Tribunal Criminal Tribunal for the Former Yugoslavia

Page 4552

1 Monday, 27 November 2006

2 [Open session]

3 [The accused entered court]

4 --- Upon commencing at 9.03 a.m.

5 JUDGE AGIUS: So Madam Registrar, good morning to you. Could you

6 kindly call the case, please.

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

8 IT-05-88-T, the Prosecutor versus Vujadin Popovic et al.

9 JUDGE AGIUS: Thank you. Everyone is here except Mr. Bourgon.

10 Prosecution we have Mr. McCloskey back, and Mr. Thayer and Mr. Vanderpuye.

11 You would have noticed this morning that we are missing Judge --

12 Reserve Judge Stole. That will happen again tomorrow. So we will be

13 invoking the provisions of Rule 15 bis and proceeding accordingly in his

14 absence.

15 We had left unfinished the matter of tendering of documents,

16 Mr. Thayer.

17 MR. THAYER: Yes, Mr. President. Good morning to you and Your

18 Honours.

19 JUDGE AGIUS: Let me see, because I think my secretary --

20 MR. THAYER: I -- I think under the press of time, Your Honour, we

21 had pretty much held up the exhibit list and asked generally if there were

22 any objections. There is one modification with respect to PIC00040, and

23 that would be the Prosecution's request to place that under seal. And

24 that is the third exhibit up from the bottom of the list, Mr. President.

25 JUDGE AGIUS: You need to refresh our memory of what that document

Page 4553

1 is.

2 MR. THAYER: Yes. That is the B/C/S version of the intercept

3 dated 14 July 1995 at 2102 hours marked by the witness during his

4 testimony on 22 November.

5 JUDGE AGIUS: And you want it under seal?

6 MR. THAYER: Yes, Your Honour.

7 JUDGE AGIUS: And there is an objection?

8 MR. THAYER: No, there is not, but we had not indicated that we

9 wished to place that under seal on that exhibit list previously.

10 JUDGE AGIUS: Okay. I heard the word objection.

11 Madam Registrar is drawing our attention to the fact that that may

12 be also the case of putting under seal also the next two documents, 41 and

13 42 from the notebook.

14 MR. THAYER: That would be a good idea, Your Honour, out of an

15 abundance of caution.

16 JUDGE AGIUS: Yes, Mr. Ostojic.

17 MR. OSTOJIC: Good morning, Mr. President and Your Honours.

18 JUDGE AGIUS: Good morning to you.

19 MR. OSTOJIC: I'm just not sure why we are placing it under seal.

20 The three pages that are at issue are IC00040, 41, and 42. 42 is the only

21 one that bears a signature apparently of the protected witness; the other

22 two pages do not. They were just markings. I would just like to know the

23 basis of why he wishes that the two pages that do not bear any signature,

24 why they require that to be under seal.

25 JUDGE AGIUS: Mr. Thayer. If we see them -- if we see them it

Page 4554

1 will help us understand better, if we have a look at them. I mean, I

2 suppose they can be easily found.

3 MR. THAYER: Again, they are PIC00040.

4 JUDGE AGIUS: The thing is -- I think my memory is coming back.

5 We are talking of this same intercept in all three cases to start with,

6 and that intercept is signed, I think, if I remember well, by the witness.

7 So irrespective of whether you're referring to one or more parts of it, if

8 you leave the end part -- or if you leave the entire document or parts of

9 it not under seal, anyone can make two and two together, refer to the

10 intercept by date and time, because we have date and time, and be able to

11 trace it back to the -- to the witness, because there is the -- his

12 signature at the end of it. This is what I mean.

13 I have 40. Say if we put only 40 under seal, okay, the rest of

14 the evidence which is not in private session and which refers to that

15 document would ultimately reveal his identity. So I think the whole --

16 the whole statement -- or the whole intercept should be under seal that

17 whole intercept.

18 MR. OSTOJIC: I don't want to belabour the point, but I thought it

19 was in open session when I questioned this witness on the first two pages,

20 and only the third page bears the witnesses signature, so I'm not sure how

21 with in excess of 140 logbooks but I just wanted to know the basis for

22 it. If that's what it is, we'll accept that.

23 JUDGE AGIUS: Questioning him and answering questions on that

24 document is one thing. Making the document available is another. In

25 other words, the testimony in open session as it relates to that document

Page 4555

1 provided that document is kept under seal is harmless. It won't expose

2 his identity. While if in -- you let parts of that document be available

3 to the public, then his handwriting is made available, his name could be

4 made available. So it's putting -- putting the jigsaw together that could

5 identify. So I think it's better to play it safe and have it -- have it

6 under seal.

7 [Trial Chamber confers]

8 JUDGE AGIUS: Okay. Yes, let's put it all -- the entire document

9 under seal, please.

10 You have the list. You told me last Friday that this -- the list

11 of intended exhibits was handed to you. Is there any objection from any

12 of the Defence teams, please?

13 [Trial Chamber confers]

14 JUDGE AGIUS: Yes, Mr. Zivanovic.

15 MR. ZIVANOVIC: [Interpretation] Thank you, Your Honour.

16 We have sent a list of documents to the Bench. These are

17 documents that we used during cross-examination of the previous witness.

18 I don't think there's any need for me to repeat the documents again

19 because you have them in written form.

20 Thank you.

21 JUDGE AGIUS: Thank you. Is there any objection on the

22 Prosecution's part?

23 MR. THAYER: Your Honour, unfortunately we've not received that

24 list.

25 JUDGE AGIUS: It was around last Friday. I'm sure you have

Page 4556

1 received it, because it was circulating last Friday.

2 MR. THAYER: Is it just the list of exhibits that were used now

3 being offered as tendered? Okay. I understand now.

4 JUDGE AGIUS: I know it was circulated last Friday and my

5 impression is that it crossed the floor. Okay. But it shouldn't be

6 difficult.

7 Let's give you our decision. In view of the general objection

8 that has been raised by the Defence teams as to the admissibility of

9 intercepts, all intercepts that are being sought to be tendered following

10 the testimony of the gentleman we had with us last week, instead of being

11 admitted now will be marked for identification along the lines that we

12 explained to you when we first started the trial. Ultimately, eventually

13 we will decide on their admissibility, the final admissibility or not.

14 So I don't think we need, Madam Registrar, to waste time to

15 identify which is an intercept and which is not. I think you can do that,

16 and you can receive assistance, I suppose, from the Prosecution and then

17 check it out which the parties.

18 That applies both ways, because you have also made use, of course,

19 of some of these intercepts, but that will not be held against you

20 because -- because you have this general objection. So -- but all

21 intercepts will be marked for identification for the time being. All

22 right? Understood.

23 All right. Yes, Mr. Thayer.

24 MR. THAYER: Your Honour, I'm sorry. One just -- just one matter

25 of clarification. If you take a look at the Prosecution's list of

Page 4557

1 exhibits to tender, given our prior discussion I just wanted to make clear

2 that with respect to P01164, it is the entire packet that the Prosecution

3 seeks to place under seal for the same reasons that Your Honour just

4 pointed out, in addition to the final printout also bearing his name in

5 typed form. The way it's printed here might just be a little misleading

6 in that it may seem to go to that last printout incept or we intend or we

7 seek to admit the entire packet under seal. I just wanted to make that

8 clear.

9 JUDGE AGIUS: That's clear enough.

10 [Trial Chamber confers]

11 JUDGE AGIUS: Okay. I think we can close this matter here. It

12 stands to reason that all other exhibits which are not intercepts coming

13 from both sides are hereby admitted.

14 Yes. I noticed Madam Nikolic first.

15 MS. NIKOLIC: [Interpretation] Good morning, Your Honours.

16 JUDGE AGIUS: Good morning.

17 MS. NIKOLIC: [Interpretation] There is one document which remains

18 unclear to me whether the Prosecution tendered it. This is P02312. This

19 is a set of working reports that were presented to the witness during

20 examination. This document is not contained on the exhibit list for this

21 witness. It was added during the examination-in-chief of the witness.

22 In the course of our cross-examination, I used page 20 of the

23 document. I would like to tender the document or, rather, the page into

24 evidence. However, if my learned friend wishes to tender the entire

25 document, then there is no need for me to do this.

Page 4558

1 Thank you.

2 JUDGE AGIUS: Madam Nikolic, I think if -- at least in the list

3 that I have, that I was given -- that we were given last Friday, it is

4 there. It's between -- it's the last one before the IC PIC documents.

5 MS. NIKOLIC: [Interpretation] It is possible, because I don't have

6 the -- my notes from Friday here. 2308 is the last document according to

7 myself, to my notes. If that's correct, then --

8 JUDGE AGIUS: There's also P02312. All right? So that settles

9 the matter.

10 I had recognised Mr. Ostojic.

11 MR. OSTOJIC: Thank you, Mr. President.

12 With respect to the packet of printed materials, it was my

13 understanding that the Court requested that the Prosecution also provide

14 prior dates in addition to the one -- the 15th, because only the 14th was

15 there. So I would object only on the grounds that I haven't -- maybe

16 they've produced it, but I haven't seen that yet. So in accordance with

17 that.

18 And also just for clarification if the Court -- although you say

19 we tender -- will accept, admit all documents, we specifically just want

20 to clarify for the record that we wanted Exhibit 2D38 admitted and also

21 Exhibit which was previously marked as 3D31 and now I think we call it by

22 the new name 2D3D31, which is the May 1999 information sheet from the

23 Office of the Prosecutor.

24 JUDGE AGIUS: All right. I take it there is no objection.

25 MR. THAYER: There is no objection, Your Honour.

Page 4559

1 JUDGE AGIUS: As regards the other, you said the Trial Chamber

2 requested. We didn't request. We asked Mr. McCloskey at the time whether

3 he thought it would be more helpful if he brought all -- along also the

4 13th July intercepts if they existed, and he did say that he was trying to

5 get them over, but I don't think we can -- yes. I don't think that we can

6 say we requested them, and I don't think that there was an undertaking,

7 specific undertaking on the part of the Prosecution which rather

8 acknowledged at the time that this could be more confusing. I couldn't

9 see how it could be more confusing, but Mr. McCloskey, on the eve of

10 Thanksgiving, thought it was confusing. Yes.

11 MR. THAYER: Your Honour, I think at the time that -- that that

12 offer was -- was brought up again, frankly it appeared that we'd all

13 suffered enough with the exposition with P02312.

