Tribunal Criminal Tribunal for the Former Yugoslavia

Page 28746

 1                           Tuesday, 25 November 2008

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The Accused Pandurevic not present]

 5                           --- Upon commencing at 2.18 p.m.

 6             JUDGE AGIUS:  Good afternoon, Madam Registrar.  Could you call

 7     the case, please.

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

 9     IT-05-88-T, The Prosecutor versus Vujadin Popovic, et al.

10             JUDGE AGIUS:  All right.  Thank you.  All the accused are

11     present, minus Vinko Pandurevic, who has sent a waiver which we have

12     seen.  Prosecution today is represented by Mr. McCloskey, Mr. Thayer, and

13     Mr. Vanderpuye.  Absent from the Defence teams I notice Mr. Ostojic,

14     Mr. Bourgon, and Mr. Haynes.  Right.

15             Yesterday we finished the witness off, General Simic.  We

16     admitted two documents offered by the Pandurevic Defence team, and we

17     agreed, also, at the request of Mr. Josse to postpone the matter of

18     documents to be tendered by others to today.  I suggest -- propose to

19     start with the list of documents of the Miletic Defence team that has

20     been circulated.

21             Is there any objection, Mr. Thayer?

22             MR. THAYER:  Good afternoon, Mr. President.  No objection.

23             JUDGE AGIUS:  No objection.  Any of the other Defence teams wish

24     to object to any of these documents?  None.  So all these documents are

25     admitted.  I'm just checking whether there are any that require

Page 28747

 1     translation.  Yes, it's the last one, 5D1397, so that will be MFI'd

 2     pending translation thereof.

 3             Ms. Fauveau, I just want to make sure of something.  In the list

 4     there was 5D1328 which, in the copy I have, has been crossed out with

 5     ink.  It's the same -- all right.  Okay.  So you're not tendering that?

 6             MS. FAUVEAU: [Interpretation] Yes, Mr. President, it's not on the

 7     list.

 8             JUDGE AGIUS:  All right.  I also have one document which the

 9     Gvero Defence team seeks to tender, and it's 6D311.  Is there any

10     objection, Ms. Fauveau?

11             MS. FAUVEAU: [Interpretation] No, Mr. President.

12             JUDGE AGIUS:  Mr. Thayer?

13             MR. THAYER:  No, Mr. President.

14             JUDGE AGIUS:  All right.  So that document is also admitted.  And

15     then there is a Prosecution list of nine documents, one of which will be

16     under seal, that's 3938.  Any objections, Ms. Fauveau.

17             MS. FAUVEAU: [Interpretation] No, Mr. President.  There are no

18     objections.  The only thing is could my colleague precesise [as

19     interpreted] regarding 7D712, the list of prisoners in Batkovic, and we

20     see the date 13th of May, does my colleague have any information as to

21     whether this list was compiled on the date indicated 13th of May 2004.

22             JUDGE AGIUS:  [Interpretation] Thank you, Madam.

23             MR. THAYER:  Mr. President, that reflects the date of transmittal

24     by the authorities from the Republika Srpska pursuant to our RFA or the

25     RFA of the requesting party.  It's simply the first page that attaches

Page 28748

 1     the list.  The list itself, as I understand it, is contemporaneous with

 2     the events.

 3             JUDGE AGIUS:  All right.  Thank you.  And this is a Pandurevic

 4     document, isn't it?

 5             MR. THAYER:  It is.  I believe though, that we have used the

 6     document previously.  I don't believe it had been tendered previously,

 7     but it is a document that all parties have previously used.  Our exhibit

 8     number was 03939.

 9             JUDGE AGIUS:  And one question, out of curiosity.  I seem to

10     remember Mr. Haynes yesterday, in mentioning the two documents, saying

11     712, amongst other things.  702?  It's not the same one, is it.

12             MR. THAYER:  No, these are different documents, Mr. President.

13             JUDGE AGIUS:  These are different documents.  Okay.  All right.

14             MR. THAYER:  If I may, Mr. President.

15             JUDGE AGIUS:  Yes.

16             MR. THAYER:  With respect to our list, there is one other item

17     that I believe we'll be in a position to offer tomorrow.  I wanted to

18     give my -- my learned friends an opportunity to look over the materials

19     this evening.  Madam Fauveau and I have been in consultation with respect

20     to the tape recorded interviews of General Simic there.  As the Court

21     recalls there was some reluctance or hesitation on General Simic's part

22     with respect to part of the interview.  What we have agreed between the

23     Miletic Defence team and the Prosecution is to offer to the Chamber the

24     transcript pages from the 2004 and 2007 interviews which touch upon the

25     conversation that General Simic testified about with General Miletic as

Page 28749

 1     well as the audio portion only of the section where the Prosecution

 2     cross-examined General Simic with respect to the guards about to kill the

 3     prisoners at the school.

 4             We would offer that for credibility purposes, if the Court is

 5     interested, to hear whether, in fact, that is on the tape.  We do have

 6     the tape, and we can tender that portion, and we've agreed that --

 7     between parties, that that can go to the Court if the Court desires to

 8     hear that specific portion of the tape which the Prosecution obviously

 9     alleges contains the statement by General Simic that one of his

10     subordinates told him that when he arrived at the school the guards were

11     about to execute those prisoners.

12             But we've distributed the portions of the transcript to my

13     friends pertinent the conversation that General Simic said he had with

14     General Miletic for their review.

15             JUDGE AGIUS:  Thank you, Mr. Thayer.  Do you wish to comment on

16     that, Ms. Fauveau.

17             MS. FAUVEAU: [Interpretation] No, Mr. President.  I am fully in

18     agreement with what the Prosecutor has said.  I just want to be sure that

19     all the parts of the interview relating to this issue are included in the

20     file.

21             JUDGE AGIUS:  Any -- thank you, ma'am.  Any other comments from

22     other Defence teams?  Yes, Mr. Josse.

23             MR. JOSSE:  Well, dealing with that first of all, we too would

24     simply like to check what we have just been given.  So I support what my

25     learned friends have just said that that issue should be deferred until

Page 28750

 1     tomorrow.

 2             So far as the Prosecution list is concerned, we do have an

 3     objection to one document on that list, and that is P3938.  The first

 4     issue that we would like to raise is why this document is being tendered

 5     under seal.  We would invite a full explanation of that, both factual and

 6     legal, because we -- if it's admitted, we would much rather it was

 7     admitted publicly than under seal.  But that's a discreet issue.  So far

 8     as the admission of it is concerned, we are not inviting the Trial

 9     Chamber to prejudge the ongoing issue as to the admission of documents

10     used by the Prosecution of Defence witnesses in the course of their

11     cross-examination; though, I think, the filings in relation to that issue

12     are closed or almost closed.  Clearly the Trial Chamber has yet to make a

13     determination.

14             The Trial Chamber may have noted that the Gvero team have taken a

15     particular stance in relation to that and accept for the most part that

16     the Prosecution are entitled to introduce documents which go to the

17     substance of any particular issue, in the course of their

18     cross-examination.  Putting it very shortly, Your Honours, we submit that

19     this document crosses the line.  We ask rhetorically why it was not

20     introduced as part of the Prosecution case.  We suggest that it's

21     improper for it therefore to be introduced at this particular junction of

22     the case, and in particular we suggest it's improper and unfair for it to

23     be introduced via a witness called by a co-accused of our client; and the

24     Trial Chamber will need to bear in mind the rules in relation to that.

25             So bearing in mind all of those matters, we would invite the

Page 28751

 1     Court to refuse admission.  We are quite content for the Chamber, if it

 2     so pleases to make a decision here and now.  We are not asking for any

 3     decision to be deferred until the more general issue is resolved.

 4             JUDGE AGIUS:  Thank you, Mr. Josse.  Mr. Thayer.

 5             MR. THAYER:  Mr. President if --

 6             JUDGE AGIUS:  Take the two issues, one by one.

 7             MR. THAYER:  I will, Mr. President.

 8             JUDGE AGIUS:  First question of the confidentiality of this

 9     document under seal.

10             MR. THAYER:  If we may go into private session, for a moment,

11     Mr. President.

12             JUDGE AGIUS:  Yes, let's go into private session.

13                           [Private session]

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 28752

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19                           [Open session]

20                           [Trial Chamber confers]

21             JUDGE AGIUS:  All right.  Now we are in open session and you need

22     to comment on the rest of the observations, objections, made by

23     Mr. Josse.  Yes, Mr. Thayer.

24             MR. THAYER:  Mr. President, as to the second grounds, the

25     document clearly falls into the category of fair game for

Page 28753

 1     cross-examination.  Like any other document that we've been using and

 2     that have been used by other parties, it has relevance and probative

 3     value in and of itself, and I won't belabour the position that we've

 4     taken in our filings on this issue; but it is no different than any other

 5     military record or other document that the Trial Chamber is -- has seen

 6     time and again.  There is nothing unfair about it.  The witness was

 7     called here.  We had an opportunity to cross-examine, and the

 8     cross-examination was fair and appropriate; and it went directly to

 9     issues that my friends raised during the course of their examination of

10     the witness.

11             JUDGE AGIUS:  But the points made by Mr. Josse are the following,

12     let's take them one by one.

13             One is a rhetorical question:  Why didn't you introduce this

14     document in the course of your case -- case in chief.  That's number one,

15     you haven't touched on that.

16             Second point made was a suggestion that it is improper for the

17     Prosecution and unfair to have this document regarding General Gvero

18     introduced via a witness called not by Mr. Gvero but by a co-accused.

19     That's the second point made by Mr. Josse; and he suggested there are

20     rules in relation to that, perhaps he can be more specific on that, on

21     these rules, and you haven't touched on this either.

22             MR. THAYER:  Well, Mr. President, in response to the rhetorical

23     question, you know, we've got thousands and thousands of potential

24     documents that -- that we could have introduced probative, we believe, of

25     General Gvero's position, responsibilities; and ultimately his state of

Page 28754

 1     mind and a number of other issues that, for various reasons, we didn't

 2     introduce.  It's as simple as that.  I mean, I can't stand here and give

 3     the Court an explanation for all these documents.  I don't know why this

 4     one in particular wasn't introduced during our case in chief, but we have

 5     an opportunity, my friends raised some very specific issues with respect

 6     to General Gvero; and I think it was fairly used and offered in response

 7     to those specific issues.

 8             As to the -- the second point, I don't see anything unfair about

 9     using a document when the Defence team for General Gvero engages in a

10     long cross-examination of a witness and touches on kinds of issues.

11             I just don't see anything in the rules that bars that or in the

12     practice that we have engage in the two years for this trial that would

13     bar that use.  I don't see any prejudice that's been caused.  I don't

14     think there is any allegation of surprise, so I simply fail to see why

15     it's unfair.

16             JUDGE AGIUS:  Okay, yes, Mr. Josse.

17             MR. JOSSE:  If it helps.

18             JUDGE AGIUS:  Yes.

19             MR. JOSSE:  We won't pursue the second point, certainly not at

20     this juncture and we are not asking for a ruling on that.  We most

21     certainly will pursue the first point, and we submit that that isn't an

22     adequate explanation; and the cross-examination that gave rise to the use

23     of the document was nothing beyond what had been -- come out in the

24     course of the Prosecution case in short; in other words, we weren't

25     expanding the ambit of our case in any way at all.  That's our

Page 28755

 1     submission, and therefore it should have been used as part of their case.

 2             JUDGE AGIUS:  All right.  Let's go back into private session for

 3     on moment, please.  I need to have you clarify something.

 4                           [Private session]

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22                           [Open session]

23                           [Trial Chamber confers]

24             THE REGISTRAR:  We are in open session.

25             JUDGE AGIUS:  So our decision is, of course, without prejudice to

Page 28756

 1     the decision that we will handing later on on the motion and the

 2     responses that we've had and to which Mr. Josse referred to earlier on.

 3             Our decision on this particular document is first that it is a

 4     relevant question -- a relevant document, and essentially we allowed

 5     questions to be asked on the document, and there being no objection to

 6     those questions; and he answered those questions, we feel the need to

 7     have this document in the records if we are to understand and give weight

 8     to the whole testimony of General Simic.  So the objection is overruled

 9     and as regards the status of this document, it will be admitted; and it

10     will be preserved under seal.

11             All right.  We are going to have the next witness come in soon.

12     Are there any submissions in relation to him before he is brought into

13     the courtroom?  Okay.

14                           [The witness entered court]

15             JUDGE AGIUS:  Ms. Fauveau, this one is Milijanovic or -- or

16     Pajic.

17             MS. FAUVEAU: [Interpretation] Pajic.

18             JUDGE AGIUS:  Okay.  Pajic, okay.  Thank you.

19             Good afternoon to you, Mr. Pajic.

20             THE WITNESS: [Interpretation] Good afternoon.

21             JUDGE AGIUS:  And you're most welcome to this Tribunal.  I am the

22     Presiding Judge, my name is Agius.  To my right I have Judge Kwon and

23     Judge Stole, to my left Judge Prost.  You have been summoned as a Defence

24     witness by General Miletic.  Before you start your testimony, you are

25     required by our rules to make a solemn declaration that you will be

Page 28757

 1     testifying the truth.  Madam Usher is going to give you the text.  Please

 2     read it out aloud and that will be your solemn commitment with us.

