Tribunal Criminal Tribunal for the Former Yugoslavia

Page 7100

1 Tuesday, 7 November 2000

2 [Open session]

3 [The witness entered court]

4 --- Upon commencing at 9.25 a.m.

5 JUDGE RIAD: I would like to greet the parties and all our staff

6 and extend my greeting to the gallery. We can resume asking the witness.

7 I forgot to greet the witness too. Good morning.

8 THE INTERPRETER: Microphone, please.

9 MR. PETRUSIC: [Interpretation] Good morning, Your Honours, my

10 learned friends from the Prosecution, Witness DB. Mr. President, the

11 Defence wishes to inform you that in the course of today's hearings,

12 General Krstic will not be attending due to problems of health, which have

13 been confirmed by the doctors yesterday afternoon in the Detention Unit,

14 so that as far as the Defence is aware, there might be some surgery.

15 General Krstic agrees to continue today's hearings in his absence, and

16 during the afternoon the Defence will have his written waiver prepared so

17 that we can continue our hearings without further problems.

18 JUDGE RIAD: Thank you very much. We are aware of this and we

19 wish General Krstic recovery and we'll continue the trial since he has

20 agreed. Thank you. Please proceed.

21 MR. PETRUSIC: [Interpretation] Thank you, Mr. President.

22 WITNESS: WITNESS DB [Resumed]

23 [Witness answered through interpreter]

24 Examined by Mr. Petrusic: [Continued]

25 Q. Witness DB, we stopped yesterday when we were discussing the 13th

Page 7101

1 of July, that is, the establishment of the forward command post in the

2 village of Krivace. You said that you don't remember what time of day it

3 was when you noticed General Krstic's presence, so my question is: Can

4 you tell us which officers of the Drina Corps were present at the forward

5 command post at Krivace for as long as it existed?

6 A. (redacted)

7 (redacted)

8 (redacted)

9 (redacted). In

10 the logistics section of this forward command post, I remember the

11 presence of Lieutenant Colonel Hendryk Jevitski.

12 Q. While the forward command post existed in Krivace and later in

13 Godenje, were other officers of the Drina Corps or the Main Staff present?

14 A. At the forward command post in Krivace and later Godenje, General

15 Mladic would occasionally come, but he didn't stay for long. I think that

16 he came in all two or three times throughout the duration of the Zepa

17 operation.

18 Q. Was General Krstic present at the forward command post throughout

19 the duration of the operation?

20 A. General Krstic was present more or less all the time at the

21 forward command post in the village of Krivace and the village of

22 Godenje. I remember that he would occasionally go to tour the units

23 participating in the operation, but all this took place within a radius of

24 several kilometres.

25 Q. While touring the units was he in radio contact or in contact in

Page 7102

1 any other way with the forward command post and with the units?

2 A. Throughout the time he was connected to the command radio network

3 in such a way that one of the soldiers with a mobile device would

4 accompany him as he moved, or General Krstic himself would call from the

5 command post of one of the subordinate units, using their transmitters.

6 Q. Witness DB --

7 JUDGE RIAD: Excuse me. You say one of the soldiers with a mobile

8 device would accompany him as he moved. Was that a constant accompanying

9 person, like a bodyguard accompanying somebody everywhere?

10 A. No. He was a soldier from the communications battalion who would,

11 pursuant to General Krstic's orders, go with him carrying the mobile

12 equipment along. So depending on General Krstic's assessment as to

13 whether he would need him while he was touring or while he was temporarily

14 absent, this soldier with the mobile device would go with him in the jeep

15 or on foot, if that was how -- if he could walk at the time. So the

16 soldier was not from his -- a bodyguard or security unit, but from the

17 communications centre of the forward command post.

18 JUDGE RIAD: According to your knowledge and experience, a man in

19 the position of a General would be constantly accompanied by a soldier for

20 communication?

21 A. General Krstic had his own security and escort, physical escort.

22 JUDGE RIAD: I'm speaking of communication. The mobile device, is

23 this part of a General's equipment?

24 A. No, no. That was not the practice in our conditions for a part of

25 the communications equipment to always accompany the General.

Page 7103

1 JUDGE RIAD: Thank you. Please proceed.

2 MR. PETRUSIC: [Interpretation]

3 Q. Witness DB, who would decide whether when leaving the forward

4 command post the General needed to have a communication line?

5 A. I think that the decision would be made by General Krstic himself.

6 Q. And this communication line that he would take with him leaving

7 the forward command post, with whom could he establish contact by means of

8 it?

9 A. It was one of the reserve mobile transmitters that could only be

10 used within the same radio network of the units participating in the Zepa

11 operation. So when he would leave the forward command post to go to the

12 area of responsibility or the command post of one of the units

13 participating in the Zepa operation, in his absence from the forward

14 command post, he could command only those units that were participating in

15 the operation because with that device which the soldier was carrying, the

16 soldier from the communications centre, General Krstic could command only

17 the units that were involved in the Zepa operation.

18 JUDGE WALD: Excuse me, on the transcript, is that really the

19 correct English translation, that he could "command only" the units, or

20 should it be "communicate only" with the units? It says here, "In his

21 absence ... he could command only those units participating in the

22 operation because with that device," and then later on it repeats that,

23 that he could "command only the units." I'm wondering if you don't mean

24 communicate, if the English translation shouldn't be "communicate"?

25 MR. PETRUSIC: [Interpretation]

Page 7104

1 Q. Witness DB, in his absence from the forward command post, could

2 General Krstic, using this device, communicate only with units

3 participating in the Zepa operation?

4 A. Yes. It is a device with limited range and voice protection, and

5 the key that we used to protect the speech was available only to units

6 participating in the Zepa operation. To explain this technically, this

7 means that using this device, he could communicate only with the units

8 participating in the Zepa operation.

9 According to its technical properties, it has a range of 8 to 12

10 kilometres, but because of the characteristics of electromagnetic waves,

11 its range is considerably reduced in a mountainous and wooded terrain.

12 Q. Witness DB, do you know -- no, let me withdraw that.

13 Do you know what position General Krstic held in the command of

14 the Drina Corps on the 13th of July, 1995?

15 A. I think that General Krstic was Chief of Staff of the Corps.

16 Q. Do you have any knowledge as to when General Krstic became

17 commander of the Drina Corps?

18 A. I know that this is an important question, but in my preparations

19 for my testimony here, I read the order of the president of the Republika

20 Srpska dated the 13th of July appointing General Krstic commander of the

21 Drina Corps, because it is only the president who has the authority to

22 appoint people to these strategic groupings and positions.

23 While we were at Zepa, whether it was over the media or in some

24 other way, anyway, we learnt of the decree of the president of the

25 republic. And I know that sometime around the 20th of July or

Page 7105

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Page 7106

1 thereabouts, there was a gathering of generals in a facility close to Han

2 Pijesak. There were a number of generals from the Main Staff and the

3 commanders of the other Corps, and also present were General Zivanovic and

4 General Krstic, and I know that the event was organised to observe the

5 handover of duty by the commander of the Drina Corps. And I know that

6 after General Krstic's return to the forward command post in the village

7 of Godenje, some people congratulated him on his taking over of duty.

8 I wish to mention that in that period we were at a location which

9 had very little information outside those related to the combat operations

10 in Zepa and around it, and General Krstic himself did not talk about his

11 appointment with us other officers.

12 Q. Sir, you're an officer who has graduated from the highest military

13 educational institutions that existed in the former Yugoslavia and in the

14 newly formed republics. According to your laws and regulations, the

15 takeover of duty, is it an obligatory act that has to take place when

16 commanders change, regardless of the level of command?

17 A. Yes. According to our laws and regulations, it is prescribed in

18 detail that all duties in the army, from the lowest to the highest level,

19 have a date fixed when one officer hands over duty to the other and all

20 the obligations, the documents, the material consequences resulting from

21 that position. And after this period, which is defined clearly by their

22 superior, a document has to be compiled with a defined content, and that

23 document is called a record on the handing over and taking over of duty.

24 So it has a clearly defined format according to instructions, and

25 only after that report has been drafted, this is the basic document which

Page 7107

1 serves as a basis for the drafting of other documents such as the taking

2 over of duty and other personnel papers. So that the person taking over

3 of duty, once these documents come into effect, in fact becomes what he

4 has been appointed to become by his superior commander.

5 Q. Let us depart for a moment from our main topic, that is,

6 Srebrenica and this time period, and let me ask you a general question.

7 As you are a military officer, and one can assume that you are

8 knowledgeable about these things, the regular combat report from

9 subordinate units when addressed to the superior command, who receives

10 these reports?

11 A. The regular operative combat report from subordinate units, if

12 they are being sent by teletype encoded links, reach the communications

13 centre; and if they are sent by courier or messenger, they are delivered

14 to the mailing department, from where they are carried to the operations

15 room or the operations centre of the Corps command, the reception of which

16 is confirmed by signature to the carrier in his book by the operations

17 officer on duty or the duty officer in the operations centre, so he signs

18 this book confirming receipt.

19 Q. So the operations officer on duty is the first person to

20 familiarise himself with the contents of such reports?

21 A. Yes. Within the framework of the daily functioning of control and

22 command, it is clearly defined up to what time those reports have to be

23 delivered, so that the operations officer on duty will have time to round

24 off all those reports and make a compilation of them and send an

25 operations report of that command to the superior command. Once he has

Page 7108

1 drafted such a report, he takes it to the commander for his inspection,

2 and on that occasion he may draw his attention to something that may be

3 new, that deviates from the regular situation regarding the unit's

4 reports.

5 Q. In the course of the proceedings so far, we have seen a great deal

6 of markings, and I don't want to put them on the ELMO, but I'm going to

7 give you an example. For example, Zlatar 1 as a name, and 01. Can you

8 explain to us what that means, Zlatar 1 and 01?

9 A. The instructions with regard to documents related to

10 communications is precisely defined in a document which is called a review

11 of code names, and it is there to protect the names of the actual units.

12 For example, if we're talking about the command of the Drina Corps as the

13 actual name and title of the unit, then its code name should be Zlatar.

14 Then in going through the other code names and a review of them, it states

15 that the rear command post is Zlatar 1, that the forward command post is

16 Zlatar 2. And if we define a reserve command post, if that is defined as

17 well and stipulated, then that could be Zlatar 3. In the rules and

18 regulations that exist in the army, the mark "01" or "02" does not exist

19 anywhere, although in wartime practice it is frequently used to -- that is

20 to say, the commanding officers who are commanders or chiefs or suchlike.

21 Q. Witness DB, I should now like to show you some intercepts, radio

22 messages intercepted.

23 MR. PETRUSIC: [Interpretation] And may I call upon the usher for

24 Exhibit -- OTP Exhibit 698A bis. Would you please put it on the ELMO, the

25 English version.

Page 7109

1 Q. And you, Witness DB, would you please read through this intercept,

2 radio message.

3 Have you read it?

4 A. Yes.

5 Q. Do you remember in the course of the time you spent at the forward

6 command post of Zepa, do you remember having had this conversation?

7 A. I remember that there was some 150, 200 soldiers which were to

8 have been pulled out of the composition of forces which took part in the

9 Zepa operation and that they were to be deployed to the vicinity of Han

10 Pijesak, not far from Zepa, in order to ensure certain communications or

11 to set up some ambushes, because at that time, that is to say, during that

12 period, we expected a breakthrough by the forces of the 285th Zepa Brigade

13 from the direction of Zepa towards Han Pijesak and Kladanj. I remember

14 this because I thought at the time how I could organise communications

15 with that unit, which was going a little further off from the area of the

16 combat operations themselves. But I don't remember -- here there's --

17 there's a question here which I don't seem to remember. It says, "Is

18 Jokic there?" "Is Jokic around?" That's what the question is: "Is Jokic

19 around?" And I'm quite certain that there wasn't any Jokic there at the

20 time, if that is the conversation and the period. There wasn't a Jokic

21 there at all at Krivace or Godenje either.

22 MR. PETRUSIC: [Interpretation] I should like to ask the usher now

23 to place OTP Exhibit 477A bis on the ELMO, please.

24 JUDGE RIAD: Mr. Petrusic, just a question. This intercepted

25 message, do you have it by any chance in an audio cassette?

