150813ED

Page 37740

1 Examination by Mr. Ivetic: [Continued]

2 Q. Good morning, Colonel.

3 A. Good morning.

4 Q. I would like to start off where we left off yesterday. First can

5 we have again 1D05787 but not broadcast the same, and we'd want to have

6 page 56 in the Serbian, page 37 in the English.

7 And we left off at the paragraph 11.12.1, listing 1, 2, 3, 4,

8 5 -- 6 radio relay routes and ending with radio relay route number 644.

9 Before we address that list, I'd like to ask you about the next

10 line, which says:

11 "This shows that 76 channels were to be monitored ..."

12 Could you please clarify for us the total number of channels that

13 should be reflected in this paragraph.

14 A. When the number of channels is added up, 0431, 4791, and 0431,

15 4792, that is a total of 70 channels. When this was typed out, instead

16 of a 0, a 6 was typed out. So it should be 70 channels, really.

17 Q. And now looking at the routes that are reflected here, I take

18 note that the last one is radio relay route number 644, and the footnote

19 directs us to the document that I yesterday indicated was D879. I'd like

20 to now look at D879 with you.

21 A. Yes.

22 Q. And if we can go to the second page of the document in both

23 languages, I think we'll see at number 6 the radio relay route 644, and

24 there are an additional two entries, 7 and 8, on this page of the

25 document in the original Serbian and it continues on to the top of the

Page 37741

1 page in the English.

2 What can you tell us about these additional routes - namely, 0654

3 and 1052 - which are not printed in paragraph 11.12.1 of your expert

4 report with the other routes that are reflected as coming from this

5 document?

6 A. The frequencies were added, handwritten: 0654, number 7; and

7 also --

8 Q. I'm asking about in relation to your report. Since these entries

9 are not listed in your report, what do you want to tell us about the

10 omission of these entries from your report?

11 A. The number of channels in this document on the first and second

12 page, that's included in the 70 channels. However, I'm saying that this

13 entire page was omitted during typing.

14 Q. So these additional two entries for number 7 and number 8, should

15 we consider them as being part of that paragraph that we just looked at

16 in your report? Is that how I'm to understand what you're saying? And

17 that's paragraph 11.12.1.

18 A. Yes, correct.

19 MR. IVETIC: And now if we could return to 1D05787, and again

20 let's not broadcast it just to be on the safe side. And if we could turn

21 to page 66 in the Serbian and page 44 in the English.

22 Q. I see a -- well, we'll wait for the English. Oh, there it is.

23 I see in the original Serbian a quadrant box that says: a, b, c,

24 d. And then it says underneath: "Photograph no. 4 (from the internet)."

25 But we already have a photograph number 4 earlier in your report. What

Page 37742

1 can you tell us about these two items that are on the last page of your

2 report?

3 JUDGE ORIE: Could we also see the relevant English?

4 MR. IVETIC: It's on the bottom of the page, Your Honours.

5 JUDGE ORIE: Yes. But the box is not there, yes?

6 MR. IVETIC: That's correct.

7 JUDGE ORIE: Okay. Please go on.

8 MR. IVETIC: Oh.

9 JUDGE ORIE: Yes, I'm sorry.

10 MR. IVETIC: I apologise.

11 Q. Sir, what can you tell us about these two items that I've drawn

12 our attention to on this last page?

13 A. During scanning, it got to this page out of carelessness.

14 Nothing more than that.

15 Q. Do we need to consider these two items as part of your report or

16 not?

17 A. No, no. No.

18 Q. Now, sir, apart from these corrections that we've gone through

19 today and yesterday, do you believe the remainder of your report to be

20 correct and accurate?

21 A. I do.

22 Q. Do you stand by your report from the perspective of your

23 knowledge, experience, and expertise in military communications?

24 A. Fully.

25 MR. IVETIC: Your Honours, I would ask for the report to be

Page 37743

1 marked for identification, to be tendered later on after completion of

2 all questioning and submissions by the parties.

3 JUDGE ORIE: Yes. We'll wait for that moment.

4 Nevertheless, Mr. Ivetic, I'm still puzzled by the line: "When

5 the number of channels is added up," and then a few numbers appear, "that

6 is a total of 70 channels." I have got no idea what is added up there.

7 Certainly not the numbers there. I'm just lost there.

8 MR. IVETIC: Okay.

9 JUDGE ORIE: Could you please --

10 MR. IVETIC: If we can --

11 JUDGE ORIE: -- spell that out for us with the witness in more

12 detail.

13 MR. IVETIC: Okay. If we could then return to page 37 in the

14 English and page 56 in the Serbian.

15 JUDGE ORIE: It looked as if these were ERN numbers in the

16 footnote 48, but ...

17 MR. IVETIC: They are.

18 JUDGE ORIE: Yes.

19 MR. IVETIC: And that relates to document D879 that we looked at.

20 JUDGE ORIE: So what actually is added is the number of routes

21 that is found on those pages? Is that --

22 MR. IVETIC: The number of channels in those routes that are

23 found on those pages, as each route --

24 JUDGE ORIE: Yes.

25 MR. IVETIC: -- has multiple channels.

Page 37744

1 JUDGE ORIE: Yes. Okay. Now I better understand what we are

2 talking about.

3 JUDGE MOLOTO: But if I may add to the confusion. That sentence

4 that Judge Orie referred to gives the total of 70 with respect to

5 route 644 only. What about the other five routes that are mentioned on

6 that list?

7 MR. IVETIC: It says "not including," so that -- that 70 channels

8 is everything except for route 0674.

9 JUDGE MOLOTO: 67 -- 644.

10 JUDGE ORIE: Yes, now --

11 MR. IVETIC: So the correction is, first of all, to the reference

12 to 76, which should be "70," and the text reads:

13 "This shows that now 70 channels were to be monitored not

14 including the secure channels on radio relay route number 0674."

15 JUDGE MOLOTO: Thank you.

16 JUDGE ORIE: Yes. And the witness now refers to ERN numbers

17 of -- well, of -- looked at military [indiscernible] which are not in

18 evidence yet?

19 MR. IVETIC: They are. It's D879. It's an exhibit already.

20 JUDGE ORIE: Then I have missed that. Apologies for that.

21 Please proceed.

22 MR. IVETIC: Okay.

23 JUDGE ORIE: Yes, of course, the document is to be marked for

24 identification awaiting further submissions and a decision on admission.

25 Mr. Registrar.

Page 37745

1 THE REGISTRAR: It shall be assigned Exhibit D1187 MFI. Thank

2 you.

3 JUDGE ORIE: D1187 is marked for identification.

4 [Trial Chamber and registrar confer]

5 JUDGE ORIE: Do we need to have it under seal?

6 MR. IVETIC: I think we do. There are some parts that should be

7 under seal, so we should do the whole thing under seal.

8 JUDGE ORIE: Okay. Marked for identification under seal.

9 MR. IVETIC:

10 Q. Sir, now I would like to follow up with some items from your

11 report that has now been marked D1187, MFI, under seal. Let's look first

12 at page 3 in both languages and paragraph number 2 of the same. And in

13 the middle of that paragraph, you say:

14 "The ABH had RP-2M, 2-12MHz frequency banned interception devices

15 of domestic (Yugoslav) manufacture ..."

16 What kind of devices or transmissions did these have the ability

17 to intercept?

18 A. According to establishment, all brigades of the

19 Territorial Defence in the former Yugoslavia had this RP-2M with 2 to 12

20 megahertz frequency band, and it was supposed to report on enemy flights.

21 So I'm certain that the brigades in the Army of BH, as in the Army of

22 Republika Srpska, had these receivers, and with them one could follow

23 radio traffic from 2 to 12 megahertz.

24 Q. And in the continuation of this paragraph, you identify reception

25 devices of the Japanese firm Ikon, Kenwood, and the AOR, which were the

Page 37746

1 basis of the ABH interception system. Were these devices what would be

2 considered professional military grade or amateur grade manufactured

3 devices?

4 A. The mentioned pieces of equipment, Japanese made, could have been

5 obtained in the free market, and they were only for ham radio operators

6 and other structures. People who dealt with communications by way of a

7 hobby. And then also there were some companies that used this. The only

8 piece of equipment here that had a military version was, I mean, 450S.

9 It had a military version. The rest, no. And, of course, such devices

10 are weaker than professional devices that armies had and still have.

11 Units equipped for electronic surveillance, that is.

12 Q. If I could ask you to explain the last part of your answer that

13 you gave when you said: "Such devices are weaker than professional

14 devices"? What does that mean in terms of the technical capabilities or

15 operation of those devices?

16 A. This is what it means: When a device is manufactured, everyone

17 who places an order says what the technical capacity should be. So the

18 devices of the Army of BiH were such that they probably wanted to hear

19 the participants that were far away. However, when the army asks for

20 that, they want to hear a participant that they are following even

21 outside the range. So that's the essence.

22 So these receivers are a lot more sensitive and they can operate

23 in all weather and other conditions, whereas the former are not equipped

24 in that way. That is what I have to say.

25 Q. So you could clarify once again. You said:

Page 37747

1 "These receivers are a lot more sensitive and they can operate in

2 all weather and other conditions, whereas the former are not equipped

3 that way."

4 Could you tell us which receivers are more sensitive? Was it the

5 amateur grade or the professional military grade that you are talking

6 about?

7 A. The devices that the BH Army had, Japanese made, these are

8 devices that are intended for civilian structures, and they do not have

9 the kind of performances that professional ones do, those that are

10 ordered by the military.

11 Q. And again, of the two types - the types ordered by the military

12 or the amateur ones for civilians - which are more sensitive? Which

13 receivers are more sensitive?

14 A. Military devices are always more sensitive. And as I have said,

15 they need to meet other challenges, like the configuration of the land,

16 weather, and the way in which they are being used. It's not the same as

17 if you use something in a tent, a dugout, et cetera, or something that

18 you use in an office where the temperature is always right and so on and

19 so forth, when there is no dust, when there are no other influences of

20 that kind.

21 Q. Now looking at paragraph 3 on the same --

22 JUDGE ORIE: Before we move on. Witness, you have told us what

23 type of equipment the BH had and sensitivity, civilian use, military use.

24 What's the basis of your knowledge for what exactly was within the BiH

25 available as equipment?

Page 37748

1 THE WITNESS: [Interpretation] Your Honour, I know what the Army

2 of Bosnia and Herzegovina had on the basis of the documents that were

3 provided to me by the law office. Nothing more than that.

4 JUDGE ORIE: So the basis for it is the documentation you

5 received from the Defence, is that what you're telling us?

6 THE WITNESS: [Interpretation] Yes, yes.

7 JUDGE ORIE: Could you tell us then exactly what you received?

8 Do you have a list or what is it that you received from the Defence?

9 THE WITNESS: [Interpretation] From the Defence I received a

10 document, I mean, about the devices that stations north and south had;

11 those interception stations. And then on the internet, I found these

12 pieces of equipment, I photographed them -- or rather, scanned them and

13 attached them to my paper.

