150520ED

Page 35836

1 Now, in relation to the protected encrypted route via the FM-200,

2 can you tell us how encryption and transmission of voice communications

3 would happen? How did it work?

4 A. This other radio relay, 074, that worked with Vlasenica -- I

5 mean, in order to have this kind of communication, we needed two FM-200s.

6 We needed crypto encryption on both sides, KZU-71, and a telephone

7 multi-channel device with a time redistribution of channels that was

8 called IMD-310. The speech information provided, or written text, in

9 order for it to be relayed to the other side, this speech would be turned

10 into a binary system by way of impulse code modulation. It was

11 transferred -- [In English] Okay.

12 [Interpretation] For this kind of signal to be transmitted, an

13 AMD-310 is needed. This speech signal would be turned into an impulse

14 code or delta modulation with a time distribution of channels. So in

15 order to transmit this kind of signal, we needed impulse code modulation

16 at a speed of 256 kilobyte per second, 512, 1.024 kilobyte per second,

17 all depending on the channels on that protected route. Usually --

18 JUDGE ORIE: Please slow down, otherwise we'll not be able to

19 receive your full evidence.

20 THE WITNESS: [Interpretation] So this speed was applied depending

21 on the number of channels. Was it eight or more? 32 was the maximum.

22 Such a signal, binary-modulated, the code impulses were protected through

23 KZU-71, and then it goes to a 690 to 960 megahertz range, and then it

24 goes through antennae to the other side, and then it is modulated on the

25 other side, demodulated, depending on whether it is eight or 32 channels.

Page 35837

1 So such a signal is impossible to be listened into. It is fully

2 protected.

3 Say, if it is 10 kilometres, as was the case with the

4 Drina Corps, so it is 10 kilometres as the crow flies, usually the power

5 was not very big, the output. 09074 from 93, that is to say, this radio

6 relay route 09074 and then 9658, was digital or, rather, full protection

7 of speech was guaranteed.

8 Q. Now, while being transmitted via the radio relay device on a

9 particular frequency channel, how would that impulse signal sound to the

10 human ear of a listener on the same channel but without all the equipment

11 that you described?

12 A. These signals that enter the frequency-carrying device or this

13 telephone have a permanent tone, usually. So the speech cannot be

14 understood. Nothing. Whereas telegraph signal goes in interpreted

15 impulse. Again, it's some kind of tone but it's interrupted, the

16 impulses are.

17 Q. And now could you just describe for us briefly how that tone

18 signal is made understandable and rendered to normal speech on the other

19 end, the recipient's end of a radio relay communication?

20 A. This tone signal is sent to the other side, and the other side,

21 or rather the relay station, also has the same FM-200. So this radio

22 relay device that has a certain megahertz range and it has KZU-71 and a

23 multi-channel device for time distribution of channels in impulse code

24 modulation; that is to say, on this KZU-71, the deciphering or -- no,

25 demodulation takes place, and then through this multi-channel device, a

Page 35838

1 redistribution of signals is carried out in the receiver or rather in the

2 so-called channel section. So every one of them has eight channels and

3 then it is turned into speech information. So in the AND itself, this

4 transformation takes place into speech information and as such it is sent

5 to the cable itself as speech.

6 Q. And now I want --

7 JUDGE ORIE: Ms. Hasan.

8 MS. HASAN: Your Honours, I don't know how much further

9 Mr. Ivetic would like to go on this particular topic, but just to be

10 clear, it's the Prosecution's position, and it has been the evidence of

11 the Prosecution in this case, that the intercept operators did not have

12 the capabilities of intercepting FM-200s.

13 JUDGE ORIE: Does that help, Mr. Ivetic?

14 MR. IVETIC: It doesn't change matters in terms of understanding

15 the technology and as I'm about to now go to the RRU-800 and the

16 differences.

17 JUDGE ORIE: No. But to understand the technology is mainly

18 important if there's dispute about what could be done by whom with that

19 technology. If that there's no disagreement that there could be no

20 intercepts, we don't have to understand -- then we don't have to

21 understand what the technology of the system is which could not be

22 intercepted. That's --

23 MR. IVETIC: My recollection is that there were two different

24 witnesses talking about the FM-200, one of which said they could not and

25 one, speaking for different entity, said that they could. That's my

Page 35839

1 recollection anyway.

2 JUDGE ORIE: Well, we've heard it. You are moving --

3 MR. IVETIC: I'm moving on.

4 JUDGE ORIE: -- to the RRU-800 anyhow, so therefore time enough

5 to find out.

6 Please proceed.

7 MR. IVETIC:

8 Q. Now, sir, how about voice communications via the unencrypted

9 radio relay device RRU-800 from the Main Staff to the Drina Corps? How

10 would a voice communication be processed and transmitted by this radio

11 relay device?

12 A. I just recall that FM-200 had a protected and unprotected mode of

13 operation, may I just add that. And this other thing or rather this

14 other combination, the RRU-800 0607, how speech was transmitted. Speech

15 was transmitted as opposed to protected information. Different devices

16 were used, RRU --

17 THE INTERPRETER: Interpreter's note: The witness would have to

18 clearly state all the devices. Thank you.

19 JUDGE ORIE: Witness, could I just -- it was -- would have one

20 been one of my questions, what you told us about the two modes, the

21 protected and the unprotected mode, does that mean that you could

22 activate the protection and you could switch it off, to say so?

23 THE WITNESS: [Interpretation] You know what? This device does

24 have this possibility to work digitally and in analogue manner, but the

25 telephones themselves are different. When there is this protected

Page 35840

1 version, then a multi-channel device is used, 310, and I'm referring to

2 telephones. Now, when there is unprotected communication, it is 12K --

3 THE INTERPRETER: The interpreters did not understand the end.

4 THE WITNESS: [Interpretation] As for FM-200 --

5 JUDGE ORIE: 12K what?

6 THE WITNESS: [Interpretation] 12K communication. That's what it

7 was called. It was not used for the unprotected system for analogue

8 communication.

9 So let me explain --

10 JUDGE ORIE: Witness, we don't have to hear necessarily all the

11 technical details. If we need, we'll ask questions about it or the

12 parties will do so. But I do now understand that whether or not the

13 protected mode was used or not depended on other devices that were used,

14 whether they were such that the protection could work but perhaps the

15 more old fashioned ones did not fit into this protection system. And

16 apart from that, if you would use devices which were fit for this

17 protection system, could it still be activated or non-activated or would

18 it automatically be activated if the right equipment was used?

19 THE WITNESS: [Interpretation] As for protected systems, the

20 equipment that I listed is automatically used in protection. In order to

21 move onto a different system of work in the same device, FM-200, on the

22 device itself there is a system, and we can choose whether we want to

23 work in an unprotected or protected mode. Let me emphasise that when the

24 regiment is analogue, unprotected, again certain channels can be

25 individually protected - not the entire system necessarily, 12 channels,

Page 35841

1 24 channels. So even with an unprotected system in 12K, channels could

2 individually be used with a different kind of KZU; for instance, usually

3 KZU-71 and so on.

4 JUDGE ORIE: And the operator would decide whether he would

5 not -- that individual channel to be protected, yes or no?

6 THE WITNESS: [Interpretation] Yes. Yes, depending on the

7 importance.

8 JUDGE ORIE: Yes. That was --

9 THE WITNESS: [Interpretation] Depending on the importance of the

10 communication whether it had to be protected or not.

11 JUDGE ORIE: Yes. Thank you.

12 Please proceed, Mr. Ivetic.

13 MR. IVETIC:

14 Q. Now, you had started answering my question about how a voice

15 communication is processed and transmitted by an RRU-800 and -- if I

16 could just find it. If you could -- if could you finish that, I think

17 you had -- that's where you mention the 12K and had left off and had

18 answered the Judge's questions. Could you please explain for us how

19 voice communications are processed and transmitted by a RRU-800.

20 A. The other route towards the Drina Corps, 0607, worked through

21 RRU-800, and the multi-channel telephone device was an RM4A. Speech or

22 written information that enters that channel is modulated in terms of

23 frequency in a range from 03 to 108 kilohertz, and then such a signal is

24 modulated and is transmitted to the radio relay device 610 to 960

25 megahertz. By way of an antenna it is sent out. Then on the other side,

Page 35842

1 that is received, this signal, through electromagnetic waves. It is

2 demodulated, it is brought down to the MF signal, and in the telephone

3 system on the other side there can be 12K or another device --

4 THE INTERPRETER: The interpreters did not hear which one.

5 THE WITNESS: [Interpretation] So on one side there can be RM4 but

6 not necessarily, not necessarily the same telephone on both sides. I

7 don't know if I'm being clear on this.

8 MR. IVETIC:

9 Q. You mentioned in addition to the 12K another device which the

10 interpreters did not hear. Can you tell us which other device apart from

11 a 12K?

12 A. The multi-channel telephone device RM4A. Just like 12K, it can

13 have 12 or 24 channels depending on what is needed. These two devices

14 can operate mutually because there is no problem involved as they have

15 the same frequency range.

16 Q. Now, while the signal is being transmitted between the devices,

17 how would that signal sound to the human ear of someone on the same

18 frequency channel but without this equipment?

19 A. These speech signals are modulated within a certain frequency, so

20 there is no other written information or speech. There is just certain

21 tones that enter the frequency-carrying devices, and then as

22 electromagnetic waves they are being transmitted. So it's just the

23 signal, the tone signal, the interrupted signal, that is there, something

24 like that.

25 Q. And can --

Page 35843

1 A. I mean, we need equipment to demodulate that signal, to turn it

2 into a low frequency signal so that it would go to a certain kilohertz

3 range and to be transmitted into speech on the other side. So along the

4 route there is no other speech that functions. There is no speech that

5 can be heard, just some kind of interrupted tone. However, in order to

6 have proper quality of sound, the speech signal has to be strong enough

7 in terms of decibel. A certain value.

8 JUDGE ORIE: Witness, let's try to keep matters short. Do I

9 understand your answer to be that it would not be recognizable as speech

10 if you would listen to it? Because that's the issue. I think I heard

11 you say "da," but you agree?

12 THE WITNESS: [Interpretation] Well, the essence of that is that

13 no speech is transmitted along the relay route.

14 JUDGE ORIE: So the human ear would receive no speech.

15 Please proceed, Mr. Ivetic.

16 MR. IVETIC:

17 Q. Now, returning to the two routes, the RRU-800 and the FM-200

18 going from the Main Staff to the Drina Corps, which -- what would each

19 route be most frequently used for? What type of communications?

20 A. Could you please repeat the question? I didn't understand. The

21 interpretation came late, so I didn't get it.

22 Q. In relation to the FM-200 route and the RRU-800 route going from

23 the Main Staff to the Drina Corps, for what would each route be most

24 often used? What type of communications?

25 A. A digital route, the protected one, was mostly used for direct

Page 35844

1 communication between the commander of the Main Staff, the commander of

2 the Drina Corps, operative centres of the Drina Corps, of the Main Staff,

3 the telephone switchboards of the Main Staff and the Drina Corps, and the

4 automatic telephone number that was forwarded was 332. And the radio

5 relay route 0607, the analogue route, which did not have protection was

6 used for other communications, most frequently for the transmission of

7 telegraph signals; that is, to send written information that was

8 processed at the encryption station. Because such information could not

9 be listened into along the route, they could not be decrypted along the

10 route without the appropriate KZU devices. Also a three-digit automatic

11 number was used along a protected route. It all depended on the

12 importance of secure communication.

13 Q. Now, what communications hub was utilized by the Main Staff at

14 Crna Rijeka and the G-1, or Goljak, site for radio relay communications?

15 A. The radio relay hub Veliki Zep was used for radio relay

16 communication between the Drina Corps and the Main Staff. These radio

17 relay devices located at Veliki Zep, they were connected with the devices

18 of -- that carried frequency by a cable, VF, towards the V-1

19 installation, and the distance is 1 kilometre or 1 and a half kilometre,

20 I forgot. So telephone devices were at the G-1 and radio relay devices

21 were at the radio relay hub Veliki Zep, and they were connected between

22 them by a special cable.

