Tribunal Criminal Tribunal for the Former Yugoslavia

Page 28823

 1                           Wednesday, 26 November 2008

 2                           [Open session]

 3                           [The accused entered court]

 4                           [The witness entered court]

 5                           --- Upon commencing at 2.20 p.m.

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

 7     the case, please.

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

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

10             JUDGE AGIUS:  Thank you, ma'am.  All the accused are present bar

11     Pandurevic who sent his waiver.  Prosecution today is Mr. McCloskey,

12     Mr. Vanderpuye.  Defence teams absentees are Mr. Ostojic, Mr. Bourgon,

13     and Mr. Haynes.  The witness is already here, so we can start.

14             Between yesterday and today, were you approached by anyone or did

15     you have any contact with anyone to discuss the subject matter of your

16     testimony?

17             THE WITNESS: [Interpretation] No, no contact at all.

18             JUDGE AGIUS:  Thank you.

19             THE WITNESS: [Interpretation] I didn't discuss the case with

20     anyone.

21             JUDGE AGIUS:  Thank you.  Mr. Vanderpuye.

22             MR. VANDERPUYE:  Thank you, Mr. President.  Good afternoon to

23     you, Your Honours, and good afternoon to my colleagues.

24                           WITNESS: VELO PAJIC [Resumed]

25                           [Witness answered through interpretation]

Page 28824

 1                           Cross-examination by Mr. Vanderpuye: [Continued]

 2        Q.   And good afternoon to you, Mr. Pajic.  Yesterday when I left off,

 3     I was in the process of showing you a document.

 4             MR. VANDERPUYE:  It's 65 ter 2821.

 5        Q.   And that was in relation to your answer to a question that I put

 6     to you, which was:  Whether or not you were shocked to hear that

 7     communications, along those lines, meaning the radio relay lines, had

 8     been intercepted.  You indicated that you had not gained any information

 9     about that.

10        A.   That's right.

11        Q.   What I wanted to show you was a communications plan that was

12     prepared in connection with an Operation Stit which is signed by NATO

13     Blagojevic, who is the chief of communications for the Drina Corps and

14     Svetozar Andric, who was the Chief of Staff of the Drina Corps at the

15     time.

16             MR. VANDERPUYE:  And if I could take you to point number 5 at

17     this, which is at the bottom of the page I believe in your language, and

18     on the second page in the English.

19        Q.   And at point 2 under number 5 you can see that it reads:

20             "Anti-electronic protection:  The enemy are in a position to

21     monitor and jam our command and control communications.  In planning and

22     using communications make certain that besides prescribed tactical and

23     technical measures for protection, general and special documents for

24     cryptographic protection are used."

25             Now, did you receive any information concerning this particular

Page 28825

 1     issue at any time during your service in the war?

 2        A.   I had no information about this document.

 3        Q.   Well, I am asking you in particular about what this document

 4     discusses, which is the ability of the enemy to monitor communications.

 5        A.   As I pointed out yesterday, it was impossible to intercept secure

 6     communication lines.  Those that were channeled through the encryption

 7     post.  On protected lines of communication that were transmitted by a

 8     lower frequency, such as RR1 were possible to intercept.  Specifically, I

 9     don't have any information indicating that any of the lines be channeled

10     through the encryption post were, in fact, at any point intercepted.

11        Q.   Okay, what about the lines that were not being channeled through

12     the encryption or were not encrypted, did you have any information that

13     those lines were being intercepted?

14        A.   No, that type of information was never conveyed to me.  If

15     anyone, the security bodies might have been in possession of such

16     information.  They might have told the head of the signals unit.  I, for

17     one, was never told that.  Had that not been the case, we would have

18     requested for our frequencies to be altered or perhaps we would have

19     sought alternative channels for our communication.  To sum it up, I had

20     no information indicating that any of our lines of communication were

21     intercepted or tapped.

22             MR. VANDERPUYE:  Let me show you 65 ter 3425.

23        Q.   In particular let me draw your attention to the first paragraph

24     of the document, and it's a document that's dated 22nd April, 1993, and

25     it indicates that it's signed by one Lieutenant Drago Nikolic.  And in

Page 28826

 1     the first paragraph, second sentence it reads:

 2             "We have confirmation that the enemy is intensively intercepting

 3     our radio and radio relay communications, particularly active are their

 4     interception centres in Tuzla and in Trovrh (Gorazde)."

 5             Did you become aware of any information that's contained in this

 6     particular document?  Not so much the document itself but the information

 7     that I've just read to you?

 8        A.   I am not familiar with this document.  I haven't seen it before.

 9     I did however know that the enemy did have interception centres at Trovrh

10     and in the general Tuzla sector.  Did I know about that.

11        Q.   You had no information about the fact that they had the capacity

12     to intercept VRS communications along radio and radio relay lines.

13     That's your testimony, right?

14        A.   That's right, I had no information.  However, let me say this

15     again.  Radio relay lines that were transmitted over lower frequencies

16     and those that were not protected or insecure could be intercepted, but I

17     had no idea what technology they were using and what the frequency ranges

18     were being used by them from the Trovrh and the Tuzla sector.

19        Q.   All right.

20             MR. VANDERPUYE:  Let me show you 65 ter 3D00319.

21             THE INTERPRETER:  The interpreters would like Mr. Vanderpuye to

22     speak more directly into the microphone.  It's difficult to hear.  Thank

23     you very much.

24             MR. VANDERPUYE:  I've heard that, and I'll comply.

25             JUDGE AGIUS:  Thank you, Mr. Vanderpuye.

Page 28827

 1             MR. VANDERPUYE:

 2        Q.   This is a document that is dated 23rd June, 1995, and it's

 3     type-signed by Lieutenant-Colonel Vujadin Popovic.  In particular, this

 4     document reads, in the first paragraph anyway:

 5             "Through reconnaissance on the enemy's radio communication and

 6     information transmitted via radio, we have obtained information that our

 7     units are extremely careless when using communications equipment and do

 8     not verify the cryptographic data protection value of communications

 9     equipment ..."

10             And it goes on:

11             "Take all measures to ensure that these devices are not used to

12     send documents classified confidential and higher, for they offer

13     practically no protection of confidentiality."

14             Now, it talks about different kinds of equipment that can be used

15     to protect data and to send information that's less urgent because of the

16     danger of that information falling into the wrong hands.  Were you aware

17     of information of this information?  Not so much the document, but the

18     information as concerns encrypted data protection?

19        A.   I can't think of a specific example.  Nevertheless, I must point

20     out again that such telegrams, as were processed through the encrypted

21     teleprinter station could not be intercepted or listened in.  As for

22     ROG12 and RRU1, those radio devices in particular, as long as they

23     weren't secured, could be intercepted; and I believe I pointed this out

24     on a number of occasions already.

25             Even being unaware of this particular warning, I knew that this

Page 28828

 1     type of device, RUP12, RUP1, RUP33, RRU1 and other devices could be

 2     intercepted, but whenever a telegram was processed through a coded or

 3     encrypted teleprinter post, KZUS31, now that could not be intercepted.

 4        Q.   So you don't disagree with what's actually in this document that

 5     you've just read, do you?

 6        A.   I agree as far as the open systems were concerned, meaning the

 7     devices that I've just enumerated, but whenever telegrams were coded,

 8     they could not be intercepted.

 9        Q.   When Lieutenant-Colonel Popovic talks about verifying

10     cryptographic data protection, he's not talking about open lines, is he?

11     If you don't know what he's talking about, just let us know as well.

12        A.   I don't know what lieutenant-colonel, which I think was his rank

13     at the time, meant exactly.  I completed a certain kind of training, then

14     it wasn't possible for me to imagine that the enemy, given the equipment

15     they were using, could possibly intercept our communication.  I did not

16     know, however, what the General based his assumption or suspicion on.

17        Q.   All right.  Well, thank you for that, Mr. Pajic.  I think the

18     document speaks for itself.  But in terms of the actual process of

19     encrypting or data protection along a radio relay route, how did that

20     process actually occur?  Was it automatic, did a person have to actually

21     engage it?  Tell us how that works.

22        A.   For example, if there was a hidden telegram that the -- had

23     reached the teleprinter post -- are you asking me about protected written

24     information or encrypted speech?

25        Q.   Encrypted speech, encrypted speech.  That's what I'm asking you

Page 28829

 1     about.

 2        A.   All right.  Our device that I used to encrypt speech,

 3     cryptographic protection devices, KZU71, for example, if there was an

 4     open line, an open telephone line, it went into this device with a

 5     carrier waive, KZU71; it would get demodulated there and transformed into

 6     a code.

 7             Such a modulated signal would then go into 690 to 96 -- 610 to

 8     960 megahertz, and then we had a carrier waive that we were using this

 9     device we could head a tone, but we couldn't hear the actual

10     conversation.  It was only the tone that carried.  And then having

11     reached the other end of the line, it would get demodulated and then

12     there was a device with a certain frequency that would decode this speech

13     and transform it back into an open signal.

14             Such an encrypted conversation could be listened to by wire,

15     KZU71 for example, and then when it reached the other end and came out of

16     the KZU1, and then as along as it took to reach the actual phone.  So

17     that was the section in which you could actually hear the conversation.

18     Everything aside from that was just an indistinct tone, not an actual

19     communication conversation.

20        Q.   All right.  And does that mean that the device had to be

21     activated in order for -- does that mean that the device would have had

22     to have been activated before the transmission occurs and some period of

23     time allowed before the actual conversation is transmitted or does it

24     mean that it could be operated instantaneously.

25        A.   The device were operating on a permanent basis.  It's not this

Page 28830

 1     was suddenly activated.  They kept it operating throughout.

 2        Q.   Okay.  And as far as you're aware, in the radio route, let's call

 3     it from Vlasenica through Zvornik, that is Vlasenica to Veliki Zep,

 4     Veliki Zep to Cer, to Gucevo to Zvornik, and also down to Han Pijesak and

 5     Crna Rijeka.  Your understanding is that there was a protected route from

 6     Crna Rijeka to Vlasenica; that's the Drina Corps command, right?  You

 7     mentioned yesterday about two routes, 0674 and 0607; do you recall that?

 8        A.   Yes, but before that let me tell you that the relay route between

 9     Vlasenica and Zvornik did not exist at all.  There was none there between

10     Veliki Zep and the command of the Drina Corps there were the two routes

11     that I specified yesterday, and you have now brought up, one was the

12     secure 0674 and there was one that was not protected in any way and that

13     was the 0607 route.

14        Q.   Well, you say there is no route between Vlasenica and Zvornik,

15     you mean there is not a direct route, right?  Because there is a way to

16     communicate through the radio relay system between those two points,

17     isn't there?

18        A.   Yes, I'm talking about a direct route.  There was no direct radio

19     relay route between Vlasenica and Zvornik.  There were other kinds of

20     communication that we used and other relay routes through Veliki Zep,

21     Cer, Rogatica, and Zvornik.  Those were the points along the route that

22     was used to convey, both spoken and written information between the Drina

23     Corps and the Zvornik Brigade.

24        Q.   And those operators were with RR800 devices as you indicated,

25     right, and FM200 devices?

Page 28831

 1        A.   Yes, they were using RR800 between Cera and Gucevo, again RR800

 2     between Gucevo and Zvornik, between Veliki Zep and Seren Kojista [phoen],

 3     SMC1306B; and as far as Vlasenica there were two routes, 0674 was M200

 4     and 0607 was RR800.

 5        Q.   And with respect to those routes, that is the route from Gucevo

 6     to Zvornik, that wasn't necessarily a protected route, was it?

 7        A.   That's right.

 8        Q.   And the route from Veliki Zep to Cer, that was the SMC device

 9     that you talked about, there was also an RRU800 back-up device on that

10     line; isn't that true?

11        A.   That's right, those were two routes, 1058 through the SMC that

12     was operating; 0719 secure through the FM200 that was operating and the

13     alternative route that was there; BB no number, RRU800 operating.  This

14     route was activated when the SMC was damaged during an air raid bombing

15     in early September 1995.

16        Q.   And with respect to that bombing, by the way, were the

17     frequencies changed after that?

18        A.   No.

19        Q.   Now, yesterday, when you mentioned that there was an annual plan

20     with respect to these frequencies, what did you mean by that?

21        A.   Well, under the rules governing work at radio relay facilities,

22     I'm telling you what was envisage, what the plan was, and not what was

23     actually done.  The annual plan provided for the annual frequency plan to

24     be altered at some point; however, I told you yesterday why this didn't

25     happen so the frequencies were not changed at any point between 1993 and

Page 28832

 1     1995 -- or after 1995 for that matter.  Therefore, given the fact that

 2     the frequency plan was changed within the army of Republika Srpska - and

 3     this was something that was ordered by the head of signals of the army of

 4     Republika Srpska - given the fact that Cer and Strazbenice were within

 5     the area of responsibility of the Yugoslav Army and the head of signals

 6     of the Yugoslav Army had to give this particular order, this would have

 7     implied a very complicated procedure; and we wanted to find a way around

 8     that and that was the simple reason why we never changed the frequencies.

 9        Q.   You changed the radio paths, right?  You changed the numbers for

10     the paths, right?  0658, that's what you said yesterday.

11        A.   Yes, yes, that was the one route where this was changed because

12     of the documents there, because this route cropped up twice so we had to

13     change it.  The number, the number of the route was changed, but not the

14     frequencies, not the devices that were used, or the distribution of

15     channels, nothing else.

16        Q.   What was the purpose of changing the number of the route if

17     nothing else was changed, if you know?

18        A.   Well, quite simply we wanted to have the same numbers for the

19     secure lines and the non-encrypted lines, non-protected lines, the chief

20     of signals took that decision, but it wasn't about changing the

21     frequencies or the distribution of channels.  They were simply the number

22     for this particular route that was changed.  They were just about

23     bringing our documents up to date on the secure lines and the numbers

24     that we were using to talk to the corps, and then 00674 and 0658, those

25     were two that were changed, and that was the extent of it.  It wasn't

Page 28833

 1     about security-related reasons or anything like that.