14 JUDGE ORIE: So if I understand you well, you are saying that

15 your answers are based on information the Defence provided to you and on

16 what you found on the internet?

17 THE WITNESS: [Interpretation] Yes, that's right.

18 JUDGE ORIE: Please proceed.

19 MR. IVETIC: And we'll get to it later, Your Honours, but I can

20 already let the parties know 1D01081 and 1D01082 are, I believe, the

21 documents for the northern and southern facilities that the witness has

22 just mentioned. If --

23 JUDGE ORIE: The Chamber then, of course, expects to -- in the

24 best way possible that it's already clear from the report what the

25 sources of information are. But at least it's good to hear that we'll

Page 37749

1 hear more about it soon.

2 MR. IVETIC: If we can look at paragraph 3 on the same page in

3 both languages.

4 Q. Here you say in talking about the level of measures implemented

5 by the 2nd Corps, and procedures were similar in other corps, made for

6 minimum chance of interception. Can you tell us: Were these measures

7 that were being undertaken by the 2nd Corps undertaken to any specific

8 orders?

9 A. All measures that were taken with a view to protecting the

10 communications system are studied during schooling. That's the way it

11 was in the JNA. That is prescribed by rules, how one should act in a

12 particular way. It wasn't that any special order was written up during

13 the war, because that went without saying that this had to be done.

14 However, if there were to be some violation - and this kind of thing did

15 happen - and if there were some shortcomings in terms of electronic

16 surveillance, then that would happen.

17 The 2nd Corps did the same thing too, because the communications

18 people in all the units were trained in the same schools. So it is only

19 natural that they took the same measures.

20 Q. Looking at page 5 in both languages and -- I'll wait for that.

21 Looking at item or paragraph number 1.1.4, here you mention the PTT

22 service and its use. How was the PTT service used by communication units

23 of the VRS?

24 A. The communications system of the Army of Republika Srpska was

25 linked into the other communications systems, mostly with the PTT. When

Page 37750

1 it was necessary, certain devices and lines were appropriated for the use

2 of the Army of Republika Srpska, and this link can best be seen in this

3 diagram here in Attachment 6 where you can see that we used underground

4 cables of the PTT, also the wire overland connections, and then also some

5 services from the PTT to transfer military communications. The

6 cooperation went so far that perhaps if some post office was within the

7 zone, then they would work together with the army communications units

8 but they wouldn't leave their places of work. They would just be

9 carrying out instructions given by some organ of the corps or any other

10 unit that happened to be in that area.

11 Q. What can you tell us about these PTT systems when used in this

12 manner by the army? What can you tell us about any civilian or consumer

13 use of those systems during that time?

14 MR. McCLOSKEY: I'm sorry, can we just clear up which army?

15 JUDGE ORIE: I think in the context you referred to the VRS,

16 Mr. Ivetic?

17 MR. IVETIC: That's correct.

18 JUDGE ORIE: I have difficulties in looking at it in any other

19 way.

20 When Mr. Ivetic referred to "the army," it's the VRS, Witness.

21 Could you please answer the question.

22 MR. IVETIC: Perhaps I can repeat it.

23 Q. Sir, what can you tell us about these PTT systems when used in a

24 manner that you described by the VRS in terms of civilian or consumer use

25 of those same systems during that time?

Page 37751

1 A. Using the PTT communications occurred if it was in a combat zone,

2 then the civilian sector didn't have any need to use that service. But

3 mostly the PTT exchanges were located in the depth, while air or

4 underground cables were also in combat zones and they frequently linked

5 the PTT centres of the entire former Republic of Bosnia-Herzegovina.

6 So, for example, if we take Kupres and Bugojno, there would be a

7 line. That line remained in place, and our side used it for military

8 tasks from Kupres to the line of separation. And then if the

9 B and H Army was there, it would be from the line of separation with the

10 Army of Republika Srpska to Bugojno. So then it was all covered.

11 While, for example, post offices in all places also provided

12 services to the civilian structures; thus, taking certain capacities and

13 resources was not supposed to interfere with the actual work of all the

14 PTT facilities.

15 Q. Would there be military and civilian traffic on the same PTT

16 network simultaneously and the same resources within the PTT network?

17 A. It was possible. For example, if it was a permanent connection,

18 one line would be taken by the army. And then if there were two, three,

19 four, the rest would be used by the PTT. They could loan the use of one

20 line. And if it was essential, an order would be issued so that a

21 certain amount of the resources or the capacity would be loaned to the

22 army for their needs.

23 Q. In relation to that in this example you said "one line that could

24 be taken by the army," would there be civilian traffic on that one line

25 taken by the army?

Page 37752

1 A. I've already said it. If it was that kind of route, the civilian

2 sector would not be using it because they would not be covering the area

3 that was under the control of the Army of Republika Srpska at the other

4 end. So, for example, the PTT had no need for such a route, and then the

5 army would be using it in its entirety.

6 MR. IVETIC: Now if we can turn to page 8 in English and page 10

7 in the Serbian and look at 3.4.7. And I believe we need to go to page 10

8 in the Serbian -- or 8 -- no, 10, 10. 10.

9 Q. Sir, in this paragraph, 3.4.7, you are talking about

10 communications systems of the MUP and municipalities. Did the VRS

11 utilise or enter into these communication networks of the MUP?

12 A. As I said here, there were others who had communication systems,

13 such as the Ministry of the Interior, the centres for alerting, then also

14 the electric utilities system, radio, television, and so on. The army

15 did not use those systems and did not take any of those devices. It just

16 acted in cooperation with these people. Perhaps they used or exchanged

17 telephone lines; for example, if the Ministry of the Interior was engaged

18 on a task, they had their own communications system and we did not use

19 that system, but we did have a device to communicate with the commanding

20 officer from that task and from that service.

21 Q. You've answered my next question, so now we can move to page 9 in

22 the English and page 11 in the Serbian. And paragraph 4.5. And here you

23 talk about both MUP and PTT equipment at features in addition to army

24 equipment at communications features. Can you tell us who maintained

25 each type of equipment? That is to say, army equipment, MUP equipment,

Page 37753

1 PTT equipment.

2 A. Communications conducted through radio relay nodes were located

3 at certain salient features and elevations in order to be able to

4 maintain the communications properly. At these features, we often had

5 devices from the army, the Ministry of the Interior, and the PTT, and

6 everybody would have their own rooms and their own devices at that

7 facility. They had common logistics, if I may use a military term for

8 that, and combat support. But everything else -- and also at a higher

9 level, the use of frequencies was coordinated as well as the system of

10 cooperation among these different users.

11 JUDGE ORIE: And do we now know who maintained that equipment?

12 Because that was the question. You told about coordination, you told

13 about use, but who maintained that equipment?

14 Apparently that's what you want to know, Mr. Ivetic.

15 THE WITNESS: [Interpretation] Each of the users maintained their

16 own equipment. Assistance -- mutual assistance was never ruled out,

17 though.

18 JUDGE ORIE: Yes. Now we have an answer to the question.

19 Please proceed.

20 MR. IVETIC:

21 Q. If we could turn to page 10 in the English and page 12 in the

22 Serbian of your report, and you have there diagram number 2. And I

23 believe if we look at 1D05788, we should have a bigger, clearer

24 photograph of that diagram.

25 A. It's better now.

Page 37754

1 Q. And now we have it in both languages. Now, could you briefly

2 explain for us what the colours and the denotations on the original mean

3 in terms of what is depicted?

4 A. Communications in the Army of Republika Srpska ended at the

5 command post, while the final users were the commanders at the operations

6 centres and also at the telephone exchange.

7 What we see here is a diagram that was used by the personnel

8 working in the operations centre. And they were supposed to know how to

9 set up communications with specific units; which means if it was a wire

10 link, then the system of securing the link was lower. But if it was a

11 radio relay communications, then they had to stick to strict rules for

12 encryption of data.

13 For example, here in red we see in the middle it says "11 lpbr."

14 Communications with that unit were maintained only via radio relay links.

15 I'm sorry. So the colour red leading to the 11th Light Infantry Brigade

16 indicates a radio relay link which means that they needed to pay

17 attention to data protection. And then this was also linked with their

18 operations centre, because operations centres were also linked amongst

19 themselves from the Main Staff towards the corps and the other commands.

20 Then you had the direct phone line of the commander, that was linked in

21 as well as all the others.

22 Could I please look at the right side of the diagram? This is

23 going to the left. I need the other side, please. All right. This is

24 good. At the bottom underneath, we have these rectangles.

25 JUDGE FLUEGGE: Please don't touch the screen.

Page 37755

1 THE WITNESS: [Interpretation] All right. And they are part of a

2 large rectangle representing units. So if a communication -- if a

3 communication line -- actually, if the rectangular has nothing on it,

4 that means that that link is maintained by an induction telephone. For

5 example, with the 5th Light Infantry Brigade, the 3rd Light Infantry

6 Brigade as well, if there is -- if the rectangle is crossed with one

7 line, one diagonal line such as the 9th Light Infantry Brigade, then that

8 indicates that the communication is maintained through a telephone

9 exchange. It's not directly linked.

10 If there are two lines in the rectangle, that means that the

11 communications are maintained directly through the PTT by dialling an

12 automatic telephone number which is connected to that exchange. And so

13 you have these -- motorised battalion and another battalion. That's the

14 case with them. And both of those units were in Drvar.

15 MR. IVETIC: If we could tender 1D05788 as the next public

16 exhibit at this time.

17 JUDGE FLUEGGE: Mr. Ivetic, the problem is in the English

18 translation. The legend is missing, at least on this page.

19 MR. IVETIC: Let's see if it's on page 2. I apologise.

20 JUDGE FLUEGGE: And the connecting lines between the boxes are

21 missing.

22 MR. IVETIC: I know. Yeah, the legend is on this page. And,

23 unfortunately, this is how we received it from CLSS, so ...

24 JUDGE ORIE: And if you receive something which is

25 incomprehensible for the Judges, you say it comes from CLSS so therefore

Page 37756

1 we present it to the Judges. Is that the position the Defence takes?

2 MR. IVETIC: No, Your Honour, that's why I have it side by side

3 with the original, and I've asked him to explain the coloured lines on

4 the original. That's, I believe, been the practice in this case when

5 there's documents, when there is diagrams that are not shown that there

6 are translations of the notations, and the diagram one looks at the

7 original. That's the way we've been doing it since the beginning.

8 That's why I put them side by side so Your Honours could see the colours

9 and the lines.

10 JUDGE ORIE: Then I misunderstood the previous conversation.

11 Apologies for that.

12 JUDGE MOLOTO: Mr. Ivetic, if you could just repeat the 1D

13 number.

14 MR. IVETIC: Yes, Your Honours, it's 1D05788.

15 JUDGE ORIE: And then could we hear from the witness, from the

16 legend on the second page in the English, the dotted line, the third in

17 the legend, could you tell us what that stands for? Can you read it?

18 You see that, Witness?

19 No, I'd like to have it --

20 THE WITNESS: [Interpretation] I don't know how it was translated.

21 The dotted line indicates an induction line. It's a communication

22 maintained by an induction telephone. A field telephone. One that you

23 use by turning the handle on it. So it's a field telephone. And you can

24 use it in the same way that you use a normal telephone, but it's just not

25 a direct line.