14 We do have the -- the packet for the 13th available, and we can

15 make it available to the Bench.

16 JUDGE AGIUS: But I don't think --

17 MR. THAYER: I think that ship has sailed, frankly, Your Honour,

18 but we do have it.

19 JUDGE AGIUS: The three of us don't think it is necessary at this

20 stage.

21 So the other two documents that have been mentioned by

22 Mr. Ostojic, of course, are also -- also admitted.

23 JUDGE KWON: And this packet is being translated, isn't it? 2312.

24 JUDGE AGIUS: 2312.

25 MR. THAYER: We -- we haven't submitted it in its entirety but --

Page 4560

1 because the substance of the intercepts wasn't at issue. If there are

2 portions that were discussed during the testimony, of course we will make

3 those -- we will have those translated. If the Court wishes the entire

4 packet to be translated, then we can of course submit it for translation.

5 [Trial Chamber confers]

6 JUDGE AGIUS: Okay. Let's try to simplify it. What we need

7 translated is in -- in each case from these typed transcripts in B/C/S we

8 need translated the material at the top above the line and the material

9 immediately following beneath the line before the actual transcript

10 begins. All right? For example, in the first one you have the indication

11 of the megahertz, the channel, and the time. Then you have "Pravac - JI,"

12 and "UCC:XY." That's all we need to have translated. But it will -- you

13 need to cover that through the entire document.

14 For example, in the second one beneath the line there is also the

15 words "very urgent" on the right. We need to have those reproduced, not

16 translated, and so on.

17 Have you understood? Yes.

18 MR. THAYER: I believe I've understood you well, Your Honour.

19 JUDGE AGIUS: Okay. Thanks. Thanks a lot.

20 Thank you, Judge Kwon.

21 Can we -- is there any preliminary business you wish to raise?

22 Mr. McCloskey.

23 MR. McCLOSKEY: Yes. Good morning, Mr. President and everyone.

24 JUDGE AGIUS: Good morning.

25 MR. McCLOSKEY: I just wanted to make a -- make a motion, it's a

Page 4561

1 joint motion that the Defence and the Prosecution are all very much

2 together on, and that is that the week of February -- Monday,

3 February 12th be a week off for us to be able to organise ourselves and

4 catch our breath. That will be important, because it is our plan to bring

5 in the expert archaeologists and anthropologists and pathologists on the

6 week of February 19th and they're coming from all over the world. So

7 having a good idea of an exact time and some time to prepare for that

8 would be helpful, and I know the Defence would like this time as well.

9 And it's important for our scheduling purposes. We're scheduling

10 enough in advance and we need to know which week -- and these weeks, as

11 you know, have been very helpful for everyone because everyone has been

12 working very hard. And in fact we would look to March even for our

13 scheduling purposes, and the Defence joins this also, that the week of

14 Monday, March 26th would also be a good week to take. That would be the

15 next 30 days after this break.

16 JUDGE AGIUS: So I take it this has already been sort of discussed

17 and agreed upon by the two sides. We do appreciate that you have been

18 working very hard, both of you, both Prosecution and Defence, and that as

19 we had indicated in the beginning of the trial, we are -- we are conscious

20 that periodically there will be required some time off for reorganising

21 the ranks. But let us think about it and we'll come back to you in the

22 day or latest tomorrow.

23 [Trial Chamber confers]

24 JUDGE AGIUS: I understand that the week of the 25th of March is

25 required by -- 26th of March is required by the Defence. Can any one

Page 4562

1 spokesman for the Defence at least indicate what the reason is?

2 MR. OSTOJIC: I'm not sure, Your Honour, if this is the precise

3 reason. I think when we met with Mr. McCloskey we were scheduling

4 approximately 4 to 6 weeks, and anticipating that the 12th would be

5 granted we just looked into March, and then he said, "What do you think

6 about March?" And we picked the last week in March. There was nothing

7 more specific than that with respect to that scheduling. We just wanted

8 it to be 4 to 6 weeks from the last break. That was basically our logic

9 in that.

10 JUDGE AGIUS: Okay. I thank you.

11 And you confirm this, Mr. McCloskey?

12 MR. McCLOSKEY: Yes, Mr. President. And I think the logic in some

13 of -- there was some family issues, children and things.

14 JUDGE AGIUS: All right. Thank you. We'll come back to you, as I

15 stated. We need to discuss that amongst ourselves.

16 So can we bring in the witness.

17 No. I think I need to explain to the general public that we are

18 drawing the curtains down for the time being because we are bringing in a

19 protected witness, so you cannot see him entering the courtroom, but after

20 that we'll lift -- and we'll soon be in open session again very soon.

21 [Closed session]

22 (redacted)

23 (redacted)

24 [Open session]

25 JUDGE AGIUS: I think you can lift the curtains, Madam Usher,

Page 4563

1 please.

2 Thank you, Mr. Josse.


4 [Witness answered through interpreter]

5 JUDGE AGIUS: Good morning to you, sir, and welcome to this

6 Tribunal and to this case which deals with the events in Srebrenica in

7 July of 1995. You are about to start giving evidence, but before you do

8 so our rules require that you make a solemn declaration undertaking to

9 testify to the truth. The text is being handed to you. Please read it

10 out aloud and that will be your undertaking with us.

11 THE WITNESS: [Interpretation] I solemnly declare that I will speak

12 the truth, the whole truth, and nothing but the truth.

13 JUDGE AGIUS: Please make yourself comfortable. Take a seat.

14 I suppose you are aware that we have put in place by way of

15 protecting your identity three protective measures, namely, the use of a

16 pseudonym instead of your real name, and you are going to be referred to

17 as PW-131 - is that correct, 131? - and we are also -- we have also put

18 in place both visual and voice distortion. I suppose this has been

19 explained to you by the Victims and Witnesses Unit. What I would like to

20 know if this is so and, secondly, whether this is to your satisfaction.

21 THE WITNESS: [Interpretation] [No interpretation].

22 JUDGE AGIUS: Okay. You have to speak into that special

23 microphone that you have in front of you as we go along. There will be

24 moments that we will go in private session. In other words, what is being

25 said will only be heard inside this courtroom and not beyond its walls,

Page 4564

1 but we'll try to limit that as much as possible.

2 Mr. Vanderpuye will go first. He will then be cross-examined

3 by -- you will then be cross-examined by the various Defence teams. You

4 have given testimony already in other proceedings, and Mr. Vanderpuye will

5 be dealing with that matter in the beginning of his intervention.

6 Yes, Mr. Vanderpuye, he's all yours.

7 MR. VANDERPUYE: Good morning, Mr. President, Your Honours, ladies

8 and gentlemen.

9 JUDGE AGIUS: Good morning. Could you also tell us -- give us an

10 indication of how long you expect to be examining your witness?

11 MR. VANDERPUYE: Well, Your Honour, I would estimate somewhere in

12 the neighbourhood of about an hour and half to maybe two hours. I had

13 intended to follow up on certain issues identified by the witness's prior

14 testimony that I think are relevant to these proceedings and will be

15 helpful to the Court in its determination of these issues.

16 JUDGE AGIUS: Just an indication.

17 And, Madam Registrar, have you obtained from the Defence teams an

18 indication of how long they expect? If -- perhaps Mr. Zivanovic can deal

19 with that. If you can circulate a piece of paper and then let us know.

20 Give -- have an indication so that we can plan for the rest of the week.

21 In the meantime, I think we can start, Mr. Vanderpuye.

22 MR. VANDERPUYE: Yes, Mr. President. I also wanted to indicate to

23 the Court that I had intended at some point during the further examination

24 of this witness to use a map. It's a physical map, rather big. I don't

25 believe that there's an exact replica on e-court. I think part of it is

Page 4565

1 in e-court. But I just wanted to use it for demonstrative purposes in

2 order to assist the Court and also the witness in terms of conveying some

3 relevant aspects of his testimony.

4 The other thing that I would like to bring to the Court's

5 attention is that the transcript of the witness's prior testimony refers

6 to certain exhibits. The exhibits were not tendered in relation to that

7 testimony, but I had intended to offer them with respect to his testimony

8 here today. I don't know whether or not Defence has an objection to that,

9 but that would be the -- the idea.

10 JUDGE AGIUS: I hear no objection, so I understand we can proceed

11 along those lines.

12 MR. VANDERPUYE: Very well.

13 JUDGE AGIUS: Thank you.

14 MR. VANDERPUYE: If I may begin.

15 JUDGE AGIUS: Yes. The sooner the better.

16 MR. VANDERPUYE: Thank you very much.

17 Madam Usher, please show the witness the pseudonym sheet, please.

18 Examination by Mr. Vanderpuye:

19 Q. Sir, please have a look at that document, P0230 -- P02310. Have a

20 look at that, and without telling us what's on the document, can you tell

21 us whether or not you're the person named in it?

22 A. Yes. It contains my name and PW-131.

23 JUDGE AGIUS: [Previous translation continues] ... reminding me

24 that you have your microphone on. It should be off when the witness is

25 speaking. So just to make sure, I just don't like taking risks, we block

Page 4566

1 the transmission of this last part, this very last minute or few seconds

2 before I intervened. Just the transmission, that's all.

3 Please be careful, all of us, not to keep the microphone on when

4 the witness is speaking.

5 MR. VANDERPUYE: For the purposes of the 92 ter procedure, I would

6 like to read a summary of the witness's prior testimony and for that I

7 would ask if we can perhaps go into private session because it deals with

8 a lot of sensitive issues.

9 JUDGE AGIUS: All right. Let's go into private session for a

10 short while. Thank you.

11 [Private session]

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 4567











11 Pages 4567-4577 redacted. Private session















Page 4578

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 [Open session]

15 JUDGE AGIUS: We are in open session.

16 Thank you, Mr. Vanderpuye.


18 Q. Can you tell the Court what type of equipment was used in your

19 unit?

20 A. Your Honours, we had absolutely no military equipment. That is to

21 say, that all of the equipment was procured through friendly contacts,

22 through friends. So we mostly had civilian equipment from radio amateur

23 clubs, ham radio clubs. We would take that equipment, make some

24 adjustments, and then use it for our purposes, which turned out to be

25 quite useful. Initially we had several RUP 12 devices used by companies

Page 4579

1 or platoons. It was very difficult to use them because the system for

2 surveillance using them is quite complicated. So our resources were

3 really pitiful.