Page 7110

1 MR. PETRUSIC: [Interpretation] No.

2 JUDGE RIAD: Thank you.

3 MR. PETRUSIC: [Interpretation]

4 Q. Witness DB, do you know who Major Furtula is?

5 A. Yes. Major Furtula at the time was the commander of the 5th

6 Podrinje Light Infantry Brigade.

7 Q. Do you know who Tasic and Sladojevic are?

8 A. No.

9 Q. Do you know about the individuals Nastic and Blagojevic?

10 A. Yes. They were the commanders of the brigades of the Drina Corps.

11 Q. Witness, do you know who Ljubo Beara is?

12 A. I did, yes.

13 Q. Did you, during the time you spent at the forward command post,

14 see Ljubo Beara?

15 A. No.

16 Q. During your stay at the forward command post, did you hear through

17 your communications systems about him?

18 A. No.

19 Q. Did anybody, any of your soldiers, signalsmen, convey to you the

20 fact that he was -- his presence in the radio relay communications

21 network?

22 A. No.

23 Q. Thank you.

24 MR. PETRUSIC: [Interpretation] I should like now to ask the usher

25 for OTP Exhibit 786A, B.

Page 7111

1 For purposes of the record, Mr. President, the Defence would like

2 to take note that this exhibit has still not been admitted into evidence

3 as a Prosecution exhibit.

4 JUDGE RIAD: Yes, Mr. Petrusic.

5 Mr. Harmon?

6 MR. HARMON: Yes, I'm just looking in the record. I heard the

7 English translation of 786, and I believe the exhibit that my colleague is

8 referring to is 789.

9 THE REGISTRAR: That is correct.

10 JUDGE RIAD: Madam Registrar, it has not been admitted into

11 evidence?

12 THE REGISTRAR: That is correct, 789.

13 MR. PETRUSIC: [Interpretation]

14 Q. Witness DB, do you remember that you had a conversation during

15 your stay at the forward command post in which stocari are mentioned?

16 A. No. I had different conversations and different messages were

17 conveyed. I know that most of them referred to combat activities, and

18 nothing with regard to stocari, cowboys or --

19 Q. Thank you, Witness.

20 MR. PETRUSIC: [Interpretation] Mr. President, as this document has

21 not been introduced into evidence, the Defence will withdraw it, but just

22 used it to ask this one question of the witness.

23 JUDGE RIAD: Thank you, all right.

24 MR. PETRUSIC: [Interpretation]

25 Q. Witness DB, you spent a lot of your time with the communications

Page 7112

1 system and systems. You have a lot of experience and knowledge about what

2 we call intercepts, intercepts of radio-relayed messages. What is your

3 knowledge in that respect as to the possibility of interception, the

4 transcription, and the whole technique, and the general reliability?

5 MR. HARMON: Excuse me, Mr. President. If the witness is going to

6 testify as an expert, then I believe we should have received a report of

7 this witness as an expert in the subject area about which he's going to

8 testify.

9 JUDGE RIAD: Mr. Petrusic?

10 MR. PETRUSIC: [Interpretation] The Defence has posed certain

11 restrictions with respect to asking these questions. Of course, we're not

12 going to ask the witness to -- who is present here to speak as an expert

13 witness. That was not our intention. We just wanted to hear his opinion,

14 and I don't think that comes under the rules and regulations of expert

15 witness testimony at all.

16 We're just asking for an opinion in view of the fact that he spent

17 some time at that forward command post and did a lot of work with radio

18 communications, that he heard many conversations and so on and so forth,

19 and just to present us with his views about that.

20 JUDGE RIAD: You mean you want to ask him only about his own

21 experience, what he has been doing?

22 MR. PETRUSIC: [Interpretation] Precisely so, Your Honour.

23 JUDGE RIAD: And how --

24 MR. PETRUSIC: [Interpretation] And with respect to the

25 conversations that he has been presented with so far during his

Page 7113

1 examination and testimony.

2 JUDGE RIAD: Mr. Harmon?

3 MR. HARMON: Your Honour, if the testimony is limited to his

4 experience only, then that's a different issue; but if he's testifying as

5 an expert, then under the appropriate rule, we should have received an

6 expert report.

7 JUDGE RIAD: Mr. Petrusic, only his own experience?

8 MR. PETRUSIC: [Interpretation] Only his own experience, yes, Your

9 Honour.

10 JUDGE RIAD: Thank you.

11 A. As far as the functioning of communications goes and their

12 protection, radio communication and monitoring and interception in this

13 past war, what I can say is that the situation was the following: Those

14 monitoring groups listening in were formed, or perhaps 100 per cent they

15 were formed of people who do not have the necessary experience required in

16 the army. They were not trained for that work in the army or in military

17 schools. They were not trained to do that work, but they learnt to do it

18 as they went along while they were monitoring and intercepting certain

19 lines of communication.

20 JUDGE RIAD: Excuse me, you are speaking of the people

21 intercepting on your side, on the Bosnian Serb --

22 A. Yes.

23 JUDGE RIAD: Not what you call the enemy side?

24 A. Your Honour, in preparing for this trial, I had occasion to read

25 through some of the intercepts by our enemies, and I have come to the

Page 7114

1 conclusion that they worked along the lines that we worked too. The way

2 we worked was similar. So what I say for our side can also -- is also

3 true of the other side, the enemy side. But I'd just like to mention,

4 having said that, that the enemy side had far worse military technology in

5 that area and that they had to resort to improvisation using other

6 technical devices. But I do know that it was very difficult to monitor

7 and intercept certain communication lines, especially radio relay ones,

8 because, as a rule, one participant in the conversation would be heard

9 much clearer than the other; the other one would be very weak or hardly

10 audible at all. So that it was on the basis of recollections and

11 assumptions as to what that party could say. This was inscribed as the

12 message.

13 JUDGE RIAD: Proceed, Mr. Petrusic.

14 JUDGE WALD: I have one question, if I could, Witness DB. I want

15 to make sure I understand your testimony. If, if there were mistakes or

16 if an intercept didn't accurately reflect what had actually been said

17 between the parties, where is it most likely the mistake would have been

18 made? On the side of the monitoring person who was listening, who didn't

19 understand, or -- I mean, where is it most likely that the thing went

20 wrong, if in fact at the end the intercept didn't reflect what actually

21 went on in the conversation? Where is the most likely area that it would

22 have broken down?

23 A. Based on my experience, most probably where it would have broken

24 down would be the individual monitoring the conversation, because, as a

25 rule, those conversations are taped and then they are transcribed and

Page 7115

1 recorded on the basis of what is listened to and heard. And as the

2 audibility and clarity of the material that has been recorded is on the

3 limits or borderline of what can be used or not, then very often the

4 people monitoring and intercepting, based on a certain logics of their own

5 or based on previously intercepted conversations and what they heard

6 previously, determine who the speakers could be and what was said

7 approximately. According to our regulations, those individuals would have

8 had to have spent five years doing that type of work to be considered

9 competent to sift through the correct information from the incorrect, and

10 the important and unimportant.

11 MR. PETRUSIC: [Interpretation] Mr. President, the Defence has

12 reached the end of their examination of this witness. We have one or two

13 more questions, but may we suggest that this be done in private session,

14 in view of the fact that the questions emanate from questions that have

15 already been answered during this trial in private session.

16 JUDGE RIAD: All right. We'll go into private session, Madam

17 Registrar, please.

18 [Private session]

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

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16 [Open session]

17 MR. PETRUSIC: [Interpretation] The Defence has no further

18 questions for Witness DB.

19 JUDGE RIAD: Mr. Harmon, would you like to start your

20 examination?

21 THE INTERPRETER: Microphone, please, Mr. President.

22 JUDGE RIAD: Mr. Harmon, would you like to start your

23 cross-examination after the break?

24 MR. HARMON: Yes, thank you.

25 JUDGE RIAD: May I just ask: Do you have another witness for

Page 7119

1 today?

2 MR. PETRUSIC: [Interpretation] No, Mr. President.

3 JUDGE RIAD: For this week?

4 MR. PETRUSIC: [Interpretation] No. We have no more witnesses,

5 Mr. President.

6 JUDGE RIAD: Could you give us more information about the

7 condition of General Krstic when you come back?

8 MR. PETRUSIC: [Interpretation] Yes, certainly, and this is a

9 question that the Defence did wish to address.

10 JUDGE RIAD: When you come back, we expect that. Thank you.

11 May I just ask Mr. Harmon: How long would you think your

12 cross-examination will take?

13 MR. HARMON: I believe my cross-examination will conclude

14 tomorrow, sometime in the middle of the day.

15 JUDGE RIAD: Tomorrow. Good.

16 So let's have a break for 20 minutes. Thank you. So we come back

17 here at a quarter to eleven.

18 --- Recess taken at 10.26 a.m.

19 --- On resuming at 10.51 a.m.

20 JUDGE RIAD: Mr. Harmon, before you start your cross-examination,

21 I don't want to limit you with time. Usually I prefer not to make the

22 break before you finish a series of questioning, but as you saw, I

23 wouldn't like it to be more than an hour and a quarter maximum, or even

24 one hour, and then we have a break. But I don't want it to be hard and

25 fast rules; otherwise, there will be an interruption, and unless one of

Page 7120

1 the main features -- or the main players in our trial is disturbed, is

2 indisposed, we can continue till an hour or an hour and a quarter. Thank

3 you.

4 MR. HARMON: Thank you, Judge Riad.

5 JUDGE RIAD: Madam Registrar.

6 THE REGISTRAR: Excuse me, I just wanted to mention that I just

7 received a statement from General Krstic that he has no objections to the

8 Court proceedings continuing in his absence. So I have it here, and it

9 will be Exhibit D133.

10 JUDGE RIAD: May I ask Mr. Petrusic also if he has any news about

11 his medical condition?

12 MR. PETRUSIC: [Interpretation] During the break, Mr. President, we

13 spoke to General Krstic, and he is waiting for the surgery to take place

14 in the course of the day. Whether this will be carried out in the

15 Detention Unit or somewhere else, we don't know that yet.

16 JUDGE RIAD: Do you have more information about the surgery

17 itself?

18 MR. PETRUSIC: [Interpretation] Nothing more than that, except as

19 far as we have been informed, an incision has to be made to remove the

20 blood clot, which will mean that he will have to rest for the next few

21 days, and probably he will be unable to attend the proceedings, but that

22 raises another issue.

23 In view of the fact that we will probably be completing the

24 examination of this witness tomorrow, after that comes the re-examination

25 of General Krstic by the Prosecution and by Your Honours. In view of his

Page 7121

1 medical condition now and after this surgical intervention, we doubt that

2 that examination will be possible, so may I take the liberty to suggest to

3 the Trial Chamber that this part of the proceedings should take place in

4 the following sitting which has been scheduled to begin on the 20th of

5 November.

6 JUDGE RIAD: You mean the examination of General Krstic by the

7 Prosecution and the Judges? And what about your other witnesses? You

8 have no other witnesses at all this week or ...

9 MR. PETRUSIC: [Interpretation] For this week, we have no other

10 witnesses. We had too many at one point, and they were waiting for quite

11 a long time. And in collaboration with the Witness and Victim's Unit, we

12 came to the conclusion it would be best to send them home, and then for

13 the next sitting after the 20th of November, we could have them brought

14 here to testify.

15 In the meantime, again, for the Trial Chamber's information, the

16 Defence has revised the list of witnesses in relation to the list

17 submitted on the 14th of October so that we will be able to fit into the

18 time frame set by the Trial Chamber for the Defence case.

19 JUDGE RIAD: Thank you. Thank you very much for all your

20 cooperation. Please convey our best wishes to General Krstic.

21 MR. PETRUSIC: [Interpretation] Thank you.

22 JUDGE RIAD: Mr. Harmon, the floor is yours.

23 MR. HARMON: Good morning, Judge Riad and Judge Wald. Just to

24 inform you, throughout this examination I will be asking for private

25 sessions on a number of occasions because of the necessity to ensure the

Page 7122

1 protection of this witness's identity. And if I could right away ask for

2 a private session so as not to disclose this witness's identity, I intend

3 to ask him some questions that may well expose his identity.

4 JUDGE RIAD: Madam Registrar, please call.

5 THE REGISTRAR: We're in private session.

6 [Private session]

7 (redacted)

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12 [Open session]

13 MR. HARMON:

14 Q. Witness DB, I'm going to be asking you questions about the events

15 that took place in Srebrenica and the events that took place in Zepa from

16 early July to August of 1995. I will be also asking you about events that

17 took place after that. And those events took place many years ago.

18 Witness DB, did you keep a notebook and record any events or any

19 significant communications?

20 A. No.

21 Q. So your testimony before this Trial Chamber is based on your

22 recollections; is that correct?

