Tribunal Criminal Tribunal for the Former Yugoslavia

Page 19555

 1                           Tuesday, 22 May 2012

 2                           [Open session]

 3                           [The accused entered court]

 4                           --- Upon commencing at 9.09 a.m.

 5             JUDGE ORIE:  Good morning to everyone in and around this

 6     courtroom.

 7             Madam Registrar, would you please call the case.

 8             THE REGISTRAR:  Good morning, Your Honours.

 9             This is the case IT-03-69-T, The Prosecutor versus

10     Jovica Stanisic and Franko Simatovic.

11             JUDGE ORIE:  Thank you, Madam Registrar.

12             I have one brief preliminary matter.

13             There was a list of exhibits the Prosecution would like to

14     introduce in the context of the cross-examination of Witness Milosevic.

15     That list has now been verified, and I do think that on that list there

16     are 13 documents or 13 items which are sought to be MFI'd for the time

17     being.

18             Madam Registrar, would you please so kind to make a list of those

19     13 provisionally assigned numbers so that the Defence can express itself

20     on admission.

21             THE REGISTRAR:  Yes, Your Honour.

22             JUDGE ORIE:  Thank you, Madam Registrar.

23             Then I'd like to briefly turn into private session.

24                           [Private session]

25   (redacted)

Page 19556











11 Pages 19556-19558 redacted. Private session.
















Page 19559

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 5   (redacted)

 6   (redacted)

 7   (redacted)

 8                           [Open session]

 9             THE REGISTRAR:  We're in open session, Your Honours.

10             JUDGE ORIE:  Thank you, Madam Registrar.

11             Mr. Petrovic, your next witness will be ...

12             MR. PETROVIC: [Microphone not activated]

13             [Interpretation] Our next witness is Rade Vujovic.

14             JUDGE ORIE:  Thank you, Mr. Petrovic.

15             Could the witness be escorted into the courtroom.

16                           [The witness entered court]

17             JUDGE ORIE:  Good morning.

18             THE WITNESS:  Good morning, sir.

19             JUDGE ORIE:  Mr. Vujovic, I take it.

20             Mr. Vujovic, before you give evidence, the Rules require that you

21     make a solemn declaration.  The text is now handed out to you by the

22     usher.

23             May I invite you to make the solemn declaration.

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

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


Page 19560

 1                           WITNESS:  RADE VUJOVIC

 2                           [Witness answered through interpreter]

 3             JUDGE ORIE:  Thank you.  Please be seated.

 4             Mr. Vujovic, before you'll be examined by the parties, I have to

 5     raise a matter about protective measures.

 6             We've heard from counsel for Mr. Simatovic that you personally do

 7     not seek any protective measures.  On the 8th of May of this year, the

 8     Republic of Serbia has requested protective measures; most important,

 9     they were seeking closed session, and that your identity be protected at

10     all times.

11             Now, in line with the common practice of this Chamber, we have

12     denied Serbia's request for the protective measures as sought, but, at

13     the same time, we would like to instruct you, and I similarly instruct

14     the parties, that you should ask for private session - therefore, the

15     evidence not to be heard in public - if the question or if your answers

16     would reveal the identity of, one, a BIA source; or if it would reveal

17     the identity of a BIA operative; or, third category, a location used by

18     the BIA.  So if that would be part of your answer, we would invite you to

19     go in private session.

20             In addition to these three category, if specific technical means

21     used by the BIA would be touched upon in your answer or in the questions,

22     and that is, technical means, specific technical means used for

23     intelligence-gathering purposes, then we would also like you to ask for

24     private session so that this information, BIA, source, BIA operative,

25     BIA location or specific technical means would be discussed.


Page 19561

 1             Is that clear to you?

 2             THE WITNESS: [Interpretation] Yes.

 3             JUDGE ORIE:  Madam Registrar, you are hereby instructed to inform

 4     the Republic of Serbia of the decision by the Chamber.

 5             Mr. Petrovic, are you ready?

 6             MR. PETROVIC: [Interpretation] Yes, Your Honour.

 7             JUDGE ORIE:  Yes.  Before I give you an opportunity to start, I

 8     do understand that the witness has asked for a piece of paper and a pen

 9     so that he can make notes when being examined.  I take it that there's no

10     problem with that, Ms. Friedman, Mr. Jordash.

11             So, therefore, could someone provide the witness with a pen and

12     paper.

13             Mr. Vujovic, you will first be examined by Mr. Petrovic.

14     Mr. Petrovic is counsel for Mr. Simatovic.  And if at any time you would

15     need a break or any rest, don't hesitate to address me.

16             Please proceed, Mr. Petrovic.

17             MR. PETROVIC: [Interpretation] Thank you, Your Honours.

18                           Examination by Mr. Petrovic:

19        Q.   [Interpretation] Good morning, Mr. Vujovic.  Could you please

20     tell us your name for the record as well as the date and place of your

21     birth?

22        A.   My name is Rade Vujovic.  I was born on 3rd of March, 1952, in

23     Djakovica.

24        Q.   Could you please tell us where you went to the elementary school

25     and secondary school?

Page 19562

 1        A.   I went to the elementary school in Pec and then I graduated from

 2     the grammar school in Belgrade, and also from the university in Belgrade

 3     with a degree in technical sciences.

 4        Q.   You say that you graduated with a degree in electrical

 5     engineering.  What was your speciality?

 6        A.   It was electronics.

 7        Q.   Did you serve in the army, in the JNA?

 8        A.   Yes.  That was in 1978 and 1979.

 9        Q.   Could you please tell us what was your first job?

10        A.   After I graduated, I taught at the secondary school, Rade Koncar,

11     in Belgrade.

12        Q.   Did there come a time when you joined the State Security Service?

13        A.   That was in 1980.  I started working at the

14     Federal Secretariat of Internal Affairs at the State Security Department.

15        Q.   What was your position in the state security?  When you first

16     joined, what was your first position?

17        A.   I started working as a junior engineer.  That was the entry

18     position.

19        Q.   Which organisational unit did you join when you started working

20     at the state security?

21        A.   That was the administration for the application of operative

22     technique with -- in the State Security Department of the

23     Federal Ministry of Internal Affairs.

24        Q.   After that, after having been a junior engineer, how did your

25     career evolve?  What other positions did you occupy?

Page 19563

 1        A.   First, I was a junior engineer, then I was an associates

 2     engineer, an independent engineer, the chief engineer, and then when I

 3     joined the federal service I was the chief of the first department in the

 4     7th Administration, which was the administration for the application of

 5     operative techniques.

 6        Q.   Did there come a time when you became an employee of the

 7     State Security Department of the Republic of Serbia?

 8        A.   Yes.  That was in 1992 when there was a merger between the

 9     federal MUP and the republican MUP.  Then I joined the MUP of Serbia, its

10     security department.

11        Q.   When you joined, what was your position in the Serbian MUP?

12        A.   The same position.  I remained the chief of the first department

13     in the 7th Administration.

14        Q.   Did there come a time when you were promoted within the

15     State Security Department in the Republic of Serbia?  Were you assigned

16     other duties and tasks?

17        A.   I was there from 1992 until 1994 as the chief of department.  And

18     then I was appointed the chief of administration.

19        Q.   Did there come a time when you left your position in the

20     State Security Department of the Republic of Serbia?

21        A.   In 1998, something happened.  There was a shake-up.  The

22     then-chief of the security department, Mr. Stanisic, was removed, and I

23     was also removed from my position as the chief of administration, and I

24     was appointed the chief of section in the state security.  I did not

25     accept that position and I simply resigned.

Page 19564

 1             MR. PETROVIC: [Interpretation] I apologise, the record is not

 2     really clear.

 3        Q.   That new post which you were assigned, where was that?

 4        A.   That was part of the public security department.

 5        Q.   Did you remain in that position to which you were assigned in the

 6     public security?

 7        A.   No.  I resigned.  And I left the MUP of Serbia.

 8        Q.   What did you do then?  When you left the MUP of Serbia, what did

 9     you do?

10        A.   For the next three years, I worked for a company that represented

11     Motorola in Serbia.  It was a privately owned company.

12        Q.   Did there come a time when you joined the MUP of Serbia again,

13     i.e., when you rejoined the state security sector?

14        A.   In 2001, the newly appointed chief, Andrija Savic, invited me to

15     an interview and he asked me whether I would be interested in joining the

16     new management team of the State Security Department.  He wanted me to be

17     a member of that team.  I agreed.  And then he informed me that

18     Prime Minister Djindjic gave his consent, and then I rejoined the

19     department as the deputy chief for operative equipment.

20        Q.   How long did you work for the State Security Department?

21        A.   I remained there until 2005.  And in the meantime I was appointed

22     the chief of security institute, and then in 2005, I was pensioned off at

23     my request.

24        Q.   Did there come a time when the State Security Department was

25     transformed and became a different agency?

Page 19565

 1        A.   The department was part of the Ministry of Internal Affairs until

 2     2002, and then it was reorganised, and the State Security Department

 3     left, as it were, the MUP, and it became a special agency.  And from

 4     then, its name was security and information or intelligence agency.

 5             JUDGE ORIE:  Ms. Friedman.

 6             MS. FRIEDMAN:  Your Honours, we are in private session, I'm not

 7     sure if there's a reason for that.

 8                           [Trial Chamber and Registrar confer]

 9             JUDGE ORIE:  The Registry is of the opinion that we're not in

10     private session.

11             MS. FRIEDMAN:  I'm sorry, I'm misinformed then.

12             JUDGE ORIE:  Please proceed.

13             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

14        Q.   Thank you, Mr. Vujovic.

15             After having dealt with your CV, I would like to put a few

16     specific questions to you in relation to your work while you were still

17     employed there.

18             While you worked in the federal ministry dealing with operative

19     equipment, as far as the application of this equipment is concerned, what

20     was it that was actually done by the federal security service?

21        A.   Generally speaking, this kind of work with operative equipment

22     falls into two groups:  One is the offensive group, if you will, and the

23     other one is the defensive work -- group.

24             Offensive is the work that is done in order to collect

25     information and then document that, TV, video, et cetera, so that is one

Page 19566

 1     group of this kind of work.

 2             Another group that is also very important, and a lot of people

 3     work on that, too, has to do with defensive work, if you will:

 4     Anti-sabotage, sanitary, chemistry biological protection, electronic

 5     protection of buildings, mechanical protection, and so on.

 6        Q.   The federal State Security Service what kind of relationship did

 7     it have with the security services in the republics and provinces in

 8     terms of functionality?  Was it based on subordination?  Was it a

 9     different kind of relationship?  Could you please tell us what it was

10     like.

11        A.   Well, I cannot say that it was a classical relationship of

12     subordination.  It was co-ordination and guidance; primarily

13     co-operation, accommodation of views, and so on.

14             However, the federal service worked independently within its own

15     purview, and I'm talking about the field of operative equipment.

16        Q.   What was the work that was done independently at federal level?

17        A.   As far as operative equipment was concerned, it was the

18     application of all measures, offensive and defensive.  All of that was

19     done independently.