Page 37757

1 JUDGE ORIE: And what does it read? How does it read, literally?

2 So the first line is RR, the second line is wire link --

3 THE WITNESS: [Interpretation] Induction direct line.

4 JUDGE ORIE: No objections, Mr. McCloskey?

5 Then, Mr. Registrar.

6 THE REGISTRAR: It shall be assigned Exhibit D1188. Thank you.

7 JUDGE ORIE: Admitted into evidence.

8 Please proceed, Mr. Ivetic.

9 MR. IVETIC: Thank you.

10 Q. If we could return to your report, which is D1187, marked for

11 identification, under seal, and turn to page 13 in the Serbian and

12 page 10 in the English. We have here a diagram at number 3 as an example

13 of the working of the telephone centrals at the 2nd Krajina Corps,

14 Obrazac DV1. For this, I'd like to call up 1D5789, which should be the

15 original and translation.

16 And we see here also that there are colours in relation to the

17 lines on the original Serbian document. Could you please confirm for us

18 if those colours are -- mean the same as they do in the one we just

19 looked at or if it's something different?

20 A. Again here, the coloured lines indicate different ways that

21 telephone exchanges are connected. So the red colour indicates that the

22 communication is maintained through a radio relay link.

23 Q. And where would these forms be posted or made available in a

24 corps command?

25 A. This diagram would be part of the documents of the commander of

Page 37758

1 the communications battalion that is facilitating the connections. They

2 would come to me as the chief, and they would be issued to other

3 commanding officers who were actually executing these communications so

4 that they know how the communications were organised, with which units,

5 and on how many channels, and this would be along the line of the

6 exchanges, the operation centres, and the commander. This diagram would

7 not be sent to other commanding officers or senior officers in the corps,

8 only to a communications unit's senior officer.

9 Q. And we see in the middle for the 2nd KKKM, which I believe is

10 "command centre," "command post," we see the term "oblak." What is

11 "oblak"?

12 A. This form is given in the rules for communications. This is form

13 DV1. According to that form, the telephone exchanges are represented by

14 a circle. The central circle is the main exchange for that unit. And

15 it's divided into three parts: The top part is where the name of the

16 unit is, by establishment; for example, the command of the 2nd Krajina

17 Corps. Then underneath that, there is the secret name, that's "oblak,"

18 and then that same thing applies to the other smaller exchanges. The

19 links connecting them - for example, the first line on the left, it's

20 quite small, but it says "album," that's the secret name - and then there

21 is a small circle split into two where in the upper half of the circle

22 there is the number of the telephone channels and at the bottom there is

23 the number of the telegraph channels, the teleprinter links.

24 Some units that had teleprinters could also maintain teleprinter

25 communications. But those who were not supposed to have it by

Page 37759

1 establishment, did not have teleprinter links. So then the diagram would

2 indicate to the officer what kind of communications he could have with

3 the other unit.

4 MR. IVETIC: Your Honours, I would tender 1D5789 at this point.

5 JUDGE ORIE: Mr. Registrar.

6 THE REGISTRAR: It shall be assigned Exhibit D1189. Thank you.

7 JUDGE ORIE: Admitted into evidence.

8 Any need to have it under seal?

9 MR. IVETIC: No, not this one.

10 JUDGE ORIE: Please proceed.

11 MR. IVETIC:

12 Q. Now, if we return to your report, which is D1187, marked for

13 identification, under seal, and look at page 17 in the Serbian and

14 page 12 in the English.

15 And -- I'll wait for the English. Here in paragraph 5.3, you are

16 talking about Jastrebac documents. Now, I want to know a little bit more

17 about these documents. To understand when you say: "They could be used

18 without fear of disclosure even though all the armies after 1991 had

19 them," could you please explain to us how that can be.

20 A. The Jastrebac documents were drafted by the JNA. There were nine

21 books in that set of documents; secret names, call signs, ID tables,

22 frequencies of all the devices, and I mean radio relay devices as well.

23 And so this was drafted army by army and from republic to republic for

24 each one. When the former JNA disintegrated, all the newly formed

25 armies, up until a certain time, kept those documents and operated

Page 37760

1 according to the documents. There was no fear that data could be leaked

2 unless there was interception. Those who did the interception knew that

3 these documents were being used. They knew the other armies, the manner

4 in which they operated, their documents, and so on.

5 So here we have the ID table. That book has 99 pages. And the

6 chief of communications, when he tells his subordinates which table to

7 use, he would say, let's say, table 7555, and then he would provide the

8 key for the use of that particular table, because without a key it

9 wouldn't mean anything. So he would provide the key, and now those who

10 wanted to identify their collocutors, they would, for example, ask, and

11 I'm going to give you an example: They would say "86," and then when you

12 look at the intersection between those two numbers, you see the number

13 988, which means that that is correct. And then that number is

14 immediately crossed off, and it cannot be used anymore for as long as

15 this table is in use. And then for each subsequent operation, a new

16 document would be issued and that, of course, implies new tables. And

17 that would be a new table for the call signs, for frequencies, for secret

18 names, and so on and so forth.

19 JUDGE ORIE: Mr. Ivetic, I'm looking at the clock.

20 MR. IVETIC: We can break at this time, Your Honours.

21 JUDGE ORIE: Yes. We take break and we would like to see you

22 back in 20 minutes.

23 [The witness stands down]

24 JUDGE ORIE: We will resume at 5 minutes to 11.00.

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

Page 37761

1 --- On resuming at 10.59 a.m.

2 [The accused not present]

3 JUDGE ORIE: We're waiting for the witness to be escorted into

4 the courtroom.

5 The Chamber is considering to adapt the schedule but is still

6 busy making the necessary calculations where, as is now also put on the

7 record, Mr. Mladic has waived his right to be present and is not in

8 court.

9 [The witness takes the stand]

10 JUDGE ORIE: Mr. Ivetic, meanwhile you may proceed.

11 MR. IVETIC:

12 Q. Sir, looking at paragraph 5.4 of your report, and it's the last

13 line in B/C/S before going on to the next page in Serbian, and it is the

14 last sentence in English, it says that the A-B key was difficult to

15 decode because numbers were changed by machine or out of a hat.

16 Could you please explain how that would work? What does that

17 mean?

18 A. Keys are the basis for the protection of this table, so it's not

19 the table itself. It's the keys. The keys were made by machine, and

20 this was done by the communications organ. In a situation when there

21 wouldn't be the right kind of equipment to make a key, and then on little

22 pieces of paper numbers would be made, written down from 01 to 99 --

23 THE INTERPRETER: Interpreter's note: Could all other

24 microphones please be switched off. Thank you.

25 THE WITNESS: [Interpretation] Then all these little pieces of

Page 37762

1 paper would be put into a hat and then numbers would be taken out - 10,

2 20, 30, no matter how many are needed. And I've already said that once a

3 certain number is used from the list, then that one is crossed out and it

4 cannot be given again. And for each and every operation and for a

5 certain number of days, there is always a different table and, of course,

6 a different key.

7 MR. IVETIC: If we can go back one page in the B/C/S.

8 Q. When referring to a --

9 MR. IVETIC: And if we can zoom in on the photograph at the top.

10 Q. When referring to a key, which part of the table represents the

11 keys that would be done by machine or out of a hat?

12 A. In the upper left-hand corner in this table it says B-A; that is

13 to say, column B is the horizontal key and column A is the vertical. So

14 what I said: One number from the horizontal, one from the vertical, and

15 then the number that is the ID is obtained in that way.

16 MR. IVETIC: Your Honours, there is an original with an English

17 translation, it's 1D5791 of this table, but I will not be tendering it as

18 I don't think it adds much to the comprehensions and [indiscernible]

19 numbers involved and the --

20 JUDGE ORIE: I think it's pretty clear as it is now.

21 MR. IVETIC: Okay. Then if we can look page 17 in the Serbian

22 and page 12 in the English.

23 Q. You identify in footnote number 18, talking of instructions for

24 identifications in telephone and radio communications from the internet

25 which show that the Croats used that system.

Page 37763

1 MR. IVETIC: If we could just briefly look at 1D5792.

2 THE REGISTRAR: Could it be a different number? This one isn't

3 in e-court. Thank you.

4 MR. IVETIC: 1D05792 is what I have listed. I think I'll just

5 move on and we'll come back to that if need be.

6 Q. If we can look at, staying in your report, then, page 24 in the

7 Serbian and page 18 in the English. And here you are describing

8 diagram 4 in the English, whereas it's the page where the diagram is in

9 the Serbian original.

10 MR. IVETIC: And if we could see 1D05796 in e-court. And if we

11 wait for the translation.

12 Q. Is this the same schematic that we just looked at in your report?

13 A. It's the same. Except that this one is a lot clearer.

14 Q. If we could look for a moment. The name of the unit that is just

15 below Dubrava, could you please read that into the record as the

16 translation does not have that information.

17 A. This rectangle here, Dubrava, between the triangle and the

18 circle, what is written, it is the 3rd lpbr ; that is to say, the

19 3rd Light Infantry Brigade, and there is radio communication with it. Up

20 there in that rectangle, you can see a triangle where says "inside 20,"

21 and above it it says "30," which means that it is radio network 30, and

22 "VF" is used. Also, "VVF," these circles, next to the circle it says 31

23 and also it says 2/2 in the circle, and that means "VVF/22K" that has a

24 protection device on it.

25 In addition to that, to the far right, there is another circle

Page 37764

1 where it says 12. That is a reserve radio network in case another unit

2 gets involved if there is a combat operation going on and so on, or if it

3 is necessary to organise an entire network. Documents are planned,

4 reserve documents for these reserve devices, or rather reserve radio

5 networks.

6 Q. And if you could just --

7 JUDGE ORIE: Could I just seek --

8 You said in the triangle we see "20" and then above it it says

9 "30." Is that in the Dubrava --

10 THE WITNESS: [Interpretation] Yes.

11 JUDGE ORIE: Is that in the Dubrava box or is it in the Livada

12 box which is just above the Dubrava box?

13 THE WITNESS: [Interpretation] Where it says "Dubrava," I've

14 explained that that is the 3rd Light Infantry Brigade, and it

15 communicates with the superior command up there where it says Livada.

16 And then in that triangle, it says which radio networks are involved and

17 which units are subordinated to this Livada, if we should call it that.

18 That's the command, isn't it.

19 JUDGE ORIE: I think I now better understand what you meant.

20 I also noticed that apparently some changes or redactions have

21 been made in the Dubrava box. It looks as if pencil writing has been

22 rubbed out and replaced. Do you know anything about that? Do you know

23 why there were changes and when they were made and whether they were

24 made?

25 THE WITNESS: [Interpretation] Your Honour, this document, as can

Page 37765

1 be seen in the upper right-hand corner, was elaborated for an operation

2 called Grmec. So this is a working document. I attached it. These are

3 my documents that I worked on, and probably during the course of this

4 work something had to be changed, improved, something had to be done.