23 A. Yes.

24 Q. Prior to coming to this Trial Chamber to testify, did you have an

25 opportunity to review any documents?

Page 7124

1 A. Yes.

2 Q. What documents did you review?

3 A. I looked at a part of the documents shown to me by Mr. Petrusic.

4 Q. Other than the documents shown to you by Mr. Petrusic, did you

5 review any other documents?

6 A. Since February, or rather April this year, connected to all the

7 events that took place in the areas of Srebrenica and Zepa, I communicated

8 quite frequently with people I knew and who were participants in the

9 event, and in this way I refreshed my recollection.

10 Q. Could you identify the people with whom you communicated in order

11 to refresh your recollection?

12 A. Those were mostly officers from the Drina Corps and a number of

13 soldiers, signalsmen who were with me at Srebrenica and Zepa.

14 Q. My question is: Can you identify them by name, please?

15 A. I spoke to Colonel Vicic, with Lieutenant Colonel Obrenovic, and

16 two of my signalsmen soldiers. One is called Baki.

17 Q. Who is the other one?

18 A. The other one is Plakalovic.

19 Q. Did they have first names?

20 A. Plakalovic's first name is Mirko. And as for the other one, we

21 usually use his nickname, so I can't remember his name.

22 Q. You don't remember his first name or his surname?

23 A. There were two of them, twin brothers. One of them was with me.

24 The name of one of them is Momir, but you see, I'm not sure, because there

25 are two of them, two twin brothers.

Page 7125

1 Q. Now, did you talk to anybody else about the events in Srebrenica

2 and Zepa besides the four individuals you've identified for us today?

3 A. I probably did with a lot of people, but these are customary

4 conversations amongst us.

5 Q. My question, Witness DB, is: In order to prepare for your

6 testimony today, you've identified four people with whom you talked in

7 order to refresh your recollection. My question to you is: Did you talk

8 to any other individuals other than the four you have identified today in

9 order to refresh your recollection about the events that occurred in

10 Srebrenica and in Zepa in 1995?

11 A. I have to tell you that we often communicate amongst ourselves

12 over there and that I spoke to a number of people, but not in the context,

13 strictly speaking, of my preparations for my testimony, but rather when we

14 commented on those events and that time period and the consequences those

15 events have had, so I cannot specify the people I actually spoke to as

16 part of the preparations for this testimony.

17 Q. All right. Witness DB, we'll move on to a different topic, then.

18 Let me ask you: Who is the Drina Corps chief of communications and

19 electronic security? Who was he in 1995?

20 A. We had a position and term in the corps that was called chief of

21 communications and not commander for security and communications, if we

22 are referring to the same position.

23 Q. We are. And who was that individual?

24 A. Lieutenant Colonel Nedo Blagojevic.

25 MR. HARMON: And Your Honours, again, referring to 1D, Lieutenant

Page 7126

1 Colonel Nedo Blagojevic appears at this location in the section dealing

2 with the corps staff.

3 Q. Now, I want to focus your attention, Witness DB, on the role of

4 mister -- or Lieutenant Colonel Nedo Blagojevic. Can you describe to the

5 Trial Chamber his role, his duties and responsibilities, and his

6 relationship with the higher officers within the Drina Corps command?

7 A. You have asked me a very wide-ranging question, so could you

8 please cut it up into parts?

9 Q. I'd be glad to. Can you tell me about the role of Lieutenant

10 Colonel Nedo Blagojevic in the Drina Corps command structure? What was

11 his role? What did he do?

12 A. He was chief of communications of the Corps.

13 Q. What did being chief of communications of the corps entail? What

14 were his job responsibilities?

15 A. The chief of communications is a member of the staff of the corps,

16 and in a sense, he's a professional advisory body for the area of

17 communications. According to the chain of command, he's subordinate to

18 the Chief of Staff, and his duties are wide ranging and prescribed by the

19 rules, and they mainly entail organising, establishing, and functioning

20 and protection of all communications in the area of responsibility of the

21 corps.

22 Q. So Lieutenant Colonel Blagojevic was a subordinate to General

23 Krstic who, prior to the 13th of July, was the Chief of Staff of the Drina

24 Corps; is that correct?

25 A. In the military sense, yes, that is correct.

Page 7127

1 Q. And as an advisor to General Krstic, he would inform him, advise

2 him of important aspects that related to communications?

3 A. That is what it should be. Now, whether he informed him and

4 briefed him on these things, I don't know, because I wasn't present at

5 those meetings.

6 Q. I understand. But that's the way it should have worked in the

7 system of the army of which you were a member?

8 A. Yes.

9 MR. HARMON: Now, if I could go back into private session very

10 briefly for one or two questions.

11 JUDGE RIAD: Private session, if you please.

12 Mr. Harmon, I have a name here. I have a name called Vidoje

13 Blagojevic, Vidoje Blagojevic. It's another person?

14 MR. HARMON: Yes, it is. Vidoje Blagojevic was the commander of

15 the Bratunac Brigade, so there are two Blagojevics on this exhibit.

16 JUDGE RIAD: Yes.

17 THE REGISTRAR: We're in private session.

18 [Private session]

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 7128

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 [Open session]

19 MR. HARMON:

20 Q. Witness DB, I want to ask you about the creation of a

21 communications plan for a military operation. You have been in the VRS

22 and were in the VRS, and participated in a number of military operations.

23 Can you tell the Judges of this Trial Chamber how a communications plan is

24 created, why it is created, and how it is ultimately distributed for

25 implementation. If you would walk us through the steps of the procedure,

Page 7129

1 I would be very appreciative.

2 Let us start, for ease of your reference, let us start with the

3 commander of the Drina Corps and his idea. He has an idea. He wants to

4 perhaps commence an operation against a specific target, and he wants a

5 communications plan. Would you walk us through how that communications

6 plan is developed, reviewed, ratified, and then implemented.

7 A. When the Corps Commander is given an assignment by his superior --

8 I'm now speaking in purely theoretical terms -- he first studies the

9 assignment given to him himself. Then he convenes his closest associates,

10 members of his staff, and together with them, he reviews the assignment

11 and develops the basic concept for the implementation of that assignment.

12 After that, the whole staff gets together or all the professionals

13 who can contribute to the creation of the plan and the implementation of

14 the assignment, and they are all informed of this basic concept. A plan

15 of work for the command is created, and then all those professionals are

16 duty-bound within a certain time period to prepare proposals for the

17 commander for the implementation of that assignment, of course, each one

18 of them within their own areas of competence and their own jurisdiction

19 and in line with their duties and responsibilities. To be more specific,

20 the chief of communications, because that was the focus of your question.

21 He is now aware of the concept and the idea of the commander. He

22 knows what the technical and personnel capabilities are of the

23 Communications Battalion as a unit that can implement that assignment in

24 the communications area. And the chief of communications, on the basis of

25 that information, prepares a draft proposal for the organisation of

Page 7130

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Page 7131

1 communications.

2 Once all the professionals and assistant commanders and the

3 assistant of the Chief of Staff have drafted their proposals for a

4 decision to be made, then they all meet again and, according to their plan

5 of work, they present their proposals, either to the Chief of Staff or to

6 the commander directly. On the basis of all the proposals that serve as a

7 basis for the decision-making, the Chief of Staff drafts the proposal of

8 the decision itself, and it can have several versions, and he presents it

9 to the Corps Commander. The Corps Commander approves one of the drafts.

10 He may add something or delete something, according to his own judgement,

11 and then he announces the decision. The decision is then drafted in

12 written form and it becomes law as such in its written form.

13 Once the decision has been announced, all the assistant commanders

14 and assistants to the Chief of Staff within their areas of responsibility

15 prepare the executive documents of the operations plan. The chief of

16 communications drafts the communications plan, which consists of several

17 documents. That communications plan is approved by the Chief of Staff or

18 the Corps Commander and then that plan is forwarded to the Communications

19 Battalion and to subordinate units and their communications units.

20 I have told you now in brief the theory and one of the methods of

21 work of the command, as we were taught in schools and which it is

22 desirable to implement in practice whenever there is time and whenever the

23 situation allows it. I wish to underline that our wartime practice in

24 many ways deviated from these rules precisely because of the lack of time,

25 the impossibility of gathering in one place at the same time all the

Page 7132

1 assistants and other professionals from the various different segments,

2 because our units were drawn out along the front lines and within the

3 rear, carrying out various assignments. And I also wish to note that this

4 was the year 1995, when the command and officer cadres already had a great

5 deal of experience, and only a few input information was required by all

6 the assistants for them to be able to act more speedily than the theory

7 envisages the procedure to take and which I have tried to describe to you.

8 Q. From your description of the theory of how a communications plan

9 is created, as I understood it, it appears that the -- after the commander

10 has his original idea, the advisors or the assistants to the command,

11 including the chief of communications, go their separate ways. They draft

12 proposals and they present their proposals initially to either the Chief

13 of Staff or to the commander directly. Is that correct?

14 A. Probably the term means to propose, yes.

15 Q. Okay. And then the Chief of Staff reviews the proposals and

16 prepares a proposal that he himself presents to the commander, with

17 various options, with variations that the commander himself can select; is

18 that correct?

19 A. Yes. That is the theory of it.

20 Q. And then the commander makes a choice and the assistants are

21 informed of that choice, and they finalise a plan of communications in

22 this case that they again present to the Chief of Staff or to the

23 commander for approval; is that correct?

24 A. Yes.

25 Q. All right. I understand. Thank you. Now, at the time -- before

Page 7133

1 the Srebrenica operation was launched on the 6th of July, 1995, the Chief

2 of Staff was General Krstic and the commander of the Drina Corps was

3 General Zivanovic; am I correct?

4 A. Yes.

5 Q. Now, let me --

6 MR. HARMON: If the witness could be shown Prosecutor's Exhibit

7 428.

8 Q. And Witness DB, 428 is the order to activate combat activities in

9 Srebrenica. Have you seen this document prior to coming to court to

10 testify?

11 MR. HARMON: You can put that on the ELMO, please.

12 A. I have seen the document. It was with Mr. Petrusic. But as far

13 as any details and more profound analysis goes, I did not undertake that.

14 Q. That's quite all right. Now, this document, as you can see,

15 Witness DB, identifies where this particular order is being sent, does it

16 not? In the top part of this document it identifies "To the commands

17 of". Do you see that?

18 A. Yes. Yes, I do.

19 Q. And this plan to attack Srebrenica involved multiple subordinate

20 units of the Drina Corps; correct?

21 A. Yes.

22 Q. Now, if you would turn to -- on this exhibit I believe it's on

23 page 3 in the B/C/S. Toward the bottom paragraph, there is identified a

24 reserve force of the size of two or three companies of the MUP and one

25 company from the 1st Vlasenica Light Infantry Brigade. Do you see that?

Page 7134

1 A. Yes.

2 Q. So this reserve force of the Ministry of the Interior and the 1st

3 Vlasenica Light Infantry Brigade, those were elements that were to be

4 included in the attack on Srebrenica, although as reserve units?

5 A. That's what it says.

6 Q. All right. Now, let me ask you, Witness DB: Was a communications

7 plan created for operation Krivaja 95?

8 A. A communications plan for this particular operation I do not think

9 was drafted with all the documents that that implied.

10 Q. What is -- when you say with all of the documents that that

11 implied, would you tell us what all of the documents that a communications

12 plan implied means? What do you mean by that?

13 A. The chief of communications in those documents, that is to say,

14 that responsibility, he would have to write out an order for

15 communications, as it is called. Furthermore, he would have to write an

16 order for marching and for the actual establishment of the communications

17 centre. Additional documents would be required for all the radio networks

18 and radio relay directions that we had.

19 Q. Are any other documents included in a communications plan besides

20 the three documents that you've described?

21 A. There was a schematic for radio communication and things of that

22 kind, a review of the code names, a review of the numbers for identifying

23 the commanding officers, a schematic for the courier links, as well as the

24 crypto-protection documents and other similar documents.

25 Q. If a communications plan for Krivaja 95 was created, would that

Page 7135

1 plan have been reviewed by General Krstic?

2 A. Theoretically, that would be what would happen.

3 Q. Okay. Now, you have described in brief what is normally included

4 in a full, robust communications plan. Was an abbreviated communications

5 plan created for Operation Krivaja 95?

6 A. I think it was, yes, because otherwise communications could not

7 have been set up.