20        Q.   As far as operative measures are concerned that were applied by

21     the federal service, which structures were the subject of interest of the

22     federal service, as far as operative measures were concerned?

23        A.   In the organisation of the state security, in the SFRY, while

24     that state was still in existence, the federal service was primarily

25     oriented towards diplomacy.  So, as far as offensive measures were

Page 19567

 1     concerned, that had to do with the diplomatic, and it was basically

 2     focussed on the territory of Belgrade.

 3        Q.   Up until 1991, can you tell us how senior personnel were

 4     recruited in the federal service?  Up until 1991.

 5        A.   All the republics and provinces had to be represented properly in

 6     senior posts, so basically all the senior personnel came from the

 7     different republics and provinces.

 8        Q.   Can you tell us until when the senior personnel who came from

 9     republics that had opted out of Yugoslavia remained in their positions in

10     the State Security Service?

11        A.   Up until 1992.  One day, basically they all left Belgrade.

12        Q.   Can you tell us what the situation was in the federal service

13     after senior personnel from the cessationists republics left?

14        A.   Well, objectively speaking, we were in a state of vacuum, a state

15     that had not been fully defined.  We were simply waiting to see what

16     would happen.

17        Q.   In that period, after they had left, could you tell us what these

18     senior posts were, that were vacated by the people who left?  Were these

19     significant positions or --

20        A.   People from the republics were appointed to the most senior

21     positions.  Zdravko Mustac, a Croat, headed the service itself and then

22     the head of the important department, the first one, was a Slovene and

23     then the head of the analytical department also hailed from a different

24     republic.  So the people who were from Serbia stayed on, but the others

25     who, in my view, held the key positions in state security hailed from

Page 19568

 1     different republics, those that had left the SFRY and these persons left

 2     too.  They returned to their republics.

 3        Q.   You say that the key senior personnel left, and you referred to

 4     this vacuum that remained in the service.  How did this reflect on the

 5     everyday functioning of the service, defining tasks, managing work as

 6     such?

 7        A.   Well, we continued on the basis of inertia.  We stayed in the

 8     buildings where we were, but all of us who stayed on in the federal MUP

 9     realised that the role of the federal service had to be redefined.  The

10     situation was a completely new one.  This state was no longer in

11     existence.  And what had to be defined was what this new federal service

12     was supposed to be; if it were to stay on in the first place.

13        Q.   As the Federal Republic of Yugoslavia was established in

14     April 1992, were security services brought together at the level of the

15     Federal Republic of Yugoslavia?

16        A.   No.  This period of vacuum continued.  We all discussed this, and

17     we received some information to the effect that the key question was the

18     decision of Montenegro as a federal unit, in terms of whether they wanted

19     to take part in the restructuring the State Security Service or not, and

20     it went back and forth:  They wanted to; they didn't want to.  And these

21     discussions took place basically on a daily basis.  It went on for a very

22     long time.  Too long, in my view.

23        Q.   This period that you've been talking about, the period of vacuum,

24     as you call it, in very practical terms, how many services were there in

25     the territory of the Republic of Serbia that were doing the same kind of

Page 19569

 1     work or almost the same?

 2        A.   That was a paradox.  In the territory of Serbia, you had two

 3     State Security Services that were doing the same kind of work or similar

 4     work.  In addition to that, you also had a service that independently

 5     took measures in the territory of Serbia.  So for who?

 6        Q.   In this period of time, the federal State Security Service, in

 7     this period of vacuum that you referred to, did it have any kind of

 8     powers in the territory of the Republic of Montenegro?

 9        A.   No.  We could not act independently in the territory of the

10     Republic of Montenegro.  I'm referring to operative equipment.  In the

11     territory of Belgrade, we acted independently.

12        Q.   Is it normal, customary, is that the usual thing for there to be

13     two parallel services in the territory of one and the same country

14     dealing with the same kind of work or similar work?

15        A.   Of course, no such thing existed anywhere.  And that is absurd.

16     It's wrong.

17        Q.   Mr. Vujovic, at one point in time, did the federal service and

18     the service of the Republic of Serbia merge?

19        A.   In the Autumn of 1992, these two services merged.

20        Q.   Can you tell us what that looked like in your very own case, from

21     the point of view of your very own job?

22        A.   What do you mean exactly?

23        Q.   Did you leave your office?  Was your documentation taken over?

24     Were you expelled?  Did you lose your job?  What did it look like?

25        A.   None of the above.  In my specific case and in my department, as

Page 19570

 1     well, in the morning we had collegium meetings.  I came to work.  We had

 2     a collegium meeting of our department.  Our superior told us that the

 3     decision had been made concerning this merge, and that we should see how

 4     people should work and how jobs should be distributed and what kind of

 5     work should be given to the people would come from the republic, and so

 6     on.

 7        Q.   Did anyone take over your work documentation?  Were you banned

 8     from any of the premises that you used for your daily work?

 9        A.   No.  That did not happen to me, and it didn't really happen to

10     anyone within the 7th Department.

11        Q.   On that occasion, was anybody expelled from the

12     State Security Service?  Did they lose their jobs?  Were they dismissed?

13        A.   No.  It was stated straight away that everyone would be given a

14     job offer within the State Security Service of Serbia and that everyone

15     would receive an offer to go on doing the work they had been do doing

16     until then.  And that's exactly what was done.

17             As far as I know, and I know definitely what was happening in my

18     department, not a single person was dismissed, removed, whatever you wish

19     to call it.

20        Q.   Your department was integrated with which part of the

21     State Security Service of Serbia?

22        A.   Well, they had an organisational unit of their own that dealt

23     with operative equipment.  And as the merge took place, these two units

24     of ours also merged.

25        Q.   On that occasion, did you get a new boss; or your colleagues from

Page 19571

 1     the republican service, did they get a new boss when the two services

 2     merged?

 3        A.   Well, you know what?  Within the former SFRY, the operative

 4     equipment of the federal service, due to the nature of the work it dealt

 5     with and in general terms everything it did, it was certainly the most

 6     highly developed compared to all the other republican services, including

 7     the Serbian one.  So the people working in the Serbian department

 8     simply -- were simply redeployed in our service.

 9             I was the head of the department for the application of operative

10     equipment, and I stayed on in that position.  So no one within the

11     7th Department was removed from the positions they had held.

12        Q.   What happened with the head of the department for operative

13     equipment from Serbia?

14        A.   Some of the people from the republic did not come to work with

15     us.  Some of them were transferred to work on teaching jobs in the

16     institute, and their head was appointed advisor.  So he did not really

17     join our service, our part of the service.

18        Q.   Thank you, Mr. Vujovic.

19             You have just mentioned offensive and defensive measures, i.e.,

20     the application of offensive as opposed to defensive measures.

21             Can you just briefly tell us what measures would be offensive

22     measures?

23        A.   In our division, and I believe it is a generally used division

24     for this part of the service, offensive measures are those measures that

25     lead to obtaining intelligence, and that implies interception of all

Page 19572

 1     sorts of communications.  That also includes documentation, photographic

 2     documentation, and things like that.

 3             So that would be the category of offensive measures of operative

 4     equipment and methodology.

 5        Q.   And now, what about defensive measures?  What would be the

 6     defensive measures of operative work?

 7        A.   It is a range of measures which is within the purview of the

 8     State Security Department, and it applies to the protection of facilities

 9     and individuals, as prescribed by the law.  That's measures against

10     interception, against biological, chemical protection, technical

11     security, electronic security, mechanical security.

12             So those would be defensive measures.

13        Q.   Mr. Vujovic, you spent your career in the State Security Service.

14     What is the principle of confidentiality in the State Security Service

15     and similar services?

16        A.   I believe that everywhere in the world such services are

17     organised in a very similar, if not identical, manner and the principle

18     of confidentiality applies everywhere.  This is one of the basic

19     principles that is used in every service.

20        Q.   What does that principle mean in more specific terms?  Let me

21     give you an example:  One operative, does he have to know about the work

22     and conducts of another operative?  How does that principle apply to that

23     level of the service?

24        A.   In principle, things like that do not happen unless there is

25     specific interest in exchanging information.  When I say interest, I mean

Page 19573

 1     operative interest.

 2             When it comes to operative equipment and methodologies used, the

 3     7th Administration was a very complex administration in terms of its

 4     structure, and in view of the obligations it had, and within the

 5     administration itself, the principle of confidentiality and protection

 6     was strictly adhered to.  Within the 7th Administration, nobody who, for

 7     example, dealt with biology, chemistry or counter-division and sabotage

 8     was able to know what the first department was involved in.

 9        Q.   Within the service, who is it who defines the need to collect

10     intelligence by using operative equipment?

11        A.   There are linings of work, counter-intelligence, intelligence,

12     then there's also a group that was involved in extremism and

13     counter-terrorism and there was also a group that was involved in the

14     protection of facilities and individuals.

15             What I'm saying is that operative lines defined the need to use

16     and apply operative equipment and methodologies.

17        Q.   In the specific situation, how would that look?  For example, if

18     an operative learns that he needs to use operative equipment, what does

19     he have to do in order to apply an operative methodology measure?

20        A.   The document that allowed us to apply a certain measure was a

21     decision by the president of the Supreme Court.  Before that decision was

22     issued, there was a chain of actions that had to take place in various

23     operative administrations, which means an operative would give his

24     proposal, that goes to the chief, that, again, goes to the chief of

25     administration.  So there is a whole chain of decision-making, and the

Page 19574

 1     last person was chief of department, and that -- those were all proposals

 2     which were sent to the president of the constitutional court of Serbia

 3     who made the final decision involving a national of Serbia.

 4        Q.   Mr. Vujovic, I would like to clarify -- to ask you two things:

 5     Could you please speak more slowly for the benefit of the interpreters;

 6     and, secondly, could you specify the court in question.

 7             Who had the final say?  The president of which court had the

 8     final say when it came to the application of operative equipment and

 9     measures?

10        A.   The president of the Supreme Court.

11        Q.   Mr. Vujovic, the president of the Supreme Court, did he have an

12     office within the service; and did he perform his duties in that office?

13        A.   Pursuant to Mr. Stanisic's decision, in our building, there was

14     an ex-territorial space, as it were.  That was an office to which only

15     the president of the Supreme Court had a key.  He had his office, and he

16     had his documents there, and he was the only person who could

17     independently avail himself of that space.

18        Q.   You have just explained what measures were applied when they were

19     applied against citizens of the Federal Republic of Yugoslavia or the

20     Republic of Serbia.

21             Was the same procedure applied against foreign nationals?

22        A.   In keeping with the interpretation of the president of the

23     Supreme Court, he was not authorised to decide on measures against

24     foreign nationals.  When it came to foreign nationals, the decision was

25     signed by the minister of the interior.

Page 19575

 1        Q.   You have mentioned a procedure that had to be complied with in

 2     the matters of applying operative equipment and -- and -- and measures.

 3     Were there any exceptions to that general rule?  And the rule was that

 4     the president of the Supreme Court of Serbia issued decisions applying to

 5     Serbian nationals, and the minister of the interior issued decisions

 6     applying to foreign nationals.