 2        Q.   Maybe there was a mistranslation in my question, but what was the

 3     purpose of changing the route number if nothing else changed?  What did

 4     that accomplish, is my question.

 5        A.   Well, one number was in Strazbenica and that was the same number

 6     used for a different feature.  So we have the same number for two

 7     different features and that's why we changed that in order to avoid using

 8     the same number for two different routes and thus avoid confusion.

 9        Q.   And what number was that and how long were they the same?  Maybe

10     I will ask them separately.  Let's start with what number was that?

11        A.   0658.

12        Q.   And that was the same for which routes?

13        A.   That's Strazbenice, which was another feature, they had a route

14     to a brigade in Visegrad.

15        Q.   How long were these two numbers the same, that you're aware of,

16     before they were changed?

17        A.   I don't know exactly how long.

18        Q.   You're in charge of maintaining these lines, right?  That's why

19     you are able to tell us the route numbers, you're able to tell us the

20     devices, you're able to tell us what was implemented when and why.

21     You're now telling us that you had a situation where you had two numbers

22     that were identical for completely different routes, and you don't know

23     for what period of time that existed?

24        A.   No.  I'm telling you that this was a route from a different relay

25     feature.  It wasn't within my area of responsibility.  It was the army of

Page 28834

 1     Yugoslavia, the Strazbenice feature, it was their route.

 2             And then in order to not have the same number for one of their

 3     routes and one of ours, they asked that we change the number, and that

 4     was the reason.  It wasn't my area of responsibility.  I wasn't in charge

 5     of maintaining those devices therein that equipment, the equipment they

 6     were using.  Strazbenice belonged to the army of Yugoslavia, that being

 7     the reason I can hardly say exactly when this happened or how long it had

 8     gone on for.  The route was not at Veliki Zep.  It was a different

 9     feature, and then we got a warning from them to the effect that we should

10     change the number for our route because they were using the same number

11     for one of theirs.  We just wanted to avoid possible overlaps and that

12     was it.

13        Q.   Already.  So you have no idea how long this condition existed

14     where you shared the same route number with -- you shared the same route

15     number with Yugoslavia?

16        A.   That's right.  I didn't know that.

17        Q.   No idea?

18        A.   None at all.

19        Q.   And when did you get the warning to change it?

20        A.   It wasn't me.  It was the chief of signals, and he had been

21     cautioned by the chief of signals of the army of Yugoslavia and then my

22     chief of signals said, The number for this route shall change tomorrow.

23     As of tomorrow we are using this new one.  It was the chief of signals

24     who had conveyed that order to me.  It wasn't me who took a decision on

25     that particular change, nor did I get my information directly from the

Page 28835

 1     chief of signals from the army of Yugoslavia.

 2        Q.   Okay.  And when did that occur?  When were you told by your

 3     boss --

 4        A.   Sometime in December.  Sometime late that year 1995, probably

 5     December; but that's about as specific as I can be.  It has been a long

 6     time, after all.  It's been 13 or 14 years.

 7        Q.   1995 or 1993.

 8        A.   1993.  I'm sorry, December 1993.  I do apologise.

 9        Q.   This change that occurred, I just want to confirm for the record,

10     was the result of an order from the Yugoslav Army to the VRS to change

11     that route number; is that right?

12        A.   Yes.

13        Q.   All right.  Now, I showed you yesterday a document that was 2823.

14     And I don't think we need to put it in e-court, but as you testified to

15     it yesterday, this was the October 2nd 1993 document.  It was a Drina

16     Corps document laying out a number of radio relay routes in corresponding

17     frequencies and paths.  You recall seeing that document yesterday?

18        A.   You are referring to a document of the Drina Corps?

19        Q.   Yes, I am.  I showed it to you yesterday.  If you don't recall I

20     can put it up on the screen so you can see it again.

21        A.   Yes, I remember, if you're referring to the one that mentioned

22     frequencies.

23        Q.   I am.  Now, having read that document or having looked at it

24     yesterday, did you see any indication on it as to protected frequencies

25     or protected routes in relation to 0674, 0607 routes as you've described

Page 28836

 1     today?

 2             JUDGE AGIUS:  Yes, Mr. Zivanovic.

 3             MR. ZIVANOVIC:  Sorry, may we see this document on the screen?

 4             JUDGE AGIUS:  Yes, Mr. Vanderpuye.

 5             MR. VANDERPUYE:  I was just trying to save time but it's no

 6     problem.  It's 2823.  If we could have that in e-court, please.

 7             THE WITNESS: [Interpretation] We can see which protected routes

 8     are mentioned.  There is an error, MD310, so it is -- it should be MD310,

 9     AMD, because the device to protect speech was an AMD310 and two channels

10     are used, 8 and 32.  So the name of the device tells us that it is a

11     protected route; whereas, a 12K could not be protected.

12        Q.   And what is the AMD320?

13        A.   310.  Not 320.  It's a mistake.  There was no such device with

14     the number 320 in 1995.

15        Q.   What about 1993?  Because that's when this document is dated.

16        A.   No, no.

17        Q.   That didn't exist?

18        A.   No.  It didn't exist.  AMD310 existed, let me tell you once

19     again.  Its capacity was 32 channels, between 8 and 32 depending on the

20     requirements.

21        Q.   And that would run on path 0674, right?

22        A.   Yes, on the path 0674, between Veliki Zep and the command of the

23     Drina Corps.

24        Q.   That's right.  And from Veliki Zep to the command of the main --

25     of the VRS, I should say, the Main Staff?  How does that signal get

Page 28837

 1     carried?

 2        A.   By an underground cable.

 3        Q.   And it has different radio -- it has a different radio path

 4     number, right?

 5        A.   No.  Every channel has two wires, and from the distributor at

 6     Veliki Zep it would be led to facility G1.  So this was not a route

 7     number.  A cable was used from Veliki Zep with eight pairs until the

 8     distributor in the room that we saw when we looked at the diagram of the

 9     facility.

10        Q.   All right.  Let's go down.  You can see at point number 2, 0607?

11        A.   Yes, I see that.

12        Q.   Is that a protected line?

13        A.   No, it is not a protected line.

14        Q.   Let's go to point number 4.  That one reads:

15             "Command of the Zvornik Brigade Light Infantry Brigade ..."

16             And then it says, "Towards Gucevo."

17             Is that a protected line?

18        A.   No, in view it has a carrier capacity.  It is by a device that

19     could not be protected, so the speech could not be protected because it

20     was a carrier wave frequency and with this device.

21        Q.   We can see on point number 4 it says frequencies of 880 and 810

22     megahertz.  And you see that, right?

23        A.   Yes, I do.  Yes, I see that.

24        Q.   And that's written over something which we can't tell what's

25     underneath it, but you can see those are the numbers that are assigned to

Page 28838

 1     it, and that falls within the range of an FM200 or an RRU800 device,

 2     doesn't it?

 3        A.   Yes, that's right, only let me explain.  All 8 channels or 12, or

 4     34, that are working through this link, 1224, could not be protected as

 5     in the case of a protected route.  When an entire route is protected,

 6     only one of the channels could be protected by means of the KZU.  So

 7     KZU61 could protect only one of the channels selected from the 24 and not

 8     all of them.

 9        Q.   All right.  All right.  Thank you for that.

10             Now, I wanted to ask you some questions also about the

11     communications network, that is the radio or radio telephone network that

12     you described in your direct examination.  Now, first of all, are you

13     aware of whether or whether or not any code names were changed as a

14     result of documents falling into enemy hands in and around May of 1995?

15        A.   I can't remember exactly.  This was done by an employee in

16     crypto -- encryption department, Lieutenant-Colonel Radakovic, and when

17     the codes got into the hands of the enemy then they had to be changed.

18        Q.   And can you recall whether or not that occurred in May of 1995 or

19     not?

20        A.   I can't tell you with any certainty, I can't remember exactly,

21     but I do know that the rule was if a conversation is intercepted by the

22     enemy then the code had to be changed; but I can't remember exactly when

23     that happened.  I can't confirm it.  It probably did but I can't tell you

24     exactly.

25             MR. VANDERPUYE:  All right.  Let me show you 65 ter 3410, and let

Page 28839

 1     me see if that refreshes your recollection at all.

 2        Q.   Well, this, as you can see is a document entitled --

 3        A.   I remember these secret codes.

 4        Q.   Okay.  Well, this is a document that's dated 5 May 1995, and you

 5     can see it's submitted to a number of different units.  And it's signed

 6     by Radomir Prole, Colonel, and it indicates at the bottom of the page in

 7     the English and also, I believe, in your language:

 8             "Due to the new situation in the RSK and the suspicion that the

 9     documents of the communications plan in the Western Slavonia have fallen

10     to the hands of the enemy.  The existing code names of the units in

11     command shall be changed according to the following ..."

12             And it lists a number of different units.  Does that refresh your

13     recollection as concerns the questions I put to you before about the

14     changing of code names?

15        A.   Yes, I remember this now.  I frequently used these telephone

16     secret codes, Panorama, Zenit; and you see the telegraph codes that were

17     used when transmitting written information.  And I remember when the

18     names were changed, I forgot the exact time but I did use them when

19     establishing radio relay links.  So I am familiar with these names.

20        Q.   Are you aware of whether or not the RS telephone net -- whether

21     or not that was issued or changed in January of 1995?

22        A.   I don't know.

23        Q.   Okay.

24             MR. VANDERPUYE:  And if we could have 65 ter 3409 --

25        Q.   Maybe, you could explain this document.  All right.  This is

Page 28840

 1     another document.  It's dated 5 January 1995.  It's indicated that it's

 2     for the chief Colonel Radomir Prole sending to Drina Corps, and it's

 3     signed by Radakovic.  I think that's the person that you indicated

 4     before.  And it says:

 5             "In the attachment we are sending you the radio telephone net of

 6     the Republika Srpska registration number 13.  The Republika Srpska radio

 7     telephone net will start working on 7 January 1995 at 0700 hours."

 8             Do you recall ever seeing this document or becoming aware of the

 9     circumstances that it talks about?

10        A.   No, I haven't seen this document.  In view of the fact that I

11     haven't seen the document.  Now, why it was sent to the Drina Corps, I

12     really don't know.  It's a review of secret names of the radio telephone

13     net that you showed me a moment ago; so I really don't know what this is

14     about because I haven't seen this document, and I am not aware of it.

15        Q.   Well, the radio telephone net of the Republika Srpska, what is

16     that, if you could tell us?

17        A.   Those are the radio devices that were used:  RUP12, RUP1, RUP33,

18     and the frequencies used by those devices.  They have to be switched on

19     if the net is active, so these are devices that are operating for

20     reception, not for transmission.  And transmission is switched on when a

21     conversation is being transmitted.  So these are the devices that I've

22     already listed, RUP devices.  They use low frequencies between 30 and 70

23     megahertz, and their radiation is circular.  They need optical vision,

24     their range is 10 kilometres when the range of vision is 15 kilometres.

25        Q.   All right.  Thank you for that.  I am a little puzzled by your

Page 28841

 1     answer, though.  Is this document registration number 13 -- first of all,

 2     is it a document, and if it's a document, does it list different

 3     telephone extensions, frequencies, names, et cetera?

 4        A.   This is an accompanying document, it must have also a review of

 5     the frequencies of the radio net.

 6        Q.   Have you seen such a thing before?

 7        A.   I would come across not orders but documents of this kind,

 8     reviews of code names, users of the radio network, I would come across

 9     them.  This is just an attachment, an attached document.

10        Q.   All right.  And as you are testifying here today, I went over

11     with you just a moment ago the radio relay plan from the Drina Corps

12     document that you looked at, do you have any idea what frequencies were

13     actually operating in 1995?

14        A.   I don't know which frequencies you have in mind, the number of

15     frequency, the frequency range, or the actual radio relay device?

16        Q.   The frequencies that were operating on the routes that you

17     described, 0607, 0674, and the other routes that you looked at in the

18     document that I showed you from 1993.  Do you have a present recollection

19     of what frequencies were operating in 1995?

20      A. The frequencies at the devices RRU800 and FM200, we are talking about

21   these two relay routes, 0607 and 0674, the range was between 610 to 960.

22     Now, the transmission and reception frequencies were determined. Say, the

23   transmission frequency was, say, 783 on route 0674, in 1993, and the same

24   applied in 1995. That is to say that the frequencies were not changed. This

25   means that if the transmission frequency was, say, 783, then the reception

Page 28842

 1   frequency had to be -- the gap had to be 50 megahertz between the

 2   transmission and the reception frequency. And these frequencies did not

 3   change from 1993 to 1995. So it is within that range that the numbers of

 4   the emission and reception frequencies were.

 5     Q. Let me ask you something.  If you could just tell me, if you can

 6   recall, what is the frequency range, by the way, for an RRU800 device?

 7     A. I've told you I don't know how many times. 610 to 960 megahertz, 610

 8   to 960 megahertz for RRU800, FM200, and RRU --

 9     THE INTERPRETER:  I'm sorry, I didn't get the number.

10     THE WITNESS: [Interpretation] And the maximum number of channels was 24

11   unprotected on the RRU800; on the FM200, between 8 and 32 protected

12   channels.  Told you this yesterday, and I repeat it today. I don't mind


14     Q. I appreciate that. In terms of the routes -- well, let me just move on

15  to a different question. You indicated that there was a radio connection

16  from the Main Staff to a number of different areas. You said that there were

17  a radio connection between the Main Staff and the government of the

18  Republika Srpska, the Assembly, the president, and you said that there were

19  secure links with the government, the Assembly, the president, and the

20  Yugoslav Army. Do you remember that testimony from yesterday?

21    A. Yes, I remember that statement, and these are radio relay links

22  and not radio links.

23    Q. All right.  Now in terms of those particular connection, what types of

24  connections were they aside from the fact that they were radio relay links,

25  were they protected by encryption devices?