8 Q. Did you have an opportunity to review that abbreviated plan for

9 Krivaja 95?

10 A. Well, I probably received -- I don't actually remember. I

11 probably received a plan for the radio communications. As for the other

12 details, I really do not recall.

13 Q. Now, I made some notes while you were testifying, and you

14 mentioned something about a review of code names would be included in a

15 communications plan. Does that mean that the various units that were to

16 participate in the attack on Srebrenica under Operation Krivaja 95 were

17 given code names so they could communicate with each other during the

18 operation itself?

19 A. Yes. In the radio network of command, everybody had certain code

20 names.

21 Q. So all of the tactical units that were going to participate in the

22 attack on Srebrenica as well as the reserve units that I've identified in

23 the -- or that are identified in the Krivaja 95 plan were given code

24 names, correct?

25 A. If a plan had been drawn up, in keeping with this order in which,

Page 7136

1 among other things, the reserve units are stated, then most probably in a

2 plan of that kind, the code names should have been included for all the

3 units and reserve units.

4 I do not remember whether that plan was actually drafted, and as I

5 told you a moment ago, on the basis of our experience and the practical

6 knowledge we gained, many of the things were done based precisely on

7 experience and as an ongoing process as we progressed.

8 Q. Now, Witness DB, the units that were to participate in the attack

9 on Srebrenica would have been informed of their code names prior to the

10 operation itself being launched; is that correct?

11 A. Before the operation itself began, I'm quite certain that they

12 would have to have had a document, and that would have been the plan for

13 radio communication.

14 MR. HARMON: Now, if we could turn to the next exhibit, it is

15 Prosecutor's Exhibit 776, if that could be shown to the witness, please.

16 Madam Registrar, do you have exhibits to distribute to the Judges

17 and Defence? The Defence apparently does not have a copy of Prosecutor's

18 Exhibit 776.

19 Could we have just a moment, Your Honours? I had assumed that

20 these were available for Your Honours' viewing as well.

21 JUDGE RIAD: Witness DB, do you hear me?

22 A. Yes.

23 JUDGE RIAD: Witness DB, I just want more clarification. When you

24 said that you don't recall that a plan was actually drafted and many of

25 the things were done based on experience and on ongoing process as the

Page 7137

1 progressed, you mean the experience of whom, of the soldiers or of the

2 commanders? There was still orders given and plans made, or what? Or

3 everybody did what he felt -- what his experience told him?

4 A. Commanding did exist, and I said that it was necessary to have

5 some input information, basic input information. I don't know whether you

6 followed me there. So some necessary pieces of information as input, and

7 then everybody was able to do his job on the basis of that.

8 And for example, for me, it was always enough to know where the

9 forward command post would be and which units would take part, so those

10 are just two pieces of information; and third, when the communications had

11 been established, needed to be established. I didn't have to be told

12 anything more than that.

13 So that's what I had in mind. This type of command did exist.

14 The commanding officers did their work and the other officers, but the

15 steps necessary were reduced to a minimum.

16 MR. HARMON: Your Honours, this document is a document that was

17 seized pursuant to a lawful search warrant issued by the Trial Chamber,

18 and it was seized at the Bratunac Brigade headquarters.

19 Now, if we could have the English version on the ELMO.

20 MR. HARMON:

21 Q. Witness DB, you can see in the upper right-hand corner of that

22 document it says "strictly confidential," and it says "Krivaja 95." Do

23 you see that in front of you?

24 A. Yes.

25 Q. And it says, "This is a work schedule for radio network No. 122."

Page 7138

1 Now, does this appear to be part of the communications plan that was

2 distributed to, in this case, the Bratunac Brigade prior to the

3 commencement of the Srebrenica operation?

4 A. Yes.

5 Q. Now, we're going to review this document together. On the top of

6 the large box that is divided there are a series of words, the first being

7 "user," and I take it, Witness DB, that "user" refers to the user of the

8 communications within the work plan; is that correct?

9 A. Yes.

10 Q. The next column is the code name, and is this the code name that

11 was given to the various users identified in the previous column?

12 A. Yes.

13 Q. So if we go in the user column, for example, to the third box

14 down, we see the 1st Bratunac Light Infantry Brigade was given the code

15 name of Ruma, R-u-m-a; is that correct?

16 A. Yes.

17 Q. Now, if we go down further, we see that the Ministry of the

18 Interior, one of the reserve units of this operation, was given the code

19 name Oblak; is that correct?

20 A. Yes.

21 Q. And then all of the participating units have been identified.

22 Now, there appears to be at the bottom something called a reserve user,

23 and that appears twice, and there are two code names next to reserve

24 user. Can you explain to the Trial Chamber the meaning of reserve user,

25 and why reserve user was given code names?

Page 7139

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13 English transcripts.

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25

Page 7140

1 A. I would like to correct you, Mr. Prosecutor, on one point. You

2 said here that the planned participants who did take part, as far as I

3 recall, that it says the users who took part in the operation. These are

4 users who have been planned for the operation pursuant to the order which

5 is here, which means that the chief of communications, as in the order I

6 don't think it says anything about the organisation of communications with

7 respect to this operation, then probably the chief of communications just

8 read through the order and saw who the possible participants were and then

9 drew up a plan of this kind. So these are the possible users, those who

10 have been planned, but not the ones who might actually have taken part.

11 And now let me explain what "reserve user" means, which is what

12 you asked me. Whenever a plan of work, a work schedule for radio networks

13 is compiled, always, not just for one particular operation, but always,

14 two to four or five reserve users are provided for, and they are reserve

15 names. That is to say, if one of the units -- if a unit were to be

16 included into the combat operations and not provided for by the plan, or

17 subsequently, and the other users in that network can identify the unit,

18 that the unit is in fact engaged in the same assignment, so our rules

19 always provide for the fact that we have some reserve users, and this

20 document is an example. And there are always two to five reserve users.

21 Q. So this is a contingency plan. In the event additional units are

22 needed in the operation, they have a code name and they can be inserted

23 into the plan itself?

24 A. They need not be units should the need arise. It can be different

25 types of users, for example, a radio relay interim station or one that

Page 7141

1 also takes part as a mediator in providing communications. So that is

2 usually provided for so that the plan is made more effective and

3 efficient.

4 Q. But the term "reserve user" can be a unit of soldiers, a group of

5 soldiers; correct?

6 A. Yes, and it can also refer to a series of other subjects or

7 participants in this particular assignment.

8 Q. I understand, Witness DB. Thank you. Now, you earlier said that

9 all of these units that have been identified were given their code names

10 prior to the operation itself commencing. I take it, Witness DB, that the

11 Chief of Staff of the Drina Corps was fully aware that Ministry of the

12 Interior units were going to participate in Operation Krivaja 95 as a

13 reserve component; is that correct?

14 A. You said that you assume that.

15 Q. I assume that General Krstic, who was the Chief of Staff and who

16 in theory would have reviewed the communications plan, was aware that the

17 Ministry of the Interior forces that are identified in this exhibit were

18 going to participate in the attack on Srebrenica.

19 A. Let me clarify matters with respect to your question. Whenever an

20 operation was planned for a certain area, whether it be combat operations,

21 a battle, or anything else, and I'm talking about tactical levels, whether

22 companies or battalions or brigades take part in that particular

23 operation, and whether the assignment is an attack, or whether it is to

24 search the terrain, or whether it is defence of the terrain, or whether it

25 is reconnaissance or any other type of activity, every commander gave

Page 7142

1 thought to the units he could deploy from the area, so that MUP was

2 something that was always reckoned with as the idea was collaborated. And

3 in practice, because of their responsibilities, that is to say, their

4 duties in town with respect to safety for persons and property and traffic

5 regulation and everything else that MUP was engaged in, we never actually

6 counted on the possibility of having them be reinforcements in any given

7 operation. And on the basis of the whole of my experience during the war,

8 I recall MUP units taking part only on two occasions. That is to say that

9 they were together with the other units in an operation on a footing of

10 equality, as equal participants.

11 Q. Witness DB, you have seen Krivaja 95, and the MUP is identified,

12 along with the 1st Vlasenica Light Infantry Brigade, as a reserve unit.

13 In Prosecutor's Exhibit 776 they are identified and given a code name. My

14 question to you, Witness DB, was: Was General Krstic, in your opinion,

15 aware of the participation and role of the MUP in Krivaja 95?

16 A. I think he was not. May I explain that? May I explain why that

17 is my opinion? Because I have reviewed this plan. All these other things

18 do not belong to communications that you have given me. These code names

19 and this table are prepared by operations bodies, and they are special

20 encryption documents that have to do with coded maps and the transmission

21 of information by encrypted signs. I spoke about all this before you gave

22 me this document. And anyway, Mr. Petrusic did not show it to me. All we

23 had was this as communications.

24 But let me answer your question. I know for a fact that we at the

25 forward command post at the village of Pribicevac and in the villages of

Page 7143

1 Krivace and Godenje did not have MUP units linked to us and that General

2 Krstic could not communicate with them, regardless of where they were,

3 because they were not a component part of the operation. And I know also

4 for sure that all these other participants -- all this is based on my

5 recollection, because I didn't have a chance to look at this document, but

6 I know for a fact that General Krstic did not have command over MUP units

7 and that they were here only planned at the beginning if need be, as

8 potential participants.

9 Q. All right. So they were planned in the operation as it was

10 originally envisioned, MUP is identified again in the communications plan

11 that was distributed to all of the participants, and my question is: Was

12 General Krstic again aware of their participation and role in the plan

13 prior to Krivaja 95 commencing?

14 A. I don't know that really.

15 Q. All right. Now, let me turn to the next page of this document,

16 and you should -- do you have that in B/C/S in front of you? It is a

17 column starting in the upper left-hand corner with the upper box 102.

18 JUDGE RIAD: Excuse me, Mr. Harmon. I just want to ask the

19 witness about what he meant by they were meant -- the MUP was planned as a

20 potential participant. If they are a potential participant, when they

21 participate, would they be under the authority of General Krstic when they

22 participate effectively?

23 A. Your Honour, what I can say is that on the basis of the order in

24 which it is stated, among others, that MUP forces are designated as

25 reserve units, so the chief of communications made a plan accordingly.

Page 7144

1 What was in the mind of the person who made this plan and what he had in

2 mind at the time, I really don't know; I cannot know. All I know is that

3 from the forward command post there was no communication with them. They

4 were not in the network with us. No commands could be issued to them from

5 the forward command post, because I was next to the equipment and they

6 were not one of the participants in the radio network, so I don't see how

7 any commands could be issued to them from the forward command post.

8 JUDGE RIAD: Thank you very much.

9 MR. HARMON:

10 Q. Witness, we've concluded with this document. I'm not sure the

11 part that I wanted to refer to is included in this particular document.

12 So we can move on.

13 MR. HARMON: I'm finished with that, Cedric. Thank you.

14 JUDGE RIAD: Mr. Harmon, if you're starting a new line of

15 questions --

16 MR. HARMON: I am.

17 JUDGE RIAD: -- we can make a break here. As I previously

18 explained, I'm not trying to impose strict time limits, but in general, I

19 will suggest that we resume after 45 minutes, which means at 40 minutes

20 past 12.00. And then we can continue for an hour, till 1.40, and then

21 resume at 2.00 till 3.00. Of course, this is, as I said, flexible,

22 because I don't want to interrupt a coherent line of questions. We can

23 stop a little bit before or a little bit after, but without any abuse.

24 Thank you.

25 MR. HARMON: Thank you, Your Honour.

Page 7145

1 JUDGE RIAD: So we adjourn till 12.00 -- 12.40. Thank you.

2 --- Recess taken at 11.55 a.m.

3 --- On resuming at 12.44 p.m.

4 JUDGE RIAD: Please resume, Mr. Harmon.

5 MR. HARMON: Thank you, Judge Riad.

6 Q. Witness DB, the MUP Special Police are part of the Ministry of the

7 Interior, are they not?

8 A. Yes.

9 MR. HARMON: Could I have Prosecutor's Exhibit 185 and 186,

10 please, given to the witness. If they could be placed on the ELMO.

11 If we could start with Prosecutor's exhibit -- let me see which

12 number that is, Mr. Usher. That first one you have in your hand,

13 Mr. Usher, I'm not sure of the exhibit number of that.

14 THE USHER: 185.

15 MR. HARMON: 185 is placed on the ELMO.

16 Q. Witness DB, do you recognise that man?

17 A. I think I do.

18 Q. Who is he?

19 A. I think -- I cannot see the number on his sleeve, but I think it

20 could be General Ljubisa Borovcanin.