23 Q. What kind of special cable was this that connected G-1 with

24 Veliki Zep?

25 A. It was a normal high frequency coaxial cable for underground

Page 35845

1 communications, wire communications, and it had 24 --

2 THE INTERPRETER: Could the witness repeat 24 what.

3 THE WITNESS: [Interpretation] And the other cable was a smaller

4 cable with a smaller cross-section, 0.8, and the previous one was 1.2.

5 So these are the cables usually used for underground wire communications.

6 MR. IVETIC:

7 Q. Okay. What portion of the 1 and a half kilometres link was

8 underground?

9 JUDGE ORIE: Mr. Ivetic, I waited for you to have it clarified,

10 what the witness referred to when he mentioned 24.

11 Witness, you said:

12 "It was a normal high frequency coaxial cable, I take it, for

13 underground communications, wire communications, and it had 24..."

14 24 what?

15 THE WITNESS: [Interpretation] Kilohertz.

16 JUDGE ORIE: That was --

17 THE WITNESS: [Interpretation] No, sorry, sorry. 24 pairs of

18 wires. We call them pairs. Couplings.

19 JUDGE ORIE: Please proceed.

20 MR. IVETIC:

21 Q. How much of the 1-and-a-half-kilometre link of that wire was

22 underground?

23 A. The entire cable, from Veliki Zep to the Bijeljina feature was

24 under the ground. The whole length.

25 Q. Now, you're recorded as saying the entire cable from Veliki Zep

Page 35846

1 to the Bijeljina feature. Is that what you intended, the Bijeljina

2 feature?

3 A. No, no, no. I said from Veliki Zep up to G-1.

4 Q. Okay. Now what can you tell us about the frequencies used by the

5 VRS to transmit via radio relay devices? Did they change during the war?

6 A. The chief of communications of the Main Staff of the VRS had a

7 frequency plan for all radio relay hubs of the Army of Republika Srpska.

8 This frequency plan, nobody could change it without his orders. Nobody

9 could modify it without his approval. This frequency plan programmed

10 regular annual changes of frequency. However, since we had two important

11 radio relay hubs in the territory of Yugoslavia, stationary hubs, Cer and

12 Strazbenica, this was not practiced. In order to change frequencies at

13 these two radio relay communications, approval was necessary from the

14 chief of communications of Yugoslavia, and for other hubs the approval of

15 the chief of communications of the Army of Republika Srpska.

16 So from 1992 until 1995, under this annual plan there were no

17 changes of frequency. I don't know why. It was the chief of

18 communication's decision. I was an operator; I was supposed only to

19 service these communications. We changed frequencies at given moments

20 when we had interference, when some new radio relay routes were

21 introduced, but it was only by 2 to 5 megahertz. We would modify

22 communication -- we would modify frequency by a very small amount if

23 there was interference.

24 So this frequency plan stipulated the same frequencies from 1992

25 to 1995, except for a few situations that I described.

Page 35847

1 JUDGE FLUEGGE: May I put one question for clarification.

2 You said nobody could change it without the orders of the chief

3 of communications of the Main Staff.

4 It was not allowed to change without his permission or was it

5 technically not possible?

6 THE WITNESS: [Interpretation] It was technically possible, but

7 without his orders nobody was allowed to change it.

8 JUDGE FLUEGGE: Thank you.

9 MR. IVETIC:

10 Q. First, to follow-up on your answer, sir, you said in cases of

11 interference we could modify the frequency to a small degree, 2 to 5

12 megahertz up or down. Would that be in the transmission or in the

13 receiving end of radio relay transmissions?

14 A. Well, it depended on which frequency was closer, what was the

15 frequency of a device close to you. The receiving end or the

16 transmitting end. There had to be an appropriate distance between

17 frequencies, up to 20 megahertz. Frequencies could not be reduced lower

18 than that. The distance between frequencies could not be smaller. The

19 difference had to be at least 27 megahertz.

20 Q. I understand that. But where would you go up -- on what end

21 would you tune-up or down to 2 to 5 megahertz to better hear the signal?

22 How would that be accomplished?

23 A. For these 2 to 5 megahertz, you could do it at the transmission

24 device or the receiving device. The transmitter would tune-up by 2 or 5

25 and the receiving end also. They had to do it simultaneously. The --

Page 35848

1 the receiving end had to set their frequency at the same value as the

2 transmission.

3 Q. And now to follow up on the Judge's question, could a single

4 operator on the system on their own change the frequency and still

5 maintain communications with the rest of the network; that is to say,

6 change the frequency from that on the communications plan for the radio

7 relay network?

8 A. That could be done, but it wasn't done. As far as I know, nobody

9 did it. But technically, it was possible.

10 Q. Now if someone wanted to intercept and listen in on transmissions

11 sent via an RRU-800 or an FM-200 radio relay device, where would they

12 physically need to be located?

13 A. In order to eavesdrop on radio relay communications, the training

14 we received at school was this: The intercepting side had to enter the

15 beam of electromagnetic waves between two radio relay devices that were

16 operating, and they were usually set, as I said, at a distance of up to

17 50 kilometres with clear optical visibility. And on this route, the

18 signal noise ratio had to be very sharp in order for modulated

19 communication to function well. So with two radio relay devices, the

20 other side would have to have also two radio relay devices and be located

21 up to 25 kilometres from either end and have an appropriate

22 frequency-carrying device, and then they could listen in to unprotected

23 analogue communications. Or they could set two stations close to both of

24 these, like a couple of kilometres behind the receiving end and a couple

25 of kilometres behind the transmitting end.

Page 35849

1 If they had only one device, they could hear only one side. To

2 listen in to the entire conversation, a radio relay device had to be set

3 halfway between the two or behind the radio relay devices, both of them.

4 And then, of course, they had to tune into the correct frequency. Radio

5 relay centres were always located behind the lines. If the enemy wanted

6 to listen in, the enemy had to go very deep into our territory in both

7 versions; if they wanted to set their station halfway between the two, or

8 two of them behind each.

9 Q. Now, the Chamber has heard some evidence and has been told by the

10 Prosecution that it is possible for both sides of a conversation to be

11 transmitted via one channel of a radio relay device by way of leakage of

12 the sound from the speaker in the handset to the microphone in the same

13 handset of one participant in the conversation. What are your technical

14 observations as to this proposition?

15 A. Well, the speech signal coming out of the receiver, it's very

16 small, very few decibels, so that signal could not be carried further. I

17 mean, on these devices carrying frequency and relay devices, it doesn't

18 have enough power, that signal, not enough value in decibels in order to

19 enter the frequency modulated and received on the route as a wave.

20 In the contrary case, I mean, the signal of that kind of power

21 cannot be transmitted. That's what I learned at school at least. It has

22 to have a power of 160 to 183 decibels. That's why radio relay routes

23 were set at a distance of not less than -- not more than 50 kilometres.

24 All other conversations cannot be carried far enough. They -- you can't

25 hear it. The audibility is not sufficient.

Page 35850

1 Q. Now, in terms of personnel operating radio relay --

2 JUDGE ORIE: Could I seek clarification here.

3 I have some difficulties in understanding your answer because you

4 are referring to values, which I'm unable at this moment to link to the

5 question and to what was said. The question was about incoming signals

6 which would be made audible and that through that audible incoming sound,

7 that that would leak into the microphone which would give the signal in

8 the other direction.

9 Now, I have some difficulties, because if the person who receives

10 the signal and receives it as sound audible for him, that is either, I

11 would think, could be detected by the microphone, and you could -- even

12 if it's not strong enough, you would even be able to amplify it because

13 you need to hear it anyhow. The human ear would need to be able to hear

14 it. Why, then, a microphone, which is next to or close to the human ear

15 could not receive that same sound and it would be included in sending it

16 the other direction?

17 I have difficulties in linking your answer to what the question

18 was. First of all, is it clear to you what my understanding was of

19 leakage, which was used by Mr. Ivetic as an expression? That's my first

20 question. Is it clear to you what I -- how I understood it and --

21 THE WITNESS: [Interpretation] Coming out from the headset.

22 JUDGE ORIE: Yes. And the headset, of course, could be anything.

23 You can open it, you can close it, you could -- headsets are just

24 incoming sound.

25 I do not understand your reference to the 160 to 183 decibels

Page 35851

1 because that's a huge sound, isn't it? You almost become deaf if you

2 listen at 160 decibels. It would even perhaps harm your ears.

3 So I do not understand how to link your information with the

4 question.

5 THE WITNESS: [Interpretation] The microphone and the headset are

6 connected electrically between them. And this sound leaking through the

7 headset is of a very small value. That's what I spoke about already.

8 And, as such, it enters the device very weakly. It has to have enough

9 power in order to be modulated inside the radio relay device.

10 JUDGE ORIE: Let me --

11 THE WITNESS: [Interpretation] For instance --

12 JUDGE ORIE: Could I interrupt you for a second. Is there any

13 chance that you're talking about electric leakage, whereas perhaps the

14 question was about sound leakage? You understand what I mean? And I

15 that I think that you're talking about a kind of electromagnetic leakage,

16 whereas I think the evidence the Chamber heard was about sound, that is

17 audible sound, leakage, leaking into the microphone. But I may have

18 misunderstood it, and I would appreciate the assistance of the parties if

19 I show that I've misunderstood it.

20 Could you answer the question, whether you're talking about

21 electromagnetic leakage, and whereas the question may have been about

22 sound, that's, audible sound, leakage.

23 THE WITNESS: [Interpretation] I was saying that the microphone

24 and the headset are electrically connected. I understood you. The

25 headset transmits the signal into an understandable speech signal. I was

Page 35852

1 not talking about electromagnetics. The sounds signal enters the

2 headset, but it's so weak that it cannot enter the device on the opposite

3 side. It's too weak. It cannot be transmitted.

4 JUDGE ORIE: Yes. You would say the volume would not be good

5 enough to leave the headset and enter the microphone in any useful way?

6 THE WITNESS: [Interpretation] Yes, that's what I'm trying to say.

7 JUDGE ORIE: Could you also tell us when you refer to 160 to 180

8 decibels, what exactly were you talking about?

9 THE WITNESS: [Interpretation] I was talking about the power of

10 the signal that is modulated and put out along the route. That's the

11 necessary power of the signal for the signal to be modulated and

12 transmitted onto the route.

13 So a signal has to have a certain required power to be

14 transmitted along the route. And this speech leaking into the headset,

15 it depends all on the device, if the device is too far away and cannot be

16 received and transmitted onto the route. It has to be strong enough,

17 otherwise it would not be understandable and could not be transmitted.

18 JUDGE ORIE: Yes. Now, as far as I understand, decibel is a unit

19 for volume power, more or less?

20 THE WITNESS: [Interpretation] Yes, for induction.

21 JUDGE ORIE: When you're talking about 160 decibels, what kind of

22 volume are we talking about? Is that whispering or is that a siren?

23 Because you use those values.

24 THE WITNESS: [Interpretation] No, not a siren. Normal speech,

25 when you talk into the microphone. It can be measured, so that's why we

Page 35853

1 have this range for reducing the signal.

2 JUDGE ORIE: So you say normal conversations, normal speech is

3 approximately at 160 decibels. Is that well understood?

4 THE WITNESS: [Interpretation] No, not speech but the signal that

5 enters the radio relay device. That's the required power for the signal

6 to enter. I'm not talking about speech. The device itself will evaluate

7 how strong the signal is. If it's too weak, the device cannot transmit

8 it.

9 JUDGE ORIE: And it needs 160 decibels to receive it in a useful

10 way?