5 JUDGE ORIE: Yes. And it dates from what time, Operation Grmec

6 was when?

7 THE WITNESS: [Interpretation] Your Honour, well, as far as I can

8 remember it was in 1994. Sometime at Suva Medja. That's

9 Bosnia-Herzegovina, across the Una, on the left bank. I'm not 100

10 per cent sure but I think that's it.

11 JUDGE ORIE: So it's just used as an example as to how it works

12 for operations. Thank you.

13 THE WITNESS: [Interpretation] Yes, yes.

14 JUDGE ORIE: Please proceed.

15 MR. IVETIC:

16 Q. And the names we have along the right-hand side - Livada,

17 Dubrava, then one that cannot be read, Grude, Bastilja, Djoker and

18 another one that cannot be read - what are those -- what are those names?

19 A. Within the rectangle, it says that the unit has an establishment

20 name. Grude, for example, is the 15th Brigade. So on the right-hand

21 side, you actually have the secret names, the code names of these units.

22 And it's only the organiser of the communication that uses this document.

23 It's not the operators. It's stations that use this document. They

24 don't know which unit is involved. They just know the code names.

25 Q. If we could --

Page 37766

1 JUDGE FLUEGGE: But can you identify the word between Dubrava and

2 Grude? Can you read that?

3 THE WITNESS: [Interpretation] I think it says "Oroz."

4 JUDGE FLUEGGE: And perhaps we can scroll down a bit.

5 THE WITNESS: [Interpretation] Oroz.

6 JUDGE FLUEGGE: And then we see Djoker. And below that, what

7 could that be?

8 THE WITNESS: [Interpretation] Underneath Djoker?

9 JUDGE FLUEGGE: Yes.

10 THE WITNESS: [Interpretation] It's written like "this." It seems

11 to be the word "this." Now why, I mean, you know, it's a working

12 document.

13 JUDGE FLUEGGE: Thank you.

14 THE WITNESS: [Interpretation] These were documents that were my

15 personal documents, and I always carried them with me, and that is how

16 these documents reached you, Your Honours.

17 JUDGE FLUEGGE: Thank you.

18 MR. IVETIC: If we could now then tender this document, which is

19 1D05796.

20 JUDGE ORIE: Mr. Registrar.

21 THE REGISTRAR: It shall be assigned Exhibit D1190. Thank you.

22 JUDGE ORIE: D1190 is admitted into evidence.

23 Now, all the other names are translated for us, such as Dubrava

24 being "forest." What does "Oroz" mean? And I don't expect you to

25 explain that in English, but perhaps where the transcript says "Oroz,"

Page 37767

1 whether that is an existing word and what it means, this is a question to

2 the interpreters.

3 THE WITNESS: [Interpretation] Am I the one who is supposed to

4 give an answer?

5 JUDGE ORIE: No, you are not supposed -- well, unless you would

6 know what the word "Oroz" means in English, then ...

7 THE WITNESS: [Interpretation] Of course I know what Oroz means.

8 In Serbian, Oroz means -- well, there is two things. For example, on an

9 old-fashioned rifle, the part that is cocked in order to hit the cap,

10 that is called Oroz, that is one meaning. And Oroz is also a chicken; or

11 to be more precise, a rooster.

12 JUDGE ORIE: Yes, well, now we have a broad choice of how to

13 understand it next to the forest, the snowball, the Bastilja and the

14 Djoker.

15 Please proceed.

16 MR. IVETIC: Thank you. If we could return to D1187, marked for

17 identification, under seal, and if we could turn to page 21 in the

18 English and page 28 in the Serbian.

19 Q. And looking at paragraph 8.2.5 on this page, you say here that

20 the VRS used existing nodes and set up RR CV at Mount Ozren, Veliki Zep,

21 and Gucevo. Does that mean that these nodes did not previously exist

22 prior to the formation of the VRS?

23 A. When I said that these were newly established ones, that is to

24 say, up until the war, they did not exist. The Main Staff came to

25 Crna Rijeka, to that area, and then there was this former JNA facility

Page 37768

1 there, and then Veliki Zep was built there, the radio relay node. Then

2 down there, above Mostar - Velez, that's it - there was also a radio

3 relay node. It was taken by the HVO, however.

4 So for the Herzegovina Corps, a new radio relay node was built at

5 Leotar. Because of communications with VRS units on the left bank of the

6 Drina river, it was a problem to establish communications, so the

7 conclusion was reached that a new node should be placed on the right bank

8 of the Drina river. And then with the agreement of the then Federal

9 Republic of Yugoslavia government, the VRS was allowed to use its own

10 resources to build a new node at Mount Gucevo.

11 Q. And, sir, just for purposes of clarifying the record, could you

12 please repeat the name of that last mountain that was built with the

13 permission of the Federal Republic of Yugoslavia government.

14 A. The name of the mountain is Gucevo.

15 Q. And if we can now turn to page 23 in English of your report, and

16 it will be pages 32 through 33 in the Serbian. We have another diagram,

17 and I'd like to look at 65 ter number 1D05800.

18 And now in your report at paragraph 8.2.16, you say:

19 "The marked participants, marked yellow in the diagram, are

20 linked by radio relay communications. Use of general KZ documents

21 required."

22 Now, while we are here looking at the document, we can see which

23 ones are marked in yellow. Can you tell us what are KZ documents or KZ

24 documents?

25 A. This diagram shows the plan of communications for carrying out an

Page 37769

1 operation for the 1st Krajina Corps and the 2nd Krajina Corps. And then

2 further down, the operations centre, OC, was established for carrying out

3 that operation. IFP 11 is an intercom that links ten participants. Five

4 of them use radio relay communications.

5 Since there wasn't equipment for cryptographic encoding, then

6 general documents by way of a crypto-encryption had to be used.

7 Beforehand, it was called TKT, "secret command over troops." That

8 includes a map, other equipment, a signals table, and other documents

9 that were needed and, of course, a key, so that the coded map and coded

10 tables could be used. That is the general way in which this encryption

11 functions.

12 Q. And how would the use of KZ documents affect what would be talked

13 about over open transmissions -- over open -- or "unsecured," I guess, is

14 the better word, transmissions.

15 A. If an encoder is attached to the basic equipment, whoever were to

16 hear it would hear some tones, some sounds that would be totally

17 unintelligible. This person could not understand any of it.

18 Q. If I could clarify. I think what I said -- the acronym I used

19 has been misrelayed to you. Let me use the old acronym: How would the

20 use of TKT documents affect what was talked about in open transmissions?

21 A. General documents for encoding are used for transferring certain

22 orders, tasks, so that it would not be open, unsecured. Otherwise, if

23 the enemy was listening in, then they would see clearly what our

24 intentions were. However, with the TKT it can be heard, but again it's

25 some kind of numbers and some words that would not actually provide any

Page 37770

1 kind of information to whoever may be listening in. This person would

2 not know what this is all about.

3 Of course, whoever is an experienced interceptor will realise

4 that these are coded documents. However, quite a bit of time would be

5 needed to decode that communication, and time is important so perhaps it

6 would be too long.

7 MR. IVETIC: If we can tender this document now.

8 JUDGE ORIE: One second, please.

9 MR. IVETIC: Yes.

10 JUDGE ORIE: Could we go back in the English one page.

11 I see what looks like a footnote or not with some 15, 16 items,

12 the first one RRV; the second, IKM -- oh, I now see. That relates to the

13 entries throughout this document and it's not corresponding with the --

14 what follows under 51721, and that is found on the second page.

15 I now understand what it is, but it took me a while. I'm always

16 a bit slow.

17 Mr. Registrar.

18 THE REGISTRAR: It shall be assigned Exhibit 1191. Thank you.

19 JUDGE ORIE: Admitted into evidence.

20 MR. IVETIC:

21 Q. Sir, if we could now go back to your expert report, D1187, marked

22 for identification, under seal. And if we could look at page 26 in the

23 English and page 37 in the Serbian.

24 In 8.4 - that is, 8.4.1 and 8.4.2 - you talk about courier

25 communications, and you say that the courier did not have the key. Was

Page 37771

1 this method of delivery used for anything other than just confidential

2 documents?

3 JUDGE MOLOTO: Isn't that leading?

4 MR. IVETIC: I think it's based upon what's in --

5 JUDGE MOLOTO: No, the question. Is the question not a leading

6 question? Shouldn't the question be: What was it used for?

7 MR. IVETIC: Except that that's in 8.4.2, Your Honours. Couriers

8 carrying documents, i.e., mail, had combat support required that the bag

9 carried the courier would be locked. The courier carrying the mail did

10 not have the key."

11 So my question is: Apart from the confidential documents and

12 mail, was this system used for anything else. This method, I should say.

13 JUDGE MOLOTO: Thank you.

14 THE WITNESS: [Interpretation] No, it wasn't used for other

15 purposes. Only for confidential mail; that is to say, orders, reports,

16 and so on. Then the operations organ of the superior command would most

17 often pack this in a bag, lock it, and give it to a courier. The courier

18 would take a vehicle and armed escort they would reach the operations

19 organ of the unit that it was sent to.

20 The operations organ does have the key of that bag. Then it's

21 unlocked, and then the procedure is carried out properly. All the

22 signatures are there, et cetera, and then it is returned. And then that

23 is how these documents for encoding were transported, in this locked bag.

24 For some ordinary mail, something that is not confidential or

25 personal mail during the war, that was not used. It was just done

Page 37772

1 regularly as one does nowadays in peacetime.

2 MR. IVETIC:

3 Q. You have said that this is how documents for encoding were

4 transported. Could you please specify which documents for encoding you

5 are referring to?

6 A. What is meant there are tapes with keys and the code used to

7 encrypt the speech when you are making an encrypted telegram at the

8 cryptographic data protection centre. These are just perforated ribbon.

9 And there are also tables for encryption that are packed in non-see

10 through - so opaque and waterproof - packaging.

11 Q. And now at 9.3 on the same page in English but on the next page

12 in the Serbian, among the protection measures used, you say was the use

13 of stick antennas was forbidden for devices having directional antennas.

14 Could you explain for us the difference between these two type of

15 antennas, a stick antenna and a directional antenna?

16 A. Certain devices, such as RRU-1, have stick antennas. And if we

17 look and think that it looks like this pencil, it broadcasts on all sides

18 radially. And the other antenna is placed horizontally, and it

19 broadcasts in certain directions, and so the broadcasting to the side is

20 reduced to a minimum and it will broadcast toward the front. The

21 construction can vary, it's not exactly like a pencil, but that would be

22 the direction in which they are broadcasting. So that would be the

23 difference between a stick and a directional antenna. There are, of

24 course, other types with different types of emission.

25 Q. Between a stick and a directional antenna, which is more suited

Page 37773

1 to transmit over greater distances and why?

2 A. Directional antennas are better for longer distances. They have

3 a greater range, if I can put it that way, because the power is directed

4 in one direction, and that's why the signal is stronger than if you were

5 to measure it around the stick antenna. That's why they're better.

6 However, stick antennas have a slightly different purpose and

7 reasons why, in some situations, they are better.