 7             Were there any exceptions to that principle or to that rule?

 8        A.   A decision of the president of the Supreme Court was always

 9     necessary.

10             However, there were such cases which were urgent, and the

11     procedure could not be complied with fully.  Then chiefs of state

12     security centres had the right to issue a temporary measure that was

13     valid for seven days, not longer.  And that was done in order not to lose

14     something that was of some importance for the service.

15             However, during that period, they were duty-bound to launch the

16     procedure leading to the decision by the president of the Supreme Court.

17     That decision always had to issue -- always had to be issued.  However,

18     when the matter was urgent, temporary measures could be instituted,

19     pending that decision.

20        Q.   Mr. Vujovic, operative equipment and measures, when certain

21     intelligence was obtained, what would operatives do with that

22     intelligence?

23        A.   The result of offensive application of operative equipment was

24     intelligence.  The intelligence would be sent from the administration to

25     the body that requested the application of operative equipment and

Page 19576

 1     measures.  The -- what happens to that intelligence after that is not

 2     something that interested the operatives in question.

 3        Q.   When it comes to operative equipment and measures, will -- were

 4     operatives interested in the contents of the intelligence obtained?

 5        A.   Absolutely not.

 6             MR. JORDASH:  May we take an early break, Your Honour, please.

 7             JUDGE ORIE:  We take an early break.  I take it there are good

 8     reasons for that.

 9             MR. JORDASH:  There are.  And it's one of the usual complaints.

10             JUDGE ORIE:  Yes.

11             We'll take a break, and we'll resume at 10.30.

12                           [The witness stands down]

13                           --- Recess taken at 10.03 a.m.

14                           [The witness takes the stand]

15                           --- On resuming at 10.36 a.m.

16             JUDGE ORIE:  Mr. Petrovic, please proceed.

17             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

18        Q.   Mr. Vujovic, we were just discussing the procedure that needs to

19     be adhered to when it comes to the application of technical measures.

20             Tell us, to apply technical measures in respect of a national of

21     ours who is abroad, does that also require an approval to be issued by

22     the Supreme Court?

23        A.   Well, for our nationals, yes.  For those who are abroad, a

24     document had to be issued by the president of the Supreme Court.

25        Q.   Tell us, in respect of an individual who is to have measures

Page 19577

 1     applied in -- in his respect, should that individual go abroad?  Would it

 2     be standard practice for these measures to continue to be applied in

 3     respect of that individual even if he is now abroad?

 4        A.   Yes.

 5        Q.   Does any sort of approval have to be obtained for conducting

 6     surveillance over the radio, be it at home or abroad?

 7        A.   When it comes to radio communication, and where intelligence

 8     needs to be obtained in an area that is outside of the territory of the

 9     Republic of Serbia, that, too, would require an approval.

10        Q.   Can you tell us what lines of work within the service requested

11     the use of technical equipment?

12        A.   Well, the basic lines:  Intelligence, counter-intelligence,

13     terrorism, and protection from terrorism, as well as the unit - and I

14     think it was the sixth unit - which was charged with protection of

15     persons or vital facilities.

16        Q.   Let us go back to a question that I put to you a moment ago.

17     When it comes to radio surveillance at home or abroad - we're talking

18     about free radio communication - would the president of the Supreme Court

19     require to be informed of it and issue an approval in respect of that?

20        A.   No, that was not required.

21        Q.   Tell us, based on whose instructions would the measures of

22     operative work be conducted, and I mean within the 7th Department?

23        A.   When it comes to the application of technical measures, it fell

24     solely within the purview of the 7th Department; that's to say, the

25     department for operative equipment.  And, of course, it would be the


Page 19578

 1     operative service itself that would deal with protection of individuals.

 2             There is a certain stage in the application of these measures

 3     where you have to have the closest of terms between the operative and the

 4     operator of these technical measures, because, of course, the operator

 5     would require input from the operative who is working on a particular

 6     case as to what his wishes are.

 7             MR. PETROVIC: [Interpretation] Your Honour, I am now about to

 8     show certain documents to the witness that require us to move into

 9     private session, so can we please do that.

10             JUDGE ORIE:  We move into private session.  And the documents not

11     to be shown to the public.

12             MR. PETROVIC: [Interpretation] Yes, Your Honour.

13                           [Private session]

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19579











11 Pages 19579-19584 redacted. Private session.
















Page 19585

 1   (redacted)

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 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18                           [Open session]

19             THE REGISTRAR:  We're in open session, Your Honours.

20             JUDGE ORIE:  Thank you, Madam Registrar.

21             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

22        Q.   Mr. Vujovic, we're going back to the conversation about 1991.

23             Tell us, please, the employees of the federal service of the DB,

24     were they sent to the area of conflict in 1991?

25        A.   Yes.  Groups were established on the basis of ministerial


Page 19586

 1     decision and people were being sent to areas where more serious incidents

 2     had occurred in that period of time.

 3        Q.   Tell us, please, while you worked in the federal service of the

 4     DB, did you ever report to the higher echelons of the

 5     State Security Service or the higher echelons of the ministry itself?

 6        A.   I submitted different reports.  There were reports that I knew

 7     had to reach the minister, that the minister was bound to see.

 8        Q.   Thank you.  In formal terms, a report of yours that was supposed

 9     to reach the minister, what was it supposed to contain, as far as the

10     form of the report itself was concerned?

11        A.   Well, the procedure of sending these reports was as follows:

12     Since the service operates strictly on the principles of subordination, I

13     could not send a report like that directly to the minister, although I

14     knew that the minister was supposed to see this report.  The report was

15     sent by the head of my department.  I submit my report to the head of the

16     department.  He familiarises himself with it.  And then he compiles a

17     document, and then my report is submitted, together with that document,

18     to the minister.  That is the usual procedure involved.

19        Q.   What about this accompanying document?  What is done with that?

20        A.   Well, it includes a number in our register and also a number at

21     the minister's office.  And it also denotes the nature of the document

22     involved and the content.

23             MR. PETROVIC: [Interpretation] Your Honour, could we please look

24     at P3017 now.

25        Q.   Mr. Vujovic, this is a report that was purportedly compiled by

Page 19587

 1     Milorad Davidovic on the 8th of August, 1991.  I'm not asking you

 2     anything about the content of the report.  I would kindly ask you to take

 3     a look at the first page and the last page of that report, and I would

 4     like to ask you the following:  On the basis of your own experience in

 5     preparing reports that are supposed to end up on the minister's desk

 6     ultimately, on the basis of the form of this document, can one conclude

 7     that this report was ever sent to the minister?

 8             Could the first page be displayed first and then the last page.

 9     And then I would kindly ask you to give us your answer.

10             Could you please take a look at the entire first page.

11        A.   It is unusual that someone from the lower structures in the

12     service writes a report and says, Personally to the minister.  That is

13     impossible.

14        Q.   Do you see anything on this page that would indicate that this

15     report had been registered, sent, and so on?

16        A.   No.  As we can all see on our screens, there is no trace of any

17     such thing.

18        Q.   Thank you.

19             MR. PETROVIC: [Interpretation] Can we look at the last page now,

20     please.  The last page of this report.

21        Q.   Mr. Vujovic, my question is the same.  On the basis of the form

22     of the last page of this report, can one infer whether this report was

23     ever sent to anyone; and, if so, where and when?

24        A.   No.  No.  This was not the practice of the federal service.

25        Q.   Finally, Mr. Vujovic, please look at the upper part of this

Page 19588

 1     report.  There's some numbers here.  Can you interpret that for us?  I'm

 2     not asking you about the number in red.  I'm asking you about the numbers

 3     further up, 06-05-05.  Can you discern what these numbers are?

 4        A.   It looks like a fax header.  Obviously -- obviously it was not

 5     typed up when the document itself was typed up.  This was obviously

 6     faxed, and it looks like the kind of thing that a fax machine generates

 7     on its own.  That's what it looks like.

 8        Q.   Thank you, Mr. Vujovic.

 9             MR. PETROVIC: [Interpretation] Your Honour, 2D1218 would be the

10     document that I'd like to have displayed on our screens now.  And I would

11     like to have this document admitted as a Defence exhibit.  Actually, this

12     is a bar table submission since it is the reply that our Defence team

13     received from the Republic of Serbia in relation to this report that we

14     dealt with now.  3017, that is.

15             JUDGE ORIE:  Ms. Friedman.

16             MS. FRIEDMAN:  Yes, Your Honours, the Prosecution submits that

17     this document has very low probative value, if any, and I'd like to

18     briefly explain that.  The Davidovic report, which is the subject of the

19     letter, was found to be authentic and reliable by Your Honours in your

20     decision of the 1st of September, 2011.  The Chamber took into

21     consideration the evidence provided by Mr. Davidovic, the author of the

22     report, as well as the testimony of DST-034 an exhibits P478 and 489.

23             The Simatovic Defence has not elicited from this witness any

24     additional evidence about which copy this would be.  This witness is

25     clearly not placed -- does not have the foundation to comment on it or

Page 19589

 1     in -- specifically in a way that would address what Your Honours have

 2     already decided in your decision.  That's at paragraphs 19 to 21.

 3             The letter states that BIA does not have a copy of the report in

 4     its archive.  This fact is not surprising, especially in light of

 5     DST-034's evidence that the reason the Serbian MUP took over the federal

 6     MUP was -- or, actually, I won't get into that in front of the witness,

 7     but there is some testimony on that.

 8             JUDGE ORIE:  Yes.

 9             MS. FRIEDMAN:  Further, the letter that was received did not

10     respond to the question as to whether the document was ever created by

11     the federal MUP.  The only information provided was that is was not in BS

12     archives.  So, nevertheless, if the Chamber feels it is somewhat

13     relevant, we wouldn't oppose it, but we do question whether it has any

14     probative value.

15             JUDGE ORIE:  I think, as a matter of fact, at this stage what

16     we're interested in to see whether there where any obstacles to

17     administration, and what are you doing, as a matter of fact, is already

18     weighing evidence and then to say since there is more on the other side,

19     this is of little probative value.  I think that's a bit premature.

20             But -- have we seen the document?  [Overlapping speakers] ... you

21     asked us to -- to admit from the bar table [Overlapping speakers] ...

22     yes.

23             MR. PETROVIC: [Interpretation] Yes, Your Honour.

24             JUDGE ORIE: [Overlapping speakers] ... I've got it on my screen

25     now.  Let me just have a look at it.

Page 19590

 1             MR. PETROVIC: [Interpretation] Your Honour, I may respond, if you

 2     believe it is necessary for me to respond, to what my learned friend

 3     said.

 4             JUDGE ORIE:  I've not made up -- we have not made up our mind on

 5     that yet.  Let's first have a look at the document.

 6             MS. FRIEDMAN:  Your Honour, your microphone, please.

 7                           [Trial Chamber confers]

 8             JUDGE ORIE:  The Chamber will, at a later stage, weigh all the

 9     evidence in relation to this document, evidence of whatever kind, but

10     considers that this is a -- may well be a part of the puzzle, and,

11     therefore, is admitting it into evidence.

