4     will split into Monday -- spill into Monday, I'm sorry.  May I proceed?

 5             JUDGE HALL:  Yes, please.

 6             MR. ZECEVIC:  Thank you very much.

 7             JUDGE HALL:  Sorry, at the end of -- since you wouldn't have

 8     completed at the end, when we rise for the day, could you let the Chamber

 9     have five minutes before we adjourn for the day.

10             MR. ZECEVIC:  By all means, Your Honours.  Thank you.

11        Q.   [Interpretation] Mr. Kezunovic, we left off when you said that

12     some of those parties were more persistent in relation to others.  Now, I

13     assume you mean that -- or rather, that it is your position and testimony

14     that the Party of Democratic Action, that is to say the Muslim national

15     party, was the most persistent along those lines; is that right?

16        A.   Yes.

17        Q.   It is a fact, is it not, that the situation deteriorated

18     considerably and especially after Mirsad Srebrenkovic's arrival to the

19     post of assistant minister; right?

20        A.   Among other things, yes.

21        Q.   And that's the time when - how shall I put this ? - this

22     uncontrolled employment in numbers began, especially of Muslims; is that

23     right?

24        A.   Yes.

25        Q.   Tell me, please, sir, at the end of 1991 already it was evident

Page 11626

 1     that a joint MUP, given the present situation, would find it difficult to

 2     continue to exist and work normally; right?

 3        A.   Well, yes, that is correct because in principle everybody hid

 4     information from anybody -- everybody else and everybody worked within a

 5     small circle and on the tasks and assignments that suited them.

 6        Q.   Well, the interests of the national party that appointed the

 7     person to the post first and foremost; would that be right?

 8        A.   Yes.

 9             JUDGE HARHOFF:  Mr. Zecevic, could you just remind us or maybe I

10     could put this question directly to Mr. Kezunovic.

11             When exactly was it that you were sidelined and told that you

12     should leave your position and hand it over to this other gentleman?

13             THE WITNESS: [Interpretation] At the moment that that new head of

14     department was nominated and appointed, and he was brought in as a member

15     or a carder of the SDA.  So at that point in time.  And you can check the

16     date out.  I really can't tell you the date, but it was certainly in

17     1991.

18             JUDGE HARHOFF:  Somewhere in the fall of 1991 I understand?  Or

19     was it summer 1991?

20             THE WITNESS: [Interpretation] Well, possibly, both are possible.

21     I really can't say now.  I didn't try to remember, didn't think along

22     those lines anyway.

23             JUDGE HARHOFF:  That's all right.  Thank you very much.

24             Please proceed.

25             MR. ZECEVIC:  Thank you very much.

Page 11627

 1        Q.   [Interpretation] Sir, do you remember that a situation of that

 2     kind was recognised by the European Community plan which was known

 3     popularly as the Cutileiro Plan at the beginning of 1992, or rather, that

 4     the plan envisaged the division of MUP on ethnic lines.  Do you remember

 5     that?

 6        A.   Well, perhaps in the most general terms, but I really can't speak

 7     to you about the details.

 8        Q.   Tell me, please, yesterday on page 11.582 of the transcript --

 9     well, you were asked by my learned friend Mr. Hannis something relating

10     to Mr. Jesuric from Bijeljina.  Do you recall that?  Do you remember him

11     asking you that with respect to Predrag Jesuric?

12        A.   Yes, he asked me if I knew who he was, who the man was.

13        Q.   Do you know that Mr. Predrag Jesuric came to be chief of the

14     Bijeljina security station in 1991.  He was appointed by the minister

15     Alija Delimustafic, are you aware of that?

16        A.   Well, I think he was appointed before the war, but I don't know

17     the date.

18        Q.   Thank you.  Now, on page 11.535 of yesterday's transcript, you

19     said that at the beginning of April 1992 members of the Serbian people

20     and members of the Muslim people had barricades or check-points along the

21     road from Sarajevo towards Pale and Sokolac, do you remember saying that?

22        A.   Yes.

23        Q.   And on that occasion you said that that upset the traffic along

24     that road and that buses weren't able to pass?

25        A.   Yes, I did say that but I'd like to just add this.  The situation

Page 11628

 1     when the barricades were erected led to the interruption of traffic along

 2     the road, but that didn't last for a long time.  Now, as for

 3     check-points, that went on for quite a long period of time.  And what I

 4     mentioned was with respect to my trips from Sokolac to the other place.

 5     This was done by the Green Berets, so I would have to come earlier and

 6     wait for one of the buses going in the direction of Sokolac, and they

 7     would come up to me several times, search me, ask me where I was going,

 8     ask me to identify myself, and I actually had to hide my ID identifying

 9     me as a MUP member because it happened that their own Muslims when they

10     saw that these people had ID MUP cards they would confiscate their

11     weapons because that particular person was not perhaps a member of the

12     SDA.  So things like that happened along the way.

13        Q.   So let me get this right if I understood you correctly, let me

14     just summarise for the transcript.  Even before April - and we can say

15     perhaps March 1992 - the Green Berets, that is to say members of that

16     Muslim paramilitary group, had check-points controlling traffic by the

17     Assembly building in Sarajevo, which is in the close vicinity of the bus

18     station, so that every time you went to catch a bus at the bus-stop you

19     had to pass through this check-point where they searched you, asked for

20     your identity and credentials.  Did I understand you correctly?

21        A.   Well, it was a little different.  It wasn't a classical

22     check-point.  Quite simply -- well, nor was it a bus station.  It was

23     just that buses setting out from the bus station which was near the

24     railway station in Sarajevo would pass by that way going east.  They

25     would stop if they saw there were passengers, so they would stop by the

Page 11629

 1     Assembly building just for a brief stop if they saw you putting up your

 2     hand and wanting to board.  So they would -- the buses would stop, take

 3     in the two or three passengers, and drive on, and that's where the

 4     members of the Green Berets were, not like a classical check-point that

 5     you had to stop there and have a person take your credentials and so on.

 6     They would just be around there 24 hours, round the clock, day and night.

 7     And just as they would recognise me and ask me where I was going every

 8     time, I remembered them.  So that happened before March as well.  So let

 9     me get that straight.

10        Q.   Tell me, please, were these people armed?

11        A.   In that initial period, no.  Maybe they had side-arms, pistols,

12     but not anything else -- at least I didn't see any other weapons.

13        Q.   Thank you.  Tell me, please, if I understood your testimony

14     correctly, you weren't a member of any national party, you were a member

15     of the League of Communists; right?

16        A.   I was a member of the League of Communists and I left the League

17     of Communists before those elections at an official meeting that was held

18     because it was decided at that time that party work or political work

19     could not evolve within the frameworks of state organs, and up until that

20     like it was only the League of Communists that existed in state organs.

21     So at the time, and this was a little strange as far as I was concerned,

22     people were asked to declare publicly which organisation they wanted to

23     go to on the ground, in the field.  And to be quite honest and sincere

24     here, and I want to state this here and now, that in my opinion that

25     League of Communists is most to blame for the disruption of Yugoslavia,

Page 11630

 1     and I tore up my party membership book and gave it back.  And that's how

 2     my party affiliation came to an end and later on I didn't join any other

 3     party.

 4        Q.   Tell me, please, sir, how did you declare yourself in ethnic

 5     terms, national affiliation, how did you declare yourself, as a Serb or a

 6     Yugoslav?

 7        A.   My national affiliation, I declared myself as a Serb.  And as far

 8     as citizenship was concerned, a nationality, I said Yugoslav.  And in all

 9     the forms that you had to fill out and all the records kept when you

10     gained employment, you would have this citizenship column, and that was

11     SFRY; and then national affiliation, that's the other column you had, and

12     I declared myself as a Serb.  You didn't have to declare yourself in

13     terms of any republics.

14        Q.   Tell me now, please, on page 11.534 of the transcript yesterday

15     you said that every year during your work over a period of 14 years in

16     the MUP of the Socialist Republic of Bosnia-Herzegovina, that every year

17     you would attend training courses for the work that you were doing,

18     specific training courses for your specific job, and that in that way you

19     became acquainted with the latest state-of-the-art technology in the

20     sphere of telecommunications; is that right?

21        A.   Yes.

22        Q.   Mr. Kezunovic, do you consider yourself to be a true professional

23     and an expert in the field of telecommunications?

24        A.   Yes, I do, I do.

25        Q.   When you were called sometime in mid-April by Mr. Mico Stanisic

Page 11631

 1     and offered the job of heading the department for communications and

 2     encryption in the ministry of the Serbian Republic of Bosnia-Herzegovina,

 3     you considered yourself ready and able to perform that duty; isn't that

 4     right?

