Tribunal Criminal Tribunal for the Former Yugoslavia

Page 22261

 1                           Tuesday, 17 June 2008

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.05 a.m.

 5             JUDGE AGIUS:  Good morning, Madam Registrar.  Will you call the

 6     case, please.

 7             THE REGISTRAR:  Good morning, Your Honours.  Good morning,

 8     everyone.  This is case number IT-05-88-T, the Prosecutor versus Vujadin

 9     Popovic et al.

10             JUDGE AGIUS:  Thank you.

11             Yes.  Good morning, everybody.  All the accused are here.  From

12     the Defence teams, I notice the absence of Mr. Bourgon and Mr. Haynes.

13             Prosecution, we have present Mr. McCloskey and Mr. Vanderpuye.

14             Yes, any preliminaries?  None.

15             So I see that contact is already established.

16             Mr. Blagojevic, dobar dan.

17             THE WITNESS: [Interpretation] Good morning.

18             JUDGE AGIUS:  You are about to start giving evidence very

19     shortly.  You've been brought forward as a witness by one of the accused

20     here, Colonel Vujadin Popovic; and before you start your testimony, our

21     law requires that you make a solemn declaration to the effect, that in

22     the course of your testimony, you will be speaking the truth.  I

23     understand that you have been handed a copy of the text of the solemn

24     declaration already.  Please read it out aloud, and that will be your

25     solemn undertaking with us.

Page 22262

 1             THE WITNESS: [Interpretation] I solemnly declare that I will

 2     speak the truth, the whole truth, and nothing but the truth.

 3             JUDGE AGIUS:  I thank you.  Please make yourself comfortable.

 4             Lead counsel for Popovic will now introduce himself to you and

 5     start with his questions.

 6             Mr. Zivanovic.

 7                           WITNESS:  NEDO BLAGOJEVIC

 8                           [Witness appeared via videolink]

 9                           [Witness answered through interpreter]

10                           Examination by Mr. Zivanovic:

11        Q.   Good morning, Mr. Blagojevic.  I am Zoran Zivanovic.  I appear

12     for Vujadin Popovic in this case.  Would you kindly give us your full

13     name for the record.

14        A.   Good morning.  I am Nedo, son of Milos, Blagojevic.

15        Q.   Would you please give us the place and date of your birth.

16        A.   13th February 1955, Micevici village, municipality Lukavac, the

17     Republic of Bosnia and Herzegovina, Socialist Republic of Bosnia and

18     Herzegovina.

19        Q.   Tell us about your educational attainment.

20        A.   I completed primary school, higher school of engineering in

21     Lukavac, and the military academy land forces, as well as the

22     quarter-master services school in Belgrade, the vocation of

23     communications.

24        Q.   Can you tell us whether you joined the Yugoslav People's Army;

25     and if so, when?

Page 22263

 1        A.   I joined the Yugoslav People's Army on the 14th September 1974,

 2     when I enrolled -- in fact, when I graduated from the military academy --

 3             THE INTERPRETER:  Interpreter's correction:  When I enrolled in

 4     military academy because completion of military academy counts as

 5     completed regular military service.

 6             THE WITNESS: [Interpretation] And the military academy is a

 7     four-year course.

 8             MR. ZIVANOVIC: [Interpretation]

 9        Q.   Did you ever join the Army of Republika Srpska; and if so, when?

10        A.   I joined the Army of Republika Srpska immediately as soon as it

11     was established; that was sometime in May 1992.

12        Q.   Tell me, in which unit of the VRS did you service?

13        A.   At the time, I was in the communications unit of the Drvar Corps.

14        Q.   And later, did you transfer to the Drina Corps; and if so, when?

15        A.   I joined the Drina Corps when it was established.  They needed a

16     chief of communications and I was appointed to that position, but the

17     official date of establishment of the Drina Corps was the 1st of

18     November, 1992.

19        Q.   Did you continue in this position in the Drina Corps all the

20     time?

21        A.   I was in that position from that date until the end of the war

22     and even further on until 1997, when I retired.

23        Q.   What was your rank?

24        A.   When I took up my position I was a major.  In 1995, I was

25     promoted to lieutenant-colonel and I was retired in that rank.

Page 22264

 1        Q.   You said you were chief of communications.  I would then like to

 2     ask you:  What were the responsibilities of the chief of communications

 3     in the corps?

 4        A.   The responsibilities of the chief of communications in the corps

 5     were to organize, establish, plan, and maintain communications

 6     established.

 7        Q.   As chief of communications, can you tell me to whom were you

 8     directly subordinated?

 9        A.   The chief of communications with his organ of communications was

10     situated in the headquarters of the command of the Drina Corps; his

11     immediate superior was Chief of Staff.

12        Q.   Does that mean that you could receive orders from the Chief of

13     Staff?

14        A.   Well, I mostly received them from the Chief of Staff and only

15     exceptionally from the corps commander.

16        Q.   In the Drina Corps, was there a communications battalion?

17        A.   In the Drina Corps, like in other corps, there was a unit for

18     maintaining communications with other units and that was the

19     communications battalion.

20        Q.   Can you recall who was the commander of that battalion?

21        A.   Well, from the beginning until 1995, the commander of the

22     communications battalion was Milenko Jevdjevic; he was later promoted and

23     left this position in the rank of major.

24        Q.   Were you able, as chief of communications, to issue orders to

25     that battalion?

Page 22265

 1        A.   I, as chief of communications, was not able to give orders

 2     directly to the commander of that battalion.  I could only exceptionally

 3     pass on orders from the corps commander to him.

 4        Q.   What is the relationship of the chief of communications with that

 5     communications unit; that is, your relationship with this communications

 6     unit?

 7        A.   Well, based on the plan of communications and the orders I

 8     received from the Chief of Staff, I had to control and verify the

 9     implementation of these plans of communications and to check how

10     communications were established.

11        Q.   Tell me, were there any communications units in specific units?

12        A.   Every brigade, according to establishment, had to have a

13     communications company, larger or smaller.  At any rate, each unit had

14     its own subunit for communications to maintain communications with

15     superiors and with other units.

16        Q.   Tell me, from your recollection, what type of communications

17     equipment did the Drina Corps have at that time, or more precisely 1995?

18        A.   Compared to the very beginning, in 1995 we were better equipped

19     in terms of communications.  We had a group of radio devices, radio relay

20     devices, telephone and telegraph devices, and encryption devices.  Among

21     radio devices, we had more powerful devices, Radio Teletypes 400, Radio

22     Teletype 100, RUP-33 --

23             THE INTERPRETER:  Can you slow the witness down, please.

24             JUDGE AGIUS:  I haven't received interpretation of what

25     Mr. Zivanovic said.

Page 22266

 1             THE INTERPRETER:  Mr. Zivanovic was just repeating what I asked,

 2     to slow down.  I'm sorry.

 3             JUDGE AGIUS:  Yes.

 4             Mr. Blagojevic, it's important that you slow down a little bit

 5     because the interpreters have to catch up with you.

 6             Mr. Zivanovic, thank you for intervening and please proceed with

 7     your questions.

 8             MR. ZIVANOVIC: [Interpretation]

 9        Q.   Could you continue, please.

10             We stopped in our record with radio Teletype 400, Radio Teletype

11     100, and RUP-33.  Maybe you could repeat all these devices again, because

12     of your speed the interpreters missed something.

13        A.   Yes, I can.

14        Q.   Take it more slowly.

15        A.   Radio Teletype system 400, Radio Teletype system 100, RUP-3 and

16     RUP-33, RUP-12.  Those are radio devices.  Now I'm talking about radio

17     relay devices:  FM 200, RRU-800, and RRU-1.  Out of telephone devices, we

18     had VZ12K, TC 40, TC 10, and TC 12 or sometimes called TCI 20, and

19     Telephones F 63.  We also had interphones.

20        Q.   Could you just repeat, we couldn't hear one bit very clearly.

21     You said TC 10, and after that?

22        A.   TC 40, I said first; then TC 10 -- or TLC 10 and TLC 20, because

23     TLC is an older version.

24        Q.   Can you remember radio relay equipment that you have -- that you

25     had?  I didn't notice it in the enumeration, but maybe I missed it.

Page 22267

 1        A.   I noted them after radios.  Radio relays, we had FM 200, RRU-800,

 2     and RRU-1.

 3        Q.   Can you tell us, briefly, about the features of

 4     telecommunications available with RUP-12?

 5        A.   Radio devices RUP-12, like all radios, provide circular

 6     communication in all directions horizontally.  The range is about ten

 7     kilometres; and with good visibility, it can be even 15 or up to 20.

 8     It's 30 to 70 megahertz; that is the frequency range which is adjustable.

 9        Q.   Can you tell us, briefly, the characteristics of RRU-1?

10        A.   Radio relay device RRU-1, unlike radio devices, provides

11     communication in one direction and has one channel through which it can

12     communicate both speech and typed text.  Professionally, we call it

13     telegraphy, and that's why on our schemes we always marked it TLF for

14     telephony and TLG for telegraphy.  The frequency range is somewhere

15     between 230 and 270 megahertz.

16        Q.   Thank you.  Can you just tell me another thing, characteristics

17     of RRU-800.

18        A.   The radio relay devices of this type, just like RRU-1, provides

19     communication in one direction, but the 800 conveys a group of channels

20     in its relay beam, depending on multiplex devices with greater frequency

21     plugged into it.  It can communicate from four to 24 channels.  Usually,

22     you communicate four, eight, 12, or 24 channels in the scale -- on this

23     scale.

24        Q.   And do you remember the frequency range of these devices?

25        A.   Well, radio relay devices RRU-800 operated within a frequency

Page 22268

 1     range of 600 to 900 megahertz.

 2        Q.   All right.  Now would you kindly tell me - and we will stay on

 3     the radio relay device RRU-800 - do you remember about the radio relay

 4     route from the base of the corps in Vlasenica to the brigades?  What was

 5     the layout of that route towards the brigade of Zvornik; the Zvornik

 6     Brigade, not just any brigade?

 7        A.   The radio relay route for communications between the corps and

 8     the Zvornik Brigade went from Vlasenica to Veliki Zep; Velika Zep-Cer;

 9     and Cer-Gucevo; and Gucevo-Zvornik.

10        Q.   Did this route exist specifically in July 1995?

11        A.   Yes.  This route did not change from beginning to end because

12     there was no need to change it, so it was in place in July 1995.

13        Q.   Do you recall another direction of RRU-800 which worked from the

14     command of the Drina Corps in Vlasenica, on one hand, and the

15     subordinates in brigades, on the other hand?  I'm talking again about

16     July 1995?

17        A.   There was a communication through the RRU-800 with the command of

18     the 2nd Romanija that went through Veliki Zep and devices RRU-800 in

19     Sokolac; although, the command of the 2nd Marina was further on --

20     2nd Romanija was further on.  There was also connection with the Rogatica

21     Brigade through Veliki Zep.

22        Q.   And how was communication maintained with other units with which

23     there was no RRU communication?

24        A.   As for the Bratunac Brigade, we could not have direct

25     communication either from Veliki Zep or from any other hub; rather, we

Page 22269

 1     used RRU-1 at Veliki Zep in order to maintain communication with the

 2     Bratunac Brigade.  And, again, from Veliki Zep where there was an RRU-1,

 3     we maintained connection with the DG Pribicevac on Pribicevac hill and in

 4     Pribicevac village; and also with the manoeuvre brigade in the village of

 5     Kozluk.  From Veliki Zep, through RRU-1, we maintained communication with

 6     the manoeuvre brigade in Kozluk.

 7        Q.   Tell me, please, when we're talking about the communications that

 8     were maintained with RRU-800, were these communications routes protected,

 9     were they safe?  We're talking about RRU-80 and RRU-8 [as interpreted].

10        A.   Most of the communication was not safe, it was not secured;

11     however, the telegrams were encrypted or protected in popular words, in

12     layman's terms.  Because as soon as the corps command was established, I

13     was the head of communications and head of encryption, and I issued an

14     order that all communication about combat activities should be encrypted

15     and sent via a written document.  In other words, it has to be done

16     securely.  This is what was done because I insisted on that procedure.

17        Q.   What you have just told us now, what device were you talking

18     about because there's some ambiguities in the record?

19        A.   Both RRU-1 and RRU-800.

20        Q.   Were there devices for encrypting speech for these devices?

21        A.   For RRU-800, there was no device to provide group protection.  It

22     was only possible to single out one channel, which was only applied on

23     RRU-1, and that's KZU 61.  It could protect one channel in the speech

24     area, which we applied towards the tactical group Pribicevac in

25     June 1995.

Page 22270

 1        Q.   Do you remember, and you told us what was the radio relay route

 2     between Vlasenica and Zvornik, do you remember were there in addition to

 3     the RRU-800 there was another device that was operational on any one of

 4     the parts of that route?

 5        A.   From the command of the Drina Corps to Veliki Zep, we had two

 6     relay routes:  One was with FM 200 and the other was with RRU-800.  From

 7     Veliki Zep to Cer, we had an SMC device which had a larger capacity of

 8     channels than any other devices at our disposal, and it had a much higher

 9     frequency that was not so easy to intercept.  It was much harder.  As for

10     the rest, on other parts of the route between Veliki Zep, Cer, and

11     Zvornik, we had nothing but RRU-800 devices.

12        Q.   Can you tell me about SMC device, what was its frequency range?

13     Do you remember?  Was that frequency range different than all the others

14     that you've just talked about?

15        A.   The SMC device, unlike RRU-800 whose frequency was between 600

16     and 900 megahertz, the SMC had a frequency range from 4.4 to 4.6

17     gigahertz and from 4.8 to 5.0 gigahertz.  It worked in two parts.

18             JUDGE AGIUS:  Mr. Zivanovic, ask him to slow down a little bit.

19             MR. ZIVANOVIC: [Interpretation]

20        Q.   Mr. Blagojevic, let me just remind you, could you please slow

21     down a little in order to help the interpreters interpret your words

22     correctly.

23        A.   If need be, I will repeat.

24        Q.   Well, then, repeat the last thing.  Just give us the frequencies

25     that --

Page 22271

 1             JUDGE AGIUS:  I don't think there is a need for him to repeat.

 2     We have it all, but I got the feeling that he was running too fast.

 3             MR. ZIVANOVIC: [Interpretation]

 4        Q.   I apologise.  You don't have to repeat, sir.

 5             Please tell me what measures you, as the chief of communications

 6     in 1995, in the summer of that year, what measures did you take in order

 7     to better protect your communication from possible interception?  I'm

 8     talking about RRU-100 [as interpreted] and RRU-1 devices.

 9        A.   When I was talking about the protection of communication, on the

10     eve of the operation at Srebrenica, at RRU-1 at Pribicevac, I mounted a

11     KZU 61 to protect speech as well, and there had already been protection

12     of written information there.  I had an encrypting machine at the command

13     post as well.  As for radio device RUP-12, I mounted a KZU 3 [as

14     interpreted] so that the radio communication also had a protected speech,

15     secured speech, communication.