21 Q. And what unit is he a member of?

22 A. I don't know that, but I think that his name is linked to the

23 special units that you mentioned. I'm not sure of that, but I think that

24 his name is being linked to those units.

25 Q. The Court has heard testimony, Witness DB, that this man was a

Page 7146

1 member of the MUP Special Police. Do you have any reason to disagree with

2 that testimony?

3 A. No.

4 Q. Now, the Trial Chamber has heard evidence that the MUP Special

5 Police was in Potocari on the 11th. General Krstic testified to that

6 fact. My question to you is, first, when you travelled through Potocari

7 on the evening of the 11th and arrived in Bratunac, did you see members of

8 the MUP Special Police?

9 A. I don't remember.

10 Q. Are you aware, Witness DB, that the MUP Special Police was

11 organising themselves in and around the area of Zuti Most, the Yellow

12 Bridge, the bridge which you passed over?

13 A. Regarding the participation of MUP units in the operation of

14 Srebrenica, I know the following, if I may tell you what I know.

15 Q. Well, answer my question first, and then we may return to what you

16 know, but ...

17 A. Very well. I know that there were some people at the locality of

18 Zuti Most, at the checkpoint which earlier was the defensive position of

19 the 1st Bratunac Light Infantry Brigade. I'm referring to the asphalt

20 road. And I know that as I was moving from Potocari towards Bratunac via

21 Zuti Most, that I did see there some men. In my judgement, this must have

22 been around 2130 hours. It was already dark. I do not remember whether

23 they were just soldiers or only the police, or both soldiers and the

24 police together.

25 MR. HARMON: Now, if we could have, Mr. Usher, the next photograph

Page 7147

1 placed on the ELMO.

2 Q. In this photograph, Witness DB, do you see Mr. Borovcanin once

3 again standing next to the man with the United Nations helmet on his head?

4 A. I must admit that the picture on the monitor is rather hazy, and I

5 wouldn't dare to make a final judgement.

6 Q. The Trial Chamber has seen evidence of MUP Special Police

7 operating along the Bratunac-Milici road. There is film footage of this

8 that has been presented to the Trial Chamber where Mr. Borovcanin, who is

9 in the picture before you, and other members of his unit are along that

10 road.

11 You travelled that road on the night of the 11th, Witness DB. Did

12 you see members of the MUP Special Police along that road when you

13 travelled it?

14 A. I said in the -- I answered in the affirmative a question put by

15 Mr. Petrusic to me yesterday that moving from Bratunac towards Vlasenica,

16 after 2300 hours on the 11th of July, on the road

17 Bratunac-Kravica-Konjevic Polje, in several places I saw members wearing

18 blue uniforms, and those were the uniforms of the MUP at the time.

19 Now, whether when I was passing the Yellow Bridge, Zuti Most,

20 whether they were there also mixed together with soldiers or whether there

21 were only soldiers there, I don't remember.

22 MR. HARMON: Could I have Exhibit 499A, the B/C/S version 499B

23 given to the witness. And 499A placed on the ELMO, and in the English

24 version, Mr. Usher, I would like page 3 placed on the ELMO. Mr. Usher, if

25 the witness could be shown this page with the tank, in that page of the

Page 7148

1 article. If you could place page 3 of this article on the ELMO, the

2 English translation.

3 Q. Witness DB, this is an article that was written -- it is dated the

4 21st of July, 1995, in a Belgrade publication. Its author is a gentleman

5 named Zoran Petrovic. The Trial Chamber has seen a film that was taken

6 during the events in Potocari and Srebrenica throughout the days of the

7 attack and the events that took place along the Bratunac-Milici road that

8 was prepared by this very same author, Zoran Petrovic.

9 Now, I'd like to direct your attention, please, Witness, to the

10 article that is in front of you in B/C/S. And if you would please refer

11 to this section that I have highlighted and which I hope you can see from

12 where you are, and read that to yourself.

13 MR. HARMON: And Your Honours --

14 Q. Have you had a chance to read that, Witness DB?

15 A. You mean have I read it before?

16 Q. This section of the article that I have directed your attention

17 to.

18 A. I have read it.

19 Q. Now, this portion that I would like to read into the record is as

20 follows. This is on page 3:

21 "In less than three days of fighting, Mladic's forces reached the

22 suburbs of the enclave, and on the fourth day they had fully taken over

23 Srebrenica. After the main attack, RS MUP forces, commanded by Ljubisa

24 Borovcanin, struck along the Zuti List-Potocari line and were advancing

25 toward Djogazi and Milacevici from the right side."

Page 7149

1 Now, Witness, it appears from this article that the MUP, Ministry

2 of the Interior Special Police, were engaged in a capacity of combat in

3 this particular article, does it not?

4 A. Yes, according to this article. Whoever reads this article would

5 come to that conclusion.

6 Q. And the MUP special police that are referred to in this article

7 are consistent with the Ministry of the Interior forces that are described

8 in Krivaja 95 communications plan that you saw prior to adjourning for

9 lunch?

10 A. I told you that the plan is one thing and the actual

11 implementation quite another. We had an identical plan to this one for

12 the Zepa operation, and immediately after the first day the Zvornik

13 Brigade was pulled out of that operation, but its position in the plan

14 remained. I don't know how you come to the conclusion that on the basis

15 of the communications plan, where MUP was planned, that that was this very

16 unit.

17 Q. Is there anything in this plan that indicates it is not, Witness

18 DB? Anything in this communications plan that indicates that it is not?

19 A. I think that then, in this communications plan, it should have

20 said "the special MUP units" if before the combat operation started it had

21 been known that that particular special unit would be participating,

22 because that was the only special MUP brigade, and then it would have been

23 included in the plan. If I may take the liberty of saying, when MUP was

24 mentioned in all our plans, the reference was to local public security

25 stations in the local communities.

Page 7150

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Page 7151

1 Q. So in Krivaja 95, which is an order to attack the Srebrenica

2 enclave and identifies a reserve force and it identifies the 1st Vlasenica

3 Light Infantry Brigade as one of those reserve forces and the MUP, those

4 forces were reserves for combat activities, weren't they, Witness DB?

5 A. When reserves are being regulated, reserves can be used for

6 several options. They can be used to blockade a certain area, to

7 establish control over a certain area, or simply for inclusion in combat

8 operations after the main forces had accomplished their task.

9 Q. We'll move to a different topic, Witness DB.

10 JUDGE RIAD: Just a second, Mr. Harmon. Before we leave the MUP

11 members, I just want a clarification, because Witness DB, you mentioned

12 that on the 11th of July, at 11.00 p.m., you saw, when you were moving

13 from Bratunac to Vlasenica, you saw MUP members in blue uniform; is that

14 right?

15 A. Yes.

16 JUDGE RIAD: And then as you passed the Yellow Bridge, the Zuti

17 Most, I think, which is, I suppose, at the same time, you don't remember

18 having seen anything. They were in blue uniform? They were

19 distinguishable from others or were they mixed up in a crowd which you

20 couldn't distinguish? You remember the first one, and this is linked with

21 it. What made the difference?

22 A. Your Honours, allow me to explain. While I was moving from

23 Pribicevac via Srebrenica and Potocari to Bratunac, about 2100 hours I

24 passed through Zuti Most. This is quite a different route. On that Zuti

25 Most, which is close to the town of Srebrenica, or Potocari, which is

Page 7152

1 between Bratunac and Potocari, I noticed on that part of the road where

2 defensive positions of the Bratunac Brigade used to be towards Srebrenica,

3 I saw men in uniform. I cannot now say with certainty whether they were

4 only soldiers, only MUP, or both, because I just drove past them. This

5 was a small group of people next to the road.

6 And when after the meeting that was held in the Bratunac Brigade

7 headquarters I headed towards Krivace -- or rather, Vlasenica, this was

8 after 2300 hours, in quite a different area, the route from Bratunac via

9 Krivace, Konjevic Polje, Kasaba Milici, towards Vlasenica, this is an

10 entirely different area along the road at several points, and that is why

11 I paid more attention because I saw several groups. I did notice members

12 of MUP. I saw them along the road, and I registered in my mind these

13 blue-coloured uniforms.

14 JUDGE RIAD: Thank you very much.

15 MR. HARMON:

16 Q. Finally, Witness DB, it's your position that in the Srebrenica

17 attack plan, the reserve forces of the MUP that are designated here were

18 traffic police; is that right?

19 A. I did not say that, as far as I recall. I didn't say it was the

20 traffic police. I have knowledge that the unit which was -- which has

21 been identified, that it was part of the Srebrenica operation, and that it

22 came one or two days prior to the military fall of Srebrenica, which means

23 that that was around the 10th of July, and that it did have some

24 assignments in the area ranging from Bratunac, that is to say, from the

25 north to the south of the enclave.

Page 7153

1 I was very interested in seeing whether it would be necessary to

2 establish communication with them because they were coming from quite a

3 different direction, and therefore I was interested in seeing where they

4 were coming from, when they arrived, and whether they would have --

5 whether we would need to establish communication with them, because for me

6 as a signalsman, this was a very vital point. I had to ensure that there

7 was -- that communication should not upset control and command.

8 I do know that with that particular MUP unit which was there on

9 the spot and which probably, based on all the material that we have and

10 that you have shown me and which I, too, became acquainted, that -- and

11 that it was commanded by General Borovcanin. We did not have any

12 communications with them. I'm thinking about the forward command post,

13 from the forward command post from which General Krstic was in command of

14 that operation. We did not have that unit on the line.

15 Q. Did you talk to the signalsman from the MUP Special Police?

16 A. No. No, because they never had within their composition the kind

17 of devices that we have, and I didn't see him at all.

18 Q. What kind of devices did they have?

19 A. I think that they mostly used devices on the UKT wave band, ultra

20 short, and to facilitate interpretation, these were known as the Motorolas

21 because of the firm that produced those devices, Motorola.

22 Q. Let's turn to a different topic. Let's turn to the forward

23 command post and the location of Pribicevac, and what I'd like to ask you

24 first off is, this was a village, wasn't it? This wasn't a swath of

25 territory cut out of a virgin forest for purposes of the forward command

Page 7154

1 post, was it?

2 A. It was a former Serbian village which in the spring of 1992 had

3 been burnt and destroyed.

4 Q. Now, when you got to Pribicevac, did you happen to see a man by

5 the name of Vukota Vukovic at that location?

6 A. Yes.

7 Q. Can you tell me what his position was?

8 A. Colonel Vukota Vukovic was on behalf of the corps command sent to

9 the Pribicevac area, Pribicevac area. I think that that was a year or so

10 before the Krivaja-5 operation, and I do believe that he had the

11 assignment of coordinating the defence positions of the Skelani Battalion

12 and the Bratunac Brigade in the area.

13 Q. And was he the commander of the Skelani Separate Battalion?

14 A. No.

15 Q. Was there a commander of the Skelani Separate Battalion by the

16 name of Vukota Vukovic?

17 A. No.

18 MR. HARMON: Okay. Now, let me first of all start with

19 Prosecutor's Exhibit 821. If the witness -- Mr. Usher, if the witness

20 could be shown the B/C/S version and the English version placed on the

21 ELMO.

22 Q. Witness, take a moment to examine this document, and let me know

23 when you have finished your review.

24 Now, the content of this document, Witness, is not important;

25 however, the captions in this document are important. In the upper

Page 7155

1 left-hand corner you will see in this document that's dated 19 April 1994

2 a reference to the Pribicevac Tactical Group 1, and at the bottom of this

3 you will see that the commander of that group was Colonel Vukota Vukovic.

4 Are you familiar with the Pribicevac Tactical Group No. 1?

5 A. Our rules and regulations, the ones that were in force with

6 respect to the grouping of forces, implied the establishment of combat

7 groups and tactical groups. Combat groups are of a smaller composition,

8 not more than the rank of battalion, and they are established for the

9 execution of a limited combat operation.

10 Tactical groups are groups of the armed forces of a battalion-type

11 composition, and they are a provisional composition having the task of

12 uniting and coordinating action of -- the action of several battalions or

13 several brigades.

14 I think that to all intents and purposes, the Pribicevac Tactical

15 Group did exist, precisely with the task of coordinating action of what --

16 the action of one to two battalions of the Bratunac Brigade, I think in

17 the area ranging from Kvarc or Pribicevac via Kvarc towards Zuti Most, and

18 the operations of the Skelani Battalion which covered the area to the left

19 and right of the river Zeleni Jadar, and that it served as a coordinator.