12             Madam Registrar, the number would be ...

13             THE REGISTRAR:  Document 2D1218 will receive number D872,

14     Your Honours.

15             JUDGE ORIE:  D872 is admitted into evidence.

16             Please proceed, Mr. Petrovic.

17             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

18        Q.   Mr. Vujovic, we're moving on to the period after the federal and

19     republican services were merged.

20             Can you tell us what things were like now, once you moved into

21     the republican service?  How was the work distributed between you and the

22     regional centres within Serbia?

23        A.   As the services were merged, the 7th Department became even

24     busier.  Namely, we had to be involved in providing guide-lines,

25     supervision, technical assistance, et cetera, in various centres in

Page 19591

 1     Serbia.

 2        Q.   So your 7th Administration continues to do what kind of work

 3     directly?

 4        A.   Well, the administration continued doing what had been its main

 5     work up until then; and that is to say, the diplomatic.

 6        Q.   Mr. Vujovic, you're saying that centres did a considerable amount

 7     of work.

 8             These centres, do they submit to the 7th Administration the

 9     results of their work after they had applied operative technical

10     measures?

11        A.   No.

12        Q.   To whom are these results submitted, the ones that technicians in

13     centres obtain?

14        A.   They send the results of their work to the operative in that same

15     centre who was in charge of that particular work.

16        Q.   Mr. Vujovic, what were all the lines of work within the

17     7th Administration after the merging of the services?

18        A.   Well, the same lines of work:  Counter-intelligence,

19     intelligence, extremism, terrorism, and also the protection of buildings

20     and individuals.  That was line 6.

21        Q.   When you joined the RDB at the end of 1992, in the

22     7th Administration was there a service, a particular division, for radio

23     monitoring or surveillance?

24        A.   You call it a very simple name, radio monitoring, but that was

25     not within the 7th Administration anyway.

Page 19592

 1        Q.   Radio monitoring would be of relevance to which administration?

 2        A.   In terms of the radio spectrum and all the beneficiaries of such

 3     communications, well, that would practically be only within the remit of

 4     the intelligence service.

 5        Q.   Radio monitoring, can you tell us just in a few words how this

 6     measure can be successfully implemented?

 7        A.   Well, what you keep calling radio monitoring is just part of the

 8     work involved in a field that is called monitoring the radio spectrum.

 9             Radio monitoring is the initial part of the work that has to be

10     carried out by those who want to monitor the radio spectrum.  Radio

11     monitoring is certainly a very demanding thing, very difficult.  It

12     requires a great deal of professionalism, a great deal of experience, a

13     great deal of patience.  Quite simply, in radio monitoring, you are

14     seeking certain channels, certain frequencies, that may be of interest to

15     the service.  And the search itself is very, very, very, delicate, as

16     I've already said, and it is also very strenuous.

17        Q.   Geographically speaking, where is it best to deploy such

18     equipment for radio monitoring?

19        A.   As far as the radio spectrum is concerned, according to its

20     physical characteristics, it is very diverse, in terms of how the radio

21     waves spread due to the physics involved.  Most of the radio spectrum

22     requires the following:  To get as close as possible physically, the best

23     geographical point, as you had put it, in order to be able to monitor the

24     radio spectrum.

25             MR. PETROVIC: [Interpretation] Your Honours, could we please move


Page 19593

 1     into private session for a moment.

 2             JUDGE ORIE:  Yes.  Before we do so, Mr. Petrovic, if I look at

 3     the last two minutes:  Can you tell us in a few words how radio

 4     monitoring can be successfully implemented.

 5             The answer doesn't say a thing about that.  It is about that it's

 6     not as simple and that it's very delicate and very strenuous.

 7             So apparently you are happy with an answer which does not in any

 8     way reflect what you apparently are seeking, listening to your question.

 9             Then the next one:  Geographically speaking, what's the best --

10     what is it best to deploy equipment.

11             And then "... get as close as possible."

12             Well, is that really information which you think the Chamber

13     would need?  I mean, if you want to monitor radio, then it does not

14     really come as a surprise that being closer to it rather than far away is

15     better.  And, apart from that, again, I really have difficulties in

16     following the relevance.  And if it is relevant, then please try to get

17     an answer to your question rather than to wait for one minute and then

18     accept whatever the witness says, whether or not related to your

19     question.

20             We move into private session.

21             [Private session] [Confidentiality partially lifted by order of the Chamber]

22             THE REGISTRAR:  We're in private session, Your Honour.

23             JUDGE ORIE:  Thank you, Madam Registrar.

24             MR. PETROVIC: [Interpretation]

25        Q.   Mr. Vujovic, I just asked you about the deployment of the

Page 19594

 1     equipment in view of the geographical characteristics of the terrain.

 2             You said that one should get as close as possible.  Does the

 3     distance play a role in the choice of equipment?  Can some of the

 4     equipment be used only when you're closer?  Can some others be employed

 5     at a certain distance?  Can you tell us something about this notion of

 6     closeness and distance?  For which equipment is it important to be close

 7     and what kind of monitoring can be done from a distance?  With what

 8     equipment?

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23        Q.   Do you know if any of the members of your service suggested that

24     interesting intelligence might be obtained through radio monitoring?  And

25     was that conveyed to the service employees who were interested in the

Page 19595

 1     intelligence that could be obtained through radio monitoring?

 2        A.   As far as I know, before 1993, the 7th Administration was not

 3     involved in that.  Later on, as the situation evolved, I know that there

 4     was an initiative to monitor the whole radio spectrum -- came from an

 5     official of the republican MUP.  Can I perhaps say his name?  His name

 6     was Luki, also known as Lula.  He was a ham operator.  He was passionate

 7     about it and his initiative was prompted by the fact that his colleagues

 8     drew attention to the fact in there -- to the fact that in their work

 9     they could intercept information that was sent from Bosnia and

10     Herzegovina or perhaps Croatia and that they didn't know what to do with

11     that.  And they told him, Okay, you're a member of the service.  We're in

12     Belgrade.  We're able to intercept that information in terms here in

13     Belgrade.  Why don't you say something to somebody?

14             So the initiative was his and those were the circumstances under

15     which the situation developed.

16        Q.   Before you joined the RDB, were there people who heard that

17     Lukic's initiative and did they become engaged in their tasks that I

18     erroneously called radio monitoring?

19        A.   What happened next is something that I can tell you from what I

20     heard.

21             The operatives from the intelligence administration wanted to see

22     how the whole thing worked.  They then realised that they could, indeed,

23     obtain interesting intelligence in that way, and then they decided under

24     the circumstances to engage that group of ham operators to collect

25     intelligence.  And when I joined, after the merger with the republican

Page 19596

 1     MUP, that group already existed, and we called them amateurs in our

 2     jargon.  They had already started collecting intelligence, using their

 3     equipment in that area, in the area of radio monitoring.

 4        Q.   Do you know any of the individuals who were members of that group

 5     that controlled the radio spectrum?

 6        A.   There were several of them.  But later on I had contacts with two

 7     of them:  Ranko Tadic, who had a degree in electrical engineering -  he

 8     was an excellent engineer - and Nikola Varda, who was a watch repairman -

 9     he was an excellent ham radio operator.  And the two of them were leaders

10     of sorts of that group.

11        Q.   Thank you.

12             MR. PETROVIC: [Interpretation] Your Honour, can we go back into

13     open session, please.

14             JUDGE ORIE:  We return into open session.

15                           [Open session]

16             THE REGISTRAR:  We're in open session, Your Honours.

17                           [Trial Chamber confers]

18             JUDGE ORIE:  Please proceed.

19             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

20        Q.   Mr. Vujovic, the group that you have just described for us, was

21     it deployed anywhere?  Was it stationed anywhere to continue monitoring

22     the radio spectrum?

23        A.   From my subsequent conversations with them and when we jointly

24     planned our tasks in a subsequent period, at first, I know that they were

25     deployed or stationed in Pajzos.  That was a facility called Pajzos.


Page 19597

 1        Q.   And did you learn what kind of equipment they had initially?

 2        A.   Initially, since we, as the service, had not been involved in the

 3     radio spectrum control, at the very beginning, they had their own

 4     equipment.  The service provided them with an adapted vehicle.  However,

 5     when they first started working, they worked on their equipment.  Later

 6     on, professional equipment was purchased.  But at first they used their

 7     own equipment and our vehicle.

 8        Q.   What kind of a vehicle was that?

 9        A.   I believe that they had a Land Rover at that time.  And that

10     Land Rover was adapted to accommodate both the equipment and the men who

11     operated the equipment.

12             JUDGE ORIE:  Ms. Friedman.

13             MS. FRIEDMAN:  Yes.  I just wanted to note that this was not at

14     all in the 65 ter summary in relation to this witness.  It's all

15     unnoticed evidence, though, also, the relevance is questionable at this

16     stage.

17             JUDGE ORIE:  Mr. Petrovic.

18             MR. PETROVIC: [Interpretation] Your Honours, please bear with me

19     for a moment, please.

20             Please look at our summary.  And in that summary, in the second

21     paragraph, in the third and fourth paragraphs, you will see that those

22     paragraphs contain all this information.  There is reference to Pajzos,

23     the significance of radio monitoring.  There's also a reference to the

24     adapted Land Rover.  And it says here that people who were involved had

25     special expertise but they were not permanent members of the service.

Page 19598

 1             All that is contained in our summary.

 2             JUDGE ORIE:  Ms. Friedman.

 3             MS. FRIEDMAN:  Yes.  The summary focuses on the 7th and

 4     2nd Administrations.  I see now the comment about others not employed.

 5     Perhaps the problem is generally that there is so little detail that it's

 6     really -- this, for example, calling them the amateurs, all of this is

 7     specific information that could be included -- that would be included in

 8     a statement, and in this way we are continually prejudiced by the lack of

 9     notice.  But I will not, at this stage, object to the questions.

10             JUDGE ORIE:  Then Mr. Petrovic may proceed.

11             MR. PETROVIC: [Interpretation] Thank you, Your Honours.

12        Q.   Mr. Vujovic, you have told us about this adapted Land Rover

13     vehicle.  And you told us that those men were stationed at Pajzos.  In

14     geographical terms, why was Pajzos significant, if you know?

15        A.   Pajzos, as I have already told -- told you before, had to do with

16     geography.  Tactically it was well located because it covered a large

17     part of Eastern Slavonia, and we're particularly interested in Pajzos

18     because we wanted to chase those link communications; because at the

19     beginning of the conflict, the Croats had re-routed their links.  So we

20     were trying to find them, and Pajzos was suitable because we believed

21     that we could intercept some of their communications from there.

22             MR. PETROVIC: [Interpretation] Your Honours, can we please move

23     into private session again.