11 THE WITNESS: [Interpretation] That's the value the signal has to

12 have in order to be transmitted. That's the value of the modulated

13 signal putting -- put out into the route. It's not the power of our

14 speech. The signal enters the device, then it is frequency-modulated in

15 the device-carrying frequency, and the signal, modulated in such a way,

16 needs to have the power of 160 to 183 decibels to be successfully

17 transmitted. I'm talking about the required power of the signal, not

18 the volume of the speech. And if we're talking about normal speech, the

19 device itself will decide if the signal is strong enough or not, if it

20 can enter the range of the modulated signal in order to be successfully

21 transmitted.

22 JUDGE ORIE: Well, most likely my understanding of what a decibel

23 is is too limited to fully understand.

24 But it is approximately time for a break, Mr. Ivetic. Would you

25 want to use this last minute to clarify the matters forever or would you

Page 35855

1 You can explain this to Mr. Mladic if you wish, but that is how

2 the Chamber understands the present situation.

3 MR. STOJANOVIC: [Interpretation] Just now, we talked to

4 General Mladic. We conveyed this information to him, and he said to us

5 that in that case he would stay here and follow via videolink, and then

6 if Simic starts today, he would like to be in the courtroom.

7 JUDGE ORIE: Yes. Of course, you will understand there's no

8 guarantee that Mr. Simic would start his -- by the way it is -- yes, it

9 is Mr. Simic will start his testimony today. We do not know. That's --

10 but you have fully understood, then, the situation; Mr. Mladic as well.

11 Could the witness be escorted in the courtroom.

12 Meanwhile, if the parties -- I was a bit confused by the

13 decibels, as you may have noticed. Most likely explanation is that

14 decibel is not only used in acoustics but also in electronics. If that

15 is the case, if the parties would agree on that, that would at least make

16 clear what type of confusion is possible there. Not to say that the

17 whole leakage issue, whether this is the explanation or not is a totally

18 different matter. It's just a matter about concept.

19 [The witness takes the stand]

20 JUDGE ORIE: Mr. Ivetic, please proceed.

21 MR. IVETIC:

22 Q. Sir, in terms of the personnel operating the radio relay device

23 communications system at the Main Staff of the VRS in 1995, what can you

24 tell us about their overall level of skill and training?

25 A. The personnel operating the communications equipment - that is to

Page 35856

1 say, all the devices in the communication system of the Army of

2 Republika Srpska - were mainly professional military personnel; that is

3 to say, officers who had completed military schools and also civilians

4 serving in the army who had completed certain schools in the field of

5 electrical engineering so that they could operate such equipment. So the

6 personnel were professionals who were capable of operating this kind of

7 equipment.

8 Q. Now I would to take a look at 65 ter number 24516 with you in

9 e-court. Now, first of all, sir, do you recognise this drawing or sketch

10 that is on the monitor?

11 A. Yes.

12 Q. Can you tell us what this sketch or drawing is depicting?

13 JUDGE MOLOTO: Before we do that, can we get an English copy.

14 MR. IVETIC: It's my understanding that there is only a B/C/S

15 copy of this Prosecution 65 ter number.

16 JUDGE MOLOTO: Thank you.

17 MR. IVETIC:

18 Q. Sir, can you describe for us what this sketch depicts?

19 A. This is a sketch that I drew of the underground part of the

20 facility; that is to say, the distribution of rooms underground in G-1.

21 Q. And does this sketch accurately depict the distribution of spaces

22 or rooms in the underground G-1 object, or are there need for any

23 corrections?

24 A. The sketch is mainly accurate. However, one room is missing here

25 on the left-hand side where it says OC GS VRS. There was another room

Page 35857

1 next to that one for the chiefs of the administration for security and of

2 the security service. So it is between the room where it says OC GS VRS

3 and the other one where it says VIP VO. I made a mistake, I omitted to

4 draw that other room there as well. The rest is accurate.

5 Q. With the assistance of the court personnel, I would ask that you

6 mark with an X the approximate location of that room that you have just

7 described for us that is missing from the diagram.

8 A. It was here where I marked this in blue. But it was just as big

9 as the other rooms down there. However, now it is impossible for me to

10 draw it that big.

11 Q. Let the record reflect the witness has marked on the left-hand

12 side of the document a line that appears to have two Xs interposed on top

13 of one another above that line --

14 JUDGE ORIE: Mr. Ivetic, do you want to tender it?

15 MR. IVETIC: Not now but later I think I will and then I'll

16 ask -- identify it first, of course.

17 JUDGE ORIE: Because if so, then, of course, it's perfectly

18 clear. The blue marking appears clearly.

19 MR. IVETIC: But there will be other markings and that's why --

20 JUDGE ORIE: Oh, there will be other markings.

21 Yes, please proceed.

22 MR. IVETIC: Thank you.

23 Q. Can you identify for us in what space or room you performed your

24 duties by circling that space? Again, with the assistance of the court

25 personnel and the pen that is attached to the court monitor.

Page 35858

1 A. [Marks]

2 Q. Okay. Now what was the numeric designation for this room for the

3 G-1 object, the G-1 feature?

4 A. Should I mark that or ... it was number 3.

5 Q. Why don't you put a number 3 in the circle then.

6 A. [Marks]

7 JUDGE FLUEGGE: Could the usher assist? It doesn't work at the

8 moment.

9 JUDGE ORIE: You were invited, Witness -- yes, I think the 3 is

10 now next to the circle.

11 Please proceed.

12 MR. IVETIC:

13 Q. Could you describe for us what kind of equipment was present in

14 this room which you have marked with a circle and the number 3 where you

15 performed your duties at the G-1 feature?

16 A. This room was for telephone equipment, multi-channel telephone

17 equipment was kept there. RRMAV-120, VZ-4/12, and a few automatic

18 telephones. And some M63 telephones. So it was two or three telephones

19 of each.

20 Q. Now just below the room that you have marked with a circle and a

21 3, we see a space that has the designation ATC OM-60, and then we have

22 two other spaces below that, PS and the other one is "Razdelnik" in

23 B/C/S. Could you describe for us what those rooms were used for?

24 A. Would you like me to mark them with numbers or not?

25 Q. Why don't you do that just to be on the safe side. Mark first

Page 35859

1 the --

2 A. [Marks]

3 Q. Okay. Could you first then tell us about rooms --

4 Could you first tell us about the rooms that you've marked 1, 1A,

5 1B, and 1C, please? For what were those rooms used?

6 A. There were three smaller rooms in room 1. In PS, there is a

7 hand-operated telephone switchboard where direct communication was

8 established between direct telephone links and automatic telephone links.

9 So there was an operator there who connected these telephone

10 communications by hand. Or between automatic lines. So it was different

11 kinds of connections that were established there.

12 Q. And now, the room that you have marked with a number 2, what was

13 the function of that room at the G-1 feature?

14 A. I didn't tell you something a moment ago. Where it says

15 Razdelnik 1B, that is where all the cables were arriving from Veliki Zep

16 and all the telephones. So they were all there at the distribution

17 board, and then it was possible to switch from one channel to another. C

18 was a generator for the automatic telephone exchange that is in room

19 number 2. And in room number 2, there was an automatic telephone

20 exchange, OM-60, that had 250 automatic numbers. So this was used for

21 the direct establishment of communication through automatic telephones

22 between two or more participants.

23 JUDGE FLUEGGE: May I put one question at this moment to the

24 witness.

25 You are talking about automatic telephones. What is, in your

Page 35860

1 understanding, an automatic telephone?

2 THE WITNESS: [Interpretation] An automatic telephone has a dial

3 with numbers from 1 through 9. And then, for example, this was a

4 switchboard with a three-digit number. So say you choose number 111, so

5 you dial 1-1-1. You don't need an intermediary. You just choose the

6 number that you want with regard to these 250 numbers. So it is similar

7 to regular civilian PTT, the way you establish telephone communication

8 through a telephone exchange. So it is with a dial, with numbers from 1

9 through 9, including 0.

10 JUDGE FLUEGGE: Thank you.

11 MR. IVETIC: And let me just check where we left off.

12 Q. And the room above the room that you've marked with a circle and

13 a number 3, that -- the left-hand side it says teleprint ST, and the

14 right-hand side says "prostor" [interpretation] area for repair,

15 [In English] and then it has some letters.

16 Could you describe for us what that room was utilized for or what

17 those two rooms were utilized for that you've now marked with a number 4?

18 A. Room number 4 where it says teleprinter station, that is where

19 teleprinters were. RTL-1 [as interpreted] and T100 for transmitting

20 written information via telephone channel communications equipment and

21 radio relay after telegrams were processed, but we'll deal with that

22 later. So that is where written information was sent from.

23 Now, the room where it says area for repairing telephone

24 equipment, there was a repairman there who repaired all this equipment --

25 THE INTERPRETER: Interpreter's note: We didn't hear any of the

Page 35861

1 equipment.

2 MR. IVETIC:

3 Q. The interpreters did not hear what equipment was repaired in that

4 room. Could you please repeat that part of your answer.

5 A. Telegraph equipment, teleprinters that were operated in room 4;

6 that is to say, RTL-1, T100.

7 Q. And just above the room you've marked with a 4, there appears to

8 be a space -- two spaces, one is a square and one is an L with the

9 letters STPLST, and now I see you've marked it with a number 5. Could

10 you explain for us the function of those rooms?

11 A. This is an encryption teleprinter station. This is a room where

12 the encryption is and the crypto encryption, and then this other thing is

13 a little hallway. There was nothing there. And then there were openings

14 towards the other ones. So that is where the encryption and decryption

15 of written information took place that was being sent to and sent from

16 the command post of the Main Staff of the RS. I mean, information that

17 was encrypted and sent to another side. Such telegrams that were

18 processed were sent to room number 4 -- were handed over to room number 4

19 and then sent on further via teleprinter.

20 JUDGE ORIE: Mr. Ivetic, the Chamber wonders what the -- although

21 appreciating the details, what the relevance is of knowing exactly what

22 teleprinters were repaired, where, in that room. So if you would first

23 put questions to the witness which show the relevance, and then we are

24 quite willing to look in every detail that is important for us to know in

25 order to understand.

Page 35862

1 MR. IVETIC: If I can remind, Your Honours, I was responding to

2 the request of the interpreters, so I was relaying the request of the

3 interpreters at that point in time, not phrasing a question myself.

4 JUDGE ORIE: Yes, could you have refrained. You have said, well,

5 that information is not vital for the Defence and move on.

6 Please proceed.

7 MR. IVETIC:

8 Q. Were these rooms that you have now marked 1, 2, 3, 4, and 5, were

9 they in use throughout the time-period that you were at G-1 during the

10 war from 1992 through 1995?

11 A. These rooms further on. I'll mark them.

12 JUDGE ORIE: Would you please first answer the question as put to

13 you by -- but I see now that you a have a line up, you've marked three

14 rooms by 6, 7, and 8. But could you first now answer the question put to

15 you by Mr. Ivetic.

16 THE WITNESS: [Interpretation] Yes, I marked it because they were

17 used throughout the period from 1992 to 1995. Some of them were, some of

18 them were not actually. That's why I marked these 6, 7, 8. They were

19 constantly used. That is where personnel were -- I mean, the personnel

20 who worked in rooms from 1 through 5, and the rooms on the left-hand side

21 where it says the commander of the Main Staff of the VRS, and then

22 further down all the way down to "Staresine," that is to say, officers,

23 they were there only from time to time; if there was an air-raid, if

24 there was an alert. They were not busy all the time. It's not that

25 people were in there all the time, so that's why I marked them in a

Page 35863

1 different way.

2 MR. IVETIC:

3 Q. If I could just clarify in relation to rooms that you've marked

4 1, 2, 3, 4, 5, were those in use throughout your tenure at the G-1

5 feature from 1992 to 1995?