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

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

 5             JUDGE AGIUS:  Thank you, sir.  Please make yourself comfortable.

 6             THE WITNESS: [Interpretation] Thank you.

 7             JUDGE AGIUS:  Mr. Petrusic will be putting some questions to you.

 8             MR. PETRUSIC: [Interpretation] Thank you, and good day, Your

 9     Honours.

10                           WITNESS:  VELO PAJIC

11                           [Witness answered through interpretation]

12                           Examination by Mr. Petrusic:

13        Q.   [Interpretation] Good day, Mr. Pajic.  Let me introduce myself to

14     you officially.  My name is Nenad Petrusic, as you know, and today I will

15     be putting some questions to you on behalf of General Miletic --

16             THE INTERPRETER:  Counsel is kindly asked to speak more loudly

17     and to approach the microphone as the interpreter cannot hear him.

18             JUDGE AGIUS:  Mr. Petrusic, okay, you've heard the comment from

19     the interpreter or not?  You need to speak a little bit louder into the

20     microphone, please.  And I suggest you also tell your witness about the

21     usual problem when counsel and witness speak the same language with the

22     inevitable result of overlapping.

23             MR. PETRUSIC: [Interpretation]

24        Q.   Mr. Pajic, before I officially -- before you officially introduce

25     yourself, you've heard what the Presiding Judge has suggested.  Given

Page 28758

 1     that we both speak the same language, you and I, too, naturally, have to

 2     wait before answering my questions.  There is a monitor in front of you

 3     on which you can follow the transcript.  Wait for the sentence to be

 4     completed, and then answer the question.  You can follow this on the

 5     monitor.  When taking the solemn declaration, I noticed that you spoke

 6     quite softly; so I would also like to ask you to feel free to speak a

 7     little more loudly.

 8             And now I would officially like to ask you to introduce yourself

 9     for the sake of the transcript.

10        A.   My name is Velo Pajic.

11        Q.   Where were you born and when?

12        A.   On the 28th of July, 1960, in Rogatica, Bosnia and Herzegovina.

13        Q.   What is your educational background?

14        A.   I completed primary school in Borike in 1975, and then I

15     completed secondary military school, the communications section in

16     Belgrade in 1979.  It was within the land army.

17        Q.   Have you completed any other military schools apart from this

18     one?

19        A.   Yes.  In 1992, I graduated from the high military school in

20     Belgrade.

21        Q.   Having completed your secondary military school, did you receive

22     a rank of any kind or did you find employment?

23        A.   Yes.  I was promoted to sergeant, and I was sent to Sarajevo,

24     military post 1519.  My command was in Lukavica in Sarajevo, and I worked

25     in the Konjic garrison.  I worked on features for special purposes,

Page 28759

 1     Feature D.

 2        Q.   Tell me, what does that mean, Feature D?

 3        A.   Feature D, well, all features of special interest were

 4     exclusively features used to make calls, commands were located there, and

 5     communications equipment.  Feature D -- well, the abbreviation used was D

 6     but in fact it was called Dilj.  It was a military command post of the

 7     former presidency of the SFRY.  It was a command post used under military

 8     or wartime, rather, conditions.

 9        Q.   I thought you said that this feature was called D; am I correct?

10        A.   Yes.  Dilj, D-I-L-J, Dilj.

11        Q.   Are you aware of the existence of other such features or

12     facilities in the territory of the former Yugoslavia?

13        A.   Yes, apart from these Dilj features, there were M features.

14     Military command posts of the airforce on Jahorina, for example; and then

15     Azlatice [phoen], the military command post of the former 7th army.

16     Features G, Goljek [phoen], command post for the 7th army in Hans

17     Pijesak.  There were also radio relays, I won't list them, but there were

18     such relays throughout the territories of the former SFRY.

19        Q.   Please speak up a bit and perhaps you could slow down when

20     answering the questions.  We're still discussing the feature or the

21     facility Dilj, used for special purposes.  Was it operational before the

22     war?

23        A.   Yes, the facility had been manned by people maintaining the

24     facility, and it was in a state of readiness.  It could receive men at

25     any point in time, men intended -- or whose purpose was to work in that

Page 28760

 1     facility.

 2        Q.   Mr. Pajic, how long did you stay in that facility?

 3        A.   I stayed in the facility Dilj until the 9th of May 1992.  The

 4     last two and a half months I spent there -- well, I had been cut off by

 5     the Muslims forces; and on the 9th of May 1992, a helicopter managed to

 6     withdraw us and transport us to Belgrade.

 7             In order to withdraw, we had to pass through the territory held

 8     by paramilitary units.  We had to go to Bijelasnica, and then we were

 9     received and transported to the brigade command.

10             The brigade command of the 398th brigade in Belgrade.  Its

11     headquarters were in Belgrade, and that's where we were transported to.

12             THE INTERPRETER:  The witness is kindly asked to slow down for

13     the sake of the interpretation.

14             JUDGE AGIUS:  Witness, one moment.

15             The interpreters, let me explain something, because, probably,

16     you are not aware of how we operate here.  What you say in the Serbian

17     language is being simultaneously translated into English to us and into

18     French to those of us that speak French.  You're speaking a little bit

19     too fast, so please slow down a little bit to enable the interpreters to

20     catch up with you.

21             THE WITNESS: [Interpretation] Very well, very well.

22             MR. PETRUSIC: [Interpretation]

23        Q.   Mr. Pajic, did you stay on in the JNA after returning to

24     Belgrade?

25        A.   Yes, I remained there until the 18th of May 1992.

Page 28761

 1        Q.   After that day, did you at any point in time join the army of

 2     Republika Srpska?

 3        A.   Yes, on the 18th of May, we were transported from Belgrade to the

 4     Hans Pijesak section.  I, in particular, was transported there.

 5        Q.   Which unit did you join in Hans Pijesak, could you tell us,

 6     briefly?

 7        A.   When I arrived in Hans Pijesak, or rather, to Crna Rijeka sector,

 8     I was received there by command of the 67th Communications Regiment,

 9     Colonel Miletic [as interpreted]; and the chief of the communications of

10     the Main Staff of Republika Srpska, Radomir Prole, was his name.  I was

11     appointed as command of the second platoon within the company.  I was

12     responsible for the communications garrison of the 67th Communications

13     Regiment of the Main Staff of the army of Republika Srpska.

14        Q.   Mr. Pajic, let's just correct an error in the transcript.  Was

15     the commander of the 67th Communications Regiment Colonel Milikic

16     [phoen]?  What did you say?  Who was Colonel Milikic?

17        A.   Yes, it was Colonel Milikic at the time, and one month later he

18     went to Yugoslavia; and Lieutenant-Colonel Gordan Bosko [phoen] was

19     appointed to that position.  I am talking about May 1992.  That's when I

20     arrived there.

21        Q.   You said you were appointed to a position in the 2nd platoon of

22     the 67th Communications Regiment.  Can you tell us how strong that

23     platoon was?

24        A.   Yes.  It was the 2nd platoon within the company for the

25     communications garrison.  There were 25 men according to the

Page 28762

 1     establishment, but given the lack of men, I was alone in that platoon.  I

 2     was the commander and I was also one of the men.

 3        Q.   At the beginning of your testimony, you mentioned a facility in

 4     Hans Pijesak, G1.  We know this is an underground facility.  Apart from

 5     that underground facility, were there any other military facilities in

 6     that area that is called Crna Rijeka?

 7        A.   Yes.  Apart from that guilt, the G1 underground facility, there

 8     was a settlement, there were these cabins, these features that we used

 9     for offices from the Main Staff.  And the feature, the facility, was for

10     the 67th Communications Regiment.  There was a facility for the 67th

11     Communications Regiment also in the Crna Rijeka sector.  There was

12     another underground facility, Goljak 2, the so-called G1 facility.

13             THE INTERPRETER:  Interpreter's correction:  The so-called G2

14     facility.

15             MR. PETRUSIC: [Interpretation].

16        Q.   Was the command located in any of those cabins you have

17     mentioned, the command of the Main Staff?

18        A.   Yes.  The command was located in one of those cabins, the command

19     of the Main Staff of the Republika Srpska army.  But that doesn't include

20     the commander of the Main Staff who stayed in -- in a feature which was

21     above ground within the G1 complex.  It was the so-called Javor villa.

22        Q.   Tell us, what were your duties?  What tasks did you have, and in

23     which facility did you perform your duties?

24        A.   I performed my duties in the G1 facility, and my duties were to

25     establish and maintain radio relay and wire communications for the needs

Page 28763

 1     of the Main Staff of the army of Republika Srpska.

 2        Q.   We are now discussing 1995.  So tell me, what kind of

 3     communications did the Main Staff use in 1995?

 4        A.   The Main Staff of the army of Republika Srpska mainly used radio

 5     relay communications and wire communications in 1995.  When necessary,

 6     radio communications, but to a lesser extent.  So these communications

 7     were used only when needed.

 8        Q.   At the very beginning of your testimony, you also mentioned

 9     the -- a certain radio relay points.  So what I am interested in is the

10     following:  Where were these radio relays located, radio relays used for

11     the Main Staff?

12        A.   Well, one of the points -- one of the main points used for the

13     Main Staff of the Republika Srpska army was at Veliki Zep.  Then there

14     were other sites on the territory of the former Yugoslavia, there was Cer

15     Strazbenice.  Then we had Svinjar, Kozara, Klekovaca [phoen], Jahorina,

16     Borasnica [phoen]; so I am talking about these sites, these

17     communications points that we used for the communications needs of the

18     Main Staff of the army Republika Srpska, and they had their subordinate

19     units there.  They had corps and there was the presidency of the

20     Republika Srpska.

21        Q.   You mentioned the presidency, but with regard to the civilian

22     institutions, were you linked up to any other institutions within

23     Republika Srpska apart from the presidency?

24        A.   Yes.  We also had a communications network that was established

25     with the government of the Republika Srpska with the Assembly and with

Page 28764

 1     the president of Republika Srpska.

 2        Q.   You also said that you used radio relay and wire communications.

 3     My question has to do with radio relay communications.  Could you briefly

 4     explain to us the way in which these communications function?

 5        A.   Radio relay devices are used by using a modulated signal which is

 6     conveyed or propagated throughout electro-magnetic waves to a receiver.

 7     In order to do this, in order to establish such communications, you need

 8     two radio relay devices.  You need an optical line of sight; the distance

 9     must not exceed 50 kilometres.  If one is to establish a viable

10     communications link, you need to have a source of energy, and naturally

11     you need to have a device with adequate frequency.  This could be via the

12     relay device, or they could be linked to the radio device by cable.

13        Q.   And what about wire communications, how did that work?

14        A.   Wire communications worked in the following way:  You needed two

15     participants being linked up by a low-frequency, a high-frequency cable.

16     There had to be inductive phones being used, also, or a hand-carried

17     switchboard.

18        Q.   You mentioned in passing also radio communications, can you

19     please tell us how that worked?

20        A.   RO2/2K, RUP-12, and radio telephones were the types of equipment

21     most frequently used.  Radio telephones that could be transported in

22     vehicles, specifically.  They use such frequencies as 30/70 megahertz.

23             The radiation was a circular one, their antennas were not pointed

24     any particular direction.  These were used over short distances within

25     optical line of sight that was open.  The range being 10 to 15 kilometres

Page 28765

 1     with an optical line of sight available and open.

 2        Q.   In your experience, to what extent were these types of

 3     communication used by the Main Staff -- or, rather, at what levels of

 4     command were these types used?  I am talking about radio communications.

 5        A.   Radio communications were hardly ever used by the Main Staff.

 6     Motorolas were used occasionally, but radio communications were hardly

 7     used at all.

 8        Q.   What about the range of those Motorolas?

 9        A.   Between 1 and 2 kilometres, depending on the lay of the land,

10     depending on whether there was an optical line of sight with no repeaters

11     involved.  If there was a repeater, an intensifier, the range could

12     easily have been increased with a repeater available, as I say.

13        Q.   But you didn't have those repeaters, did you?

14        A.   No, not at Veliki Zep.  Motorolas have to be used in direct

15     communication, their range being between 1 and 2 kilometres.

16        Q.   Can you tell us what sort of equipment you used at the central

17     communications hub out of Veliki Zep?

18        A.   At Veliki Zep, there were a number of radio relay devices such as

19     the SMC-1306B.  FM-200 was another one, RRU800, RRU9B, RRU1.  As for

20     multiplex equipment for encoding speech, we used AMD310.

21        Q.   What about the underground facility itself, since you mentioned

22     that particular piece of equipment with a transportable frequency.  Were

23     you using any other types of equipment there as well?