24             JUDGE ORIE:  We move into private session.

25             [Private session] [Confidentiality partially lifted by order of the Chamber]


Page 19599

 1             THE REGISTRAR:  We're in private session, Your Honour.

 2             JUDGE ORIE:  Thank you, Madam Registrar.

 3             MR. PETROVIC: [Interpretation] Thank you, Your Honours.

 4        Q.   Mr. Vujovic, did you go to Pajzos once you joined the RDB?

 5        A.   Yes, I was there.  I was in Pajzos.

 6        Q.   The technicians and translators from your administration, did

 7     they also go to Pajzos?

 8        A.   Yes, they did.  Pajzos was a very good point for radio

 9     monitoring.  And one of its advantages was that you could send

10     translators there to work there because there were accommodation

11     facilities there as well.

12        Q.   Did any other employ employees -- as far as you know, any other

13     RDB employees were they deployed in Pajzos when you went there?

14        A.   From RDB?

15        Q.   Yes.

16        A.   Yes, people from the 2nd Administration.

17        Q.   According to what you know, was there an intelligence point at

18     Pajzos?

19        A.   Well, we were there with our equipment which means that it was an

20     intelligence point.  It goes without saying.

21        Q.   Mr. Vujovic, how did intelligence operatives and the employees of

22     your administration co-operate at Pajzos?

23        A.   In principle, similar organisations was in place in every

24     intelligence point and that applied to Pajzos as well.  Since it was not

25     in the centre, the intelligence that was collected through radio

Page 19600

 1     monitoring was submitted to the intelligence operative who was also

 2     there.

 3        Q.   Did you meet Franko Simatovic at Pajzos?

 4        A.   Yes.

 5        Q.   To the best of your recollection, how many times and why did you

 6     meet Simatovic there?

 7        A.   I believe that that happened twice, if I'm not mistaken.  It was

 8     a long time ago.

 9             We had working meetings.  We wanted to see if we could do

10     anything else at that place, how many people we should have there, and so

11     on and so forth.  Nothing special about those meetings.

12        Q.   You mentioned equipment that was at Pajzos.  Was that mobile or

13     stationary equipment?

14        A.   At first, that was mobile equipment, and later on, there came a

15     time when we were able to obtain stationary equipment.

16        Q.   In order to install that equipment, did you have to have antennas

17     and were those antennas visible?

18        A.   Absolutely, yes.  Those antennas were visible.  You could not

19     work without antennas, and especially the surveillance antennas that were

20     used in the surveillance systems.  In terms of their physical

21     characteristics, they have to be bigger than any other transmitter's

22     antennas, and there's no way you could mask them or disguise them or hide

23     them.

24        Q.   Could you please tell us when you went there?  Could you be more

25     specific and tell us what years were those?

Page 19601

 1        A.   I went there in 1994 and 1995, 1996.  During that period, I was

 2     there twice, I believe.  I really don't know exactly.

 3        Q.   Can you tell us, the equipment with -- electronic surveillance

 4     and the operators who used them, do they need to be secured; and, if so,

 5     how?

 6        A.   Yes.  Both people and equipment have to be secured.  There's no

 7     two ways about it.

 8        Q.   Why?  Why is that important?  Why do men and equipment have to be

 9     secured?

10        A.   For several reasons:  The first is physical protection; the

11     second reason is the confidentiality that we already discussed.  That's

12     part of the method of work.  Things have to be confidential, secure;

13     hence, the physical security.

14        Q.   Mr. Vujovic, you're saying that you went to Pajzos in 1994 and

15     1995.  Who was it who provided security for Pajzos in 1994 and 1995?

16        A.   It was an anti-terrorist unit.

17        Q.   How were they engaged?  Who was that unit engaged to provide

18     security for the facility at Pajzos?  Do you know anything about that?

19        A.   That was an independent unit which was an integral part of the

20     State Security Department.  The request for their engagement could have

21     been issued by the chief of department or the special advisor, whoever.

22             However, it was the minister who could make the final decision on

23     their engagement.

24        Q.   Mr. Vujovic, you mentioned the adapted Land Rover.  Were any

25     other vehicles adapted to suit the purpose of radio monitoring that we

Page 19602

 1     have been discussing?

 2        A.   When we were ordered to organise that part of the activity as

 3     part of the 7th Administration, then we hired people, we got vehicles,

 4     and as time went on, we ended up with a lot of vehicles, different

 5     vehicles.

 6        Q.   As the equipment for radio monitoring developed, did you develop

 7     any other facilities with radio monitoring equipment, to your knowledge?

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19603

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7        Q.   You mentioned Ranko Tadic and his group.  Can you tell us why

 8     that group continued to be involved in this work even after your people

 9     had started working on it?

10        A.   Well, quite simply, there weren't enough people for this job.  We

11     started developing this kind of work in 1993 practically.  So we had to

12     organise people and resources as the work went along.  This is a very

13     special kind of work.  You don't have enough trained personnel to do

14     that.  So, quite simply, we never, ever had enough people to meet all the

15     needs of the intelligence line of work.  So it was only natural that this

16     team went on working.

17             MR. PETROVIC: [Interpretation] Your Honours, I am checking the

18     time, and I wonder whether this would be the right time to take a break.

19             JUDGE ORIE:  We had a relatively short first session.  If we

20     would take a break now we would have a last session of one and a half

21     hour.  I would prefer to split up, so if you would go on for six or seven

22     minutes, then we have three sessions divided by two breaks of half an

23     hour.

24             Please proceed.

25             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

Page 19604

 1        Q.   Mr. Vujovic, how was this agreed upon, getting Ranko Tadic's

 2     group to work on this job?

 3        A.   Well, this was agreed upon with the intelligence people.  A

 4     decision was reached who was supposed to go.  I already told you.  We

 5     didn't have enough people.  So the questions was whether we should

 6     withdraw a group from amongst our permanent personnel or whether we

 7     should send ham radio operators.  So it always had to do with the

 8     assessment of our priorities, what was the priority at a given point in

 9     time.

10        Q.   Mr. Vujovic, do you know what the legal basis was for involving

11     the ham radio operators headed by Ranko Tadic?

12        A.   As far as I know, they had freelance contracts and they were paid

13     on the basis of such contracts, and that is how they did their work.

14             MR. PETROVIC: [Interpretation] Could we just pause for a moment,

15     please.

16             JUDGE ORIE:  Ms. Friedman.

17             MS. FRIEDMAN:  I just wanted to inquire whether the issue of

18     technical means will be returned to, or perhaps we could be in public

19     session for this part.

20             JUDGE ORIE:  Can we return into public session, Mr. Petrovic?

21             MR. PETROVIC: [Interpretation] Your Honours, we can go back into

22     public session now.

23             JUDGE ORIE:  We turn into open session.

24                           [Open session]

25             THE REGISTRAR:  We're in open session, Your Honours.


Page 19605

 1             JUDGE ORIE:  Thank you, Madam Registrar.

 2             MR. PETROVIC: [Interpretation]

 3        Q.   Mr. Vujovic, you mentioned freelance contracts.  Can you tell us

 4     which administration within the RDB was in charge of contracting such

 5     individuals?

 6        A.   The 8th Administration.

 7        Q.   Do you know whether these individuals received per diems when

 8     they were sent out into the field for that period of time that they spent

 9     in the field?

10        A.   Of course.

11        Q.   Can you tell us who paid these per diems; and can you tell us

12     whether the principle involved was any different from the principle

13     applied in the case of other employees who were sent out into the field?

14        A.   As far as per diems were concerned, there was no difference, in

15     principle.  It was the 8th Administration that paid all the per diems.

16             MR. PETROVIC: [Interpretation] Could we please have 5458.  Could

17     it please not be displayed to the public.  And could we have a look at

18     page 28.

19             Could I please have page 20.  The document I want is P5458.

20     P4558 [as interpreted], page 20.

21             MS. FRIEDMAN:  Just -- if it is of assistance, the document that

22     was noted to us was P458.  I don't know ...

23             MR. PETROVIC: [Interpretation] Your Honours, I think that I've

24     been saying that all along.  And I would like to see page 20.

25             Your Honours, there is no English translation here on page 20

Page 19606

 1     because this is simply a list of names.

 2        Q.   Mr. Vujovic, this is a list that was compiled for having

 3     per diems paid.  I would like to ask you to take a look at the list and

 4     tell us whether you recognise any of the names.

 5        A.   Number 17, Nikola Varda; and Ranko Tadic, number 20.  That is

 6     what I can see straight away.

 7        Q.   Do you recognise any other names?

 8        A.   I don't know.  Possibly.  But these two, yes, quite.

 9        Q.   Thank you, sir.  Thank you, Mr. Vujovic.

10             You told us that people who dealt with electronic surveillance

11     were involved in Pljesevica and Petrova Gora.  Can you tell us when this

12     actually took place?

13        A.   1994, 1995, that's for sure.

14             MR. PETROVIC: [Interpretation] Your Honours, I'm facing a dilemma

15     now.  But I believe that following your instructions from the beginning

16     of the hearing, I think it would be a good thing if we moved into closed

17     session because I'm going to refer to a location where certain measures

18     were being applied, and I'm going to refer to individuals who were

19     involved in that.

20             So following your instructions, I believe it would be a good idea

21     if that were to be discussed in closed session.

22             JUDGE ORIE:  But we will do that after the break.

23             I would have one or two additional questions to seek

24     clarification of the witness.

25             Mr. Vujovic, I take you back to -- well, let's say, approximately

Page 19607

 1     a half-hour ago when you commented on the report which you said was at

 2     least uncommon because it was directly addressed to the minister.  It was

 3     the report by Mr. Davidovic.

 4             Do you have any personal knowledge about the activities of

 5     Mr. Davidovic, or is it just that you commented on the document, as you

 6     saw, it without having any knowledge about Mr. Davidovic's activities and

 7     this specific report?

 8             THE WITNESS: [Interpretation] I don't know even know who

 9     Mr. Davidovic is.  I didn't know then; I don't know now.

10             JUDGE ORIE:  Then my next question relates to the document we

11     just looked at, which is, in order to avoid whatever confusion, is P458,

12     we see a list of 27 names.  Is it your testimony that all these persons

13     were involved in surveillance of radio communications?

14             THE WITNESS: [Interpretation] No, Your Honour.  That is not what

15     I'm saying.

16             My understanding of the question was as follows:  Do I recognise

17     any individuals from this list, and who are these people.  And I

18     identified Nikola Varda and Ranko Tadic who were in this group of ham

19     radio operators.  Possibly there are some other ham operators here.  Who

20     these other people are, I don't know.

21             JUDGE ORIE:  Yes.  So, therefore, you couldn't tell us anything

22     about the other persons, what their activities were, whether they were

23     involved in radio communications or other matters?

24             THE WITNESS: [Interpretation] If you insist, for example,

25     number 1, Milorad Budimir.  He worked -- he worked on securing

Page 19608

 1     communications for anti-sabotage units.  So he was a communications man.

 2     I could single him out therefore, but not anybody else.

 3             JUDGE ORIE:  Yes.  Is there any way you can link these persons to

 4     an ATD unit of the MUP?  ATD standing for anti-terrorist operations.