4 As I told you earlier, we had absolutely no resources to follow

5 civilian communications which go above 900 or 1000 megahertz.

6 Q. Do you recall, for example, what types of transceivers were

7 employed in the unit in and around 1995?

8 A. Yes, I do remember. Those were mostly devices produced by

9 Collins, JVC and others.

10 Q. In addition to the technical equipment, did you use physical

11 tapes?

12 A. Yes. The situation was a bit unusual regarding the tapes. Since

13 all of the channels for procuring equipment had been shut down, most of

14 our tapes originated from Radio Tuzla station, which means that they had

15 been in use for over 10 years, maybe even more. I remember that it was

16 only in 1996 that we received the first set containing 10 tapes.

17 In addition, recording devices, UHER, at the time used only by

18 journalists were the ones that we received from radio stations in Tuzla,

19 Lukavac, Banovici, wherever we were able to find them. We didn't have a

20 single military piece of equipment in our unit. We constructed all of the

21 antennas by ourselves from traffic signs, plastic sewage pipes, using

22 copper. That's what we used.

23 Q. You'd indicated before that some modifications were made to the

24 radio equipment in order to -- in order that they be used effectively.

25 Can you tell us what those modifications were, if you know?

Page 4580

1 A. Buying the equipment that had been procured before the war in the

2 civilian world, all ham radio equipment had only a certain range within

3 which they functioned. Military frequencies had a different range, a

4 totally different range. So we would make a simple modification,

5 adjustment, and we would expand the band, thus adjusting these pieces of

6 equipment to military frequencies.

7 In this case, we did it so that we could follow communications on

8 RRU 800, which used exclusively analogue system. It was very easy to

9 follow these communications. Then we also used this for a newer piece of

10 equipment, RRU 1, which was also easy to monitor, and a piece of equipment

11 known as HVT, FM-200.

12 Similarly, we made modifications on antennas to make adjustments

13 for certain ranges. Initially we used just plain TV antennas. Later on,

14 we constructed more flexible antennas that could cover a broader range.

15 People doing this did it for two reasons. In order to defend

16 themselves; that was the first reason. And the other reason, let me to be

17 frank again, in order not to go into combat. They had to produce a

18 valuable result so that they wouldn't be sent to combat. After all, they

19 were much safer. Their lives were much safer in these facilities than at

20 the front. Whoever worked there was either a ham radio operator or

21 somebody who did that in the former JNA.

22 I always used to say that it would have been better for the JNA

23 and VRS to have used civilian communications than the ones that they

24 actually used, because that technology was over 30 years old. This means

25 that they had certain protected or encrypted channels, but they used it

Page 4581

1 infrequently mostly, and we were unable to follow that.

2 Q. Well, in terms of the capabilities of the unit, and maybe you'll

3 correct me if I'm wrong, are you suggesting that the unit didn't have the

4 capacity to monitor these civilian lines of communication?

5 A. Yes. Given that the SMC pieces of equipment mostly used by

6 civilians and during wartime - sometimes the army used it too - we were

7 unable to monitor those frequencies because we were unable to make

8 modifications on our equipment in order for it to be used on these

9 frequencies, because they used a different technical approach. It's a bit

10 complicated for me to explain it to you, but let me just say that the ham

11 radio equipment that we had was not capable of monitoring these

12 frequencies.

13 Q. With respect to the frequencies that you were capable of

14 monitoring, did the VRS engage in tactics in order to avoid having these

15 communications intercepted, such as terrain masking or things of that

16 nature?

17 A. From my point of view, this is something that should have existed

18 in all armies. The advantage we had -- what gave us the advantage is that

19 they had precisely that type of equipment.

20 In addition, ABiH army also had the advantage of not possessing

21 any equipment. Otherwise, they would have been monitoring our

22 communications too.

23 Officers at lower levels mostly abided by radio communication

24 regulations, whereas higher-level officers disregarded them. And it was

25 precisely from these persons that we gathered most of our data. They

Page 4582

1 probably only looked towards the end of the war, and they never tried to

2 conceal their goals.

3 Q. When you say they never tried to conceal their goals, can I ask

4 you, in your experience did the VRS broadcast, for example, at minimum

5 power from these relay stations, or did they broadcast it more than what

6 was necessary in order to relay a given communication?

7 A. The army of Republika Srpska used to the maximum radio relay

8 communications, especially when it came to combat operations, in which

9 case they used RRU 1, which was transportable easily. They could go

10 anywhere where they did not have an energy supply and install it there.

11 In this case, they installed this radio relay equipment in

12 Pribicevac above Srebrenica in January of 1995. They installed it in the

13 middle of a forest, and they planned to do something. We were able to

14 uncover this quite soon.

15 Q. In general, can you tell us whether or not your unit --

16 MR. VANDERPUYE: Can we go into private session for a moment?

17 JUDGE AGIUS: Certainly, Mr. Vanderpuye.

18 Private session, please.

19 [Private session]

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 4583











11 Page 4583-4584 redacted. Private session















Page 4585

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 [Open session]


19 Q. Did your unit have any relationship with the 21st Division of the

20 ABiH?

21 A. In the command sense we had absolutely no links with them. We had

22 nothing to do with the 21st Division.

23 As for cooperation, yes, we did cooperate, but we never used the

24 same equipment. They sent all of their reports to the command of the

25 21st Division. Their first and main task was to monitor communications of

Page 4586

1 the army of Republika Srpska in the part of Bosnia called Posavina. That

2 is to say, from Modrica to Bijeljina.

3 Q. Was there any overlap between the area that that unit covered

4 versus the area that yours covered?

5 A. Certainly. We had horizontal coordination. For example, if

6 something came up near Olovo or, say, in Srebrenica, we would ask for

7 assistance from that same unit, because we had, for example, one piece of

8 equipment, one UHER, and we could only follow one channel with it. That

9 was the regular procedure.

10 I'm trying to bring your attention to the fact that in addition to

11 the platoon and the 21st Division we had platoons in other divisions,

12 24th, 22nd, 25th Division, and they all covered certain areas.

13 Q. Was there any sharing of information or intercepts between your

14 unit and the 21st?

15 A. Yes. As I said a bit earlier, it was a regular procedure. For

16 example, we would say, "We're interested in the channel, in this

17 particular channel. Can you give us this information?" And since we were

18 quite close, if we were busy working on one channel, we would tell

19 them, "Why don't you monitor this other channel?"

20 MR. VANDERPUYE: Can we go into private session for one second?

21 JUDGE AGIUS: Certainly. Let's go into private session for a

22 while.

23 [Private session]

24 (redacted)

25 (redacted)

Page 4587

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 [Open session]

11 MR. VANDERPUYE: It's actually a perfect time.

12 JUDGE AGIUS: We'll have a 30-minute break starting from now.

13 --- Recess taken at 10.29 a.m.

14 --- On resuming at 11.05 a.m.

15 JUDGE AGIUS: So we are in open session. We have the map stuck to

16 the screen. You also said previously, Mr. Vanderpuye, that at least part

17 of it is on e-court. It may become important to have it available in that

18 manner as well, because we will be able at least to zoom into parts of it.

19 All right. You may proceed. Thank you.

20 MR. VANDERPUYE: Thank you, Mr. President.

21 My information is actually the entire map is on e-court. It's

22 just enormous and takes a tremendous amount of time to load, and my

23 suggestion was at some point maybe to refer to a smaller area of it so as

24 to make it more convenient for everybody.

25 JUDGE AGIUS: We can always -- let's be practical about it. If

Page 4588

1 that is the case, we can always have copies made of the interesting parts

2 of that map which we can put on the ELMO, and we can zoom in on those as

3 well, or put those selected parts on e-court in addition to what we have

4 already, and we can utilise that facility better then. All right?

5 MR. VANDERPUYE: Thank you, Mr. President.

6 JUDGE AGIUS: Thank you.


8 Q. Good afternoon -- good morning. Good morning, Mr. Witness. Could

9 you tell us with respect to the work protocol at your unit, during the

10 course of actually transcribing an intercept was it the case that more

11 than one person could or would listen to a given communication?

12 JUDGE AGIUS: Your mic.

13 THE WITNESS: [Interpretation] Yes. Under the work protocol there,

14 was the possibility for one person to listening in to a conversation or

15 for several persons to listen in. The latter method served to make sure

16 that you did not miss out on something, and it also depended on the way

17 the people worked. (redacted)

18 (redacted)

19 JUDGE AGIUS: We need to redact this last sentence, please.

20 Witness, please. I mean, I don't need to stay repeating this.

21 Please refrain from mentioning the names of any of the sites, please.

22 MR. VANDERPUYE: Thank you, Mr. President.

23 Q. Did you -- did you have the ability to receive or -- receive

24 corroborative information with respect to the intercepts that were being

25 taken down or transcribed within your unit?

Page 4589

1 A. Well, this may be a bit difficult to explain. However, the

2 situation on the ground indicated -- or, rather, proved the veracity of

3 these conversations. We knew of every attack by the VRS ahead of time.

4 We were able to confirm the information received through the events on the

5 ground.

6 Q. With respect to the intercept operators that were working at

7 the -- working within the unit, were you aware of whether or not or to

8 what degree their prior training had been or they had received?

9 A. For the most part the people coming into the unit were ham radio

10 operators or persons who were engaged in these activities in the JNA. We

11 provided some degree of training at the workplace, and these people had to

12 meet certain requirements. There had to have been a recommendation to the

13 effect that a given person was specialised in that activity.

14 In my unit I had top-notch mathematicians, mechanical engineers,

15 and there were people coming from different backgrounds.

16 Q. With respect to the organisation of the unit, were platoon

17 commanders trained intercept operators?

18 A. Every platoon commander, in addition to holding that post, was an

19 operator and did the job just as all the other persons did. That person

20 would coordinate the work taking place in a room. If one frequency was

21 occupied, then he would instruct another operator to go on and monitor

22 another frequency.

23 Q. And in terms of the monitoring of frequencies, as long as we're

24 talking about that, by what authority, if any, were given frequencies

25 monitored within the unit?