 5        A.   Yes.  And may I make an additional comment to that?  First of

 6     all, that was one possibility.  The other possibility was for me to be

 7     mobilised as a recruit, a conscript.  But I went to the infantry school

 8     for reserve officers, and as such the army would have liked to have me as

 9     an infantryman.  And since I wasn't a member of any party and all the

10     other circumstances that I described to you, I was very grateful to

11     Mr. Stanisic for giving me this opportunity, first of all, to do the job

12     I did best and it was more comfortable - if I can put it that way - and

13     less dangerous.  And I didn't have to go through all the subsequent

14     events that took place.

15        Q.   If I understood your testimony correctly, the communications

16     centre attached to the seat of the MUP of the Serbian Republic of

17     Bosnia-Herzegovina in the course of 1992 was -- well, in actual fact

18     changed its seat and headquarters four times; is that right?  First of

19     all, it was at Vrace and then for a brief period in Lukavica, and then it

20     went to Pale, and then from Pale sometime at the beginning of December it

21     was relocated to Bijeljina; right?

22        A.   Yes, but not the communications centre in the physical sense that

23     people moved.  It was only from Vrace that we left, but this referred to

24     the centres that had already been established and were operational.  They

25     just took on this function of work, of working for the Ministry of the

Page 11632

 1     Interior at the headquarters and centre.  Let me give you an example.

 2     The Bijeljina communications centre, it was in existence ever since the

 3     municipal SUP building of Bijeljina existed, and then later on when the

 4     organisation changed and you had the MUP and the security centre then I

 5     would send cadres to that centre and equipment and documents for them to

 6     be able to work for the purposes and requirements of MUP.  So that was

 7     the sense of that whole operation.

 8        Q.   But the main point was that you as head of that department went

 9     that way from Vrace to Lukavica, from Lukavica to Pale, from Pale to

10     Bijeljina, that was the route, your route; is that right?

11        A.   Yes.

12        Q.   Tell me, please, on page 11.545 of yesterday's transcript, lines

13     22 and 23, when asked -- well, you were saying how your telephone lines

14     at Vrace had been cut, and then my learned friend asked you whether it

15     was possible to use the ultra short-wave communications to convey

16     messages.  And you said:

17             "Yes, we could do this by relay."

18        A.   Do you want me to explain that?

19        Q.   Because this part was not properly recorded in the transcript.

20     I'd like you to explain what you meant by "relay."

21        A.   That means that an individual who has a radio station transmits

22     an information, a piece of information, to another individual who has a

23     radio station, and the two stations have to have mutual optical

24     visibility.  And then the information is passed on in the same way.  In

25     some cases it was practiced for several reasons, but not widely.  First

Page 11633

 1     of all, because it was open traffic and confidentiality of information

 2     was not guaranteed, but this mode could be used for brief reports.

 3        Q.   On the same page, line 24 and 25 of the transcript of yesterday,

 4     my learned friend asked you whether people were able to organise

 5     themselves to deliver documentation, for instance, from Vrace to Pale,

 6     and you said they were able but you have no idea whether they actually

 7     did.  Do you remember that?

 8        A.   Yes, I do.  But let me make this quite clear, if I may, in a

 9     broader sense.  It's one thing to assign someone and organise a service

10     for the entire institution and it's quite another matter when I organise

11     this service for my particular line of work because it wouldn't

12     necessarily suit everyone else.

13        Q.   On page 11.553 my learned friend asked you about a courier

14     service, and you then confirmed that you had not organised such a service

15     and that in your opinion in order to organise such a service it would

16     have been very difficult because you would have needed people, vehicles,

17     petrol, et cetera?

18        A.   Yes.

19        Q.   It's a fact, Mr. Kezunovic, isn't it, that early in 1992, and

20     especially in the months from April through October 1992, you were facing

21     constant shortages of fuel, personnel, and means of transportation?

22        A.   Yes.  And just to illustrate let me tell you something that

23     people will probably find incredible.  There was one period when the

24     shortages were so bad that the ministry in its seat would ration fuel

25     among its organisational units.  I got for my administration 20 litres in

Page 11634

 1     one of those months for the month, that is one jerrycan, and I

 2     immediately assigned this fuel for the power generator.

 3        Q.   So for the whole month you got 20 litres of diesel for the entire

 4     administration?

 5        A.   Yes, for the whole of my administration, just 20 litres for the

 6     month.  It's incredible.

 7        Q.   Just briefly - and again you've discussed this with Mr. Hannis,

 8     but let's be completely clear - I want to ask you about the types of

 9     telecommunications at the Ministry of the Interior.  One, you had

10     telegraph communications in the form of teleprinters?

11        A.   You mean generally speaking in the ministry before the war what

12     the police used?  Yes, perhaps not in that order, but yes, one network

13     was the teleprinter network.

14        Q.   Now this telegraph/teleprinter network, there are documents that

15     were transmitted openly and others were encoded?

16        A.   Yes, dispatches were encrypted.

17        Q.   There were also dispatches that were sent through open

18     communications?

19        A.   Yes.

20        Q.   Just to explain graphically this technology, this method of work,

21     the communications centre would receive a document written on a

22     type-writer.  The operator at the teleprinter re-types the document on

23     the teleprinter, and if it goes through open traffic such a teleprinted

24     document is transmitted on?

25        A.   Yes.

Page 11635

 1        Q.   If the document is encrypted, then this document after being

 2     re-typed on the teleprinter goes through the operation of encryption, and

 3     only after encryption is it transmitted to the addressee?

 4        A.   That's correct.

 5        Q.   When the recipient receives that encrypted document they must

 6     have a key to decrypt it and the key must be agreed with the sender?

 7        A.   That's correct.

 8        Q.   Another type of communications available to you were telephones?

 9        A.   Yes.

10        Q.   Telephone communications were public and special telephone

11     communications?

12        A.   Yes, the latter was called the police network which we called

13     special lines.

14        Q.   The whole point of these special lines was that this platoon --

15     sorry, this cable was quite separate from the public telephone cables

16     owned by the PTT.

17        A.   Yes, I have to explain.  In the entire network of telephone

18     cables from Sarajevo towards centre and from these centres to public

19     security stations, the PTT built up its own system of network, either

20     through cable or through radio relay systems.  And in this overall

21     capacity of channels a certain amount was allocated to the police, and

22     the police of course financed it proportionally.  Physically they used

23     the same route, but it was also quite separate physically so that one

24     system did not have access to the other one.  And in cities, we had a

25     special system.  There was a network of our own special cables between

Page 11636

 1     all police buildings and installations, and in every city we had our own

 2     separate telephone network -- telephone switchboard.

 3        Q.   However, the essence is this:  The PTT telephone lines and your

 4     own special telephone lines go through these same cables, the same

 5     conduits?

 6        A.   Yes, they follow, they run along the same physical route.

 7        Q.   Thus, if PTT telephone lines break down along this physical

 8     route, then automatically the special and all the other lines are also

 9     broken down?

10        A.   That's one option.  It depends on what the breakdown is about.

11     If it's a general power cut, an outage, then we are all without

12     electricity.

13        Q.   And then there can be no communication along these routes if

14     there is no electricity.  These same telephone lines, the public lines,

15     serve as a conduit for the fax signal; right?

16        A.   Yes.

17        Q.   So if the lines are broken down because there is a power outage,

18     then fax communication is also impossible; right?

19        A.   Yes.

20        Q.   Speaking of fax communication, you said that it was the position

21     of your service that this line of communication is open and you were very

22     reluctant to use it?

23        A.   It's not only that we were reluctant to use it.  Before the war

24     it was even forbidden -- sorry, during the war it was even forbidden, but

25     then it was also unnecessary because all the fax communication could also

Page 11637

 1     be sent by telephone lines.  Perhaps it would not be a bad idea for me to

 2     add something to this.

 3        Q.   Yes, say what you want to add and then we'll perhaps correct

 4     the -- your answer on the transcript.  It was not quite properly

 5     recorded.

 6        A.   The teleprinter network made possible also the so-called circular

 7     work.  That means we were able at any moment to send a dispatch to all

 8     the organs on the ground simultaneously.  And we would call it a

 9     circular.  The contents of all the dispatches that must be sent to all

10     our organs, all the centres, or even municipal stations.  And then it

11     would be sent in one single moment, these moments were defined, and it

12     was a very comfortable way to do it.  The operator sitting at a disk like

13     this would use these -- this simple telephone switchboard, the kind where

14     you see in movies where they plug a jack into a row of holes, that's how

15     they would send dispatches in this circular.  So faxes were of no

16     interest.

17        Q.   What we've been discussing over the past ten minutes all relates

18     to the MUP of the Socialist Republic of Bosnia and Herzegovina and the

19     normal functioning of the MUP before the war; right?