16        Q.   Can you please tell me, you're talking about Veliki Zep.  Can you

17     describe what it was that was on Veliki Zep?  What was the feature there?

18     What was the building there or what kind of a centre?

19        A.   Veliki Zep was the main radio relay hub of the Main Staff of the

20     Army of Republika Srpska, and it was also the same thing for the command

21     of the Drina Corps because we did not have any means to establish our own

22     hub.  Veliki Zep was suitable to be the hub of the Drina Corps as well.

23     The terrain lended itself perfectly for that function.

24             JUDGE AGIUS:  Mr. Zivanovic, I want to understand better.

25     Referring to his previous answer, not this last one, when he said

Page 22272

 1     Pribicevac, he mounted a KZU 61, and for radio device RUP-12, he mounted

 2     a KZU 3 to secure communications.  Were these kind of scrambling machines

 3     or what, scramble devices or what?  If he could describe how they

 4     protected speech communication, these two pieces of equipment.

 5             MR. ZIVANOVIC: [Interpretation]

 6        Q.   You heard the President's question.  You understood, I suppose,

 7     so could you please answer.

 8        A.   KZU 61, when I was talking, maybe it was too fast.  I mounted

 9     that to protect speech on the relay route for RRU-1; and as for the

10     operations, when it came to RUP-12 radio-sets, that's where I mounted the

11     KZU 63 to protect speech as well.

12             JUDGE AGIUS:  What I want to know as well --

13             THE WITNESS: [Interpretation] I believe I was clear.

14             JUDGE AGIUS:  Yes.  But what I want to know, Mr. Blagojevic, is

15     how these two pieces of equipment, the KZU 61 and KZU 63, protected

16     speech.  What was their effect?  How would speech communication be

17     protected by their use?  Did they scramble speech communication or what?

18             THE WITNESS: [Interpretation] With RUP-12, which doesn't have a

19     KZU 63, you can't hear a thing from the device that has a KZU 63;

20     complete protection.  And KZU 61 on a relay device scrambles, distorts

21     speech; it distorts it to the point of not being intelligible.

22             JUDGE AGIUS:  Thank you.

23             MR. ZIVANOVIC: [Interpretation]

24        Q.   I showed you --

25             JUDGE AGIUS:  One moment.  Sorry, again, Mr. Zivanovic.

Page 22273

 1             But in the case of an RUP-12 using a KZU 63 device, you say you

 2     have complete protection; you cannot hear a thing.  But if you are

 3     communicating with someone at the other end, how would that person on the

 4     other end be able to hear what you are saying, if with the KZU 63 you

 5     have complete protection and you don't hear a thing?

 6             In other words, does the person on the receiving end, does he

 7     require to have special equipment to receive the communication when it's

 8     passing through a KZU 63 device?

 9             THE WITNESS: [Interpretation] Every combat activity or group that

10     participated in Operation Srebrenica had a RUP-12 with a KZU 63 that I

11     personally mounted on that device, so that it was possible to communicate

12     for all the combat groups between themselves and the command of the

13     combat task that was located in Pribicevac.

14             JUDGE AGIUS:  All right.  So, my final question to you:  Do you

15     confirm to me that there was no means at the time, no technical means at

16     the time, by which one could intercept a communication between RUP-12

17     machines with a KZU 63 device mounted?

18             THE WITNESS: [Interpretation] Correct.  It was impossible to

19     intercept or listen in to any of those conversations.

20             JUDGE AGIUS:  Thank you.

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   Let's just clarify a little bit more.  An interlocutor who would

23     be using a KZU 63, what would the other interlocutor have to have in

24     order to hear him, i.e., to be able to understand what the first person

25     was saying?  What does the other interlocutor have to have at his

Page 22274

 1     disposal?

 2        A.   In order for somebody who's not in the network of RUP-12 devices,

 3     to be able to hear what is being said in the network supplied with a

 4     KZU 63, he would have the same KZU 63 on an RUP-12.  However, a certain

 5     key has to be inserted into that other KZU 63, so the device itself is

 6     not enough.  You have to have a numerical key that consists of several

 7     digits, more than one digit, and that has to be inserted into that KZU 63

 8     device.

 9        Q.   Does that mean that somebody who wanted to listen in to such a

10     conversation would have to have both the device and several -- and the

11     several-digit key?

12        A.   The same key, not just any, the same key, the same device.  Yes.

13     If they had that, they would be able to intercept and listen in to the

14     conversations.

15        Q.   Thank you.  I've shown you the expert opinion provided by

16     Mr. Djuro Rodic, and I'm going to ask you about several details of that

17     analysis.  Could you please look at the binder that has been presented to

18     you.  You will find it under number 3.  On page 22, there is an image, a

19     scheme.  This is 1D323 and page 22, attachment 53.  It's a schematic.

20        A.   Yes, I can see it.

21        Q.   Could you please hold on just for a second for the image to

22     appear on our screens as well.

23        A.   Before the image appears on your screen, Mr. Zivanovic, could you

24     please explain things to me.  Everything I have is in English.  What is

25     this?  I need your explanation.

Page 22275

 1        Q.   As far as I can see, this is an antenna for RRU-800.  I suppose

 2     you are able to recognise this?

 3        A.   Yes, I can see that.  That's okay, but everything is in English.

 4     Why am I looking at this?

 5        Q.   Unfortunately, there has been a mistake.  I've not been able to

 6     locate the original analysis in e-court; and since I'll be asking you

 7     about the image only, I believe that in this case you will be able to

 8     recognise what the thing is all about without being able to understand

 9     the words.

10             My question is this:  Could you please explain what is this?

11     What are we looking at here?

12        A.   This is an antenna for RRU-800, and the same one is for the 200

13     device.  Let me explain.  This is the antenna holder which has up to

14     eight parts.  There are two radio -- antenna radiators on the top; and

15     here on the side --

16             JUDGE AGIUS:  Stop for one moment.  Sorry to interrupt you like

17     this, Mr. Blagojevic.

18             Mr. Zivanovic, from what I can gather, Mr. Blagojevic is pointing

19     to the diagram that he has in front of him, but we can't see what he's

20     pointing at from that diagram.

21             MR. ZIVANOVIC: [Interpretation]

22        Q.   Yes.  Mr. Blagojevic, we cannot see what you are pointing at.  I

23     don't know whether there are any technical possibilities to have that

24     shown to us.  I'm going to ask you just one thing.  I'm going to rephrase

25     my question a little.  I just want to ask you to tell us --

Page 22276

 1             JUDGE AGIUS:  Ultimately, Mr. Zivanovic, because let's be

 2     practical.  In relation to this diagram, what is the purpose of your

 3     question or your series of questions?  What do you want to establish?

 4             MR. ZIVANOVIC:  I would like for him to establish the name of two

 5     devices at the very top of the antenna.

 6             JUDGE AGIUS:  All right.  You mean to say where there is

 7     reflector and radiator?

 8             MR. ZIVANOVIC:  Yes.  And my question is if he could confirm that

 9     such a position of the radiator was the same as at the place, at the

10     site --

11             JUDGE AGIUS:  Then go --

12             MR. ZIVANOVIC:  -- as in 1995.

13             JUDGE AGIUS:  -- straight to those questions.

14                           [Trial Chamber and registrar confer]

15             JUDGE AGIUS:  And I am told that the only way, "technical" if you

16     can so call it, that we can go about it is for the witness to mark the

17     document that he has in front of him; and then it will be brought over

18     here and we can see it later on, but I don't think this is the optimum.

19             MR. ZIVANOVIC:  Yes.

20             JUDGE AGIUS:  So, if the purpose of your question is what you

21     said, I think you can address the witness straight to the top of that

22     diagram where you have those two pieces, those two devices, and you ask

23     the questions.

24             MR. ZIVANOVIC: [Interpretation]

25        Q.   Can you please tell us, what are the two things or devices that

Page 22277

 1     you see at the very top of the antenna pole?

 2        A.   On the top of the antenna pole are radiators.  It says reflector

 3     or radiator here; but if you pay a closer attention, you will see that

 4     there are actually two radiators and two reflectors, and the antenna's

 5     beams go from the reflector across the radiator.  And these radiators

 6     have to be in a horizontal position when they're mounted; otherwise,

 7     there is another way of mounting is when the antenna pole joints are

 8     vertical.  The best position for the radiators is when they are in a

 9     horizontal position; that's when they can establish the best

10     communication because they radiate the best.

11        Q.   Mr. Blagojevic, you are looking at the image and the position of

12     the radiators.  Can you tell us whether at that time, can you remember,

13     when was the position of those radiators just the same on the antenna

14     system on Veliki Zep and other features?  Can you remember that and can

15     you confirm the position of the radiators at that time?

16        A.   All the operators, as well as the communications officers, know

17     that that's the rule for the antenna to be mounted; that is, radiators

18     have to be in a horizontal position.  That's according to our rules and

19     that's how things were done after all.

20        Q.   Thank you.  I will no longer need this schematic.  Can you please

21     tell us something about the power that RRU-800 devices used at the time?

22        A.   If I tell you that while I was a student at the military academy

23     that already then RRU-800 was a museum exhibit and was discontinued, was

24     no longer produced, then you can imagine too what was the condition of

25     those devices 20 years later, 25 years later.  These devices had to use a

Page 22278

 1     much reduced power on shorter distances.  The full power was 10 watts and

 2     reduced power was 5 watts.  However, because of the state of repair of

 3     these devices, you have to count with a 25 to 30 per cent less power.

 4     And why did we reduce the power?  It is part of the instructions which

 5     says that this is part of a measure of electronic protection and less

 6     possibility of interception on the part of the enemy side and conditions

 7     with the energy supply because the device had to be supplied either

 8     through a generator or through a power network.

 9             RR distances were up to 15 kilometres, even up to the Rogatica

10     Brigade, the 2nd Rogatica Brigade, and especially to the Zvornik Brigade,

11     Vlasenica, Veliki Zep, Cer, Gucova, Zvornik.  All of that was up to 15

12     kilometres' distance.  I wouldn't be able to give you the precise

13     distances.  I would have to take measurements, but I don't have a map in

14     front of me, so it's difficult for me to tell you exactly.  At that time,

15     I had a map and I knew exactly what the distances were.

16        Q.   Can you tell me something about the meaning of the so-called

17     duplex connection.  We have come across this, but we need you to explain

18     the term for us.

19        A.   Let me explain.  A duplex connection is speech on one frequency

20     and reception on another frequency.  A duplex connection can only be

21     established with radio relay devices, and radio-sets can only establish a

22     simplex connection.  It takes a radio relay device to be able to

23     establish a duplex connection.

24        Q.   Does this mean that if you have a couple of RRU-800 devices, a

25     conversation can only take place on two different frequencies between one

Page 22279

 1     point and another?

 2        A.   Yes, correctly, and that's what was always planned.  Two

 3     frequencies were always taken into account when planning communication.

 4        Q.   How were the frequencies determined for different RRU-800 routes?

 5        A.   Frequencies for RRU-800 were determined based on the technical

 6     characteristics of each particular device.  A minimum difference between

 7     the emission and reception frequencies had to be at least 50 kilohertz,

 8     and that was what determined the frequency.  I, as the chief of

 9     communications of the Drina Corps in this particular case, was not the

10     one who determined frequencies.  The frequencies, some of them at least,

11     were determined by the Main Staff, the chief of communications for the

12     Main Staff; and some were adjusted to the characteristics of the hubs in

13     Cer, Gucevo, Strazbenica, and so on and so forth.

14        Q.   Do you know who specifically designated these frequencies for

15     RRU-800 communications between the command of the Drina Corps in

16     Vlasenica and Zvornik?

17        A.   From Vlasenica to Veliki Zep, the frequencies were determined by

18     the chief of communications of the Main Staff because that's

19     communications between the Main Staff and the corps command, but it was

20     the same route for communications towards units.  Veliki Zep is also a

21     hub for the command of the Drina Corps.  From Veliki Zep to Cer, that was

22     within the jurisdiction of the communications authorities of another

23     state, and from Cer to Gucevo as well.  From Gucevo to Zvornik, the relay

24     communications were adjusted, but it was decided in principle by the

25     chief of communications who was in charge of that territory.  Neither I

Page 22280

 1     nor the chief of communications of the Main Staff were responsible for

 2     that.

 3        Q.   When you mentioned another state, did you mean Yugoslavia as it

 4     was then?

 5        A.   Yes.

 6        Q.   Now, could we look at another attachment from the findings of

 7     Mr. Rodic, 1D322, page 13 and page 14.  In your bundle, it's the second

 8     tab, also pages 13 and 14.

 9        A.   You said page 13?

10        Q.   Yes.

11        A.   Yes, I can see it.

12             MR. ZIVANOVIC:  This document was shown to our expert, Rodic, but

13     I see that it is not translated in English.  There are just few locations

14     and references, number of references.

15        Q.   [Interpretation] Can you please tell me -- or rather, can you

16     confirm if this is the plan of frequencies -- or, in fact, you tell me

17     yourself what is this.

18        A.   As you say, this is the plan of frequencies; however, it contains

19     information about radio relay routes that I submitted to the chief of

20     communications of the Main Staff.  You will remember my explanation from

21     a moment ago that we were not in charge of certain hubs, so we couldn't

22     determine frequencies for some of our units.  Therefore, I gathered radio

23     relay frequencies from our units and submitted them to our chief of

24     communications to have it on record to avoid messing up.

25        Q.   Tell me, in addition to this document where frequencies are

Page 22281

 1     marked, do you know if these frequencies had ever been changed during the

 2     war?

 3        A.   These frequencies have not been changed from the beginning of the

 4     war because there was no interference.  Now, whether anybody listened in,

 5     I don't want to go into that.  We did our best to avoid listening and

 6     interception, but there was no interference and no jamming, so there was

 7     no need to change these frequencies.

 8        Q.   Can you tell us if the Drina Corps was even able to change these

 9     frequencies.  Did you, as chief of communications, or anyone else in the

10     Drina Corps have the ability to change these frequencies?

11        A.   I, as chief of communications, did not have the right, the power,

12     to change it because none of these frequencies was specifically the

13     frequency of the Drina Corps, which would have given me jurisdiction.

14     But in this case, I was not able to, no.

15        Q.   What about these end radio relay stations in Vlasenica and in

16     Zvornik, were they stationary?

17        A.   Radio relay stations, when they operate, they're always

18     stationary; that's the law.

19        Q.   Were they integrated with other communications systems?

20        A.   Radio relay communications, whenever possible, are integrated

21     with both radio and wire communications; however, in our case they were

22     integrated with only wire communications.

23        Q.   These stations, RRU-800, could they be moved from one location to

24     another?

25        A.   Radio relay stations were movable; however, unlike radio devices,

Page 22282

 1     radio relay stations beam in one direction, so moving them would be like

 2     looking for a needle in a haystack.  They work point to point; and if you

 3     move the station, then the other participant would have to search for

 4     that point in the territory.