 5             THE WITNESS: [Interpretation] I don't know who generated this

 6     document.  If it was generated by the 8th Administration, that is usually

 7     the case when documents dealt with per diems, or if this is from some

 8     particular location where an ATD was and whether there was radio

 9     surveillance involved.  It could have been Pajzos or anywhere else.  And

10     then perhaps a composite document was sent for the payment of per diems.

11     I don't see any other possibility.

12             JUDGE ORIE:  Does your answer mean that intercepting or

13     monitoring radio communications was part of the anti-terrorist

14     operations?

15             THE WITNESS: [Interpretation] Intercepting communications is

16     handled by the intelligence administration.

17             As I've already said, and as I saw in Pajzos, there was a unit

18     for providing physical security for this intelligence point.

19             JUDGE ORIE:  Would you protect the -- this point with staff from

20     the -- or people involved in the anti-terrorist operations unit?  Is that

21     logical, to give them a task in securing such a facility as you'd

22     described?

23             THE WITNESS: [Interpretation] I did not quite understand what you

24     said, Your Honour.

25             JUDGE ORIE:  Well, let me check your last answer then.

Page 19609

 1             I asked you whether "monitoring radio communication was part of

 2     the anti-terrorist operations."

 3             You said:

 4             "Intercepting communications is handled by the intelligence

 5     administration."

 6             And then you said:  As I told you already, in Pajzos, there was a

 7     unit for providing physical security for this intelligence point.

 8             Now I earlier -- understood your earlier answers that the

 9     intelligence point was primarily monitoring radio communications because

10     that was such an excellent place.  Is that well understood?

11             THE WITNESS: [Interpretation] You understood that well,

12     Your Honour, and that is exactly what I had said.  But ...

13             JUDGE ORIE:  Then my question was -- you introduced, then, the

14     physical security of those involved in this monitoring of communications.

15             And my question was:  Would you use an anti-terrorist operations

16     units to secure a facility in which monitoring radio communications is

17     the main thing to be done?

18             THE WITNESS: [Interpretation] Well, my answer would be

19     affirmative.  The unit at Pajzos was in charge of providing physical

20     security for the facility.  External physical security.

21             JUDGE ORIE:  Were these members of the anti-terrorist unit?

22             THE WITNESS: [Interpretation] As far as I know, they were.

23             JUDGE ORIE:  I leave it to that.

24             We'll take a break, and we'll resume at 12.30.

25                           --- Recess taken at 12.00 p.m.


Page 19610

 1                           --- On resuming at 12.34 p.m.

 2             JUDGE ORIE:  Mr. Petrovic, please proceed.

 3             MR. PETROVIC: [Interpretation] Thank you, Your Honours.

 4             May we kindly move into private session.

 5             JUDGE ORIE:  We move into private session.

 6             [Private session] [Confidentiality partially lifted by order of the Chamber]

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19611

 1   (redacted)

 2        Q.   Where did the intelligence from Pljesevica go to?

 3        A.   The intelligence from Pljesevica went to the operative on

 4     Petrova Gora, along the operative work line.

 5             JUDGE ORIE:  Can we confer, and if we do not ask you to stop,

 6     then we will re-read the transcript, the five lines we are missing.

 7             Please proceed.

 8             MR. PETROVIC: [Interpretation] Thank you, Your Honours.

 9        Q.   Mr. Vujovic, according to what you know, was there an

10     intelligence point on Mount Petrova Gora?

11        A.   Yes.

12        Q.   How do you know that?  How do you know things about Pljesevica

13     and Petrova Gora?  Do you have first-hand knowledge, or did you learn it

14     from somebody else?

15        A.   I have first-hand knowledge about Petrova Gora because I was

16     involved in the planning and sending men who worked there for a fortnight

17     or longer.

18        Q.   Thank you.

19             MR. PETROVIC: [Interpretation] Can we now look at -- or, rather,

20     before that, I have another question for you in private session.

21        Q.   You mentioned the third division of the 7th Administration.  When

22     was it set up, the third division, and how did it develop over time?

23        A.   As I have already told you, the 7th Administration was not

24     involved in radio monitoring and radio spectrum surveillance until the

25     moment that the two services were merged in Serbia.  And then an

Page 19612

 1     initiative was launched --

 2        Q.   No, no, I'm just interested in the time-period.

 3        A.   That's was in 1993.

 4        Q.   After the third division was set up, in view of the nature of

 5     their work, could ham radio operators be members of the team of the

 6     7th Administration?

 7        A.   In -- in a functional sense, they were members of the team, but

 8     they were not on permanent contracts.  When it came to planning and

 9     sending people into the field, we always had made arrangements with the

10     intelligence as to where people would go because we did not have enough

11     men.  But, in formal terms, they were never permanent members of the

12     7th Administration.

13             JUDGE ORIE:  Ms. Friedman.

14             MS. FRIEDMAN:  I just wanted some clarification.  I looked in the

15     transcript - maybe I missed it - but I can't find the witness having

16     mentioned the third division.  So it's leading, but also just unclear,

17     exactly, if that is referring to these amateurs that he was talking

18     about, or what it's referring to.

19             JUDGE ORIE:  Yes.

20             Mr. Petrovic, I would like to add to, what Ms. Friedman just

21     said, one comment.  We are interested primarily in facts.  For example,

22     if the witness says, I have first-hand knowledge about Petrova Gora

23     because I was involved in the planning in sending men who worked there

24     for a fortnight or longer, what I'm interested to know is how many men

25     did he send there?  What was the average number of people working there?

Page 19613

 1     Were they technicians?  Were they translators?  Because it seems that, if

 2     I understand you well, it's -- the Defence is eliciting evidence which

 3     shows the presence and the activities of radio monitoring people in that

 4     places you refer to.

 5             Now, whether there were or not may be relevant.  Perhaps even

 6     more relevant is whether they were exclusively there or whether there

 7     were others, and what the others were doing as well.

 8             Now by hearing about I didn't have enough people.  Enough.  What

 9     is enough?  Give me the numbers.  Give me also for those who were sent

10     there.  If the witness could tell us how many people he sent to

11     Petrova Gora, then I would be happy because that gives me at least some

12     of the information I would need.

13             So, therefore, I -- when you said you were involved in the

14     planning and sending of people to Petrova Gora, how many -- I think you

15     called them ham monitoring or -- these technician who do the technical

16     work in monitoring the -- the radio range, how many people did you send

17     to Petrova Gora?

18             How many would be there, on average?  Two, five, ten?

19             THE WITNESS: [Interpretation] You put it well, Your Honour.  The

20     average number changed from one situation to the next.  However, if we

21     are talking about averages, I would say that a minimum number would be

22     four or five men who were on Petrova Gora mount at any one time.

23             JUDGE ORIE:  Yes.  Do you know how many support, in terms of

24     translators, were sent to Petrova Gora, if any?

25             THE WITNESS: [Interpretation] There were one or two translators,

Page 19614

 1     not more.  We did not have any -- any more of them on our team, or

 2     available to us.

 3             JUDGE ORIE:  Do I then understand well that, on average, for

 4     performing the radio communication monitoring would take some seven

 5     people on average, the presence of seven people, on average, in

 6     Petrova Gora?

 7             THE WITNESS: [Interpretation] I believe that that -- you can put

 8     it that way, at least for this particular part of the whole exercise.

 9             JUDGE ORIE:  Could you give us detailed information as how many

10     people were there to secure the equipment and the -- and the persons

11     performing that job?

12             THE WITNESS: [Interpretation] I can't tell you.  I personally

13     never went to Petrova Gora, so I wouldn't be able to share that

14     information with you.

15             Even if I'd gone there, chances are I would have never been aware

16     of that particular figure.

17             JUDGE ORIE:  At Pajzos, I take you back to Pajzos, technicians

18     monitoring and persons assisting in translation, how many, on average,

19     would there be at Pajzos?

20             THE WITNESS: [Interpretation] When radio monitoring is happening,

21     then you don't need that many people.  When you're transcribing, you need

22     more.  On average, five to seven, I suppose.  They worked in shifts, and

23     so on and so forth.

24             One or two men would not have been enough to cover the whole

25     spectrum for 24 hours a day.

Page 19615

 1             JUDGE ORIE:  Now, translators for Pajzos.

 2             THE WITNESS: [Interpretation] The same applied to Pajzos.  They

 3     were not there all the time, but there were never more than two

 4     translators there.  One at -- on -- on most occasions.

 5             JUDGE ORIE:  So we're always talking about less than ten people

 6     doing the job; that is, monitoring and assisting in translating?

 7             THE WITNESS: [Interpretation] At locations where conditions were

 8     in place for that.  On Pljesevica, there were fewer people because the

 9     conditions there were simply not good enough for accommodating a higher

10     number of people.

11             But at Pajzos and Petrova Gora, that would have been the

12     situation, more or less.

13             JUDGE ORIE:  Pajzos, how many security persons involved, securing

14     both operators and the equipment?

15             THE WITNESS: [Interpretation] I can't tell you exactly.  We're

16     talking about physical security around the entire facility, and if I were

17     to give you any figures, I would be speculating.  I don't have any idea

18     about the number of men who were involved.  Obviously, since we're

19     talking about physical security and people being deployed so that they

20     could see each other, I suppose that there may have been a dozen or ten

21     people in one shift, but this is pure speculation because I really don't

22     know.

23             JUDGE ORIE:  Yes.  This is what I mean by facts, Mr. Petrovic.

24     Instead of having long stories about the technicalities of monitoring, I

25     would like to know how many people were there doing their job and then to

Page 19616

 1     see whether that explains the presence of all men there, or whether there

 2     would have been more or less on the basis of other evidence.  That's what

 3     I'm thinking that's what the Chamber needs, this kind of practical

 4     information, rather than how close you should be to the target, if you

 5     want to monitor radio communications.

 6             Please proceed.

 7             MR. PETROVIC: [Interpretation] Thank you, Your Honour.  I'll try

 8     to abide by your guidance.

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15             As for the physical security that was provided, again, that was

16     not within my purview, so I can't tell you how many men provided physical

17     security for the facility.

18        Q.   Thank you.

19             MR. PETROVIC: [Interpretation] Your Honours, can we go back into

20     public session.

21             JUDGE ORIE:  We return into open session.

22                           [Open session]

23             THE REGISTRAR:  We're in open session, Your Honours.

24             JUDGE ORIE:  Thank you, Madam Registrar.

25             MR. PETROVIC: [Interpretation] Thank you, Your Honours.


Page 19617

 1             Can we now look at P235.

 2             This is the operative log-book of Pauk Command.

 3        Q.   Mr. Vujovic, I understand that you were not on Petrova Gora,

 4     which is why I'm not going to ask you about any details.  I just need

 5     your assistance in interpreting some of the entries in this operations

 6     log-book.

 7             MR. PETROVIC: [Interpretation] Can we look at page 15 in B/C/S

 8     and 9 in English.

 9             Can we focus on the middle of the page.  Thank you.

10        Q.   Mr. Vujovic, we have an entry here in this operations log at

11     1120 hours and there's a remark:  Frenki RPG.  Could you please tell us

12     what the abbreviation RPG stand for?  How do you understand that?