20        A.   Yes.

21        Q.   Tell me, you were talking about the regimen of communication.  In

22     the Ministry of the Interior there is an internal regulation specifying

23     exactly what type of documents may be transmitted in the open and which

24     type of documents must be encrypted on a compulsory basis?

25        A.   That's correct.

Page 11638

 1        Q.   I suppose that the main reasons for this distinction between open

 2     and encrypted had to do, first of all, with the contents, the information

 3     transmitted in the document; and second, the sender and the receiver?

 4        A.   No, no, that was irrelevant.  It -- the only criterion was the

 5     confidentiality and the importance of information transmitted.

 6        Q.   Now, when you just started setting up the communications centre

 7     of the MUP in the Serbian Republic of Bosnia and Herzegovina, you had no

 8     part of that equipment that you normally had at the MUP of

 9     Bosnia-Herzegovina?

10        A.   That's right.

11        Q.   On page 11.562 when you were shown a document containing the

12     conclusions of the meeting of the 11th of July dealing with nomenclature,

13     namely, numeric designations of various units in the MUP of Republika

14     Srpska, a dead-line was given, the end of July, for this nomenclature to

15     be completed.  That means, in fact, that until the month of August 1992,

16     you did not have any official nomenclature in the MUP of Republika

17     Srpska?

18        A.   To put it even better, we did not have an established

19     organisation.  It was a work in progress.  Things were being added or

20     removed all the time or relocated.  It was logical, first of all, to

21     draft the rules on internal organisation, and then based on those rules

22     to develop a nomenclature.

23        Q.   You know that the rules on the internal organisation of the

24     Ministry of the Interior of Republika Srpska was enacted only in March

25     1993?

Page 11639

 1        A.   Well, I don't remember the date, but I know that that was the

 2     case.

 3        Q.   Sir, if I can express myself figuratively, let me say that in

 4     actual fact you started setting up communications centres or a

 5     communications centre attached to the seat of the MUP of the Serbian

 6     Republic of Bosnia-Herzegovina with a green light?

 7        A.   Yes.  I was told to go there and to start working.

 8        Q.   Just a moment, please.  On page 42, line 24, I used the term

 9     "from scratch."  I said "green grass," but meaning "from scratch;" is

10     that right?

11        A.   Yes.

12        Q.   Now, if I understood your answer correctly, you were told to

13     create a system of communications centres attached to the MUP

14     headquarters which would be operational; right?

15        A.   Yes.  What I was told was, "You know what needs to be done best,

16     so go ahead."

17        Q.   Without a doubt -- well, there's no doubt that especially in the

18     first months when you started working to form a communications centre

19     attached to the seat of the MUP, that your communications with the CSBs

20     on the territory of Republika Srpska were non-existent or very often

21     interrupted; isn't that right?

22        A.   Yes, but the situation was much worse than you're depicting, and

23     here's why.  You say that I was supposed to set up a communications

24     centre.  What I was actually supposed to do was to ensure the

25     establishment of a system where this MUP communications centre would be

Page 11640

 1     able to function.  So that means that even if somebody had equipment and

 2     manpower, they didn't have the necessary documents to start working, the

 3     encryption, work-plans, and so on.  The system is far more complicated

 4     than it appears to be at first glance.  Setting up a communications

 5     centre is just a part of the job.  Even if I'm given all the manpower and

 6     equipment I need, I need to have all the encryption documents and create

 7     a whole system.  So it's a little difficult to answer your question in

 8     general terms, could this have been possible or not.  So when I say "yes,

 9     it was possible," but I had to struggle to ensure that all this

10     functioned and also I had to see that the system was not abused in the

11     meantime, that people should not make mistakes sending out information in

12     the wrong way.  So that was a broader explanation of the whole situation.

13        Q.   But the crux of the matter is this.  Let me try and summarise.

14     Not only did you have to set up a communications centre attached to the

15     MUP seat, but to create a whole functional system of communications with

16     all the security services on the territory of Republika Srpska?

17        A.   Yes, and that was the difficult part.

18        Q.   Now, for us to establish this functional link between the

19     communications centre attached to the MUP seat and the security centre in

20     Banja Luka, for example, you physically had to go to the Banja Luka CSB

21     with the documentation that you had and took with you from Pale - let me

22     take that example - or from Bijeljina to establish a functional,

23     operational communications system; is that right?

24        A.   Yes.

25        Q.   The fact is, sir, that if I take the Banja Luka CSB as an

Page 11641

 1     example, you arrived at that only after the corridor had been opened,

 2     probably in July or August 1992; right?

 3        A.   Yes.

 4        Q.   The fact is, and I think that I've already asked you this and

 5     that you said that it was in Brcko that you had to wait for three days in

 6     a car to be given permission to drive on to Banja Luka; isn't that right?

 7        A.   Yes.

 8        Q.   So the truth is that a normal communications system only became

 9     operational after August or during August 1992 with the area covered by

10     the CB -- CSB of Banja Luka and the Doboj CSB; is that right?

11             Could you repeat your answer.  It wasn't recorded.

12        A.   That's right.

13        Q.   Now, sir, it is also a fact, is it not, that it was only after

14     going to Bijeljina at the beginning of December 1992 and the formation of

15     the communications centre in Bijeljina that that was the beginning of a

16     relatively normal functioning of the system of communication on the

17     territory of Republika Srpska; right?

18        A.   Yes, that's right.

19        Q.   I think that you made a comment and said that in your opinion

20     throughout 1992 everyone just disrupted -- went about disrupting things,

21     including the communications system.  Nobody built anything or did

22     anything.

23        A.   Yes, that was true of all systems, the electricity supply system

24     and everywhere else.

25        Q.   Now, sir, let's try and illustrate this.  If you cannot establish

Page 11642

 1     some sort of communication, then at that time from the communications

 2     centre you have no indication of the reason the lines were down, the

 3     communication was down?

 4        A.   Well, mostly no.

 5        Q.   So there were various possibilities.  Perhaps there was no

 6     electricity in the area, that's one possibility, isn't it?

 7        A.   Yes, that's right.

 8        Q.   And then there's another possibility.  For example, one -- the

 9     reception equipment was down; is that right?

10        A.   Yes.

11        Q.   Then there's another possibility.  There might have been a

12     physical interruption to communications; isn't that right?

13        A.   Yes.

14        Q.   And then there's also the possibility of the communication lines

15     being overused and not enough capacity?

16        A.   Yes, that's right.  And there was also combat going on where the

17     phones would be ringing but nobody would answer, and then when they did

18     answer they would say that they were in a shelter.  So that was another

19     possibility.

20        Q.   Tell me, please, in addition to the keys for decoding, there were

21     plans as well, documents called plans, for establishing communication;

22     isn't that right?

23        A.   Yes.

24        Q.   And those plans were limited for security reasons.  They had a

25     dead-line, just as the keys did, they had a life span?

Page 11643

 1        A.   Yes, that is correct, in addition to other things.

 2        Q.   So, for example, if at a given point in time you provided the

 3     keys for decoding and the plan for establishing communications, which

 4     covered a period of, say, one month, after that month had expired you are

 5     unable to supply a new set of documents, then you were facing a serious

 6     problem again; right?

 7        A.   Yes.

 8        Q.   Very well.  Thank you.

 9             Now I'd like to show you a number of documents for us to

10     illustrate this communication between the CBS [as interpreted] and the

11     communications centre of MUP at its headquarters.  It is a fact, is it

12     not, that there were five security services centres on the territory of

13     Republika Srpska, the MUP of Republika Srpska I mean?

14        A.   Yes.

15        Q.   They were Banja Luka, Doboj, Bijeljina, Sarajevo, and Trebinje;

16     right?

17        A.   That's right.

18             MR. ZECEVIC: [Interpretation] Now may we see document 65 ter 955,

19     please.

20        Q.   It's a bulletin of daily events, one of them, shown to you by

21     Mr. Hannis.  I know that you said you didn't receive anything like that,

22     but what I'm interested in basically is just a comment at the very end of

23     this daily bulletin or report.  And the date of it is the 15th of May,

24     1992, signed by the service for information of the ministry where it

25     says:

Page 11644

 1             "On the territory of the CSB of Bijeljina there were no

 2     especially interesting events security speaking ..."

 3             And at the -- do you see that final paragraph there:

 4             "There were no incidents of particular security interest in the

 5     area of Bijeljina CSB ..."

 6             Now, I assume -- I assume that that means that at that point in

 7     time there was no communication between the communications centre of the

 8     ministry at its seat and the CSB of Doboj and Banja Luka, or rather,

 9     Trebinje; is that right?

10        A.   For one of the reasons that you enumerated earlier on most

11     probably, yes.

12        Q.   Thank you.

13             MR. ZECEVIC: [Interpretation] Now may the witness be shown 65 ter

14     956 next, please, page 2.