Page 28843

 1     A. Yes. Along all those routes, radio relay routes, towards the

 2   president, the government, and the Assembly, the radio relay protected

 3   route 0661 was operating, and the device for encryption was MD310 --

 4     THE INTERPRETER:  Could the witness slow down, please.

 5     THE WITNESS: [Interpretation] -- with the army of Yugoslavia, 0719.

 6             JUDGE AGIUS:  Yes.  Mr. Pajic, please, slow down a little bit.

 7     The interpreters having problems.  And Judge Kwon is right, in order to

 8     make sure that all your answer has been captured and transcribed, could

 9     you repeat it, please.  What we have here is:

10             "Yes, along all those routes, radio relay routes, towards the

11     president, the government, and the Assembly, the radio relay ..."

12             Can you continue from there, please?

13             THE WITNESS: [Interpretation] Yes, I will.

14             I was saying a protected radio relay route, 0661, was operating

15     for the presidency, the government, and the Assembly of Republika Srpska

16     using the radio relay device FM200 with 24 channels.  So I don't have to

17     repeat the device, but we are talking about protected routes using the

18     same relay device, there was a protected route with the army of

19     Yugoslavia with 24 channels.  On 674, also a protected route, with eight

20     channels with the Drina Corps; 0662, a protected relay route for the 1st

21     Krajina Corps, the 2nd Krajina Corps, and for the air and air defences.

22     And I wish to underline that 0719 route, a part of the channels went to

23     Bijeljina and was directed towards the Eastern Bosnian Corps.  That would

24     be a review of protected radio relay routes for speech of the army of

25     Republika Srpska.

Page 28844

 1             MR. VANDERPUYE:  All right.  If I could have you take a look at

 2     1D322.  And I think it will be page 17.  If we could blow that up a

 3     little bit so we can see it a little bit better, and if we could -- yes,

 4     just come down a little bit.  And if we could centre the flag a little

 5     and then blow it up.  All right.  Thank you.

 6        Q.   Now, in this diagram which was provided in a Defence exhibit

 7     through an expert witness, I just wanted to ask you:  The route that you

 8     see here, 0607, that goes from Vlasenica to Veliki Zep, you see that,

 9     right?

10        A.   Yes, I see it.

11        Q.   And the route, that's 0674, that goes from Han Pijesak to Veliki

12     Zep, right?

13        A.   This is not correct.  This route never went to Han Pijesak.  I

14     forgot to mention a moment ago when I was listing the protected routes,

15     there was another protected relay route, 0718, between Veliki Zep and Han

16     Pijesak, between the rear and the Main Staff.  And this one, 0674, was

17     installed, and it connected Vlasenica.  And instead of the number 9 there

18     should be a number 2 where Han Pijesak is.  And as for 0607, we have a

19     number 8, that is correct.

20        Q.   Okay.  So this -- if we could just go up to the top of the page

21     so we can see what it is.  And that says -- if you can tell me what it

22     says, actually, I'd appreciate it.  It looks like it says analogue radio

23     relay routes or radio relay for the Republika Srpska army, but maybe you

24     can tell us better since I can't read your language very well.

25        A.   This is a scheme, it connects the radio relay routes for the

Page 28845

 1     needs of the 1st Krajina Corps, the 2nd Krajina Corps, the Eastern

 2     Bosnian Corps.  These are analogue relay routes 0601.  This works for SMC

 3     1.036B device.  There was an intermediary station in Ozren and Jagonje.

 4     This route went to Svinjar to a hub, a communications hub, and then it

 5     went through the SMC to Kozara.  The route continued there.  So these are

 6     analogue relay routes, and so the SMC device was used, 0601 was a route

 7     that used 120 device.  There is the SMC Kozara.  Svinjar also used the

 8     SMC.  There was the Klekovaca, Kozara SMC device.

 9        Q.   I don't want to you to read the whole document.  I just want to

10     know what the title of it is.  I think you've answered that, but you've

11     also mentioned a number of other radio relay routes, and if we can go

12     back down the centre of the flag a little bit, maybe you can tell us

13     where those are.  Now you mentioned the route 0661 as a radio relay

14     route.  Do you see that on this diagram?

15        A.   I can see it on the diagram, and these connections that existed

16     until the time that Jahorina was shelled, and then they disappeared after

17     the communications hub on Jahorina was shelled; and as for 0661, as for

18     this route, it went from Veliki Zep, Ravna, Romanija, Pale.  It isn't

19     represented here, it came to life a little later when Jahorina was

20     shelled.

21        Q.   All right.  That's all I wanted to know.  It's not on this

22     particular diagram, right?

23        A.   It's not on the diagram, I don't know who made this but this

24     route to the government, 0661, did exist.  It was a secure route.

25        Q.   Okay.  And 0719, that's another route that you mentioned.  Do you

Page 28846

 1     see that on -- and if you want we can make this so that you can see the

 2     entire document, if that will help.  It's a bit small, but since you've

 3     indicated that it went to the government, I assume it went in the

 4     direction of Pale, which I think you can see relatively clearly here.

 5     But do you see that route on this document, 0719?

 6        A.   0719.  I said it went to Cer, to the army of Yugoslav Army, not

 7     towards the government.  0661 was the route that was connected to the

 8     government.

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

10     the sake of the interpretation.

11             JUDGE AGIUS:  Again, Mr. Pajic, the interpreters are having

12     difficulties --

13             THE INTERPRETER:  Microphone, please, Your Honour.

14             JUDGE AGIUS:  Sorry.  Thank you.  And my apologies.  The

15     interpreters are having problems.  I know it comes natural, because even

16     I speak somewhat fast, but if you could slow down a little bit I am sure

17     they will be very happy.  Thank you.

18             MR. VANDERPUYE:

19        Q.   Okay.  0719 you said went towards Cer; is that right?  Did I hear

20     you correctly?

21        A.   Yes.  0719 went to Cer.  It was a secure route.  And 0718 towards

22     Han Pijesak, towards the rear command post.

23        Q.   All right.  Let me show you a different document, then.  Let's

24     try 16 in this same document.  All right.  I think this might be a little

25     bit better.  First of all, since I can't read the title could you tell us

Page 28847

 1     what that says?

 2        A.   It's a diagram of radio relay and wire communications of the

 3     command of the Drina Corps.

 4        Q.   All right.  And if we could focus a little bit -- yes, closer to

 5     the square, if we could centre that and blow it up a little maybe we

 6     could see.

 7             Now, I see here a route, 0719 to Veliki Zep to Cer.  It's on the

 8     right-hand side of the screen, do you see that?

 9        A.   Yes, 0719 goes towards Cer.  I have already said that.

10        Q.   I just want to confirm that that's what it says on the document.

11     You see it on the right-hand side of the screen, yes?  0607 --

12        A.   Yes.

13        Q.   -- do you see that route?  And 0674, right?

14        A.   Yes, 0607 and 0674.  I can see both routes.

15        Q.   And in that diagram 0674 doesn't connect to Han Pijesak, does it?

16        A.   It doesn't connect to Han Pijesak because it was in Vlasenica, so

17     there was an error in the previous diagram.

18        Q.   All right.  So the previous diagram - and just for the record

19     that was page 17 of 1D322 - by your account that document is erroneous,

20     it's wrong?

21        A.   Yes.  The number of that relay route, 0674, is erroneous.  It

22     says that 0674 was connected to Han Pijesak.  It was connected to

23     Vlasenica, not to Han Pijesak.  As I have already said, 0718, which was a

24     secure route, was connected to Han Pijesak.

25        Q.   Okay.  Do you see 0718 on this diagram?

Page 28848

 1        A.   I can't see it here.  They only provided a diagram off a radio

 2     relay communications in the Drina Corps, and now we are dealing with

 3     communications link of the Main Staff of the army of Republika Srpska,

 4     the rear command post of the army of Republika Srpska.  So this is

 5     probably why they did not represent it here.

 6        Q.   All right.

 7             MR. VANDERPUYE:  If I could, maybe I can describe it.  Where the

 8     square is in the middle of the screen on the right, if we could just blow

 9     that up a little bit.  That's good.  And we can centre it on the circle

10     to the left below square.  On the left of the square and below if we

11     could just blow that up.  That's right.  All right.

12        Q.   Now, you can see in the middle where the circle is it says

13     Crna Rijeka, right?  That's the circle where it looks like a flag on top

14     or writing immediately above it?  I just want to know, do you see where

15     it says Crna Rijeka?

16        A.   Yes.

17        Q.   And you can see there is a line that goes from that small circle

18     where it says Crna Rijeka to a larger circle and a route number; it looks

19     like it ends in 66.  Can you tell us what that is?

20        A.   This is BB, it's not 66.  So it's probably a route without a

21     number, BB stands for "Bez Broj", no number.

22        Q.   And what about the letters that proceed that, what does that

23     stand for?

24        A.   Let me explain this.  This is permanent line without a number,

25     SVL, it's in the Cyrillic script here -- well, this is an overground air

Page 28849

 1     line or route that connected Vlasenica and Han Pijesak.

 2        Q.   It's a secure line, right?

 3        A.   Well, certainly as far as interception is concerned, but it was

 4     removed with time since these were things that people took for their own

 5     needs.  In the course of 1995 this line was destroyed.  Thieves took it

 6     away.

 7        Q.   Does this document -- or this page of this document represent

 8     what the radio lines were like in July 1995?  Is this accurate to your

 9     recollection of how things were laid out at that time?  That's what I

10     want to know.

11        A.   As far as these two radio relay routes to Vlasenica are

12     concerned, yes, it's correct.  As far as the permanent wire line is

13     concerned, it worked occasionally because the trees would fall, pillars

14     would collapse, there was a lot of snow and cables would break so it

15     didn't working all the time.

16             As far as the radio relay route at Cer, well you've removed this

17     from the screen now, so I cannot see it.  Could you perhaps show me Cer,

18     the route to Cer again.  Lower down the square -- scroll down so that the

19     goes down in the opposite direction.

20             MR. VANDERPUYE:  Is facing the opposite direction of the

21     right-hand side -- no, no, now if we go up, that's it.  All the way.

22        Q.   That's it 0719, right?  That's accurate.

23        A.   Well, there are certain things that are missing, that's true.

24     It's not 1058, that's not the route number.  It's not shown.  Most of the

25     channels that were used for the Drina Corps, or, rather, the Zvornik

Page 28850

 1     Brigade, and the Bratunac one.

 2        Q.   All right.

 3        A.   So in addition to 0719 to Cer, there is route 1058, and an SMC

 4     device was used for this route.

 5        Q.   Okay.  So --

 6        A.   And let me tell you the Drina Corps did not use radio relay

 7     routes 0719 for its needs.  They only used the radio route 1058.  So the

 8     Drina Corps did not use 0719, it used 1058 you exclusively.

 9        Q.   Okay.  So this document isn't accurate in that respect either, is

10     it?  It doesn't represent how things were laid out in 1995?

11        A.   It's not accurate when it comes to 0719.  That route did exist.

12     However, secured links were used for the needs of the IBK, the Eastern

13     Bosnia Corps, and the army of Yugoslavia.  The other routes to Cer was

14     1058, and this route was used for communications for the need of the

15     Zvornik Brigade, Sekovici and so on.

16             MR. VANDERPUYE:  All right.  Let's take a look at page 15 of this

17     same document.  Okay.  That's good.  If we could focus again on the

18     square in the -- that's it.  All right.

19        Q.   Here again we see route 0719, right, and you can see that goes

20     from Veliki Zep to Cer.  This time we see route 661 -- you see that,

21     right?  It's on the right-hand side of the screen, and maybe I'm

22     reading --

23        A.   Yes, I can see it.

24        Q.   That's accurate too, isn't it?

25        A.   I can see that relay route, that's correct, 0719.

Page 28851

 1        Q.   You see 0607 on the left -- well, the left-hand side of the

 2     square, and 0674.

 3        A.   Yes, I can see everything.

 4        Q.   You see 0793?

 5        A.   I do.

 6        Q.   And that goes to Strazbenice, right?

 7        A.   Yes.

 8        Q.   And you can see that there are connections, I'll call them,

 9     between Crna Rijeka and Veliki Zep, and you can see between Crna

10     Rijeka -- I mean, between Veliki Zep and Han Pijesak, right?

11        A.   Yes, I can see that.

12        Q.   Okay.  And can you identify from this diagram what the

13     connections were between Crna Rijeka and the Assembly, the presidency,

14     and so on.

15        A.   You can't see that in this diagram.  The relay route that was

16     used from Veliki Zep through Ravno Romanija and up as far as Pale is not

17     depicted in this overview of the radio relay communications of the Drina

18     Corps.  That's probably the case because it's not their route.

19        Q.   It's not their route.  Okay.  And you can see, by the way, where

20     it says "Drinski Korpus" on the top of the screen, it says "diplomas,"

21     you can see that?

22        A.   Yes, I can see that.

23        Q.   Do you know whether or not that code name was ever changed?

24        A.   Well, this code was probably changed.  I can't remember what it

25     was changed, but it was changed -- or, rather, the secret code was only

Page 28852

 1     changed within the Drina Corps, at the level of the Drina Corps; other

 2     secret codes were not changed, but I can't remember when this code was

 3     changed.

 4        Q.   All right.  Okay.  Thank you for that.  Now, you maintain contact

 5     from the headquarters of the Main Staff with the Assembly, you said, with

 6     the presidency, you said; did you maintain contact from the Main Staff

 7     with the 10th Sabotage Unit in Vlasenica in Bijeljina?

 8        A.   No, I didn't maintain such contact.  That was within the domain

 9     of the Eastern Bosnia Corps, the Drina Corps, rather, within the domain

10     of their communications battalions.  That was for them to deal with.  I

11     was only responsible for establishing and maintaining communications

12     between the Main Staff and the corps and the presidency and the army of

13     Yugoslavia.

14        Q.   All right.  Thank you.  And my question was inartful, and I

15     apologise, what I want to know is whether or not those communications

16     were maintained; that is, kept between the Main Staff and the 10th

17     Sabotage Unit -- detachment.  If you wanted to reach them from the Main

18     Staff, how would you do that?

19        A.   We did not have any direct connections to those units.  In order

20     to establish communication from the Main Staff with some of the units you

21     have mentioned, well, you had to do this through an intermediary, central

22     station.  Central station in the Crna Rijeka Corps, central in the Drina

23     Corps, and then you would asked ask the server at the telephone exchange

24     to connect you to the detachment at Vlasenica -- or, rather, I don't know

25     where that detachment from the Drina Corps was.  So in the Main Staff we

Page 28853

 1     didn't have a direct link.  We had to go through another exchange centre.