24        A.   Yes.  In that underground facility, we also had -- well, as a

25     matter of fact this was a device with transport or frequency, but we

Page 28766

 1     referred to them at a different way.  They were these telephones.  There

 2     was V120/341, VZ12K/24, VZ4/12, and an automatic telephone switchboard

 3     80COM60, the capacity being 250 automatic numbers.  Needless to say, they

 4     were automatic telephone devices inductor type or handheld type, M63, for

 5     example, inter-phones, mediation boards; and that was it as far as the

 6     telephone devices used at G1 were concerned.

 7             Perhaps I should also point out that the ones with portable

 8     frequency were interconnected by wire or by radio relay devices.  The

 9     transmission was done by wire or by radio waves.

10        Q.   Can you tell us what this abbreviation stands for, V120/3?

11        A.   This is a multiplex device with portable frequency.  The

12     circumference, within which it works is between 4 and 108 kilohertz.  120

13     means that it can convey 120 channels at the same time which means that

14     you can have 120 lines of communication as it were operating through this

15     device all at the same time.

16             MR. PETRUSIC: [Interpretation] Can we please have 5D139 [sic]

17     brought up, thank you.  My apologies, 5D1395.  We can see zoom out a

18     little in order to be able to see the entire page in a single screen.

19     Thank you.  That's quite efficient for our purposes, thank you.

20             Can we please zoom out in order to get a view of the entire

21     sheet.  Thank you.  I think that will do.  Can I have the usher's

22     assistance please, Madam Usher if you could please pass the electronic

23     pen to Mr. Pajic so that he can enter certain changes to this chart or

24     diagram.

25        Q.   First and foremost, Mr. Pajic, do you recognise the diagram in

Page 28767

 1     front of you?

 2        A.   Yes, I do.  It shows where the rooms were inside G1, inside this

 3     underground facility.  It's a layout.

 4        Q.   Were you the person who drew this diagram or plan?

 5        A.   Yes, I was the one.

 6        Q.   What about the left upper corner, we see the date 19th of

 7     November 2008.  Just below that date we see a signature, right?

 8        A.   Yes, that's right, that's my signature.

 9        Q.   Therefore, this is the layout of G1, the underground facility,

10     right?

11        A.   Indeed.  Indeed it is, yes.

12        Q.   Before we move on to specifically explaining individual sections

13     of this layout or ground plan, can you please tell me how much time you

14     spent in this underground facility during your stint with the army of

15     Republika Srpska?

16        A.   A total of nine years and ten months, specifically.

17        Q.   Let's proceed in the following way, sir.  Let's go to this first

18     room that says "the separation board."  Can you see that writing in one

19     of the rooms on this diagram?

20        A.   Yes, I see that.

21        Q.   Can you please put a number one there.

22        A.   There was an entrance, and then the rooms were 1A, 1B, 1C.  1B is

23     the room you are talking about.

24        Q.   So put the number on 1B, please.

25        A.   [Marks]

Page 28768

 1        Q.   Can you please explain the concept that I refer to as the

 2     separation board or switchboard?

 3        A.   That's where all the wires are connected.  All the cables are

 4     wider up as it were, as well as all the telephone and telegram cables,

 5     and they were all plugged into various devices.  So they were all put

 6     together here, as it were, all the automatic numbers came from UM620, the

 7     switchboard.  They went to the switchboard, the separation board, and all

 8     the cables that came from the cabins specifically from the Veliki Zep

 9     central communications hub and from the Hans Pijesak barracks.  They were

10     all put together and redirected, channeled over as it were here.  And

11     this device also made it possible for us to rearrange the different

12     communication lines depending on the requirements placed on us by the

13     participants.

14        Q.   We have room 1B here.  In addition to that room, we also see DS,

15     a room marked as DS.  Can you please place 1A there, the mark 1A.

16             In addition, I would like you to please explain to us what the

17     room was used for.

18        A.   This was a room with what we refer to as the mediation board.

19     There was a handheld telephone switchboard there.  There was an operator

20     who would then switch the cables over, specifically automatic and direct

21     lines depending on requirements.  The established name was handheld

22     telephone switchboard.  Some people -- or hand-operated telephone

23     switchboard.  Some people called it the mediation board, but it was a

24     hand-operated telephone switchboard and what was done there is certain

25     channels and certain types of communications were rearranged.

Page 28769

 1        Q.   The next room is marked as ATCOM60.  Put a number two there,

 2     please.  As in the previous case, please explain what the room was used

 3     for?

 4             JUDGE AGIUS:  Yes, before you answer, please, Mr. Pajic.

 5     Mr. Vanderpuye.

 6             MR. VANDERPUYE:  Thank you, Mr. President.  I'm sorry to

 7     interrupt my colleague, at line -- at page 23, I think it's line 12,

 8     it's -- it's a question that you put to the witness -- I'm sorry, it's

 9     line 2 where you refer to a room marked as DS.  In the diagram that's

10     provided in e-court, it seems to indicate PS, P like "pole."  And I just

11     wanted the record to be clear as to what we are referring to.

12             JUDGE AGIUS:  Yes, Mr. Petrusic.

13             MR. PETRUSIC: [Interpretation] The Prosecutor is entirely right.

14        Q.   Mr. Pajic, could we therefore go back to 1A, the initials that

15     were placed there.  Can you tell us what they read?

16        A.   In 1A we see the initials "PS," PS, which is short for

17     "posraniski spor [phoen]."  It was the device used to switch channels

18     over between different kinds -- types of communication.

19        Q.   Thank you.  Let us now go back to the room marked as number 2.

20        A.   Yes.

21        Q.   Shall I repeat my question?

22        A.   No, no need.  Thank you.  This is the automatic telephone

23     switchboard, OM60.  250 automatic numbers being its capacity.  This is a

24     commutational system being used for direct communication by automatic

25     selecting a number on a telephone device establishing communication

Page 28770

 1     between two participants.  Therefore, the dialing itself was automatic

 2     and the numbers were automatic between two or more participants.

 3        Q.   Can you please mark the following room as number 3.

 4        A.   [Mark]

 5        Q.   And tell us what UNF room means.

 6        A.   In this room, there were telephone devices with portable

 7     frequency.  As I mentioned before, these were V120/3, 12K/24, VZ4/12.

 8     These devices being connected by cable to the radio relay communications

 9     hub at Veliki Zep.  They were used for demodulating signals from high

10     frequency to low frequency, and then transmitting the signal to the end

11     user.

12        Q.   The next premise, could you mark it with a number 4, please.

13        A.   [Marks]

14        Q.   And it says "teleprinter station," so could you very briefly

15     describe it for us?

16        A.   In this room the telegraph devices are placed, teleprinters, PTL1

17     and PT100.  They were used for the transmission of written information

18     between two participants, and the room next to it, we can call it 4A; it

19     was a workshop used for repairing these telegraph devices.

20        Q.   Let me be quite sure.  Did you say that it was teleprinter PTL1,

21     PTL1?

22        A.   ETL1, ETL1, Europe.

23        Q.   The next room, could you mark it with the number 5.

24        A.   [Marks]

25        Q.   And it says STPL, SEKZS [as interpreted]?

Page 28771

 1        A.   Yes, this is the abbreviation --

 2        Q.   Just a moment please.  There is an error here.  The marking is

 3     STPL --

 4             THE INTERPRETER:  Could counsel speak into the microphone,

 5     please.

 6             MR. PETRUSIC: [Interpretation] STPL, that is the marking.  SDKZC.

 7        Q.   So could you please explain what the purpose of this room was?

 8        A.   Yes.  This is an abbreviation which means crypto-protection or

 9     encoding station.  It's a station for encoding.  This is where acts were

10     transformed into telegrams, telegrams coded, and sent as such to a

11     particular participant.  So in the teleprinter stations, documents were

12     transformed into telegrams, encoded, and sent to participants.

13        Q.   The next rooms, would you please mark them with the numbers 6, 7,

14     and 8.

15        A.   [Marks]

16        Q.   And tells what these rooms were used for.

17        A.   These rooms were intended for the rest of the personnel at the

18     stationary communications centre, people working in the underground

19     facility of the communications centre.

20        Q.   And the room at the top left hand corner, could you mark it too.

21     Do you remember what number it bore?

22        A.   10.

23        Q.   And whose room was it?

24        A.   It was intended for the accommodation of the commander of the

25     Main Staff of the army of Republika Srpska in the event of danger from

Page 28772

 1     the air, chemical or biological threat or the incursion of enemy

 2     elements.

 3        Q.   And the room below the commander's, whose was that?

 4        A.   It was the number 9.  It was for the same purpose only for the

 5     chief of the Main Staff of the army of Republika Srpska.

 6        Q.   And the next one please?

 7        A.   [Marks]

 8        Q.   This was intended for the accommodation and stay of the chief of

 9     the sector for intelligence security affairs.

10             Do you know who was the chief of staff of the army Republika

11     Srpska in 1995?

12        A.   The Chief of Staff of the army of Republika Srpska in 1995 was

13     General Manojlo Milovanovic.

14        Q.   And the chief of the sector for intelligence and security?

15        A.   The chief of the sector for intelligence and security was

16     General Zdravko Tolimir.

17        Q.   The next room, do you remember what number it bore?

18        A.   Yes, it carried the number 12.

19        Q.   And tell us what it was used for?

20        A.   It is the operations centre where the operations officer on duty

21     would stay, and the officers working in the operations administration.

22        Q.   And the room next to the operations room, you called it a working

23     room --

24        A.   [Marks]

25        Q.   Could you mark it with 12A.

Page 28773

 1        A.   That was room number 13.  It was a work room with maps or simply

 2     a kind of study for the officers.

 3        Q.   And we have three more rooms left.  Could you mark them with the

 4     numbers 14, 15, and 16?

 5        A.   Yes, the next room, that is number 14, was envisaged to house the

 6     chief of the anti-air defences and airforce, the chief of the financial

 7     service, and for --

 8        Q.   Have you finished, Mr. Pajic?

 9        A.   Are you referring to room number 14?

10        Q.   Yes.

11        A.   I said the officers of the air force, anti-air defences, the

12     officers of the financial service, and of the officers -- I can't exactly

13     remember what these abbreviations stood for.  I think for religious

14     affairs or something like that.  I forget what the precise name of the

15     administration was for moral and religious affairs.

16        Q.   Tell us now please, Mr. Pajic, whether all these rooms were

17     linked by the communications system, and if so, how?

18        A.   Yes, all these premises were linked together by the

19     communications system so that in each room there was an automatic

20     telephone number that was forwarded from the automatic telephone exchange

21     M60.  So the cable linked all these premises and linked to the

22     distribution board 1B.

23        Q.   In view of the time that has passed, but also in view of the time

24     you had spent in that underground facility, do you remember any telephone

25     numbers?

Page 28774

 1        A.   Yes, I do.  Some of them, not all of them, but I do remember a

 2     lot.

 3        Q.   Could you tell us which numbers you remember?

 4        A.   Let me start from room number 1 where it says telephone switching

 5     box 222 and 9; in number 2, 149; in number 3 -- in room number 3, 280; in

 6     room number 4, 221; in room number 10, 161 and 370; in room 9, 155 and

 7     156; in room 12, 155 and 151; in room 13, 227; in room 15, 270.  I can't

 8     remember the number in room 16.  There are some numbers that I don't

 9     remember, but those I have indicated are quite right.  I am quite sure

10     about that.

11        Q.   Do you remember number 277?

12        A.   Number 277, I think it was in room 13.  I am not quite sure of

13     that.

14        Q.   Mr. Pajic, could you tell us how - and on the basis of which

15     principle - the number 155 functioned in view of the fact that we have

16     them in two different places?

17        A.   This number, 155, was distributed into four different places and

18     not two.  In the underground facility, it was in room number 9 and room

19     number 12.  And at the same time, it was also distributed to the

20     above-ground facilities, so-called Crna Rijeka, in the operations centre

21     and in the premise where General Milovanovic rested and stayed.

22             But when the operations centre and the chief were underground,

23     then this number was switched off with plastic -- by a plastic device.

24        Q.   Perhaps it's a leading question, but does that mean it would ring

25     at the same time in room 9 and room 12?

Page 28775

 1        A.   Yes.  It could ring in room number 9 and in room number 12.  And

 2     technically, it's also possible to isolate room number 9 so that it would

 3     only ring in room number 12, but usually it would ring in both these

 4     rooms in view of the fact that it could be switched off on the

 5     inter-phones, so the alarm wouldn't go on.

 6        Q.   Mr. Pajic, are you familiar with the concept of the command post

 7     in the rear?

 8        A.   Yes, yes.  I know the command post in the rear.  In -- the

 9     abbreviation was PKM.  You are talking about the command post in the

10     rear?

11        Q.   But before we go into that, could you tell me whether and how the

12     premises of the command that were in the cabins, were they linked in the

13     same way, and was the same system applied as in the underground facility?