 5             THE INTERPRETER:  Could the witness repeat the last thing he said

 6     about antennas.

 7             MR. ZIVANOVIC: [Interpretation]

 8        Q.   Could you repeat the last thing that interpreters didn't hear.

 9     You said the stations were working point to point; and if you move the

10     station, then the other participant has to search for that point in the

11     field.  And after that, you said something else; so if you can remember

12     please say it again.

13        A.   A station that would relocate would be moving on a vehicle,

14     therefore.  How would we mount the antenna then?  The rule did not

15     prescribe that, and it would be impossible anyway.  That is why work in

16     motion was not applied.  It only operated on a stationary basis.

17        Q.   You've already said this, I believe, but please confirm.  Does

18     this mean that while you were chief of communications, these stations,

19     RRU-800, were not moved from one point to another?

20        A.   They were not.  They worked on a stationary basis.

21        Q.   I have just one more question for you:  Can you tell me, was it

22     at all possible to establish direct radio relay communication with

23     RRU-800 from Vlasenica to Zvornik?

24        A.   In view of the lay of the land, it was impossible to have direct

25     communication between Vlasenica and Zvornik.  There was no optic

Page 22283

 1     visibility.

 2        Q.   Thank you, Mr. Blagojevic.  I have no further questions for you.

 3             JUDGE AGIUS:  I thank you so much, Mr. Zivanovic.

 4             Mr. Ostojic, you indicated 30 minutes.

 5             Yes, Mr. Nikolic.

 6             MR. NIKOLIC: [Interpretation] Good morning, Mr. President.  I

 7     have a few questions.

 8             JUDGE AGIUS:  Yes, go ahead.  Please introduce yourself with the

 9     witness.

10                           Cross-examination by Mr. Nikolic:

11        Q.   [Interpretation] Good morning, Mr. Blagojevic.  My name is

12     Predrag Nikolic, an attorney on the team of the accused Ljubisa Beara.  I

13     have a few questions regarding the technical characteristics of the TCE

14     switchboard.

15             Tell me, was it possible, with the system of communications that

16     you explained and that operated in 1995, to establish communications with

17     the public PTT service?

18        A.   Well, yes.

19        Q.   How?

20        A.   Quite simply, from the PTT switchboard in any place where we

21     were, the corps command brought a number of plug-ins from the PTT to us;

22     and in every brigade command, we brought in connections from TC -- from

23     the PTT service to our own communications.  We had a link in any case.

24        Q.   Does it mean that from the corps command you could directly to

25     any participant on a PTT line in any location in Republika Srpska?

Page 22284

 1        A.   You could talk with any participant, not only in Republika Srpska

 2     but also to Germany, to the US, China, Russia, through PTT lines.

 3        Q.   Does that mean that that participant from the PTT network, let's

 4     say from Valjevo, was able to call the corps command?

 5        A.   Yes.

 6        Q.   Was he able in the same way to call lower units?

 7        A.   Yes.

 8        Q.   Where were these PTT lines installed at the corps command?

 9        A.   At the corps command, we connected them to the switchboard that

10     existed in the building of the corps - that's the former administrative

11     building of the mining company, the bauxite processing plant - and there

12     we connected it to our TC 40.

13        Q.   Did I understand this correctly?  If a call from a PTT

14     switchboard in any town or place in Yugoslavia comes to the switchboard

15     at the corps command, the operator would be able to connect another

16     collocutor, not only in the corps, but also in lower units?

17        A.   That's correct.

18        Q.   Thank you.

19             MR. NIKOLIC:  I have no other questions.

20             JUDGE AGIUS:  Thank you, Mr. Nikolic.

21             Madam Nikolic, you intimated you were not going to cross-examine

22     this witness?

23             MS. NIKOLIC: [Interpretation] That's correct, Your Honour.  Thank

24     you.  I have no questions.

25             JUDGE AGIUS:  Thank you.

Page 22285

 1             The same applies to you, Mr. Lazarevic?

 2             MR. LAZAREVIC:  Yes, Your Honour.

 3             JUDGE AGIUS:  Thank you.

 4             Madam Faveau?  Mr. Petrusic will be cross-examining the witness

 5     instead.

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

 7                           Cross-examination by Mr. Petrusic:

 8        Q.   [Interpretation] Good morning, Mr. Blagojevic.

 9        A.   Good morning.

10        Q.   My name is Nenad Petrusic; and on behalf of the Defence team of

11     General Miletic, I will ask you a few questions.  At the outset, I'd like

12     to look into your relationship as chief of communications in the Drina

13     Corps with the command; that is, the staff.

14             You were subordinated, as you said, to the Chief of Staff of the

15     Drina Corps?

16        A.   Correct.

17        Q.   This section of yours, you were part of a section, the arm of

18     communications?

19        A.   Could you say that again.

20        Q.   Was your organ of communications on the level of section?

21        A.   We should have had another five men; however, it was wartime and

22     there was shortage of personnel.  I was alone.

23        Q.   And you had one unit for technical maintenance, conditionally

24     speaking, and that was the 5th Communications Battalion of the

25     Drina Corps; correct?

Page 22286

 1        A.   It was a unit for establishing and maintaining communications;

 2     whereas, technical maintenance is something entirely different.

 3        Q.   Thank you for that clarification.  Did you, therefore, as chief

 4     of communications, participate in the preparation and submission of

 5     proposals to the corps commander or Chief of Staff when certain combat

 6     documents were developed, documents that involved the communications

 7     organ in a certain operation?

 8        A.   I participated in the preparation of documents for every

 9     operation, precisely for the reasons stated, because personnel and

10     equipment of communications need to be employed and communications need

11     to be planned.

12        Q.   So you made a proposal to the commander how to organize this

13     communication system?

14        A.   Correct.

15             MR. PETRUSIC: [Interpretation] Could we call up 5D1182.  We have

16     a draft translation for this, and I would like it provided to the

17     Chamber.  It has also been supplied to the Prosecution and the Defence

18     teams of course.

19             JUDGE AGIUS:  Thank you, Mr. Petrusic.

20             MR. PETRUSIC: [Interpretation]

21        Q.   Mr. Blagojevic, do you have a document before you marked 5D1182?

22        A.   I do.

23        Q.   This is a document from the command of the Drina Corps, dated

24     14 March 1994, signed by the commander, Major-General Milenko Zivanovic.

25     At the top of the document, we read:  "Establishing a section of

Page 22287

 1     communications for the requirements of..."  please let me read this,

 2     "... for the requirements of the Tactical Group 1.  Order."

 3             Does it say in this order that from the composition of the

 4     5th Communications Battalion, a movable, a mobile, communications section

 5     should be set up that would consist of the commander of the section,

 6     operator of the radio relay device, an encryptor and Teletypist, and one

 7     driver?

 8        A.   Correct.

 9        Q.   In this order, item 2, do you see that the equipment in this

10     section of communications are to be RRU-1 and KZS?  Do you see that?

11        A.   I see it.  KZ is a station.

12        Q.   Please let me ask my question, and that was going precisely what

13     you anticipated.  This acronym, KZS, is what?

14        A.   Encrypting station.

15        Q.   So these items, 1 and 2, was it you or someone from your

16     communications organ that proposed it to the commander?  That was within

17     your area of expertise.

18        A.   Mr. Petrusic, I prepared the whole order, all of the items.

19        Q.   We see below, in item 5, that the dead-line for executing this

20     task is the 16th of March, 1994.  So is it the case that this station at

21     Pribicevac had to be established and put into operation by this

22     dead-line, 16th March?

23        A.   In the order, you read that the commander of the tactical group

24     of Pribicevac shall inform the commander at 1200 hours, and that was the

25     dead-line for the order, because with the establishment of radio relay

Page 22288

 1     communication, it was possible to inform the commander.

 2        Q.   Was it really put into operation then?

 3        A.   Yes.

 4        Q.   Did it then continue to operate throughout 1994 and even in

 5     June 1995?

 6        A.   From the time when it was established until the completion of

 7     Srebrenica operation, this communication worked.

 8        Q.   We heard here that this communication started to operate in

 9     January 1995, and it was even given a frequency, 259.275 megahertz.  So I

10     want to know is it the case that in January 1995 some other type of

11     communication was established, apart from this?

12        A.   This was the only radio relay communication between Veliki Zep

13     and Pribicevac using RRU-1, and 275 megahertz was not possible because

14     the frequency range for this device is 230 to 270 megahertz.

15        Q.   You probably misheard me.  I was talking about a frequency of

16     259.275 megahertz, so the first one is 259.

17        A.   259 was possible with -- I don't have the plan of frequencies

18     before me, and I don't know by heart what the frequencies were, but 275

19     was impossible was -- because of the characteristics of the device.

20        Q.   But to conclude, it was not established in January 1995?

21        A.   No, it was not.

22        Q.   Could we move on to 5D1181.  This is also an order from the

23     command of the Drina Corps dated 11 December 1994 issued by Major-General

24     Milenko Zivanovic, commander of the Drina Corps.  And it's --

25             JUDGE AGIUS:  Mr. Petrusic, I'm sorry to interrupt you.  But if

Page 22289

 1     you look at page 28, line 16, when you are describing this document, you

 2     say an order from command of the Drina Corps, dated 11th December 1994,

 3     issued by Major-General Milenko Zivanovic.  It is, indeed, issued by

 4     Milenko Zivanovic, but the date we have here is 1st February 1994.

 5             So is it --

 6             MR. PETRUSIC: [Microphone not activated]

 7             JUDGE AGIUS:  No.  But I want to make sure that the translation

 8     that we have --

 9             MR. PETRUSIC: [Interpretation] Yes, yes, Your Honours.  You

10     will -- I read this date as the 11th of December.  But it's also possible

11     it could be the 11th of February, because in the copy that I have in the

12     Serbian language, yes, it's really possible.

13             JUDGE AGIUS:  Yes.  But --

14             MR. PETRUSIC: [Interpretation] Mrs. Faveau has just drawn my

15     attention --

16             JUDGE AGIUS:  -- I want you to think further about your answer.

17     Could you please go to the last line of that document, which starts with:

18     [B/C/S spoken].  There you have the date again:  "Dead-line for the

19     execution is."  Then you have a date which looks as if it is

20     10th February 1994.

21             Anyway, let's say you will look into this later on.  I don't

22     think it is important for the time being.  Let's not waste or lose time

23     on this, but please look into it so that if there is a -- and there in

24     the English translation we will correct it.

25             Yes, Madam Faveau.

Page 22290

 1             MR. PETRUSIC: [Interpretation] We will probably take a break.

 2             JUDGE AGIUS:  No, no. We don't need a break.  We can continue

 3     with the question unless it's referred -- oh, it's break time.

 4             Yes, Madam Faveau.

 5             MS. FAVEAU: [Interpretation] I would just like to clarify one

 6     point.  This is an unofficial translation done by the Defence, so the

 7     date wasn't quite clear.  And when my team translated this document, the

 8     date is the 1st of February, 1994.  In fact, they referred to this last

 9     sentence of the document.  This is why we have the date of the 1st of

10     February, 1994, because the date was not very legible in the B/C/S

11     version.

12             JUDGE AGIUS:  All right.  Anyway, you think about this.

13             We'll have a 25-minute break starting from now.  Thank you.

14                           --- Recess taken at 10.31 a.m.

15                           --- On resuming at 11.01 a.m.

16             JUDGE AGIUS:  Okay.  So, irrespective of the correct date of this

17     document, which I think should be February and not December, let's

18     proceed with your question, please, to the witness.

19             MR. PETRUSIC: [Interpretation] Yes.  During the break, we had

20     consultations.  It was probably the month of February.  Actually, it was

21     the 1st of February, 1994.

22        Q.   Mr. Blagojevic, could you please look at the document 5D1181, and

23     you will see.  Do you have that document in front of you?

24        A.   Yes, I do.

25        Q.   The commander of the Drina Corps orders that a radio interception

Page 22291

 1     group force should be established in order to detect and monitor enemy

 2     communication in the area of electronic surveillance, and then he

 3     provides the location which is Jeceva, Zebanjsko, Ljeskovik, Kamenica,

 4     and Zepa.

 5             Do you know that this radio eavesdropping group was, indeed,

 6     established; or rather, did you, as the chief of communications, or the

 7     5th Engineering Battalion participate in the equipping of this particular

 8     radio eavesdropping group?

 9        A.   I was aware of this order.  You made a slip of the tongue.  It

10     was not the 5th Engineering Battalion, but the 5th Communication

11     Battalion.  We were informed and aware of this order because information

12     was to be transferred from a hill Sarampov, (Pribicevac), to the corps

13     command and the organs that had use of the information that was

14     transmitted, and that's what we did.

15        Q.   It may be concluded from this order that what should be monitored

16     were radio communication between Srebrenica and Zepa.  Was that something

17     that was within the purview of the intelligence organs, and I'm talking

18     about the collection of information here?

19        A.   Precisely so.  The radio eavesdropping group was established in

20     order to listen in to the enemy radio communication in the territories of

21     Zepa and Srebrenica.

22        Q.   In the corps command, did you have another similar group; or to

23     be more precise, are you aware of the existence of 4th Radio

24     Reconnoitring or Reconnaissance group within that corps?

25        A.   The radio reconnaissance platoon existed within the Drina Corps,

Page 22292

 1     and it was headquartered in Vlasenica.  But most of the men were at

 2     forward points or posts as radio eavesdropping groups, and there were

 3     other such eavesdropping group.  And if you want me to, I can --

 4        Q.   Their main task was to collect and monitor radio traffic in the

 5     enemy territory.  Is that correct?

 6        A.   Yes, it is.

 7        Q.   And the information collected in this way was then submitted to

 8     the command organs?

 9        A.   Yes.

10        Q.   You also spoke already about that, but now I'm asking you again

11     what was the main aspect of communication lines between the Drina Corps

12     and the brigade commands?

13        A.   Between the Drina Corps and the brigade commands, the main line

14     of communication was a radio relay communication line.

15        Q.   It seems that you've already told us that there was also a wire

16     connection; is that correct?

17        A.   A wire connection existed from the beginning to the very end with

18     the Milica Brigade.

19        Q.   When it comes to the switchboard, more specifically at the corps

20     command, did a civilian number came there?

21        A.   Yes.  I've already said that to Mr. Zivanovic.

22        Q.   Yes.  I'm just using this for the basis for my further questions.

23     This civilian number, was it further on distributed through extension

24     numbers to the offices of certain officers?

25        A.   The commander and the Chief of Staff, the chief of security, and

Page 22293

 1     the chief of intelligence had direct civilian numbers.  And there was one

 2     civilian number that was attached to the switchboard, and that one number

 3     had extensions to other members of the command from the switchboard.

 4        Q.   And, now, what was the civilian treatment of this postal

 5     communication between the brigade command and the battalion command?