6 A. Yes.

7 Q. Thank you.

8 MR. IVETIC: Your Honours, I would ask for this to be marked for

9 identification as marked, and then I'm sure between the Prosecution and I

10 we can figure out how to get a translation for the entire diagram into

11 English from CLSS once it becomes marked with a D number.

12 JUDGE ORIE: Yes, Madam Registrar.

13 THE REGISTRAR: Your Honours, the number would be D1061.

14 JUDGE ORIE: Marked for identification.

15 Mr. Ivetic, do you know when this sketch or this diagram was

16 made?

17 MR. IVETIC: Yes, I do. If we can --

18 JUDGE ORIE: No, just if you could tell us so that we know.

19 MR. IVETIC: It's either 14 or 19 November 2008, as indicated in

20 the upper left. This was an exhibit in the Popovic proceedings.

21 JUDGE ORIE: Yes. And does that mean that in the Popovic

22 proceedings that there must have been a translation?

23 MR. IVETIC: No, it does not mean that, Your Honours. It was

24 without.

25 JUDGE ORIE: Popovic is more lenient in that.

Page 35864

1 MR. IVETIC: Yes.

2 JUDGE ORIE: Okay.

3 MR. IVETIC: I was surprised as well.

4 JUDGE ORIE: Yes, that's clear. Please proceed.

5 MR. IVETIC: Thank you.

6 Q. Mr. Pajic, on behalf of my client and the rest of the team, I

7 thank you for answering my questions.

8 MR. IVETIC: At this point, I finish my direct examination,

9 Your Honours.

10 JUDGE ORIE: Thank you, Mr. Ivetic.

11 Mr. Pajic, you will now be cross-examined by Ms. Hasan. You find

12 Ms. Hasan to your right, standing. Ms. Hasan is counsel for the

13 Prosecution.

14 Cross-examination by Ms. Hasan:

15 Q. Good morning, Mr. Pajic.

16 A. Good morning.

17 Q. Just a point of clarification, you are recorded in the transcript

18 at transcript page 28 that in room 4 was a device that is recorded as R,

19 for Roger, TL1. Is that correct?

20 A. No, no. It's a type of teleprinter.

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

22 witness again.

23 JUDGE ORIE: Could the microphone be adjusted, Witness, because

24 you're now turning a bit more to the right --

25 THE INTERPRETER: Interpreter's note: It's not a question of the

Page 35865

1 microphone. Could the witness just speak clearly. Thank you.

2 JUDGE ORIE: Could you also -- you're invited to speak very

3 clearly so that the interpreters can well hear you, and could you speak

4 slowly and then could you then repeat your answer. You were taken to

5 transcript page 28, that in room 4 was a device that is recorded as RTL

6 and you were asked whether that is correct.

7 Could you repeat your answer to that question.

8 THE WITNESS: [Interpretation] It was not correct. What I said,

9 it was a teleprinter, ETL.

10 MS. HASAN: Thank you.

11 Q. Now you spoke yesterday about the company for the communications

12 garrison of the 67th Communication Regiment of the Main Staff, and you

13 mentioned the 2nd Platoon. Now, was it made up of other platoons as

14 well, that garrison; and if so, what were those platoons and what were

15 they responsible for?

16 A. Yes. It was a company for garrison communications. There was

17 also a platoon for telephones and telegraphs. It was used for

18 communications at the teleprinter station and sending written information

19 from teleprinters T100 and ETL-1. I've already mentioned that. Then the

20 other platoon was supposed to maintain and organise communications of the

21 automatic telephone exchange OM-60, especially the switchboards that were

22 in number 1, and also the distribution board in the other room. And

23 there was a radio relay platoon that was at Veliki Zep to establish

24 radio relay communications.

25 Q. And who was the commander of the platoon at Veliki Zep

Page 35866

1 responsible for radio relay communications?

2 A. I'm sorry, it was a squad, and I was responsible, and there were

3 NCOs up there, and they were -- they held the rank of sergeant, these

4 three NCOs. So there was this mixed platoon for UNF where I was

5 commander, and that included telephone communications with

6 frequency-carrying devices and the radio relay communications that was at

7 Veliki Zep. So it was a squad at Veliki Zep.

8 Q. Now this squad of three persons that you mentioned -- is that

9 right, there was three persons there?

10 A. Yes, three persons were there.

11 Q. Could you name those three for us, please.

12 A. Zeljko Serbula, Dragoljub Gagovic, and Lepir -- I cannot remember

13 his first name now. Believe me. Lepir was his last name.

14 Q. Okay. And who was sitting at the switchboard in the G-1 facility

15 in 1995?

16 A. There were operators who were military conscripts. After they

17 did their military service, they would leave, so I cannot recall all

18 their names. So these were ordinary soldiers who were doing their

19 military service in the signals corps.

20 Q. The 67th Communications Regiment also comprised of two

21 battalions; isn't that right?

22 A. 67th Regiment consisted of two battalions, the 1st Battalion and

23 the 2nd Battalion, then the technical support company and the garrison

24 communications company. That is the entire 67th Regiment.

25 Q. Just very briefly, could you tell us what the 1st and

Page 35867

1 2nd Battalion were responsible for.

2 A. The 1st Battalion was at the location of the barracks

3 Han Pijesak, and its task was to handle mobile communications. In case

4 the forward command post had to be set up, the communications equipment

5 was mounted on vehicles, and with these vehicles they would go to that

6 command post and set up communications.

7 So the company for garrison communications was of stationary

8 type, and the mobile company served for mobile communications, for

9 setting up forward command posts.

10 Q. And what about the 2nd Battalion?

11 A. The 2nd Battalion exclusively served for logistics, for support

12 to the company for garrison communications. If the chief of

13 communications was on leave or was ill, if somebody needed to be sent to

14 provide, among other things, security personnel for the command post.

15 Q. You mentioned yesterday that -- in your platoon, the 2nd Platoon

16 of the garrison company, you had another soldier who worked together with

17 you. Could you tell us his name?

18 A. These were conscripts serving their compulsory military service.

19 They changed all the time. I can't remember now. I can't remember the

20 names, believe me. Normal conscripts, doing their regular military

21 service. Five or ten of them took turns.

22 Q. You spoke about Vila Javor yesterday and that there was access to

23 the underground facility G-1. Is it correct that that facility, the

24 underground facility, is embedded in the base of Javor mountain?

25 A. On the maps it was drawn as Javor, but we called it Veliki Zep.

Page 35868

1 On topographic maps, it was marked as Javor, and the top of it, the

2 summit, was called Veliki Zep. That's where the radio relay hub was.

3 Q. And it's at Vila Javor where General Mladic stayed; right?

4 A. Yes. That's where he stayed. Not all the time. He had an

5 office also in the populated area where the hutments were. It was a bit

6 further away from Javor. He spent time also frequently at the forward

7 command post. Part of his time he spent at Vila Javor.

8 Q. And at Vila Javor he had access -- I mean, he had access to a

9 telephone?

10 A. Yes, he had a telephone.

11 Q. Now we spoke about the radio relay route that existed between

12 Veliki Zep and Vlasenica, and you spoke about an unprotected line as well

13 as a protected line.

14 Now, where -- can you tell us where the communications station

15 was in Vlasenica?

16 A. The communications centre in Vlasenica - that is to say, the

17 radio relay station - was at the command of the Drina Corps. It's a

18 building belonging to the bauxite mine. At least it did before the war.

19 I'm not quite sure about this, but I think so. That's where the

20 communications centre was, the radio relay station.

21 Q. So as far as you can recall, was the antenna then mounted on top

22 of the Drina Corps command building?

23 A. I really don't know where exactly it was mounted. Somewhere

24 there, whether it was on top of the building or on top of a vehicle, I'm

25 not sure. You could mount it on a vehicle that was designated for a

Page 35869

1 radio relay device or perhaps on the building. I never was interested

2 enough to find out.

3 Q. What about at Zvornik? Do you know where the communication --

4 radio relay communication station was there?

5 A. No.

6 Q. Now, there existed a radio relay route from the communications

7 centre at Veliki Zep to -- towards Pale; isn't that right?

8 A. Yes.

9 Q. And it was connected to Pale through Ravno Romanija and Kalovita

10 Stena [phoen]; is that right?

11 A. Yes, it was protected radio relay route between the Main Staff,

12 the president of Republika Srpska, members of the government and of the

13 assembly, and the Sarajevo-Romanija Corps. That's 0601 route. There was

14 a station at Ravno Romanija and the end station at Kalovita Brda. From

15 there, it went down by wire communications to the command of the

16 Sarajevo-Romanija Corps in Tilav and to Pale up to the Presidency and the

17 other authorities of the Republika Srpska and in the assembly and the

18 government, and there was also an analogue route in other directions.

19 Unprotected ones.

20 Q. Now, the analogue route from Veliki Zep to Ravno Romanija, did

21 that exist?

22 A. No. Only 0601 route, the protected one. When I say this number,

23 it's the designation of the route, its number. It's a digital route.

24 And the analogue one went to the other side, across Strazbenica and

25 Jahorina and went down to Pale.

Page 35870

1 Q. So just so I understand it correctly, is the route - the analogue

2 route, then - Veliki Zep-Strazbenica, Strazbenica-Pale? Were there any

3 other nodes along that route, intermediary notes?

4 A. Strazbenica-Jahorina and then Pale.

5 Q. Now, do you recall what devices were used on this unprotected

6 route? And if we can do it segment by segment. So between Veliki Zep

7 and Strazbenica, what was the device that was used?

8 A. Between Veliki Zep-Strazbenica, the device FM-200 was used. But

9 it worked in analogue mode, unprotected mode. I said previously this

10 device could work in unprotected and protected modes both. It worked in

11 analogue mode.

12 Q. Now from Strazbenica to Jahorina, what was the device that was

13 used along that segment?

14 A. A device working on higher frequencies compared to FM-200. It's

15 a device SMC-1306B. That one works in frequency range from 440.000 to

16 460.000 megahertz --

17 THE INTERPRETER: Could the witness repeat the other range?

18 THE WITNESS: [Interpretation] A different device was used with a

19 higher frequency. V120, the multi-channel one. You couldn't uses RM4

20 with it. That means 12K. Its capability was 120 channels

21 simultaneously, telephone or telegraph. It didn't matter. So it had a

22 higher capacity compared to RRU-800, and it was difficult to intercept

23 because it was a very large piece of equipment. It was only installed by

24 the JNA on radio relay hubs. It could not be mounted on a vehicle

25 because the parabolic antenna was too big. It was used only in

Page 35871

1 stationary facilities.

2 MS. HASAN:

3 Q. And are you saying that SMC-1306B was operating in analogue mode

4 and was an unprotected line?

5 A. Yes. It worked within an analogue system with a proviso that

6 some channels could be protected individually, like in other devices.

7 There was no telephone device for encryption that could protect the

8 entire system.

9 Q. Now how about from Jahorina to Pale?

10 A. Between Jahorina and Pale, FM-200 was operating with 24 channels.

11 Q. Also operating in unprotected mode?

12 A. Yes. Because it makes no sense to set up one segment protected

13 and one segment unprotected. It makes no sense not to protect the whole

14 channel. Analogue sections were all analogue. That means unprotected

15 along the whole length.

16 Q. Now along that route, were there also RRU-800 devices?

17 A. For that route, the one we're talking about now, from Jahorina to

18 Pale that was used for those needs, as far as I know, no other device was

19 used.

20 Q. What about from Veliki Zep down to Jahorina?

21 A. There was no relay route Veliki Zep-Jahorina.

22 Q. Sorry. What I meant to say is between Veliki Zep through

23 Strazbenica to Jahorina.

24 A. Whether RRU-800 was used? Is that what you're asking?

25 Q. Yes.

Page 35872

1 A. No, I told you from Veliki Zep to Strazbenica, we used FM-200.

2 And from Jahorina to Pale, also FM-200. And the last section was

3 SMC-1306B.

4 Q. Now, there was a central communications centre for PTT civilian

5 lines in Sokolac; isn't that right?

6 A. Yes. A civilian post office existed with civilian numbers.

7 Q. And some of those civilian lines, at least, were used by the VRS

8 for communications; isn't that right?