13        A.   RPG is the radio monitoring group, the group that was involved in

14     controlling radio communications.

15             This means that the radio monitoring group obtained information

16     and submitted it to somebody from the intelligence administration.  In

17     this case, it was Frenki, and that the material was then submitted to a

18     staff.  I see that all of these entries were made in a chronological

19     order.

20        Q.   Thank you, Mr. Vujovic.

21             Mr. Vujovic, you mentioned on several occasions earlier today,

22     JATD, the anti-terrorist unit.  Who was it who decided on the setting up

23     of that unit?  Do you know that; and, if you do, when was that?

24        A.   The JATD, as far as I know, was established in 1993, and the

25     decision had been signed by the minister of the interior.


Page 19618

 1        Q.   What was the position of the JATD within the department?

 2        A.   It was an independent motorised unit.

 3        Q.   Did you have any contacts with the JATD in your work?

 4        A.   Yes.  We provided them with technical support when they needed

 5     it, when they needed assistance, or when something had to be done in

 6     their base in Lipovicka Suma, Belgrade.

 7             MR. PETROVIC: [Interpretation] Your Honours, may we move into

 8     private session.

 9             JUDGE ORIE:  We move into private session.

10             [Private session] [Confidentiality partially lifted by order of the Chamber]

11             THE REGISTRAR:  We're in private session, Your Honours.

12             JUDGE ORIE:  Thank you, Madam Registrar.  [Microphone not

13     activated].

14             MR. PETROVIC: [Interpretation] Your Honours, page 63, the

15     witness's answer on line 8, I believe that what was recorded does not

16     reflect what the witness said.  There may have been some confusion there.

17             JUDGE ORIE:  Witness -- that was the question about the JATD,

18     yes.

19             Witness, you were asked whether you had any contacts with the

20     JATD in your work.

21             What I'll now do, I'll read you to the answer, as it is

22     transcribed for us, and would you please comment whether it accurately

23     reflects what you said.

24             Your answer was:

25             "Yes.  We provided them with technical support when they needed

Page 19619

 1     it, when they needed assistance, or when something had to be done in

 2     their base in," and then one word is missing, "... Belgrade."

 3             MR. PETROVIC: [Interpretation] Your Honours, I apologise for

 4     interrupting you.  The answer to the previous question is in dispute.

 5             On line 8, the answer on line 8.

 6             JUDGE ORIE:  Yes.  Sometimes I -- I read from my left screen the

 7     answer on line 8.  But there is sometimes -- let me just check.

 8             Yes, sometime there is's a slight difference between the line

 9     numbering in the -- on the various screens.

10             I'll read now again a question and your answer, as it was

11     transcribed.

12             The question was:

13             "What was the position of the JATD within the department?"

14             And then it is transcribed to us -- that may be not fully

15     accurate:

16             "It was an independent motorised unit."

17             Of course, motorised comes as a bit of a surprise.

18             What did you want to say, or what you may have even said.  It was

19     a ...

20             THE WITNESS: [Interpretation] The JATD was an independent unit

21     within the department, as were other administrations.  They were

22     independent units of work within the department.

23             JUDGE ORIE:  May I take it that this cures the matter.

24             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

25             JUDGE ORIE:  Then we can return into open session or would you

Page 19620

 1     like to stay in private session?

 2             MR. PETROVIC: [Interpretation] Your Honour, if we may remain in

 3     private session.

 4             JUDGE ORIE:  Please proceed.

 5             MR. PETROVIC: [Interpretation] Thank you.

 6        Q.   Mr. Vujovic, you told us that you had contacts in your work with

 7     the JATD.  Can you tell us who did you receive orders from when it came

 8     to these dealings with the JATD?

 9        A.   Well, for the most, from Mr. Milan Tepavcevic, deputy chief of

10     department.  And, at times, from the head of administration as well.  But

11     most often they came from Milan Tepavcevic.

12        Q.   Did Tepavcevic have any specific requests in that context?

13        A.   Whenever he issued orders for certain activities, he would order

14     them to me, addressing me by my name and he would tell me exactly the

15     names of the persons involved.

16        Q.   Can you tell us who were the persons he was interested in?

17        A.   Vlado Tucin, Miladinovic, Kusakovic.  But it was Vlado Tucin in

18     most cases.

19        Q.   Can you tell me what sort of activities had to be carried out on

20     Tepavcevic's orders?

21        A.   I would categorise them in the main as providing assistance to

22     the staffs of various units to facilitate their work, setting up

23     satellite TV, the various closed-circuit television systems, et cetera.

24        Q.   Do you know who was this charge of the anti-terrorist unit?

25        A.   As far as I know, deputy commander was Milan Radonjic.

Page 19621

 1        Q.   Witness, did you attend the ceremony at Kula in 1997?

 2        A.   Yes.

 3        Q.   Can you tell us why were you there?  What was the reason for your

 4     attendance?

 5        A.   Well, there was this ceremony in honour of this unit, and all

 6     heads of administrations were invited, including myself.

 7        Q.   Thank you, Mr. Vujovic.

 8             I would now like to go through several documents that were

 9     provided to us.  We will be dealing with technical details in these

10     documents in most general of terms.

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16             MR. PETROVIC: [Interpretation] Can we look at D749.

17        Q.   After you've looked at the document, can you tell us, what was

18     the device from which this material was taken, if you can tell.

19        A.   Well, the print is rather small, but I'll do my best.

20             This is an intercepted communication.  In fact, it's a

21   (redacted).

22        Q.   Look at the bottom of the page in B/C/S.

23             MR. PETROVIC: [Interpretation] And page 2 in English.

24        Q.   At the bottom it says, "7th Administration, third department."

25             Why is that; can you tell us?

Page 19622

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8             MR. PETROVIC: [Interpretation] Can we now look at D748, please.

 9        Q.   We see that this is a report from the 2nd Administration of the

10     RDB of the Republic of Serbia MUP.  Can you tell us who produced this

11     report?

12        A.   This report was generated by the third department of the

13     7th Administration, although the heading reads 2nd Administration.

14   (redacted)

15   (redacted)

16   (redacted)

17     third department had to be dislocated from the headquarters of the

18     service in Belgrade.  Well, why should -- why should it be logical for

19     them to be dislocated?  Because you had to have large antennae in order

20     to be able to follow the bulk of communications.  In order to have an

21     efficient flow of information, an instruction was produced whereby the

22     information generated by the third department of the 7th Administration

23     should immediately be given a heading of the 2nd Administration and

24     sent -- or forwarded on from there along those lines.

25             That was the decision made.

Page 19623

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21     people who were breaking the code.  And then you would have a text like

22     this one.  You see here it reads "Fata," because within the service

23     itself we had certain confidentiality measures in place.  And you had to

24     pay attention to details in order not to jeopardise the work of the

25     service that was dealing with breaking codes and deciphering encrypted

Page 19624

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25     D751, which was produced on the same date, i.e., 11 September 1995.

Page 19625

 1     Time:  1130.  The number is 1192.

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 19626











11 Pages 19626-19627 redacted. Private session.
















Page 19628

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10        Q.   This information that was obtained by the third department of the

11     7th Administration and that, say, the 2nd Administration of the RDB in

12     the heading, who is this forwarded to?  Do you know?

13        A.   To the analysis department of the 2nd Administration; that is,

14     the intelligence administration.

15        Q.   Do you know what was done further on, how this information was

16     used further, where it was sent and so on?

17        A.   No.  Every administration that receives this information, that is

18     their own affair.  The 7th Administration is no longer interested in what

19     happens to this information in these documents.

20             MR. PETROVIC: [Interpretation] 2D690, could we please have a look

21     at that now.

22        Q.   Can you tell us which device was used to obtain this information?

23   (redacted)

24   (redacted)

25        Q.   What is the nature of the information contained in this document?

Page 19629

 1     Can you assess that?

 2        A.   Judging by what is written here, it is obviously intelligence.

 3        Q.   In the upper right-hand part of this document -- actually, could

 4     the witness please be shown the entire document so that he can see all

 5     the markings.  Thank you.

 6             So in the upper right-hand corner of this document, we see two,

 7     or, rather, three markings.  Can you tell us what this is about?

 8        A.   This is a document that was also generated by the

 9     7th Administration; that is to say, those who were involved in monitoring

10     telephones.

11             The numerical number is our number.  This is information that we

12     sent to administrations that were involved in work other than that of

13     intelligence, like counter-intelligence, and so on.  I've already

14     explained that.  Just as you had the numbers of reports there, you also

15     had the numbers here that were sent to the counter-intelligence

16     administration.

17             This is obviously a measure that was imposed at the request of

18     the counter-intelligence people because it has to do with the number of

19     the embassy, and it is usually the counter-intelligence people that asked

20     for that number.  This is a document from the counter-intelligence

21     administration that reached the assistant head.  I see that there is

22     something here.  And then this was sent to Franko Simatovic.  I assume

23     that this is his signature.  He organised information that had to do with

24     intelligence.

25             So this was the usual thing.  If something is found within

Page 19630

 1     counter-intelligence that is obviously intelligence, then that is sent to

 2     the intelligence department.  And vice versa.

 3             So this is one such document.

 4             JUDGE ORIE:  Could I ask one question, Mr. Petrovic.

 5             This is a telephone number which was intercepted, belonging to

 6   (redacted)

 7     interceiving [sic], I think I should say, numbers used by diplomats?

 8             THE WITNESS: [Interpretation] Foreign nationals, according to the

 9     principle involved, well, it would have to be the minister of the

10     interior.

11             JUDGE ORIE:  And that would include communications by diplomatic

12     staff which enjoy a certain protection?

13             THE WITNESS: [Interpretation] I don't understand what you mean

14     when you say "protection."

15             JUDGE ORIE:  Well, I mean communications and between --

16     communications between persons with a diplomatic status and their capital

17     is legally protected, isn't it?

18             THE WITNESS: [Interpretation] What I know from my own line of

19     work is that we never imposed measures generally, non-selectively.

20     Whenever measures were to be implemented, a separate decision would have

21     to be taken for each and every number.

22             Now, whether any of these had to do with diplomatic status, that

23     really depended on the person that provided the original proposal to have

24     the measure taken.

25             JUDGE ORIE:  So the procedure was finally the same for persons of

Page 19631

 1     foreign nationality and diplomats?

 2             THE WITNESS: [Interpretation] The decision was taken by the

 3     minister, yes.

 4             JUDGE ORIE:  Please proceed, Mr. Petrovic.

 5             MR. PETROVIC: [Interpretation] Thank you, Your Honour.

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)


Page 19632

 1                           [Open session]

 2             THE REGISTRAR:  We're in open session, Your Honours.

 3             JUDGE ORIE:  Thank you, Madam Registrar.

 4             Again, Mr. Petrovic, the last question/answer again where -- the

 5     answer given -- the answer did not respond to your question.  But if

 6     you're happy with that, then please proceed.  If you ask questions, I

 7     assume that you're interested to hear an answer to that question.