15        Q.   Sir, this is another daily bulletin or report.  The following

16     day, the 16th of May, 1992, the information service once again, and at

17     the bottom it says:

18             "So far the Bijeljina, Doboj, and Trebinje CSBs have not

19     submitted their daily reports."

20             And I assume that the reason for that was the same, that there

21     was no communication; right?

22        A.   That is very possible, yes.

23             MR. ZECEVIC: [Interpretation] Now may the witness be shown 65 ter

24     957, please, page 2 again.

25        Q.   This is a document, once again a bulletin or a report, dated the

Page 11645

 1     18th of May this time, and once again those three CBS centres, Trebinje,

 2     Doboj, and Bijeljina failed to submit reports on daily events or

 3     incidents.  I assume that your answer will be the same as to the reason

 4     that there was no communication; is that right?

 5        A.   Yes, that is right.

 6        Q.   Now, sir, in normal situations in the MUP of the Socialist

 7     Republic of Bosnia-Herzegovina, and that was also true for the MUP of

 8     Republika Srpska, the CBS, the security services centres, are duty-bound

 9     to send in daily reports to the MUP at its seat; right?

10        A.   Yes.

11        Q.   Now, here we have a situation that is different, looking at those

12     two documents.  Of the five centres, three were not sending in reports,

13     and that's a highly irregular situation, is it not?

14        A.   Yes, absolutely.

15        Q.   Now I'm going to show you document 65 ter 270, and I'm going to

16     ask you for your comments.

17             MR. ZECEVIC:  I wonder if I could be assisted by my friends from

18     the Prosecutor's side.  I was notified that the documents which I read,

19     65 ter 955, 956, and 957 have not been exhibited.

20             MR. HANNIS:  [Microphone not activated]

21             I'm sorry.  Those are on the list of daily reports that I wanted

22     to tender.  I don't think they've been assigned a number yet because

23     they're part of that group of 15 or so.

24             MR. ZECEVIC:  Thank you very much.  That's perfectly all right.

25             THE ACCUSED: [Interpretation] We're not receiving the

Page 11646

 1     interpretation.

 2             MR. ZECEVIC:  I believe that there was no interpretation in

 3     Serbian.

 4             JUDGE HARHOFF:  Mr. Hannis, could you just repeat your answer.

 5             MR. HANNIS:  Yes.  I said that those are on the list of daily

 6     reports that I wanted to tender.  I don't think they've been assigned a

 7     number yet because they're part of that group of 15 or so that we

 8     provided to the Registry officer by e-mail just a few minutes ago.

 9                           [Trial Chamber and Registrar confer]

10             MR. ZECEVIC:  And just for the purposes of interpretation, I

11     said:  Thank you, it's appreciated.

12        Q.   [Interpretation] Now, sir, this is a letter sent to the Ministry

13     of the Interior on the 7th of May, or rather, the date is the 7th of May,

14     1992, and it is signed by Predrag Jesuric.  Now, what I'm interested is

15     this, the first paragraph which says, and I'll help you out because it's

16     rather a poor copy so I'll read it out.

17             "Due to a break in the telephone, telegraph, and fax

18     communications, during the period from the last report you did not

19     receive reports, although they were compiled by the chief of the

20     Bijeljina CSB, security services centre."

21             Now, it is a fact, is it not, that Bijeljina - and we saw this on

22     the basis of some previous documents - was for a time left without any

23     communication with Pale; right?

24        A.   Yes.

25        Q.   We can then indubitably conclude from this that this lasted for

Page 11647

 1     some time because he speaks of reports, in the plural.

 2        A.   And I can also tell you that it was mostly because of power

 3     outages, in Bijeljina especially.  And the building in Bijeljina, that of

 4     the municipal secretariat, was the last one to be built and put into

 5     operation.  It was built according to all the proper standards.  It even

 6     had a power generator for the entire building, but it didn't help.  If

 7     you just tried to ignite a car 100 times a day by pushing the car, it's

 8     impossible.  It was simply impossible to find a moment during the day

 9     when everything was working properly.  There were days like that.

10        Q.   I heard you saying that it was impossible to find a half-hour

11     during the day when everything was working to actually send and receive?

12        A.   Yes, because the whole process of re-typing dispatches and all

13     that you described before takes a couple of hours.  And if you interrupt

14     it for some reason midway, you have to start all over again.

15        Q.   I just want to ask you if this document is known to you or not?

16        A.   No, I personally don't know about it because it was not addressed

17     to me or ever made available to me.

18             MR. ZECEVIC: [Interpretation] If there is no objection, for the

19     sake of completeness of this testimony, I would like to offer this

20     document to be MFI'd.

21             MR. HANNIS:  No objection.

22             JUDGE HALL:  This isn't a part of the -- okay.  So marked for

23     identification.

24             THE REGISTRAR:  As Exhibit 1D234, marked for identification,

25     Your Honours.

Page 11648

 1             MR. ZECEVIC:  Thank you.

 2             [Interpretation] Just to illustrate this situation further, can I

 3     show the witness 1D00-2978.  I would like page 2 first in Serbian.

 4        Q.   This is an undated document, unfortunately, but judging by what

 5     is written there I would say it's from May/June, possibly, 1992.  And it

 6     comes from the Zvornik public security station.  It says "report on the

 7     situation ..."

 8             MR. ZECEVIC: [Interpretation] Page 3, please.  Page 3 in Serbian

 9     and page 2 in English.

10        Q.   Do you see in paragraph 1 on this page it says:

11             "One difficulty in our work is the communications system which

12     could be used to communicate between reserve police stations and

13     neighbouring municipalities.  Telephone communications almost throughout

14     the municipality are down.  Radio communication can be used only at

15     smaller distances because the repeater is broken down."

16             MR. ZECEVIC: [Interpretation] I'm sorry, it should be page 3 in

17     English.

18        Q.   And in brackets:

19             " ... (there is only one fixed, two on wheels," I suppose that

20     means cars, "and two Motorolas)."

21             And then it goes on to speak about other technical equipment.  Do

22     you remember that at that time in 1992 at the level of public security

23     stations too such problems were experienced throughout Republika Srpska?

24        A.   Yes, especially Zvornik was in a difficult situation and some

25     more municipalities like Milici and Vlasenica because they belonged to

Page 11649

 1     the Tuzla region and they were connected through the PTT and other lines

 2     directly to Tuzla.  So something had to be changed dramatically in the

 3     state for them to be reconnected to someone else.  First the telecom had

 4     to do it and then the police had to join in with their capacities.  Now,

 5     if somebody's holding or controlling transmitters and radio relay

 6     installations, that would have been very difficult to effect that change.

 7     It's not perhaps across the board what I'm describing, but it was

 8     different in every municipality, every region.  Only Banja Luka was

 9     fortunate in that respect, that all of their municipalities in Doboj

10     remained connected to them, of course with all the accompanying problems

11     like power outages, et cetera.

12        Q.   So all this eastern part of Republika Srpska, municipalities of

13     Vlasenica, Milici, Zvornik, I suppose Bratunac as well, they were all

14     connected to the PTT node, the switchboard in Tuzla, which was controlled

15     by the Muslims.  And that is why no kind of communication with them was

16     possible?

17        A.   At the outset, that's how it was.  Bijeljina, Brcko, Ugljevik,

18     Lop are, the entire north-eastern part from Zvornik on was connected to

19     Tuzla.  After Sarajevo it was probably the largest region by the number

20     of municipalities.

21        Q.   And that part of the communications with Eastern Bosnia and

22     north-Eastern Bosnia resumed practically only in the summer of 1992?

23        A.   You could say that.  Some transitional solutions were found, but

24     they were really transitional.  There was something, but absolutely

25     substandard.

Page 11650

 1             MR. ZECEVIC: [Interpretation] I would like to tender this

 2     document to be marked for identification if there is no objection by

 3     Mr. Hannis.

 4             MR. HANNIS:  No objection to MFI.  I know there's no date or

 5     signature or name on it.

 6             JUDGE HALL:  So marked.

 7             THE REGISTRAR:  As Exhibit 1D235, marked for identification,

 8     Your Honours.

 9             MR. ZECEVIC: [Interpretation] Could the witness be shown P589.

10        Q.   This is a letter from the CSB Sarajevo dated 25 July 1992, and

11     you can see on page 1 the second sentence, indicating how serious the

12     situation is.  It says:

13             "The most frequent problem in the preparation of data is weak

14     communication with public security stations as a result of war

15     operations."

16             Since Sarajevo was not far from Pale, are you aware that the

17     security services centre and their chief, Mr. Zoran Cvijetic, experienced

18     difficulties in communications and establishing contact with the public

19     security stations subordinate to them?