9 A. Yes.

10 Q. And so there would be a phone number that you could reach the

11 Sokolac switchboard; isn't that right?

12 A. Yes.

13 Q. And say if I was a civilian and I was calling that phone number

14 and my call arrives in Sokolac via this PTT line and I wanted to speak to

15 someone at the Main Staff, can you tell me how my call, along what route

16 my call would travel to reach the Main Staff at Crna Rijeka?

17 A. Not only from Sokolac from the PTT. We could do that from Pale,

18 too. We could do it also from Han Pijesak. We had those PTT numbers.

19 And specifically if you're ask being Sokolac, there was a radio relay

20 route also analogue, Strazbenica-Sokolac.

21 And using telephone and radio relay devices, we pick up the

22 Sokolac number, never mind which, and I set it up in Crna Rijeka, I

23 transfer it, and from there, you can dial any number in Sokolac or in

24 Pale, anywhere. So a radio relay route was set up between Strazbenica

25 and Sokolac. And two FM-200 devices were used, one in Sokolac, one in

Page 35873

1 Strazbenica.

2 Q. And from Strazbenica, is the route directly to Veliki Zep or is

3 there an intermediary node between the two?

4 A. No, it was direct. Just as the previous one. We used the

5 radio relay route from Sokolac to Strazbenica, and then we plugged it

6 into already existing channels from Strazbenica-Sokolac. We transferred

7 it to Crna Rijeka, that number from Sokolac.

8 JUDGE ORIE: Ms. Hasan, could I seek a clarification.

9 You said:

10 "And two FM-200 devices were used, one in Sokolac, one in

11 Strazbenica."

12 Was that operating in protected mode or unprotected note?

13 THE WITNESS: [Interpretation] Unprotected, analogue.

14 JUDGE ORIE: Thank you. Please proceed.

15 MS. HASAN:

16 Q. Now, the -- members of the United Nations who, for example, were

17 situated in Sarajevo, they weren't directly connected to the VRS's

18 radio relay network, were they?

19 A. I have no knowledge that they were connected.

20 Q. So if they wanted to reach the Main Staff at Crna Rijeka, they

21 would have call using a PTT line, at least initially?

22 A. That's probably what they did. I really don't know. It was

23 possible for them to do that. And along military lines, I don't know. I

24 didn't monitor these communications. I just maintained them. I don't

25 know whether there was a special channel for UNPROFOR.

Page 35874

1 Q. Do you know the frequency that the analogue FM-200 operated on

2 between Veliki Zep and Strazbenica?

3 A. I don't know off the cuff. It's probably from 610 to 960

4 megahertz. Within that range, you could select any frequency for

5 transmission. And I never tried to memorize these frequencies because

6 they were all on paper.

7 Q. So I take it then you also don't recall the frequency that

8 operated between Strazbenica and Sokolac?

9 A. No, I really don't remember that. I mean, I don't remember any

10 frequency, not only that particular one. I never needed to memorize

11 them. It was written on the device and it was written on a separate

12 piece of paper, so I never needed to remember them. All I know, it was

13 within that range.

14 Q. So someone from the United Nations calling from Sarajevo using a

15 PTT line, they would dial a particular phone number that would arrive,

16 for example, at the Sokolac PTT centre at which point their communication

17 to the Main Staff would enter the radio relay network and be transmitted

18 onwards?

19 A. Yes, that's correct. But I have to explain.

20 Apart from those PTT numbers from Sokolac which were at the

21 communications centre in my headquarters, there were PTT numbers from the

22 post office at Han Pijesak. Those telephones from the post office in

23 Han Pijesak are connected with a special cable to Crna Rijeka. They

24 didn't go along a radio relay route. They went along regular FM cables,

25 and they could dial personnel from the Main Staff and they could dial

Page 35875

1 personnel from the United Nations. I know for a fact that such numbers

2 existed at the post office in Han Pijesak and the post office in Sokolac

3 and the PTT in Belgrade.

4 Q. So somebody calling using a PTT line dialling the Han Pijesak PTT

5 centre would then be transmitted via cable to Crna Rijeka. It would not

6 pass over the radio relay network; right?

7 A. Yes, that's correct.

8 Q. But when the call is coming in to Sokolac PTT -- when the call is

9 coming in -- from Sokolac, it would enter the radio relay network to

10 finally arrive at Crna Rijeka, if I have understood you correctly?

11 A. Yes, correct.

12 Q. Have you been shown any intercepts by the Defence before you came

13 to testify here yesterday? Intercepts that were taken by the Bosnian

14 army or the Bosnian State Security Service.

15 A. They showed me some document, but I didn't know anything about

16 it. I had never seen them. If there were such things, it was -- they

17 were probably submitted to the chief of communications of the Main Staff.

18 During the war, I had never seen such documents, nor did I have any

19 knowledge or awareness about interception.

20 MS. HASAN: Your Honours, I'm told it's time for the break. I

21 don't know if you want to break at this point or given that

22 General Mladic is not in the courtroom, if we want to sit longer. I

23 leave that in your hands.

24 [Trial Chamber confers]

25 JUDGE ORIE: Since there is a chance that Mr. Mladic would join

Page 35876

1 us later, then I think it's preferable that we use our usual schedule as

2 if he were there. So that would mean time for the break.

3 Witness, we take a break. You may follow the usher and we'd like

4 to see you back in 20 minutes.

5 [The witness stands down]

6 JUDGE ORIE: We resume at ten minutes past 12.00.

7 --- Recess taken at 11.52 a.m.

8 --- On resuming at 12.14 p.m.

9 JUDGE ORIE: I have to personally apologise for the late start

10 after this break.

11 [Trial Chamber confers]

12 [The witness takes the stand]

13 JUDGE ORIE: Ms. Hasan, you may proceed.

14 MS. HASAN:

15 Q. Mr. Pajic, I'm going to show you a record of an intercepted

16 communication.

17 MS. HASAN: If we could take a look at P1207, and this is an

18 under-seal exhibit so it should not be broadcast.

19 Q. It's intercepted by the Bosnian State Security Service. And as

20 soon as we get the English. You can see there this is an intercept from

21 the 11th of July, 1995, a conversation that took place at 1800 hours.

22 And it's recorded in the header that they were monitoring the radio relay

23 in the Pale direction on frequency 836.000 megahertz, and they recorded a

24 conversation between General Gvero and General Gobillard.

25 Now in this particular conversation, General Gobillard, who

Page 35877

1 there's evidence is speaking from Sarajevo, could not be heard, that only

2 one participant -- participant's voice was audible. And let's just reads

3 the start of this -- of -- of this communication. So it's only recording

4 what General Gvero is saying. And it starts:

5 "General Mladic is in the field --"

6 And I should preface this by saying you will see that it appears

7 that is an operator speaking who then connects the call to General Gvero.

8 It will become apparent.

9 "General Mladic is in the field and he too is away.

10 "I can only put him through to General Gvero if he wants.

11 "Please.

12 "Hold on.

13 "Hello, this is Gvero.

14 "Who?

15 "Svetlana.

16 "My regards to you and General Gobillard."

17 Now, General Gobillard is speaking through an interpreter who we

18 understand to be the person named here as Svetlana. So this

19 communication, and I won't go into the contents of the rest of the

20 conversation, is a call that's put through General Gobillard from

21 Sarajevo through to General Gvero.

22 Now, can you tell us, this communication would have reached a PTT

23 centre, be it the number that Gobilliard dialled, whether it's the PTT

24 centre in Sokolac or Pale; correct?

25 A. First of all, I don't know what General Gobilliard used to call

Page 35878

1 from. And this is not a complete conversation, it's just one side

2 talking, so I don't know what the man used from where he called. There's

3 just some frequency here, 836 megahertz, and that is within that RRU

4 range. So the complete conversation is not there. I don't know what the

5 man used to call. Did he call from PTT? Did he call from a direct line?

6 I don't know. Because PTT numbers were also transferred when they were

7 taken from the civilian PTT telephone exchange.

8 Q. And when you're talking about the civilian PTT telephone

9 exchange, where is that located?

10 A. If it is Sokolac, then the post of Sokolac, if it's a civilian

11 number. I don't know where General Gobilliard was, what the location

12 was. So civilian PTT number from Sokolac. That was at the post office

13 Sokolac, and then the Strazbenica-Sokolac relay equipment was also at the

14 Sokolac post office.

15 Q. All right. And it's possible that -- now, like I said, there is

16 evidence in this case that General Gobilliard is calling from Sarajevo.

17 So would it also have -- then be possible that he dialled the number for

18 the Pale PTT centre to reach the Main Staff?

19 A. Possibly from a Pale PTT number one can call Sokolac PTT --

20 THE INTERPRETER: Interpreter's note: We did understand the rest

21 of the sentence. Could the speaker please speak clearly. Thank you.

22 MS. HASAN:

23 Q. You started off saying that it was possible that from the Pale

24 PTT number one can call the Sokolac PTT. So if a call comes into the

25 Pale PTT centre, a civilian PTT line, is it not entering the radio relay

Page 35879

1 network at that point on the route you spoke about before the break, the

2 radio relay route.

3 A. Well, yes, if he called from a civilian PTT Pale, but he called

4 the civilian PTT Sokolac that is at the location of Crna Rijeka and

5 Han Pijesak.

6 Q. Okay. Let me just make sure that I understand your evidence

7 correctly.

8 Are you independently saying you have knowledge that the UN call

9 coming in from Sarajevo would have necessarily have been a call coming

10 into the PTT Sokolac communications centre?

11 A. First of all, I don't know about this call at all. I mean, this

12 is the first time I'm seeing.

13 And the second thing, I've been telling you: If from a Pale PTT

14 number you're making a call, and if it's not part of the relay equipment,

15 and a Sokolac number that was installed, the PTT Sokolac number was

16 installed in Crna Rijeka, then that Sokolac number had to be in the

17 system of the radio relay equipment and as such had to be in Crna Rijeka

18 within this range.

19 Q. So the PTT centre in Pale, was that installed as -- I mean, was

20 that a connection that existed to Crna Rijeka? I mean, what I understood

21 you to have said, that when a call comes into Pale, that it gets into the

22 radio relay network and travels via Jahorina-Strazbenica-Veliki Zep and

23 then to Crna Rijeka.

24 A. Yes. If a Pale number is in --

25 THE INTERPRETER: Interpreter's note: Could the witness start

Page 35880

1 his answer again slowly and clearly. Thank you.

2 JUDGE ORIE: Could you restart slowly and clearly your answer.

3 THE WITNESS: [Interpretation] I'm saying that the PTT number that

4 existed in Crna Rijeka from Sokolac, it was transferred using the system

5 RRU FM-200 via Sokolac-Strazbenica-Crna Rijeka, so it exists in that

6 route. And man who calls from Pale from a telephone exchange, civilian

7 exchange, then he calls that number, it can be listened to at the

8 Sokolac-Strazbenica-Veliki Zep route. I mean, that conversation can be

9 heard. I mean, we've already said what is needed for intercepting that

10 conversation.

11 So let me explain this for you: Military equipment, radio relay

12 equipment, could have heard this call only within

13 Sokolac-Strazbenica-Veliki Zep because the Sokolac number that arrived in

14 Veliki Zep takes that route. I don't know if I've explained it to you.

15 I don't know how else to explain this to you.

16 JUDGE ORIE: May I take it this is an answer to your question,

17 Ms. Hasan?

18 MS. HASAN: Yes, it is. I'm --

19 JUDGE ORIE: Please proceed.

20 MS. HASAN:

21 Q. So then this communication was travelling on an open line to

22 Crna Rijeka?

23 A. To Veliki Zep radio relay system, and then it went down by cable

24 to Crna Rijeka; that is to say, it is an analogue relay throughout was

25 not protected. I've already said that individual channels can be

Page 35881

1 protected. Individual ones, not all of them. So, say, from 12 to 24.