14        A.   Yes.  The premises in the cabins or the settlement, as we called

15     it, were also linked together; and each premises had an automatic 3

16     siphon number, because the underground cable linked the G1 underground

17     facility with the above-ground facilities.

18        Q.   And in that facilities known as cabins, did they have the same

19     devices as those in rooms from 1 to 5?

20        A.   These devices were not installed in the cabins if you're talking

21     about those in rooms 1 to 5.  In the cabins, there were only telephone

22     receives, inductors, automatic ones, and inter-phones.  F2 and F3.

23        Q.   And before the break, could you tell us also how the rear command

24     post was linked to the basic command post?

25        A.   The command post in the rear, which was in the hotel in Hans

Page 28776

 1     Pijesak, was linked by cable - that is by wire - via the facility G2, the

 2     barracks in Hans Pijesak, the PTT - that is the post office - in Hans

 3     Pijesak, and the hotel where the command was situated.  And we also had

 4     another relay direction, 0718; Veliki Zep, Hans Pijesak hotel.

 5             JUDGE AGIUS:  All right.  Mr. Petrusic, we'll soon be having the

 6     break any minute now.  I suggest that the witness signs the document

 7     before the break.

 8             Mr. Pajic, you need to put your signature down below or upper

 9     right-hand corner, it's better -- okay, all right.

10             THE WITNESS: [Marks]

11             JUDGE AGIUS:  Plus the date, please.

12             THE WITNESS: [Marks]

13             JUDGE AGIUS:  All right.  Thank you.  Shall we have the break

14     now?  25 minutes.  Thank you.

15                           --- Recess taken at 3.45 p.m.

16                           --- On resuming at 4.14 p.m.

17             JUDGE AGIUS:  Yes, Mr. Petrusic.

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

19        Q.   Mr. Pajic, we'll now carry on.  And --

20             JUDGE AGIUS:  Do you still require the documents so that we bring

21     it up if necessary?

22             MR. PETRUSIC: [Interpretation] Not for the moment.

23             JUDGE AGIUS:  Okay.

24             MR. PETRUSIC: [Interpretation]

25        Q.   Mr. Pajic, can you tell us how the basic command post was linked

Page 28777

 1     up to the rear command post in Hans Pijesak?

 2        A.   The basic command post in Crna Rijeka was linked to the rear

 3     command post in Hans Pijesak by wire communications and by radio relay

 4     communications.

 5        Q.   Can you tell us whether these links or other words these numbers

 6     were three-figure numbers, or were other civilian numbers used?

 7        A.   Yes.  The numbers used were three-digit numbers sent from the

 8     switchboard to the rear command post via the relay post and via wire

 9     communications.

10        Q.   Where there devices for cryptographic protection, and was there a

11     teleprinter at the rear command post?

12        A.   Yes, at the rear command post there was a coded teleprinter

13     station.

14        Q.   Was it also linked up to your teleprinter post?

15        A.   Yes, the Main Staff had teleprinter connections with all

16     subordinate units, the corps, the PKMs, the rear command posts, the

17     forward command posts; and they also had links to the presidency of the

18     Republika Srpska.

19        Q.   And now, very briefly what kind of direct links, if there were

20     any such links, between the rear command post and the basic command post?

21        A.   Yes, there were direct links between the command post and the

22     rear command post.  There was a link between the encrypted teleprinter

23     posts, and there were direct links between the duty officer at the PKM

24     and the operations duty officer in Crna Rijeka.

25        Q.   Tell me, were you aware of the fact that in the course of 1994 or

Page 28778

 1     1995 forward command posts were established by the Main Staff?

 2        A.   Yes, towards the end of 1994 a forward command post of the Main

 3     Staff was established in the sector.  In fact, the name of the place was

 4     Jesenice.  Prior to that act, a forward command post of the 93rd had been

 5     established on Jahorina for the Lukavac 93 operation.

 6        Q.   This IKM, forward command post, in Jesenice, we heard something

 7     very briefly evidential about it, but do you know anything about the

 8     territory -- or, rather, the part of the Republika Srpska that it was

 9     located in?

10        A.   It was in the western part of Republika Srpska in the area of

11     responsibility of the 2nd Krajina Corps.

12        Q.   Do you know anything about which officers from the Main Staff

13     were present at that IKM?

14        A.   I remember that the Chief of Staff, General Milovanovic, was

15     present at the IKM at the forward command post; and then there was

16     Colonel Masal, and there were some other officers whose names I cannot

17     remember right now.

18        Q.   Can you tell us whether when this IKM was established, the IKM --

19     whether the 67th Communications Regiment of the Main Staff had anything

20     to do with the establishment of that post?

21        A.   Yes.  The 67th Communications Regiment dealt with communications

22     for the needs of the Main Staff of the Republika Srpska.  It was the

23     command of the 67th Communications Regiment that provided the equipment

24     and men for the IKM in question.

25        Q.   When you say "equipment," what do you have mean by that?

Page 28779

 1        A.   Well, if a unit located in the area before the IKM was set up had

 2     certain equipment we could use, for example, relay devices or frequency

 3     carrier, well then in such cases we wouldn't establish new networks.  We

 4     would use the channels in existence, and if there was anything missing,

 5     we would add the necessary equipment.  We had an FM20 [as interpreted]

 6     radio relay that was set up, and crypto-protection station that was set

 7     up.

 8             MR. PETRUSIC: [Interpretation] In line -- rather, page 33, line

 9     12, it says FM20 --

10        Q.   I believe that you said an FM200; can you confirm whether we are

11     dealing with an FM200 device?

12        A.   Yes, the device is an FM200 device.

13        Q.   Tell me, when this was being done, when the communications

14     network was being set up, what kind of direct links were there to the

15     basic command post and the forward command post, if there were any such

16     links in the western part of the Republika Srpska; or, rather, I am

17     talking about the IKM in Jesenice?

18        A.   Yes.  The forward command post was linked to the command post via

19     relay communications.  There were four channels.  There was a direct link

20     between the command of the Main Staff and General Milovanovic at the

21     forward command post.  There was a link between the operations duty

22     officer and the duty officer at the IKM, and then there was a link -- or

23     there was a communications network for forwarding written information,

24     the teleprinter post was used for these purposes, and there was a fourth

25     channel that was used to make sure that one had an automatic three-digit

Page 28780

 1     number at the IKM.

 2             So, when you say "three-digit number," I am thinking about the

 3     M60 device, and this is how information was sent to the IKM.

 4        Q.   I'd just like to correct something -- or, rather, clarify

 5     something.  When you spoke about direct links between the IKM and the

 6     Main Staff, can you tell us whether General Milovanovic and

 7     General Mladic had a direct link?

 8        A.   Yes, they had a direct link.

 9        Q.   Tell me - and this is a subject we will go back to later - was

10     the link you've been discussing protected, encrypted, link?

11        A.   Yes, these links were secure links.

12        Q.   And does that involve all the four channels that you have

13     mentioned?

14        A.   Well, usually channels used for the commander -- for the

15     operations centre, would be secure.  But it wasn't necessary to secure

16     the link that was used to forward information to the teleprinter post,

17     and the three-digit number that was at the IKM was also a secure link at

18     the time.

19        Q.   Let's briefly go back to the telephone number 155.  Does this --

20     was it possible to transfer this telephone number from Crna Rijeka to the

21     IKM?

22        A.   Yes, it was technically possible to transfer it; however, at the

23     time it wasn't transferred to the IKM.  All I can remember is that it was

24     transferred in 1993, there was an IKM at Jahorina, but in 1995 there was

25     some other number that was used.  Not the one you have mentioned.  But

Page 28781

 1     technically, it is possible to move or, rather, transfer that number.

 2        Q.   Yes, and you said that in 1995 this number had not been

 3     transferred?

 4        A.   No, it hadn't been transferred at that point in time.  It was

 5     used at the IKM in Jesenice.

 6        Q.   Mr. Pajic, given the duties you had to perform, given your

 7     position, and given the devices that you worked with, do you know whether

 8     the communications of the army of Republika Srpska could be tapped?

 9        A.   It was technically possible to wire-tap these communications.

10     Devices that used high frequencies, for example, the SMC1306B, was a

11     device that could be wire-tapped only with a lot of difficulty.  As far

12     as the FM200 device is concerned, I am talking about relay devices that

13     used a frequency of 610 to 960, well, if they -- if these devices were

14     secured then they couldn't be wire-tapped.  So technically, it was

15     possible to wire-tap the communications system, but it was very

16     complicated.

17             The devices have to be used at maximum output.  It's possible to

18     have an intermediary station between the electro-magnetic waive length.

19     You have to have two radio devices.  You have to have two MF devices for

20     one of the participants or both of the participants; so you practically

21     have to enter the area where the relay system is being used in order to

22     tap into it.  Or, you have to set up a station opposed for both

23     participants; in such a case, you can only wire-tap communications in one

24     direction.  So technically this was possible, but it was very difficult.

25     But when I mentioned secured links, I said that it wasn't possible to

Page 28782

 1     wire-tap them.

 2        Q.   Did the Main Staff have secure communications links?

 3        A.   Yes, the Main Staff of the Republika Srpska army had secured

 4     links to all subordinate units, to corps; it had a secure link to the

 5     government, the Assembly, and the president of the Republika Srpska; and

 6     it also had a secure link to the army of Yugoslavia.

 7        Q.   If I have understood you correctly, do you exclude the

 8     possibility of the ABiH wire-tapping these devices or some other act?

 9        A.   Yes.  With regard to these communications links, as I have

10     already said, it wasn't possible to wire-tap them.  I am talking about

11     secure links, about this secure communications system.

12        Q.   Two radio relay devices have often been mentioned here.  One

13     radio relay device in the so-called RRU1, I am interested whether when

14     this device was used to establish communications, was it possible to

15     intercept these communications?

16        A.   The RRU1 radio relay device is a one-channel device.  Its range

17     is up to 30 kilometres.  If there is an optical line of sight -- if there

18     is a good optical line of sight.  And given that its antenna isn't a

19     directional one, it's not as focused, and it uses lower frequencies; so

20     it is possible to intercept communications when this device is used.

21        Q.   And what is your experience with the 800 radio relay device?

22        A.   RRU800 is one of the radio relay devices.  It is a somewhat older

23     model, the range being 690 [as interpreted] to 960, same as the 200, and

24     the 9B.  As I explained, it can't be intercepted.  From one of the two

25     relay posts communicating, if it operates at its full capacity, it

Page 28783

 1     normally admits a rather powerful magnetic field.  Or, for example, it

 2     can go into a node with one of the posts involved in the communication,

 3     but I am not aware of this ever happening.  I apologise, 610 to 960.  I

 4     see that it was mis-recorded, the frequency range of the RRU is 610 to

 5     960 megahertz.

 6        Q.   Can you please repeat yet again.  What is the frequency range for

 7     that device, RRU800?

 8        A.   The range is between 610 and 960 megahertz, and there are another

 9     two device that have the same range, the 200 and the RRU9B; I keep

10     repeating that.  But the thing is all these three radio devices use the

11     same frequency range, and the frequency range is 610 to 960 megahertz.

12        Q.   If my understanding is correct, this being the case, one could in

13     theory listen to one participant at a time, right?

14        A.   Yes, as long as the party doing the intercepting is actually

15     located behind one of these posts if they are receiving a reflected way

16     or through an antenna.  Thus is set up at the point of reception.  In

17     that case, he would be able to listen to one of the parties involved in

18     the exchange.  In order to hear both ends of the communication, you would

19     need to interpose a post within the electro-magnetic sheathe.

20        Q.   What about the interposed --

21             JUDGE AGIUS:  One moment, one moment.  Yes, Mr. Vanderpuye.

22             MR. VANDERPUYE:  Thank you, Mr. President.  I don't want to

23     interrupt my colleague before the long, but I did just want to let the

24     Court know that this is an area of examination of which we've had no

25     prior notice, and I wanted to let -- well, rather, ask the Court's

Page 28784

 1     permission when I cross-examine this witness it may take longer than I

 2     had initially anticipated and this relates to intercepts and the

 3     capability to receive and transmit them, which we've gone over I think

 4     rather extensively in the case; but still think I will need to address

 5     it.

 6             JUDGE AGIUS:  Okay.  I think I saw Madam Fauveau even nodding.

 7     Yes, we'll see into that later, and you tell us what your needs are and

 8     we'll decide depending on what we consider to be in the best interests of

 9     justice at the time.  Thank you.

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

11             MR. PETRUSIC: [Interpretation] Indeed, you are right, but my

12     understanding is that these are general questions on intercepting without

13     going into detail.  Anyway, I was about to move on.

14        Q.   Mr. Pajic, after completing your training and education you got a

15     promotion, you were now a sergeant and you dealt with communications,

16     generally speaking.  Throughout your career in wartime or before the war

17     broke out, were you ever trained in encryption, to perform jobs that had

18     to do with encryption?