20        A.   That's precisely what we were discussing before.  They were at

21     Vrace at the outset and then they moved to Lukavica, and they moved from

22     Lukavica mainly because communications were impossible to establish.

23        Q.   This move from Lukavica - because it was impossible to establish

24     communications and make contact - also happened in the end of summer

25     1992?

Page 11651

 1        A.   That's correct.

 2             MR. ZECEVIC: [Interpretation] Your Honours, I can see the time

 3     and I would like -- perhaps it's time for the break.

 4             JUDGE HALL:  Yes, Mr. Zecevic.

 5             MR. ZECEVIC:  Thank you, Your Honours.

 6                           --- Recess taken at 12.05 p.m.

 7                           --- On resuming at 12.30 p.m.

 8             MR. ZECEVIC:  May I, Your Honours?

 9             JUDGE HALL:  Yes, please.

10             MR. ZECEVIC:  Thank you.

11             [Interpretation] Could we please have 1D176.

12        Q.   Mr. Kezunovic, it is a fact, isn't it, that as you said at the

13     beginning, that Mr. Stanisic gave you a carte blanche in the sense that

14     you were allowed to create a fully functioning communications system

15     within the MUP of the RS; correct?

16        A.   Yes.

17        Q.   And it is also a fact, is it not, that Mr. Stanisic supported you

18     in that, he met every request of yours that he could in terms of

19     equipment and similar things; correct?

20        A.   Yes.

21        Q.   You're probably familiar with the fact that the minister insisted

22     on constant, daily exchanges of information; is that correct?

23        A.   Yes.

24        Q.   To illustrate that, I wanted to show you 1D176, which is an order

25     of the minister dated the 27th of July, 1992.  Let's go to item 9 on page

Page 11652

 1     2 in both versions, please.  Item 9.

 2             I don't know how well you can read this on the monitor.  In

 3     essence, the minister says that it was necessary to have a continuous and

 4     timely exchange of information within the Ministry of the Interior in all

 5     lines of work in accordance with valid regulations and our earlier

 6     orders.  In order to ensure that appropriate measures are taken, focusing

 7     on priorities, and providing specialist assistance, as well as informing

 8     the competent state organs.

 9             Then he says:

10             "You shall report every day with reference to this order, on the

11     execution of this order and problems that might occur in connection with

12     performance of the tasks."

13             This illustrates both the minister's and the ministry's position

14     concerning insufficient communication and communication links; is that

15     correct?

16        A.   Yes.

17        Q.   Sir, let me ask you this:  Do you recall that sometime in early

18     August an employee of your administration together with a certain Drobok

19     [phoen] from the national security service went to pick up mail in

20     Bijeljina because telecom systems did not function, they were ambushed.

21     Some were between Capard e and Zvornik where they unfortunately were

22     killed.  Is that correct?

23        A.   Yes.

24        Q.   Can you recall the name of your employee in question?  If you

25     can't remember that, that's fine, but in any case he was a signals man in

Page 11653

 1     your administration, was he not?

 2        A.   I think they both worked for me and then they were transferred to

 3     another service.  I know the exact location.  It was at Crni Vrh that

 4     they were ambushed.

 5        Q.   And as I said, it was in the first half of August 1992; correct?

 6        A.   I do not remember the exact date, but around that time, yes.

 7             MR. ZECEVIC: [Interpretation] Could we please have P668 shown to

 8     the witness.

 9             JUDGE HARHOFF:  While we wait for the document to come up,

10     Mr. Kezunovic, could I ask you if you ever attended any of the meetings

11     with the minister, the daily meetings that you just referred to?  Did you

12     personally ever go to any of these meetings?

13             THE WITNESS: [Interpretation] These were not daily meetings.

14     These were daily reports, information exchanged daily from the organs in

15     the field, which would then be collated in the MUP headquarters and

16     forwarded to operational services.  I don't remember any meetings to that

17     effect.  Perhaps the minister did hold certain meetings if he believed

18     the problem was important enough to have a meeting, such as the

19     non-functioning of communications, then he might summon me to his office

20     to explain.  But this would only concern the most important things from

21     those daily reports per professional line of work.  I presume that if it

22     did happen, it happened more frequently with other aspects of police

23     work.

24             JUDGE HARHOFF:  Thank you very much.

25             I apologise because I understood that there were daily meetings

Page 11654

 1     held, but I was mistaken.  Thank you.

 2             MR. ZECEVIC:  Thank you, Your Honour.

 3        Q.   [Interpretation] Sir -- could we only have the first page in

 4     Serbian and the second page in the English.

 5             Sir, this is a report of the SJB in Prijedor.  On the first

 6     sheet, which in e-court in English is the second page, it says:  "Coded

 7     dispatch return."  I suppose this S with a diacritic is what you referred

 8     to when you explained it meant coded?

 9        A.   Yes.

10        Q.   And then we have the dates of the 18th and the 19th of July and

11     the 1st of August.  Can you explain this concept of "return."  Does it

12     mean that those coded dispatches were not sent?

13        A.   Well, that would be one of the options.

14             MR. ZECEVIC: [Interpretation] Let's have the first page in the

15     English and second in the Serbian version.

16        Q.   Sir, you can see the third dispatch of the 1st of August here.

17     Underlined we see the title "MUP of the Serbian Republic of Bosnia and

18     Herzegovina and army of the Serbian Republic of B&H."

19             And then there is a handwritten note saying:

20             "We are not in a position to send it" or "we are unable to send

21     it."

22             This confirms what we have just said, that it was impossible to

23     send it on the 1st of August?

24        A.   Yes, and I believe the note was made by the signals man.

25        Q.   So this Goran person?

Page 11655

 1        A.   Yes.

 2             MR. ZECEVIC [Interpretation]  Could we have P158 shown to the

 3     witness next.

 4        Q.   To further illustrate the situation with the CSB in Trebinje, the

 5     document you're about to see is a report on the work of the CSB in

 6     Trebinje between the 1st of July and the 15th of August.

 7             MR. ZECEVIC: [Interpretation] Let's go to page 2, please.  I

 8     suppose the same goes for both versions.  Apologies.  Page 3 then.  In

 9     the English too.

10        Q.   The third paragraph in both versions says:

11             "Non-functional communications system, lack of equipment, and

12     materiel, frequent fuel shortage, and interruption of communications,

13     apart from insufficient number of workers, were special problem in

14     performance of daily activities.  As a result we are now unable to

15     process data from the area of ancient Herzegovina, so this instruction

16     only relates to the area of eastern Herzegovina."

17             It is a fact, is it not, and you know that the CSB with its

18     regional public security stations also had this issue of communications

19     to deal with.

20        A.   Yes.

21        Q.   Much the same way as it was the case with the CSB in their

22     communication with the communications centre at MUP headquarters at Pale;

23     correct?

24        A.   Yes.  All communication before that went through Mostar for the

25     entire area of Herzegovina, and that was disrupted.

Page 11656

 1        Q.   It was disrupted because Mostar was controlled by Croatian or

 2     Muslim forces?

 3        A.   Correct.

 4        Q.   We see here that at the CSB they were unable to process

 5     information from a large part of the territory they covered?

 6        A.   That is correct.

 7        Q.   Thank you.  The last document served to illustrate this issue has

 8     to do with the territory of the CSB in Doboj.  You were shown this

 9     document yesterday, it is P1426.  It is a report about the work of the

10     communications department and encryption department of the CSB in Doboj

11     between the 30th of July and the 30th of September, 1992.  Head of

12     department, Miomir Djekic signed it.  You were shown this document

13     yesterday and you recognised it, did you not?

14        A.   I did.

15        Q.   In paragraph 2 it says that -- well, the date of the document is

16     the 1st of October, 1992.  It says:

17             "In this period the employees of this technical services

18     department managed to establish telephone and telegraph communication

19     among the following liberated territories in the region:  Derventa,

20     Modrica, Teslic, Bosanski Samac, Petrovo, and Maglaj, although there are

21     frequent disruptions in the communications with Maglaj and Petrovo ..."

22             Based on this we can draw a certain conclusion, which is that the

23     telephone and telegraph connections were not operational at least until

24     the 30th of July concerning these municipalities, and between the 1st of

25     August and the 30th of September communication was established.  It was

Page 11657

 1     as late as that, was it not?

 2        A.   Yes, although it was still under difficult circumstances.

 3        Q.   Two paragraphs following that says that in the same period,

 4     between the 1st of August and the 1st of October, 1992, the CSB in

 5     Banja Luka was made part of the telephone and telegraph network, whereas

 6     the ministry could only be contacted through the KT or encryption system.

 7     It also states that towards the end of September communications were

 8     established between the CSB in Doboj and the CSB in Banja Luka and the

 9     ministry, and the ministry could only be reached by encrypted

10     communication.