2 In this case, I think it was 24 channels - in this case - not all of them

3 could have been protected individually or they were, if necessary.

4 And in order to listen in to an analogue unprotected

5 conversation, I've already explained what was needed in my previous

6 answer, and I have no knowledge of interception.

7 JUDGE ORIE: Witness, you tend to repeat things you had said

8 before. There's no need for that. I think the beginning of your answer

9 was clear, that it was a -- it travelled through an unprotected

10 radio relay system where only individual channels could be protected.

11 That's, in short, what I understood to be your answer.

12 Please proceed, Ms. Hasan.

13 MS. HASAN:

14 Q. Now if there's a civilian user who is calling from abroad, where

15 would the call have to travel, along what route for it to have been

16 captured -- to have been intercepted before reaching Crna Rijeka? So

17 what I'm interested in is the route of a communication -- of a telephone

18 call that was put in by someone who's calling from abroad, a civilian

19 caller. So let's start. The caller is on a -- on a civilian line and it

20 would arrive, I take it, at either the Sokolac PTT or the -- the Pale PTT

21 and then travel along the route you've described. Is that right?

22 A. Yes, it depends if a Sokolac number was called from the post of

23 Sokolac to Crna Rijeka. If from Pale, then the Pale route, if it is a

24 Pale PTT number.

25 Q. And in both instances, it's anyway passing through Strazbenica to

Page 35882

1 Veliki Zep; right?

2 A. Yes.

3 Q. So I'd like to look at another intercept now, and this is 65 ter

4 21062b, and this is an under seal intercept, and it's just an example I'd

5 like you to take a look at.

6 It's a communication intercepted by the State Security Service,

7 the Bosnian State Security Service, from the 17th of July, 1995. And you

8 will see in the header there:

9 "On that day, while monitoring the Pale axis on frequency 836.000

10 megahertz, channel 13, at 2340 hours, we recorded a conversation between

11 General Ratko Mladic and Milos Kostic, whom we did not hear."

12 Now, do you know at all what users were using channel 13 on that

13 frequency?

14 A. I'm not aware of any of this. I don't know Mr. Kostic. I don't

15 know this channel 13. I really don't know which radio route this is.

16 Q. All right. Do you -- now, here we only hear one side of the

17 conversation, and Milos Kostic is not heard at all. Are you familiar

18 with somebody by that name?

19 JUDGE ORIE: That question has been answered already, Ms. Hasan.

20 THE WITNESS: [Interpretation] No.

21 JUDGE ORIE: "I don't know Mr. Kostic."

22 MS. HASAN: I'm sorry. Thank you, Your Honours.

23 JUDGE ORIE: Please proceed.

24 MS. HASAN:

25 Q. Now it's our position, Witness, that on the 17th of July, and

Page 35883

1 there's evidence in this case, that General Mladic is in Crna Rijeka, and

2 it's our position that he's speaking to Milos Kostic, who we believe to

3 be in the United States.

4 So isn't this an example of what we've been talking about, which

5 is that Milos Kostic is calling from the United States using clearly a

6 civilian line, and that his call comes in either to Sokolac PTT centre or

7 Pale PTT centre, and he gets transferred along the path that you've

8 described to reach Crna Rijeka?

9 A. I've already said this is possible, but I'm telling you again I

10 don't know Kostic and I don't know which route was taken because I don't

11 know the number that the man used to call. I mean, there were different

12 numbers from different centres, so I cannot say now. It went along such

13 and such a route, this conversation.

14 JUDGE ORIE: Ms. Hasan, the witness is apparently not in a

15 position to say anything about it because you present the facts, whereas

16 we always expect the witness to present facts here, if this and if that,

17 if that is then, so the witness says he doesn't know.

18 MS. HASAN: Your Honour, I'm just trying to put our case to the

19 witness. Now, the fact that he doesn't know this particular

20 communication is not -- is not exactly what I'm getting at. I'm just

21 trying to establish along what routes must this call have gone through,

22 and I think he's already described the routes.

23 JUDGE ORIE: He has described the routes. You're telling that

24 he's calling from aboard. The witness doesn't know, so the witness is

25 not in a position to confirm anything.

Page 35884

1 MS. HASAN: And that's why --

2 JUDGE ORIE: But you could, of course, later argue that if

3 there's evidence that this person calls from abroad that it fits well in

4 the description given by this witness. But that's argument rather than

5 testimony of a witness of fact.

6 MS. HASAN: Your Honour --

7 JUDGE ORIE: Please proceed.

8 MS. HASAN: -- I'm just trying to get and I am putting a

9 hypothetical question to him: If he accepts the fact that someone is

10 calling from the United States, and I understand that that's a fact I'm

11 putting to him, along what path would that communication travel.

12 JUDGE ORIE: Please proceed.

13 MS. HASAN:

14 Q. So, Mr. Pajic, for this communication to have been intercepted,

15 and we see here it says on the Pale axis, and you've described to us the

16 route from Pale, that communication would have travelled along the route

17 you've already described to us to reach Crna Rijeka?

18 A. Let me tell you, in order to be able to confirm something I have

19 to know. I have to know from which number -- or rather which PTT number

20 was used by someone to call General Mladic. In this case, it was

21 General Mladic's Belgrade number. There was also a Han Pijesak number.

22 Then there was a number at the switchboard, the Sokolac PTT number. Now,

23 they all take different routes, and I cannot confirm that to you now; it

24 took such and such a route and could be listened to on such and such a

25 route.

Page 35885

1 So he had a civilian PTT number that came from a completely

2 different relay from Belgrade through Ser to Veliki Zep. The civilian

3 PTT number from Han Pijesak took a wire communication to the Main Staff

4 of the Army of Republika Srpska, and the PTT Sokolac number that took the

5 relay communication that I already described via --

6 Q. Can you just slow down. I know the interpreters are -- it looks

7 like they're keeping up, but I'm not.

8 JUDGE ORIE: Could I ask a simple question. Earlier a question

9 was asked about the civilian user calling from aboard, and then you said:

10 "Yes, it depends if a Sokolac number was called from the post of

11 Sokolac to Crna Rijeka. If from Pale, then the Pale route, if it is a

12 Pale PTT number."

13 And you confirmed that it's passing through the Strazbenica and

14 Veliki Zep, and you said, yes, that's how it happens. Would that be any

15 different if the person would be calling from the United States?

16 THE WITNESS: [Interpretation] Of course there's a difference. I

17 repeat once again: General Mladic had several civilian PTT numbers that

18 took different routes. So the civilian number in Belgrade that was

19 called most often came from Avala Cer to Veliki Zep. Then the civilian

20 number from Han Pijesak that took wire communication from Han Pijesak. I

21 don't know which number this call is coming from, from abroad. So all of

22 this was in Crna Rijeka but there were different routes that were taken

23 if they were from different telephone exchanges, Sokolac, Pale, Belgrade,

24 it doesn't matter. There was just Han Pijesak, Sokolac, and Belgrade.

25 JUDGE ORIE: Please proceed, Ms. Hasan.

Page 35886

1 MS. HASAN:

2 Q. Now, we have -- the Prosecution has spoken to

3 General Milovanovic, and we can call up 65 ter 32034 for the benefit of

4 the Defence and the Chamber, and he said that if someone is calling from

5 abroad, let's say, as the case that I just showed you, from the United

6 States, and if that person wanted to speak to General Mladic in

7 Belgrade --

8 JUDGE ORIE: If you would finish your question, then Mr. Ivetic

9 has an opportunity to object if he wishes.

10 MS. HASAN:

11 Q. Then his call, the call that's put in from the United States,

12 would have been connected to General Mladic in his apartment in Belgrade

13 via the FRY headquarters in Belgrade. Do you agree with that?

14 JUDGE ORIE: Mr. Ivetic.

15 MR. IVETIC: The number given by my colleague is not anything

16 related to Mr. Milovanovic, so I would ask for that to be clarified and

17 then perhaps -- I don't know if what she called up is something that is

18 identifiable or if we need a reference.

19 MS. HASAN: The number is 65 ter 32644.

20 MR. IVETIC: Then I would want on the record that we were not

21 disclosed this statement from a witness of [indiscernible].

22 MS. HASAN: I will just wait for Ms. Stewart to provide us with a

23 date on when this information report was disclosed.

24 JUDGE ORIE: Can we meanwhile -- I take it we can continue the --

25 your question and your observation is on the record.

Page 35887

1 Please proceed.

2 MS. HASAN:

3 Q. So, Mr. Pajic, do you need me to repeat the question? Do you

4 understand the question?

5 A. Repeat it once again.

6 Q. Okay. So do you agree with what General Milovanovic told us,

7 which is that if a caller was trying to reach General Mladic in his

8 apartment in Belgrade, that that call would have been connected to

9 General Mladic via the FRY headquarters in Belgrade? That's the route

10 that that call would have taken.

11 JUDGE FLUEGGE: Please scroll down in the English.

12 MS. HASAN: We can look at --

13 JUDGE ORIE: Mr. Ivetic is also on his feet.

14 MR. IVETIC: I think it might be the same thing. The question is

15 now being asked differently than was originally stated, as the

16 origination of the call.

17 MS. HASAN:

18 Q. The originator of the call, and I gave an example of the

19 United States, is calling from the United States -- a civilian from the

20 United States is trying to reach General Mladic in his apartment in

21 Belgrade.

22 What General Milovanovic told us is that call would have been

23 connected to General Mladic via the FRY headquarters in Belgrade. Do you

24 agree with that?

25 A. I don't know who was calling General Mladic to Belgrade but that

Page 35888

1 person had the number where General Mladic could be reached. Why would

2 he call at Crna Rijeka? The PTT number coming from Belgrade went along

3 the route Avala Ser --

4 JUDGE ORIE: Witness, I stop you. You may have not clearly

5 understood the question. Ms. Hasan, I leave it in your hands.

6 We are not specifically talking about this conversation any

7 further but about what General Milovanovic told in an interview.

8 Ms. Hasan.

9 MS. HASAN:

10 Q. Okay. So I think I have your answer which is what also

11 General Milovanovic explained to us, which is that call would not have

12 been connected via the RS territory through the radio relay network in

13 the RS territory. If -- if -- if the civilian user is reaching Mladic in

14 Belgrade, it's going directly to Belgrade, not through the RS to

15 Belgrade. You agree with that?

16 A. Yes.

17 Q. And what General Milovanovic went on to tell us is that a

18 civilian user calling from abroad who's trying to reach Mladic in

19 Crna Rijeka when, in fact, Mladic is in Belgrade, that that person would

20 not have been put through by an operator to Belgrade. Do you agree with

21 that? And let me be clear: That an operator from Crna Rijeka would not

22 have connected the civilian user to Belgrade to enable him to -- him or

23 her to reach General Mladic.

24 A. In this case, no.

25 Q. And that's because there were security implications for --

Page 35889

1 related to revealing General Mladic's whereabouts; isn't that right?

2 A. When he was staying in Belgrade, he had some sort of PTT number

3 where he could be reached at all times, and that's where people called

4 him.

5 Q. So it would be incumbent on the civilian user who is trying to

6 reach General Mladic to call directly Belgrade and reach him there?

7 A. He received information from the ADC of General Mladic in

8 Crna Rijeka and then that person would dial General Mladic at the given

9 number.

10 Q. And who is the ADC?

11 A. Captain Rajko Banduka.

12 Q. So Captain Rajko Banduka would be the person who would then

13 decide whether to reveal to the -- to the user who is calling that Mladic

14 is in Belgrade? But he would tell him to call Belgrade, the Belgrade

15 number, if at all.

16 A. That's probably what General Mladic himself would tell him when

17 he decided which call to accept, which not, I suppose.

18 Q. Now, if Mladic was in Belgrade, okay, and General Mladic is

19 calling from a PTT line in Belgrade, and he's trying to reach the duty

20 officer at Crna Rijeka, so not -- I'm not talking about Captain Rajko

21 Banduka but the duty officer, can you tell us how that call would be

22 connected?