 2        Q.   And was that the same with respect to your connection, your

 3     ability to contact or maintain a connection with the 65th Protection

 4     Regiment in Novo Kasaba in July of 1995?

 5        A.   No, as far as the 65 protection regiment is concerned, which was

 6     located in Kasaba, there was on a radio relay device, RRU1 at Veliki Zep

 7     in Kasaba.  There was a direct connection to themselves.  There was an

 8     automatic three-digit telephone number that you could dial on an

 9     automatic telephone.  Anyone could get them.  If anyone had that

10     three-digit telephone number could get through to that number in Kasaba,

11     I can't remember what the three-digit number was.

12        Q.   Naturally and travelling over an RRU1 line, the kind that you

13     said could be intercepted, right?

14        A.   Yes, only if a KZU71 had been set up, which served for

15     protection, in such cases this device couldn't be intercepted; otherwise,

16     if it wasn't protected by KZU71, then it would be possible to intercept

17     communications on that device.

18        Q.   All right.  And did you have a similar connection with a -- the

19     command post in Borike in July 1995?

20        A.   Yes, there was a similar connection.  In fact, it was an

21     identical type of connection, an RRU1 device was used.

22        Q.   All right.  And in terms of the connection that you had with

23     Borike in July 1995, was there a communications centre located there in

24     Borike -- or communications unit, I'm sorry.

25        A.   As far as for a communications centre, well, I know there was no

Page 28854

 1     communication us centre.  There was a forward command post over the 1st

 2     Rogatica Brigade or the Podrinje Brigade, I'm not sure what you have in

 3     the documents not in Borka but in Sesko [phoen] which is 4 kilometres

 4     from Borike.

 5             MR. VANDERPUYE:  Your Honour, I see we are at the break, if you

 6     like.

 7             JUDGE AGIUS:  Yes, 25 minutes.  Thank you.

 8             MR. VANDERPUYE:  All right.

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

10                           --- On resuming at 4.15 p.m.

11             JUDGE AGIUS:  Yes, Mr. Vanderpuye.  How much longer?

12             MR. VANDERPUYE:  I think about --

13             JUDGE AGIUS:  Five minutes.

14             MR. VANDERPUYE:  No, I was hoping actually, but I think more like

15     25 minutes.  I will try to keep my answers "yes" and "nos," but that's

16     what I'm hoping for.

17             JUDGE AGIUS:  Yes, let's hope so.

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

19        Q.   Okay, thank you.  I was asking you about the communications

20     facilities in Borike, and you indicated that there was a command post,

21     and I think you said that was for the 1st Light Infantry Podrinje

22     Brigade, and I think you said that was in Sesko; is that right?  Just

23     tell me if I'm wrong.

24        A.   Yes, that was a forward command post, the forward command post of

25     the 1st Podrinje Brigade.  In a hamlet called Borike, the hamlet has a

Page 28855

 1     different name, it's called Sesiske [phoen], but it all belongs to the

 2     Borike local commune.

 3        Q.   And the Rogatica Brigade headquarters, where is that located

 4     relative to I think you said Sesisko?

 5        A.   The command post of the Rogatica Brigade was at Rogatica.  The

 6     forward command post was at Borike.

 7        Q.   And you wanted no communicate from Borike, how would that go, how

 8     would that be accomplished?

 9        A.   Given the fact that there was a radio relay device there, RRU1,

10     at Borike, and there was a three-digit figure; I'm not sure which

11     particular link you mean, but it was possible to get in touch with the

12     Drina Corps.  Primarily that's what we set it up for, for their needs,

13     for the purposes of the Drina Corps and the Rogatica Brigade.  The Drina

14     Corps had a three-digit number as well, their own switchboard; therefore,

15     they were able to communicate.

16        Q.   And where was the actually building in Borike where this forward

17     command post was located, if you can recall?

18        A.   I can't recall specifically.  For a while there was a holiday

19     cottage right next to the hotel, later it was the hotel, the local

20     office, this changed over time and I forget where it was exactly.

21        Q.   All right.  So you can't recall where it was in 1995, as it were,

22     right?

23        A.   I don't know exactly.

24        Q.   Okay.  And if you wanted to send a document, not over an RRU1,

25     perhaps an encrypted document, how would you do that?

Page 28856

 1        A.   I never had any need to send any document like that.  It was

 2     probably done by the Drina Corps with the subordinate brigades.  The

 3     communication lines went to the Drina Corps, and then the Drina Corps

 4     with its brigades would establish communication.  I had no need at all to

 5     send any documents like that.

 6        Q.   I'm sorry.  My question is inartful again, and I apologise.  I am

 7     not asking about what you did personally, I am asking about how would one

 8     go about sending a document if one were at the forward command post in

 9     Borike?  How would you go about doing that?

10        A.   One could dial directly by using the three-digit automatic

11     number, or you could use the switchboard in the Drina Corps.  The Drina

12     Corps was directly in touch with the Rogatica Brigade, the route being

13     0793 to Strazbenice and then 0695 to Rogatica, and that's how the

14     communication happened.  Between Rogatica and Borike there was a wire

15     connection or a postal system that used to operate before the war so

16     there was a cable already in place linking Rogatica to Borike.  So it

17     could have been a direct link through the Drina Corps central, hub Drina

18     Corps through the central communications up to Rogatica and then by wire

19     to Rogatica or directly through RRU1 and the three-digit number.

20        Q.   Could you send a document -- an encrypted document, from Borike

21     directly?  In other words, did they have encryption equipment in Borike

22     as far as you know in July of 1995?

23        A.   They didn't have that sort of equipment back 1995.  I do remember

24     that.  Just in Rogatica at the brigade command.

25        Q.   So if you wanted to send an encrypted document from Borike would

Page 28857

 1     it make sense for you to get that document to the headquarters in

 2     Rogatica in order for it to be sent?

 3        A.   Yes, that's right.  I am not really sure, but as far as I know

 4     they did have an encryption device at Borike.

 5        Q.   All right.  Now, you don't recall exactly where the

 6     communications equipment was in Borike, let me ask you:  Do you know

 7     where the communications equipment was with respect to your connection

 8     from the Main Staff with Pale?

 9        A.   Can you please repeat that, the last word.

10        Q.   All right.  I think I will rephrase it.  When you had connection

11     between the Main Staff in Pale, who was in charge of the equipment that

12     was maintained in Pale, the communications equipment?

13        A.   I was in charge of the radio relay equipment.

14        Q.   And where did that line go to?

15        A.   You mean the radio relay route, where it went to?

16        Q.   Yes.

17        A.   It went via Veliki Zep, Veliki Zep, Ravno Romanija, the hill

18     above Pale, Kalovite Stijene.  That's what the hill was called; and then

19     all the way down to the centre for communications and reporting at Pale.

20     And the encryption device was stationed there as well.

21        Q.   And was there a connection, a direct connection as you say

22     between the Main Staff and the president's office?

23        A.   Yes, there was.

24        Q.   And where did that line go, the one that connected to the

25     president's office?  Was it direct or was it indirect?

Page 28858

 1        A.   It was a direct line.  There was also the automatic three-digit

 2     number that was installed in the president's office, and you could use

 3     direct dialing but you could go indirectly as well.  There was a direct

 4     channel linking the president to the commander, and then there was the

 5     automatic three-digit number which could be dialed directly; therefore,

 6     it was accessible from the central switchboard.

 7        Q.   Were you responsible for maintaining that equipment, that is, the

 8     equipment on the president's end of the communications network?

 9        A.   I was responsible for the operating of the radio relay equipment

10     at Veliki Zep.  At the other end, at Pale, there was the crew from the

11     signal's battalion of the Sarajevo Romanija Corps, and they were in

12     charge of maintaining communications there.

13        Q.   And as a practical matter, it didn't involve much for the

14     president to actually have access to that line, just to pick up the phone

15     from his office; is that fair to say?

16        A.   Yes, he would have to pick up the receiver and he would have to

17     actually dial the three-digit number, or press a button to make a call.

18        Q.   Was that a dedicated encrypted line or was that a line that might

19     be protected or not be protected?

20        A.   It was not a special secure line.  It worked along the protected

21     radio relay route as all the other channels and the KZU71 device was

22     used, same as all the other routes to all the other corps commands.

23     KZU71, that was the device used to protect this route.  Nothing special

24     as compared to all the other protected routes.

25        Q.   All right.  So in other words it's not a device that's actually

Page 28859

 1     sitting in the office, it's a device that's located somewhere where the

 2     office connects -- the office line connects, right?

 3        A.   Yes, that's right.

 4        Q.   That, you said, is maintained by a unit from the Sarajevo

 5     Romanija Corps, right?

 6        A.   Yes.  The signals battalion of the Sarajevo Romanija Corps.

 7        Q.   And by the way do you know anybody from that particular signals

 8     battalion?  Can you tell us people that you were in contact with, their

 9     names and such?

10        A.   Yes, I can:  Captain Nenad Gracanin, Captain Nedeljko Planojevic.

11        Q.   And these would be two individual that would be responsible for

12     maintaining the integrity of the encrypted line, the KZ device that you

13     spoke about, as well as the regular line from the president's office

14     outward?

15        A.   Well, these specific people were in charge of maintaining the

16     radio relay route and keeping the line operating, the carrier way device

17     between the distributor itself and the office.

18        Q.   Were there any other communication -- I'm sorry, any other

19     communication devices or routes that were used to allow the president to

20     communicate with the Main Staff that you are aware of besides the radio

21     relay routes as you've described?

22        A.   One could use PTT numbers.

23        Q.   And are you aware if those particular lines went directly into

24     the president's office as well?

25        A.   Well, I'm talking about automatic telephone numbers, from

Page 28860

 1     existing telephone switchboards or hubs; for example, the one at Pale,

 2     they could have used direct dialing to get in touch.  At the Main Staff

 3     there were PTT connections established by the post office.  At Han

 4     Pijesak they could have used PTT connections directly and not rely on our

 5     military links, and they could still communicate.  This wasn't really the

 6     case that often, though.

 7        Q.   All right.  So these are regular civilian lines like you would

 8     use today, pretty much?

 9        A.   Yes, that's right.

10        Q.   Okay.  And those were available from the president's office.  Can

11     you tell us where the president's office was in July of 1995 if you know,

12     what building it was in, et cetera?

13        A.   I don't know exactly.

14        Q.   All right.  Now, you had mentioned yesterday in relation to 65

15     ter 183, I believe it was, that the Main Staff didn't have an RU2/2K

16     device.  But earlier on in your testimony you were asked a question about

17     the type of equipment that was used, and you said:

18             "That the RU2K -- RU2/2K - I'm sorry - RUP12 and radio telephones

19     were types of equipment most frequency used."

20             And I just wanted to clarify that a little bit on the record

21     because I'm not sure exactly what you meant by that.  That's at page

22     28764 in the record.  It wasn't the case that the Main Staff had an

23     RU2/2K in 1995?

24        A.   Yes, there was a device like that.  But I said yesterday this was

25     hardly ever used, hardly ever, not that I was aware of, but there existed

Page 28861

 1     a device like that.

 2        Q.   All right.  I just wanted to clarify that because it wasn't clear

 3     to me and I appreciate your answer.  You were also asked a question about

 4     extension 155 and whether or not that particular extension corresponded

 5     to more than one location in 1995.  And I wasn't clear on your answer

 6     with respect to that either, because at one point you indicated that it

 7     corresponded to a forward command post, I believe you said that was in

 8     Jasenica, and then one in Jahorina; and then you said that it wasn't

 9     transferred in 1995.  I am not sure what you meant by that.

10             Was extension 155 in operation in the Main Staff in Crna Rijeka

11     in 1995, in July of 1995?

12        A.   Yes, the extension was in use in the Main Staff in Crna Rijeka in

13     1995.  It was installed at four different physical locations in

14     Crna Rijeka itself.  But when I talked about 1995, about it being used,

15     but what I said was that it had been used at Jahorina, at the forward

16     command post back in 1993.  In 1995 it was a different three-digit

17     number.  I can't remember which one exactly.  155 was operating in July

18     1995 at four different locations -- or, rather, it was installed in four

19     different locations at Crna Rijeka, in the underground facility, and in

20     two other rooms, and in the cabins there were two outlets.

21        Q.   So if you wanted to reach General Miletic, for example, in July

22     1995, it would make sense to call that extension, wouldn't it, 155?

23        A.   Yes, the number was the personal number for General Milovanovic,

24     chief of the Main Staff of the army of Republika Srpska.  He had ordered

25     for that number to be installed also at the operations centre, so it was.

Page 28862

 1     Given the fact that General Miletic was spending most of his time at the

 2     operations centre, he was always there, he was normally the person who

 3     responded to that number.  If it wasn't him, it was probably the

 4     operations duty officer.

 5        Q.   All right.  Let my just -- and by the way, do you know how long

 6     in 1995 extension 190 -- 155 was in operation or connected to Crna Rijeka

 7     as you've said?

 8        A.   It was permanently connected and permanently operating.  We never

 9     switched it off.  One thing, it was installed at four different

10     locations; and then the operations centre was in the underground

11     facility, then we would use so-called debt-securing devices, to switch

12     off the number to the cabins; but as of the 25th of May 1995 and onwards

13     up until the end of September, the operations centre was, in fact, in the

14     underground facility, then it was being used above-ground and it had two

15     locations, the operations centre and room number 9, which is where the

16     chief of the Main Staff was staying or where he was supposed to be

17     staying.