11        A.   Well, yes.  But this should be interpreted in the way we saw a

12     normal situation or what would amount to a normal situation in the sense

13     of exchange of information by the regular means.

14        Q.   When I -- well, I'm talking about the regular system of

15     communication within the Ministry of the Interior of the RS?

16        A.   Correct.

17        Q.   In the last paragraph the department chief says that work is

18     stabilised of the communications centre and the CSB since at the outset

19     the system had been completely non-existent basically; is that correct?

20        A.   Yes.

21        Q.   Very well.  Sir, let's go back to the communications centre of

22     the MUP.  Could you please be shown P847.  It is another document you saw

23     yesterday.  It is a fact that you had insufficient personnel,

24     insufficient number of operators in the communications centre of the MUP

25     headquarters at Pale; is that correct?

Page 11658

 1        A.   Yes.

 2        Q.   Apologies.  It could be that I was confused with the numbers.  I

 3     wanted to see 65 ter 153.

 4             You remember this list, don't you, for personal incomes for May

 5     of the MUP headquarters?

 6        A.   Yes.

 7        Q.   Now, on page 2 we have a list of 12 names of people employed in

 8     the administration for communication, including you as assistant and head

 9     of the department, do you see that?

10        A.   Yes.

11        Q.   Now, of these people here employed at the -- communications

12     administration, a number of them -- I think you said three, I think you

13     said that three of them were technicians; right?

14        A.   Let me just take a look.  I can go through them all.

15        Q.   Yes, please do.

16        A.   Andric Blagoje he worked in the PTT and he was an engineer and

17     moved over to us.  He was a graduate of engineering.  And then the next

18     person was for encryption.  He was retired and reactivated.  Vasilic

19     Slobodan was also an engineer, having graduated from a higher -- the high

20     school for PTT, and he worked in the municipal SUP.  Then we have Dragan

21     Elez.  He was taken in later on.  Predrag Bozic, also later on, which

22     means that these two had no experience working in the Ministry of the

23     Interior.

24        Q.   Just pause there for a moment, please.

25        A.   You were interested in who the technicians were; right?

Page 11659

 1        Q.   I'm interested in how many technicians you had and how many

 2     signals men you had.

 3        A.   Well, only three were operators, encoders, three of them.  All

 4     the rest were technicians.

 5        Q.   In fact, for you to be able to service the communications centre

 6     round the clock under normal conditions, you would need at least five

 7     people or six operators, signals men; right?

 8        A.   Yes, for the lowest level in the communications centre at the

 9     security station, five; and of course far more for the MUP for anybody to

10     be able to work round the clock, 24 hours.

11        Q.   Just a digression at this point, if I may.  Yesterday you were

12     asked several times by Mr. Hannis about the location at Pale, and you

13     said that you were at a couple of locations at Pale, the centre, the

14     communications centre.  Do you remember that?

15        A.   Not the communications centre, but the MUP, the organs of this

16     internal MUP unit.  They were distributed in various facilities, and the

17     communications centre would move around, although there was just one.  It

18     was one centre but moving around from one location to another.

19        Q.   I'm sure you know, Mr. Kezunovic, that Mico Stanisic, as the

20     minister, from June 1992 was at Jahorina not Pale.

21        A.   Yes, that's right.  I perhaps omitted to state that yesterday,

22     but you're quite right.  That's how it was.

23        Q.   Now, sir, yesterday during our discussions, this communications

24     centre at the Ministry of Defence was mentioned at Pale, do you remember

25     that you spoke about that?

Page 11660

 1        A.   Yes.

 2        Q.   And you also said on the same subject that a certain colonel, the

 3     late Milorad Kotlica, was in charge of that communications or signals

 4     detachment, which was the communication line for the government and other

 5     organs?

 6        A.   He was the assistant minister of defence for communications, just

 7     as I was for internal affairs he was for communications, and within that

 8     there was a detachment and the command of the detachment was a major,

 9     Redji Agic [phoen], I believe.

10        Q.   Does the name Ranko Vukovic sound familiar?  I think he worked

11     in --

12        A.   Yes, I am familiar with the first and last name, but I can't link

13     it up to an image.  I don't know -- I can't remember how the man looked

14     like, but yes, the name does ring a bell.  I know it.

15        Q.   Tell me now, please, this communications centre of the Ministry

16     of Defence which served the government and the Presidency, did not have

17     anything to do with the MUP; right?

18        A.   Well, not at the beginning, no.  Not at that time, during the

19     period that you're referring to, but later on I don't know what the fate

20     of that centre and system was.

21        Q.   What I want to say is that your communications centre, the one

22     that you led as assistant minister and head of the department for

23     communications and encryption in the MUP of Republika Srpska, was

24     completely separate from this communications centre of the Ministry of

25     Defence; is that right?

Page 11661

 1        A.   Yes.

 2        Q.   And you had your communications through your centre; right?

 3        A.   Yes.

 4        Q.   It is a fact, is it not, that this communications centre of the

 5     Ministry of Defence also faced identical problems, the same problems you

 6     did, because it was linked up with the PTT system in the sphere of

 7     communication; right?

 8        A.   Yes.

 9        Q.   And it is also a fact, is it not, that they needed at least three

10     months, or rather, over three months to establish any kind of

11     communication at all from that centre?

12        A.   Yes, that's right.

13        Q.   Now, sir, this morning you were discussing some documents with

14     Mr. Hannis, and if I may -- well, if the OTP would return 1428 to you,

15     please, so that you can have it in front of you to take a look at in hard

16     copy, the printed version, please.  If the Prosecution could help us out.

17             MR. ZECEVIC:  65 ter 2516.

18             [Interpretation] I apologise, I should have announced that

19     earlier on, which I had omitted to do.  Thank you, Mr. Hannis and

20     Mr. Smith.

21        Q.   That's the document that you were asked to comment on by my

22     learned friend.  It's a notebook with entries of received and sent

23     dispatches from the communications centre of the Ministry of the Interior

24     of Republika Srpska for the period up to the 13th of May, I believe,

25     1992.  And when that notebook was transferred to the centre in Sarajevo.

Page 11662

 1     You remember that?

 2        A.   Yes.

 3        Q.   Now, it was put to you - and you accepted that - that although it

 4     says that this was a log-book of received and sent dispatches, that in

 5     actual fact the entries were for the most part -- or rather, that all the

 6     entries were of sent dispatches.  And now I'd like us to look at number

 7     20, which is on page 5 of the Serbian version, and I assume it's the same

 8     page in English.  But anyway, let's look at number 20 in both versions.

 9     And there you will see that it was a dispatch received, a message of some

10     kind, it says "message from Belgrade to the minister."  Do you see that?

11        A.   Yes.

12        Q.   Then if we go on to number 36, the page with entry number 36,

13     that's page 8, number 36, please.  Once again, it's a dispatch received

14     and it says:  "SDS Ilidza information service," that's the person sending

15     it.  It's a report from -- some report from the military hospital, and so

16     on.  Do you see that?

17        A.   Yes.

18        Q.   So that's a dispatch received?

19        A.   Well, a moment ago and now I don't know what received message and

20     received dispatch means.  I can call up, for example, and say a brawl has

21     broken out in a cafe.  That would be information about something,

22     somebody reporting something.  This doesn't appear to be a dispatch to

23     me, to be quite honest because if it is a proper dispatch then -- I don't

24     know.  It wouldn't say "dojava" or report.  There would be a title of

25     some sort, a heading.

Page 11663

 1        Q.   Well, be that as it may, it doesn't only refer to sent dispatches

 2     but received dispatches as well.  Let's take a look at the last page,

 3     number 49.  Page 10.  You've already looked at that page you will recall?

 4        A.   Yes.

 5        Q.   So the first document that we looked at under number 1 was of the

 6     22nd of April, 1992, and this last one, number 49, is dated the 13th of

 7     May.

 8        A.   Yes.

 9        Q.   So that means a period of some three weeks overall.  The entries

10     cover a three-week period; right?

11        A.   Yes.

12        Q.   Now, for purposes of illustration and the lack of communication

13     between the CBS of Doboj and Trebinje that we discussed earlier on, if

14     you look at number 47 and number 48 you will see that there is no entry

15     with the telephone when these were received in these SBS centres, do you

16     see that?

17        A.   Doboj and Trebinje.

18        Q.   Well, the truth of the matter was that the communications were

19     down, so these dispatches were never received; is that right?

20        A.   Yes.

21        Q.   Now, sir, here we had the MUP headquarters, and the MUP has five

22     SCBs, security services centres.  Now, over the space of 21 days, which

23     is the period covered here with the entries, we have barely 50, or

24     rather, 49 dispatches sent out, which is I think about two and a half

25     dispatches per day on average; right?