20 And as the commander of that tactical group at Pribicevac in the period

21 that I mentioned, that Colonel Vukota Vukovic was sent there to command,

22 from the command of the Drina Corps.

23 MR. HARMON: Now, if we could turn to the next exhibit which is

24 Prosecutor's Exhibit 822, and if this Exhibit could be placed under seal.

25 And Your Honour, if we could go into private session in respect of this.

Page 7156

1 JUDGE RIAD: Yes. Exactly, yes.

2 THE REGISTRAR: We're in private session.

3 JUDGE RIAD: Yes, let's go.

4 [Private session]

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18 [Open session]

19 THE REGISTRAR: We're in open session.

20 MR. HARMON:

21 Q. Now, after you left the Pribicevac Forward Command Post, it

22 continued to exist, didn't it?

23 A. Are we talking about the 11th of July now?

24 Q. We're talking about after you left on the 2nd of November, 1994.

25 Did the Pribicevac Forward Command Post continue to exist?

Page 7161

1 A. It was not a forward command post; it was a command post of the

2 Pribicevac Tactical Group.

3 MR. HARMON: Could we turn to the next Exhibit, please, which is

4 Prosecutor's Exhibit 824. Mr. Usher, if you could place the first page of

5 the English version on the ELMO, please.

6 Q. Now, Witness, this is a document that is dated the 4th of June,

7 1995. It is signed by the commander of the Bratunac Light Infantry

8 Brigade, Colonel Vidoje Blagojevic. And in the top part, left-hand side

9 of the document, you can see that this document was issued from the

10 Pribicevac Forward Command Post on the 4th of June, 1995, and it is an

11 order for the deployment of units in the defence of the region of the 3rd

12 Infantry Battalion. What can you tell us, Witness DB, about the

13 Pribicevac Forward Command Post of the Bratunac Light Infantry Brigade?

14 A. This is a time period -- that is to say, it's the beginning of

15 June, 1995, and according to my recollections, I said yesterday that I was

16 there at the beginning of June, when in that particular region [inaudible]

17 communication was established for Zeleni Jadar, Jasenova, and Podravanje,

18 and placed under the control of our own forces, and quite simply by

19 rounding off and encircling that part of the territory and placing it

20 under our control, and this was determined by the peace agreement for that

21 particular period. I had to be there at the time because we're dealing

22 with the beginning of June.

23 And these assignments were compiled by Colonel Blagojevic, the

24 commander of the Bratunac Brigade, and he probably at that time had

25 reached Pribicevac and himself had established his own forward command

Page 7162

1 post at Pribicevac for the implementation of the assignment issued to him

2 by the corps command.

3 It is quite possible that during that period of time when General

4 Zivanovic was at Pribicevac himself, that there were two forward command

5 posts there at the time, one forward command post of the Bratunac Brigade

6 as it says here in this document, and another forward command post, a

7 provisional forward command post of the Drina Corps for the duration of

8 that assignment.

9 Q. Witness, paragraph 4 reads as follows: "The commander of the 3rd

10 Infantry Battalion shall incorporate this company in the battalion's

11 command and control system, and with the assistance of the brigade's chief

12 of communication organise wire and radio communication with this company."

13 Now, once again there's reference to communications at this

14 location; am I correct?

15 A. Yes. Yes, you're right, communications are mentioned here.

16 Q. Now, let's turn to the last document in this series; it's

17 Prosecutor's Exhibit 823.

18 MR. HARMON: Actually, I see, Your Honours, and for my friends at

19 the Defence bench, this is out of sequence. This is a document that is

20 one month earlier than the previous document.

21 Q. Now, Witness, this also is a document that was issued by General

22 Zivanovic on the 12th of May, 1995, to the command of the 1st Bratunac

23 Light Infantry Brigade and to the Skelani Independent Infantry Battalion.

24 And if you turn to the order itself, paragraph 3 of the order -- which is

25 on page 2, Mr. Usher, of the English version -- paragraph 3 reads, "The

Page 7163

1 command of the Skelani Separate Battalion will immediately establish an

2 IKM, a forward command post, in the village of Jasenova and provide from

3 there secure telephone and packet communication links with the command of

4 the 3rd Battalion of the 1st Bratunac Light Infantry Brigade."

5 Now --

6 A. That's not what it says.

7 Q. That's what the English translation of it says. Perhaps you had

8 a --

9 A. Please. In the official document that I have, and it is a copy of

10 the original, it says that telephone and courier communication should be

11 secured, not packet communication, with the commander of the 3rd Battalion

12 of the Light Infantry Brigade and not with the 1st Bratunac Light Infantry

13 Brigade.

14 MR. HARMON: Well, we will have this submitted once again, Your

15 Honours, to the language service section that translated it in the first

16 place, and we can resolve that issue. We stand by correct and accurate

17 translations, and given that's the status of this particular document, I

18 will not ask him any additional questions on it.

19 JUDGE RIAD: All right, Mr. Harmon.

20 MR. HARMON:

21 Q. Witness DB, so when you arrived at the Pribicevac Forward Command

22 Post and you saw Colonel Vukota Vukovic, was there still a tactical group

23 at that location, or was there still a Bratunac Forward Command Post at

24 that location?

25 A. What date are we talking about now?

Page 7164

1 Q. Now we're talking about your arrival at the Pribicevac Forward

2 Command Post on the 5th of July, 1995.

3 A. As far as the Bratunac Brigade is concerned, I seem to feel that

4 for the most part at that forward command post, that is to say, in that

5 particular village where the command of one battalion of the Bratunac

6 Brigade was located, that I did see Colonel Blagojevic. I seem to

7 remember that. And on the basis of that, I am able to conclude that for

8 the Krivaja 95 operation, he established a forward command post of the 1st

9 Bratunac Light Infantry Brigade at Pribicevac in the command of his

10 battalion. He formed the forward command post of his brigade. I assume

11 that that was so because on several occasions I saw him at that command.

12 Whether in that same period Colonel Vukota Vukovic received the

13 assignment to focus his activities on the Skelani Battalion, and I seem to

14 feel that at that time because commanders were frequently replaced in that

15 independent battalion, a corresponding officer did not exist there, and

16 the possibility -- it is possible that Colonel Vukota received an oral

17 order and was designated to direct the operations of that battalion,

18 because I do know that at Pribicevac after combat activity had started, he

19 did not appear. He was constantly with the Skelani Battalion.

20 Q. Did you ever visit Colonel -- sorry, did you ever visit Colonel

21 Vukovic's command centre?

22 A. You mean Pribicevac?

23 Q. Yes.

24 A. Yes.

25 Q. Where was it located in respect of your forward command post

Page 7165

1 communication centre?

2 A. Can you repeat the question, please?

3 Q. You said you visited Colonel Vukovic's command centre at

4 Pribicevac. How far away was it from the communications centre of the

5 forward command post of the Drina Corps?

6 A. 100 metres.

7 Q. Did Colonel Vukovic have communications facilities at his

8 disposal?

9 A. He had in his office where he stayed one military inductor

10 telephone, which he could reach the command of the 1st Battalion of the

11 Bratunac Brigade which was 100 metres away from him. He could reach their

12 switchboard. That switchboard had connections to certain defence

13 positions integrated in the Pribicevac tactical group. These defence

14 positions were connected in one series so when you called one of the

15 positions, all the telephones on all positions rang, and that was done in

16 order to economise with the field telephone cable.

17 I think that was a pretty secure and reliable communication which

18 was available to Colonel Vukota within his tactical group, and I believe

19 that he must have had another alternative radio communication with at

20 least two or three key positions, in particular, I believe with the

21 Jasenova area.

22 That is my recollection of the organisation of communications for

23 as long as I was with the command of the Pribicevac tactical group.

24 Q. Did he have the ability to communicate with the Bratunac

25 headquarters, the Bratunac command in Bratunac, from his location?

Page 7166

1 A. I think not.

2 Q. Did he have the ability by his radio system to communicate to the

3 Drina Corps headquarters?

4 A. Not through radio communication. He could reach them through

5 radio relay communication.

6 Q. Now, you left the forward command post of the Drina Corps on the

7 11th of July in your communications van, and you went to Bratunac. At the

8 time you left, was Colonel Vukovic's position, his command post that you

9 have just testified about, still in existence when you left?

10 A. After these combat operations had developed, together with the

11 entire situation on that part of the front line from the 5th to the 11th,

12 as the army moved on, it was followed by logistics and communications.

13 Colonel Vukota, in view of the fact that he did not come to

14 Pribicevac but instead spent all his time with the Skelani Battalion, and

15 I personally am aware that after the Srebrenica operation was completed,

16 with that unit or a part of those units he took part in the attack -- or

17 rather, demonstrative actions towards Zepa from north to the south. I

18 therefore don't think that he returned to Pribicevac.

19 Q. Let me rephrase the question, Witness DB. When you left

20 Pribicevac, was Colonel Vukovic's command centre still there on the 11th

21 of July?

22 A. I left on the 11th of July. And speaking in military terms, in

23 view of the development of the situation, I believe that this command

24 centre had no reason to exist whatsoever because Colonel Vukota was far

25 away from it. All the communications were withdrawn by Colonel Blagojevic

Page 7167

1 from that centre towards the area of his attack, so I believe that this

2 communication centre, Colonel Vukota at Pribicevac, ceased to exist on the

3 11th, that is, on the afternoon of the 11th.

4 Q. Do you know that for a fact?

5 A. I am speaking according to my information and based on what I know

6 about the development of the military situation because all the units had

7 gone forward, and that communication served nobody at that location any

8 more.

9 Q. So your testimony is not based on your personal observations; is

10 that correct? Did you see the command centre of Colonel Vukovic leave

11 before you left on the night of the 11th? That's the point I'm trying to

12 get to. It was 100 metres away from you.

13 A. Yes. At this command post there was Colonel Blagojevic with his

14 forward command post, and I personally saw Colonel Blagojevic with his

15 signalsman moving and following his army on the directions of attack of

16 his units. And based on that, I conclude that as soon as the army left

17 and Colonel Blagojevic left with his signalsman, there was no longer any

18 need for communications from Pribicevac and no need for it.

19 Q. Let's turn to a different subject, Witness DB.

20 JUDGE RIAD: Would that be a right time now for a break?

21 MR. HARMON: It would be fine, Judge Riad.

22 JUDGE RIAD: Thank you. We will break until 2.00.

23 --- Recess taken at 1.45 p.m.

24 --- On resuming at 2.04 p.m.

25 JUDGE RIAD: Yes, Mr. Harmon. Proceed, please.

Page 7168

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Page 7169

1 MR. HARMON: If the witness could be given the next exhibit, which

2 is Prosecutor's Exhibit 784.

3 Q. Witness, before we turn our attention to this particular exhibit,

4 as I understand, the communications centre of the forward command post

5 that you set up at Pribicevac, it was essentially a mobile communications

6 centre with the communications equipment located in a van or a truck. Do

7 I understand that correctly?

8 A. The communications centre at the forward command post of the Drina

9 Corps was mobile and was on a truck, that is, on a vehicle, and from that

10 vehicle, using a cable, we could install a telephone at a smaller or

11 greater distance, and radio transmitters could be moved around within a

12 15-kilometre circle, and we would usually take them out, because those who

13 commanded normally didn't get into a vehicle to issue commands from a

14 vehicle except on rare occasions, when they wanted to use secure

15 communications.

16 Q. And with your communication, you could communicate with the Main

17 Staff, with the command of the Drina Corps, and with the combat units

18 participating in the operation of Krivaja 95; am I correct?

19 A. Yes, you're right, with the proviso that we were able, also

20 through the communications centre of the Drina Corps, to communicate with

21 all the other participants, that is, the entire outside world.

22 Q. So you could communicate through the Drina Corps command in

23 Vlasenica with the commands of the various brigades within the area of

24 responsibility of the Drina Corps?

25 A. Yes, with their headquarters.

Page 7170

1 Q. I have put before you, Witness DB, an exhibit which is the

2 communications system for the Socialist Federal Republic of Yugoslavia,

3 the old JNA communications manual. Are you familiar with this document?

4 A. Yes.

5 Q. I don't want to spend a lot of time on this document, Witness, but

6 focusing on your mobile communications centre, you said that you had radio

7 devices. And if you would turn to the section of this plan that deals

8 with the means of communication. In the B/C/S version, Witness, you will

9 see a chart that looks like this. Can you see what I'm holding in my

10 hand, Witness?