23 A. There was a radio relay communications between the Main Staff of

24 the VRS and the General Staff of the Army of Yugoslavia. There was one

25 protected and one unprotected. There was no problem for him to call

Page 35890

1 anyone at the General Staff in Belgrade through the military switchboard

2 in Belgrade.

3 MS. HASAN: Can we take a look at Exhibit P1655, and this is an

4 under seal exhibit.

5 And Ms. Stewart advises me that the information report was

6 disclosed in disclosure batch 119, which was a DVD that was placed in the

7 Defence's locker on Friday, the 15th of May, 2015.

8 Q. So this is an intercept, and this shouldn't be broadcast. Again,

9 it's a state security intercepted communication, and the communication

10 date is 16 July 1995. And the header reads:

11 "On the above date, monitoring the Pale radio relay on frequency

12 836.000 megahertz, channel 13, at 1615 hours, we recorded a conversation

13 between the duty officer in the Main Staff and General Mladic, who was

14 inaudible."

15 So, again, this is another example where only one side of the

16 communication -- one of the participants was heard.

17 Now, the Defence and the Prosecution agree that, at this time,

18 1615 hours, General Mladic was in Belgrade. So this is General Mladic in

19 Belgrade speaking to the Main Staff's duty officer, who sits in

20 Crna Rijeka; isn't that right?

21 A. Well, if General Mladic was in Belgrade and he was talking with

22 the duty operations officer in Crna Rijeka or whoever, and this was

23 intercepted at some section in Pale, it's impossible. Because there was

24 a route directed from Veliki Zep through Cer towards Belgrade and you

25 could hear only one side of the conversation. First of all, I'm not

Page 35891

1 familiar with this conversation. Second, Pale has nothing to do with it

2 nor the Pale radio relay route. It has nothing do with this conversation

3 between Belgrade and the Main Staff.

4 Let me repeat: This is the section Veliki Zep via Cer which is

5 in Serbia, and Mount Avala, outside Belgrade. If this was intercepted

6 and the intercepter claims that this was along the Pale radio relay

7 route, that's nonsense.

8 Where is the other side of the conversation? Where is the entire

9 conversation so we can confirm some things?

10 Q. We're not -- for this purpose, it's -- we're not interested in

11 the entire conversation but we're just interested in -- in the routes

12 here.

13 So, now, if General Mladic is calling from a PTT line, let's say

14 General Mladic is calling from his apartment or, for example, from the

15 VMA, so he is using a civilian PTT line, can you tell us the routes that

16 his call would travel? And can you start -- start at the beginning. So

17 his PTT line would arrive where?

18 A. If General Mladic would use a PTT number in Belgrade where you

19 claim he was would call Crna Rijeka on a PTT number, he had, in his own

20 office with the ADC Banduka, a civilian PTT number. So from his PTT

21 number in Belgrade, he could call the PTT number in his own office. This

22 one, this route was Veliki Zep-Cer-Avala. Mladic had no need to call in

23 any other direction. In Belgrade, he had only the PTT number. With

24 other numbers, he could communicate using the manual, normal switchboard.

25 Why would he call in Crna Rijeka a different civilian number when he had

Page 35892

1 his own?

2 Q. Now if he's calling using that -- his own civilian number, that

3 communication would not have been intercepted; right? I mean,

4 theoretically the wirelines may have been intercepted but let's just keep

5 it to the radio relay.

6 A. That's a radio relay connection. Let me repeat once more:

7 Mladic had a civilian number in his office in Han Pijesak, and when he

8 called that number from Belgrade, it would go from Veliki Zep to Avala.

9 It's the system SMC-1306B. Although it's analogue, it's perfectly safe.

10 You cannot -- you have to mount an incredible amount of equipment in

11 order to listen into that, and I explained to you already how close the

12 intercepter would have to be to both stations. In this situation, that

13 was impossible.

14 Q. And the manual -- the normal switchboard you're talking about is

15 located where?

16 A. That switchboard, I already explained when we were discussing the

17 switch, that was room number 1 in the underground part of the

18 installation. Room marked 1A.

19 Q. Okay. So if he's calling trying to reach the switchboard to then

20 be connected to the duty officer in Crna Rijeka, his communication is

21 travelling over the radio relay network; isn't that correct?

22 A. At any rate, it has to go through a radio relay connection

23 although it's in Belgrade, and he has several possibilities. He has the

24 option to call from his apartment in Belgrade from his PTT number. He

25 could call the PTT number which is in the switchboard in the exchange of

Page 35893

1 the General Staff in Belgrade, and they could directly transfer him to my

2 telephone exchange in Crna Rijeka. That connection still exists,

3 although I don't believe it went that way.

4 My telephone exchange - that is, the exchange of the Main Staff -

5 had a direct protected connection with the exchange of the General Staff

6 of the Army of Yugoslavia in Belgrade. He could make telephone calls

7 that way. And that's what he normally did. He usually -- I mean, he

8 exclusively used secure lines when he was calling from Belgrade.

9 Although it doesn't mean that he couldn't use the other option.

10 Q. And in respect of the other option, you -- were there several

11 possibilities for that communication travelling to Crna Rijeka?

12 A. You know, the communication system is a very large system. There

13 are a number of options. He used mainly these two. He mainly used

14 secure lines, and communications were operating, of course. There were

15 connections with all the corps. The exchanges of the corps were

16 connected to the Main Staff, of course, and they had both analogue and

17 digital connections, each corps did.

18 Q. The connection that existed between Cer and Veliki Zep, okay,

19 that segment, there was an SMC-1306B operating along that route; right?

20 A. Yes. We had two radio relay routes with Cer, that is, to

21 Belgrade. One was --

22 THE INTERPRETER: Could the witness be asked again to slow down.

23 THE WITNESS: [No interpretation]

24 JUDGE MOLOTO: Witness, the interpreters asked that you slow

25 down, please.

Page 35894

1 [Trial Chamber and Registrar confer]

2 THE WITNESS: [Interpretation] I'm sorry. I really forget myself.

3 MS. HASAN:

4 Q. Could you repeat your answer. You started off saying:

5 "We had two radio relay routes with Cer, that is, to Belgrade.

6 One was ..."

7 A. [No interpretation]

8 JUDGE ORIE: We don't receive interpretation at this moment on

9 the English channel.

10 Could you restart your answer on from the beginning.

11 THE WITNESS: [Interpretation] Towards Cer, that is to say

12 Belgrade, the communication was along two radio relay connections. One

13 was a digital or protected one, and the number of that route was 0719.

14 The second relay route also towards Cer and on towards Avala, Belgrade,

15 was 1058. That was its number. And the device used was SMC-1306B. And

16 the entire route was protected; that is to say, 0719, but towards Avala,

17 the number was 7001.

18 MS. HASAN:

19 Q. From Cer to Veliki Zep, there was a backup RRU-800 operating,

20 wasn't there?

21 A. That device was in the process of preparation. It never worked.

22 But in case of air strikes or the SMC device broke down, that device was

23 planned to be activated.

24 Q. Okay.

25 [Prosecution counsel confer]

Page 35895

1 MS. HASAN: Your Honours, I'm just going to review my notes to

2 see how much more I need to go through.

3 Q. So a communication travelling on that RRU-800 from Cer to

4 Veliki Zep, we agree that that would have been an open line that could

5 have been intercepted?

6 MR. IVETIC: Objection. That misstates the evidence. The

7 witness clearly said at line 7 it never worked, so ...

8 MS. HASAN: I can rephrase my question.

9 JUDGE ORIE: Please do so.

10 MS. HASAN:

11 Q. That line -- should that RRU-800 have been operating from Cer to

12 Veliki Zep, that would have been an open line that could have been

13 intercepted; correct?

14 A. In this case, that would be the analogue unprotected route. But

15 let me repeat once again. That was a backup piece of equipment. That

16 device was never used. It was just there in -- if SMC broke down.

17 JUDGE ORIE: There's no need to repeat that. Ms. Hasan was just

18 inquiring to the kind of line it would have been if operational.

19 THE WITNESS: Okay.

20 [Prosecution counsel confer]

21 MS. HASAN: Okay. Could we take a look at P1655 and -- I'm

22 sorry, P1658, please, and this is another under seal exhibit.

23 Q. And this is, Mr. Pajic, an intercepted communication on the same

24 date, on the 16th of July, and it's a communication between

25 General Mladic and a Kostic, at 2250 hours. It's intercepted on the same

Page 35896

1 frequency, 836.000 megahertz, on the Pale axis.

2 Now, can we turn to page 2 in the English to see the relevant

3 intercept. So the one we're interested in is -- you can see it there,

4 number 672, the communication on the bottom half of this document.

5 Now you previously told us that if a civilian was trying to reach

6 General Mladic at Crna Rijeka and General Mladic was not present at

7 Crna Rijeka but was present at Belgrade, that his call would not have

8 travelled through the RS radio relay network but rather he would either

9 have been not connected at all or he would have been given a number to

10 reach General Mladic directly in Belgrade.

11 So my question to you is that this communication which comes into

12 a civilian telephone line and is intercepted on the radio relay network,

13 necessarily meant that General Mladic was within the RS territory and not

14 in Belgrade?

15 A. In this case, I don't know where General Mladic was. You can't

16 see it from this document. There is some kind of intercept, but I don't

17 know at which number they were looking for him. It makes a big

18 difference on which number he was called, if it was a civilian number.

19 These people from aboard, let me repeat, called me at the civilian PTT

20 number that was located with his ADC in Crna Rijeka, and 90 per cent of

21 those communications went through his ADC. He almost never used the

22 manual switchboard. Banduka can confirm that. All his conversations

23 with UNPROFOR, with foreign countries, et cetera, went through his

24 civilian PTT number in Belgrade. And that one enters the radio relay

25 communications from Belgrade at Avala, that is, through Cer, to

Page 35897

1 Veliki Zep.

2 Q. I understand your answer and what you're saying. My question is

3 a little bit the reverse of what your saying, which is: Kostic calling

4 from the United States, and that's a fact I'm putting to you, I'm asking

5 you to accept that Kostic is calling from abroad, his call is coming in

6 and is being intercepted in the radio relay network of the RS. And what

7 you had told us before is that a civilian calling, trying to reach

8 General Mladic, would not have travelled -- would not have been -- sorry.

9 He would not have been put through to General Mladic over the radio relay

10 network but rather he would have either been told where General Mladic

11 is, if that was the decision made, and told to directly contact him in

12 Belgrade, therefore bypassing the radio relay network in the RS and

13 making it impossible to intercept that call. Do you agree?

14 A. I agree, if somebody is calling General Mladic at a civilian

15 number in Belgrade instead of his civilian Belgrade number located in his

16 office.

17 JUDGE ORIE: Witness, could I ask you one question. Do I

18 understand that -- what route it took to get through to General Mladic

19 depended on what the caller would choose as the number he wished to

20 reach, whether that was a Belgrade number or whether that was a number at

21 Crna Rijeka?

22 THE WITNESS: Okay.

23 JUDGE ORIE: So if -- yes, that's not on the record. I heard you

24 whispering "okay." Is that what I heard? Is that accurate?

25 THE WITNESS: [Interpretation] Yes, you understood that.

Page 35898

1 JUDGE ORIE: So if you wanted to choose to reach him in

2 Crna Rijeka, you would dial the number and that would be -- that would

3 travel over the radio relay system. If you wished to call him in

4 Belgrade, you would choose another number and that would not travel over

5 the radio relay system in Republika Srpska. Is that well understood?

6 THE WITNESS: [Interpretation] Yes.

7 JUDGE ORIE: Please proceed.

8 [Prosecution counsel confer]

9 MS. HASAN: Your Honours, it's about five minutes to the break.

10 If you would allow us to take the break early, I'll reassess what I have

11 left and I may have a few questions left or none at all.