18             MR. VANDERPUYE:  Let me show you 65 ter 3935.

19        Q.   Now, this is an intercept as you can see, it's dated 6 October

20     1995.  You can see in the title that it's from the state security service

21     in Tuzla, and it purports to be captured on 642.00 -- well, 642.000

22     megahertz, 1210 on that day.  And in that conversation -- just a second,

23     let me make sure I have it correctly in front of you in your language.

24             MR. VANDERPUYE:  On the second page of the B/C/S, and it's on the

25     bottom, it's 1531 -- yes, that's right.

Page 28863

 1        Q.   You can see here -- you can read this intercept.  It says that it

 2     was captured at 642.000 megahertz, and it's a conversation between

 3     somebody named Ljubo Jevic and an unidentified person in this

 4     conversation.  About halfway down you can see where it reads:

 5             "I know, but why Arsic doesn't call extension 250 directly and

 6     cut it all short.  I've sent it down there to General Miletic as

 7     well ..."

 8             It goes on and you can see he asks, later on, X asked:

 9             "Well, that was yesterday, I didn't want to go there until they

10     send it because I'm in trouble, you know, I really don't know what to do

11     anymore.  Tell me, is he still on 155?"

12             And then it says:

13             "On 250, I'm going to call him right away."

14             That's on the bottom of the intercept.  Now, would it have made

15     sense to try to reach General Miletic at extension 155 in October of

16     1995?  And if you could also tell us what does extension 250 correspond

17     to?

18        A.   One could use 155 to get in touch with General Miletic.  As for

19     250, that is another three-digit number which was installed somewhere in

20     the cabins.  I am not sure in which room exactly, it had to be nearby, so

21     probably it was just moved to an adjacent office.  I can't remember

22     specifically who the number belonged to, the 250 number.  It's near 155.

23     It must have been one of the adjacent offices or thereabouts.  There were

24     a number of these numbers being used and the automatic switchboard had a

25     total of 250 such numbers.  Each of the rooms had a three-digit number,

Page 28864

 1     so it must have been one of the rooms right there, nearby.

 2             MR. VANDERPUYE:  All right.  Thank you for that.  Could I have 65

 3     ter 3934 in e-court, please.  Could we not broadcast this -- I'm sorry.

 4             JUDGE AGIUS:  Yes, Madam Registrar.  Will you take care of it.

 5             MR. VANDERPUYE:  Thank you.  Thank you very much.

 6        Q.   This is an intercept, and it's dated 10 September 1995.  It's

 7     also from the state security services at Tuzla, and it indicates that on

 8     frequency 641000 that they recorded a conversation involving, it says,

 9     between a general of the aggressor's army, Miletic, and some other

10     participants from Panorama.  And if you look immediately below that you

11     can see it says:

12             "M:  General Miletic here, Panorama 155.  In case there is some

13     activities in the air, in the afternoon, inform Panorama 155 immediately

14     because the agreement has been reached that the activity should stop for

15     a while and we need information in case it is not being carried out."

16             Now, with respect to this particular intercept, it seemed to

17     indicate that General Miletic is speaking, and if it's connected to

18     Panorama 155 that would indicate that he's at what location?

19        A.   Yes, this was at the command post of the Main Staff, but I don't

20     know who he happened to be talking to at this time or where the other

21     participant involved in this was.

22        Q.   Well, it says here that it conveyed a message -- he conveyed a

23     message to someone and to Zenit.  Now, Zenit you saw on the document I

24     showed you before ask that related to the Krajina Corps, right?

25        A.   The 1st Krajina Corps.

Page 28865

 1        Q.   Okay.  Thank you for that.

 2             MR. VANDERPUYE:  If I could have 65 ter 3933 in e-court, please.

 3        Q.   This is another intercept.  And this one is indicated to be from

 4     the 2nd Corps of the ABiH, and it indicates that it was delivered to

 5     their intelligence organ.  It's dated 10 September 1995, like the other

 6     one; and the time of this one is 1710.  Just so the record is clear, the

 7     time on the -- on 65 ter 3934 was 1746.

 8             In this particular intercept, it involves General Miletic and it

 9     says:

10             "Operations duty officer, inaudible."

11             It says:

12             "GM:  Give me operations duty officer.  Hello, Pama here, tell me

13     is there anything new at your place ..."

14             And so on.  I won't read the whole thing, but it says further on:

15             "Something appears somewhere, call Panorama 155 immediately.

16     Immediately inform Panorama 155."  And it repeats that.

17             Further on in the intercept we see that they note that

18     General Miletic spoke on channel 7 and had a heated conversation with a

19     duty officer, that the duty officer does not have Panorama 155 in his

20     code book, so he doesn't know how to pass on the information.  In this

21     intercept, if you go to page 2 in the English, General Miletic tells him

22     to look for Panorama in the ads, and once he finds it to ask for 155 and

23     that's how he's going to pass the information where it's supposed to go

24     in the end.

25             Further on in the intercept, toward the bottom of the intercept

Page 28866

 1     in the English, and I think it might also be toward the bottom in the

 2     B/C/S, on the same page, it says that General Miletic asked another

 3     person, Zenit, a duty officer, he asked him as well to inform him of

 4     Panorama 155.  That seems to indicate as well that General Miletic, as

 5     you say, is at Crna Rijeka as well, right?

 6        A.   Yes.

 7        Q.   And these three intercepts all contain information that matches

 8     the reality of the situation in terms of the extension that is used and

 9     the person that is attached to that extension as it existed in September

10     and October of 1995, right?

11        A.   Yes, I am just not sure where the interception took place, at

12     which segment of the line.

13        Q.   Okay.  Well, thank you for that.  I want to ask you about a

14     different document.  Just a moment.

15             MR. VANDERPUYE:  65 ter 3038, please.  If I could have that in

16     e-court.

17        Q.   All right.  This is a -- well, it's an order, and at the bottom

18     of it you will see that it is from General Mladic and it indicates --

19     well, first of all --

20             MR. VANDERPUYE:  For the record, it's 11 July 1995 and the

21     strictly confidential number is 03/4-1616, and it's directed to the

22     commands of the Drina Corps.  In the translation -- the English

23     translation.  It reads the Zvornik Motorised Regiment.  What it reads in

24     the B/C/S is 65.zmtp.  First, can you tell us what that is for the

25     record.

Page 28867

 1             JUDGE AGIUS:  Before you tell us, Mr. Petrusic, I notice you

 2     standing.

 3             MR. PETRUSIC: [Interpretation] I do apologise for interrupting my

 4     learned friend, but I'd like the whole document to be shown on the screen

 5     so that the witness can see it in its entirety.

 6             JUDGE AGIUS:  Or you can give him a copy of it if that is quicker

 7     and easier.

 8             MR. VANDERPUYE:  Unfortunately, Mr. President, I don't have a

 9     copy of the B/C/S.

10             JUDGE AGIUS:  All right.  Let's show the whole document on the

11     screen.  How many pages?

12             MR. VANDERPUYE:  It's one page in the B/C/S and --

13             JUDGE AGIUS:  Okay, then it should be easy.  So ...

14             MR. VANDERPUYE:  Yes, I'll direct him to specifically where I

15     want him to go.

16             JUDGE AGIUS:  Yes.

17             MR. VANDERPUYE:

18        Q.   First, in the header it indicates that it's directed to the

19     command, and it says "65.zmtp."  Do you see that?  I just want you to

20     tell us what that is, if you know, so the record is clear.

21        A.   The header is not correct.  If it's General Mladic's telegram, it

22     should say the Main Staff of the army of Republika Srpska, then his

23     number.  I find this very strange that in the header it only says

24     "Republika Srpska."  Also, I can't see what it says where the signature

25     is.

Page 28868

 1        Q.   I just want you to tell me, if you can, what does 65.zmtp mean?

 2     I will get to the rest of the document in a minute, if you know?

 3        A.   This 65th Protected Motorised Regiment.

 4        Q.   Okay.  Thank you.  And among the units that it's directed to is

 5     also the 67th Communications Regiment and that's denoted as 67.PV, right?

 6        A.   Regiment.

 7        Q.   Is that right?

 8        A.   Yes, the 67th Communications Regiment.

 9             MR. VANDERPUYE:  And now if we could page down on this document,

10     please.

11        Q.   Now, on this document you can see that it says "Komandant General

12     Vukovnik [phoen], Ratko Mladic," and it's type-signed, right?

13        A.   Yes.

14        Q.   And it's indicated on the receipt stamp 1945 hours.  You can see

15     that, right?  And also 2nd Romanija Motorised Brigade.

16        A.   Yes.

17        Q.   And at point 4 of this document it says that:

18             "The commands of the 65th Motorised Protection Regiment and the

19     67th Communications Regiment platoon," or regiment, I'm not sure how the

20     translation reads, "are to ensure that the sound of air sirens.  That at

21     the sound of air raid sirens reasons all available personnel go to the

22     shelters, the unit commanders are responsible to me for carrying out this

23     order."

24             Do you see that written there?

25        A.   Yes, I do.

Page 28869

 1        Q.   And at point number 3, it indicates, in addition to its present

 2     tasks, the command of the 67th Communication Regiment is to provide one

 3     rapid reaction platoon for the deployment at the KM Main Staff VRS --

 4     well, it says command post of the Main Staff of the army Republika Srpska

 5     and other -- and another in the Han Pijesak barracks for outside

 6     intervention toward the command post.  Do you see that?

 7        A.   Yes, I do.

 8        Q.   Were you aware of what is indicated in this order with regard to

 9     the deployment of 67th regiment members and both to the Main Staff and

10     the Han Pijesak barracks, and also with respect to making sure that at

11     the sound of air raid sirens, personnel go to their shelters.  Were you

12     aware of that on the 11th of July on the day that you had this party?

13        A.   No, I didn't know that.

14        Q.   You said that this particular document raised some suspicions in

15     your mind; is that true?

16        A.   Yes, this telegram, which was received by the command of the 2nd

17     Romanija Brigade, their encoder, it was not done properly.  The telegram

18     should have reached the Drina Corps.  It should be reprocessed and then

19     sent to the command of the 2nd Romanija Brigade.  So it is an incorrect

20     telegram.  They simply forwarded this telegram without processing it at

21     the encryption station at the command of the Drina Corps.  So the

22     telegram to the 2nd Romanija Brigade should have been signed and approved

23     by the commander of the Drina Corps, because General Mladic or our

24     encoder could not have sent such a telegram directly to the 2nd Romanija

25     Brigade, and I don't remember this order.

Page 28870

 1        Q.   You don't remember it?  Okay.  Well, you were a member of the

 2     67th Communication Regiment, right?  On the day that this order with you

 3     issued, 11 July 1995?

 4        A.   Yes, I was a member, and I do not remember that on that day there

 5     was any kind of an alarm in connection with any threat from the air.

 6     Everything was normal.

 7        Q.   Well, it's clear here from this order that this was an order that

 8     was directed to your unit and concerned matters of relevance to your unit

 9     on the 11th of July 1995 and also involved personnel from your unit,

10     right?

11        A.   My personnel was in the underground facility G1, so we couldn't

12     take any special measures; and if this order was received, it was

13     received by the commander of the 67th Communications Regiment, but I was

14     not aware of it; so the company for garrison communications of the 67th

15     regiment was constantly staying under ground, so there was no need for

16     the commander to inform us about any special measures in the case of

17     threat from the air or anything like that.

18        Q.   Well, who would have formed this -- who would have formed this

19     rapid reaction platoon for deployment in the 67th Communications

20     Regiment?  Who would that involve, what people?

21        A.   The 67th regiment had two battalions and a company for garrison

22     communications.  One battalion was at Crna Rijeka, where the cabins were,

23     and it the other one was in the barracks in Han Pijesak, so the 67th

24     regiment, in addition to the company for garrison communications that I

25     was in, it had two battalions.  One was at the command post, the

Page 28871

 1     so-called Barake [phoen]; and the other in Han Pijesak, so this probably

 2     applies to them.

 3        Q.   And you, the person charged with maintaining and setting up

 4     communications lines, have no recollection or had no involvement in this

 5     relative to this particular order, is that what you're saying?

 6        A.   Yes.

 7        Q.   You do know certainly now that VRS positions were in fact bombed

 8     on that day?

 9        A.   I heard about that.

10        Q.   You have no recollection of that as you have no recollection of

11     this order, right?

12        A.   Yes, that is true, because the bombing was a daily occurrence, so

13     I didn't devote special attention to it; and I really can't remember this

14     order.  It is addressed to the commander, and I was not at the encoding

15     station, so I didn't control the receipt and transmission of such

16     telegrams.  It is true that it refers to the 67th regiment, but this

17     telegram was not drafted properly.  But I'm not challenging that

18     General Mladic may have sent it, but it was not properly written.  And

19     this order for the 67th regiment need not have been encoded at all,

20     because it was nearby.

21             MR. VANDERPUYE:  I may I have just one question, please bear with

22     me for a moment, Your Honours.

23        Q.   All right.  Thank you very much, Mr. Pajic.  I have no further

24     questions.

25             MR. VANDERPUYE:  Thank you, Mr. President, Your Honours.

Page 28872

 1             JUDGE AGIUS:  Thank you, Mr. Vanderpuye.  Is there redirect,

 2     Mr. Petrusic?

 3             MR. PETRUSIC: [Interpretation] Very briefly, Mr. President.

 4                           Re-examination by Mr. Petrusic:

 5        Q.   [Interpretation] Mr. Pajic, talking about this ordering I would

 6     like us to look at this document again P3038.  And let us go in order.

 7     The header says "Republika Srpska."  Could this document have been sent

 8     from the Drina Corps?

 9        A.   It could have been sent from the Drina Corps, yes, it could have.

10             MR. PETRUSIC: [Interpretation] Please scroll down the document,

11     to the bottom, so we can see paragraph 3.  That's fine.  Thank you.

12        Q.   In item 3 there are certain combat orders as I would call them,

13     in the course of your service, in the army Republika Srpska, did you have

14     any combat assignments?