 6        A.   The brigade command and the battalion commands were not very

 7     often connected because of the possibilities and the positions that were

 8     held by the battalion commands.  Wherever it was possible, it was used

 9     but that was not very often.

10             MR. PETRUSIC: [Interpretation] Can we now have document 1D338,

11     please.

12        Q.   While this is being brought up into e-court, I would kindly ask

13     you to confirm that this is the system of radio relay lines of which

14     we -- you spoke at great length when answering Mr. Zivanovic's questions,

15     the schematic image.

16        A.   Yes.  This is a schematic that I did myself.

17        Q.   Mr. Blagojevic, from the Main Staff to Vlasenica, i.e., the Drina

18     Corps, was the radio relay line protected?  Was it safe?

19             JUDGE AGIUS:  Mr. Vanderpuye --

20             THE WITNESS: [Interpretation] From the Main Staff --

21             JUDGE AGIUS:  One moment, one moment, one moment.

22             Mr. Vanderpuye.

23             MR. VANDERPUYE:  Thank you, Mr. President.  It's unclear as to

24     when this particular schematic was drawn and to what period of time my

25     colleague is referring to.

Page 22294

 1             JUDGE AGIUS:  Yes.

 2             Could you address that, Mr. Petrusic?

 3             MR. PETRUSIC: [Interpretation] Yes.

 4        Q.   Mr. Blagojevic, this schematic that you have in front of you, was

 5     it in force in 1995, more specifically in July 1995?

 6        A.   Yes.

 7        Q.   Can you now answer my previous question, which was as --

 8             JUDGE AGIUS:  I think we have to.

 9             Mr. Vanderpuye [sic], you have addressed to the witness a

10     question which does not really answer the points raised by

11     Mr. Vanderpuye.

12             Mr. Vanderpuye, yes.  Mr. Vanderpuye would like to know, before

13     Mr. Blagojevic answers your previous question, when this schematic, this

14     particular schematic was drawn and to what period of time you are

15     referring to.

16             So your question suggested to the witness that the schematic that

17     he has in front of you, without indicating when it was drawn and to which

18     period when it was drawn, you are asking him whether it was in force in

19     1995, more specifically in July 1995.  But when was it drawn?  When was

20     this schematic drawn, before or after July 1995; and who is the author of

21     it?

22             MR. PETRUSIC: [Interpretation]

23        Q.   Mr. Blagojevic, you heard the President's suggestion.  Do you

24     want me to repeat the question at all?

25        A.   You don't have to.  This schematic was drawn when the corps was

Page 22295

 1     established, which means in November 1992, and I'm the author.  It was

 2     attached to the orders that applied to the communications, and you can

 3     see that in the heading there is a title "Attachment 2."

 4        Q.   As you have already told us, this communications system was

 5     applied in July 1995?

 6        A.   Yes, that's correct.

 7        Q.   And let's go back to my previous question.  We're talking about

 8     the Main Staff and Vlasenica or the command of the Drina Corps.  Was the

 9     radio relay line between the two protected?  Was it safe?

10        A.   From the Main Staff to the corps command, as well as to the other

11     corps command --

12        Q.   Mr. Blagojevic, hold on.  I'm only interested in this particular

13     route:  The Main Staff-Vlasenica.

14        A.   The Main Staff-Vlasenica was 0574 radio relay route, as you can

15     see it on the schematic.  FM 200 was the marking of the device, and that

16     route was fully protected which means both written and oral communication

17     was -- were protected.  There was a total of eight channels that were all

18     safe.

19        Q.   In order to establish a communication with Zvornik, you had to go

20     via Veliki Zep-Cer-Gucevo-Zvornik.  Did I understand you correctly?

21        A.   Yes.

22        Q.   This particular radio relay route, was it protected along its

23     entire length or just in some of its parts?

24        A.   The radio relay line between Vlasenica and Zvornik was protected

25     and safe, and it was impossible to listen in between Veliki Zep in Cer.

Page 22296

 1     And as for Vlasenica-Veliki Zep, Cer-Gucevo, and Gucevo-Zvornik, this is

 2     where it was possible to listen in under the condition that you enter the

 3     radio relay beam which was difficult because we applied measures of

 4     anti-electronic protection.  You could only intercept oral communication,

 5     which was impossible with the written communication because the written

 6     communication was always encrypted, and that's how they were broadcast.

 7             JUDGE KWON:  Mr. Petrusic, as a layman of communication and

 8     without having the translation, it's almost impossible to follow.  For

 9     example, I couldn't locate in this schematic where the Main Staff is,

10     and I couldn't find the 0574 radio route either.  So could you bear that

11     in mind?

12             MR. PETRUSIC: [Interpretation]

13        Q.   Mr. Blagojevic, kindly look at the schematic that is in front of

14     you and follow the markings on it -- let me rephrase that.

15             In the schematic that you have in front of you, the marking

16     Crna Rijeka, does it imply the Main Staff?

17        A.   Crna Rijeka stands for the Main Staff, and this is what you can

18     see written above the circle, the GSV of Republika Srpska.

19        Q.   It is left to the centre --

20        A.   Left to Veliki Zep --

21        Q.   Hold on.  It is left to the central square marked as Veliki Zep?

22        A.   Yes.

23        Q.   Kindly bear in mind that these documents will be returned to us.

24     Could you please make a circle around that particular location.

25        A.   [Marks]

Page 22297

 1        Q.   I'm referring to the location of Crna Rijeka or the Main Staff

 2     that we have just identified there.  And could you please also answer my

 3     next question -- or, actually, it was the second question by the

 4     Presiding Judge, which is the radio relay route 0674, is that the radio

 5     relay route that went from the location marked as Vlasenica to the Veliki

 6     Zep square?

 7             JUDGE KWON:  Mr. Petrusic, now I found 0674.  It was formerly

 8     translated as 0574, so that's the reason I couldn't find it.

 9             Let's move.  Yes.

10             MR. PETRUSIC: [Interpretation] Thank you, Your Honour, for your

11     intervention.  I believe that now this problem has been removed, and we

12     have now identified the position of the Main Staff.

13             And now I would like to call up document 5D1186 --

14             JUDGE AGIUS:  Yes.

15             MR. PETRUSIC: [Interpretation] -- 1186.

16             JUDGE AGIUS:  Yes, while we load this document.

17             Mr. Vanderpuye, please.

18             MR. VANDERPUYE:  Thank you, Mr. President.  Actually, I'm not

19     convinced that we have resolved the issue as you might be.  The

20     translation was 0574, and it was mentioned in connection with the corps

21     command and Main Staff.  0674 traverses the corps command and Veliki Zep,

22     which is the relay point, and I'm not sure that that's what the witness

23     was referring to, at least it's not clear to me in the record.  So if my

24     learned friend would clarify that issue, I think that would make the

25     record clear.

Page 22298

 1             JUDGE AGIUS:  Mr. Petrusic, who is quite familiar with this

 2     schematic, or you on cross-examination.  I suggest that Mr. Petrusic

 3     tries to sort this out now.

 4             MR. PETRUSIC: [Interpretation]

 5        Q.   Mr. Blagojevic, could you please answer this objection.  When it

 6     comes to the connection between the Main Staff and Vlasenica, what was

 7     Veliki Zep in that connection?  Let's deal with that.  Was Veliki Zep the

 8     radio relay hub for all lines irrespective of their origin?

 9        A.   Veliki Zep was a radio relay you hub.  It was the hub of the

10     Main Staff, and in this case of the Drina Corps as well.  From the relay

11     devices at Veliki Zep to the command of the Main Staff, there was a

12     multi-wire cable.

13             MR. PETRUSIC: [Interpretation] I don't know if my learned friend

14     is happy with this explanation; but in any case, he will have an

15     opportunity to cross-examine the witness and ask for further

16     clarification.

17             JUDGE AGIUS:  Okay.  Let's proceed.  I saw Mr. Vanderpuye

18     nodding.

19             MR. PETRUSIC: [Interpretation]

20        Q.   Mr. Blagojevic, was Veliki Zep connected with cables, to put it

21     in lay terms, with the Main Staff?

22        A.   Yes, by cables or by a wire connection.

23             MR. PETRUSIC: [Interpretation] And now I would like to call

24     5D1186 up in e-court.

25        Q.   Mr. Blagojevic, before you, you have a document which is

Page 22299

 1     entitled:  "The overview of the secret codes of the corps command."

 2             Would you please tell us whether this overview of the secret

 3     codes refers to the Drina Corps and its secret codes?

 4        A.   Yes.

 5        Q.   Who was it who assigned those codes -- no, I withdraw that.

 6             What period of time is it that these codes were applied?

 7        A.   This overview of codes applies from the moment when the Drina

 8     Corps was established.  Sometime in 1994 the codes were changed.

 9        Q.   How often did the codes change?

10        A.   Sometimes two times annually.  And in this particular case, these

11     were applied for two years; and then there was a strong suspicion that

12     the conversations may have been listened in and then codes changed.

13        Q.   And when the codes changed in your superior command, in the Main

14     Staff, or in any other commands or any other corps, you would I suppose

15     be informed about the change?

16        A.   I should have been informed; however, the chief of communications

17     of the Main Staff was not duty-bound to inform us.  He could have done it

18     without us being in the know.

19        Q.   Who was it who changed the codes, was it the superior command?

20        A.   The codes are changed and then communicated to step further.  So

21     it is the Main Staff for the corps and brigade commands, and the corps

22     for the battalion commands.

23        Q.   In the fourth column, we have a marking "TGR."  What does this

24     stand for?

25        A.   TGR stands for telegraphy.

Page 22300

 1        Q.   These are codes for teleprinter stations or Teletype stations of

 2     particular units of the Drina Corps?

 3        A.   Yes.  You can see the Drina Corps units starting with 22 and

 4     further on, and those units had Teletyping machines.

 5        Q.   Now, these secret codes, do they refer exclusively to the units

 6     of the Drina Corps and not to the places that are part of those units'

 7     names?

 8        A.   These codes refer only to the units, nothing else.

 9             MR. PETRUSIC: [Interpretation] And, finally, we have another

10     document, 5D187 -- 5D1187.

11             THE WITNESS: [Interpretation] Very well.

12             MR. PETRUSIC: [Interpretation]

13        Q.   We have a list of numbers to identify commanding officers of the

14     Drina Corps here.  Please, can you explain what this schematic means,

15     what this list of number means.

16        A.   This list of numbers to identify commanding officers is attached

17     to the list of secret codes; and when somebody asks for code Zlatar 412,

18     that means he's looking for the corps commander.

19        Q.   And this column from 1 to 10, what does it mean?

20        A.   That means from the 1st till the 10th of the month, from the 11th

21     to the 20th of the month, to identify the commander, you use the number

22     657; from the 21st to the 31st of the month, the commander's number

23     is 150.

24        Q.   These identification numbers for COs, are they changed every

25     month?

Page 22301

 1        A.   This list of identification numbers is subject to change, just as

 2     the list of codes; if they are revealed, divulged, they have to be

 3     changed.

 4        Q.   Mr. Blagojevic, I have no further questions for you.

 5             MR. PETRUSIC: [Interpretation] This is the end of my examination,

 6     Your Honours.

 7             JUDGE AGIUS:  Thank you, Mr. Petrusic.

 8             The Gvero Defence team and the Pandurevic Defence team have

 9     indicated they don't wish to cross-examine this witness.

10             I see a confirmation of that.

11             So it's you, Mr. Vanderpuye, now.  Are you going to stick to your

12     one hour?

13             MR. VANDERPUYE:  I'm hoping to, Mr. President.

14             JUDGE AGIUS:  So are we, Mr. Vanderpuye.  L.

15             Et's proceed, please.

16                           Cross-examination by Mr. Vanderpuye:

17        Q.   Good morning, Mr. Blagojevic.

18        A.   Good morning.

19        Q.   My name is Mr. Vanderpuye.  I'm going to put some questions to

20     you on behalf of the Prosecution in relation to your direct examination.

21     I'll try to be as brief as I can, but you did cover a lot of ground on

22     your direct, and so let's see how you get through this.

23             You indicated, just initially, that the RRU-800 covers a

24     frequency range from 600 to 900 megahertz.

25             Do you recall that testimony, sir?

Page 22302

 1        A.   Yes.

 2        Q.   And, in fact, in the frequency plan that you were referred to by

 3     my colleague Mr. Zivanovic, there is a frequency that is indicated in

 4     that plan that runs from Vlasenica to Veliki Zep of 922 megahertz, which

 5     by your testimony would be outside of the possible range of communication

 6     for that device.

 7        A.   That's a mistake, a typing mistake.

 8             JUDGE AGIUS:  Whose typing mistake?  I think we need to be clear.

 9             MR. VANDERPUYE:  Thank you.

10        Q.   You say that's a typing mistake, Mr. Blagojevic?

11        A.   Yes.

12        Q.   All right.  Let me suggest to you that that document is actually

13     handwritten and that frequency is handwritten, as you've testified to, by

14     you.

15             MR. VANDERPUYE:  If I could just have in e-court, so that I can

16     show Mr. Blagojevic what I'm talking about, 65 ter 2823.  All right.  If

17     we could just page down a little bit, I think right in the middle of the

18     screen, you can see where it says "922/680."

19        Q.   I don't know if you have that in front of you now,

20     Mr. Blagojevic, but I would refer you to number 2 that's indicated on the

21     document you should have in front of, you which is indicated by an

22     ERN number ending in 791.  You can see where it's written in.

23             It's handwritten 922/680, 6-8-0.  That's a radio relay

24     route 0607.  You see that, sir?

25        A.   Yes, here it is.  I can see it.

Page 22303

 1        Q.   And you say that that's a mistake?

 2        A.   A mistake.

 3        Q.   Actually, sir, the mistake is that the RRU-800 has a frequency

 4     range or capacity from 610 megahertz to 960 megahertz.  Isn't that true?

 5        A.   Possibly.

 6        Q.   You're not sure?

 7        A.   I'm no longer sure.

 8        Q.   Now, in 1995, you were the chief of communications for the

 9     Drina Corps, right?

10             JUDGE AGIUS:  He has already answered that question.

11             MR. VANDERPUYE:

12        Q.   And you were responsible for maintaining all communications

13     within that system, within the corps system?

14        A.   Right, that's correct.

15        Q.   And that involved maintaining communications with all the

16     battalions, all the brigades, and the Main Staff?

17        A.   Correct.

18        Q.   And you said before that you were intimately involved in the

19     planning stage of any giving operation that was undertaken by the corps?

20        A.   Correct.

21        Q.   So you had to know the number of units that would participate in

22     any given operation?

23        A.   Correct.

24        Q.   You had to know where they were positioned and where they were

25     going?

Page 22304

 1        A.   Correct.

 2        Q.   You had to know the locations of their command posts and who

 3     their commanders were?

 4        A.   Correct.

 5        Q.   And you had to assist in planning an operation to make sure that

 6     you could provide adequate operational communications among those units?

 7        A.   Correct.

 8        Q.   And in determining what appropriate equipment that you would use,

 9     you had to consider also the type of equipment that was available to you?