Page 4590

1 A. Every job of work was done on the basis of an order. Orders

2 specified in detail the zones to be intercepted from one facility and the

3 zones to be intercepted by another facility. On the basis of the

4 information, the unit command decided whether a facility was to assist in

5 intercepting communications. For instance, if the communications to be

6 intercepted took place in the south, then we decided which facility would

7 be covering that, whether that would be the one in the north. For

8 instance, our facility in the north had consistent tasks to cover

9 communications ranging from Banja Luka all the way down to Zvornik,

10 whereas the facility in the south was to cover the communications from

11 Zvornik all the way down to Rogatica or Han Pijesak in the south. That

12 was their basic task.

13 Q. Well, did the platoon commanders assist other intercept operators

14 in either the analysis or transcription of particular or given

15 communications?

16 A. Yes. Every commander was the first filter for data analysis.

17 They had their aide-memoires where they would write down the features of a

18 communication, the persons participating in it, and the contents. Let me

19 point out that at no point in time did the -- one commander know which

20 communications were being intercepted at the other facility and

21 vice versa. These processes were kept quite separate.

22 Q. In terms of data analysis, did these commanders help in the

23 identification of persons, locations, resources, things of those -- things

24 of that nature that was -- were the subject of a given intercept

25 communication?

Page 4591

1 A. Yes, of course. This was auxiliary material helping us in our

2 work without which we would not have been able to work properly or draw

3 proper conclusions.

4 In addition the intercepting activities, every commander would

5 have a given time to search the bands. The first and foremost task was to

6 designate a code-name for all the activities and to fill in all the gaps.

7 For instance, participants in the communications. We knew who Panorama 1,

8 Panorama 2, or Panorama 3 were. What posed the greatest difficulty to us

9 was when these code-names changed.

10 In addition to that, all the members of the unit and department

11 were well aware of the features of every person, what sort of accents they

12 used who were their most frequent contents, what the names of their

13 children and wife were, who answered the phone for them, and every person

14 had a dossier which contained only the data collected through monitoring.

15 Q. Now, when you refer to this body of information and the data, is

16 that -- well, was that information available to intercept operators

17 working within your unit for the purposes of analysis and processing,

18 et cetera?

19 A. Naturally. These lads had been doing the job for three years.

20 They were on top of what they were doing, and they had no trouble

21 recognising and identifying persons. What's more, they would work

22 together and, if need be, they would listen to the tape for 20 times, time

23 and again, in order to recognise the person. We weren't interested so

24 much in who was speaking as we were in what they were talking about. This

25 was the next point. We were supposed to accurately convey the words

Page 4592

1 uttered, i.e., the information obtained.

2 Q. With respect to the development of the information that was relied

3 upon by the intercept operators in performing their function, were there

4 meetings that were held with regard to the development or analysis of this

5 information?

6 A. Within the unit we carried out a series of analyses. One analysis

7 was taking place in all the facilities every 10 days where the main focus

8 of the forthcoming period was designated, as were the activities. We also

9 had a small analysis section within our unit at our facility, and we held

10 briefings once weekly.

11 There were persons whose only job was to enter features of

12 certain -- or attributes of certain persons and other information

13 concerning these persons for days, so that we were able to uncover their

14 chain of command simply on the basis of intercepting these conversations.

15 We knew which person hid behind which number.

16 Q. Now, you'd indicated that part of the information that was

17 developed in part by your unit included the code-names for certain

18 locations; is that right?

19 A. Yes. This was the first and main task we had, to -- to uncover

20 the location, unit, or a person behind a certain code-name.

21 Q. With respect to the reliability of the information that was

22 developed by your unit, can you tell us what the unit's responsibility to

23 the headquarters was in terms of the timeliness of the information that

24 was conveyed?

25 A. I wouldn't wish to discuss the reliability of information. I told

Page 4593

1 you already that our main task was to accurately convey the information

2 recorded. We provided our assessment of reliability at our level, which

3 was then double-checked at a higher level, at the corps command. In view

4 of the events that had transpired in the previous three years, we were

5 able to assess what the actual events on the grounds would be.

6 Q. Now, you mentioned that the information that was conveyed by your

7 unit was double-checked at the corps command. May I ask, did you ever

8 receive any complaints or concerns with respect to the information that

9 was furnished by your unit?

10 A. As far as I remember, I never received any complaints or concerns.

11 Quite the contrary. We were commended for our work.

12 MR. VANDERPUYE: May I go into private session for a moment,

13 Mr. President?

14 [Private session]

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 4594

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 4595

1 [Open session]


3 Q. Certain information was sent from your unit to the higher command

4 in Tuzla, and you've indicated that that information was then analysed a

5 second time. And could you tell us, if you know, was that particular

6 analysis done by a dedicated unit?

7 A. As I've said already, the first analysis was done within the unit

8 by drawing upon -- on the information received through intercepting alone.

9 The next step of analysis was done in the intelligence department where

10 they got information from elsewhere, from captured persons and informants,

11 and all the information converged to this one point.

12 Q. Now, with respect to the information that was conveyed by your

13 unit to the higher command, was that information conveyed electronically?

14 A. The information from both facilities, once they were produced in

15 their final form on the computer, was sent on through a protected radio

16 package. From the north facility we had the wire device, whereas we did

17 not have one in the southern facility, and that's why the paket

18 communication was used on a daily basis with encryption.

19 Q. With respected to the sending of encrypted information, was

20 that -- was that done by a person that was qualified within the unit to do

21 so?

22 A. Yes. We had a communications platoon as part of our unit. The

23 persons manning this package system had to go through special training and

24 they had to take an oath, a confidentiality oath, and persons holding such

25 qualifications would be sent to apposite facilities. They had their own

Page 4596

1 rooms to which only the platoon commander and other authorised persons had

2 access.

3 Q. With respect to the information that they sent, the electronic

4 information, I should be more specific, are you familiar with how that

5 information is sent from the site to the headquarters?

6 A. Of course I'm familiar with that. First of all, we would receive

7 from the superior command every month a key, a password for every day, and

8 only the information obtained on a given date could be sent, passed on on

9 that same day. So that all the information typed out in the original form

10 was sent encoded to the relevant organ in Tuzla.

11 Q. With respect to the information that was typed out and sent, can

12 you tell us where that information was derived from?

13 A. For the most part the information received was typed out from

14 notebooks that were previously filled up by listening to the taped reels.

15 This was hard work and time-consuming, but we didn't have any other

16 working method.

17 Q. Now, the notebooks that you're referring to, are those otherwise

18 known as daily logs?

19 A. These were just ordinary notebooks. Every such station should by

20 its structure have a station logbook, but we didn't have such formats of

21 logs because they were in short supply. We had to use regular notebooks.

22 Quite a few such notebooks were actually incinerated because there had

23 been no obligation to store these notebooks for a given time. They would

24 be disposed of as soon as the information from them had been conveyed onto

25 a computer. We were in the middle of a forest. We also needed firewood.

Page 4597

1 THE INTERPRETER: Interpreter's correction: "In the middle of a

2 mountain."


4 Q. With respect to the notebooks in particular, can you tell us who,

5 if anyone, was responsible for distributing and/or collecting these

6 notebooks?

7 A. I've already said there was no requirement by law to save those

8 notebooks.

9 The procedure was as follows: Whenever there was a shift working

10 in a facility, we would bring paginated, new notebooks. We would take

11 those that had been filled up and take them back to the unit command.

12 Q. With respect to tapes, reel-to-reel tapes, can you tell us what

13 the procedure was with respect to that?

14 A. Reel tapes presented the greatest problem for us, for the simple

15 reason that we were isolated for three years. We were unable to procure

16 reels, and we had a short supply of them. So as soon as they were

17 recorded, we would take them to Tuzla where there was a unit which would

18 listen to the tapes. Let me just remind you that in order to hear one

19 tape, one side only, one needed four hours.

20 Listening to the conversations they would set aside those which in

21 their view were important. Then they erased those tapes and sent blank

22 tapes back to the unit. Occasionally, due to the volume of work, they had

23 no time to erase them, so that the tapes would be sent back to the

24 facility with the original material still recorded on them.

25 Q. Can you tell us who was responsible for collecting and/or

Page 4598

1 distributing the tapes?

2 A. It was mostly I who was present when each shift came. I would

3 distribute tapes. I would assign tasks and convey those that we had

4 received from the superior command. I did that unless I had some other

5 business to attend to.

6 MR. VANDERPUYE: May we go into private session for a moment?

7 JUDGE AGIUS: Certainly. Let's go into private session for a

8 while, please.

9 [Private session]

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 4599











11 Pages 4599-4601 redacted. Private session















Page 4602

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 [Open session]

7 MR. VANDERPUYE: I would at this point like to have 65 ter number

8 1072 shown to the witness following the procedure prescribed by Your

9 Honour. That's fine just where it is.

10 Q. Can you see that, Mr. Witness?

11 A. Yes.

12 Q. Can I draw your attention to what is designated number 3 on that

13 page?

14 A. It says: "Annex number 3, review of diskettes 1.44 Mb with data

15 collected by electronic reconnaissance of communications. Seven pieces."

16 Q. Now, was that information that was turned over by your unit to the

17 Office of the Prosecutor on the date that's indicated on the top of that

18 document of 13 December 2000?

19 A. Yes.

20 Q. And did you compile that information?

21 A. Yes.

22 Q. And is the information relating to what's on the diskettes

23 consistent with and in addition to the information that was furnished back

24 in May of 1999 in the form of two diskettes?

25 A. Yes. The diskettes accompanied logbooks and reports printed on

Page 4603

1 printers.

2 Q. Now, with respect to the information or even the physical items

3 that were turned over to the Office of the Prosecutor, did you assist in

4 preparing those items or furnishing those items to the Office of the

5 Prosecutor?

6 A. On behalf of the chief of G-2, I was tasked with handing over this

7 material related to electronic surveillance data.

8 Q. You'd indicated -- it appears from the transcript that you've

9 indicated that the diskettes accompanied logbooks and reports printed on

10 printers. I see that on page 51; I think it's line 12 and 13.

11 Let me just ask: The reference to logbooks, are you talking about

12 logbooks separate and apart from the notebooks or inclusive of the

13 notebooks?