12 JUDGE ORIE: Then before we do so, Mr. Ivetic, I don't know --

13 let's just assume that Ms. Hasan would need anything between five and ten

14 minutes for a few questions or no questions at all, how much time would

15 you need? And I'm asking this so that Mr. Stojanovic can consult with

16 Mr. Mladic as to what he prefers to do at this moment.

17 MR. IVETIC: We're on the same page. That's what I thought. I

18 have about 10 to 12 minutes right now.

19 JUDGE ORIE: That means that we most likely would start the

20 testimony of the next witness still today. Yes.

21 Then we take the break.

22 Mr. Pajic, you heard that most likely you will be excused later

23 on today. We'd like to see you back in 20 minutes.

24 We'll resume at 25 minutes to 2.00, and I assure you that I will

25 not have to make apologies again for a late start.

Page 35899

1 [The witness stands down]

2 --- Recess taken at 1.13 p.m.

3 --- On resuming at 1.35 p.m.

4 JUDGE ORIE: Ms. Hasan.

5 [Prosecution counsel confer]

6 JUDGE ORIE: Ms. Hasan, have you made up your mind? Should

7 Mr. Ivetic already prepare or should he wait for another second?

8 MS. HASAN: I'll just have a few questions.

9 JUDGE ORIE: Yes.

10 MS. HASAN: Thank you.

11 [Trial Chamber confers]

12 [The witness takes the stand]

13 JUDGE ORIE: Please proceed, Ms. Hasan.

14 MS. HASAN: Could we take a look at 65 ter 05923b, please.

15 Q. You'll see, Mr. Pajic, that this is the Main Staff of the Army of

16 Republika Srpska phonebook. It's dated August 1995.

17 MS. HASAN: And if we turn to page 2 in both the English and

18 B/C/S, Your Honours, this is an excerpt from the complete phonebook.

19 Q. We see the page which lists a number of phone numbers for the

20 Main Staff, starting with other telephone -- automatic telephone

21 exchanges connected to G-1 automatic telephone exchange. And it lists

22 there a number -- phone numbers for various PTT centres, automatic

23 telephone exchanges. And is my understanding correct: That 011 was

24 the -- the number you had to call before dialing a Belgrade phone?

25 A. Well, this number, 011 199 208, if you're calling a Belgrade

Page 35900

1 number, you just directly dial the six-digit or seven-digit number in

2 Belgrade. You don't need the city code 011.

3 Q. So if you're calling Belgrade PTT automatic telephone exchange

4 from the RS you would have to dial the complete number, right, including

5 the code, 011?

6 A. No. I've told you: If you call a civilian PTT number in

7 Belgrade, you don't need to dial 011 from Crna Rijeka, if you're calling

8 this first number on this list. From this number, you directly dial any

9 other number in Belgrade. You don't need to use the city code, 011. I

10 don't know if you're understanding that.

11 JUDGE ORIE: I have one follow-up question. Wouldn't that depend

12 on from where you call?

13 THE WITNESS: [Interpretation] It doesn't matter. You can call

14 from anywhere, if it's this number; Han Pijesak, Banja Luka, anywhere.

15 If it that's number, then you don't have to dial 011. That is an

16 existing Belgrade number that is installed there through relay channels.

17 You are not going into a different network. You are dealing within the

18 same network, the 011 network. The Belgrade network.

19 I don't know if you understand what I'm saying now?

20 JUDGE ORIE: If you're calling from the 011 network, you don't

21 have to dial it. If you call from outside the 011 network, you would

22 have to dial the full number?

23 THE WITNESS: [Interpretation] For example, if you are dialling

24 this telephone -- if you're calling from this number in Crna Rijeka, if

25 you're calling this other number, then you need to use the area code 071

Page 35901

1 and then the six-digit number. But if you're calling from that Belgrade

2 network number another Belgrade network number, then you don't need the

3 area code.

4 JUDGE ORIE: That's standard for all countries, I think.

5 Please proceed.

6 JUDGE MOLOTO: And Crna Rijeka was in the 011 network? Was Crna

7 Rijeka in the same network as 011?

8 THE WITNESS: [Interpretation] No. Crna Rijeka was not in that

9 network. It was only that Belgrade number that was in Crna Rijeka that

10 was. 011 199 208. That number belonged to the Belgrade network.

11 JUDGE MOLOTO: Thank you. I understand now.

12 MS. HASAN:

13 Q. And we see just below that the numbers that one would have to

14 dial to reach the PTT centre in Sokolac?

15 A. No, you don't have to dial anything. You take the receiver and

16 you call 868-042, you hear the signal from the Sokolac PTT. You can dial

17 any number in Sokolac. You can do that for Han Pijesak and Pale. For

18 all these numbers where the area code is 071, you don't have to do

19 anything. You just lift the receiver. So that number was at the

20 switchboard in Crna Rijeka.

21 Q. All right. I think we're in agreement on that. Now you see

22 below it says: Other automatic telephone exchanges connected to the

23 operations centre, and we see military automatic telephone exchange with

24 G-1. And there's an extension there, 153. You recall that extension?

25 A. You see where it says military ATC from G-1, 153, you lift the

Page 35902

1 receiver and you dial another three-digit number. It depends where

2 because they were practically at all the switchboards of all the corps,

3 so you can choose any number that is at the hand-held switchboard at G-1.

4 You can dial any number outside Crna Rijeka that was connected to other

5 corps.

6 JUDGE ORIE: Witness, the question was whether you remember that

7 number, 153.

8 THE WITNESS: [Interpretation] No, this is in the operations

9 centre. In the operations centre -- well, I've forgotten the exact

10 number already, but that is what is written here. Operations centre is

11 the duty officer --

12 JUDGE ORIE: Yes, could you please focus your answer very much on

13 the questions. We'd like to have you excused till today and by focusing

14 your answer on the questions, that would help.

15 Please proceed, Ms. Hasan.

16 MS. HASAN:

17 Q. If I was calling from the Drina Corps switchboard, for example,

18 and I wanted to reach the military automatic telephone exchange at G-1,

19 what number would I dial?

20 A. I don't know whether you registered it yesterday, the three-digit

21 ATC was 332 at the exchange in the Drina Corps, and it went along a

22 protected channel. I don't know if you noticed that. I explained that

23 yesterday and I said which channels were protected. So 332, number 332

24 for the same switchboard was for the --

25 JUDGE ORIE: What is the number you'd have to dial? Don't tell

Page 35903

1 us about what connections protected or not. What number would you have

2 to dial from the -- the Drina Corps switchboard?

3 THE WITNESS: [Interpretation] If you want to reach 153, if you

4 want the telephone switchboard three 2s or 9. I don't know what they

5 want. I don't know what they're selecting. So operations centre 153,

6 the telephone exchange, 222 or 9.

7 JUDGE ORIE: Please proceed, Ms. Hasan.

8 MS. HASAN: Can we turn the page in both the English and -- well,

9 in the English first.

10 Q. And we now see under the heading "Commander," military automatic

11 telephone exchange with G-1, 161.

12 And so that I understand correctly, I mean, this is a phone book,

13 so if I want to reach the commander of the Main Staff, am I to dial one

14 of these numbers that's listed here?

15 A. Depends which number you're calling from. If it's the three

16 digit switchboard, then you call this first number, if you're calling

17 from the G-1 switchboard.

18 Q. Right. So -- and we see that in order to reach General Mladic,

19 we see that he's got a protected -- one protected military line which is

20 a -- a Belgrade military -- from the Belgrade military automatic

21 telephone exchange, as well as from Belgrade he's got a protected

22 civilian PTT line and the numbers are provided there. Does that accord

23 with your recollection?

24 A. Civilian PTT line.

25 THE INTERPRETER: Interpreter's note: We cannot follow at this

Page 35904

1 speed.

2 JUDGE ORIE: Could you slow down and start your answer again.

3 THE WITNESS: [Interpretation] What is written here is Belgrade

4 ATC, 22-984. That was a military five-digit number in Belgrade. It is a

5 number that General Mladic had in Crna Rijeka in his office there. It's

6 a protected number.

7 MS. HASAN:

8 Q. And that's -- we see it says protected there under Belgrade PTT,

9 so that's -- that's also a protected line; right? And that's what you

10 remember, there was --

11 A. I don't see a translation here on the right-hand side, and over

12 here I cannot see it on the left-hand side.

13 JUDGE ORIE: Witness, it may be that we have to move to the next

14 page -- no, we are on the right page. One second. Yes.

15 Could you look at the -- the -- the -- where it says "commander"

16 and then the following four lines. You see that?

17 THE WITNESS: [Interpretation] I do, I do.

18 JUDGE ORIE: And do you also see the Belgrade PTT - protected?

19 THE WITNESS: [Interpretation] Yes.

20 JUDGE ORIE: Please proceed.

21 MS. HASAN:

22 Q. And so these two -- these two lines are designated protected.

23 Now, the military automatic telephone exchange with G-1, you would --

24 we're not talking here about a protected line, so to speak; right?

25 A. Well, it cannot be a protected line since it was from

Page 35905

1 General Mladic's office to the switchboard 20 metres from Vila Javor to

2 the underground office. That was 20 or 30 metres of cable.

3 JUDGE ORIE: Well, then, Witness, it is an internal line and

4 therefore needs no protection. Is that what you want to say?

5 THE WITNESS: [Interpretation] Your Honour, I just want to explain

6 this here. It says here protected, for both numbers, because they come

7 along this route from Belgrade --

8 JUDGE ORIE: Witness, I was focusing on the military ATC with

9 G-1, 161. That's an internal line. It's just another connection

10 internally and therefore needs no protection. Is that understood?

11 THE WITNESS: [Interpretation] Internal line, yes, if

12 General Mladic is not using it. However, as he is dialling some other

13 number from that number, that is, within the Drina Corps, then he has to

14 use a protected line.

15 JUDGE ORIE: Yes, I understand that.

16 Next question, please, Ms. Hasan.

17 MS. HASAN:

18 Q. Can you then explain the fourth number down there, Pale PTT

19 automatic telephone exchange, 071 783-371 [sic]. Sorry, I'll repeat

20 that: 071 783-375. Could you explain how that connected to

21 General Mladic?

22 A. I don't know why it's not written here. It also went through

23 0601 to Pale. It was also a protected line. This is a Pale number,

24 783-375. It took the protected route:

25 Veliki Zep-Ravna Romanija-Kalovita Brda and down there to Pale and then

Page 35906

1 we brought this number that way to Crna Rijeka.

2 Q. And you previously told us that that route was also unprotected?

3 A. Not that route. I said that this one was protected, 0601 -- no,

4 sorry, 0661. Sorry. That was protected. Whereas, this is the analogue

5 one that I was speaking about that goes through Strazbenica-Jahorina to

6 Pale, and specifically this number, 06 -- no, 783-375, it took 0661.

7 This is a protected route: Veliki Zep-Ravno Romanija-Kalovita Brda-Pale.

8 Q. And you have no explanation why that's not designated protected

9 as the two phone numbers before that are?

10 A. I don't know really who made this telephone book. It was

11 omitted. I didn't make this.

12 MS. HASAN: Your Honours, I'd offer 65 ter 5923b into evidence.

13 JUDGE ORIE: Madam Registrar.

14 THE REGISTRAR: Your Honours, the document will receive number

15 P7396.

16 JUDGE ORIE: P7396 is admitted.

17 MS. HASAN: Nothing further, Your Honours.

18 JUDGE ORIE: Thank you, Ms. Hasan.

19 Mr. Ivetic.

20 MS. HASAN: Your Honours, sorry. Ms. Stewart reminds that I

21 didn't tender 65 ter 21062b. This was the intercept dated 17 July at

22 2340 hours.

23 JUDGE ORIE: Madam Registrar.

24 THE REGISTRAR: Your Honours, the document receives number P7397.

25 JUDGE ORIE: P7397 is admitted.