15        A.   No, never.  I never had any combat assignments.  I worked

16     exclusively on the maintenance and establishment of radio relay and wire

17     communications and that is why I was not familiar with this order and

18     that is what I told the Prosecutor.

19        Q.   In the stamp, the time mentioned, 1945, could you tell us what it

20     relates to?

21        A.   First of all, this telegram could not have gone in this way,

22     because it says Republika Srpska at the top.  Now, if it was -- if it was

23     sent by the Drina Corps, then the stamp of reception should be there, a

24     round stamp, the time it was processed, then the telegram is revised, and

25     then it is sent from the Drina Corps to the 2nd Romanija Brigade with a

Page 28873

 1     different header.  So the command of the Drina Corps would be at the

 2     header and the same contents and signed by the command of the Drina

 3     Corps.

 4             So in this case --

 5             MR. McCLOSKEY:  Objection, Your Honour, excuse me.

 6             JUDGE AGIUS:  I let him go for a while because I didn't see

 7     clearly what you could have in mind, but I do now.  Yes, Mr. McCloskey.

 8             MR. McCLOSKEY:  I apologise, can we have the witness not -- I

 9     don't know if he speaks English or not.

10             JUDGE AGIUS:  How much English do you know?  How much English do

11     you know?

12             THE WITNESS: [Interpretation] No, I don't.

13             JUDGE AGIUS:  All right.  Could you remove your headphones,

14     please.  No -- remove them, put them ... give them to the usher.  Yes.

15     Thank you.

16             Yes, Mr. McCloskey.

17             MR. McCLOSKEY:  I just wanted to alert Mr. Petrusic and the Court

18     to a potential problem.  This document from the handwriting on it, the --

19     the triangle, it's my memory that this document was provided to us by

20     Mr. Petrusic in the Krstic case.  And that's confirmed by Ms. Stewart.  I

21     am not sure, and I don't think we have been able to find it in some other

22     collection; so I believe Mr. Petrusic is our foundation for it.  And he

23     may not be challenging the authenticity of it.  From his questions, I

24     can't tell, but the witness certainly is.

25             And I don't think that Mr. Petrusic should be in a position where

Page 28874

 1     he is challenging a document that he actually gave to the Prosecution.

 2     This was always going to be a potential problem.  We thought that it

 3     wouldn't be so much that Ms. Fauveau could take over in situations like

 4     this, but I just wanted to alert everyone to that problem.  I haven't

 5     heard Mr. Petrusic challenge the document, but he's asking questions

 6     about it and the witness is, and given the situation where it came from,

 7     I just wanted to alert everyone to that.

 8             JUDGE AGIUS:  Are you challenging the document, Mr. Petrusic?

 9     Let's make that clear first.

10                           [Trial Chamber and registrar confer]

11             JUDGE AGIUS:  Perhaps Madam Fauveau can answer the question.

12             MS. FAUVEAU: [Interpretation] No, Mr. President.  We are not

13     challenging this document or its authenticity.

14             JUDGE AGIUS:  All right.  Does that change the position for you,

15     Mr. McCloskey?

16             MR. McCLOSKEY:  I think that helps, but as this witness goes down

17     the road he's going, you've got the same problem, but we're -- I think we

18     are okay.

19             JUDGE AGIUS:  Yes.  I think we are okay at this stage.  Yes --

20             MR. McCLOSKEY:  The problem becomes, Mr. President, if the

21     witness challenges the authenticity, then --

22             JUDGE AGIUS:  But my --

23             MR. McCLOSKEY:  Then ask where it came from.

24             JUDGE AGIUS:  Yes, but it seems there is one reason why I let the

25     witness goes on and on is precisely so that we could have his answer

Page 28875

 1     already given that would solve your problem, unless he continues, of

 2     course; because if he continues that could create a problems too.

 3             But let's see.  Can you please.

 4             Do you have anything else to add to your answer?

 5             THE WITNESS: [Interpretation] I have nothing.  I just wanted to

 6     say that it was incorrectly sent.  I am not denying that the 2nd Romanija

 7     Brigade received this telegram from the Drina Corps.  Only thing is that

 8     it should have been drafted differently --

 9             JUDGE AGIUS:  All right.  Your --

10             THE WITNESS: [Interpretation] -- because this was not our

11     practice to work in this way.

12             JUDGE AGIUS:  Thank you.  Your next question, Mr. Petrusic.

13             MR. PETRUSIC: [Interpretation]

14        Q.   My question was, and I repeat it, could this document have --

15     could this document have left the Drina Corps with the signature of

16     General Ratko Mladic?

17        A.   According to the rules in the teleprinter station, it could not

18     have.

19        Q.   Mr. Pajic, when the officers were staying in the underground

20     facility, could you tell us how many officers would be in the operations

21     room, in room number 2?

22        A.   I don't know the exact number.  I know that General Miletic who

23     was there, that the operations duty officer would be there.  I would see

24     Captain -- was it Micic or Micevic I can't remember.  Colonel Sokanovic,

25     I would see him there occasionally, too.  Three, four, or five.  It

Page 28876

 1     depended.  I cannot give you a precise answer.

 2        Q.   And could each of them have answered and taken the receiver at

 3     155?

 4        A.   Yes, they could have.  Usually it was General Miletic, but if he

 5     left the room or go to another one, then the officer on duty -- or one of

 6     the officers.  Anyone could have answered the call if General Milovanovic

 7     was not there.

 8        Q.   Finally, your memories of October and -- September and October

 9     1995, do you know where the officers from the Main Staff Command were

10     staying?

11        A.   In September and October, once the bombing ceased, I can't

12     remember the date, I think that was at the end of September, they would

13     leave the underground facility and return to the so-called cabins, the

14     compound.  I don't know the exact date, whether it was the end of

15     September, the beginning of November; in any event, it was once the

16     bombing ceased.

17        Q.   And do you know that in September and the beginning of October,

18     some officers from the Main Staff went to another theater of war?

19        A.   Yes, at the western Krajina battlefront, some officers did go

20     there.  In the zone of the responsibility of the 2nd Krajina Corps.

21             MR. PETRUSIC: [Interpretation] I have no further questions,

22     Mr. President.

23             JUDGE AGIUS:  Thank you.

24             THE WITNESS: [Interpretation] Thank you.

25             JUDGE AGIUS:  Mr. Pajic, we have come to the end of your

Page 28877

 1     testimony.  We don't have any further questions for you, which means you

 2     are free to go.  Our staff will assist you and arrange your return back

 3     home.  Before you leave this courtroom, however, I want to make sure to

 4     wish you a safe journey back home and also thank you for having come over

 5     to give testimony.

 6             THE WITNESS: [Interpretation] Thank you.

 7                           [The witness withdrew]

 8             JUDGE AGIUS:  Mr. Petrusic -- Mr. Petrusic, you have five

 9     documents on the list.  It has been circulated.  Any objections from the

10     other Defence teams?  None.  Any objection from the Prosecution?

11             MR. VANDERPUYE:  No, Mr. President.

12             JUDGE AGIUS:  So these five documents are admitted.  I take it

13     there are no documents from any of the other Defence teams, in any case

14     it was only basically Mr. Krgovic putting some questions.

15             Mr. Vanderpuye, you have also five documents which have been used

16     in the course of your cross-examination.  Any objections, Mr. Petrusic?

17             MR. PETRUSIC: [Interpretation] No objections.

18             JUDGE AGIUS:  Thank you.  And I take it there are no objections

19     from the other Defence teams?  Hearing none, the decision is to admit

20     these documents as well.  And we move to the next witness.

21             Do you wish to make any statements before we start with the next

22     witness, Ms. Fauveau.

23             MS. FAUVEAU: [Interpretation] Mr. President, just as a matter of

24     caution it would be useful to inform the witness of his rights pursuant

25     to Rule 90(e) of the Rules of Procedure and Evidence.

Page 28878

 1             JUDGE AGIUS:  We are talking about of Ratko Miljanovic, aren't

 2     we?

 3             MS. FAUVEAU: [Interpretation] Yes, Mr. President.

 4             JUDGE AGIUS:  Okay.

 5                           [The witness entered court]

 6             JUDGE AGIUS:  Good afternoon to you, Mr. Miljanovic.

 7             THE WITNESS: [Interpretation] Good afternoon.

 8             JUDGE AGIUS:  And on behalf of the Trial Chamber, I extend a

 9     welcome to you.

10             THE WITNESS: [Interpretation] Thank you very much, Your Honours.

11             JUDGE AGIUS:  Very soon we will start with your testimony.

12     Before you commence, however, you are required by our rules to make a

13     solemn declaration that you will be telling us the truth.  If you read

14     that text that you are being shown now aloud, that will be your solemn

15     undertaking with us and that would be equivalent to an oath in several

16     jurisdictions.

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

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

19             JUDGE AGIUS:  I thank you, sir.  Please make yourself

20     comfortable.

21             Mr. Miljanovic, we, the four judges up here, have no idea at all

22     what questions will be put to you and by whom, except that we know for

23     sure that the Defence teams for General Miletic will surely be asking --

24     putting some questions to you, but they will be followed by others.

25             And we do not exclude, because we cannot, that there might be

Page 28879

 1     some questions which, if you answer truthfully, could possibly expose you

 2     to possible criminal proceedings.  I don't know, I am not tell you that

 3     this will be the case, because as I said I don't know what questions will

 4     be asked.  But if you feel that by answering truthfully any particular

 5     question, you may be incriminating yourself, you have a right to draw our

 6     attention to that and ask that you be exempted from answering such a

 7     question.

 8             This is not an absolute right.  We have the option and the right

 9     to grant you such exemption, but we can also decide to deny your request

10     and order you to answer such questions.  If we order you to answer such

11     questions, you have a further right under our rules and that is that

12     whatever you may say in replying to such incriminatory questions, cannot

13     be made use of later on in any proceedings that may be taken against you,

14     criminal proceedings, that may be taken against you by this Tribunal or

15     elsewhere.  Unless, of course, in answering such questions you are

16     rendering yourself responsible for perjury.  Is that clear enough to you?

17     Have I explained myself well?

18             THE WITNESS: [Interpretation] Yes, Your Honours.

19             JUDGE AGIUS:  All right.  I think Ms. Fauveau will go first.

20     Thank you.

21             MS. FAUVEAU: [Interpretation] Thank you, Mr. President.

22                           WITNESS: RATKO MILJANOVIC

23                           [Witness answered through interpretation]

24                           Examination by Ms. Fauveau:

25        Q.   [Interpretation] Sir, could you tell us your first and last name?

Page 28880

 1        A.   Your Honours, my name is Ratko Miljanovic.

 2        Q.   What's your educational background, what sort of schools have you

 3     finished?

 4        A.   I graduated from the secondary technical school in Gradanska?

 5             THE INTERPRETER:  In construction, interpreter's correction.

 6             THE WITNESS: [Interpretation] And then the military technical

 7     academy, the command staff tactical school, and the school for national

 8     defence, those are the schools that I have graduated from.

 9             MS. FAUVEAU: [Interpretation]

10        Q.   What position did you hold before the war in the former

11     Yugoslavia broke out?

12        A.   Before the war in the former Yugoslavia broke out, I was the

13     chief of the military gymnasium, Ivolola Ribar in the Yugoslav Peoples'

14     Army.

15        Q.   And before holding that position --

16        A.   Before that when graduating from the military technical academy,

17     I was the command of the platoon for technical maintenance and for

18     technical supplies, I was also an official for the technical department

19     in an infantry regiment.  Then, I was the deputy company commander for

20     technical maintenance of technical equipment.  It was in a logistic organ

21     and in a very large barracks.  And then I was the commander of a platoon

22     in the school for reserve officers who were within the technical service

23     of the Yugoslav Peoples' Army.  And then I was the chief of a class in

24     the military technical academy for the land army, the territorial army,

25     the land forces.

Page 28881

 1        Q.   Can you tell us where you were located when you were performing

 2     all the duties that you mentioned in your last question -- in your last

 3     answer?

 4        A.   The first position I mentioned, that of a platoon company in the

 5     position of the deputy commander for the maintenance service, well, those

 6     duties I performed in Skopje.  And then duties I performed in the

 7     military technical academy when I had the position as head of the Ivolola

 8     Ribar gymnasium, on those occasions, I was located in Zagreb.

 9        Q.   Have you ever served in Serbia?  Did you ever serve in Serbia

10     between -- before 1992?

11        A.   Your Honours, no, never.

12        Q.   Where were you when the war in the former Yugoslavia broke out?

13        A.   I was in Zagreb.  I was the head of the military secondary

14     school, Ivolola Ribar.

15        Q.   And how did you leave Zagreb?

16        A.   Your Honours, after our barracks in Zagreb had been under

17     blockade for three months, I left with a column of vehicles and men.  It

18     was a column of the -- from the military technical school of the land

19     forces of the Yugoslav Peoples' Army.  And this column set off from the

20     Zagreb to Karlovac, Banja Luka, Belgrade; and I then arrived in Krusevac

21     in Serbia.

22        Q.   You said that you were under a three-month blockade.  Did you

23     have any contact with the outside world during this period of time?

24        A.   Your Honours, during that period of time, and particularly

25     towards the end of that period, we had minimal contact which was under

Page 28882

 1     surveillance.  But otherwise, we had no communications, movement was

 2     restricted, food and water wasn't supplied.

 3        Q.   And one last question about this subject, who else was with you

 4     in the barracks during those three months?

 5        A.   Your Honours, in the barracks there were 13 professional officers

 6     who remained towards the end of that period, and there were 50 soldiers

 7     who remained there.  They were serving their military service, that's a

 8     total of 63 men.

 9        Q.   What position did you hold after having managed to leave Zagreb?

10        A.   I was appointed as commander of the secondary military technical

11     schools of the land forces.  At the time it was already within the Army

12     of Yugoslavia.

13        Q.   During this period, who was your immediate superior?

14        A.   My immediate superior officer was the late General Djukic.

15        Q.   Was General Djukic your immediate superior during the entire

16     period of time that you spent in Serbia or did this change at any point

17     in time?