14 A. Logbooks are actually notebooks, one and the same thing.

15 Q. Okay. Thank you.

16 JUDGE AGIUS: Mr. Ostojic.

17 MR. OSTOJIC: I apologise for interrupting, Your Honour, but my

18 learned friend referenced page 51, line 12, which starts really with a

19 question, and I don't know if we got an answer to the last question. It

20 would seem to be an answer that they're one and the same thing, but I

21 think the question was whether they were included with the diskettes or

22 not in this chain of custody issue.

23 JUDGE AGIUS: I think the witness said logbooks are actually

24 notebooks, one and the same thing. So I think he's provided an answer.

25 MR. OSTOJIC: I followed that part. The question -- if I may, the

Page 4604

1 question I thought was whether the logbooks or notebooks accompanied the

2 diskettes, and we were examining this exhibit in front of us which talks

3 about these diskettes. I don't think that he answered.

4 JUDGE AGIUS: No. I don't read it the same way as you do, but

5 I'll block this and go back to his question, to Mr. Vanderpuye's question.

6 You've indicated, it appears -- from the transcript that you've

7 indicated that the diskettes accompanied logbooks and reports printed on

8 printers. I see that on page 51; I think it's lines 12 and 13. Let me

9 just ask -- now we come to the question. Let me just ask: The reference

10 to logbooks, are you talking about logbooks separate and apart of the

11 notebooks or inclusive of the notebooks?

12 And his answer was: Logbooks are actually notebooks, one and the

13 same thing.

14 So I -- we don't have any problem with it, Mr. Ostojic.

15 JUDGE KWON: Line 12 and 13 is the answer of the witness.

16 JUDGE AGIUS: Go ahead.

17 MR. VANDERPUYE: Thank you, Mr. President. At this point I wanted

18 the witness to reference specific information that's on the map. We're in

19 open session, right? Can we go to private session for a moment?

20 JUDGE AGIUS: Yes. Let's go to private session for a short while.

21 [Private session]

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 4605

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 (redacted)

10 (redacted)

11 (redacted)

12 (redacted)

13 (redacted)

14 (redacted)

15 (redacted)

16 (redacted)

17 (redacted)

18 (redacted)

19 (redacted)

20 (redacted)

21 (redacted)

22 (redacted)

23 (redacted)

24 (redacted)

25 (redacted)

Page 4606

1 (redacted)

2 (redacted)

3 (redacted)

4 (redacted)

5 (redacted)

6 (redacted)

7 (redacted)

8 (redacted)

9 [Open session]

10 JUDGE AGIUS: So we are back in open session.

11 The witness will be asked to indicate some locations on the map

12 which is on the screen behind him.

13 MR. VANDERPUYE: Okay. Okay.

14 Q. Mr. Witness, could you please -- well, first let me ask you: How

15 is it that this map came into existence?

16 A. This map was created in 1998. It was created by me and my

17 colleagues based on the analyses performed from 1995, because at that time

18 we had an analysis performed every month in writing. So it was sufficient

19 for us to take the piece of paper. We knew the location. We knew

20 everything else. We just needed to copy down frequencies, code-names, and

21 which communications were operative at which times.

22 Q. Did you create this map for the benefit of the Office of the

23 Prosecutor?

24 A. Yes.

25 Q. And is the information that's contained in the map information

Page 4607

1 that you had at your disposal in 1995?

2 A. Yes.

3 Q. And was that the source of the information that was used to create

4 the map?

5 A. Yes.

6 Q. Okay. I guess just for the record the map has a 65 ter number,

7 1468.

8 And I would ask the witness at this time to tell us a little bit

9 about the map, if you would. Could you tell us what the symbols are that

10 you used to create this map?

11 A. The symbols we used are those that we used in the former JNA. I'm

12 referring to the symbols used for radio relay hubs. Our task was to fill

13 up the empty communication documents. So we would produce a form, blank

14 one, and then as we gathered data we filled up the blank. That is to say,

15 the command, deputy commander, and logistics assistant, and so on.

16 Everybody had their own number, and we had a list of those numbers so that

17 we would know. If somebody called, we would know what person called.

18 Q. Could you just show us by indicating on the map where these radio

19 relay hubs are located?

20 A. You mean ours or --

21 Q. Maybe theirs. The VRS radio relay hubs, if you could.

22 A. I don't even have to turn to the map, because I know by heart.

23 These locations -- I will repeat once again what I said earlier. The army

24 of Republika Srpska or, rather, the former JNA used the grid system. In

25 that grid system, the facilities where we worked were also included in it.

Page 4608

1 They had remained in our territory, and they had to do certain

2 redirections, redirection of their communications. So it went from Cer to

3 Vucevo to Brcko, Trebova, Svinjar, Banja Luka, and further on to Kozara.

4 This was the western wing.

5 As for the south wing, it went from Gucevo, Cero, towards

6 Veliki Zep, because Veliki Zep was a kind of an intersection. That means

7 that all of the most important communication lines of the army of

8 Republika Srpska went across Veliki Zep. It was a purpose-built facility

9 built long time before the war, and underneath it there were tunnels for

10 communications in case of war. It was originally built by the JNA.

11 Therefore, it was not a problem. The main problem for us was initially to

12 uncover secret codes and frequencies, and after that everything went easy.

13 The army of Republika Srpska used in parallel military equipment,

14 but there was also civilian communications originating from these radio

15 relay hubs and they were interconnected via SMC system which had a much

16 greater number of channels and we were unable to monitor them.

17 Q. Well, just for the benefit of the Court so that the Court can have

18 a kind of overview of what you're talking about, could you actually point

19 to some of these locations on the map so that they can -- so that the

20 Court and all of us here can see the inter-relationship between these

21 various points.

22 JUDGE AGIUS: One moment. How difficult is it to upload this map

23 on e-court? Because if we could upload it -- yes. If we could upload it,

24 then perhaps he can mark -- mark on it with the stylus and we can preserve

25 it that way.

Page 4609

1 [Trial Chamber confers]

2 JUDGE AGIUS: I think it's good enough. I think it's good enough.

3 If we -- first gives us an indication --

4 Mr. Vanderpuye, if the witness more or less from here we can

5 visualise the map, also the markings that there are on it. I mean, if he

6 points at particular parts of that map, I'm sure that our staff can follow

7 and zoom on that part as far as we can zoom, because I understand because

8 the pixel grading amount does create a bit of a problem. But we could

9 give it a try, because then he can mark on what he sees on his monitor

10 with the stylus and we can preserve that as an exhibit.

11 MR. VANDERPUYE: That's fine as well. I'm just not familiar with

12 the technical aspects of displaying the exhibit.

13 JUDGE AGIUS: But I still agree with you. First he needs to point

14 to the various parts on the map and then we try and zoom on those parts.

15 MR. VANDERPUYE: Okay. Thank you.

16 JUDGE AGIUS: Okay. Did you follow me, Witness? You understand

17 what -- what I would require you to do? Thank you.


19 Q. Okay. Could you just indicate on the map by pointing to it, if

20 you can, the relay -- radio relay hubs that you were referring to

21 previously.

22 A. This way. There were two branches, and I will start from the

23 east. From Avala all the routes were picked up by the Cer hub, which was

24 called Brana at the time. One wing of these communications went under the

25 east corps to Bijeljina, Brcko, across Trebova, Svinjari, on to Kozara and

Page 4610

1 Banja Luka. That's the 1st Krajina Corps.

2 The southern wing had the following important relay hubs --

3 JUDGE AGIUS: Let's stop there for the time being. Sit down,

4 please.

5 Usher, have you more or less figured out the point that he was

6 pointing to, and if we could zoom on that. Yes. It's this point in the

7 extreme -- extreme -- can we zoom more? No. It's the section -- it's the

8 extreme right. Yes. It's the point that you have to zoom in where the

9 lines start. Yes, exact. Not there. No, no. Yeah. You need to zoom in

10 the section where all the lines -- it's -- just one more. Yes. Okay. We

11 can start with that. Thanks.

12 Now, Witness, you see a focal point there from which -- or from

13 where lines are drawn, and I can read there Brana, Brana. Is that the

14 point that you were referring us to?

15 THE WITNESS: [Interpretation] Yes. That's one of the hubs of --

16 on the route from Belgrade to Banja Luka.

17 JUDGE AGIUS: All right. Can you circle --

18 THE INTERPRETER: Microphone, please.

19 JUDGE AGIUS: Can you circle that point in red, please, or with

20 the stylus?

21 THE WITNESS: [Interpretation] [Marks].


23 THE WITNESS: [Interpretation] This is the code-name for the

24 Eastern Bosnian Corps.

25 JUDGE AGIUS: Now, you were explaining to us the direction of the

Page 4611

1 two perpendicular lines to the left of that focal point. Can you explain

2 to us what those two lines -- or where those two lines take us to, please?

3 THE WITNESS: [Interpretation] These lines were imaginary aerial

4 lines showing the route, where it goes.

5 If you take the airways for planes, there had to be optical

6 visibility between two stations and there had to be a certain distance

7 along which they can operate.

8 The first line, the topmost line is the radio relay route

9 connecting Bijeljina and Brcko. The second route is the SMC route, I

10 believe, which directly went to Trebova, Svinjari, and on to Banja Luka,

11 from Cer. And there is the third route which connects the terminal radio

12 relay station which was the command of one of the brigades at Majevica in

13 the territory of Brcko municipality.

14 JUDGE AGIUS: Stop there. Just to make clear which is the third

15 route, is it the one that is immediately beneath the second and which

16 takes us to a triangle below which -- underneath which are the words

17 Kalimbro?

18 THE WITNESS: [Interpretation] Yes.

19 JUDGE AGIUS: Okay. Thank you. Let's try to make it even

20 clearer. Could I ask you to put against the first line number 1, against

21 the second number 2, and against the third number 3, please, in that

22 order.

23 THE WITNESS: [Interpretation] [Marks].

24 JUDGE AGIUS: Thank you. You -- Mr. Vanderpuye, I don't know if

25 you want to continue asking or whether he can proceed to explain to us

Page 4612

1 what the other lines are, imaginary lines.

2 MR. VANDERPUYE: We can proceed. The map is really only intended

3 as a kind of general aid.

4 JUDGE AGIUS: Okay. So thank you, sir. Let's continue the --

5 describing the imaginary lines that are projected from the focal point

6 Brana that you circled earlier on, and let's take the next line, the one

7 where we see the numbers 859, 200 and whatever, and you can mark it as

8 number 4 and then describe it to us, please.