10        A.   Correct.

11        Q.   You had to consider the terrain on which that equipment was going

12     to be used?

13        A.   Correct.

14        Q.   You had to consider the distance over which that equipment had to

15     be used, whether it's radio relay, radio, wire, telegraph, or telegram?

16        A.   Correct.

17        Q.   And you also had to pay attention to security issues to make sure

18     that those communications were safe and protected from the enemy?

19        A.   Correct.

20        Q.   Now, over your career, you've participated in the planning of a

21     number of operations; that's fair to say, isn't it?

22        A.   Correct.

23        Q.   You participated in the communications plan that was developed

24     for Krivaja 95?

25        A.   Probably.  I can't remember now which operation it was.

Page 22305

 1        Q.   Okay.  You participated in developing the communications plan

 2     that was used in the Srebrenica operation?

 3        A.   Right.

 4        Q.   And that was in 1995, July, right?

 5        A.   In July, right.

 6        Q.   You participated in preparing the communications plan for a

 7     subsequent operation, Operation Stit, 1995, in November?

 8        A.   In November 1995, I don't know what operation it was.

 9        Q.   All right.  Well, we'll get back to that in just a minute.

10             You also participated in an operation in 1993 by the name of

11     Operation Proboj, right?

12        A.   Well, I don't know which operation it was; the name of the

13     operation itself doesn't help.

14        Q.   But it was an operation that began on the 24th November 1992 and

15     ended 3rd February 1993; you remember that?

16        A.   If that's the operation from axis towards Srebrenica, then I do

17     remember.

18        Q.   This was an operation that involved the liberation of the

19     Podrinje region, and it was designed to force the enemy into a small area

20     to create the conditions for the subsequent operation which was carried

21     out in 1995.  Does that help refresh your recollection?

22        A.   That's right.  That's the operation I remember.

23        Q.   And in relation to that operation, there were combat activities

24     that were carried out in Kamenica, Cerska, Konjevic Polje, Bratunac,

25     Visegrad, and Rogatica, right?

Page 22306

 1        A.   In that operation, there was fighting in Konjevic Polje, Cerska,

 2     and Kamenica; whereas, Rogatica and Visegrad are on another side.  It's

 3     not the same operation.

 4        Q.   All right.  And with respect to your participation in that

 5     operation, you were assigned to coordinate the actions for it along with

 6     Mile Kosoric and Captain Radenko Visnjic.  Do you recall that?

 7        A.   I don't recall that I made it with the two of them, but if you --

 8        Q.   All right.

 9             MR. VANDERPUYE:  If I could just have 65 ter 3413, so that the

10     witness can briefly take a look at it.

11        Q.   All right.  If I could just direct your attention to the bottom

12     of your screen, I think you can see your name in there, where it's

13     indicated the members of the group for the coordination of the actions --

14     of actions are:  Miladin Prstojevic, Mile Kosoric, and you, Nedo

15     Blagojevic.  Can you see that there?

16        A.   I can see that.

17        Q.   And that's accurate, isn't it?

18        A.   It must be true because it's an order from the corps command, but

19     I participated in so many of these operations that I can't recall

20     everything.

21        Q.   Okay.  But you do recall that you were tasked with setting up

22     communications in relation to the carrying out of this particular

23     operation?

24        A.   I remember that.

25        Q.   All right.  And, in particular, you were tasked with setting up

Page 22307

 1     or coordinating those communications among the units that were involved

 2     in the operation and their commanders?

 3        A.   Correct.

 4        Q.   All right.  And you also had to set up communications with the

 5     Yugoslav Army as well, right, the Uzice Corps?

 6        A.   I don't recall that; but, generally speaking, our corps command

 7     and the command of the Uzice Corps were able to communicate.

 8        Q.   Now, the units that participated in that operation included the

 9     Zvornik Brigade, 1st Light Infantry Zvornik Brigade, Bratunac Brigade; it

10     also included elements outside the Drina Corps, including the 1st Krajina

11     Corps and the 2nd Krajina Corps, as well as the 65th Motorised Protection

12     Regiment of the Main Staff, right?

13        A.   There was some interruption in the line.  In that operation, the

14     Zvornik Brigade was involved, the Bircani Brigade, there was one

15     battalion from the 1st Krajina Corps, the Bratunac Brigade, the Milic

16     Brigade, and the Independent Battalion of Skelani.  Those are the units I

17     know about.

18        Q.   Right.  And I take it you know who Vinko Pandurevic is?

19        A.   Vinko Pandurevic was the commander of the Zvornik Brigade.

20        Q.   And what was his role in the operation in which you participated

21     in 1993, 1992 November to February 1993, that we've been discussing?

22        A.   He commanded the Zvornik Brigade, and they were advancing from

23     Zvornik via Kamenica, Konjevic Polje -- I cannot remember the exact axis

24     at this moment, but it was certainly via Kamenica.

25        Q.   All right.  Thank you for that.  Now, if I've understood your

Page 22308

 1     testimony correctly with respect to radio intercepts, you're not

 2     suggesting, sir, that the VRS was not being intercepted by the Bosnian

 3     army, are you?

 4             JUDGE AGIUS:  Yes, Mr. Zivanovic.

 5             MR. ZIVANOVIC:  As far as I recall, the witness didn't say this.

 6             JUDGE AGIUS:  Yes, Mr. Vanderpuye --

 7             MR. ZIVANOVIC:  If we can see the reference page.

 8             JUDGE AGIUS:  In any case, it's cross-examination, so let's

 9     proceed.

10             MR. VANDERPUYE:

11        Q.   Are you suggesting that the Bosnian army was unable to intercept

12     VRS radio relay communications, Mr. Blagojevic?  Is that what the point

13     of your testimony is?

14        A.   If your question relates to radio communication from November

15     1992 to March 1993, they were able to -- I mean, the enemy was able to

16     intercept our radio communications, if that was the point of your

17     question.

18        Q.   All right.

19             MR. VANDERPUYE:  If I could just have just one moment.

20             Could I have 65 ter 3425.

21        Q.   I don't know if you have the document in front of you now, but

22     I'll refer you to this document which is dated 22nd April 1993.  This is

23     a document that is authored by or signed by Drago Nikolic, as the chief

24     of security of the Zvornik Brigade, and it's a document that was

25     transmitted through the channels of the intelligence organ.

Page 22309

 1             In the first paragraph of that document, it says:  "We have

 2     confirmation that the enemy is intensively intercepting our radio and

 3     radio relay communications.  Particularly active are the interception

 4     centres in Tuzla and at Dvor."

 5             Now, that would be after March 1993 that you've indicated that

 6     they lost the ability to intercept your communications.

 7        A.   I don't know what you have been following; but in terms of radio

 8     communications, I said that in 1995 I placed KZU devices, not 1993,

 9     because in 1993, I did not have KZU devices; whereas, in 1995, in June, I

10     mounted KZU devices for the oncoming operation.  That's when they were

11     not able to listen in; however, in the period you are talking about, they

12     were able to listen and intercept.

13        Q.   All right.  So it's accurate to say that in 1993, when this

14     document was authored, that the Bosnian army had the ability to intercept

15     VRS radio relay communications?

16        A.   Radio communications were easier to intercept.  Radio relay

17     communications were harder, sometimes impossible, to intercept.

18        Q.   I appreciate the clarification, but my question is:  As the

19     document states, is it the case that the Bosnian army had the ability to

20     intercept radio relay communications?  You'll see that written in

21     paragraph -- in the first paragraph of this document authored by

22     Mr. Nikolic.

23        A.   I can see that and I agree, and that's what I told you.  Radio

24     communications, yes; radio relay harder, some radio relay impossible.

25        Q.   All right.  If you read further on in this document, Mr. Nikolic

Page 22310

 1     explains what the nature of this problem is.  And in part, he says that

 2     even the most responsible commanding officers in the units are prone to

 3     negligence; and then he proposes a number of things that should be

 4     changed in order to accommodate the problem, such as prevent

 5     unnecessarily long conversations, prohibit the use of Motorola hand-sets,

 6     and change the frequencies in call-signs more often.

 7             You were aware of that in 1993, weren't you, Mr. Blagojevic?

 8        A.   I was aware of that even earlier.  Even in December 1992, I wrote

 9     an order that was signed by the corps commander to the effect that all

10     actions related to combat activities should be related only in writing.

11     It was sent from the corps to brigades.  Precisely for these reasons, it

12     was said that conversations by radio should be minimised.

13        Q.   All right.  You said it wasn't until June 1995 that you actually

14     got what you've called KZ crypto protection for communications.  Is that

15     right?

16        A.   KZU 63 for radio protection, yes.

17        Q.   Would it surprise you to learn that the Bosnian army was actually

18     aware of your request to have those devices installed?

19             MR. VANDERPUYE:  If I could have 65 ter 3407 in e-court for the

20     witness to take a look at.

21        Q.   What you should have in front of you is a report from the

22     2nd Corps command directed towards their intelligence organ, which

23     indicates that you specifically requested, demanded, the installation of

24     KZU 31 cryptographic data equipment to be installed.  In part, this is

25     based on the fact that they say that you were able to break a code of

Page 22311

 1     theirs.

 2             Does this suggest to you, sir, that as late as July 1995, they

 3     were actually picking up your radio communications, communications that

 4     you were having with respect to the protection of your radio -- your

 5     radio relay system?

 6        A.   As for the report of the intelligence organ of the BiH army, it

 7     speaks about the KZU 31, which was already there.  It must be a mistake

 8     there.

 9             THE INTERPRETER:  The interpreter is not sure whether the witness

10     said that it does speak or does not speak.

11             THE WITNESS: [Interpretation] Because from 1993 in March, there

12     was a TG 40 or 41 device on Pribicevac for the encryption of written

13     information.  In 1994, this encrypting device was replaced by the KZU 31.

14     So that this is a mistake.  That's the only thing I can say, but a

15     hundred per cent.

16             MR. VANDERPUYE:

17        Q.   You do admit, though, that you made a specific request for KZU

18     protection in or around June of 1995, right?

19        A.   What is referred to in here, no.

20        Q.   All right.

21        A.   Maybe I requested a KZU 61 for speech protection.

22        Q.   Okay.  Let me refer you to 65 ter 3412.

23             What you should have in front of you is a request signed by

24     General Mladic to fix certain radio relay routes involving -- involving

25     the KZU 61 device.  In particular, he talks about a radio relay route

Page 22312

 1     from Veliki Zep to Cer that had been fixed, and he also indicates that

 2     he's requesting the same team to come and fix other problems in the radio

 3     relay communications network.  And he says:  "Until now, we used the

 4     radio device for protecting speech KZU 61."

 5             He says:  "Due to the decreased use and the quality and

 6     convergence path, we are unable to use the speech protection device

 7     KZU 61."  In other words, those lines of communication were not

 8     protected.

 9             Now, you can see that was the state of affairs in 1993, right?

10        A.   This is probably a mistake.  It must have referred to KZU 71

11     because KZU 61 protects just one path, one line; whereas, KZU 71 protects

12     a group which contains eight paths or eight lines.

13        Q.   Well, could it be that the KZU 61 that is protecting a particular

14     path relates to the use of the SMC device?

15        A.   As for the SMC device, it could not have been 61 because the SMC

16     had 120 channels, and we had -- we did not have an encryption protection.

17     It was only because of its higher frequency that an SMC was more

18     difficult to listen in to.

19        Q.   All right.  The 120-channel radio relay communication between

20     Veliki Zep and Cer is an SMC communication, right?

21        A.   Yes, that's the whole point.

22        Q.   Okay.  And that operated between 4 and 5 gigahertz, you said?

23        A.   Yes.

24        Q.   And in July 1995, there was also a back-up RRU-800 communications

25     path between Veliki Zep and Cer, right?

Page 22313

 1        A.   There was a reserve option even in 1993, but this path was

 2     repaired and returned into good working order.

 3        Q.   When was it repaired --

 4             JUDGE AGIUS:  Yes, one moment.

 5             Madam Faveau.

 6             MS. FAVEAU: [Interpretation] Your Honour, I didn't want to

 7     interrupt before because I didn't know what the Prosecutor was getting

 8     at, but it seems to me that this document has nothing to do with the

 9     Drina Corps.  Perhaps the Prosecutor could tell us what the connection

10     is, because the 1st and 2nd Corps are the only corps mentioned in this

11     document.

12             JUDGE AGIUS:  Yes, Mr. Vanderpuye, if you could answer that,

13     please.

14             MR. VANDERPUYE:  Yes.  It might be that my colleague perhaps has

15     missed the issue.  The document specifically talks about the radio relay

16     direction from Veliki Zep to Cer, which is integral to this witness's

17     testimony concerning the Drina Corps radio relay path between Vlasenica

18     and Zvornik.

19             JUDGE AGIUS:  Yes.

20             Madam Faveau.

21             MS. FAVEAU: [Interpretation] Yes.  But could we perhaps read

22     paragraph 2 in its entirety because the document has mentioned this

23     direction, but it also mention which line is not being used.  It talks

24     about Kozara-Banja Luka and the equipment designed to protect voice

25     KZU 61 for the 1st and 2nd Krajina Corps.  I know nothing about these

Page 22314

 1     technicalities.  Perhaps the witness could explain this to us.

 2             JUDGE AGIUS:  Yes, Mr. Vanderpuye.  Do you wish to comment on

 3     that?

 4             MR. VANDERPUYE:  I'm sure she can put it to the witness if she

 5     wants to.  The point of the issue is that this document describes that

 6     the condition of that line between Veliki Zep and Cer was in disrepair at

 7     a certain point, that it was fixed, that it's 120-channel radio relay

 8     device which is the same device that was, in fact, in 1995 on the same

 9     line --

10             JUDGE AGIUS:  Okay.

11             Mr. Blagojevic, do you need to hear the question again or can you

12     answer it?

13             MR. VANDERPUYE:  My question was, if I recall:  When was it

14     fixed?

15             JUDGE AGIUS:  Your question is on page 51 between lines 23 and

16     line 1 on page 52.

17             THE WITNESS: [Interpretation] Since I was in Vlasenica, and this

18     was within the purview of the Chief of Staff -- chief of communications

19     of the Main Staff, it must have lasted for two or three, days but our

20     lines of communication were not interrupted.  As you've told it yourself,

21     RRU-800 was in reserve, and I suppose that that's when the SMC was

22     replaced by the RRU-800 in order to have the lines of communication

23     working.  Then upon the repairs were completed, the whole thing was

24     reinstated.

25             MR. VANDERPUYE:

Page 22315

 1        Q.   All right.  And so my question is:  When was it repaired, if you

 2     recall?

 3        A.   No.

 4        Q.   Okay.  Do you know whether or not that system, that is, the SMC

 5     line between Veliki Zep and Cer, went down at any point between July or

 6     June or August of 1995?

 7        A.   There were no problems in 1995 with that path during the

 8     bombardment.