18        A.   No.  He was my immediate superior until I left the army of --

19     until leaving to the army of Republika Srpska, somewhere around May 1992.

20     And of afterwards, my immediate superior was -- General, or maybe a

21     colonel I can't remember at the time, Ratomir Milovanovic.

22        Q.   When did you join the army of Republika Srpska?

23        A.   Your Honours, I joined the army of Republika Srpska on the 26th

24     of January 1993.

25        Q.   And why did you decide the join the army of Republika Srpska?

Page 28883

 1        A.   Well, I was born in Bosnia and Herzegovina.  My mother still

 2     lives in my place of birth, as well as my closest relatives, and I was

 3     sent from Bosnia, from my place of birth, to attend military schools.

 4        Q.   What positions did you hold in the army of Republika Srpska?

 5        A.   Your Honours, from the beginning until the end of my service in

 6     the army of Republika Srpska, I held position of the chief of the

 7     department for operations and logistics.  It was within the logistics

 8     section of the Main Staff of the army of Republika Srpska.

 9        Q.   And who was your immediate superior in the army of Republika

10     Srpska?

11        A.   My immediate superior in the army of Republika Srpska was

12     General Djukic.  Apart from when I represented him and performed his

13     duties, on that occasion my immediate superior was General Mladic.

14        Q.   We'll go back to that periods a little later.  You mentioned

15     General Mladic.  Did you know General Mladic before joining the army of

16     Republika Srpska?

17        A.   Your Honours, yes, I did know him.

18        Q.   Where did you meet him?

19        A.   I met General Mladic in a unit I had been assigned to having

20     graduated from the military technical academy in Skopje in 1970.  We

21     served together up until 1977.

22        Q.   Do you know General Miletic?

23        A.   Your Honours, yes, I do.

24        Q.   When did you meet him?

25        A.   I met General Miletic when I arrived in the Main Staff of the

Page 28884

 1     army of Republika Srpska.

 2        Q.   What position did General Miletic hold in 1995?

 3        A.   General Miletic was the chief of operations and training within

 4     the Main Staff of the army of Republika Srpska.

 5        Q.   And in 1995 who was the chief of the Main Staff of the army of

 6     Republika Srpska?

 7        A.   The chief of the Main Staff of the army Republika Srpska was

 8     General Milovanovic, Manojlo Milovanovic.

 9        Q.   Do you know where General Milovanovic was in the summer of 1995?

10        A.   General Milovanovic, in the summer of 1995, was involved in an

11     operation in Bosnian Krajina, I think.

12        Q.   And who was the chief of the Main Staff of the army of Republika

13     Srpska when General Milovanovic was in Krajina?

14        A.   General Milovanovic was always the chief of the Main Staff.  I

15     never met anyone else who held that position.

16        Q.   During this period in the summer of 1995, did you have any

17     contact with General Milovanovic?

18        A.   Your Honours, yes.  I did have contact with him on occasion.

19        Q.   I would now like to go into more details with regard to the

20     position that you held.  You said that you stood in for General Djukic

21     for a certain period of time, but before doing that who would replace

22     General Djukic when he was absent?

23        A.   When General Djukic was absent, and in performing daily duties at

24     the logistics command post, and in the sector for logistics of the Main

25     Staff, I would stand in for him.

Page 28885

 1        Q.   I should like to show you a document showing the structure of the

 2     Main Staff of Republika Srpska --

 3             MS. FAUVEAU: [Interpretation] And it is document P3178.

 4     Unfortunately, it is a Prosecution document which has not been translated

 5     into English.  Can we have page 13, please.

 6        Q.   What we can see at the bottom of this page.  Sir, I know that

 7     this is not a good copy, but does the end of this page actually relate to

 8     the logistics section?

 9        A.   Yes, Your Honour, it is the sector for logistics.

10        Q.   And here we see the name of Djordje Djukic.

11        A.   Yes.

12             MS. FAUVEAU: [Interpretation] Could we now go to the next page,

13     page 14.

14        Q.   Can you see your name on this page?

15        A.   Yes, I do see my name.

16        Q.   And just before your name, one can see the word "colonel," and

17     also the head and also the deputy assistant for logistics.  What does

18     this mean at the same time, "deputy assistant"?

19        A.   Your Honour, it says here in the first column:

20             "The organ for operation and logistics affairs."

21             And then after that, "(chief also deputy assistant commander for

22     logistics)."

23             And then in the next column headed "rank," it says "colonel."

24     And then in the next column, "family," father's name and first name.  And

25     in the second line it says, "Milijanovic, Tose, Ratko."  That's me.

Page 28886

 1        Q.   Could you explain what is in brackets, also deputy commander --

 2     deputy assistant commander for logistics.  What does this mean, could you

 3     explain what that means, please?

 4        A.   Your Honour, I shall try to explain in the way it was explained

 5     to me and how I understood my duty at the time.  If, as was my case, my

 6     position was the chief and at the same time deputy assistant commander

 7     for logistics, this means that I, who was appointed to this position, may

 8     deputize for the deputy commander for logistics in the performances his

 9     daily duties when he is physically absent at the command post for

10     logistics.

11              Also, that I may stand in for him with all the authority and

12     responsibility that is assigned to him with his position during the time

13     when he is prevented from performing his duties due to; for instance,

14     sickness, official travel, annual leave, and the like.  And if that

15     absence doesn't last longer than one month.  That is what this means.

16        Q.   You've already said that you represented General Djukic.  Could

17     you explain the situations in which you stood in for General Djukic?

18        A.   Your Honour, I stood in for General Djukic in the sense in which

19     I have just explained when he was prevented from performing his duties.

20     And this happened on a number of occasions for short periods of time when

21     he would officially travel to Serbia, or somewhere else, I didn't know

22     where.  And that is when I would stand in for him in performing his daily

23     duties.

24        Q.   Did you deputize for General Djukic for a longer period of time?

25        A.   No.

Page 28887

 1        Q.   Was there a period when General Djukic was sick?

 2        A.   Yes, Your Honours.  In the period from the end of March until the

 3     beginning of June 1995, General Djukic could not perform his duty because

 4     of illness and surgery and treatment.

 5        Q.   And what was your function during that period of time?

 6        A.   In that period of time, I performed my regular duties.  And by a

 7     decision of the command of the Main Staff, an order was written for me to

 8     stand in for General Djukic, and I was appointed to that position.

 9        Q.   What was the importance of that order, the order whereby you were

10     appointed?

11        A.   Your Honours, by this appointment, I was given the inalienable

12     right to decide about the use of effectives and materiel subordinated to

13     the assistant -- main commander for logistics, and also I had to bear

14     responsibility for any consequences that may arise as a result of such

15     use.

16             JUDGE AGIUS:  It's time for the for the break whenever it's

17     convenient.

18             MS. FAUVEAU: [Interpretation] I only have one more question on

19     this subject, Your Honour.

20             JUDGE AGIUS:  Then please proceed.

21             MS. FAUVEAU: [Interpretation] Thank you, Mr. President.

22        Q.   Did you obtain any personal privileges as a result of this order,

23     or benefits?

24        A.   Yes, Your Honours.  As opposed to the period when I stood in,

25     sort of automatically, for the General, when I represented him my salary

Page 28888

 1     increased.  I don't remember for how much.  The difference being between

 2     the salary that belonged to my position and the position held by

 3     General Djukic.

 4             MS. FAUVEAU:  [Interpretation] Mr. President, we can now have the

 5     break.

 6             JUDGE AGIUS:  That's what we will do.  25 minutes, please.

 7                           [The witness stands down]

 8                           --- Recess taken at 5.47 p.m.

 9                           --- On resuming at 6.15 p.m.

10             JUDGE AGIUS:  Yes, Ms. Fauveau.

11             MS. FAUVEAU: [Interpretation] Mr. President, I should just like

12     to clear up the subject that we discussed with respect to document B3038

13     [as interpreted], that we discussed with the previous witness.  I have

14     spoken to the Prosecutor, and he agrees that it -- that the document

15     comes from the Ministry of Defence of Republika Srpska.  We are not

16     challenging it, and I just wish -- I just wish to tell you that the

17     document came from Ministry of Defence.

18             JUDGE AGIUS:  Okay.  Thank you.  Let's bring in the witness,

19     please.

20                           [The witness takes the stand]

21             JUDGE AGIUS:  Yes, Madam Fauveau.

22             MS. FAUVEAU: [Interpretation] Thank you, Mr. President.

23        Q.   Sir, before the break, we were talking about situations when

24     General Djukic was prevented from exercising his duties.  What was the

25     situation when General Djukic was not at his post in Han Pijesak, but he

Page 28889

 1     was nevertheless somewhere in Republika Srpska?

 2        A.   Your Honours, General Djukic would frequently be absent from the

 3     command post for logistics performing other documents, in most cases in

 4     the field.  In those cases all subordinate organs in the sector for

 5     logistics performed their duties in accordance with the duties and in

 6     accordance with the instructions that he gave them from time to time.

 7             Therefore, in addition to my regular duties, I would also

 8     takeover some of his, and that meant receiving visitors, taking care of

 9     the duty officers at the command post for logistics, reviewing the

10     documents in the mail, signing documents which should have been signed by

11     him, and so on.

12        Q.   When you signed documents for General Djukic, how did you sign

13     them?

14        A.   At the beginning, that is, shortly after I joined the army of

15     Republika Srpska, this matter was not really regulated.  General Djukic

16     had not defined it, so that frequently we would put the word "for," and

17     then at a certain point in time he decided that this should not be done

18     any longer, and he instructed his subordinates that each person should

19     sign documents from their sphere of responsibility.  And if I signed

20     documents that he should have signed, I would have to put "deputy" or the

21     word "representing" and things like that.

22        Q.   And when General Djukic was not in Han Pijesak and documents

23     arrived which needed to be responded to, if there was a request that

24     arrived or something, what would happen?  Who would take the decision?

25        A.   Your Honours, General Djukic had, I can say, a permanent

Page 28890

 1     communication with the command post; and, therefore, with me too, so I

 2     would regularly inform him about the most important questions that needed

 3     to be dealt with while -- during his physical absence from the command

 4     post.  General Djukic, as a rule, gave instructions how a particular

 5     order should be written, what the content should be, and he virtually

 6     dictated such documents.  And his decision was always there.  It was

 7     always present.

 8        Q.   Was it possible for you to decide when General Djukic was

 9     somewhere else in Republika Srpska?

10        A.   Your Honours, that would be in contradiction with the basic

11     principle of single command, which applied in the armies I served in and

12     also contrary to the rules that I studied.  So that was not possible.

13        Q.   Who could issue orders to General Djukic within the army of

14     Republika Srpska?

15        A.   The immediate superior to General Djukic was the command of the

16     Main Staff, General Mladic, and he was the only one who could issue him

17     orders.  He was his superior.

18        Q.   In certain conditions, could someone else in the army of

19     Republika Srpska give orders to General Djukic?

20        A.   Only in the event that the commander of the Main Staff was

21     prevented from performing his duties and if someone else was standing in

22     his place, that is, the Chief of Staff.

23        Q.   Could you give us the name of the Chief of Staff, please?

24        A.   Your Honours, I've already said that the Chief of Staff was

25     General Manojlo Milovanovic.

Page 28891

 1        Q.   Have you had -- did you have opportunity to hear

 2     General Milovanovic giving orders to General Djukic?

 3        A.   Your Honours, I did attend one such conversation.  I was present

 4     there.  General Milovanovic called General Djukic and said something to

 5     him, I didn't hear what, and then General Djukic in my presence answered:

 6             "General, I am not your subordinate.  And remember once and for

 7     all that you cannot order me around."

 8        Q.   Where was the logistics centre of the Main Staff of the army of

 9     Republika Srpska headquartered?

10        A.   Your Honours, I am afraid I didn't get a good translation.  I

11     assume the question is where the command post was.  Could you please

12     kindly repeat your question?

13        Q.   The logistics sector.

14             JUDGE AGIUS:  Of the Main Staff, Madam Fauveau?  The logistics

15     centre of the Main Staff?

16             MS. FAUVEAU: [Interpretation] The logistics centre of the Main

17     Staff, yes.

18             JUDGE AGIUS:  Of the VRS.

19             MS. FAUVEAU: [Interpretation] Of the VRS.  The logistics sector.

20             THE WITNESS: [Interpretation] The logistic sector of the Main

21     Staff was deployed at the rear command post of the VRS in Han Pijesak.

22             MS. FAUVEAU: [Interpretation]

23        Q.   What other sectors and organs of the army of Republika Srpska

24     were based in Han Pijesak?

25        A.   In addition to the logistics sector and within the framework of

Page 28892

 1     the rear command post, there were also the following organs:  The sector

 2     for organisation, mobilization, and personnel affairs; a part of the

 3     organ for moral, religious, and legal affairs; I think that's what its

 4     name was, part of that sector; then the supreme court-martial and the

 5     prosecutor's office; the communications unit; and the encryption unit;

 6     also the department for air and technical security; a part of the organ

 7     for finances, and I hope I've listed all of them.  I may I have left some

 8     of them out.

 9        Q.   Could you explain for us the structure of the logistics centre?

10     What elements constituted the logistics sector?

11             JUDGE AGIUS:  Yes, Mr. McCloskey.

12             MR. McCLOSKEY:  Could we get a time-frame?  Because this is a

13     long period of time that we are talking about.

14             MS. FAUVEAU: [Interpretation]

15        Q.   In 1995, to avoid any confusion, when you spoke about the organs

16     that were in Han Pijesak which period were you referring to?  During

17     which period were these organs, these bodies, present there?

18        A.   Your Honours, I meant the entire period throughout which I was

19     staying at the rear command post between January 1993 and the end of the

20     war.

21        Q.   Could you now tell us what the structure of the logistics sector

22     was like in 1995, the logistics sector of the Main Staff?