9 THE WITNESS: [Interpretation] Line number 4 is radio relay route

10 between the command of the East Bosnia Corps and one of the Majevica

11 Brigade -- brigades. I believe that it was the 2nd Majevica Brigade, if

12 my memory doesn't fail me.

13 JUDGE AGIUS: And number 5?

14 THE WITNESS: [Interpretation] Again, the route connecting this

15 point with one of the Majevica brigades. These communications were up

16 because there were no wire communication links. These were sites on

17 elevated ground and mountains.

18 JUDGE AGIUS: And the line which goes the other direction, SMC,

19 300, 200, which you can mark number 6.

20 THE WITNESS: [Interpretation] This route linked the Cer site in

21 Serbia and the East Bosnia Corps. SMC is a device with several channels

22 which was used by civilian structures. This was the lifeline for

23 communications covering Western Bosnia.

24 In addition to the SMC, we have the number 800 there, which means

25 that the military device RRU 800 was also used for military purposes. It

Page 4613

1 went beyond Cer to Veliki Zep and Avala.

2 JUDGE AGIUS: My suggestion, but please advise me on this, is

3 to -- for the time being focus on this map, have the witness put PW-131

4 against it, and that will be the first map. Then Madam Usher will come

5 back, zoom out a little bit, and we move to the top of the triangle -- top

6 of the curve that we have, and then the witness can be asked to start

7 describing from there onwards.

8 Okay. So, Witness, with the same stylus, please, on the top

9 right-hand corner, could you put PW-131, please.

10 I have his right number, correct number, don't I, 131?

11 MR. VANDERPUYE: Correct.

12 JUDGE AGIUS: Because incidentally, Borovcanin Defence, team you

13 filed an explanation note in relation to the previous witness, but you

14 have indicated him with the number PW-131 when it's PW-132. So you need

15 to correct that. Okay? All right.

16 JUDGE KWON: To understand the geography better, could you

17 underline Bijeljina, please? Is Bijeljina seen in this map, Mr. Witness?

18 Thank you.

19 THE WITNESS: [Interpretation] [Marks]. Yes. I can explain this.

20 Bijeljina or, rather, East Bosnia Corps there had wire connections with

21 Brana. Brana was located in a village and according to our information it

22 was in one of the granaries there.

23 JUDGE KWON: Near Brcko.

24 THE WITNESS: [Interpretation] No, where it says Brana radio relay

25 hub. They had to place it on elevated ground because this area is the

Page 4614

1 area of plains.

2 JUDGE AGIUS: Now, usher, you need to move -- thank you, Judge

3 Kwon.

4 You need to move and zoom in the top of the triangle. Okay. I

5 have done it on my monitor. Bring it down a little bit -- no -- yes.

6 Move it to the right slightly, and zoom in on the top of the triangle.

7 That's enough. Thank you.

8 Now, Witness, you see that we have the continuation -- partly the

9 continuation of the first two lines, what you marked as 1 and 2 before.

10 Now, on -- before we reach to the tip of the triangle, on the

11 first line there are the numbers 12/800. Could you explain those to us?

12 I'm sorry I've taken him over a little bit from you, but it's all

13 for a good cause.

14 THE WITNESS: [Interpretation] I will do my best. The marking

15 12/800 stands for the following: The army of Republika Srpska used a

16 military device RRU 800 for this route but only its 12 channels. It might

17 also stand -- the marking might also stand as 24/800. In that case, 24

18 channels are used, and the flow of information is greater. However, in

19 this particular instance, they used a 12-channel RRU 800.

20 JUDGE AGIUS: All right. Thank you. And in what is line number 2

21 that you had indicated to us before. Again we see the letters SMC,

22 FM-200. If you could explain that, please, to us. Thank you.

23 THE WITNESS: [Interpretation] This is the continuation of the

24 route which led from Cer to Bijeljina in that this route goes directly

25 from Bijeljina to the relay hub of Trebova. The SMC is the civilian

Page 4615

1 device of communication, whereas the FM-200 is a military device. So this

2 was an alternative bridge.

3 All the units up to the level of brigade mostly ended up with

4 radio relay communications -- mostly used radio relay communications.

5 JUDGE AGIUS: Thank you. And just immediately below that, beneath

6 that line, there are words that you can perhaps read for us giving us the

7 benefit of having them translated to us into English and French.

8 THE WITNESS: [Interpretation] It says below that the route was set

9 up after the NATO strikes. This way we confirmed the information we came

10 by. During the strikes, NATO destroyed the Cer facility, Svinjari

11 facility, and the terminal relay station of Kozara in order to disrupt

12 their communications system. Kozara was very important because that is

13 where the most outlining radar of the army of Republika Srpska was which

14 was also used by the Yugoslav Army.

15 JUDGE AGIUS: And a question which probably has a very obvious

16 answer to it: We see on this map a curvature with interrupted or

17 intermittent red lines. What's that supposed to indicate?

18 THE WITNESS: [Interpretation] This red intermittent line was the

19 front line between the ABiH and the army of Republika Srpska.

20 JUDGE AGIUS: I also notice on the map triangles in black and

21 triangles in red with -- some of which are -- the red ones are flagged

22 with numbers. Can you explain to us what's the difference between black

23 triangles and red triangles and what the flagged part of the red triangles

24 is supposed to signify, to indicate?

25 THE WITNESS: [Interpretation] On the right-hand side we see the

Page 4616

1 first red triangle and the red flag, which was something that the JNA or

2 the VRS used to designate their units. So this is the command post of the

3 Brcko Brigade. That's the first triangle. The second triangle with a

4 flag as well stood for Tactical Group 5. I remember this well because the

5 1st Krajina Corps brought its units over to that spot, and that's where

6 they had their provisional command, and it was called Tactical Group 5.

7 The black markings, the black triangles under the JNA standards

8 were designations for communications facilities, and that's how one would

9 denote them, by drawing black triangles.

10 JUDGE AGIUS: Thank you. Now, we -- could you kindly put again

11 number 1 against the line which you have already indicated in the previous

12 image as number 1 and number 2 against the line which you have indicated

13 previously as number 2.

14 THE WITNESS: [Interpretation] [Marks].

15 JUDGE AGIUS: Okay. Thank you. Now, going -- taking you back to

16 the tip of the triangle, there is a line which runs perpendicular towards

17 the west -- towards the left, sorry, towards the left. Could you give

18 that line number 7, please. Mark it with number 7.

19 THE WITNESS: [Interpretation] [Marks].

20 JUDGE AGIUS: No, no, no. Usher, you need to help him cancel that

21 number 7.

22 What I meant is go to the tip of the triangle where there is

23 Bozur.

24 Now, I want you to concentrate on the line that from Bozur takes

25 us from the left of the screen.

Page 4617

1 THE WITNESS: [Interpretation] Now I understand. But let me

2 explain that this is the same route but -- it's the same route but it's

3 just another station that was used for range. It's Bozur, and they had 12

4 channels there.

5 JUDGE AGIUS: So could you put again number 1 against that part of

6 the -- of the route, please.

7 THE WITNESS: [Interpretation] [Marks].

8 JUDGE AGIUS: Okay. Thank you. Now, let's see. Now, I see that

9 lines -- the continuation of line 1 and line 2 at the extreme left of the

10 screen seem to converge at a place which on the map is described as Obala.

11 Can you explain to us what that is? You can put a circle at the --

12 where -- on the place where they converge, please.

13 THE WITNESS: [Interpretation] This is the radio relay hub at

14 Trebova.

15 Now, why do these lines go up and this one goes down? For the

16 simple reason that the range of the SMC device is far greater so that you

17 could directly reach Banja Luka, whereas the radio relay device has a much

18 shorter range, to the maximum of --

19 THE INTERPRETER: Could the witness please repeat the number of

20 kilometres.

21 JUDGE AGIUS: Yes. The interpreters haven't caught the number of

22 kilometres that you mentioned.

23 THE WITNESS: [Interpretation] I said that the RRU 800 has the

24 maximum range of up to 80 kilometres.

25 JUDGE AGIUS: All right. Perhaps you can now top right-hand

Page 4618

1 corner of this map put your number, witness number, PW-131, please.

2 THE WITNESS: [Interpretation] [Marks].

3 JUDGE AGIUS: We can store that, and Madam Usher can come forward

4 again, and let's move to the other part of the map, further -- further

5 west from -- you need to put the place where those two lines converge in

6 the middle and zoom on that spot, the -- yes. I think it's enough. It's

7 enough like that. It's enough like that.

8 So now we come to the other part. You see that from the spot

9 where these lines -- those previously two lines converge, 1 and 2, another

10 two lines are projected. Would the one on top where we find FM-200 be

11 still a continuation of line 1, or is it a new line?

12 THE WITNESS: [Interpretation] Yes. It's the continuation of line

13 number 1, which goes to the radio relay station of Svinjari above Teslic.

14 JUDGE AGIUS: Could you kindly put number is against it where the

15 river is. Yes. Thank you.

16 THE WITNESS: [Interpretation] [Marks].

17 JUDGE AGIUS: And the line that goes south to Brana, I think

18 it's --

19 THE WITNESS: [Interpretation] This is the line which has the route

20 toward Doboj or what was the Operations Group Doboj at the time. Since

21 Doboj is down in a depression, there was no optical visibility. You can

22 see here that there is the terminal radio relay station to the west of the

23 town of Doboj which was next to Ciganiste, and Ciganiste is close to the

24 war zone, and this was an area that you could see from the place where we

25 were with the naked eye. This was the link between the 1st Corps and

Page 4619

1 Doboj and the Ozren units.

2 JUDGE AGIUS: All right. So let's give it number 7, please.

3 THE WITNESS: [Interpretation] [Marks].

4 JUDGE AGIUS: And again put PW-131, top right-hand corner, please.

5 THE WITNESS: [Interpretation] [Marks].

6 JUDGE AGIUS: Now, registrar -- okay. Do that first.

7 You need to focus now extreme right, the last two lines. Just

8 below where we started from. Keep on going. Now take it up. Move it

9 upward. No, that's the other way. Move -- yes, at -- and we need to

10 concentrate on where those words are, Ka Avali. More or less.

11 Now, Witness, you see again the focal point and the triangle

12 marked against the words Ka Avali, and there are two lines that project

13 from that spot towards the south.