19        A.   Yes, I took a course in encryption, in cryptographic protection,

20     if you like.  At various points throughout my career I used devices for

21     the encryption of speech.  I was required to take and complete that

22     course, and the course applied to both encryption of both written

23     material and voice encryption.  However, I never actually performed the

24     job of an encryption officer.

25             MR. PETRUSIC: [Interpretation] Can we please have P192.

Page 28785

 1        Q.   Mr. Pajic, in your --

 2             THE INTERPRETER:  Could counsel please be asked to repeat what he

 3     just said, to speak up, and to move closer to the microphone.  Thank you.

 4             JUDGE AGIUS:  Mr. Petrusic, the interpreters couldn't hear what

 5     you were saying.  So if you could repeat the question, please.  Thank

 6     you.

 7             MR. PETRUSIC: [Interpretation]

 8        Q.   Mr. Pajic, do you distinguish in your profession between what you

 9     normally refer to as an act or enactment, on the one hand, and a telegram

10     on the other?

11        A.   Yes, there is something that we refer to as an act or a document

12     and then there is a telegram, too.

13        Q.   You can see a document that is now being displayed on the monitor

14     in front of you.  It's in the Latinic script.  Can you tell us what it

15     shows?

16        A.   This document was intended to be an act or a document; however,

17     it really is nothing.  It's certainly not an act.  An act should display

18     in its header, in the upper left corner the name of the relevant

19     institution or unit, the file number, the date it was sent, the

20     addressee, the substance of the document, and finally the sender.  There

21     should be a handwritten signature and a round stamp.  This document bears

22     none of the above; therefore, I can hardly refer to it as a telegram or,

23     indeed, an act.

24        Q.   If you look at the right-hand side, towards the bottom in the

25     Cyrillic --

Page 28786

 1             MR. PETRUSIC: [Interpretation] If we can please pull up the

 2     English a little, page 2 in the English.

 3        Q.   If you look at the Cyrillic it reads, "Handed over at 1510, 13th

 4     of July 1995."  And then there is a signature.  Can you comment on this,

 5     what the document says?

 6        A.   It tells me nothing.  If we are talking about what the

 7     regulations said, this is not done properly.  I happen to know this lad,

 8     Darko Gojkovic.  He noted down the time, who it was sent to.  I really

 9     don't know.  I don't know if the recipient ever in fact received this.

10     It is not confirmed on the face of the document.  It was done improperly.

11     This is not an act, and it's certainly not a telegram that was sent.

12     Maybe it was sent at some point, but being what it is, it was done

13     improperly; and I don't think it could have been accepted by the

14     encryption system.

15        Q.   So how far do you think this document could possibly have got?

16        A.   Believe me I simply don't know.

17             MR. VANDERPUYE:  The witness has answered the question.

18             JUDGE AGIUS:  Anyway, its doesn't matter.  So yes, Mr. Petrusic.

19             MR. PETRUSIC: [Interpretation] Can we have 5D1005.

20        Q.   Mr. Pajic, this is a document from the Drina Corps command.  Can

21     you please have a look and read through it.

22        A.   Yes, I've read it.

23        Q.   What about the encryption people at the Main Staff, did you

24     comply with the rules on official correspondence and on encryption

25     throughout 1995?

Page 28787

 1        A.   Yes, we complied.  And this is one of the documents or; rather,

 2     orders by the Drina Corps done in that spirit.  So this was the way it

 3     was supposed to be done, and we certainly complied with the rules and

 4     regulations on encryption in our office work.  This order shows nothing

 5     new.  All it is is some sort of a warning to comply with the rules in the

 6     way just described.

 7             MR. PETRUSIC: [Interpretation] Can we please have P183.

 8        Q.   Please look at the document and tell me, if you can, whether this

 9     is an act or a telegram as defined a while ago.

10        A.   Again, it is neither.  The only difference between this document

11     and the previous one being this one was actually typewritten using a --

12     an ATL1 teleprinter; nevertheless, what's missing here is a rectangular

13     stamp showing the time of deliver, the time the telegram was processed,

14     and likewise there is no confirmation of receipt by the other end.

15             In the right upper corner we have a time.  There should be a

16     signature.  This is probably the encryption officer same as in the

17     previous document, but I really can't say.  So again, what we have here

18     is one of those improper telegrams.  I am not saying that it wasn't sent.

19     Mind you, it may I have been sent in this shape and form; all I am saying

20     is that it was not done properly not in keeping with the rules, and we

21     see no confirmation of the other end or the other side receiving the

22     document.  Therefore, we don't know if the addressee, the intended

23     recipient ever received the document.

24             JUDGE AGIUS:  One moment, Mr. Petrusic.  Just to have things

25     clear in our mind and that -- so that at all times we will be on the same

Page 28788

 1     wavelength.  You've drawn a distinction between an act and a telegram.  I

 2     think we understand quite well what a telegram is.  In order to avoid any

 3     possibility of not understanding you, what do you really mean by "act"?

 4     And then please make sure that the witness agrees with the meaning of

 5     "act" or the definition of "act" as you will be giving it to us.

 6             What do you understand by "act"?

 7             MR. PETRUSIC: [Interpretation] The word "act" is anything in

 8     writing, typewritten, signed, by a sender showing a stamp and, of course,

 9     a header indicating the name of the command sending the document.  I

10     think the witness himself in part has explained this from the perspective

11     of his own profession.

12             JUDGE AGIUS:  All right.  The important thing is that you and the

13     witness in using the descriptive word "act" mean exactly the same thing.

14     That's what we want to know.

15             Mr. Pajic, you've just heard Mr. Petrusic explain to us what, in

16     his mind, he means when he uses the word "act."  Is this what you

17     understand by the word "act" yourself, or do you wish to add anything?

18             THE WITNESS: [Interpretation] Yes, I do agree with Mr. Petrusic.

19     The only thing is when such an act arrives at the teleprinter station for

20     encryption, the encrypting officer receives this and then puts a

21     rectangular stamp on it.  He also notes the time, records the time on the

22     face of the document, after which the document is returned to whoever the

23     sender happens to be.  A telegram is what is sent to the opposite side as

24     it were.  It is first encrypted and then one uses a teleprinter post to

25     send it along, as it were.

Page 28789

 1             JUDGE AGIUS:  Thank you.

 2             MR. PETRUSIC: [Interpretation] Just briefly, to clear any doubts,

 3     we talked about the rules and office work, the document being 5D1994 --

 4     11, rather, 1194.  Page 9 of that document, please.  In the English

 5     version it is also page 9.  Let us see Provision 16.

 6        Q.   Mr. Pajic, please look at this paragraph 16.

 7             MR. PETRUSIC: [Interpretation] In the Serbian version move on to

 8     the next page, please.

 9        Q.   My question is:  Have you seen it?

10        A.   Yes.

11        Q.   Is this what is called an act, does this define an act according

12     to your professional terminology and the terminology of office work that

13     you used in the army of Republika Srpska?

14        A.   Yes, it is.

15             MR. PETRUSIC: [Interpretation] The next page in the e-court is

16     page 15, and in the Serbian version --

17        Q.   Would you please read, for yourself, paragraph 36.

18        A.   I have read it.

19        Q.   Under the concept of "telegram," do you mean precisely what is

20     stated here in paragraph 36?

21        A.   Yes, that is it.

22             MR. PETRUSIC: [Interpretation] Could we now go back to document

23     P183.

24        Q.   Will you please read through this telegram.  It's quite brief.

25        A.   I have read it.

Page 28790

 1        Q.   First of all let me ask you whether in July 1995 you were in

 2     Crna Rijeka?

 3        A.   Yes, I was, in that period in G1.

 4        Q.   Do you remember whether you were ever included in the plan of

 5     work of the communications centre, this radio device 2/2 K and KZU-63?

 6        A.   I do not remember at all such an order nor did we form such a

 7     radio network, RU 2/2.  It was not formed for the needs of the

 8     above-indicated institution.

 9             MR. PETRUSIC: [Interpretation] Could we see document 5D1020.

10        Q.   Before we discuss this document, let me ask you:  Do you remember

11     whether the Main Staff ever used a radio device 2/2 K?

12        A.   No.  It never used that device RU 2/2 K.

13        Q.   Will you please read through this document as well.

14        A.   I have read it.

15        Q.   Would it happen that communications would be switched off in the

16     Main Staff in the course of 1995?

17        A.   Before I say that, I would like to say that this is how a

18     telegram sent and received properly should look like.  There is a

19     rectangular stamp, the time it was received, stamped by the receiver in

20     the Main Staff; and that is how a telegram properly received should look

21     like.

22             As for this order, it would happen in the course of the war that

23     there was an interruption in the communications because of failure in the

24     generators which were outdated, low voltage strength of the network, a

25     shortage of fuel, and it happened during the bombing that we would switch

Page 28791

 1     off the facility during day-time because of the danger from the air.

 2             In view of the fact that when the devices got switched on, they

 3     radiate through the antennas and they reveal the location of the radio

 4     stations.  So there were such cases.

 5        Q.   Are you aware of cases at lower tactical levels of interruptions

 6     in the communications system?

 7        A.   Yes, there were problems at other facilities, especially where

 8     the nodes and centres were improvised due to the same causes, a shortage

 9     of fuel, a breakdown in the generators.  This would happen quite

10     frequently that the frequencies would breakdown, and it would be

11     impossible to communicate telegrams and other documents.

12             MR. PETRUSIC: [Interpretation] One more document, please.

13     5D1019.  In the Serbian version, please scroll the document down.

14        Q.   My first question, Mr. Pajic, is:  Do you consider this to be a

15     correct regular telegram or act or document?

16        A.   Yes, this is a proper act prepared to be sent as such from the

17     encryption teleprinter station as a telegram.

18        Q.   I should like you to focus your attention on the last sentence

19     before point 2.  It says -- it begins with the word "note."

20        A.   Yes, I see it.

21        Q.   Obviously there are problems in telecommunications, so it is

22     impossible to send a report.  How long would these failures last, are you

23     aware?

24        A.   That depended on the cause, whether it is a radio relay device,

25     the source of energy; it could last from five minutes to a whole day

Page 28792

 1     sometimes.

 2        Q.   Do you remember that there were such failures at the

 3     Veliki Zep --

 4             THE INTERPRETER:  The interpreter didn't hear the question.

 5             JUDGE AGIUS:  Don't you think he has already answered this

 6     question, Mr. Petrusic?

 7             MR. PETRUSIC: [Interpretation] Thank you, Mr. President.  I'll

 8     move on to the very end of my examination.

 9        Q.   Mr. Pajic, did you know Mr. Miletic?

10        A.   I did know General Miletic.

11        Q.   Do you know whether he spent any time in the underground facility

12     in the summer of 1995?

13        A.   Yes.  General Miletic did stay in the underground part of the

14     facility G1, sometimes -- some time around the 25th of May when there was

15     the bombing of the Jahorina stream, when the operations centre was moved

16     underground; that is, to room number 12.  And that is where I would see

17     General Miletic.

18        Q.   Do you know where his family was staying?

19        A.   His family, as far as I know, was living in Belgrade.  They had

20     an apartment in Belgrade, and that is where his wife and children were

21     living.

22        Q.   Do you have any knowledge as to whether he went to visit his

23     family?

24        A.   Yes, like all the other officers there was a monthly schedule for

25     their visits to families; and, therefore, General Miletic went to visit

Page 28793

 1     his family as well.

 2        Q.   Do you have any knowledge as to whether the General visited his

 3     family in July 1995?

 4        A.   There is an event that I remember quite well.  On the 11th of

 5     July 1995, in a weekend settlement in Hans Pijesak, we had a grill.  We

 6     were roasting a lamb, and this was organised by Mr. Petrovic; and this

 7     ended in the afternoon and mostly the officers from the rear command

 8     post, we sat at a table.  And next to me Colonel Simovic, Mirko, was

 9     sitting.  And he asked, Where is Mica?  And Petrovic responded, Which

10     Mica?  And then he said, Miletic.  And then Petrovic answered, He's in

11     Belgrade visiting his family.

12             There were some other officers present there, I can't exactly

13     remember, I think Lieutenant-Colonel Kerkez and some others.  I can't

14     remember their names, but I remember this particular event for certain.

15        Q.   Do you know the name of this Mr. Petrovic?

16        A.   Rajko Petrovic.  He worked as a an employee in the financial

17     station.

18        Q.   Could you give us the name of the lieutenant-colonel that you

19     mentioned?

20        A.   Lieutenant-Colonel Zeljko Kerkez.

21        Q.   Can you link, or, rather, do you link this particular event to a

22     particular date?  I'm sorry.  You've already told us that.  You've

23     mentioned the 11th of July.

24             Can you explain what do you link that date with, why has it stuck

25     in your memory?

Page 28794

 1        A.   I remember it because later on, in the evening, just before

 2     darkness fell, I don't remember the exactly time, we were informed that

 3     in view of the fact that Rajko Petrovic had a three-digit number on the

 4     automatic exchange that I mentioned, that the army of Republika Srpska

 5     had entered the town of Srebrenica; and that is why I remember that date

 6     so well.  Because we were having the this roast that day, so I remember

 7     it very well.