23        A.   If we look at the logistics sector, it breaks down in the

24     following way:  The Department for Operations and Logistics, and I was

25     the one who headed that department, it's a department that we mentioned

Page 28893

 1     already.  There was the Technical Department, there was the Quarter

 2     Masters' Department, there was a Traffic Department, there was a Medical

 3     Department, there was a Veterinarian Department, and there was a

 4     Construction Department.

 5        Q.   And what did the section for operations and logistics look like?

 6     What were the tasks of the sector for logistics and operations?

 7        A.   Your Honours, the interpretation that I am receiving is the

 8     sector for operations and logistics.  I suppose the references is to the

 9     department; therefore, the department for operations and logistics had

10     its tasks prescribed.  Drafting plans for supporting units of the army of

11     Republika Srpska in terms of logistic was one of those.  This also

12     required an ongoing updating procedure.

13             Further, monitoring the operating of the logistics system of the

14     army of Republika Srpska.  Further, proposing measures to improve its

15     work and to make it more functional.  Further, activities to do with

16     organising and implementing the fire protection programme, protection at

17     workplace and protection of the environment in which we were staying.  We

18     were also supposed to monitor the combat readiness of the units and

19     institutions subordinate to the logistics head.  And also proposing

20     measures to improve that.

21             Further, participating in the production of the plan --

22     logistical plan, for any operations planned and carried out by the Main

23     Staff of the army of Republika Srpska.  Further, controlling the units

24     and institutions of the logistics department, participating in the

25     organisation and implementation of the monitoring [as interpreted]

Page 28894

 1     procedure that applied to combat readiness of the units of the army

 2     Republika Srpska as a whole.  As well as carrying out any other tasks or

 3     jobs ordered by the superior officer.

 4        Q.   With regard to the transcript, page 70, line 12 -- 17, we can see

 5     the word "monitoring" appear, did you say to "monitor" or to "follow"?

 6        A.   I said "following."

 7        Q.   How many subordinates --

 8             JUDGE AGIUS:  Yes, one moment.  Yes, Mr. McCloskey.

 9             MR. McCLOSKEY:  I think in the English that roughly means the

10     same thing, so if we are talking about -- and I know this is going from

11     French, but could we get a B/C/S word, because as you may recall

12     "monitoring" is a word used frequently in the indictment, but it's meant

13     in the normal English sense.

14             JUDGE AGIUS:  Thank you, Mr. McCloskey.  Madam Fauveau, I wasn't

15     following you in French I was following the translation, which word did

16     you use in French?

17             MS. FAUVEAU: [Interpretation] I used the words "surveillez" and

18     "suivre."  It's the difference between these two words.  Perhaps this

19     should be clarified once and for all.  Perhaps this could be done

20     tomorrow without the witness being present in the courtroom.

21             JUDGE AGIUS:  All right.  You agree to that, Mr. McCloskey?

22             MR. McCLOSKEY:  Yes, but if we could use the Serbian words I

23     think we would be better off.

24             JUDGE AGIUS:  And which would be the Serbian word?  Is that a --

25     is there a unitary word, single word for both concepts or do you still

Page 28895

 1     have to use two?

 2             MS. FAUVEAU: [Interpretation] Could the witness perhaps take his

 3     headset off.

 4             JUDGE AGIUS:  Can you remove your headset for a moment,

 5     Mr. Miljanovic.  And she will be using a word which probably isn't B/C/S

 6     which we will understand.

 7             MS. FAUVEAU: [Interpretation] In fact, I'd like to clarify this a

 8     little more, the word "monitor" used in English is translated as

 9     "surveillance" in French; and it's translated as "nadzer" or

10     "nadgledanje" in B/C/S.  The word, "suivre," which means following is

11     "pracinje [phoen]" in B/C/S, and the witness used the word "pracinje."

12             JUDGE AGIUS:  Did I use the other one as well, the one which

13     would reflect "surveillance" or "surveillez."

14             MS. FAUVEAU: [Interpretation] As far as I can remember, no,

15     Mr. President, he didn't, but I can ask the witness to clear the matter

16     up.

17             JUDGE AGIUS:  Okay.  Yes, Mr. McCloskey.

18             MR. McCLOSKEY:  I don't know how the indictment got translated.

19     When we said "monitoring" which word it was given, but it was meant in --

20     not in -- in monitoring, I believe from what I'm hearing, may be in the

21     term that one of the Yugoslav terms, it may be a military term; and I

22     just -- to clarify the indictment is not meant "monitoring" as a Yugoslav

23     military term, it's meant to "follow" or to "monitor."  It's common

24     lawyer English, if there is such a thing; and so this distinction that's

25     being made is really of no distinction.  We are not -- the indictment is

Page 28896

 1     not meant to be based on a Yugoslav military model.

 2             JUDGE AGIUS:  Anyway, okay, let's stop here on this and if

 3     necessary we will take it up again tomorrow.

 4             Yes, Madam Fauveau.

 5             MS. FAUVEAU: [Interpretation] Mr. President, I believe that this

 6     is a very serious question, because the accused has the indictment in

 7     B/C/S and the word used there is a translation of the word "surveillance"

 8     into B/C/S.  If you change the indictment, well, then our Defence case

 9     should change, too.  That's fine with me, but we then have to have a

10     break, have a pause in this case, and we would have to prepare ourselves

11     again.

12             JUDGE AGIUS:  Mr. McCloskey didn't like that.

13             Yes, Mr. McCloskey.

14             MR. McCLOSKEY:  We could all quit and come back in January, but

15     that's not --

16             JUDGE AGIUS:  And we won't be the first to do that.

17             MR. McCLOSKEY:  No.  As Ms. Fauveau knows, Serbian is not an

18     official language of the -- of the Tribunal, it's -- perhaps it should

19     have been, but what they are looking at is the Tribunal's -- the CLSS's

20     best guide on what that means.

21             Now, French is, so we may go get into a battle battles over

22     French in this issue, but we should not be in a battle over Serbian, and

23     I will have to bring in Ms. Soljan to help me out on the battle for

24     French, but I think we can see the issue.  But I think it's - as you

25     say - a tempest in a teapot.

Page 28897

 1             JUDGE AGIUS:  All right.  Let's proceed, and if we need to come

 2     back to this, we will.  He can put on the headset again.

 3             Mr. Miljanovic, have you been following what we were saying in

 4     English and in French?

 5             THE INTERPRETER:  Microphone for the witness, please.

 6             THE WITNESS: [Interpretation] Your Honours, I don't know French

 7     or English.

 8             JUDGE AGIUS:  Okay.

 9             THE WITNESS: [Interpretation] No.

10             JUDGE AGIUS:  Okay.  Thank you.  Ms. Fauveau.

11             MS. FAUVEAU: [Interpretation]

12        Q.   Sir, when you answered my question, did you at any point in time

13     use the word "surveillance, surveillez," "monitor"?

14        A.   No, Your Honours, I didn't use that term.  I ...

15        Q.   How many subordinates did you ever in your department in 1995?

16        A.   In 1995, within my department, there was a single post that was

17     filled, and that was me; therefore, I did not have a single subordinate

18     under me.

19        Q.   Do you know how many people should have been working in your

20     department?  According to the army structure, the army booklet on staff

21     composition, how many staff members should there have been in your

22     department?

23        A.   Your Honours, in my job in my career, I never dealt with those

24     issues that had to do with the organisation or establishment;

25     nevertheless, based on the name itself, on the term "department," what

Page 28898

 1     that means in our terminology, is roughly a squat, about ten people plus

 2     a head.  The sheer scope of that department's job would corroborate that

 3     figure.

 4        Q.   You mentioned the tasks that your department had.  Can you tell

 5     us what tasks the technical department had?

 6        A.   The technical department was in charge of a subsystem of

 7     logistics support, we call it technical support, in our army.  So they

 8     were in charge of this subsystem as it were.  Fundamentally, their tasks

 9     would be as follows -- I can't be expected to enumerate all of those.

10     They were there to supply equipment and material.  They were in charge of

11     maintenance as well.  They were supposed to supply those forms of energy

12     and fuel, stationery and other disposables or spare parts in the case of

13     equipment.  Those would be their paramount tasks, and I can't think of

14     any other ones right now.

15        Q.   Which department was responsible for ammunition?

16        A.   The technical department, didn't I say that?  Ammunition, mines,

17     explosives, they were in charge of all of these.

18        Q.   Was the position of commander of logistics a position that had a

19     duty post that was organised?  Was there a duty post in Han Pijesak?

20        A.   Your Honours, I am not sure I understand the question fully.

21             JUDGE AGIUS:  What don't you understand of it?  The question as

22     we have it at least in our transcript is the following:

23             "Was the position of commander of logistics a position that had a

24     duty post that was organised?  Was there a duty post for commander of

25     logistics in Han Pijesak?"

Page 28899

 1             We need to know what you don't understand.

 2             MS. FAUVEAU: [Interpretation] I think that there is a problem.

 3             JUDGE AGIUS:  All right.

 4             MR. McCLOSKEY:  There is no commander of logistics is one

 5     problem.

 6             JUDGE AGIUS:  Yes, but this is what I was reading what we have in

 7     the transcript.

 8             Ms. Fauveau, if you could rephrase your question, we would be

 9     happy to proceed.

10             MS. FAUVEAU: [Interpretation]

11        Q.   Was there a post, a duty officer post, in Han Pijesak?

12        A.   Yes, I've understood the question.  There was at the rear command

13     post, and it was called the Operations Duty Officer at the Rear Command

14     Post.

15        Q.   Which officers occupied the post of duty officer at this command

16     post, this logistics command post?

17        A.   This position was occupied by officers from all the various

18     structures deployed at the rear command post apart from communications

19     detachment, but they had shifts, they were all engaged.

20        Q.   Did officers from logistics sector have duty officers at the Crna

21     Rijeka command post?

22        A.   Yes, for a while.  There were a number of officers who were

23     posted to the rear command post, and they continued to exercise their

24     duties there in Han Pijesak.  But then they were resubordinated to

25     operations duties in Crna Rijeka.

Page 28900

 1        Q.   Could you tell us, with regard to General Djukic, could give

 2     orders as assistant for logistics?  To whom could General Djukic give

 3     orders?

 4        A.   General Djukic could give orders to all of his subordinate

 5     officers within the sector as well as units and institutions that were

 6     subordinated to him.  Under the rules of command - I am not sure if my

 7     term is right - as assistant commander of the Main Staff of the army

 8     Republika Srpska, he could - at least in terms of logistics - also

 9     exercise command over corps and other units of the army.

10        Q.   I would first of all like to discuss in the subject of

11     subordinate units.  Which units were subordinate ones in the logistics

12     sector of the Main Staff?

13        A.   The assistant for logistics at the rear bases that were

14     subordinate to him.  There was also the vehicle transportation battalion,

15     the military hospital, the military medical centre at Banja Luka, the

16     Krajina military institution, the overhaul at Kosmos, the Orao overhaul

17     unit, the Hadzici overhaul unit, the automatic data processing centre, I

18     guess that's what the name was, anyway it was in Banja Luka, the military

19     book keeping centre.  I think that one was there too.  That would be it

20     for the most part.  I may I have omitted one or two whose names escape me

21     right now.

22        Q.   You mentioned an auto battalion, do you know where this battalion

23     was located?

24        A.   Yes, I know about that.  The vehicle or auto battalion, when I

25     first arrived in the army of Republika Srpska, was somewhere near

Page 28901

 1     Sokolac.  It was stationed in that area.  At a later stage, it was moved

 2     to a location near Zvornik.  There was a factory there, whose name I

 3     can't remember, but it was stationed within the factory compound.

 4        Q.   Did these subordinate units, subordinate to the logistics sector,

 5     send daily reports?

 6        A.   Yes.  All of the units subordinated to General Djukic submitted

 7     regular combat reports, and this applied to all the other army units.

 8        Q.   And to whom were these reports addressed?

 9        A.   The reports came directly from these units to General Djukic at

10     the rear command post.

11        Q.   Now I would like to clarify something that you said a minute ago,

12     page 77, line 4 and line 5.  You said that with regard to logistics,

13     General Djukic could give the corps orders.  Could you clarify that?

14        A.   Your Honours, when I said that, what I meant was this:

15     General Djukic, regarding any issues that had to do with the logistics

16     support or any issues regarding -- what shall I call them?  Instructions,

17     procedures on procedures, he had the power to prescribe rules in relation

18     to these for the entire army and also to order -- order the

19     implementation thereof.

20             By way of an example, instructions on the storing and handling of

21     ammunition and explosives.  He could have issued an order on that and all

22     the units would have been duty-bound to implement and follow his

23     instructions.  So this would be an example of a logistics job where he

24     had the power to give orders.

25             JUDGE AGIUS:  Okay.  Any time it's convenient, unless you have

Page 28902

 1     further questions on this sector?

 2             MS. FAUVEAU: [Interpretation] Two minor questions.

 3             JUDGE AGIUS:  Okay.  Yes.

 4             MS. FAUVEAU: [Interpretation]

 5        Q.   Did the corps send reports to the logistics sector?

 6        A.   Yes.  All of the corps including the airforce and the airforce

 7     command submitted to the rear command post what we refer to as a

 8     logistics report -- or, rather, a report to the logistics support.

 9             MS. FAUVEAU: [Interpretation] Mr. President, if you like, we

10     could stop here.

11             JUDGE AGIUS:  Yes, thank you, Ms. Fauveau.

12             Mr. Miljanovic, we are going to stop here for today.  We will

13     continue tomorrow morning at 9.00.  In the meantime between now and

14     tomorrow please do not allow anyone to communicate with you or you

15     discuss with anyone the subject matters of your testimony.

16             THE WITNESS: [Interpretation] I understand, Your Honour.

17             JUDGE AGIUS:  Okay.  Thank you.  We stand adjourned until

18     tomorrow morning at 9.00.  Thank you.

19                           --- Whereupon the hearing adjourned at

20                           6.58 p.m., to be reconvened on Thursday, the

21                           27th day of November, 2008, at 9.00 a.m.