Page 11664

 1        A.   Well, that's the maths of it.

 2        Q.   Now, if you look, sir, at this log-book of received and sent

 3     dispatches, you will see that a certain number of dispatches - I mean

 4     more than ten - went to Pale within the ministry in its seat -- from

 5     Vrace to Pale?

 6        A.   Yes.

 7        Q.   And that reduces the number of sent dispatches to other users

 8     towards the CBSs on the territory of Republika Srpska; isn't that right?

 9        A.   Yes.

10        Q.   This is the very beginning, April and May 1992.  The security

11     centre was just being established, there was a war on, and we have an

12     average of two to two and a half dispatches a day if we count those

13     moving within the ministry, within the ministry headquarters; right?

14        A.   Yes.

15             MR. HANNIS:  I'm sorry to interrupt.  The witness has testified

16     before that dispatch has a certain meaning for him, and I think he's

17     already indicated that he does not consider all of these things in this

18     list as dispatches.  So if we could clarify that with him.  That's my

19     only request.

20             MR. ZECEVIC: [Interpretation] Yes, I'm grateful to Mr. Hannis for

21     his suggestion.

22        Q.   Sir, when we leafed through this, and we have here among others

23     under number 16, for example, on page 4 it says order and decision re:

24     Stamps.  Under number 16 that's what it says there.  Do you see that?

25        A.   Yes.

Page 11665

 1        Q.   Then we have, as we've already seen, under 20 some message.  Then

 2     number 40, or rather, 36, report or information for "SRNA" and so on and

 3     so forth.  So almost 50 per cent of these are not actually dispatches in

 4     the true sense of the word.  So 50 documents listed here are not in fact

 5     dispatches in the true sense of the word, as we understand a dispatch and

 6     as it was used in the MUP of Republika Srpska?

 7        A.   Yes, that's right.

 8        Q.   So that then reduces the whole thing to barely one dispatch a day

 9     for the period from the 22nd of April to the 13th of May, 1992; right?

10        A.   Well, yes, it comes out that way.  It was the communications

11     centre Vrace.

12        Q.   And "SRNA," where some of the reports went to, was in Pale,

13     wasn't it?

14        A.   Yes.

15        Q.   So the traffic in those 21 days was - let me put it that

16     way - mostly between Vrace and Pale; isn't that right?

17        A.   Yes.

18             MR. ZECEVIC: [Interpretation] Can we please show the witness

19     P1429, please.

20             And I would kindly ask if the Prosecution has a hard copy of the

21     document, if they could make the witness's job a little easier.

22             Thank you.  I'm grateful.

23        Q.   Sir, you saw this document and commented on it this morning, do

24     you remember?

25        A.   Yes.

Page 11666

 1        Q.   With the Prosecutor.  This is a document that notes down outgoing

 2     mail, mail that is being sent from the MUP seat of -- the MUP of

 3     Republika Srpska?

 4        A.   Yes, I see that.

 5        Q.   And this refers to the period, as we can see here, from the 9th

 6     of November until the 30th of December, 1992.  Do you see that?

 7        A.   Yes, I do.

 8        Q.   And on the first page it says "dispatch," and then there are some

 9     documents.  There are some accompanying documents, different documents

10     that were sent out by the MUP at the Republika Srpska headquarters.  Do

11     you agree?

12        A.   Yes, I do.  But I keep thinking about one thing.  When we had the

13     previous document -- all right.  But particularly this one, why are there

14     no covers where it clearly states what that is, novel such and such

15     written by so and so, published by such and such a publisher, so that you

16     know clearly what this is.  I am responding to questions about documents

17     like this only because I am trying to be useful; but actually, it's very

18     hard for me to talk about this because there used to be a public security

19     centre in the Pale -- which was also located in Pale.  Perhaps they also

20     dispatched certain documents that also went through a certain route to

21     reach somebody.  So this can also create confusion, and these improvised

22     log-books with different columns, different contents, where it says

23     "sent" and "received," and so you're not sure whether it's one or the

24     other.  All of that can also be under a question mark -- well, I mean,

25     I'm just making this observation.  But I can continue to answer your

Page 11667

 1     questions in any case.

 2        Q.   [Microphone not activated]

 3             THE INTERPRETER:  Microphone, please.

 4             MR. ZECEVIC: [Interpretation] I'm sorry.  I apologise.

 5        Q.   And you can see the dispatches on page 1 under 3 and 4 refer to

 6     an escort for the patriarch, do you see that?

 7        A.   Yes, I do.

 8        Q.   Do you recall that the patriarch visited in late November 1992?

 9        A.   Yes, I remember he did come at the end of the year, but I don't

10     remember the details.

11        Q.   What is crucial as far as I'm concerned, sir, is this:  This is

12     57 days in all from the 9th of November to the 30th of December -- 51

13     days.  And we have a total of 97 outgoing dispatches and other documents

14     from the ministry.  At the end of the year there was an average of two

15     dispatches a day that was sent out, more or less.  Do you agree?

16        A.   Yes, that is correct.

17        Q.   Still looking at this document, there is a log-book of incoming

18     mail that covers the period of the 9th of November to the 31st of

19     December, 1992.  I don't know if Mr. Hannis perhaps has this document, a

20     hard copy of the document for you to look at, Witness.  The reference

21     numbers where the document starts from are 0371-0760 and on.  This is the

22     ERN number.

23             MR. HANNIS:  I've given him all that I have.  I ...

24             MR. ZECEVIC:  Thank you very much, Mr. Hannis.

25             [Interpretation] In order to make it easier for the witness,

Page 11668

 1     perhaps the usher can hand my copy over to him.  I don't know if there is

 2     an English.

 3             JUDGE DELVOIE:  Can we have a 65 ter number, Mr. Zecevic?

 4             MR. ZECEVIC:  Your Honours, I believe that's the same -- that is

 5     the same 65 ter number, 65 ter 3218, which is P1429 --

 6             JUDGE DELVOIE:  Oh, it's still -- okay.

 7             MR. ZECEVIC:  But apparently this part of the document has not

 8     been translated.  I wasn't aware.

 9             MR. HANNIS:  [Microphone not activated]

10             There's only a partial English translation.

11             THE WITNESS: [Interpretation] There is something that I have

12     noticed in relation to the previous document, and I noticed that and now

13     I'm a little bit confused.  That's why I wasn't really paying attention.

14     In the first column behind the numerals, can we go back --

15             MR. ZECEVIC: [Interpretation]

16        Q.   You're talking about the previous document that we were looking

17     at?

18        A.   Yes.

19             MR. ZECEVIC: [Interpretation] Could we now please go back to the

20     first page P1429, please.

21        Q.   Go ahead, sir, you wanted to comment.

22        A.   Yes.  The order number is in the first column and then let's look

23     at the next column.  You will notice that all the numbers there begin

24     with a 10, 10-2, -3, -4, and all the way to the end, which means that

25     this is not the number of the communications centre.  This is the number

Page 11669

 1     of some organisational unit.  And its documents are here which were sent,

 2     and you can see the numbers going up.

 3        Q.   So you are asserting that this document, P1429 that was shown to

 4     you by the Prosecution, is actually not a document of the communications

 5     centre of the Republika Srpska MUP?

 6        A.   No, not of the communications centre at all, because you would

 7     have the documents and dispatches that would be marked with different

 8     numbers, depending on the addressee or the person who was sending out the

 9     document.  So this is what I have noticed.  And that's why I made the

10     remark.  Why don't we have the cover for each of these log-books?

11        Q.   I assume that Mr. Hannis will cover that in his re-direct.

12                           [Trial Chamber and Legal Officer confer]

13             JUDGE HALL:  Sorry, please continue, Mr. Zecevic.

14             MR. ZECEVIC:  I just returned this document to me by Ms. Usher,

15     but I think maybe the witness can comment on this because it appears to

16     be different.

17             Thank you very much.  I'm really sorry.  So the reference number

18     is ERN 0371-0760.  Thank you very much.

19        Q.   [Interpretation] Sir, we have some different markings here, 02,

20     01, 01, then followed by 404 dash something, 143-11.

21        A.   Well, this is exactly what I was remarking.  This looks like a

22     log-book of the communications centre.

23        Q.   All right.  If that's what it seems to be to you, then let us

24     comment on this one.  Take your time and look.

25        A.   But again, I don't see -- well, it does say that it's incoming

Page 11670

 1     mail log-book, but again it doesn't say whose log-book it is.  This looks

 2     like the log-book of received dispatches.

 3        Q.   It looks like a book of received dispatches of the communications

 4     centre attached to the Republika Srpska MUP; is that correct?