 9        Q.   What about in August of 1995, do you recall if there were any

10     problems at that point?

11        A.   As far as I know, there were no problems.

12        Q.   One of the people that is mentioned in this document, 65 ter

13     3412, is an individual by the name of Major Djuro Rodic, engineer.  Do

14     you see that name in front of you?

15        A.   I do.

16        Q.   He testified in this case in August -- he testified actually on

17     the 24th of May and on the 12th of June 2007.  He said that in August of

18     1995, he was asked by Mr. Zivanovic:  "While you were there, did you

19     service that line?  I think you mentioned that a couple of times."

20             And he says:  "Preliminarily, we fixed those 120-channel paths

21     because they were the most important ones and then also the 24-channel

22     ones were the RRU-800 ."

23             Why would he be fixing them in August of 1995 if they weren't

24     down?

25             JUDGE AGIUS:  Yes, Mr. Zivanovic.

Page 22316

 1             MR. ZIVANOVIC:  It is asked -- Mr. Vanderpuye called the witness

 2     to speculate about this information.

 3             JUDGE AGIUS:  He knows the answer to that question or he doesn't.

 4     I mean, we don't go on speculation from Mr. Blagojevic.  Now, I think

 5     he's qualified enough to answer this question.

 6             Yes, Mr. Blagojevic --

 7             THE WITNESS: [Interpretation] I'm qualified enough.

 8             JUDGE AGIUS:  Yes.  And can you answer the question?

 9             THE WITNESS: [Interpretation] I'm qualified enough, but this was

10     not within my purview.  What mattered to me was that I had an

11     uninterrupted line of communication with the units.  I was never informed

12     about that line being down because the person in charge was the chief of

13     communications of the Main Staff.

14             MR. VANDERPUYE:

15        Q.   Well, had the line been down, then the back-up RRU-800 device

16     would go into service; is that fair?

17        A.   Yes.

18        Q.   And in order for you to make use --

19             JUDGE AGIUS:  One moment.

20             MR. ZIVANOVIC:  It is misstatement of testimony of Mr. Rodic.

21             MR. OSTOJIC:  [Microphone not activated]

22             MR. VANDERPUYE:  How about this, how about this.  Maybe this will

23     satisfy you.  How about page 12120, line 15 to 18; maybe that will help

24     you out a little bit.

25             MR. ZIVANOVIC:  He has never told that such that the lines were

Page 22317

 1     interrupted --

 2             JUDGE AGIUS:  Yes.  But I suggest that you look at the reference

 3     that Mr. Vanderpuye has just mentioned.  Now if you need time to look at

 4     it, I will give you time to look at it; otherwise, we will proceed.

 5             MR. ZIVANOVIC:  If it's part of his testimony, but he didn't say

 6     that the line was interrupted.

 7             MR. OSTOJIC:  [Microphone not activated]

 8             JUDGE AGIUS:  Yes, Mr. Vanderpuye.

 9             MR. VANDERPUYE:  The quote from that transcript is:  "And while

10     you were there, did you service that line?"  That's the question,

11     actually.  "I think you mentioned that a couple of times.

12             "A.  Preliminarily, we fixed those 120-channel paths because they

13     were the most important ones and then also the 24-channel ones with the

14     RRU-800."

15             JUDGE AGIUS:  Yes, Mr. Vanderpuye -- Mr. Zivanovic.

16             MR. ZIVANOVIC:  He said that they do the service, but not because

17     the line was interrupted.  It is a point.

18             JUDGE AGIUS:  All right.  Let's carry on.

19             Mr. Vanderpuye, please --

20             MR. VANDERPUYE:  Let me ask one other thing if I could,

21     Mr. President.  Maybe this will clarify.

22        Q.   It continues, and says:  "Okay.  How long were you at the

23     facility in August 1995 fixing those parts?"

24             And the answer is:  "I think we completed that in two days."

25             I think that makes it pretty clear that some fixing going on of

Page 22318

 1     the lines that was witness testified about, and that's what was put to

 2     this witness, just so the record is clear.

 3             JUDGE AGIUS:  All right.

 4             Witness, from your knowledge and recollection, what's your answer

 5     to that?

 6             THE WITNESS: [Interpretation] I just now remembered.  In the

 7     month of August, I was not in the command post in Vlasenica; I was in

 8     another location and performing other duties as well.  So I really can't

 9     answer this question because I don't know.

10             MR. VANDERPUYE:

11        Q.   All right.  Well, you were the chief of communications for the

12     Drina Corps, and that particular radio relay route was integral to your

13     ability to communicate with your subordinate units, right?

14        A.   Yes.

15        Q.   And if there was a problem getting a communication through on

16     that line, that's something that you needed to know about as the chief of

17     communications; otherwise, you wouldn't be able to advise the Chief of

18     Staff or the commander as to what to do in a given situation?

19        A.   I've just told you that.  In the month of August and September, I

20     was not in Vlasenica.  Major Jerdjevic was standing in for me, and I

21     can't answer your question because I wasn't there.  I wasn't abreast of

22     the situation.  I performed other tasks elsewhere.

23        Q.   All right.  I just wanted to draw your attention to 65 ter 2823,

24     and that's the frequency plan that my colleague went over with you.  This

25     is the plan that I think you indicated that you, yourself, prepared.

Page 22319

 1        A.   Yes.

 2        Q.   All right.  And you say that you prepared it so that there would

 3     be a record of the frequencies that were actually in use; is that right?

 4        A.   That is right.

 5        Q.   You also said that those frequencies never changed from the

 6     beginning of the war; is that right?

 7        A.   True, yes.

 8        Q.   All right.  Now, if the frequencies hadn't changed at the

 9     beginning of the war in 1992, what was the special reason to document

10     these frequencies in 1993?

11        A.   In order to update data and plan -- and possible planning of

12     other radio relay lines in order to avoid any confusion or a mix-up.

13        Q.   Well, all that information would have already existed, wouldn't

14     it, as of 1992.  So what was the special reason that you had in October

15     of 1993 to document frequencies that already existed within the

16     structure -- within the communication structure?

17        A.   Most probably, there was a request on the part of the chief of

18     communications of the Main Staff; probably he requested information about

19     the existing lines.

20        Q.   All right.  Now, with respect to the particular radio relay route

21     from Vlasenica to Zvornik, that involved going from Vlasenica to Veliki

22     Zep, then from Veliki Zep to Cer, then from Cer to Gucevo, and then from

23     Gucevo to Zvornik.  That's correct, right?

24        A.   Yes.

25        Q.   Now, with respect to those particular radio relay paths, your

Page 22320

 1     plan here establishes that there was a frequency between Vlasenica and

 2     Veliki Zep of 922 megahertz and 680 megahertz.  You see that there under

 3     number 2, right?

 4        A.   Yes.

 5        Q.   And you can also see that there is a frequency indicated for the

 6     command of the Zvornik Light Infantry Brigade to Gucevo, and it says

 7     radio relay route 65.  That's under number 4 --

 8        A.   Yes.

 9        Q.   -- and that indicates a frequency of 880, it looks like, and 810

10     megahertz?

11        A.   Yes.

12        Q.   All right.  Now, between Veliki Zep and Cer, you've indicated

13     nothing with respect to the RRU-800 device - back-up device, I should

14     say - that operates or could operate between those two points.  That

15     frequency is not in your documentation?

16        A.   This is the confirmation of what I've just said.  The chief of

17     communications of the Main Staff asked me to provide information about

18     our end radio relay stations to the hub, and our Main Staff already had

19     information about the frequencies between the hubs and Veliki Zep.

20        Q.   All right.  Your plan also doesn't indicate any frequency

21     operating between Gucevo and Cer?

22        A.   This frequency plan refers to what the chief of communications of

23     the Main Staff was supposed to update.  When I was answering counsel

24     Zivanovic's questions, I mentioned that when there were interruptions,

25     the operators could change the frequency, but they were duty-bound to

Page 22321

 1     inform and update everybody concerned.  They could do that in case they

 2     suspected interference or that they were being listened in.

 3        Q.   All right.  But in 1995, you had pretty good information that you

 4     were being listened in, right?

 5        A.   Yes.

 6        Q.   But you have no recollection that there was any change to the

 7     frequencies that are indicated in your 1993 plan, right?

 8        A.   There were no changes because they were not needed.  What you

 9     asked me about KZU 31 is not correct.  KZU 61 that General Mladic signed,

10     again not correct.  The radio relay lines and pathways and written

11     information could not have been broken into.  Only speech, only oral

12     communication, could have been intercepted.

13        Q.   All right.

14             MR. VANDERPUYE:  If I could maybe just quickly get through this

15     one document; and then we can, with the Court's permission or

16     instruction, maybe take a break.

17             JUDGE AGIUS:  Okay.

18             MR. VANDERPUYE:  I have 65 ter 1150, if we could not broadcast

19     this.  That will be 1150A for the benefit of the Court, for the English.

20     He has, I think, B.  He should have that in front of him.

21             THE WITNESS: [Interpretation] B.

22             MR. VANDERPUYE:

23        Q.   What I'm showing you, sir, is a radio intercept, and it's

24     indicated that it was taken on the 13th of July, 1995, at 2035 hours, at

25     a frequency of 785 megahertz, which you know corresponds with the

Page 22322

 1     frequency range of an RRU-800 device, a radio relay device.

 2             And it says in part:

 3             "General, sir, is that you?

 4             "Yes."

 5             One speaker says again:  "It's Major Obrenovic.

 6             "Greetings."

 7             Then it goes on and talks about ambushes that he's been setting

 8     up on the wide road and part of Glodjansko Brdo.

 9             He says:  "He just called me two minutes ago.  There's a large

10     column of Turks, three continuous kilometres long, from the school in

11     Glodi.

12             Then he says -- the general says:  "Wait.  Listen, you can't talk

13     like that on the phone.  Call Mane, gather everybody, and send them up

14     there right away."

15             And he answers, in question:  "Mane?

16             "Yes."

17             There is evidence in this case that these events as they are

18     related in this intercept transpired as they are written in the

19     intercept.  Does that suggest to you that, perhaps, the Bosnian army was,

20     in fact, able to intercept RRU-800 communications along the

21     Vlasenica-Zvornik radio relay path?

22        A.   The Vlasenica-Zvornik radio relay path could not be intercepted

23     even by the USA army because that radio relay path did not exist.

24        Q.   Well, it went through a series of connections:  One, from

25     Vlasenica to Veliki Zep; two, from Veliki Zep to Cer; three, from Cer to

Page 22323

 1     Gucevo; and, four, from Gucevo to Zvornik.  Right?

 2        A.   But when you said radio relay path, that's the way I understood.

 3        Q.   Okay.  Okay.  What I mean is the route, then.  Does that

 4     intercept and the fact that there is evidence to corroborate it --

 5             JUDGE AGIUS:  Yes, Mr. Zivanovic.

 6             MR. ZIVANOVIC:  Sorry, sorry.  But this document clearly reads

 7     that it is direction Zvornik-Vlasenica.  It doesn't mean any other

 8     direction, just Zvornik-Vlasenica.

 9             JUDGE AGIUS:  Yes --

10             MR. ZIVANOVIC:  It is question put to the witness; it is document

11     put to the witness.

12             MR. VANDERPUYE:  What the document says is:  "Intercepting the

13     'Zvornik-Vlasenica' radio relay route."

14             It doesn't say anything about a direct connection or an indirect

15     connection.

16             JUDGE AGIUS:  Yes, go ahead.

17             Go ahead, Mr. Vanderpuye.

18             MR. VANDERPUYE:  Thank you.

19        Q.   Sir, it's clear, from the fact that this intercept was captured

20     at 785 megahertz, that that implicates that it was captured within the

21     frequency range of an RRU-800 device?

22        A.   This is the frequency range of an RRU-800, I agree with that.

23        Q.   The Obrenovic that's referred to in this particular intercept is

24     a person that's likely to have been found within that radio relay route,

25     particularly in the Zvornik area, right?

Page 22324

 1        A.   Obrenovic was in the area of Zvornik.  Whether this was the exact

 2     frequency, I wouldn't know off the cuff.  I would have to check.

 3     However, I, personally, believe that they couldn't hear Obrenovic, those

 4     who were intercepting.  They could only hear from the direction of

 5     Gucevo.  They could hear the general - what general, I wouldn't know -

 6     because of the duplex connection.

 7        Q.   A duplex connection has to go through a switchboard, right,

 8     Mr. Blagojevic?

 9        A.   But of course, via a switchboard, yes.

10        Q.   That's right.  And at the point that those connections hit the

11     switchboard, it's possible to hear both collocutors, right,

12     Mr. Blagojevic?

13        A.   Yes, on a condition that there was an insider who was part of

14     their ranks, who was among their ranks.

15             JUDGE AGIUS:  Yes.  Any time when it is convenient for you.

16             MR. VANDERPUYE:  I have only two more questions before the break,

17     if I may.

18             JUDGE AGIUS:  All right.  Okay.

19             Go ahead.

20             MR. VANDERPUYE:

21        Q.   You don't know what the frequency was that operated between Cer

22     and Gucevo?  You don't know, you don't recall that today, do you?

23        A.   Look, I don't remember now, unless I look at the plan of

24     frequencies.  I don't remember the other frequency other.

25        Q.   And that's -- neither one of them is on your plan, right?

Page 22325

 1        A.   I don't know, unless I have a plan in front of me.

 2        Q.   Well, your plan is in front of you, isn't it, your 1993 plan?

 3        A.   Just a moment.

 4             THE REGISTRAR: [via Videolink] Could you give us the 65 ter

 5     number?

 6             MR. VANDERPUYE:  Yes, it's 65 ter 2823.

 7             THE REGISTRAR: [Via videolink] Thank you.

 8             THE WITNESS: [Interpretation] Zvornik, according to this plan in

 9     front of me, that's not the frequency; not the transmission frequency is

10     correct or the reception frequency.

11             MR. VANDERPUYE:

12        Q.   Tell me what the frequency is, Mr. Blagojevic, between Cer and

13     Gucevo.  Let us know when you find it.

14        A.   Between Cer and Gucevo?

15        Q.   Yes, sir.

16        A.   I don't have those frequencies.  I have Gucevo-Zvornik.

17        Q.   Okay.  Thanks.

18             MR. VANDERPUYE:  I think we can take the break at this point,

19     Mr. President.

20             JUDGE AGIUS:  Thank you, Mr. Vanderpuye.

21             We'll have a 25-minute break now.  Thank you.

22                           --- Recess taken at 12.36 p.m.

23                           --- On resuming at 1.03 p.m.

24             JUDGE AGIUS:  Yes, Mr. Vanderpuye.

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

Page 22326

 1        Q.   Mr. Blagojevic, I have here a map that I'm going to try to show

 2     you.  Let me just get the number for you.  That's 65 ter number 3424.

 3             I don't know how well you can see that from where you -- you

 4     don't see it?  Oh, great, okay.