8 Q. Could you please tell us which type of antenna would be used for

9 a radio relay device such as an RRU-800 or FM200 as opposed to radio

10 communications.

11 A. RRU-800 uses helio antennas --

12 THE INTERPRETER: The interpreter is not sure if that is the

13 word.

14 THE WITNESS: [Interpretation] -- and they are placed on a pole

15 that is 7 metres high. There is an emission and -- a transmission and a

16 receiver antenna. It's a little bit different, but it's also a type of a

17 directional antenna. And it's radial. There are a number of elements

18 that make up that antenna, but it's also directional and it's placed on a

19 pole. And then it depends on the purpose, what the height of the pole

20 would be.

21 JUDGE ORIE: Mr. Ivetic, isn't it true that we spent already

22 hours on radio relay, how it was directed, what problems it caused for

23 intercepting it, et cetera, et cetera?

24 Now, for me it's new that it's on a pole, but if that's what you

25 wanted to establish ...

Page 37774

1 MR. IVETIC: No, Your Honours. I was trying with our very first

2 expert on this matter to talk about the difference between stick and

3 directional antennas. Which --

4 JUDGE ORIE: Well, we've heard that, and then you've continued to

5 ask what type of antenna was used for radio relay device, and we've heard

6 that from all those in the field several times.

7 Please proceed.

8 MR. IVETIC: Okay.

9 Q. If we can then turn to page 28 of your report in English and

10 page 39 in Serbian. And here in your report we have diagram number 10,

11 which is described on the next page in Serbian, but I'd like to look at

12 1D5803 with you, which should be the same diagram just, of course, with

13 translation and perhaps a little bit clearer than we see here.

14 A. This is the diagram of secure communications of the command of

15 the 2nd Krajina Corps with the Main Staff, radio relay devices FM200,

16 with a device --

17 THE INTERPRETER: Could the witness please be asked to repeat the

18 acronyms of the devices.

19 MR. IVETIC:

20 Q. You're being asked to repeat the acronyms of the devices, but I

21 suggest we also break it down so it's easier to know what you are talking

22 about for those that are working off the English which does not, at this

23 moment, have the part that's to the left of the chart.

24 Sir, if I can ask you: First of all, we see on the left there is

25 a triangle with the number 200 noted in it. What does this particular

Page 37775

1 part of the diagram depict?

2 A. Let's start from the left and then move to the right. In the

3 instructions of communications documents, there is a rule as to how

4 equipment should be drawn. So the triangle with the straight line and

5 then another line under a 45-degree angle and a little line indicates

6 device, radio relay device 200. So it's not a 9. It's 2-0-0. Perhaps

7 somewhere there is the number 9. It's the same device, RRU-9, which is

8 manufactured in Yugoslavia. It's the same as the FM200. That is

9 connected to the encryption device, KZU-71.

10 Then that is connected to the carrying frequency device AMD-310,

11 and then those devices have eight channels. And we have here which

12 channel goes to whom; for example, number 1, commander of the 2nd Krajina

13 Corps; then commander of the Main Staff of the Army of Republika Srpska;

14 and then you have the operations centre, communications; then you have

15 communications with the neighbouring units - the Krajina Corps, the

16 15th Corps of the Army of the Republic of the Serbian Krajina; then there

17 is the protected telephone from the automatic telephone exchange in

18 Banja Luka - this is the stationary centre in Banja Luka, which means

19 that's the military exchange. One channel was defective and one was

20 free.

21 JUDGE ORIE: Mr. Ivetic, could we seek -- you said that the same

22 as the FM200 was connected to the encryption device KZU-71. Do we see

23 that anywhere in here, or is it just that you explained to us that that's

24 how it was done? Could you tell us whether it's found somewhere in this

25 diagram or whether it's just that you are explaining that this is,

Page 37776

1 although it doesn't appear here?

2 THE WITNESS: [Interpretation] Your Honour, the encryption device

3 is not in the diagram, but it was used in the actual operation. You can

4 also see it from the heading, that it's a secure communication.

5 JUDGE ORIE: You've answered my question.

6 Now, I think that in the English version that the text written

7 vertically is AMD-340. You said, however, it's AMD-310. Could I just be

8 sure that it is AMD-310 or is it AMD-340?

9 THE WITNESS: [Interpretation] When you zoom in, you can see that

10 it's a 1 and that the correct acronym would be AMD-310.

11 JUDGE ORIE: Yes. This may be a misinterpretation in the

12 transcription of the original into the English version. I think it's not

13 of such essence that we would need to find a new one, but it's at least

14 on the record now that it should be read "AMD-310."

15 Please proceed.

16 MR. IVETIC:

17 Q. Now, sir, could these secure channels transmitting over the FM200

18 via the AMD-310, could they be both listened to and understood as

19 recognisable speech by someone who was not an intended participant in the

20 transmission?

21 A. You could listen into the channels if you were along that route

22 and if you had a device of the same characteristics on the same

23 frequency, same modulation, and so on and so forth. But if the line was

24 secure, they would not understand anything that they heard.

25 I already said this before, they could just hear some crackling

Page 37777

1 or some tones, but there would be nothing intelligible. They could

2 record it and then try to de-scramble it by using different devices.

3 Perhaps somebody would have devices which could decode the signal. But

4 the B and H Army did not have such devices.

5 Q. Now, how --

6 JUDGE ORIE: What's the source of your knowledge, that they

7 didn't have them?

8 THE WITNESS: [Interpretation] I can confirm that by using a

9 document which I received after I wrote my document here, and it's a

10 report by one of the commanders of either the north or south location, to

11 his superior, where they say, for example: You are asking for our

12 position, please don't ask that anymore because we don't have anything in

13 order to be able to find out which location it is and the Chetniks don't

14 want to tell us, either. So it's much simpler to have locators than to

15 have decoding devices. That's my conclusion.

16 Had they been able to decode the interception, then they would

17 have been able to work out the positions as well.

18 JUDGE ORIE: But if you know the location, you have not yet

19 decoded it in any way. But let me just try to understand your last

20 answer.

21 It's translated as:

22 "Had they been able to decode the interception," that is, to

23 decode the intercepted signals. And you say:

24 "... then they would have been able to work out the positions as

25 well."

Page 37778

1 Could you explain how they could have done that?

2 THE WITNESS: [Interpretation] In orders, or in conversations

3 conducted through secure links, frequently they would mention -- it was

4 open communication when it was written, but in speech it was secure. But

5 then frequently you would mention command posts, commanding officers,

6 locations of stations, and so then they wouldn't have had to look for

7 positions in 1995 of the Army of Republika Srpska. This is what I was

8 referring to from the time of 1995.

9 JUDGE ORIE: If I understand you well, you're saying if the

10 content of the conversations would give a clue to locations, then it

11 would have been easier to find out in that way rather than by other means

12 to establish the location of the various units. Is that -- or command

13 posts or whatever?

14 THE WITNESS: [Interpretation] Yes, yes. Yes, that's right.

15 JUDGE ORIE: One other question in relation to this, that is:

16 The diagram is about secure communications, secure channels. You earlier

17 told us that the encryption device is not here. Was there any way to use

18 those channels without using the encryption device so as to bypass it or

19 to switch it off or whatever? So could you use these channels if you

20 wished to without secure the signals through the encryption devices?

21 THE WITNESS: [Interpretation] A radio relay communication, the

22 FM200, can work normally with the carrying frequency device without the

23 encryption device, and then the communication is not coded. The diagram

24 shown here was my working document, and simply during that time you often

25 didn't have enough time to do more, and so then I omitted to indicate

Page 37779

1 that the data encryption device was used here.

2 JUDGE ORIE: Yes, but also could not be used, if I understand you

3 well?

4 THE WITNESS: [Interpretation] In all the diagrams and

5 communications, you can see that there were many devices that did not

6 have a data encryption device. But then, you would use different types

7 of protection.

8 For example, in RRU-800 you cannot protect the whole group. Only

9 specific channels. Then the other channels would transmit speech, as

10 such. But then the communication would be protected by general

11 encryption data protection documents.

12 JUDGE ORIE: Yes, I see that. But if you would be negligent,

13 could you send signals and forget or negligently do not encrypt or

14 otherwise protect the communication?

15 THE WITNESS: [Interpretation] Your Honour, in these documents,

16 there is a diagram of protected radio relay communications of the Army of

17 Republika Srpska where the Main Staff of the VRS has secure connections,

18 one group of such connections with each of the corps. So there could be

19 no talk of negligence. You have the original diagram with all the

20 devices included. This would be given to the commander of the unit who

21 actually executed those communications, so he could not do anything that

22 was not negligent. And if I was having any question about it, I would

23 ask if the data encryption device was being used.

24 JUDGE ORIE: Yes. If you say there could be no talk of

25 negligence, is that because technically it was impossible, or whether it

Page 37780

1 was clearly against instructions?

2 THE WITNESS: [Interpretation] First of all, Your Honour, it's

3 technically impossible. If I am negligent on one end, the person at the

4 other end is not. So then if the commander of the Main Staff would call

5 the commander of the 2nd Corps and the encryption device is not switched

6 on at his end, he will not hear him at all.

7 In order for them to hear each other, the equipment has to be

8 identical at both ends.

9 JUDGE ORIE: And it's impossible to at both ends just ignore or

10 switch off, or whatever you would call it, the encryption devices; both

11 in sending and receiving?

12 THE WITNESS: [Interpretation] Your Honour, that would constitute

13 sabotage at the very least. If an order was issued that you must

14 establish a connection with encryption data protection, then that would

15 be sabotage.

16 JUDGE ORIE: Technically possible but sabotage?

17 THE WITNESS: [Interpretation] Yes, that would not be negligence.

18 JUDGE ORIE: Yes, thank you.

19 Mr. Ivetic, please proceed.

20 MR. IVETIC:

21 Q. To add on to what you just discussed, could you explain for us --

22 now, you told us the diagram where the KZ-71 encryption device would be

23 located, so let's talk in terms of actuality.

24 The radio relay nodes that are usually up on mountains and then

25 the command centres are usually somewhere on lower ground. Where in that

Page 37781

1 schematic or system would the KZU-71 be attached?

2 A. The KZU-71 device would be attached at the end of the radio relay

3 station. As I said, you would have the IMD frequency carrier, then you

4 would have the telephone line to the end user, the commander, the

5 operations centre and so on and so forth. And then this RRU-800 would go

6 to the radio relay node. And then through greater multiplexes, such as

7 V4 or the SMC radio relay devices, it would go to the end node and it

8 would split off from there to be received by another RRU-800, and then

9 you would have the same sequence of devices connected.

10 Q. Now, I guess --

11 MR. IVETIC: I don't think we've tendered this yet. I can either

12 tender it or mark it for identification if we need to revisit the

13 translation of AMD-340. I leave that in Your Honours' hands.

14 JUDGE ORIE: I think that we established that -- it's having been

15 put on the record that AMD-340 should be read in the English version as

16 "AMD-310" and that for the time being would be sufficient.