 8        Q.   And finally, Mr. Pajic, I ask you a technical question linked to

 9     your profession.  From which locations within the territory of Republika

10     Srpska was it possible to send an encoded telegram with the heading of

11     the Main Staff?

12        A.   It was possible to send it from any command post of a brigade or

13     a corps, wherever there was an encryption, teleprinter station it could

14     be sent.  Wherever there was an encryption, teleprinter station, a

15     telegram could be sent regardless of the header.

16        Q.   And if it is sent from the brigade, is it directly addressed to

17     the Main Staff?

18        A.   No, not to the Main Staff, but to the superior unit.  If it's

19     going from the brigade, then it is sent to the corps.  In the corps, the

20     encoders reprocess the telegram and dispatch it to the Main Staff.  And

21     then from the Main Staff, it is sent to units and institutions to which

22     it is addressed.

23             MR. PETRUSIC: [Interpretation] Mr. President, I would end my

24     examination-in-chief there, and I wish to thank the witness.

25             JUDGE AGIUS:  Thank you Mr. Petrusic.

Page 28795

 1             Mr. Zivanovic, you had asked for 20 minutes.

 2             MR. ZIVANOVIC:  No questions for this witness, Your Honour.

 3             JUDGE AGIUS:  Thank you.  Mr. Nikolic.

 4             MR. NIKOLIC: [Interpretation] I don't have any questions, Your

 5     Honour.

 6             JUDGE AGIUS:  Thank you, Ms. Nikolic.

 7             MS. NIKOLIC: [Interpretation] I don't have any questions.  Thank

 8     you, Your Honours.

 9             JUDGE AGIUS:  Thank you.  Mr. Lazarevic.

10             MR. LAZAREVIC:  No questions, Your Honour.

11             JUDGE AGIUS:  Thank you.  Mr. Krgovic.

12             MR. KRGOVIC:  I will have a few questions, Your Honour.

13             JUDGE AGIUS:  Yes, go ahead.

14                           Cross-examination by Mr. Krgovic:

15        Q.   [Interpretation] Good day Mr. Pajic.  My name is Dragan Krgovic,

16     on behalf of General Gvero's Defence, I will put a few questions to you

17     that have to do with your testimony today.

18             MR. KRGOVIC: [Interpretation] Could the witness please be shown

19     Exhibit 6D178.

20        Q.   Mr. Pajic, you have a telegram -- a recipient telegram, that's

21     how I would put it, an incoming telegram.  I don't think you've seen this

22     document before, but it fulfills the conditions you referred to when

23     answering questions from my colleague, Mr. Petrusic.  When he asked you

24     whether a document was drafted in accordance with the regulations; isn't

25     that correct?

Page 28796

 1        A.   Yes.

 2        Q.   And in the block signature, you can see the name of

 3     Lieutenant-Colonel Pandurevic, which shows that he signed this incoming

 4     telegram.  My question is as follows:  Does this necessarily mean that

 5     Mr. Pandurevic actually signed the document, or is it possible that

 6     someone signed this telegram on his behalf?

 7        A.   Well, he could have signed this document but not necessarily.  If

 8     someone signed for him, usually you have “for” pencilled in, but an

 9     encryption teleprinter cannot convey this information, this element.  So

10     he could have signed it and someone else may have signed it.  So the

11     telegram should have been signed by the person who drafted the telegram

12     or by someone representing him.

13        Q.   Or by someone who had the right to send such a telegram?

14        A.   Yes, that's correct.  The person who is authorised by the

15     commander to act in this way.

16             MR. KRGOVIC: [Interpretation] Could the witness now be shown --

17             THE WITNESS: [Interpretation] Let me just clarify this again.  He

18     could have signed it but not necessarily.  Sometimes someone would pencil

19     in "for" and then you would have a signature.  But an encryption

20     teleprinter cannot transmit this handwritten signature.

21             MR. KRGOVIC: [Interpretation] Could the witness now be shown

22     Exhibit 6D177.  177, 177.

23             JUDGE AGIUS:  This document is under seal, so there will be no

24     broadcast of it, okay.

25             MR. KRGOVIC: [Interpretation]

Page 28797

 1        Q.   Mr. Pajic, this is, in fact, the outgoing telegram.

 2             MR. KRGOVIC: [Interpretation] Can we have a look at the second

 3     page of this document.

 4        Q.   Sir, this is what you were referring to, in fact, the person who

 5     signed the telegram isn't Lieutenant-Colonel Pandurevic.  Someone signed

 6     on his behalf, and in the incoming telegram this signature and the

 7     signature of the other person are not visible, do you agree with me?

 8        A.   Well, let's me tell you, this is an act, not a telegram.  This

 9     wasn't processed by an encryption teleprinter.  You just have a stamp

10     that shows that it was received through the encryption teleprinter after

11     it was typed out on a certain device --

12             THE INTERPRETER:  This witness is kindly asked to slow down.

13             THE WITNESS: [Interpretation] -- this is an act that was issued

14     by the encryption teleprinter, and it was drafted in order to be sent

15     out.

16             MR. KRGOVIC: [Interpretation]

17        Q.   Could you please slow down.  It's difficult for the interpreters

18     to follow you.

19        A.   Okay.

20        Q.   I will just give a hard copy of this document so that you can

21     compare the contents and see whether we're dealing with the same

22     contents.

23             Usher, could you please be of assistance?

24             In the first case, the document was supposed to be outgoing, and

25     this is an incoming telegram; do you agree?

Page 28798

 1        A.   The document without a handwritten signature was received by the

 2     Drina Corps command, and this is a coded act from the Zvornik Brigade.

 3     It was supposed to be sent out as a telegram.

 4        Q.   The contents are identical practically speaking?

 5        A.   I wasn't really looking at the contents.  I was trying to see

 6     whether the form was regular, and the form of the documents are quite

 7     regular.

 8        Q.   In fact, this is a document that was encoded, and the other

 9     document was received by the Drina Corps.  I am talking about the

10     transmission of the first document.  The second document is a

11     transmission of the first one?

12        A.   Yes.

13        Q.   Mr. Pajic, I now draw the conclusion that if you have an incoming

14     telegram and you have a signature on the telegram, it doesn't mean that

15     the individual concerned actually signed the document sent.  Would you

16     agree with me?

17        A.   I'll repeat this.  With regard to the incoming telegram, the

18     document that was encrypted, the encrypted telegram can't show a

19     handwritten signature, so the person can sign it or someone can sign on

20     behalf of someone else.  Here we can see that someone signed on behalf of

21     someone else.  There was the encryption teleprinter in Zvornik that was

22     supposed to forward a telegram.

23        Q.   You have just confirmed what I said; you said "yes" in response

24     to my answer.  But the question -- or, rather, your answer "yes" wasn't

25     recorded in the transcript.  Could you repeat that you, in fact, agreed

Page 28799

 1     with my claim?

 2        A.   Could you repeat what you said?

 3        Q.   When an incoming telegram arrives in a unit, and you can see the

 4     signature or, rather, a block signature of a certain individual, that

 5     does not mean that that individual actually signed the document in

 6     question.  Isn't that the case?

 7        A.   Yes, I agree with what you have said.

 8             MR. KRGOVIC: [Interpretation] Your Honours, I will move on to

 9     another subject now.  So if it's a good time to have a break, I have

10     another ten minutes -- oh, I apologise.

11             JUDGE AGIUS:  Yes, but the break is in almost 20 minutes' time.

12             MR. KRGOVIC: [Interpretation] I'm a little confused in the

13     afternoon sittings.

14             JUDGE AGIUS:  If you want, we can cancel sitting in the

15     afternoon; after all, they're all afternoons sittings.

16             MR. KRGOVIC: [Interpretation] Your Honours, you would be doing me

17     a big favour, you know.

18        Q.   Mr. Pajic, as far as I have noticed when responding from my

19     colleague, Mr. Petrusic, you said you were born in Rogatica; isn't that

20     correct?

21        A.   Yes, I was born in Rogatica.

22        Q.   And I assume that before you went to be schooled outside of

23     Rogatica, you lived in Rogatica; and your family lives in that area ;

24     isn't that correct?

25        A.   Yes.

Page 28800

 1        Q.   And you're familiar with the area around Rogatica and Zepa; isn't

 2     that right?

 3        A.   I know it quite well.

 4        Q.   Mr. Pajic, did your family live in the sector between Rogatica

 5     and Zepa in the summer of 1995?

 6        A.   Yes.  My parents lived in the village called Babljak, which is in

 7     the Borike local commune.

 8        Q.   Could you please repeat the name of the village?

 9        A.   Babljak.

10        Q.   As far as I know, it's in the immediate vicinity of the first

11     combat lines dividing the army of Republika Srpska and the Zepa Brigade

12     in the Zepa secretary.  It's not far from there; isn't that correct?

13        A.   Yes, that's correct.

14        Q.   In the summer of 1995, did you have the opportunity of visiting

15     your parents and relatives; in fact, did you go home?

16        A.   Yes, but not that often, occasionally.

17        Q.   Mr. Pajic, can you tell me is there -- between Rogatica and Zepa

18     were there any checkpoints of the army of Republika Srpska?  I'm not

19     referring to the checkpoint at the entrance to Rogatica on the upper

20     side.

21        A.   In 1995, I think there was a checkpoint at the cross roads

22     towards Visegrad and Borike at a place called Lijesce --

23             THE INTERPRETER:  If the interpreter heard the name correctly.

24             THE WITNESS: [Interpretation] -- there was a checkpoint there

25     occasionally.  I can't give you a precise date.

Page 28801

 1             MR. KRGOVIC: [Interpretation]

 2        Q.   And towards Zepa, were there any checkpoints towards Zepa going

 3     from Rogatica towards Zepa, were there any checkpoints there?

 4        A.   Well only at Boksanica, there was one there.

 5        Q.   At the very entrance to the enclave?

 6        A.   No, at Boksanica.  Up there, UNPROFOR was up there.

 7        Q.   UNPROFOR?

 8        A.   Yes, I had UNPROFOR in mind, but I don't remember the army of

 9     Republika Srpska having any checkpoints and apart from that, there was

10     this checkpoint at Lijesce.

11        Q.   Mr. Pajic, tell me, how far is Rogatica to Zepa by car?  How much

12     time do you need to get there by bus or in a convoy?  According to

13     information I had at the time, well, it took between an hour and an hour

14     and a half; would you agree with that?

15        A.   Yes, that's right, given that a large section of the road from

16     Mrkonic to Zepa was a macadam road.

17        Q.   Thank you very much, Mr. Pajic, I have no more questions for you.

18     Thank you.

19             JUDGE AGIUS:  Thank you.  Mr. Sarapa?

20             MR. SARAPA:  No questions, thank you.

21             JUDGE AGIUS:  Thank you.  Mr. Vanderpuye, we still have ten

22     minutes to go.  You can start, I think.

23             MR. VANDERPUYE:  Thank you very much, Mr. President.

24             JUDGE AGIUS:  Unless you prefer to delay it until after the

25     break, it's up to you.

Page 28802

 1             MR. VANDERPUYE:  No, I think now is a good time to start.

 2             JUDGE AGIUS:  All right.  Then go ahead.

 3             MR. VANDERPUYE:  Thank you, Mr. President.  Good afternoon to

 4     you, and Your Honours, good afternoon to my colleagues.

 5                           Cross-examination by Mr. Vanderpuye:

 6        Q.   And good afternoon to you, Mr. Pajic.  My name is

 7     Kweku Vanderpuye, and on behalf of the Prosecution, I am going to put

 8     some questions to you in relation to your direct examination and also in

 9     relation, perhaps, to your cross-examination.  If there is anything that

10     I ask you that's unclear to you, please let me know and I will try to

11     restate it or rephrase it in a way that we can best understand one

12     another.

13             Now, I think I want to work backwards in relation to your

14     testimony, but you wound up, your direct testimony, talking about

15     information that you received concerning Mr. General Miletic's

16     whereabouts on the 11th of July 1995.  Do you recall giving that

17     testimony?

18        A.   Yes.

19        Q.   Now, on the 11th of July, you were on duty; isn't that right?

20        A.   Yes.  I was at G1 the morning of the 11th of July.

21        Q.   And G1 is located where, at Crna Rijeka?

22        A.   Yes, that's right.

23        Q.   And you recall specifically on that day you were at a party,

24     right?

25        A.   Yes, I remember that.

Page 28803

 1        Q.   And where was the party exactly?

 2        A.   At a distance of 7 to 8 kilometres from G1 at Crna Rijeka.  This

 3     was a cottage settlement called Hans Pijesak.

 4        Q.   Okay.  And what time did you go to this party?

 5        A.   I can't remember the exact time.  It could have been at some

 6     point between 9.00 and 10.00 that morning.  I drove over in order to set

 7     up the barbecue for everyone else who was coming.  I went there with

 8     Mr. Rajko Petrovic, who was the organiser.

 9        Q.   And on that day when you went to the party, who was on duty in

10     the communications unit?