 5             I'm not sure how well you can see this map.

 6             MR. VANDERPUYE:  If we can go to the top right-hand corner of

 7     that map.  All right.

 8        Q.   Mr. Blagojevic, can you read what's on the top right-hand corner

 9     of that document?

10        A.   "Military secret, strictly confidential, Stit 95."

11        Q.   Okay.

12             MR. VANDERPUYE:  If we could pan down to the lower right-hand of

13     that document as well.  That's great.

14        Q.   Mr. Blagojevic, can you read what's at the bottom right-hand

15     corner of this document.

16        A.   "Chief of communications, Lieutenant-Colonel Nedo Blagojevic."

17        Q.   All right.  And that's you, right?

18        A.   Yes.

19        Q.   All right.

20             MR. VANDERPUYE:  Now, if we could just move more towards the

21     middle of the map and up.  Okay.  If we could centre where that flag is

22     at the bottom of the screen, the other direction.  Could you move the

23     flag to the middle of the monitor if that's possible.  That would be the

24     other way, to the left, yeah.  And if we could move downward -- the other

25     way, I'm sorry, up.

Page 22327

 1        Q.   Okay.  The straight lines that are visible on this map that

 2     converge at or near that flag, do those represent the radio relay routes

 3     that you've been discussing.

 4        A.   Yes.

 5        Q.   Okay.

 6             MR. VANDERPUYE:  And if we could just go up and to the right.

 7     That's perfect right there.

 8        Q.   On the top right-hand corner of the screen, can you tell us what

 9     that purple box is -- or rather, let me just ask you:  Is that Cer that's

10     indicated on the right-hand side of the screen?

11        A.   Most probably, it's Cer, but I don't really see from here.

12        Q.   All right.  And the box in the middle, the purple box in the

13     middle of the screen a little bit just below the centre, does that

14     represent Gucevo?

15        A.   The line that goes from Cer to the left and downwards, it's

16     Gucevo.

17        Q.   Okay.  And the line to the left and downwards from Gucevo, that

18     purple line, does that go down to Zvornik?

19        A.   Yes.

20        Q.   And what's indicated in this map as you've seen it, for these

21     particular radio relay paths, those are the same paths that existed in

22     July of 1995, right?

23        A.   Yes.

24        Q.   Okay.

25             MR. VANDERPUYE:  I'm done with this map.

Page 22328

 1        Q.   Now, let me ask you, in July of 1995, who was the chief of

 2     communications for the Main Staff?

 3        A.   In 1995, the chief of communications at the Main Staff was

 4     Colonel Prole.

 5        Q.   All right.  And if you recall, what was the code-name or the code

 6     that was used to identify Pribicevac in June and July of 1995?

 7        A.   I don't know by heart.  I would need to -- I think it's Ozren.

 8     That's what Mr. Petrusic asked me, secret code-names.

 9        Q.   Okay.  And you don't have a recollection at this time as to what

10     the secret code-name was for Pribicevac; is that right?

11        A.   No, no.

12        Q.   Now, as chief of communications for the Drina Corps, how was it

13     that you were able to establish communications in July or June 1995 with

14     the 10th Sabotage Unit or Detachment?

15        A.   I don't recall that.

16        Q.   Would it have been through a radio relay communication or would

17     it have been through a direct-wire communication?  Can you tell us that?

18        A.   I don't remember at all that we established communications with

19     the 10th Sabotage Detachment.

20        Q.   All right.  And in relation to the communications network that

21     was set up, that is, the radio relay routes that went from Vlasenica to

22     Zvornik, through Veliki Zep, Cer, Gucevo, et cetera, was it the case that

23     those communications could be listened to in Serbia and Yugoslavia?

24        A.   Well, they could be monitored on those hubs.

25        Q.   Okay.  And the hubs in particular, you're talking about the ones

Page 22329

 1     that are situated in Yugoslavia, Cer, right, and Gucevo?  Is that right?

 2        A.   Cer and Gucevo, right.

 3        Q.   All right.  I want to show you a document.  It's 65 ter -- well,

 4     before I get to that, I'm sorry, let me ask you:  Did you have or were

 5     there VRS members at those particular hubs in Serbia in and around July

 6     and August of 1995?

 7        A.   I don't remember having any communication with them.  There was

 8     no need.

 9        Q.   All right.  Let me show you 65 ter 2821.

10             What you should have in front of you is an order for the

11     communications established in relation to Operation Stit that you

12     indicated was on this map.

13             Now, before, I asked you some questions about interception

14     capabilities, and you told me that at the switchboard you need a spy in

15     order to intercept communications along the RRU-800 paths.  I just want

16     to direct your attention to paragraph numbered 5 to this document in

17     front of you.  That should be at the bottom of your first page.

18             It talks about communication information protection.  It says, in

19     part:  "I strictly forbid the relaying of confidential information

20     through means of communication without the use of cryptographic data

21     protection devices, in general, and special cryptographic protection

22     documents."

23             It then says at number 2 under that paragraph:  "Anti--electronic

24     protection.

25             "The enemy are in a position to monitor and jam our command and

Page 22330

 1     control communications.  In planning and using communications, make

 2     certain that besides this prescribed tactical and technical measures of

 3     protection, general and special protection of documents for cryptographic

 4     protection are used."

 5             If I could just refer you now to the next page of that document,

 6     that appears to reflect your signature.  That is your signature, isn't

 7     it, Mr. Blagojevic?

 8        A.   It's my signature, but I didn't find what you were saying.

 9        Q.   Well, I'm sorry.  Let me refer you to paragraph numbered 5.  It

10     should be right on the front -- the first page in front of you, and it's

11     number 2 in that paragraph.

12             JUDGE AGIUS:  It is right in the middle of that page.

13             MR. VANDERPUYE:  It's at the bottom, I'm sorry, the very bottom

14     of that page.

15        Q.   You've had a chance to read that, Mr. Blagojevic?

16        A.   Yes.

17        Q.   And it is the case that when you were preparing this operation,

18     Stit 1995, that the enemy was in a position to monitor and jam your

19     command and control communications, as you've indicated in this document,

20     isn't it?

21             JUDGE AGIUS:  Yes, Madam Nikolic.

22             MS. NIKOLIC: [Interpretation] Your Honours, the witness

23     responded; however, this document does not have a date, and I would

24     really appreciate it if my learned friend could tell us to what period

25     this document relates.  Is it linked to Stit or Proboj or what operation?

Page 22331

 1     The document has no date.

 2             JUDGE AGIUS:  In his last question, Mr. Vanderpuye referred to

 3     this Stit Operation 1995.  However, does the document have a date?

 4             MR. VANDERPUYE:  The document does not have a date; however, the

 5     document -- I'm sorry.

 6                           [Prosecution counsel confer]

 7             MR. VANDERPUYE:  It's part of a November 1995 collection of

 8     documents that was received in connection -- that is related to the

 9     Operation Stit; the map, communication codes, et cetera.

10             JUDGE AGIUS:  All right.  Let's proceed.

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

12             JUDGE AGIUS:  Yes, Mr. Zivanovic.

13             MR. ZIVANOVIC:  Sorry.  May we see any document indicating this

14     date, November 1995?

15             JUDGE AGIUS:  Yes, Mr. Vanderpuye.

16             MR. VANDERPUYE:  I don't understand what the objection is.

17             JUDGE AGIUS:  It's a collection --

18             MR. ZIVANOVIC:  Yes.  Any connected with this document which --

19             JUDGE AGIUS:  But he's telling you.  Usually, we don't doubt what

20     the counsel says in the courtroom.

21             MR. VANDERPUYE:  That's all right with me.  The only issue is

22     that I've put it to the witness specifically whether or not that

23     condition existed at that time.  And he answered that it did, that they

24     did have information that the enemy was able to jam and monitor the

25     command and control structures in 1995.

Page 22332

 1             JUDGE AGIUS:  Yes, let's not lose more time.

 2             MR. ZIVANOVIC:  The witness didn't answer.

 3             JUDGE AGIUS:  Yes.  But he has to answer the question.

 4             MR. VANDERPUYE:  And Ms. Stewart has just informed me that the

 5     entire defence plan is 65 ter 128, and this document comes from that

 6     defence plan.

 7             JUDGE AGIUS:  And the question to you, Mr. Blagojevic, was the

 8     following:  And it is the case that when you were preparing this

 9     operation, Stit 1995, that the enemy was in a position to monitor and jam

10     your command and control communications as you have indicated in this

11     document, isn't it?

12             Could you give us an answer to that question, please?

13             THE WITNESS: [Interpretation] You know what?  Such measures in

14     para 2, as I indicated, anti-electronic protection always proceed from

15     the assumption that the enemy is able to do that.  Whether it's needed or

16     not, measures of anti-electronic protection are envisaged.  But we have

17     had confirmation that they had been listening in on us from 1992 and 1993

18     in unsecured communications.  That's why this is written.

19             MR. VANDERPUYE:

20        Q.   All right.  So you're saying that it's in there because it's an

21     assumption; is that right, Mr. Blagojevic?

22        A.   It's an assumption and it's for prevention purposes.

23        Q.   All right.  Since you say it's an assumption, let me direct you

24     to --

25             JUDGE AGIUS:  Listen, I don't want to interfere, but an

Page 22333

 1     assumption or knowledge?  Because the last part of his previous answer

 2     was:  "But we have had confirmation that they had been listening in on us

 3     from 1992 and 1993 in unsecured communications.  That's why this is

 4     written."

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

 6        Q.   With respect to what's stated in the document I've just shown

 7     you, 1995, was it an assumption in that document that the enemy was able

 8     to monitor and jam your command and control functions, communications?

 9        A.   This thing here is a preventive measure in the order based on

10     past experience, but it doesn't apply to all communications.  It applies

11     only to unsecured communications, especially radio ones, on a lower

12     tactical level:  Brigades-battalions; battalion-company; company-platoon.

13        Q.   All right.  Now, with respect to the RRU-800 communications that

14     you were talking about, it's a fact, Mr. Blagojevic, isn't it, that the

15     security of those radio relay paths is only as good as the personnel

16     operating that equipment?  That's true, isn't it?

17        A.   Correct.

18        Q.   And for all the rules and security that you've been referring to,

19     the bottom line is that if those rules weren't followed, the result would

20     be that the enemy would have the information that we've seen in this

21     case, through radio intercepts.  That's true too, isn't it?

22        A.   Yes.

23        Q.   And, in fact --

24        A.   That's why here -- may I finish?

25        Q.   Yes, please.

Page 22334

 1        A.   That's why here, in point 1, it's indicated:  "Protect speech by

 2     using general documents of encryption and by using equipment such as

 3     KZU 31 and 63."

 4        Q.   And, in fact, Mr. Blagojevic, that wasn't always done and that's

 5     what Drago Nikolic is talking about in 22nd April 1993 --

 6             MR. ZIVANOVIC:  Sorry.  But --

 7             JUDGE AGIUS:  Yes, Mr. Zivanovic.

 8             MR. ZIVANOVIC:  -- the translation is not complete.  If the

 9     witness could repeat his answer.

10             JUDGE AGIUS:  Yes, Mr. Blagojevic.

11             Thank you, Mr. Zivanovic.

12             The interpreters couldn't get the last part of your answer.

13             What we have is the following:  "That's why here, in point 1,

14     it's indicated:  'Protect speech by using general documents of encryption

15     and by using equipment such as KZU 31 and 63.'"

16             What was the rest of your answer that we have missed?

17             THE WITNESS: [Interpretation] No, even that is not correct.  The

18     devices were speech protection KZU 63 and KZU 61.

19             JUDGE AGIUS:  All right.  But do you wish to add anything to

20     that?

21             THE WITNESS: [Interpretation] And then it goes:  "Written

22     information should be protected with devices KZU 41, KZU 31 ..."

23             MR. VANDERPUYE:

24        Q.   Mr. Blagojevic, it is the case that those security measures that

25     you've just outlined and many other security measures that were necessary

Page 22335

 1     to your function, as the chief of communication for the Drina Corps were

 2     not followed?

 3        A.   You are referring to the information provided by Mr. Nikolic from

 4     the Zvornik Brigade dating back to 1993; however, this was done in 1995.

 5     And it is based on this that you heard from Mr. Nikolic and other who

 6     were abreast of the situation, and it is because of them that I ever

 7     drafted such order.

 8        Q.   All right.  So you drafted the orders on the recommendations

 9     concerning the security of the communications system based upon things

10     such as the document that I introduced you to that was written by Drago

11     Nikolic?

12        A.   Yes.

13        Q.   All right.  And that document indicates the commanding officers

14     were prone to negligence, people stayed on the wire too long, et cetera?

15        A.   It is very possible that this is correct, but I was not standing

16     next to every commander or their deputy.  All I did was my job, and there

17     is only as much as one can do.

18        Q.   Let me show you 65 ter 2352; it's an illustration.

19             MR. VANDERPUYE:  The English on the screen should be A, and the

20     witness should have in front of him C.

21        Q.   This is a communication, 20th of April, 1995, at 1910 hours, on a

22     frequency of 822 megahertz, which as you know corresponds to the

23     frequency range of an RRU-800 device.  This conversation is a

24     conversation between - the evidence is in this case - between

25     Lieutenant-Colonel Popovic and Second Lieutenant Drago Nikolic.  And it's

Page 22336

 1     a long conversation, but I'll tell you what it says in part.

 2             JUDGE AGIUS:  Yes, Ms. Nikolic.

 3             MS. NIKOLIC: [Interpretation] Your Honours, this document doesn't

 4     show that there is a conversation between Mr. Nikolic and Popovic.  It

 5     says here Palma and Nikolic, but we cannot know whether this person is

 6     actually Drago Nikolic.

 7             JUDGE AGIUS:  But that's a submission.  It's a proposition that

 8     the Mr. Vanderpuye is making to the witness.

 9             So let's proceed.

10             MR. VANDERPUYE:

11        Q.   In this conversation, Mr. Blagojevic, you can see that there is

12     communication with Zlatar, and if you could tell us what that is -- or

13     let me ask you this:  Is it the code-name for the Drina Corps command?

14        A.   Zlatar is the code-name for the Drina Corps.

15        Q.   And you know who Lieutenant-Colonel Popovic is, right?

16        A.   Yes.

17        Q.   All right.  And he's a person that's likely to be found at Zlatar

18     or through Zlatar?

19        A.   Yes.

20        Q.   Okay.  And this is a conversation between one Nikolic and

21     Lieutenant-Colonel Popovic, and it talks about somebody named Jovicic and

22     that Jovicic has sent some volunteers.  And as you can see from the

23     conversation, because I'm not going to read the whole thing - it is a

24     fairly long conversation - it talks about these volunteers being sent up

25     there and a response that maybe they should be tested, or there's some

Page 22337

 1     question about whether or not they are legitimate volunteers.

 2             You see that?

 3        A.   I do.

 4        Q.   All right.  Let me give you another example of a communication

 5     that was intercepted among high-ranking officers.