 8             MR. PETROVIC: [Interpretation] Of course, Your Honour.  I was

 9     expecting to receive more information from the witness.  However, the

10     witness did not have an opportunity to present that.  I don't really want

11     to waste time.  I just wanted him to help us with the device that was

12     used before this was deciphered --

13             THE INTERPRETER:  The interpreter did not hear the end of

14     Mr. Petrovic's statement.

15             JUDGE ORIE:  What did you say at the very end of your observation

16     a second ago, Mr. Petrovic, "before this was deciphered," and then?

17             THE INTERPRETER:  Could Mr. Petrovic please be asked to speak

18     into the microphone:  Interpreter's note.

19             JUDGE ORIE:  Mr. Petrovic, interpreters request that you speak

20     into the microphone.  Which is at your right.

21             MR. PETROVIC: [Interpretation] So, Your Honours, I just wanted to

22     see whether I could receive any information from the witness as to the

23     device that was used from obtaining this.

24             The witness gave us some idea what the device used could have

25     been, but ...

Page 19633

 1             JUDGE ORIE:  I'm not seeking long explanations.  I'm reminding

 2     you that if you put a question and you're interested in the answer, you

 3     should specifically ask for it, or, as apparently, you have decided here,

 4     to move on.

 5             What it would have helped us to know what device was used, is, of

 6     course, another matter.

 7             Please proceed.

 8             MR. PETROVIC: [Interpretation]

 9        Q.   Mr. Vujovic, can you be more helpful with this?  Can you tell us

10     which device was used in this situation?  We are talking about the

11     document on our screens right now.

12        A.   Absolutely not.  This is intercepted communication.  Now what was

13     used, there's no hint of that.  I was just speculating because it was two

14     soldiers that were talking that it might have been what I said, but I

15     cannot give a very precise answer, no.

16             JUDGE ORIE:  Let's move on.

17             MR. PETROVIC: [Interpretation]

18        Q.   As you look at the content of this document that is on the

19     screen, can you tell us whether this is a summary or a paraphrase or a

20     dialogue?

21        A.   Obviously this is a summary.  This is an account of an

22     intercepted conversation.

23             JUDGE ORIE:  Mr. Petrovic, that is so obvious from the text.  Why

24     do you ask this?  I mean, everyone who reads this can see that it's not

25     dialogue.  I mean ...

Page 19634

 1             But, please, I'll ask you soon how much time you would still

 2     use -- need.

 3             Please proceed.

 4             MR. PETROVIC: [Interpretation] Your Honour, I will be completing

 5     my examination-in-chief by the end of our working day.

 6        Q.   Mr. Vujovic, from when you started working in the RDB of the

 7     Republic of Serbia, do you know which position was held by

 8     Franko Simatovic?

 9        A.   After the merge took place, and after contacts started between

10     myself and Franko, specifically, Franko was special advisor.

11        Q.   At the time when Simatovic was special advisor, who headed the

12     2nd Administration, to the best of your knowledge?

13        A.   The deputy head of the administration, Dragan Filipovic.

14        Q.   Do you know what work was done by the deputy head of the

15     2nd Administration?

16        A.   If a head was not appointed, then the deputy head practically

17     acts as the head and does all the work that the head is supposed to carry

18     out.

19        Q.   You say that Simatovic held the position of special advisor.  Can

20     you tell us which activities specifically were within his purview as

21     special advisor?

22        A.   What I know from my experience and practice is that this had to

23     do with the organisation of collecting intelligence.  And due to his own

24     affinity, he was highly involved and full of energy with regard to the

25     application of new technology within that work and introducing new

Page 19635

 1     systems.

 2        Q.   Did Franko Simatovic accompany you to some trade events or fairs

 3     in 1994/1995?

 4        A.   Yes.

 5        Q.   Where did he go with you?  What kind of events are we talking

 6     about?

 7        A.   Within our areas of expertise, the area of expertise of the

 8     7th Administration, there are two fairs:  One in Athens and the other in

 9     Paris.

10             These are specialised fairs for invited audiences interested in

11     the use of electronics by the police and the military.  One year I

12     visited a Defendor in Athens with Simatovic.  And then I went to Tel Aviv

13     with Simatovic.  We visited a fair there.  We were together in Tel Aviv.

14        Q.   Can you remember when was that, what years?

15        A.   1995.  Or perhaps 1996.  Or perhaps 1994.  It's very difficult

16     for me to say.

17        Q.   Thank you, Mr. Vujovic.

18             MR. PETROVIC: [Interpretation] Thank you, Your Honours.  I have

19     no further questions for this witness.

20             JUDGE ORIE:  Thank you, Mr. Petrovic.

21             Mr. Jordash, you're next in line.  Would you have a subject

22     which -- for the first five minutes.

23             MR. JORDASH:  Yes, I think so, Your Honour.  Thank you.

24             JUDGE ORIE:  Mr. Vujovic, you will now be cross-examined by

25     Mr. Jordash.  Mr. Jordash is counsel for Mr. Stanisic.


Page 19636

 1             Please proceed.

 2                           Cross-examination by Mr. Jordash:

 3        Q.   Good afternoon, Mr. Witness.  I just want to, in the short space

 4     of time we have, ask you about your relationship with Mr. Stanisic.

 5             Have you ever worked directly with him?

 6        A.   I believe that the first time I met Mr. Stanisic was when he held

 7     a position in the republican MUP in the state security.  I was a member

 8     of the federal MUP.  They sought assistance from the federal service.  I

 9     was appointed to help them, and that's why we were involved in a joint

10     activity.  That was before the merger took place in 1992.

11        Q.   So was this in 1992?

12        A.   You mean the activity that I referred to?  If that's what you

13     have in mind, I would say that was before that.

14        Q.   Yes, the joint activity.

15        A.   That was while the federal services still existed.  And

16     Mr. Stanisic held a position - I don't which position - we were involved

17     in an operations or in an operative activity.  It was common practice

18     that the former republics sought assistance from the federal service, and

19     that particular activity was part of that practice.

20        Q.   And I'm not sure I follow that.

21             Was this in 1990 --

22             JUDGE ORIE:  No, please, I was about to ask whether the witness

23     remembers what kind of assistance was requested so to -- so as to give

24     the details.

25             MR. JORDASH:  I'll try to pick up on that, Your Honour.

Page 19637

 1             JUDGE ORIE:  Yes.

 2             MR. JORDASH:

 3        Q.   Was this in 1992 or before?

 4        A.   It was before.  I met him before.  But we were involved in only

 5     one joint activity.  That was the first time I saw Mr. Stanisic, and,

 6     after that, I saw him only in 1992.  Before -- in the meantime, we had no

 7     contacts at all, either official or private.

 8        Q.   So what was the joint activity and how long did it last?

 9             MR. JORDASH:  Oh, I think we're ...

10             THE WITNESS: [Interpretation] That was an action.  They wanted me

11     to help them with some sort of anti- -- or counter-intelligence activity.

12     It was a matter of routine.  It was a long time ago.  It was nothing

13     special.

14             MR. JORDASH:  Okay.  I think we might be in private session, I am

15     told.

16             JUDGE ORIE:  As far as I'm aware, we are not.  Usually if you use

17     it -- your screen, you'll find the indication.

18             THE REGISTRAR:  We're in open session, Your Honours.

19             JUDGE ORIE:  Thank you, Madam Registrar.

20             MR. JORDASH:  Thank you.

21        Q.   How long -- I'm trying to understand how well you know

22     Mr. Stanisic.  If you know him well, whether you're friends, whether

23     you've worked together for a long period of time before.  Can we try to

24     just shortcut this so that we don't dwell on it too long.

25             How well do you know him?

Page 19638

 1        A.   I got to know Mr. Stanisic better after the merger.

 2             Before that, we did not have any contact, either private or

 3     official.  However, I knew of him, like I knew of the other chiefs of

 4     services in the republic -- the republics.  I did not have any particular

 5     contacts with him before the merger of the two services.

 6        Q.   And is it right that you have known him professionally but you

 7     are not friends and you have never socialised together?

 8        A.   No, we did not socialise.  Mr. Stanisic was chief.  We saw each

 9     other at collegium meetings, extended collegium meetings, or when I had

10     to report to him in order to clarify things.  But all those were official

11     meetings or official occasions.

12        Q.   Thank you.

13             MR. JORDASH:  I don't know if that's a convenient moment,

14     Your Honour.

15             JUDGE ORIE:  Yes, I think it may well be.

16             One simple question.  You said it was all routine.  What was

17     exactly the assistance that you provided when you were still in the

18     federal service?

19             "We were involved in only one joint activity."

20             Could you describe what that activity was?

21             THE WITNESS: [Interpretation] Your Honour, while the

22     Socialist Federal Republic of Yugoslavia existed, the operations

23     equipment of the federal service was certainly best equipped.  It had the

24     best staff and the best equipment.  And additionally, it had --

25             JUDGE ORIE:  You're explaining why apparently you were involved

Page 19639

 1     in that.

 2             I would first like to know what you were involved in, what

 3     assistance was provided?

 4             THE WITNESS: [Interpretation] Your Honour, I'm trying to do that.

 5             The republics could not perform certain tasks, particularly some

 6     of the counter-intelligence tasks.  My group existed only in the federal

 7     service, and that's why I was involved in a routine job.  It was nothing

 8     special.  Only because the -- none of the republics could perform that

 9     type of activity.

10             JUDGE ORIE:  What was the routine job?  What was it?  That's what

11     I tried to ask you for a while now.

12             THE WITNESS: [Interpretation] That was a counter-intelligence.

13     We were duty-bound to protect federal facilities and individuals at that

14     level.  So we were probably called in to put in place facilities to

15     counter interception at such facilities.  And that was a matter of

16     routine.  It was nothing special.

17             JUDGE ORIE:  Yes, you still have not told me what it was.  What

18     it was probably may have been -- yes, Mr. --

19             MR. PETROVIC: [Interpretation] Your Honours, I believe that we

20     have problem with the interpretation.  The witness has been interpreted

21     as talking about counter-intelligence, and he is not talking about

22     counter-intelligence.  He is talking about something else.

23             JUDGE ORIE:  Yes.  Could you think it over what it exactly was

24     that you were supposed to do and then we could start with that tomorrow,

25     because at this moment we will leave it as it is.


Page 19640

 1             Mr. Petrovic, perhaps also unnecessary to remind that you D751,

 2     which you used after D748 and D749, is also MFI'd, pending further

 3     information on the provenance.

 4             I would like to instruct you, Mr. Vujovic, that you should not

 5     speak or communication in any other way - not by telephone, not by

 6     radio - with anyone about your testimony either already given in court or

 7     still to be given tomorrow, because we adjourn for the day and we resume

 8     tomorrow, Wednesday, the 23rd of May, at 9.00, in Courtroom II.

 9             We stand adjourned.

10                           [The witness stands down]

11                            --- Whereupon the hearing adjourned at 1.49 p.m.,

12                           to be reconvened on Wednesday, the 23rd day of May,

13                           2012, at 9.00 a.m.