14 Let's take the first one. Where does this take us?

15 THE WITNESS: [Interpretation] The first line, I can't see it here

16 on the map, but I believe that it leads to Zvornik and the Zvornik

17 Brigade.

18 The second line runs directly to Veliki Zep. This is the second

19 artery of the communications system, and that is why Cer was very

20 important, and that was why NATO destroyed it right away at the time of

21 the bombardment.

22 JUDGE AGIUS: So let's mark the first one with number 8 and the

23 second with number 9.

24 THE WITNESS: [Interpretation] [Marks].

25 JUDGE AGIUS: And again your PW-131 on the top.

Page 4620

1 THE WITNESS: [Interpretation] [Marks].

2 JUDGE AGIUS: And I think we have a pretty clear picture now of

3 all the map. You can store it. One moment, unless -- unless,

4 Mr. Vanderpuye -- let's store it. Let's store it, and then we can go to

5 any one of these maps as it becomes necessary. I think it will help us

6 eliminate a lot of questions that I would have anticipated from the

7 Defence bench.

8 Back in your good hands.


10 Q. Could you just indicate to us where Cer is located, Mr. Witness?

11 JUDGE AGIUS: Your microphone.

12 THE WITNESS: [Interpretation] [Marks].


14 Q. Could you just, for the record, write the name Cer right next to

15 that circle, please.

16 A. [Marks].

17 Q. You indicated previously that was the lifeline of communications

18 for the VRS in Western Bosnia; is that correct?

19 A. I meant the radio relay communications. In view of the fact that

20 they lost the Konjuh facility or -- excuse me. They lost the facilities

21 from which we surveilled them. They had to re-route themselves in order

22 to rely on such hubs in Serbia. There were some facilities that they used

23 in the southern part as well.

24 JUDGE AGIUS: All right. Would it be convenient for you,

25 Mr. Vanderpuye, to have the break now?

Page 4621

1 MR. VANDERPUYE: Yes, it would.

2 JUDGE AGIUS: All right. Thank you.

3 So we'll have 30 minutes starting from now. Thank you.

4 --- Recess taken at 12.32 p.m.

5 --- On resuming at 1.05 p.m.

6 JUDGE AGIUS: We can continue, I suppose, Mr. Vanderpuye.

7 MR. VANDERPUYE: Thank you, Mr. President. I think the last I

8 left off the witness had just circled the --

9 JUDGE AGIUS: Last point, Ka Avali.

10 MR. VANDERPUYE: That's correct, indicating the town of Cer. Also

11 he had indicated previously that there was some sort of an air-strike or

12 bombing, I think is what the witness testified to.

13 Q. And I just wondered if you could just tell us which bombing you

14 were talking about or approximately when that happened.

15 A. I was referring to the NATO bombing of the hubs in Serbia and

16 certain facilities. We saw that with the naked eye. They destroyed

17 Svinjar, destroyed the facilities at Ozren, Cer, Kozara. They also

18 targeted Veliki Zep. This was when NATO ...

19 JUDGE AGIUS: What's the problem?

20 MR. VANDERPUYE: I think we've lost the last half of the

21 translation maybe.

22 THE WITNESS: [Interpretation] The witness did not finish the

23 sentence, interpreters note.

24 JUDGE AGIUS: So you are saying, Witness, we saw that with the

25 naked eye. They destroyed Svinjar, destroyed the facilities at Ozren,

Page 4622

1 Cer, Kozara. They also targeted Veliki Zep. This was when NATO, and you

2 were about to continue when we didn't hear you anymore.

3 THE WITNESS: [Interpretation] I was going to say that this

4 confirmed our knowledge about these being key facilities through which

5 relay routes went.


7 Q. To the best of your knowledge, do you recall when that happened,

8 when that bombing occurred, what month?

9 A. I can't really recall. I think it was in 1999.

10 Q. Okay. Thank you.

11 MR. VANDERPUYE: Could I have 65 ter 1468. I think that's the

12 map. Okay. Great.

13 Q. Do you have in front of you, Mr. Witness? Not yet.

14 MR. VANDERPUYE: Okay. It appears to me to be loaded. I wonder

15 if we could zoom in on the -- yes, right about where you are now. Near

16 Ka Avali, which is on the top right. Great. Okay.

17 Q. Can you see that, Mr. Witness?

18 A. Yes.

19 Q. Now, the area of Ka Avali, could you tell us where specifically

20 that's located? Is that in Serbia?

21 A. That's in Serbia, on the Cer mountain.

22 Q. Now, you'd indicated that from that area the two lines proceeding

23 downward and to the left you had previously designated 8 and 9

24 respectively from the left to the right. With respect to the line --

25 A. Yes.

Page 4623

1 Q. -- from that location to the left, that is farthest to the left,

2 to which location does that line run?

3 A. This line reads towards the Zvornik Brigade. That is to say, that

4 line first goes to Gucevo radio relay hub, which is also in Serbia, and

5 then further on to Zvornik, because there was no optical visibility

6 between Zvornik and Cer.

7 Q. And the line moving to the left that is to the right of the line

8 going to Zvornik, can you tell us where that line goes?

9 A. According to our information, this line went directly to the TV

10 tower on Mount Avala another Belgrade.

11 MR. VANDERPUYE: Okay. Can we zoom out. And could we go to the

12 bottom. There we go. And zoom in right where the large hub is. That's

13 pretty good.

14 Q. Can you see that, Mr. Witness?

15 A. Yes.

16 JUDGE AGIUS: Microphone.


18 Q. Okay. Can we zoom in a little bit more, and could you tell us

19 what that triangle is at the centre of the screen?

20 A. This triangle is a radio relay hub called Veliki Zep.

21 MR. VANDERPUYE: Could we blow that up just a little bit more?

22 Thank you.

23 Q. Okay. Now, there are a number of lines that are going to or from

24 that particular location, and I'd like to focus your attention on those

25 lines that are to the right of your screen, and if you could tell us where

Page 4624

1 they go. But I'm going to have you mark this exhibit if you could.

2 A. Since this is a mountainous area of Bosnia, it was necessary to

3 connect them in this manner, and this part of Bosnia was not included in

4 the system. Well, this is why they used a radio relay system, especially

5 radio relay 1, which was quite mobile, and could have been placed in any

6 house, on any mountain, and so on.

7 The thickest black line was the route leading to Cer. This was

8 the link to Serbia and to the eastern part of Bosnia and Herzegovina, all

9 the way down to Banja Luka.

10 As for the lines below, those are the routes established via

11 RRU 1. I don't see the right part of the map, but I think that that area

12 leads to Bratunac Brigade. I think another one goes to Pribicevac, to

13 Milicevo, and I don't see the rest of it. To the Skelani Brigade. Those

14 were the subordinate units of the Drina Corps.

15 Q. With respect to the thick black line on the right of the screen

16 going up from the triangle, could you mark on that line or next to that

17 line the number 9.

18 A. The pen cannot write. [Marks].

19 Q. Thank you. And could you mark sequentially the lines I guess in a

20 clockwise kind of way. Number them sequentially, that is 10, 11,

21 et cetera, and could you tell us where they go, if you know.

22 A. I've already said we can't see it on this map all the locations to

23 which this leads. The first line is the radio relay route RR -- RRU 1

24 leading to the Bratunac Brigade below number 9. Then the second line

25 leads to the Skelani Brigade.

Page 4625

1 Q. Could you mark these lines as you go along.

2 A. This is 10. This is 11. And the third line I think goes towards

3 the forward command post, Pribicevac, which is above Srebrenica. No, I

4 apologise. The second line leads to Pribicevac. Line 11 leads to

5 Pribicevac. And line 12 that I'm marking right now leads towards the

6 Skelani Brigade.

7 Line 13 led towards the Rogatica Brigade. This thick black line

8 is the link with the next radio relay hub which was located near Foca or

9 Bileca. I believe it was called Zlovrh, but I'm not sure.

10 The other lines lead toward subordinate units of the Drina Corps.

11 Q. Could you, if you have a chance, just indicate next to the line

12 the location to which it goes. For example, 9 you would write Cer. 10 to

13 the extent that it goes to Bratunac, maybe you can write BRA or something

14 of that nature so that we know exactly what you're talking about.

15 Alternatively, I suppose we could pull back a little bit on the

16 map, zoom out. It can't be done. Okay. All right. So that would

17 probably be a better way to do it. Just write the first couple of letters

18 of the location to which the line goes.

19 JUDGE AGIUS: Please use capital letters.

20 THE WITNESS: [Interpretation] [Marks].


22 Q. You'd indicated that the thick black line goes to Cer; is that

23 right?

24 A. It says here on this map Veliki Tmor. I think that's the name of

25 the radio relay hub.

Page 4626

1 Q. What I'm referring to is number 9, how you labelled it. Is that

2 the line, the thick black line that you referenced earlier going to Cer?

3 A. I apologise. I made a mistake. 9 leads towards Cer and 10 leads

4 towards Bratunac. Can this be erased? Line 10 leads to Bratunac.

5 It's fine now.

6 Q. Now, there are certain other indications on the map. Can you tell

7 us what the designation Panorama is in the centre of these vectors?

8 A. The word Panorama was a code-name for the radio relay hub called

9 Veliki Zep.

10 Q. And did the name have any other significance to you in terms of

11 the functioning of your unit?

12 A. Well, these code-names were of key importance, because when the

13 link was established radio operators would call the person under their

14 secret code-name. For example, if they called Panorama, they asked for

15 the name Gric, Vrelo, or they asked for Obala in Bijela. So those

16 code-names existed in order to establish links, in order to physically

17 switch the connection to make the link.

18 Q. Can you tell us what Uran is? If you see that triangle on the

19 right side of the exhibit.

20 A. Uran is the terminal radio relay station that appeared after the

21 fall of Srebrenica. In our view, this station used the same equipment

22 that existed at Pribicevac, which means that once Pribicevac was shut

23 down, route 11 leading to Pribicevac, you can see it here, this other

24 station appeared a day later, and it was established for the purpose of

25 operation to seize Zepa.

Page 4627

1 JUDGE AGIUS: Can he circle Uran, please.

2 THE WITNESS: [Interpretation] [Marks].

3 JUDGE AGIUS: And while he was testifying before, he did give an

4 indication what line 14 stands for, where does it lead. If he could put

5 in the name of the corps or whatever he stated earlier on.