11        A.   I can't remember exactly who was on duty.  Apart from me, there

12     were other workers there who were in charge of establishing and

13     maintaining communications, telegram communications, telegraph

14     communications.  I believe the man duty that day was Domazet Sekula, who

15     was an employee of the army of Republika Srpska, but I cannot be

16     positive.

17        Q.   Apart from Mr. Sekula, who else would have been on duty that day

18     in the communications unit?

19        A.   There were a number of other people who might have been on duty

20     such as Zarko Tanasic, Nenad Ristic, Blagode Abazovic, Marijan Jerot,

21     Slobodan Mandic, that's about it, roughly speaking.

22        Q.   And I take it that some of these gentlemen, if not all of them,

23     went to the party as well?

24        A.   I don't remember any of them being there.

25        Q.   By the way, what day of the week was this; if you can recall?

Page 28804

 1        A.   It was Tuesday I think, but I'm not positive.

 2        Q.   Now, you said that you recall this day in particular because you

 3     received some information that the army had gone into Srebrenica on that

 4     day, right?

 5        A.   Yes.

 6        Q.   What other information did you receive that day concerning the

 7     army?

 8        A.   Nothing special, not on that day.  We had this barbecue at the

 9     party.  We were simply not really in touch with G1, aside from the fact

10     that someone got in touch with Mr. Petrovic on the phone telling him that

11     the army of Republika Srpska had entered Srebrenica.  There was really

12     nothing special aside from that.

13        Q.   So you don't know anything, or you didn't learn at that time

14     anything about a bombing, a NATO bombing, of VRS positions?

15        A.   No, I don't.  Nothing special really.  I wasn't really following

16     closely, there were operations that were underway all along the front

17     line; and I wasn't showing a special interest.  It's as simple as that.

18        Q.   You say you weren't following closely?  I just want to make sure

19     that I've got that right.

20        A.   Yes, that's right.  I wasn't really following too much whatever

21     was going on.  I was just doing my job and that was that.  I wasn't

22     really following on a regular basis.

23        Q.   Well, your job had to do with conveying messages and orders, et

24     cetera, essentially from the Main Staff to subordinate units, didn't it?

25        A.   Can you please repeat that?  I didn't hear the beginning.

Page 28805

 1        Q.   Your job had to do with conveying messages, orders, from the Main

 2     Staff through the radio lines, didn't it?

 3        A.   No.  My job was to establish and maintain those communications,

 4     and that alone.  Other people were in charge of the actual transmission

 5     of information.

 6        Q.   So you had no idea what information was being conveyed from the

 7     Main Staff down to the subordinate units throughout your period of time

 8     in service; is that right?

 9        A.   That's right.  That wasn't my job.

10        Q.   So as you've testified here rather extensively about the form and

11     the nature and the process of sending telegrams, that's based on

12     something you learned about but not something you actually did as a job

13     during the war, right?

14        A.   As I've pointed out already, I actually completed an encryption

15     course for teleprinters.  I didn't actually do that encrypt or dispatch

16     telegrams, but in principle I knew how this was done and how a telegram

17     like that was properly received; but that wasn't what I was doing at the

18     time.  I was in charge of maintaining radio relay links, keeping them up

19     and running at all times.

20        Q.   So when you were asked a question about whether or not the rules

21     were followed at the Main Staff in relation to the form that telegrams,

22     et cetera, were sent, that's not based on some evaluation that you did of

23     those documents, right?

24        A.   There are rules in the work of an encryption post, how a telegram

25     is dispatched, and that had to be followed.  Whenever one did not follow

Page 28806

 1     the rules, you couldn't call the resulting document a telegram.

 2             JUDGE AGIUS:  All right.  Time for the break, 25 minutes.  Thank

 3     you.

 4                           --- Recess taken at 5.45 p.m.

 5                           --- On resuming at 6.12 p.m.

 6             JUDGE AGIUS:  Yes, Mr. Vanderpuye.

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

 8        Q.   Good afternoon to you, Mr. Pajic.  The last question I asked you

 9     answered had to do with whether or not the rules -- or what your

10     knowledge was concerning the rule as it applied to the transmissions of

11     telegrams, orders, et cetera, from the Main Staff to its subordinate

12     units.

13             And what I asked you was -- or what I want to know, I should say,

14     is you don't have any actual knowledge as to how those documents acts,

15     orders, as it were, were actually transmitted, whether or not they were

16     done -- that was done in accordance with the rules or not in accordance

17     with the rules, because, A, you didn't inspect those transmissions or

18     those documents; and B, that wasn't you line of work during your service;

19     isn't that true?

20        A.   Yes, that's true.  That wasn't my line of work.  Nevertheless, I

21     did attend meetings where certain things were agreed, such as the way

22     documents were sent, and there was the instruction that one should comply

23     with the rules.  The encryption officer would see to that, they said.  As

24     far as the morning reports were concerned, ones that I looked at, I don't

25     remember any problems in terms of the compliance with the rules in as far

Page 28807

 1     as the documents were concerned that were being sent.

 2        Q.   All right.  Thank you for that.

 3             Now, you recall hearing from Rajko Petrovic that Mr. -- I should

 4     say General Miletic was in Belgrade, that was on 11th July, 1995, right?

 5     You have that specific recollection today, right?

 6        A.   Yes.

 7        Q.   You have a specific recollection today that that was a Tuesday,

 8     right?

 9        A.   I think it was a Tuesday, but I can't be positive.  I do think

10     so, though.  I probably didn't check at the time.

11        Q.   You have no recollection today as you're testifying that on that

12     day, the 11th of July, that certain positions were bombed, and in

13     particular, your commander, Mladic, was involved in such a bombing?

14        A.   No.

15        Q.   You have no recollection today about the circumstances that were

16     faced by Chief of Staff Milovanovic on the western front on that day?

17        A.   No, none.  I know that he wasn't at the Main Staff at the time,

18     General Milovanovic; but I don't remember what was going on along the

19     western front at the time.

20        Q.   And you have no recollection today, as you testify, about the

21     circumstances occurring in Trnovo around that time, right?

22        A.   That's right.

23        Q.   Now, being on duty, you went, you said, to set up this barbecue

24     in morning; is that right?

25        A.   Yes.

Page 28808

 1        Q.   And from whom did you obtain permission to go set up this

 2     barbecue?

 3        A.   I obtained permission from the company commander for the garrison

 4     and communications.

 5        Q.   And who is the company commander for the communications unit that

 6     you were in?

 7        A.   At the time, or, rather, as the company commander was not around,

 8     the person standing in for him was Warrant Officer Dragan Nedimovic

 9     [phoen].

10        Q.   And what did you tell your company commander or the person

11     standing in for him, Mr. Nedimovic, what did you tell him in relation to

12     your leaving of your post?

13        A.   Nedimovic, Mr. Nedimovic, warrant officer who was standing in for

14     the company commander -- garrison and communications company commander.

15     I told him that I had been invited by Rajko Petrovic to help him organise

16     the barbecue and that I would be on the way to give him a hand, and he

17     okayed that.

18        Q.   And when were you invited, by the way, to this barbecue by

19     Mr. Petrovic?

20        A.   In principle we had agreed several days, but he called me the

21     night before we were supposed to organise this barbecue, and we agreed on

22     a time and place.

23        Q.   And how many people attended this barbecue?

24        A.   As I said, I don't remember exactly how many people were there,

25     but I reckon between 15 and 20 people; but I can't be positive.  Probably

Page 28809

 1     about 15.

 2        Q.   And when did it occur?

 3        A.   11th of July, 1995.  I got there between 10.00 a.m. and 11.00

 4     a.m. along with Rajko.  We set the whom thing up, we grilled the meat, we

 5     set up the tables and benches, and then at about 2.00 or 3.00 p.m., the

 6     others got there as well once the whole thing had been sets up.

 7        Q.   Did this occur at his house or at some other location?

 8        A.   It was next to a house that he was renting at the time, where he

 9     was living with his family.

10        Q.   Now, today is not the first day that you've spoken about this

11     party and the information that you heard from Mr. Petrovic regarding

12     General Miletic's whereabouts, is it?

13        A.   That's right.

14        Q.   I take it you've spoken to the Defence about this particular

15     occasion?

16        A.   Yes.

17        Q.   When was the first time that you mentioned to the Defence of

18     General Miletic the circumstances surrounding this party as you've

19     indicated here today?

20        A.   On the 3rd of October, this year.

21        Q.   And have you discussed it with them since?

22        A.   Yes, I have.

23        Q.   When did that occur?

24        A.   The 3rd of October, that afternoon, at Rogatica.  I spoke to

25     Counsel Petrusic, I discussed this with him.  The reason being, quite

Page 28810

 1     simply, eventually I ended up asking myself why are they accusing this

 2     man if, for example, I remember the 11th, the 11th being etched in my

 3     mind because of what happened with the army of Republika Srpska and

 4     during Srebrenica.  I know that he was not at the Main Staff that day.  I

 5     don't know when he went away or when he returned, but I know he wasn't

 6     there on the day.  And I can state that with certainty, he was not at the

 7     Main Staff that day.

 8        Q.   All right.  Maybe there was an error in the translation, but I

 9     asked you if you had spoken to the Defence since the 3rd of October; that

10     is, between the 3rd of October and today, and is your answer "yes"?

11        A.   Yes, I talked to them about it on the 3rd and when I got here.

12        Q.   And in relation to your discussions with the Defence, did you

13     come to learn of another party that occurred at some other time in

14     relation to the whereabouts of Mr. -- or General Miletic?

15        A.   I don't remember the other party.  I certainly wasn't there, so I

16     never discussed that.

17        Q.   You never discussed with the Defence anything about

18     General Miletic's whereabouts other than on the 11th of July, 1995,

19     right?

20        A.   That's right.  We had met on the 23rd of August that same year.

21     I think Counsel Petrusic drew a diagram or rather we drew a diagram

22     together of the underground facility, and I knew at the time that

23     General Miletic was in the detention unit already.

24        Q.   Sorry, did you say the 23rd of August?  Because that's what's

25     recorded in the record here.

Page 28811

 1        A.   On or about the 23rd, I think so.  I'm afraid I can't be more

 2     specific, but the 23rd of August, and he was in detention.

 3        Q.   And would that be the first time that you met with the defence

 4     concerning General Miletic or was there yet another occasion?

 5        A.   A total of three meetings.  There was another one before that one

 6     which occurred sometime in January or February that same year.  I can't

 7     remember the date for our first meeting or the time, but we met a total

 8     of three times.

 9        Q.   When you say, "January and February of that same year," you mean

10     this year, 2008?  So --

11        A.   Yes.

12        Q.   So I would be correct then in saying that you met with them in

13     January or February of 2008, and then again in August of 2008, and then

14     again in October of 2008, and then again now, or recently, of November

15     2008; is that right?

16        A.   I can't be specific about the first meeting.  I know that it was

17     winter time.  It might have been December the previous year, I know it

18     was winter time, was it December, the previous year, January or February

19     this year; now that's something I can't confirm for you.  As for the

20     other meetings that took place I told you already what the timeline would

21     be for those.

22        Q.   All right.  Thank you for that.  So from your testimony I gather

23     you did not mention to them anything about General Miletic being away for

24     the command when you met with them in January or February and when you

25     met with them again in August?

Page 28812

 1        A.   That's right.  I mentioned nothing until the 3rd of October.  The

 2     previous meetings were mostly about communications documents and how the

 3     communications system was organised.  Eventually, I asked what all of

 4     this was about, because I knew for a fact that the man was not there on

 5     that day date, on the 11th, he wasn't at the Main Staff.  So eventually I

 6     raised the question on the 3rd of October.

 7        Q.   How did it become a matter of importance to you where he was on

 8     the 11th of July suddenly in October of 2008?

 9        A.   It didn't suddenly become important, I simply remembered the

10     period, and I asked myself why, in view of the duties he had, and the

11     fact that I knew that he wasn't there on that day, I simply remembered

12     that date.  I don't know how to explain this to you, but it was a date

13     that stuck in my memory.

14        Q.   And you drew a diagram, you said?  When you drew the diagram

15     representing how things we are laid out, was that anchored to any

16     particular period of time such as July of 1995 or the summer of 1995?  I

17     think it was 5D1395.

18        A.   Yes, I made the diagram in August after the second meeting, and

19     it's a sketch of the underground part of the facility, the way it was;

20     and that was how the premises were laid out throughout.  Sometimes the

21     communication devices would and the staff would move from the

22     above-ground facility to the underground facility, but this diagram

23     applied to the underground part of the G1 facility.

24             JUDGE AGIUS:  Yes, Mr. Petrusic.

25             MR. PETRUSIC: [Interpretation] Mr. President, I think that the

Page 28813

 1     witness and the Prosecutor are talking about the same sketch, and I would

 2     like to give this diagram to the witness so as to remove any

 3     misunderstandings.  It is the same diagram that was shown today, only in

 4     a different format.