17 Therefore, you tender it? Mr. Registrar.

18 THE REGISTRAR: It shall be assigned Exhibit D1192. Thank you.

19 JUDGE ORIE: Admitted into evidence.

20 Mr. Ivetic, the Chamber made its calculations. We'll continue

21 now until 12.30, then we'll take a break of half an hour. And from 1.00

22 we'll continue until quarter past 2.00.

23 Please proceed.

24 MR. IVETIC: Thank you, Your Honour.

25 Q. If we could return to your report, again D1187, marked for

Page 37782

1 identification, under seal, and if we can look at page 28 in the English,

2 page 41 in the Serbian.

3 Or, actually, before we do that, if we could look at

4 65 ter number 19848. You mentioned in the prior exchange in answering

5 Judge Orie's questions, a diagram of the secured channels of the GS -- of

6 the Main Staff, and at page 40 of the Serbian, you have -- diagram

7 number 11 of your report, which is identified as document 04336629. Is

8 this that diagram you were referring to?

9 MR. IVETIC: Perhaps if we could zoom out a little bit on the

10 Serbian or -- I don't know how else to -- maybe can it be flipped. There

11 we go.

12 THE WITNESS: [Interpretation] I saw it. That is the diagram of

13 secure communications between the Main Staff and the corps commands. And

14 then there is the 2nd Krajina Corps in the corner, and this arrived along

15 this radio relay route from the radio relay node Klekovaca through FM200.

16 0272 is the radio relay route, I think. But it doesn't matter. You can

17 see it. From Klekovaca to Ostrelj where the command post of the 2nd

18 Krajina Corps was.

19 MR. IVETIC: Your Honours, then I would tender this document at

20 this time.

21 JUDGE ORIE: Mr. Registrar.

22 THE REGISTRAR: It shall be assigned Exhibit D1193. Thank you.

23 JUDGE ORIE: Admitted into evidence.

24 Mr. Ivetic, we were on page 28 of the English. Could we have

25 that? That's the report of the witness.

Page 37783

1 MR. IVETIC: Yes.

2 JUDGE ORIE: Footnote 37 refers to analysis of combat readiness,

3 page 37. Do you have any idea where we could find that?

4 MR. IVETIC: Yes, Your Honours. One moment. That's a document

5 that we already have in evidence, and I will give you the number in just

6 a moment.

7 JUDGE ORIE: If you find it later, that's okay as well.

8 MR. IVETIC: I think I might have it on my old sheet. It's

9 the -- what it is, it's the analysis of the VRS dating from 1994 as to

10 the work -- 1993 dating to the work from 1992, which we've used with

11 other witnesses.

12 JUDGE ORIE: Yes. I -- if -- most important for us is that we

13 can find the reference and see to what it's related, so if you later

14 could give the --

15 MR. IVETIC: I can give you -- we have, I believe, two copies of

16 it in e-court. One copy is 1D05793. And I believe that that is already

17 in evidence as, I think, a P number, but I don't have that at present. I

18 can get back to you with that perhaps after the coming break.

19 JUDGE ORIE: Yes, yes, I'm not insisting on receiving it

20 immediately. Although Mr. McCloskey might help out.

21 MR. McCLOSKEY: Yes, Mr. President. Mr. Ivetic is correct. That

22 came in as P00338 and has been discussed by many, many witnesses.

23 JUDGE ORIE: Yes, yes, but we have seen quite a lot of documents

24 about combat readiness. And without a year and without further

25 explanations, it would be quite an effort to know exactly what this

Page 37784

1 refers to. But now we do.

2 So please proceed.

3 MR. IVETIC: And I'd like to look at 10.1, which we now have on

4 the screen in both languages.

5 Q. Here in your report, you say when the war started there were no

6 EiPED units on the territory of BH. Can you explain what you mean here?

7 A. It means electronic surveillance and anti-electronic activity.

8 In the territory of Yugoslavia, there were several units for electronic

9 surveillance and anti-electronic activity. I am going to mention only

10 some of these locations; for example, near airport Pleso in Zagreb, there

11 is one battalion for that; then in Divulje near Split another --

12 JUDGE ORIE: Mr. Ivetic, you didn't ask for the locations of such

13 units. Are you interested to know? And what is the use for the Chamber

14 to know exactly where they were located?

15 MR. IVETIC: Okay.

16 JUDGE ORIE: And could I also verify that the translation

17 "reconnaissance surveillance" is not exactly the same, perhaps? I do not

18 know whether that causes any inconvenience and whether you could agree

19 with Mr. McCloskey on what the meaning is.

20 MR. IVETIC: I think we can agree on that.

21 JUDGE ORIE: Yes.

22 MR. IVETIC: He's nodding so ...

23 JUDGE ORIE: Yes. Then please proceed, and if you need the

24 locations, ask for them. Otherwise, proceed otherwise.

25 MR. IVETIC:

Page 37785

1 Q. Now, under the JNA system, what specific course work or training

2 was required for someone to be qualified as an operator within an EiPED

3 unit?

4 A. Training personnel for carrying tasks out in that area was

5 carried out in the School for Electronic Surveillance and Anti-Electronic

6 Activity in Belgrade within the School Centre for Communications, and

7 that is where both NCOs and commissioned officers were trained; that is

8 to say, everyone at their own level.

9 In addition to that, the JNA sometimes had soldiers through

10 contracts for radio reconnaissance. I don't know about other duties, but

11 I know that for that particular field there would be contractors of that

12 kind.

13 Q. How long would the training or schooling for EiPED, and

14 especially radio reconnaissance, last?

15 A. The training went on for a year for officers after they complete

16 the general military academy in Belgrade. Then an additional year at the

17 school centre. Afterwards, some of that was changed when all these

18 changes took place, and then they were trained together with technical

19 personnel in the military institute in Zarkovo, near Belgrade. NCOs were

20 also trained. After basic training in Sarajevo, they would come to

21 Belgrade for specialised training in Belgrade, for a year.

22 Q. Okay. Now in the course of your review and analysis for this

23 case and this report for the Mladic case, did you have occasion to review

24 any information about the training and qualifications of the ABiH

25 operators who were said to be engaged in radio surveillance work?

Page 37786

1 A. A specific document? Well, on the basis of everything, I managed

2 to conclude that these units received personnel from the former JNA, but

3 very few such people, then from the Ministry of the Interior, and ham

4 radio operators. These were three categories of people, as far as I

5 could conclude, in units for EiPED in the units of the BH Army.

6 MR. McCLOSKEY: Objection. That's not responsive.

7 MR. IVETIC: Can the Prosecution object to an answer?

8 MR. McCLOSKEY: Review any information? What information is he

9 basing this on?

10 JUDGE ORIE: Well, he is telling us that there were no specific

11 documents.

12 But, Mr. Ivetic, if you -- one second, please.

13 Well, he gave his sources. That's everything. Based on

14 everything, the witness managed to conclude.

15 If that is the information the witness had, then the probative

16 value of that answer is limited, Mr. Ivetic. So if you want better

17 evidence, please further explore.

18 Mr. McCloskey, this, to some extent, I would say, meets your

19 concerns?

20 MR. McCLOSKEY: Absolutely, thank you.

21 JUDGE ORIE: Please proceed.

22 MR. IVETIC:

23 Q. Sir, being careful not to mention any names, did you have

24 occasion to review any witness statements of the ABiH operators?

25 A. Well, while reading a statement of an, I mean, official --

Page 37799

1 The witness will be escorted into the courtroom.

2 Further scheduling, Mr. Lukic. I think we will discuss it. As

3 always, you are always encouraged to see whether you can, nevertheless,

4 find solutions, but I do understand that there are serious problems.

5 [The witness takes the stand]

6 JUDGE ORIE: Mr. Ivetic, you may proceed.

7 MR. IVETIC:

8 Q. If we can turn to page 30 in the English and page 43 in the

9 Serbian, I'd like to focus just briefly on footnote 39 of your report.

10 A. Your Honours, I found in some documents that the JNA and then the

11 VRS communications were not secure because the company that produced the

12 radio relay device AMD did not manufacture them properly, that

13 communications via those devices were not secure, and some of these

14 devices that were sold to the Gulf countries -- all the conversations on

15 those devices were picked up, intercepted, and decoded by the USA very

16 easily.

17 So I can say that when the JNA decided to buy those devices, they

18 considered all the options and decided to buy them but to change the --

19 some parts and some switches in the devices, so it was not possible to

20 broadcast beyond what was set by the code and the key that much. I mean,

21 there are many pages on the internet about this.

22 Q. Now if we can turn to page 36 in English --

23 JUDGE ORIE: Before we continue, whatever may have been about the

24 internet, about selling, producing, et cetera, you said when the JNA

25 bought these devices, it developed its own cryptographic data protection

Page 37800

1 system device. Is that your personal knowledge? That's not what you

2 learned from the internet, or was it?

3 THE WITNESS: [Interpretation] This is something that I learned

4 from my colleague, a colonel who worked at the institute for applied

5 mathematics, and that institute was the one that developed the code. So

6 I didn't find out about it from the internet, no.

7 JUDGE ORIE: You heard that. When did it happen? When was the

8 own cryptographic data protection system developed?

9 THE WITNESS: [Interpretation] Your Honours, I didn't ask that of

10 my colleague, but I understood from the conversation that it was done at

11 the time that device became part of the JNA arsenal.

12 JUDGE ORIE: Yes. And when was that?

13 THE WITNESS: [Interpretation] I think it was sometime in 1975, as

14 far as I can recall.

15 JUDGE ORIE: Yes. And it was still that same equipment that was

16 used later with these adaptations?

17 THE WITNESS: [Interpretation] Your Honour, the change was made

18 within the AMD device and the KZU-71. Changes were made in the device

19 and certain switches were changed.

20 JUDGE ORIE: Was that a hardware change or was the data

21 protection applied through software?

22 THE WITNESS: [Interpretation] It was made inside the AMD device,

23 a part, a sector of the section of the device that is important for

24 encryption was modified or changed.

25 JUDGE ORIE: But whether that was hardware or a software change,

Page 37801

1 would you know that? If you don't know, tell us.

2 THE WITNESS: [Interpretation] It was a hardware change.

3 JUDGE ORIE: And that included also its own software?

4 THE WITNESS: [Interpretation] It was the JNA software. The JNA

5 had its own programmes for creating the key, then it had its own system

6 for mixing the encoded parts of the tape and open parts of the -- the

7 tape. It was TG-43. That was the -- and other parts.

8 JUDGE ORIE: Thank you.

9 Please proceed, Mr. Ivetic.

10 JUDGE FLUEGGE: May I put one question to the witness.

11 What is the name of your colleague, the colonel you referred to

12 from whom you received this information? What was his name?

13 THE WITNESS: [Interpretation] His name is Zivko, Dzenopoljac.

14 JUDGE FLUEGGE: Could you perhaps repeat the family name.

15 THE WITNESS: [Interpretation] Dzenopoljac.

16 JUDGE FLUEGGE: Thank you.

17 JUDGE ORIE: Please proceed, Mr. Ivetic.

18 MR. IVETIC:

19 Q. If we can turn to page 36 in the English and page 54 in the

20 Serbian of your report, I'd like to look at paragraph 11.11.

21 In the fourth subparagraph of this introductory paragraph, it

22 says that parabolic antenna are unsuitable for interception of

23 frequencies under 1 gigahertz. Can you explain for us why that is.