 6             JUDGE AGIUS:  One moment.

 7             Mr. Zivanovic, do you have re-examination?

 8             MR. ZIVANOVIC:  Yes, Your Honours.

 9             JUDGE AGIUS:  How long?

10             MR. ZIVANOVIC:  I don't believe that I could complete my

11     re-examination today.

12             JUDGE AGIUS:  So are there arrangements in place to have this

13     witness available tomorrow?

14             MR. VANDERPUYE:  There's about a half-hour left, and I can wrap

15     this up hopefully in five minutes.

16             JUDGE AGIUS:  What do you mean a half-hour left?

17             MR. VANDERPUYE:  I'm sorry.  I looked at the clock the wrong way.

18     You're right.  I don't know whether --

19             JUDGE AGIUS:  I just want to confirm that there are arrangements

20     for this witness to be present again tomorrow and whether arrangements

21     have been -- how can we know that?

22                           [Trial Chamber and registrar confer]

23             JUDGE AGIUS:  All right.  Then we can continue, but I would ask

24     you to wrap-up.  We are not going to accept any further wrong

25     indications.  You indicated one hour and, it's already past the one hour,

Page 22338

 1     well past the one hour.

 2             So please conclude your cross.

 3                           [Trial Chamber confers]

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

 5        Q.   Mr. Blagojevic, I would like to show you 65 ter 1160.

 6             MR. VANDERPUYE:  The English is A and the B/C/S which you should

 7     have is C.

 8             JUDGE AGIUS:  Yes, go ahead.

 9             MR. VANDERPUYE:  I've just put a document to the witness.  I'm

10     sorry, Mr. President.  It's 65 ter 1160, and it should be coming up in

11     the e-court.  A is the English.

12        Q.   This is an intercept, sir, where you have two participants.  And

13     if you look towards the bottom of the -- towards the bottom of the page

14     in front of you, this is 14th of July, 1995.

15             You can see that these two individuals are discussing

16     information, and one of them is actually complaining that sensitive

17     information is being leaked by the other person on the -- by the other

18     speaker on the end of this conversation.

19             And in particular in this conversation, you see P says:  "You're

20     worse than the one who put me through to you.  He says the rank, the

21     name, the last name.  The only thing missing is the date of birth,

22     current location, and what his intentions are."

23             In fact, Mr. Blagojevic, it is the case that this is precisely

24     the types of things that were going on with relation to communications

25     conducted over the radio relay system; and you're aware of that, aren't

Page 22339

 1     you?

 2        A.   This is a radio relay communication, and it doesn't say that

 3     everything was recorded in both directions.  They could not record both

 4     the emission and reception frequencies regardless of the feature.  It is

 5     incredible that they did.

 6        Q.   You find it incredible that two people are talking on an

 7     intercept and one is complaining about the other leaking information?

 8     You find that incredible, Mr. Blagojevic?

 9             MR. OSTOJIC:  [Microphone not activated]

10             MR. VANDERPUYE:  I don't know if you have an objection, but if

11     you do I'd like to hear it.

12             JUDGE AGIUS:  He has answered the question.  Let's move to the

13     next question.  You have already exceeded the one hour by 36 minutes,

14     Mr. Vanderpuye.

15             MR. ZIVANOVIC:  I'm not sure the witness saw the same document as

16     the --

17             JUDGE AGIUS:  I don't know.  I mean, I wouldn't be able to tell.

18             MR. OSTOJIC:  [Microphone not activated]

19             JUDGE AGIUS:  In the English text that we have on e-court, it is

20     the document that he has been referred to.

21             MR. OSTOJIC:  [Microphone not activated]

22             JUDGE AGIUS:  No, no.  But in the -- yes.  You're probably right,

23     you're probably right, but we want to make sure.

24             Mr. Blagojevic, the document that you have in front of you over

25     there which you were given, what is its reference number at the top or

Page 22340

 1     the bottom?

 2             THE WITNESS: [Interpretation] 1160C.

 3             JUDGE AGIUS:  Okay.  All right.  Then we are fine.

 4             MR. VANDERPUYE:  All right.

 5             JUDGE AGIUS:  Yes, Mr. Vanderpuye.

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

 7        Q.   Mr. Blagojevic, you were on duty on the 13th July 1995; that's

 8     correct, isn't it?

 9        A.   Yes.

10        Q.   And, in fact, you were the duty officer for the Drina Corps

11     command on that day; is that true?

12        A.   Possible.

13        Q.   All right.  Take a look at 65 ter 3011, please.

14        A.   3011?  What document did you say then?  We've got it.

15        Q.   All right.  If you look at line 14, that's your name, and you're

16     on duty on the 13th of July as the duty officer?

17        A.   Yes.

18        Q.   And, in that position, you would have been aware of all the

19     events that were occurring in and around the corps on that day?

20        A.   Yes, on all important details.

21        Q.   And you were present at the corps command on the 13th of July in

22     the evening when General Krstic became the commander of the corps --

23             JUDGE AGIUS:  Mr. Vanderpuye, you have to finish your

24     cross-examination in five minutes.

25             Then you have not more than 15 minutes to finish your re-direct.

Page 22341

 1             MR. ZIVANOVIC:  Yes.  I'll comply with your guidance.

 2             JUDGE AGIUS:  Thank you.

 3             Yes, Mr. Vanderpuye.

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

 5        Q.   I think you would have been present at the corps at the time that

 6     General Krstic became the corps commander; is that right?

 7        A.   Correct.

 8        Q.   Okay.  And at that point, who became the Chief of Staff?

 9        A.   Colonel Svetozar Andric was standing in for the Chief of Staff.

10        Q.   All right.  If I could, I would like to show you 65 ter 1134B.

11             MR. VANDERPUYE:  This will be the last document I show this

12     witness.

13        Q.   While that's getting loaded, Mr. Blagojevic, can you tell us who

14     the chief of operations was at the Drina Corps on 13 July?

15        A.   I'm not sure.  I don't know.  I've forgotten his name, but Obrad

16     Vitic took over from him a few days later.  He was a colonel by rank.

17        Q.   Thank you, sir.  With respect to this last document, my question

18     is to you, Mr. Blagojevic - I'm going to read to you part of it - where

19     it says:  "C:  Hey, wait.  Someone else will talk to you first until I

20     find Krstic for you.  Here, you have Zlatar on the line.

21             "Hello."

22             And it says:  "Hello, Krsmanovic speaking.

23             "Hey Krle."

24             Then it says:  "Yes.  One boss from the other batch so they can

25     turn to the other side?"

Page 22342

 1             Then it says --

 2             JUDGE AGIUS:  Yes, one moment.

 3             Ms. Nikolic.

 4             MS. NIKOLIC: [Interpretation] Thank you, Your Honour.  There's no

 5     date on the document.  What's the date of this conversation, please?

 6             MR. VANDERPUYE:  13 July.

 7             JUDGE AGIUS:  Yes.

 8             MR. VANDERPUYE:  Frequency is 785, and the time is 1110 hours.

 9             JUDGE AGIUS:  Mr. Blagojevic -- or your question, actually.

10             MR. VANDERPUYE:

11        Q.   It says:  "One bus from the other batch so they can turn to the

12     other side."

13             And it says:  "Dammit, Nedo.  Over there, you know, for those in

14     Batkovic, that means the job is being done over there now?

15             "No, no.  The job is being done, but one batch will go there."

16             And it says:  "One batch."

17             At it says:  "From Sekovici."

18             And it continues.

19             Do you have any idea what job it is talking about, and are you

20     the Nedo that is indicated in this intercept, Mr. Blagojevic?

21        A.   I am a Nedo, but this is not a name; this is just an expression.

22     Nedo is part of the expression:  goddammit.  This is not a name.

23        Q.   This is a communication that went to the Drina Corps on the

24     13th of July the day that you were the duty officer, is it not?

25             JUDGE AGIUS:  This is your last question, Mr. Vanderpuye.

Page 22343

 1             MR. VANDERPUYE:

 2        Q.   What job are they talking about?

 3        A.   I was a duty officer, and Krsmanovic was the logistics chief of

 4     the transportation services.  That's on the third floor, and the

 5     operations centre where I was on duty was on the first floor.  So I

 6     really could not be in the picture there, nor did I know what the

 7     conversation was all about.  I've never seen this conversation before.

 8        Q.   Thank you, Mr. Blagojevic.  I have no further questions.

 9             MR. VANDERPUYE:  Thank you for your indulgence, Mr. President.

10             JUDGE AGIUS:  Thank you.

11             Mr. Zivanovic.

12             I saw you standing, Madam Faveau.

13             MS. FAVEAU: [Interpretation] The witness has answered.

14             JUDGE AGIUS:  Thank you.

15             Mr. Zivanovic.

16             MR. ZIVANOVIC:  Your Honours, I'm really not in position to

17     reduce my re-examination in next five minutes.  I identified more than --

18             JUDGE AGIUS:  Fifteen minutes.

19             MR. ZIVANOVIC:  Fifteen minutes.  Okay.

20             JUDGE AGIUS:  You think you will finish in 15 minutes?

21             MR. ZIVANOVIC:  I'll do my best to do.

22             JUDGE AGIUS:  You always do, so let's try it.

23                           Re-examination by Mr. Zivanovic:

24        Q.   [Interpretation] Mr. Blagojevic, I would like to ask you a couple

25     of questions with regard to the Prosecutor's examination --

Page 22344

 1     cross-examination.  He asked you about the changes in the frequencies.

 2             Since we did not see among the documents all the frequency plans,

 3     when you were talking about the changes of the frequencies, what radio

 4     relay devices did you have in mind?  You provided us with several when

 5     you were talking about that, so which ones did you have in mind in

 6     particular?

 7        A.   This primarily referred to the radio relay devices RRU-1, because

 8     they are much easier to interfere with and listen to, much easier than an

 9     RRU-800.

10        Q.   Let's now look the document that the Prosecutor showed you, which

11     is 2823.

12        A.   Very well.

13        Q.   I think I'm --

14             MR. ZIVANOVIC: [Interpretation] I apologise.  1150 is the number.

15             THE WITNESS: [Interpretation] Go on.

16             MR. ZIVANOVIC: [Interpretation]

17        Q.   The Prosecutor asked you whether a duplex connection at the

18     switchboard give you possibility to hear both collocutors.  Do you

19     remember that?

20        A.   Yes.

21        Q.   And you said --

22        A.   Yes, affirmative.

23        Q.   Does the fact that both collocutors can be heard at the

24     switchboard allow those who are listening in the conversation to hear

25     both collocutors?

Page 22345

 1        A.   No.  And that's what I said to the Prosecutor when he was

 2     examining me.  It's impossible because those who are listening are

 3     listening to the radio relay route, and they can only listen to one

 4     direction and that's the direction going towards the intercepters.  And

 5     they can't hear the other collocutor, the other side.

 6        Q.   So to cut a long story short, when you have two collocutors in a

 7     conversation, are you saying that only one of them could be heard, not

 8     the other?

 9        A.   Precisely.  The other person would be impossible to hear.

10             MR. ZIVANOVIC: [Interpretation] Can we now look at 3412, please;

11     it's a Prosecution document.

12        Q.   Can you see in this document that the radio relay route, one of

13     those routes used by the Drina Corps, was inoperative.

14        A.   No, that's what I said to the Prosecutor.

15        Q.   Tell me, is it usual to perform regular maintenance of these

16     routes, radio relay routes, even when they are in operation?

17        A.   It's a reasonable question.  We do regular checks and servicing

18     and maintenance.

19        Q.   Just to add to my previous question about duplex devices, if

20     during a conversation you could hear both collocutors, would that mean

21     that two devices were used from both sides for eavesdropping?

22        A.   That could mean that they had one device in the territory of the

23     Federation and the other device in the territory of Serbia; that's the

24     only way.

25        Q.   One more thing.  You have seen this.  In this document, while

Page 22346

 1     we're looking at it, let's finish with it, it says:  "Repair and put into

 2     working order the radio relay route with 120 channels," and the routes

 3     are indicated.  Are they in the area of the Drina Corps?

 4        A.   They are on Veliki Zep-Cer and Veliki Zep-Stara -- Strazbenica.

 5        Q.   No.  You didn't understand my question.  Let's look at this

 6     document from the 25th of November, 1993.  The second paragraph begins

 7     with the words:  "Please send the same team to VRS to put into working

 8     order the 120-channel radio relay routes, number," and then you see the

 9     routes.  Is one of these routes in the area of the Drina Corps?

10        A.   None of the routes indicated in this paragraph is in the area of

11     the Drina Corps.

12        Q.   Thank you.

13             MR. ZIVANOVIC: [Interpretation] Could we just look at another

14     exhibit, 3425, Prosecution exhibit.

15             THE WITNESS: [Interpretation] I'm ready.

16             MR. ZIVANOVIC: [Interpretation]

17        Q.   Can you tell me to whom this document was sent?

18        A.   It was sent --

19        Q.   If you can't, say you can't.

20        A.   I don't see here; it only says to the organ for other affairs,

21     intelligence and security affairs.

22        Q.   Have you seen this document before?

23        A.   I have not, nor was there any need to submit it to me, because it

24     was supposed to go to intelligence and security.

25        Q.   Just repeat, can you tell from which document to which unit it

Page 22347

 1     was sent?

 2        A.   You can't see that.  You can't see to which unit.  You can see

 3     who wrote it and you see to which organ it is being sent, but not to

 4     which unit.

 5        Q.   Thank you, Mr. Blagojevic.

 6             MR. ZIVANOVIC:  No further questions.

 7             JUDGE AGIUS:  Thank you.

 8             I think you're standing up in vain, Mr. Petrusic.  If you're

 9     asking to put questions, we are not going to allow it.

10             Yes?

11             MR. PETRUSIC: [Interpretation] Thank you, Mr. President.  I had

12     no intention to ask questions, but I would like to take up document 338,

13     while the witness is here, to ask the witness to sign it and put today's

14     date because certain changes have been made to the document.

15             JUDGE AGIUS:  All right.

16             Yes, thank you, Mr. Petrusic.

17             Madam Registrar over there, could you take care of that, please.

18             THE REGISTRAR: [via Videolink] Yes, Your Honours.

19             JUDGE AGIUS:  And for the record, we can see the witness

20     hesitating.

21             THE WITNESS: [Interpretation] What date is it?

22             JUDGE AGIUS:  Today is the 17th of June.

23             THE WITNESS:  [Marks]

24             JUDGE AGIUS:  Now, Mr. Blagojevic, I wish to thank you very much

25     for having been patient with us and stayed there all this time, and for

Page 22348

 1     having accepted to give evidence; and on behalf of the Trial Chamber, I

 2     wish you a safe journey to wherever you are going.  Thank you.

 3             We'll do the exhibits tomorrow morning.  Thank you.

 4                           --- Whereupon the hearing adjourned at 1.57 p.m.,

 5                           to be reconvened on Wednesday, the 18th day of

 6                           June, 2008, at 9.00 a.m.