11 A. Can you tell me which page would that be?

12 Q. I can't tell you, because ... Do you see the chart that deals with

13 the technical details of the radio devices that were available to the JNA?

14 Well, Witness, if it's not in there, then we will -- I'll ask you some

15 questions about the English version of this, which is found on page 9 of

16 the ELMO. I apologise, Witness, if it's not there. Let me proceed,

17 because I don't want to take too much time on this issue.

18 On the ELMO, Witness, there appears a figure that was taken from

19 this manual. It is figure 63 and it is the technical details of some

20 radio devices. Can you tell me: In your mobile communications centre

21 that you established in Pribicevac, what were the names of the radio

22 devices that you had available to you?

23 A. The one in line 4, where it says RUP-12.

24 Q. And below that there are three additional devices. Did you have

25 any of those devices?

Page 7171

1 A. No.

2 JUDGE RIAD: Mr. Visnjic, do you have anything to ...

3 MR. VISNJIC: [Interpretation] No. I would like to remind the

4 witness that it is on pages 336 and -- 396 and 397 in the B/C/S version.

5 MR. HARMON: I thank my colleague for his assistance in this.

6 Q. Do you have that before you, Witness?

7 A. Yes.

8 Q. Beside the RUP-12 at the forward command post, did you have any

9 other radio device that was available to you?

10 A. I would like to clarify one technical matter. We had a device

11 called RU-2/2K. It is basically the same as the one in line 4 which I had

12 indicated earlier. It operates in the same frequency range, it has the

13 same number of channels, and two of them can work together, can

14 communicate between them, the only difference being that this device,

15 which is not in this table, can have built into it another device for the

16 protection of speech, for scrambling, and we used that type of device in

17 the command network for communicating to -- commands to orders to

18 subordinated units.

19 Q. So Witness, am I right the RUP-12 and the RU-2/2K is a tactical

20 communications device that has a rather short range of between 8 and 12

21 kilometres?

22 A. Yes. It says in the rules 8 to 12 kilometres; however, deviations

23 are possible here as well. If you read the manual for this device, you

24 will see that the range can be increased with lower frequency -- can be

25 increased with higher frequencies and vice versa, unless there are

Page 7172

1 obstacles on the terrain such as hills, then the range can be greater; and

2 if there are more natural barriers or obstacles, then it can be lower than

3 eight kilometres.

4 And then also when a scrambling device is incorporated into it,

5 then this technical feature makes the device 20 per cent less effective,

6 and its range is decreased accordingly.

7 Q. In addition to radios, did you have a radio telephone device in

8 the mobile communications centre?

9 A. No.

10 Q. What other communications devices did you have in your mobile

11 communications centre besides the two radios that you have described? Can

12 you just give me a list?

13 A. We had telephone devices, that is to say, telephones, field

14 telephones, induction-type telephones of the military kind. We had field

15 telephone switchboards with ten numbers. Furthermore, we had coded

16 teletype machine devices, teletypewriters: the T100, a mechanical type, or

17 the teletype ETL1, an electronic one. We had devices for the protection

18 of written information which is called KZU31, and devices for the

19 protection of oral information, the KZU61 device and KZU63. And with the

20 relay devices, we had a radio relay device which was referred to as RRU1.

21 Q. Now, with the RUP-12, could you communicate outside of the

22 immediate area of the combat theatre? Could you communicate to the

23 headquarters of the Drina Corps?

24 A. No.

25 Q. What was the device that you used to communicate with the Drina

Page 7173

1 Corps command from Pribicevac and from the forward command posts that were

2 in Zepa?

3 A. RRU1.

4 Q. And is the RRU1 a radio, or does the communication that emanates

5 from a RRU1 between the forward command post and the Drina Corps command

6 consist of a radio beam?

7 A. Yes, the frequency range is between 2 and 300 megahertz. I don't

8 know the exact figure, but basically they are beamed radio waves. They

9 are beamed. They are radio waves that are beamed. And we had this type

10 of communication with the help of a stationary junction, Veliki Zep, and

11 it is from that area, both from Srebrenica and from Zepa, that radio relay

12 line was not a direct one, but it was beamed via the radio relay junction

13 at Veliki Zep which is close to Han Pijesak.

14 Q. So the signal would go from you to Veliki Zep, be relayed from

15 Veliki Zep to the command at Vlasenica, correct?

16 A. Yes, that's right.

17 Q. Now, you also had a teleprinter. You described the names of those

18 teleprinters -- actually, before I -- let me withdraw that question, and

19 let me show the witness one additional exhibit before I get to

20 teleprinters. It's Prosecutor's Exhibit 826, and if I could have the

21 witness examine this communications device.

22 Witness DB, in this Prosecutor's exhibit there is a man with a

23 black uniform, and he has a radio communication device on his back. Can

24 you identify that radio device?

25 A. Although I can't see the other side well enough where we attached

Page 7174

1 the device to the protection device, but according to what I can see and

2 the black part, it could be the RU-2/2K device. But at all events, if the

3 device has not been attached, which I can't see on the other side, it is

4 one of the two devices that we talked about a moment ago.

5 Q. All right. Thank you very much.

6 Now, let's turn to teleprinters. Can you tell us very, very

7 briefly about a teleprinter and how it communicates from point A, the

8 forward command post, to the command at the Drina Corps headquarters in

9 Vlasenica?

10 A. The answer in the technical sense would be a little more complex.

11 I'll try and make it as clear as possible, but please bear with me. In

12 order to have teleprinter communication from the forward command posts, we

13 had that with the use of just one channel which we established with the

14 radio relay device, the RRU1 device. That means that while the

15 teleprinter was working, and either receiving or sending out messages,

16 during that period of time you can't talk to anybody else.

17 The teleprinter is a device which has as its -- which has a print

18 board, and its purpose is to type out certain information or a message,

19 and that information uses a paper tape or sheet of paper coded for each

20 letter. It is 17 and a half millimetres wide, so it is still an open

21 text. Later on, that tape is introduced into a device for the coding of

22 that written information, encryption, and a communication is established

23 with the participant to whom we wish to send out that information, a

24 button is pressed, the start button is depressed, and the tape then passes

25 through and is locked or coded at the same time and goes to the other

Page 7175

1 side.

2 The other side, the other party, takes up the tape, introduces it

3 into the device which has the same lock to unlock it or decode it or

4 decipher it, and then we get the printed text. It is the key which

5 unlocks this, and this is done on a page of 10 millimetres.

6 Q. Now, did you have one teleprinter in your van, or did you have

7 more than one?

8 THE INTERPRETER: Microphone please.

9 MR. HARMON:

10 Q. Did you have one teleprinter device in your mobile communications

11 van when you were in Pribicevac and Zepa, or did you have more than one?

12 A. Well, based on logic, we probably had at least two teleprinters,

13 because if one were out of order, we were able to send out messages with

14 the other. So that was logical. That was the logical back-up system that

15 we had when we were on assignments of this kind.

16 Q. While you were at Pribicevac and Zepa, did you have breakdowns

17 with those teleprinters?

18 A. Those teleprinters function exclusively on 220 volts, whereas the

19 other devices can function using 12 volts, a 12-volt system. So there

20 were breakdowns from time to time, but they were not as frequent and not

21 as important to upset control and command, because I know that I was not

22 criticised for my communications system, although breakdowns could occur

23 from time to time, either on our side or at the stationary junction or at

24 the ultimate destination, the communications centre of the Drina Corps.

25 So the number of -- the human factor is multiplied by three there, because

Page 7176

1 if you have this triple link, there are two ends and one intermediary

2 point, and therefore it is possible that there are reasons for a breakdown

3 of a technical nature or human error. But as I say, I don't think that

4 there were any major upsets in the system of communications, and I want to

5 repeat that here.

6 Q. Let me read to you a portion of General Krstic's testimony that

7 was taken on the 31st of October, and I'm referring to page 6673 of the

8 transcript, lines 5 through 19 of the English version. This was a

9 question asked by my colleague, Mr. McCloskey:

10 "Q. While you were in the forward command post, did you have

11 the capability of receiving orders like this in a secure

12 manner?"

13 And this was a teletype document.

14 "A. Yes, I did.

15 Q. How did that work?

16 A. I can't describe to you how it worked. There is a

17 communications centre with officers and soldiers of the

18 communications department, work led by their commander, the

19 communications commander, battalion -- I'm sorry --

20 battalion.

21 Q. Is it fair to say that the VRS at that time had the

22 capability of teletyping an order like this, that is, typing

23 in the information and sending it via teletype in encrypted

24 teletype?

25 A. Yes, it did, but there were some problems, and the teletype

Page 7177

1 very often didn't work, and there was no electricity for the

2 signals and communications to function properly. There was

3 a breakdown in the system very often."

4 Apparently General Krstic, from his point of view, has a slightly

5 different viewpoint of the workings of the teletypes. Do you care to

6 comment on this testimony provided by General Krstic?

7 A. I remember that very often my superior commanders and their

8 assistants were warned by me. I warned them, cautioned them, and asked

9 that longer reports with a number of pages of -- typed pages, if possible,

10 to send them by courier link, because if you want to hand over just two

11 pages of a typed-out text, then via the teleprinter and via the radio

12 relay waves, this takes five minutes. There are orders, certain orders,

13 which are longer than two typed-out pages, and then there is the

14 possibility that just one interference signal, which lasts for just one

15 second, breaks down the whole system of reception, and then you have to

16 ask the telegramme repeated in its entirety. Or the opposite side, quite

17 simply, as this message is long-winded and takes a long time, succeeds in

18 decoding it, and that is why teleprinters are exclusively intended for the

19 transmission of important, urgent, and short messages. And I'm speaking

20 on the basis of my recollections, and I have no reason at this point in

21 time to say how good my work was at that time, but as far as I remember,

22 those interruptions were not very frequent for them to be -- to upset the

23 control and command system in its global sense.

24 Q. Let's talk about couriers for a minute. At both the Pribicevac

25 Forward Command Post and the forward command post that you used in Zepa,

Page 7178

1 did you use couriers to communicate with the Bratunac Brigade

2 headquarters -- I'm sorry -- the Drina Corps headquarters?

3 A. During the time I spent at the forward command post of Pribicevac,

4 in view of the fact that it is at quite a distance from the command of the

5 Bratunac Brigade itself and a good deal greater from the command of the

6 Drina Corps, a good deal further off from the Drina Corps, it would not be

7 a rational link to use a courier, and I'm quite sure that as far as the

8 communication centre, we did not organise it, and I can only assume that

9 nobody else in the capacity of a courier from the forward command post at

10 Pribicevac did not carry any written messages, or oral ones, for that

11 matter.

12 By moving to the forward command post at Krivace, as that was very

13 close to the command of the Main Staff of the army of Republika

14 Srpska -- I don't know exactly how close, but it was four, five, or six

15 kilometres, thereabouts, and some 30-odd kilometres from the command of

16 the Drina Corps -- I, as a communications man, did not plan to have any

17 courier communication, but it is quite possible that certain messages in

18 written form, via some other individuals, drivers, for example, from the

19 staff command, or by some transport coming back from the logistics base,

20 might have carried information of this kind. But we adhered to the rule

21 that the safest communication was a courier communication, in fact, and

22 that couriers should be used whenever possible, whenever it was indicated.

23 Q. I'm sorry. I'm a little confused by your answer. Did you or did

24 you not use courier communication from the Pribicevac Forward Command Post

25 and the Zepa Forward Command Post?

Page 7179

1 A. Let me explain this. In order to plan and organise a courier

2 link, courier links are planned by the chief of communications, and I know

3 that as a signalsman, we did not have a permanent courier link, courier

4 communication. But in wartime, when you had to fend for yourself and do

5 what you could, there was a possibility that certain written messages

6 could be transmitted by other means, by people who actually took on the

7 role of courier and acted as couriers.

8 Q. Now, when courier messages were received at the forward command

9 post, were they logged, were they entered, or were the courier packages

10 given directly to the person who was the intended recipient of those

11 courier parcels?

12 A. According to the rules and regulations, and we had an organised

13 system of courier communications of the Drina Corps for certain messages

14 which were not urgent and important, couriers bringing the message or

15 messages would go to the dispatch unit and the dispatcher would sign for

16 the reception of certain messages, sign that he had received them. So

17 according to the rules, every message or document going by courier must

18 have -- must be registered in the dispatch centre.

19 MR. HARMON: We're going to change our subject again, and if I

20 could have the witness provided with Exhibit 750.