 5        A.   Yes.

 6        Q.   All right.  Very well.  I'm interested if you can comment on the

 7     period from November 9th until the 31st of December.  Can you please look

 8     at entry number 1 and can you look at the last entry, please.  And it

 9     relates to 1992, doesn't it?

10        A.   Yes.

11        Q.   What is the last entry number?

12        A.   284.

13        Q.   Sir, this is the log-book of incoming mail, and it covers all

14     that arrived at the Republika Srpska MUP communications centre,

15     regardless of whether it arrived from the security services centres, some

16     other state organs, or third parties.  Thus, everything that came in was

17     noted in the log-book; is that correct?

18        A.   Yes.

19        Q.   If we take it that at least one-half of those documents from the

20     CSBs, if I manage to understand things and evaluate them correctly or

21     two-thirds, and since we're talking about the period of 51 days again at

22     the end of 1992 during war time, this again would mean at least -- at the

23     most four dispatches from the CSBs on average reaching the MUP of

24     Republika Srpska every day; is that correct?

25        A.   Yes.

Page 11671

 1        Q.   That's less than the total number of the CSBs, which is actually

 2     five?

 3        A.   That is correct -- well, we have some from municipalities, from

 4     hospitals, institutions that have nothing to do with the MUP too.

 5        Q.   Thank you.  Sir, can we now look at P625, please.  You will

 6     recall and that you looked at this and commented on it with Mr. Hannis.

 7     This is the report on work in the period of April-December 1992.  The

 8     date when the report was drafted is 1993.  And you will recall that you

 9     told Mr. Hannis about the number of 9.585 ultra short connections

10     achieved in that period in these nine months in 1992.  Do you remember

11     that?

12        A.   Yes, I do.

13        Q.   You gave us an explanation then that this number was extremely

14     high and that it was indeed true; however, you also explained that these

15     were only tests of connection, that there was no actual traffic using

16     that backup system.  You recall that?

17        A.   Of course.

18        Q.   In this document, the report, it says that on average these tests

19     were done on ultra short waves every 45 minutes; you remember that?

20        A.   Certainly.

21        Q.   Just to be perfectly clear, a test of connection looks like this:

22     A calls B, B picks up, A reads out:  Today's a nice day, B says:

23     Received, over and out, and that's it?

24        A.   Yes, this was a simple test of quality.

25        Q.   And that's the explanation for this number, 9.585?

Page 11672

 1             MR. HANNIS:  I'm sorry, if that's a question, can we have an

 2     answer; if it's just a statement, can it be stricken.

 3             MR. ZECEVIC:  I believe the witness answered.  I don't know how

 4     it wasn't recorded.

 5        Q.   [Interpretation] Would you please repeat your answer to the last

 6     question.  I said that's the explanation for this number, 9.585?

 7        A.   Yes.

 8             MR. HANNIS:  I'll address it on re-direct.

 9             MR. ZECEVIC:  Okay.

10             [Interpretation] That's page 29 -- or no, no, I'm sorry.  32 in

11     Serbian.

12                           [Defence counsel confer]

13             MR. ZECEVIC: [Interpretation] 32 in Serbian, but I really can't

14     find what page in English it is.  It's FE20-1307.

15        Q.   Can you see the last-but-one paragraph?

16             MR. ZECEVIC: [Interpretation] I'm being told it's page 22 in

17     English.  It's the last-but-one -- no, no, it's on the next page.

18        Q.   I'm sorry, Mr. Kezunovic, but we have to get it on the screen.

19             So in English it's paragraph 2 and in Serbian it's the

20     last-but-one.  It says:

21             "On average 15 dispatches a day were sent to the centres and

22     other organs of the interior from the MUP headquarters (a total of 4.170

23     in all lines of work) and on average 16 dispatches a day were received (a

24     total of 4.400)."

25        A.   Yes.

Page 11673

 1        Q.   Which means that in these nine months we have 9.585 [as

 2     interpreted] dispatches, both sent and received?

 3        A.   That's correct.

 4        Q.   I suppose this is information attached by your administration to

 5     this report?

 6        A.   That's correct.

 7             MR. HANNIS:  I'm sorry.  I don't follow the math.  4.170 and

 8     4.400 is not 9.585.  I think you're referring to the old short wave

 9     number.

10             MR. ZECEVIC:  I said 8.570, and I believe --

11             MR. HANNIS:  I'm just reading what's on the transcript.

12             MR. ZECEVIC:  Thank you very much.  I wasn't following the

13     transcript.  I was following the document.

14             [Interpretation] Can we show the witness page 36 in Serbian, 27

15     in English.  That's item 3.  The tasks and duties of communication and

16     cryptographic protection.  That's it.

17        Q.   This is part of this annual report, and in paragraph 1 -- first

18     of all, your administration drafted this?

19        A.   Yes, we prepared a longer text.  This was taken out of my overall

20     report, and the analysis department took out the passages they believed

21     relevant to the annual report.

22        Q.   But you're not questioning this paragraph?

23        A.   No, no, it's absolutely correct.  We prepared it.

24        Q.   I actually said you are not questioning the veracity of the data

25     regarding your administration and you said "correct."

Page 11674

 1             MR. ZECEVIC: [Interpretation] Could we maybe enlarge the first

 2     paragraph or I'll just read it out.

 3        Q.   You say:

 4             "... it can be noted that this part of the Ministry of the

 5     Interior was among those which organisationally speaking faced the most

 6     problems."

 7        A.   It's not that we had the most problems.  We had only problems.

 8     You know what a problem is by definition, something you are not able to

 9     deal with; something you can deal with and resolve is not a problem.

10             JUDGE HALL:  Mr. Zecevic, don't forget to wind up in about three

11     minutes for me, please.

12             MR. ZECEVIC:  Thank you very much.  Perhaps this is an adequate

13     time for me to stop.  I have maybe ten more minutes or 12, 15 for Monday

14     morning.  Thank you, Your Honours.

15        Q.   [Interpretation] Thank you, Mr. Kezunovic.  We'll continue on

16     Monday.

17             JUDGE HALL:  Mr. Kezunovic, we're about to take the adjournment

18     for the weekend and to resume at 9.00 on Monday.  The Chamber will not

19     rise immediately, so I'll ask the usher to escort you from the chamber.

20     We trust you have a safe weekend.  Thank you, sir.

21                           [Trial Chamber and Registrar confer]

22             THE REGISTRAR:  Your Honours, the bulletins tendered at the end

23     of the previous session will be assigned numbers P1430 through P1445, and

24     the 17th document is already marked for identification as P142, so it

25     will be admitted as exhibit.

Page 11675

 1                           [The witness stands down]

 2             JUDGE HALL:  Thank you.

 3             [Microphone not activated]

 4             Sorry.

 5             On the 28th of May, 2010, the Prosecution filed a motion to amend

 6     its Rule 65 ter witness list as a result of the Trial Chamber's decision

 7     of the 1st of April, 2010, on judicial notice of adjudicated facts,

 8     seeking to add 57 witnesses.  The Defence jointly responded on the 8th of

 9     June, 2010, objecting to the motion, in part on the ground of incomplete

10     disclosure of witness material pursuant to Rule 66(A)(ii).

11             To consider a motion for additional witnesses once the trial has

12     commenced, the Chamber must be satisfied, inter alia, that the

13     anticipated testimony of each proposed witness is relevant and probative

14     to the issues in the case and that the Defence has adequate time to

15     prepare its cross-examination and is not unduly prejudiced by the

16     decision -- by the addition.  Accordingly, the Chamber would have

17     expected the Prosecution to provide the summaries of the anticipated

18     testimony of the proposed 57 witnesses pursuant to Rule 65 ter (E)(ii)

19     (b) in a contemporaneous filing.  In the absence of these summaries not

20     yet provided, the Chamber is unable to proceed with the motion on the

21     merits.

22             Further, the Prosecution's motion does not inform the Chamber of

23     the progress it has made in fulfilling the disclosure obligation under

24     Rule 66(A)(ii) for the proposed witnesses since it formed the intention

25     to call them.  For these reasons, the Chamber now orders the Prosecution

Page 11676

 1     to file an addendum with the summaries of the anticipated evidence of the

 2     proposed 57 witnesses by Wednesday, the 16th of June.  The Chamber also

 3     orders the Prosecution to provide status reports on the disclosure of

 4     material related to the proposed additional witnesses pursuant to

 5     Rule 66(A)(ii).

 6             So we take the adjournment to Monday morning, and I believe

 7     according to the schedule we're in Courtroom III for all mornings next

 8     week.  So I trust everyone has a safe weekend.  Thank you.

 9                           --- Whereupon the hearing adjourned at 1.42 p.m.,

10                           to be reconvened on Monday, the 14th day of

11                           June, 2010, at 9.00 a.m.