6 THE WITNESS: [Interpretation] Line 14 led towards the second hub

7 called Veliki Tmor. It was a route for the Hercegovina Corps. So from

8 Veliki Tmor, the route led further down towards Bileca, towards the

9 Hercegovina Corps.

10 JUDGE AGIUS: And you also testified on the line next to it which

11 seems to indicate at the bottom, Pale, but you mentioned the Drina Corps.

12 If you could then give it a number, number 15, please, and put

13 down "Drina Corps."

14 THE WITNESS: [Interpretation] [Marks]. Your Honours, this was not

15 the link with the Drina Corps. It was the link with Pale. Since the

16 political authorities were in Pale, the army reinforced this link with a

17 24-channel device called RRU 800.


19 Q. Is that denominated by a 24 that is depicted or written at the

20 bottom of this exhibit?

21 A. Yes.

22 Q. And could you indicate further on this map the connection --

23 A. Further on, the next route was the one established with one of the

24 brigades of the Drina Corps that I cannot see on the map. To be more

25 precise, with the Sokolac Brigade.

Page 4628

1 The next route was established with the code-name Matica where the

2 2nd Romanija Brigade was.

3 The next route was established because the Romanija Brigade did

4 not have good communication with its subordinate units. Therefore, they

5 established a link via RRU 1 with one of their battalions called Odra.

6 This red flag on the right denotes the General Staff of the army of

7 Republika Srpska, and this command had a wire connection. So this was not

8 the connection via RRU 1, no. They had a wire connection with the

9 command.

10 The next line is with the code-name Zlatar, which was the command

11 of the Drina Corps, and that was the radio relay route RRU 800 with the

12 command of the army of Republika Srpska. This was their link --

13 Q. With respect to --

14 A. -- with the Zlatar unit.

15 Q. -- to the connection that you'd indicated that the General Staff

16 had that was by wire, could you indicate or write on the map maybe --

17 well, I guess you could write "wire" or W on that circle.

18 THE WITNESS: [Interpretation] [Marks].

19 JUDGE AGIUS: He can complete it. He can write "wire," it will

20 confuse us less later on.

21 THE WITNESS: [Interpretation] [Marks].


23 Q. Now, the staff that you indicated, there was the Main Staff of the

24 VRS; is that right?

25 A. Yes.

Page 4629

1 Q. With the relation to the location of Zlatar, can you tell us what

2 that location was?

3 A. Zlatar, I can't see it here. That was the command of the Drina

4 Corps, and it is marked here. Line number 19 links up the command of the

5 Drina Corps with Veliki Zep.

6 The next line, line number 20, linked up the Sekovici Brigade with

7 the Drina Corps and then beyond.

8 Line 21 is somewhere above Sekovici. There was a command there,

9 and I can't tell you which one. I believe that the name of the locality

10 was Osmaci.

11 Line 22 linked up, in my estimate, the engineers regiment with the

12 code-name Udarnik stationed at Konjevic Polje, I believe.

13 And line 24 linked up Milici Brigade with its superior command.

14 Q. Can you identify from these lines any line that goes up in the

15 area of Zvornik or near there?

16 A. The lines with Zvornik were established across Cer, Gucevo, and

17 down to Zvornik. Since Zvornik was in a depression, there was no optical

18 visibility, and that's why they used the so-called reflecting signal,

19 which is the thick black line.

20 Q. Okay. For this exhibit, could you write maybe in the top

21 left-hand corner PW-131, please.

22 MR. VANDERPUYE: Okay. I was wondering if we could go to a

23 different part of the map. I'd like to go to the part of the map -- let's

24 see. It's still over to your right. A bit north, north of that. And a

25 bit -- well, could you blow that up, please? Okay. Down. Yes. And

Page 4630

1 where the -- right near where the end of that vector is on your left.

2 Okay, a little bit down -- a little bit down from there. That seems fine.

3 Okay. If you could blow it up a little bit, please. Okay. Right where

4 it says Palma, could you blow that up, please. Okay.

5 Q. Can you see that, Mr. Witness?

6 A. Yes.

7 Q. And do you see the destination Palma on there?

8 A. Yes.

9 MR. VANDERPUYE: Perhaps we can blow that up just a little bit

10 more.

11 Q. Okay. Next to that word there is a line that runs north and

12 south, I guess you could say, up and down. Could you tell us where that

13 line goes running downwards?

14 A. The line running from the north to the south leads to Veliki Zep,

15 from Gucevo to Veliki Zep.

16 Q. Do you see Gucevo on this particular exhibit?

17 A. No. A bit to the north. Now you can see it.

18 Q. With the pen could you mark on this particular exhibit those two

19 locations.

20 A. This is Gucevo with the code-name Brana 99, and it was included in

21 the documents, communications documents, of the army of Republika Srpska,

22 although it is located in Serbia. This is the radio relay hub.

23 Down there where there's the red flag, that stands for the Zvornik

24 Brigade. We have a terminal radio relay station there as well, which

25 meant that this is where the communications ended, and this is the area.

Page 4631

1 Q. Is that in the area of Zvornik?

2 A. Yes.

3 Q. Could you just underline -- underline the city, the name of the

4 city on the map.

5 A. [Marks].

6 Q. Okay. Thank you. And on where the line is -- where the word

7 Palma is written, could you just indicate that that goes down to

8 Veliki Zep. In other words, put a number next to it, maybe number 1 in

9 this case, and write Veliki Zep.

10 A. Palma is not the name for Veliki Zep. Palma is the code-name of

11 the Zvornik Brigade. That's why you have Zvornik-Palma. It has nothing

12 to do with Veliki Zep. It's the other line that crosses the word Palma

13 that goes to Veliki Zep.

14 Q. The vertical line you're referring to, right?

15 A. Yes.

16 Q. Right. Indicate next to that line that it goes to Veliki Zep.

17 A. [Marks].

18 Q. Okay. If you could just mark on the top left-hand side of this

19 exhibit also PW-131, please.

20 A. [Marks].

21 Q. In relation to this particular exhibit, you'd indicated on the

22 triangle that you circled on the top the code-name Brana; is that right?

23 A. Yes. Brana 99.

24 Q. And on a prior exhibit you'd indicated another triangle to the

25 east -- to the west of this location, which I believe you referred to --

Page 4632

1 or had been referred to as Brana. Is there such a code-name with respect

2 to the area to the left of this, to the west of it?

3 A. Can you please refer me to the area you have in mind?

4 Q. Okay. I think I can -- I think I actually can.

5 MR. VANDERPUYE: If you go to the left of the screen. At the base

6 of the big triangle on the top. Just keep going up and to your left now.

7 Left. Right where that angular line bends going down. Right there. The

8 triangle on your left. Yeah. Could you blow that up, please.

9 THE WITNESS: [Interpretation] Yes.


11 Q. Okay. I believe that that's what was referred to as Brana before.

12 Is that in fact the case? Is that accurate, the name?

13 A. Based on what we know, yes. If we set up a temporary radio relay

14 station, and if we have a code-name already, then you add a number to it

15 in order to distinguish it for the other. That's normal procedure.

16 This is the radio relay station at Ciganiste to the north of Doboj

17 with the code-name Brana.

18 Q. Thank you. And that's just distinguishable from Brana 99, right,

19 as a separate location?

20 A. Yes.

21 MR. VANDERPUYE: Can we go on the map to the other side, please.

22 That would be, I guess, to the east and down. Okay. A little further

23 down, please. Okay. And then to the right in the area of Bratunac. Do

24 you see that? A little bit down so we can get also Srebrenica in the same

25 frame. Could you please just blow up that area, please.

Page 4633

1 Q. Okay. Can you see that, Mr. Witness?

2 A. Yes.

3 Q. Indicate with a line underneath the name Srebrenica that's

4 depicted on the map, please.

5 A. [Marks].

6 Q. Do you see Bratunac on this map?

7 A. Yes.

8 Q. Okay. Can you indicate also by highlighting the line of

9 communication that goes through Bratunac or to Bratunac.

10 A. [Marks].

11 MR. VANDERPUYE: Is it possible to move the map a little bit down?

12 No. It's fixed. Okay. It's okay.

13 Q. Are those two lines of communication connected with Veliki Zep,

14 the area that you indicated before?

15 A. Yes.

16 Q. And are you familiar with any code-name that's associated with the

17 area of Bratunac or Srebrenica?

18 A. You can look on the left-hand side. It says 22nd of January a

19 forward command post was established at Pribicevac, and it was then that

20 we established the existence of this route which got the extension 311.

21 It was linked up with the command of the Drina Corps at Vlasenica, which

22 meant that from Vlasenica by dialling extension 311 they could get

23 connected to the line at Pribicevac. I can even recall the person

24 establishing the connection, Captain Jevdjevic, and he was boasting about

25 the fact that the lines functioned perfectly. I believe that he was

Page 4634

1 Captain Jevdzevic from the command the Drina Corps.

2 Q. Are you familiar with the code-name Badem?

3 A. Yes. That was the code-name of the Bratunac Brigade.

4 Q. Are you familiar with the code-name Palma?

5 A. The code-name Palma stands for Zvornik Brigade.

6 Q. Are you familiar with the code-name Zlatar?

7 A. Zlatar is the code-name of the Drina Corps.

8 Q. And you're familiar with the code-name Panorama you indicated,

9 right?

10 A. Yes.

11 Q. On this exhibit there's -- there's a line further down from the

12 two lines that you've marked. Can you tell us what that line is and to

13 what it's connected?

14 A. This line stands for the radio relay route number 1, which linked

15 up the Skelani Brigade with the command of the Drina Corps.

16 Q. Could you just write your name on this one? We'll save it, and

17 we'll wrap it up.

18 THE WITNESS: [Interpretation] [Marks].

19 Q. Thank you, Mr. Witness.

20 JUDGE AGIUS: So that brings us to the end of today's sitting.

21 We'll continue tomorrow morning at 9.00.

22 In the meantime, Witness, you are not to allow anyone to contact

23 you or you try to contact anyone in connection the matters that you are

24 testifying about.

25 Tomorrow we continue at 9.00. Thank you.

Page 4635

1 --- Whereupon the hearing adjourned at 1.47 p.m.,

2 to be reconvened on Tuesday, the 28th day

3 of November, 2006, at 9.00 a.m.