21 Q. Witness, the B/C/S version portion that I would like you to take a

22 look at is found on page 37 of the document. And this is a document that

23 is an analysis of the combat readiness and the activities of the army of

24 the Republika Srpska in 1992. This was prepared by the army of the

25 Republika Srpska, and the date on this is April of 1993.

Page 7180

1 Now, the section that I'd like to refer you to is the section that

2 deals with electronic reconnaissance and counter-electronic operations

3 units. And in this analysis of the activities of the army, this section

4 deals with the analysis of that particular activity.

5 Now, first of all, Witness, before you read much of this, let me

6 ask you: Did the electronic reconnaissance operations, the intercepting

7 groups that were in the VRS, fall under the purview of the intelligence

8 department?

9 A. Yes. We had, for example, a unit that ranked with the radio

10 reconnaissance platoon, which in the professional sense was subordinated

11 to the intelligence department, just as the Communications Battalion in

12 the professional sense was subordinated to the communications chief, chief

13 of communications.

14 Q. Now, I'm going to read to you the -- actually, Witness, this might

15 be of better assistance to you. If you take my copy, I've highlighted the

16 portions that I'm going to read.

17 MR. HARMON: And we are on page 41, I'm sorry, Mr. Usher, of the

18 English version.

19 Q. Now, I'm referring to the first highlighted area, and I will read

20 this to you, "On account --" starting in the second sentence of the second

21 paragraph. "On account of the above and a number of other difficulties,

22 it was decided to form radio reconnaissance platoons (RIVs) in the corps

23 to engage in electronic reconnaissance, interception, interference,

24 misinforming and deceiving the enemy using his system of communications.

25 By the end of 1992, the platoons had been trained to intercept, identify,

Page 7181

1 and present indicators of the offensive intentions of the enemy vis-a-vis

2 RS and the VRS, and to gather information about the enemy (formation

3 strength, disposition, and intentions) for the needs of the corps and the

4 Main Staff of the VRS."

5 And the fourth paragraph I've highlighted an area for you,

6 Witness, it's the first -- it reads as follows: "To the extent permitted

7 by the technical possibilities, the RIVs," which are the radio

8 reconnaissance platoons, "organise their work in radio reconnaissance

9 groups so that the six corps, the air force, the anti-aircraft defence, as

10 well as the VRS Main Staff receive intelligence from 16 radio

11 reconnaissance groups."

12 The following paragraph reads, the first part of it, "The total

13 number of RIV," that's radio reconnaissance platoon, "personnel is 130

14 soldiers and officers. Through its work so far, this formation has

15 provided the command structures with about 70 per cent of all the

16 intelligence data gathered. The importance of this activity is enormous."

17 Now, reading on to the following paragraph, I'd like to read a

18 portion of this. "The EI system," and EI is electronic reconnaissance,

19 "that was made for successful reconnaissance and interception of enemy

20 tactical and operational strategic radio and radio relay communications,

21 due to the size of the theatre of war, these interception groups collected

22 data at all levels of the enemy's system. This made it possible to deploy

23 radio interception groups, RIGs, in the immediate vicinity of the front

24 line of defence, exclusively at points dominating the enemy's battle

25 positions."

Page 7182

1 Now, my first question -- let me read one more portion of this.

2 MR. HARMON: It is found on page 42, Mr. Usher, toward the

3 bottom.

4 Q. "All 16 RIGs were connected to corps intelligence and security

5 bodies by one or more communication channels as well as to the tactical

6 and operational group in whose zone they worked."

7 The next paragraph, "The processing and distribution of

8 intelligence obtained by EI is carried out by intelligence squads in the

9 corps and the air force and the anti-aircraft defence, fully applying

10 crypto-protection measures."

11 The next paragraph, "The available technical, personnel, and

12 material potentials make possible the successful simultaneous surveillance

13 of between 50 and 60 radio channels at all levels of over 600 linked up

14 channels. We cannot listen to about 100 channels because of

15 crypto-protection measures applied or technical inadequacy of our

16 equipment."

17 Now, this is in 1992, Witness, and one can see from this

18 description provided by the VRS of its activities in 1992, that they had

19 collected -- that these groups were responsible for collecting 70 per cent

20 of the intelligence gathered by the VRS, and it appears from this

21 description that this operation and procedure was successful and relied

22 upon by the Main Staff and the corps. Do you agree with me with this, or

23 do you have any comment that you'd like to make in light of what I've

24 read?

25 A. This is an analysis of combat readiness of the army of Republika

Page 7183

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Page 7184

1 Srpska in 1992, and this portion on units in all this material was

2 probably compiled and drafted and sent to the chief for electronic

3 surveillance and counter-electronic operations, and he probably did so on

4 the basis of the information he had at his particular level. And I don't

5 have any particular comments to make in this regard and in view of what is

6 written here.

7 Q. Now, the data that was collected by the radio reconnaissance

8 groups went to a particular entity within the sphere of operation of the

9 intelligence operation of the corps staff, specifically, the 4th Radio

10 Reconnaissance Platoon in the Drina Corps; am I correct?

11 A. The Drina Corps had a radio reconnaissance platoon. I don't know

12 whether it was called the 4th because there was only one, but it had a

13 radio reconnaissance platoon.

14 MR. HARMON: And Your Honours, in the Prosecutor's Exhibit 28, one

15 can see that the 4th Radio Reconnaissance Platoon is found in the box

16 dealing with the intelligence section, the chief of which is Lieutenant

17 Colonel Svetozar Kosoric, and the assistant in entity is Major Pavle

18 Golic.

19 Q. Now, you were in the army throughout the war. Would the radio --

20 I see my colleague is on his feet, so I will ...

21 JUDGE RIAD: Yes.

22 MR. PETRUSIC: [Interpretation] Your Honours, I don't know, it

23 remained unclear whether this was a question of Mr. Harmon, this reference

24 to the two officers who were representatives of this radio reconnaissance

25 unit, or it is a claim of Mr. Harmon's.

Page 7185

1 JUDGE RIAD: I think Mr. Harmon is the best to answer this. I was

2 going to ask him something about it.

3 MR. HARMON: Well, I will answer the concerns of my colleague. I

4 was merely pointing out the location in the structure where the 4th Radio

5 Reconnaissance Platoon is. It falls within the ambit of the intelligence

6 section whose head is Lieutenant Colonel Svetozar Kosoric.

7 JUDGE RIAD: And Golic is the assistant, or vice versa?

8 MR. HARMON: Let me ask this witness if he knows because we had

9 testimony on this point previously.

10 Q. But do you know Lieutenant -- I'm sorry, Major Pavle Golic?

11 A. Yes.

12 Q. What was his role in the intelligence section?

13 A. He was in the intelligence sector, but I don't know what his role

14 was. But I wish to say that the two officers you mentioned were not

15 commanders of the radio reconnaissance platoon. The commander of that

16 platoon was the captain, and this radio reconnaissance platoon,

17 professionally speaking was subordinated -- responsible to the

18 intelligence organ and provided information to the intelligence organ.

19 Q. Okay. Now, Witness DB, the 4th Radio Reconnaissance Platoon had

20 its groups within the Drina Corps area of responsibility, it collected

21 radio intercept information, and it forwarded that information to the

22 intelligence section, did it not?

23 A. Yes.

24 Q. In addition to the 4th Radio Reconnaissance Platoon that operated

25 in the Drina Corps area of operation, in other core areas there were

Page 7186

1 similar radio reconnaissance platoons that collected intercept operation

2 -- information, correct?

3 A. Yes.

4 Q. And they didn't collect the information merely to collect the

5 information; they collected the information in order to share it with the

6 relevant branches that may potentially be affected by that sensitive

7 information, correct?

8 A. Yes.

9 Q. So if another corps area was intercepting information that related

10 to, for example, the operations of the Drina Corps, that sensitive

11 information would be sent down to the Drina Corps, to the intelligence

12 section of the Drina Corps?

13 A. Quite logical.

14 Q. Okay. Now, do you know Colonel Kosoric, Lieutenant Colonel

15 Svetozar Kosoric?

16 A. Yes.

17 Q. And do you know what his relationship was to General Krstic?

18 A. You mean in the military relationship, or some other relationship?

19 Q. In some other relationship.

20 A. You mean private, personal, family relationship?

21 Q. Yes, that's correct.

22 A. They are related.

23 Q. Lieutenant Colonel Kosoric is General Krstic's brother-in-law,

24 isn't he?

25 A. Yes.

Page 7187

1 Q. Lieutenant Colonel Kosoric during the Zepa -- I'm sorry, during

2 the Srebrenica operation was at the forward command post throughout the

3 period of time that the Srebrenica operation took place?

4 A. Lieutenant Colonel Kosoric was there the whole time, but my --

5 from my recollection, he had greater freedom to leave that forward command

6 post.

7 Q. So he left from time to time?

8 A. Yes, meaning that he didn't spend as much time as I did on the

9 forward command post every day.

10 Q. And in Zepa, Lieutenant Colonel Svetozar Kosoric was likewise at

11 the forward command posts that were established at the Zepa operation,

12 correct?

13 A. Yes. He was at the forward command post for the Zepa operation.

14 Q. And did he remain in Zepa throughout the period of time of that

15 operation?

16 A. I can only say that, for instance, he would not spend as much time

17 as I would during the day at the forward command post -- at the command

18 post. His job was not to stay at the command post all the time as I was

19 supposed to, and that would be my answer to your question.

20 Q. Lieutenant Colonel Kosoric continued to have obligations as the

21 chief of intelligence for the Drina Corps while he was at both of those

22 command posts, forward command post, correct?

23 A. I think so.

24 Q. So is it fair to assume, Witness DB, that he was informed of

25 intelligence developments while he was out of the headquarters?

Page 7188

1 A. You mean the command in Vlasenica, when he was outside the command

2 in Vlasenica?

3 Q. When he was outside of the command in Vlasenica, he continued with

4 his responsibilities as the chief of intelligence of the Drina Corps, and

5 I assume, and you can correct me if I'm wrong, that he continued to be

6 informed by his subordinates of relevant and important intelligence

7 information.

8 A. Well, if those were his orders to them, and if he insisted to be

9 kept informed of all the developments while he was outside the command of

10 the corps, or to give -- to keep informed his deputy, or if such

11 information was particularly important, important enough to be given

12 personally to the commander, then they would have done so. If he had

13 ordered them to send him information wherever he was at the time, then

14 they would have done so. But perhaps they might have done so and

15 forwarded the information to his deputy at the command.

16 MR. HARMON: Judge Riad, we're going to stop at 3.00, are we?

17 JUDGE RIAD: Do you have any other suggestion?

18 MR. HARMON: I have four exhibits I'd like to go through with this

19 witness and I will try to be as quick as I can with them, or we can

20 adjourn now and I can review them tomorrow morning with the witness.

21 JUDGE RIAD: I prefer that last option, because I prefer that we

22 proceed in some kind of coherent series of questions. So I don't want to

23 stop you in the middle of anything.

24 MR. HARMON: It won't be stopping me in the middle, but I would

25 not want to be stopped with two documents into this and lose the thread of

Page 7189

1 the examination.

2 JUDGE RIAD: So how much time do you need now?

3 MR. HARMON: I would say I need ten minutes with these exhibits

4 and we would be required to go over.

5 JUDGE RIAD: I'll give you 12.

6 MR. HARMON: I appreciate it, Judge, and I will accept.

7 If I could have four exhibits given to the usher. They are

8 exhibits 364/12. And actually, Judge, I see this is a document that is

9 under seal and will require a private session, so my 12 minutes may not be

10 enough time getting in and out of private session. So perhaps if we can

11 adjourn now, I can resolve this matter in 12 minutes or 15 minutes

12 tomorrow morning.

13 JUDGE RIAD: We will be having enough time tomorrow morning.

14 MR. HARMON: Yes.

15 JUDGE RIAD: How much time do you expect to be in need of

16 tomorrow?

17 MR. HARMON: I think I have not progressed as quickly as I had

18 hoped and I may need the complete day tomorrow.

19 JUDGE RIAD: Complete day?

20 MR. HARMON: Yes.

21 JUDGE RIAD: We'll give you a complete day. Thank you.

22 I think we'll adjourn till tomorrow morning, 9.20. I hope we can

23 have good news about General Krstic's health, and I request that

24 Mr. Petrusic can inform us tomorrow morning. We are adjourned

25 --- Whereupon the hearing adjourned at 2.58 p.m., to

Page 7190

1 be reconvened on Wednesday, the 8th day of November,

2 2000, at 9.20 a.m.

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