24 A. You can see one of the parabolic antennas here. When you

25 consider this, I believe for a number of reasons that it was not used for

Page 37802

1 interception. And if you like, I can explain that later.

2 Below 1 gigahertz, the reason is that these would be large

3 antennas and then would need to be in balloons or some short of shelter.

4 The antenna is then named after the shelter, "kaponir," and they are very

5 visible. Regardless of the weather conditions and in order to

6 reconnoiter properly, an antenna would need to be moved around.

7 Q. You have analysed here in your report photo number 1.

8 MR. IVETIC: I would like to call up P1649, which should be the

9 source photograph.

10 Q. So ask you to identify items there -- in there so we can

11 understand your report.

12 JUDGE ORIE: Yes, while we're waiting for that, Witness, could

13 you tell us what would be the diameter needed for a parabolic antenna

14 intercepting any signal under 1 gigahertz? What size, therefore?

15 THE WITNESS: [Interpretation] Technical calculations are made for

16 that. But in my estimate, I believe that the dish would need to be

17 approximately 2 metres in diameter. Even 2 and a half metres.

18 JUDGE ORIE: Thank you.

19 MR. IVETIC:

20 Q. Now, this is a photograph that is the source of your photo

21 number 1, and you have identified certain antenna types by name. I'd

22 like you to first, with the help of the usher, mark with a numeric

23 number 1 and number 2 both of the Yagi antenna that you discuss in this

24 photograph of your report.

25 A. The Yagi antennas are the ones on the left pole. Number 1

Page 37803

1 indicates the first one, and number 2 indicates the second one. These

2 are the Yagi antennas installed on the same antenna pole. One is

3 installed horizontally, and the other vertically. The polarisation is

4 changed with proximal antennas because then you could hear two signals

5 that are close together, and you can do this also to augment a single

6 signal. And their frequency goes up to 1.300 megahertz, which means that

7 these antennae can be used for the interception of radio relay devices,

8 RRU-1 and these others ones that are covered by the FMU and the RR-800

9 devices.

10 This third antenna on the right close to the dish --

11 Q. Before you talk about the next one, could you mark the one you

12 are talking about with the number 3 and tell us what name of antenna it

13 is so we can tie it to what you have written in your report?

14 A. This is number 3. This is a logo-periodical antenna, or a

15 "log-antenna" for short. It has a range from 40 to 800 megahertz, which

16 means that it can monitor communications over the RRU-1 device. To the

17 left of that antenna is the dish, parabolic antenna.

18 Q. Let the record reflect that has been marked as number 4.

19 You've already told us about the parabolic antenna. You also

20 mention an umbrella antenna. Could you mark the umbrella antenna with a

21 number 5.

22 A. There it is, number 5 in the corner. You can't see all of it.

23 All you can see are the lateral spikes.

24 It's known as an umbrella antenna in jargon, because it reminds

25 you of an umbrella. It's an antenna from the set of devices that I

Page 37804

1 mentioned, the ICR-100 for example. For the reception of frequencies of

2 180 megahertz. It has circular radiation and reception, so it's not

3 necessary to point it or direct it towards the source, because it

4 receives all around and transmits also in a complete circle.

5 MR. IVETIC: Just waiting for the translation.

6 Can we now tender the photo as marked, Your Honours.

7 JUDGE ORIE: Mr. Registrar.

8 THE REGISTRAR: It shall be assigned Exhibit D1194. Thank you.

9 JUDGE ORIE: Admitted into evidence, all five antennas.

10 MR. IVETIC:

11 Q. Now, in your report at page 32 in English and in Serbian it's

12 page 46, you have also document number 3, which should not be broadcast.

13 I'd like to call up the source of that, which is 1D05807 which, likewise,

14 should not be broadcast.

15 And without identifying the names of the southern and northern

16 locations, can you tell us what is depicted herein?

17 A. This topographical map refers to both of the locations, the

18 northern and the southern location. And this is definitely a map that

19 was part of the documents that were received by the commander of the

20 southern facility. And you can see that certain zones were set there;

21 zone number 1, number 2, going from the left to the right - 1, 2, 3,

22 and 4.

23 And then earlier reconnaissance established some earlier

24 locations of some listening stations, and they are mentioned here. Since

25 I said that the B and H Army did not have any locators or radio search

Page 37805

1 devices, they probably directed their antennas, and whenever they

2 received the best signal on their receivers, they would understand from

3 that that the listening-in device was in that route. They probably --

4 the officers knew what their forward forces were and those of the enemy,

5 the forces of Republika Srpska. And knowing the manner in which these

6 devices worked, they would estimate the elevation at which the device

7 would need to be directed.

8 So this was -- you could see that it wasn't done very precisely.

9 On the example of the Veliki Zep node, 1 centimetre on the map is

10 1 kilometre actually in the field. So when you look at it here, you

11 could see that the stations are at least 2 kilometres away from each

12 other, but that's not true because all of them were actually clustered at

13 Veliki Zep.

14 Also indicating that they didn't have the most precise data is

15 the fact that they worked amongst themselves, that two of them worked

16 together. And that's not very logical. If one radio relay is working,

17 it would be facing a specific unit or a feature. They should not just be

18 oscillating in the area between them. So they would need to be linked to

19 some facility that would be intercepting all the communications from all

20 the brigades. They did know that these were brigades, however, because

21 they had some intercepted material, most probably. And, secondly, TO

22 brigades were formed in the territory of the former B and H -- yes, yes.

23 I apologise. And the TO had its own brigades, which were called

24 according to the settlements or places where they were formed, so on the

25 basis of that, they could determine that that would be such-and-such a

Page 37806

1 brigade using such-and-such a device.

2 Q. [Previous translation continues]...

3 A. I would leave it at that.

4 Q. If I can ask you --

5 MR. McCLOSKEY: Can I object for a second.

6 MR. IVETIC: I don't think you can object to an answer.

7 JUDGE ORIE: I don't know what the objection is about. Is it

8 about a question, is it about a --

9 MR. McCLOSKEY: Can we have some foundation on whose map this is?

10 We're going into a lot of detail about it with no foundation.

11 JUDGE ORIE: Mr. Ivetic, as a matter of fact, I would have left

12 you with all the questions about this map. But if they would not have

13 included who produced it, then I would have asked for it.

14 MR. IVETIC: Okay. If we can call up 1D5798, but that should not

15 be broadcast.

16 MR. McCLOSKEY: Could we have an answer to the question?

17 JUDGE ORIE: When we move this map away, unless you want to have

18 it back later and then put --

19 MR. IVETIC: Yeah.

20 JUDGE ORIE: -- the question to the witness, that's fine.

21 MR. IVETIC: I want to go with a document that depicts what's on

22 the map that shows who would have created it. That's what I want to do.

23 JUDGE ORIE: Okay.

24 MR. IVETIC: Which I think was --

25 JUDGE ORIE: We will learn that from that document.

Page 37807

1 MR. IVETIC: I believe so, yes.

2 JUDGE ORIE: Yes. Let's wait and see.

3 MR. IVETIC:

4 Q. And, sir, in the map we had zones 1, 2, 3, and 4 --

5 MR. IVETIC: If we can -- I apologise. This is a document dated

6 the 21st of August, 1995 from the Army of the Republic of

7 Bosnia-Herzegovina.

8 Q. And we have zones 1, 2, 3, and 4 depicted in the centre. Could

9 you please, for our purposes, sir, read the B/C/S there and tell us how

10 it corresponds to the zones that we had on the map. And perhaps it might

11 assist if we have on one half of the screen the map and on one half of

12 the screen the document. That might help us follow.

13 MR. McCLOSKEY: Same objection.

14 JUDGE ORIE: Then perhaps we first ask the witness or you give

15 further information as where the document comes from, Mr. Ivetic.

16 MR. IVETIC: This document comes from EDS given to us by the

17 Office of the Prosecutor, Mr. McCloskey, sitting across this room.

18 MR. McCLOSKEY: I was hoping he would ask the witness.

19 JUDGE ORIE: Well, there are a few matters.

20 Witness, this document that you see on the screen at this moment,

21 that's the written document to the left, are you familiar with that

22 document?

23 THE WITNESS: [Interpretation] Sir, Your Honour, are you

24 addressing me?

25 JUDGE ORIE: Yes.

Page 37808

1 THE WITNESS: [Interpretation] I am familiar with this document.

2 I received it -- actually, first I received the map. And then after that

3 was printed, or after my material was printed, then I received this too.

4 On the basis of the map itself, one could conclude that --

5 JUDGE ORIE: One second. We are not there yet.

6 When did you -- and I'm exclusively talking about the written

7 text, not the map. When did you see that for the first time?

8 THE WITNESS: [Interpretation] I first saw it in May, June.

9 That's when I received it. This year.

10 JUDGE ORIE: Of this year. From whom did you receive it?

11 THE WITNESS: [Interpretation] Yes. The lawyers.

12 JUDGE ORIE: And do I understand that you said that you received

13 after that the map? Oh, no. You first received the map as far as I'm --

14 I'm apologising because I think I misrepresented what you said.

15 So you first received the map also from the Defence team?

16 THE WITNESS: [Interpretation] Yes, yes.

17 JUDGE ORIE: And then later you received that document.

18 Now --

19 THE WITNESS: [Interpretation] Yes.

20 JUDGE ORIE: -- do you have any personal knowledge about the

21 document so as to where it came from, when it was drafted? Do you know

22 anything about that? Or, if not, please tell us as well.

23 THE WITNESS: [Interpretation] No, no. I have no idea whatsoever.

24 I know what is written here. Nothing else.

25 JUDGE ORIE: Yes, that's clear.

Page 37809

1 Mr. Ivetic, please proceed.

2 MR. IVETIC: Thank you.

3 Q. I believe I had already asked a question to have you read what

4 zones 1, 2, 3, and 4 are depicted on the document and to comment upon the

5 map, how those correlate to what is depicted on the map.

6 JUDGE FLUEGGE: Is there an English translation?

7 MR. IVETIC: There is not. That's why I want the witness to read

8 it so that we get the English, otherwise I would -- otherwise it would be

9 self-evident.

10 THE WITNESS: [Interpretation] Republic of Bosnia and Herzegovina

11 in the heading.

12 MR. IVETIC:

13 Q. It meant it -- to read the part that says "zones 1, 2, 3, and 4."

14 We don't need to read the heading which might mention --

15 A. I understand. I understand. Zone 1 that was received by the

16 commander of this facility. To the left is Vozuca; in depth, Banja Luka;

17 to the right, Doboj; azimuth, 293 to 320.

18 THE INTERPRETER: Interpreter's note: Could the witness please

19 read slower.

20 JUDGE ORIE: Witness, could you read slower because the

21 interpreters are unable to follow you.