 5             JUDGE AGIUS:  Yes, Mr. Vanderpuye.  Thank you, Mr. Petrusic.

 6             MR. VANDERPUYE:  I have no objection to it.  I haven't seen that

 7     particular diagram, but I would like to.

 8             JUDGE AGIUS:  Yes, will you make it available then, Mr. Petrusic,

 9     please.

10             MR. PETRUSIC: [Interpretation] Gladly.

11             JUDGE AGIUS:  Madam Usher, please.  Have him put it on the ELMO,

12     please.

13             All right.  Let's proceed.

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

15        Q.   This is the diagram that you say that you drew in August of this

16     year?

17        A.   Yes, that is the diagram, but I forgot to indicate a room between

18     the operations centre and here where the chief of departments were.  I

19     didn't draw it on that occasion.  I just left out this one room when I

20     drew it then.

21        Q.   All right.  Well --

22        A.   So there is one additional room to those drawn here, which I had

23     forgotten at the time because of a certain accident I had, and I forgot

24     all these things.

25        Q.   All right.  Well, your recollection, I take it, then, on 19th

Page 28814

 1     November was better than it was back in August when you drew this, right?

 2     19th of November, just so you know, was the date that's written on the

 3     document that's in evidence, it's 5D1395.  Is that fair to say?

 4        A.   Yes, that's right.

 5        Q.   And you've got me at a bit of a disadvantage here because

 6     unfortunately I can't read what's written here, but the point is when you

 7     drew this diagram, that is the one that's on the ELMO now, in August of

 8     2008, was this intended to reflect the way these rooms were laid out in

 9     July of 1995?  In other words, was that brought to your attention at that

10     time?

11        A.   Yes, that is how it was in July 1995.

12        Q.   And that was what this was intended to reflect, right?

13        A.   Yes.

14        Q.   When you met with the Defence in January or February of 2008, it

15     was also brought to your attention that the events that they were

16     concerned about, with respect to communications or radio relay devices,

17     had to do with July of 1995.  They made that clear to you, didn't they?

18        A.   Yes.

19        Q.   You know somebody by the name of Vojislav Babic?

20        A.   I do know Vojislav Babic.  In 1995, he was chief of staff of the

21     67th Communications Regiment.

22        Q.   And did you ever discuss Vojislav Babic in any respect with the

23     Defence before your testimony here today?

24        A.   No, no I didn't discuss Vojislav Babic.  I just knew that he was

25     due to come here to testify, but nothing more than that.

Page 28815

 1        Q.   Did you ever tell the Defence that in relation to Mr. Babic --

 2     did you ever tell the Defence or explain to the Defence that the barbecue

 3     that you attended had nothing to do with Mr. Babic's birthday which

 4     related to a party or an event that occurred on 7 July 1995?  Did you

 5     ever tell them about that or did they ever discuss that with you?

 6        A.   No, they didn't discuss that with me at all, and I am not aware

 7     of that party yet.

 8        Q.   All right.  All right.  Mr. Pajic, I just want to acquaint you

 9     with something that I received from the Defence, and it talks about this

10     party on the 7th.  And in part, and I will offer that later on.  It says:

11             "Mr. Babic spoke about his birthday party and the Witness Pajic

12     explained today, 16 November, that the barbecue had nothing to do with

13     Mr. Babic's birthday.  So it seems that these were two separate

14     occasions, one on the 7th and one on the 11th."

15             Did you explain to the Defence that the barbecue that you went to

16     had nothing to do with Mr. Babic's birthday, did you have that discussion

17     at all?

18        A.   No, we didn't discuss that.  I just know that Babic did not

19     attend this barbecue on the 11th of July 1995.  I don't know when Babic's

20     birthday is, and I was not aware of that party.

21        Q.   All right.  And just so that I am clear, you never had that

22     discussion at all in any of your meetings with the Defence; that is,

23     either in January or February or August or October or November of 2008?

24        A.   [No interpretation]

25        Q.   All right.  Thank you for that, sir.  Now, you testified some

Page 28816

 1     about the organisation of the communications network, if you will, as

 2     regards the Main Staff.  And in order for the Main Staff to communicate

 3     with subordinate units, you said that this could transpire over a secure

 4     line; is that right?

 5        A.   Yes.

 6        Q.   When you say "subordinate units" you mean corps and brigades and

 7     battalions and so forth, right?

 8        A.   The Main Staff had organised communications only with the corps.

 9     The units attached to staffs, the army of Yugoslavia, the presidency, the

10     government, and the Assembly of Republika Srpska, those were the main

11     lines of communication; whereas, the corps organised communications with

12     their subordinate unit, brigades, and others.

13        Q.   And in terms of the organisation of the communications of the

14     corps, the Main Staff would be apprised of that, right?

15        A.   Yes.

16        Q.   That way if you needed to reach somebody within a brigade you

17     knew how to do it from the Main Staff, right?

18        A.   Yes.

19        Q.   And the way you would communicate in -- from the Main Staff to

20     the corps would be through a wire line from Crna Rijeka to Veliki Zep and

21     over a radio, radio relay, from Veliki Zep to whatever subordinate unit

22     you try and reach, right?

23        A.   Yes, that was how it was except for the Sarajevo-Romanija Corps

24     where we had alternatives between relay and wire lines.  Though we

25     combined the communications because it was not possible to organise radio

Page 28817

 1     relay connection with this corps, part of the route was covered by wire

 2     connections.

 3        Q.   In terms of the security of the communications, for example, from

 4     the Main Staff to the Drina Corps, that is for voice communications,

 5     those were protected in so far as their transmission from the Main Staff

 6     to Veliki Zep; isn't that true?

 7        A.   That is correct.  There were two relay directions between

 8     Veliki Zep and the Drina Corps.  One was protected and the other one was

 9     unprotected.

10        Q.   Do you recall specifically what those lines were?

11        A.   I do.  The protected line was 0674, that is, the number it had in

12     1992; and in 1993 it was 0658.  And the other is 07 -- sorry 0607, that

13     was the analogous line.  0674 was protected up to a certain point of

14     time, and then it was 0658, and the analogous one was 0607.  In this one

15     FM200 was operational because it is the only one that can be operational

16     under a regime of protection; whereas, for the other it was not possible

17     to protect it, to secure it.

18        Q.   And just so we know, the FM200 is a device that's similar to an

19     RRU800, right?  It operates within the same range -- same frequency

20     range, right?

21        A.   Well, they are not similar, but they do use the same frequency

22     range.

23        Q.   Well, if I could I'd like to show you --

24             MR. VANDERPUYE:  -- 65 ter 2893.  Sorry, my fault, 2823.

25        Q.   What I am showing you is the -- essentially what is a frequency

Page 28818

 1     plan.  It's a Drina Corps document.  It's dated 2 October 1993, and it

 2     sets out radio relay routes.

 3             If you look at item number 2 at the bottom of -- well, it's in

 4     the middle of the page in your language, and it's the bottom of page 1 in

 5     the English.  It sets out command of the Drina Corps, this is the radio

 6     relay direction versus -- towards Veliki Zep, do you see that?  It says

 7     radio relay Bravac RRPR, number 0607, right?

 8        A.   Yes, that's the radio relay route, 0607, that I mentioned just a

 9     minute ago.

10        Q.   And there is another radio relay route 0674 that you indicated,

11     right?

12        A.   Yes, 0604, I said that the number was subsequently changed, and

13     it became 0658 around 1993.

14        Q.   0658 changed -- it was changed in 1993?  Is that right or did it

15     change to that in 1993?

16        A.   In 1993, it was changed into 0658.

17        Q.   So this document, October 2nd, 1993, doesn't reflect the correct

18     relay route numbers as they existed in 1993, right?

19        A.   Well, that was probably changed towards the end of the year.  I

20     know that it was in 1993 that we would usually change the route number.

21     So only the route number was changed, but the links themselves were not

22     affected.  Everything remained the same.

23        Q.   What about the frequencies, did they change, or did they stay the

24     same, too?

25        A.   No, the frequencies weren't changed.  They remained the same.  We

Page 28819

 1     only changed the route number for the document, but as far as the

 2     frequencies are concerned, everything remained the same.

 3        Q.   Okay.  Have you seen this document before by the way?

 4        A.   You're asking whether I've seen this document before?

 5        Q.   That's what I'm asking.

 6        A.   I'm -- never had the opportunity of seeing it before because it's

 7     a telegram from the Drina Corps, and they only informed us about the

 8     frequencies of their devices since the chief of communications of the

 9     Main Staff gave his authorisation for the frequencies and for changes

10     frequencies.  I'm familiar with this document when it came to the Main

11     Staff because the chief of communications of all the corps asked for an

12     overview of the frequencies at radio relay stations, of the situation at

13     radio relay stations.

14        Q.   Who sets the frequencies that are on these radio relay paths?

15        A.   At the hubs, at all the hubs of the Republika Srpska army, the

16     frequency plan was adopted by the chief of the communications of the Main

17     Staff of the Republika Srpska army, and at the radio relay hubs that

18     belong to the army of Republika Srpska, Tvren [phoen], Strazbenice, well,

19     it was the chief of communications of the army of Yugoslav Army who

20     authorised these frequencies.  We couldn't the change the frequencies at

21     Strazbenice and at Cer without the authorisation of the chief of

22     communications of the army of Yugoslavia, naturally of the request of the

23     chief of communications of the Main Staff of the army of Republika

24     Srpska.

25             So the communications at the hubs of the army was Republika

Page 28820

 1     Srpska were authorised by the chief in the Main Staff.

 2        Q.   And the chief in the Main Staff would be somebody by the name of

 3     Prole, chief of communications?

 4        A.   The chief of communications of the Main Staff of the army of

 5     Republika Srpska was Colonel Radomir Prole.

 6        Q.   Prole, PR; is that right?

 7        A.   Prole, P-R-O-L-E.

 8        Q.   And when you talk about the ability to change the frequencies,

 9     what about the hubs that were in the territory of the RS, what about

10     those?

11        A.   Well, as I said, those frequencies could only be changed at the

12     order of the chief of communications of the Main Staff of the Republika

13     Srpska army.  There was some kind of an annual plan; however, there were

14     divergencies.  So as of 1993 up until 1995, well, I don't remember having

15     ever changed those frequencies during that time-period, because the hubs

16     that we mostly used at Strazbenice and Cer, well the frequency plan had

17     to be authorised by the chief of communications of the communications

18 administration of the army of Yugoslavia; so we didn't change the frequencies

19  that often. It wasn't done annually. I know that in 1992, 1993, these

20  frequencies weren't changed and that was the case until the end of war. If

21  necessary, if there were any disturbances one would go one or two megahertz

22     up or down, during the disturbance, and then go back to the same one.

23        Q.   So as far as you're aware, the frequencies that were used to

24     communicate, for example, from the Main Staff through to, say, Zvornik,

25     those frequencies never changed throughout the war in your experience,

Page 28821

 1     right?

 2        A.   No.

 3        Q.   And I take it you're shocked to hear that communications along

 4     those lines were intercepted?  Is that news to you, sir?

 5        A.   Well, I didn't have any information about that.  In a way, yes,

 6     but it's technically possible to intercept such communications.

 7        Q.   You were in charge of maintaining the communication lines, radio

 8     relay lines, and you're telling us here today that you have no

 9     information throughout the entire war that those lines were being

10     intercepted by your enemy?  Is that what you're trying to say?

11        A.   Well, I didn't have any concrete information.  I didn't have any

12     documents showing that such and such a route at such and such a time was

13     intercepted.  I didn't have such information; although, I received

14     unofficial information according to which certain communication routes

15     were being intercepted.  This had to do with the RRU1 exclusively, the

16     RRU1 device exclusively.  I knew about that so I insisted on using a

17     device for cryptographic protection.  I am talking about the RRU1 device,

18     which could be intercepted or, rather, it was more easy to intercept this

19     device than it was to intercept other devices that used higher

20     frequencies.

21             MR. VANDERPUYE:  Mr. President, I think it might be a good time

22     to break with your permission, otherwise I could certainly fill it up

23     until 7.00 on the dot, if you prefer.

24             JUDGE AGIUS:  Go a little bit more.

25             MR. VANDERPUYE:  Okay.  Thank you, Mr. President.

Page 28822

 1             Could I have 2821, please, in e-court.  And if we could go to the

 2     next page.  It's under subheading number 5.  I think it's page 2 in the

 3     English.

 4             JUDGE AGIUS:  This is taking too long.  Let's leave it.  Let's

 5     leave it.

 6             We'll continue tomorrow as the same time as today, 2.15 in the

 7     afternoon.

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

 9                           --- Whereupon the hearing adjourned at

10                           6.59 p.m., to be reconvened on Wednesday, the

11                           26th day of November, 2008, at 2.15 p.m.