22 So could you --

23 THE WITNESS: [Interpretation] I understand.

24 JUDGE ORIE: -- slowly repeat what you read.

25 THE WITNESS: [Interpretation] Zone 1: To the left, Vozuca; in

Page 37810

1 depth, Banja Luka; to the right, Doboj; azimuth, from 295 to 320.

2 Zone 2: To the left, Zvornik; in depth, Sarajevo, the Drina

3 river; to the right, Nisici; azimuth, from 80 to 190.

4 Zone 3: To the left, Brcko; in depth, the Sava and the Drina; to

5 the right, Zvornik; azimuth from 20 to 80 degrees.

6 Zone 4: To the left, Doboj; in depth, the Sava; to the right,

7 Brcko; azimuth, from 320 to 20 degrees.

8 MR. IVETIC:

9 Q. And, sir, now could you comment, based upon your viewing this map

10 that is on the right-hand side, how the zones referenced in the document

11 correlate to the zones on the map?

12 A. These zones that are written down in this document and the zones

13 that are marked on this work map, they correspond to one another. And

14 from this, one can see that the task was for this facility to intercept

15 communications of the Drina Corps, the Eastern Bosnian Corps, and the

16 Sarajevo-Romanija Corps of the Army of Republika Srpska.

17 Q. Sir, if I can direct your attention to the second paragraph

18 before it says "zone 1," that starts "dalje sada ima." And if I can ask

19 you to read that paragraph for us.

20 A. Yes. "Further on, there is this rubric, location of participant.

21 Please, who, amongst us, can write that, where the participants are?

22 Unless the Chetniks listen to the order themselves and tell us themselves

23 where they are. We still have the valid distribution of the so-called

24 zones of RE. We can write them and comment upon them."

25 And then the rest follows down here.

Page 37811

1 Q. You earlier mentioned a document from 1995 that led you to

2 believe that the ABiH did not know where our nodes were located. When I

3 say "our," I mean "VRS nodes" are located.

4 Can you tell us if this is that document you're referring to?

5 A. This is the strongest evidence. Although even through previous

6 documents, I saw that they did not really have information on the

7 locations involved in terms of these radio relay locations activated in

8 the Drina Corps. And I did not receive any information as to what they

9 knew about the other corps that they were following.

10 MR. IVETIC: If we could, Your Honours, mark for identification

11 1D5798, pending a full translation of the document.

12 JUDGE ORIE: Have you done with the document?

13 MR. IVETIC: Yes.

14 JUDGE ORIE: Yes. Before we do so.

15 Witness, you read a certain line to us.

16 "Further on, there is this rubric. Location of participant," it

17 says.

18 You are, in your answer, suggesting that the location is the

19 location of any communication centre. Where does that appear clearly, if

20 it does, in this line?

21 THE WITNESS: [Interpretation] Your Honour, it says:

22 "Please, which one of us can say who, where" -- or rather, "...

23 where some of the participants are."

24 And when he says "participants," he means a radio relay station

25 that he is intercepting, listening to.

Page 37812

1 JUDGE ORIE: Yes. So it's on the basis of the word

2 "participants" that you conclude that this is how it has to be

3 understood.

4 THE WITNESS: [Interpretation] Yes.

5 JUDGE ORIE: First of all, the document, that's not the map yet,

6 Mr. Ivetic, just the document, would receive what number, when it's

7 marked for identification, Mr. Registrar.

8 THE REGISTRAR: It shall be assigned Exhibit D1195. Thank you.

9 JUDGE ORIE: Marked for identification.

10 Are you going to return to the map, Mr. Ivetic?

11 MR. IVETIC: I leave it in your hands, Your Honour. A smaller

12 version of the map is already included in the report of the expert at

13 page 46 --

14 MR. McCLOSKEY: I'd object to him -- telling him what's in his

15 own report after he was asked where the document came from and didn't

16 know.

17 JUDGE ORIE: Well --

18 MR. IVETIC: Am I allowed to answer the Judge's question? Your

19 Honour asked me what I want to do with the report that relates to --

20 JUDGE ORIE: Yes, I may have -- I may have misunderstood it in

21 the sense that whether you wanted to ask further questions about the map

22 and that -- in that way, to return to the map itself. I do understand

23 that you leave it in our hands whether you want to have it separately --

24 MR. IVETIC: Fine.

25 JUDGE ORIE: -- exhibited or as it appears in the report.

Page 37813

1 Now, Witness, you said you received this map first. Do you know

2 anything about where it comes from, who drafted it, when it was drafted?

3 THE WITNESS: [Interpretation] Your Honour, there is no date on

4 it, there is no signature, and I can just conclude that this task was

5 probably given by the commander of the unit who was the commander of both

6 of these facilities and that this pertains to this southern point, here.

7 Now, the map was made at sometime, say, in 1993, 1994, when they

8 already had some information about some deployment of the Army of

9 Republika Srpska.

10 JUDGE ORIE: Witness, are you speculating or do you have any

11 knowledge which makes you believe that it may have been made in 1993 or

12 1994?

13 THE WITNESS: [Interpretation] This is my assumption, Your Honour.

14 I have no data.

15 JUDGE ORIE: Yes.

16 Then, Mr. Ivetic, you apparently provided the witness with the

17 map. Is it a map that was disclosed to you by the Prosecution? Is

18 that --

19 MR. IVETIC: Yes.

20 JUDGE ORIE: Yes.

21 Mr. McCloskey, do you have any information as to where the map

22 comes from?

23 MR. McCLOSKEY: Yes, I do.

24 JUDGE ORIE: And if you consider it not a good idea to tell it in

25 the presence of the witness, then we would hear that at another point in

Page 37814

1 time later.

2 But I would have another question for you, Witness. Have you

3 analysed the content of this map, and have you asked yourself what it

4 depicts?

5 THE WITNESS: [Interpretation] Your Honour, I've already said that

6 this is one of the documents, orders that are being sent to the commander

7 of this facility to the south. It's part of an order, and we assume that

8 it's his superior officer that is issuing this. I did not see any other

9 documents in addition to this map, and I am not aware of any.

10 JUDGE ORIE: You say it's part of an order. How do you know that

11 it's part of an order?

12 THE WITNESS: [Interpretation] That would only be natural. When

13 an order is being issued, it would be quite natural, normal, along with

14 an order to reconnoiter that one provides a map for the reconnaissance

15 involved.

16 JUDGE ORIE: So you assume that it's a conclusion rather than any

17 specific knowledge.

18 Have you looked at the accuracy of what is depicted on this map?

19 THE WITNESS: [Interpretation] Well, I've already mentioned that

20 that is partial knowledge about the location and number of radio relay

21 stations used by the VRS. The locations are not fully correct. And also

22 the number, as we can see from those documents, the number of radio relay

23 devices used.

24 There is another symptomatic thing. Not a single radio relay

25 RRU-1 was identified. Or maybe this person did not believe that it was

Page 37815

1 important, that that information should be contained in this map, but I

2 believe that he didn't have the information in the first place.

3 JUDGE ORIE: Yes. Could I take you to zone 4 on the map. The

4 azimuth angle there is described as 80 degrees. Do you see that?

5 THE WITNESS: [Interpretation] Yes, yes. I do see it.

6 JUDGE ORIE: Do you think it's 80 degrees, that angle?

7 THE WITNESS: [Interpretation] Your Honour, I have a protractor.

8 Maybe it's not all of 80, but it's around that figure. 90 would be a

9 full one, and this is somewhat less.

10 JUDGE ORIE: Yes. Do you know why it says 80 degrees or -- and

11 can you read what is in zone 1? Can you decipher what is ...

12 THE WITNESS: [Interpretation] Zone 1 says 25 degrees.

13 JUDGE ORIE: Yes.

14 THE WITNESS: [Interpretation] Just 25. And then over there,

15 there is 80. So that would -- well, 80, that's quite big.

16 JUDGE ORIE: Yes. Any comment, then, on the accuracy of those

17 two figures?

18 THE WITNESS: [Interpretation] My comment would be that it wasn't

19 done very professionally and with the aides that one should use when

20 working on a map. That would be it.

21 JUDGE ORIE: Thank you.

22 Mr. McCloskey, would you give any further information at this

23 point in time, where we're about to decide on admission, yes or no?

24 Witness, you understand the English language, don't you?

25 THE WITNESS: Very, very small.

Page 37816

1 JUDGE ORIE: Yes, yes. You greeted me this morning in English, I

2 think, when you entered the courtroom. And I think it would be safer not

3 to just ask the witness to take off his earphones but to ask him to

4 leave, if it's to be done at this very moment, Mr. McCloskey.

5 MR. McCLOSKEY: Mr. President, this witness has relied on a

6 former expert for a lot of his report, an expert called Rodic, which I'm

7 sure Mr. Ivetic knows about, from, I believe, the Popovic case.

8 This map is part of Rodic's report, which was attached as an

9 annex to this man's report. Whether Rodic made this map or he got it

10 from somewhere else, I'm not -- my Popovic memory is not all it could be.

11 We're looking into that. But this does not have -- I don't have any

12 recollection of the 2nd Corps or the MUP making such a map.

13 But ...

14 JUDGE ORIE: Yes.

15 MR. McCLOSKEY: -- this is --

16 JUDGE ORIE: So we --

17 MR. McCLOSKEY: -- a complicated issue.

18 JUDGE ORIE: The Prosecution has its doubts on the provenance of

19 this document to say where it comes from.

20 MR. McCLOSKEY: Well, it comes from Rodic's report.

21 JUDGE ORIE: Yes, I see that. But whether it was originally

22 drafted for that report or whether it came from another source is

23 still --

24 MR. McCLOSKEY: It's still an open question. I believe it's a --

25 I think he's -- I think it was done by Rodic, but before I can tell you

Page 37817

1 that, I need to get back into our history a bit.

2 JUDGE ORIE: Yes.

3 [Trial Chamber confers]

4 JUDGE ORIE: Now, the other document -- well, first of all, the

5 Chamber will decide on admission of this map at the end of the

6 examination of the witness.

7 MR. IVETIC: Do I need to tender it then, Your Honours? Because

8 I have not.

9 JUDGE ORIE: Yes. You have not tendered it?

10 MR. IVETIC: No.

11 JUDGE ORIE: And you do not intend to tender it either.

12 THE INTERPRETER: I had left it up to Your Honours whether you

13 thought we needed the bigger portion of it because there is a smaller

14 portion in the --

15 JUDGE ORIE: Yes, yes, you would say the -- perhaps if only for

16 purposes of knowing that this map and admission of this map needs,

17 perhaps, specific attention that we put it as a separate --

18 MR. IVETIC: That's fine.

19 JUDGE ORIE: So if you would tender it at this moment as a

20 separate document, then --

21 MR. IVETIC: I do.

22 JUDGE ORIE: -- it would be marked for identification.

23 Mr. Registrar, the map as a separate document would receive

24 number?

25 THE REGISTRAR: D1196.

Page 37818

1 JUDGE ORIE: And is marked for identification.

2 MR. IVETIC: Under seal, under seal, Your Honours.

3 JUDGE ORIE: Under seal. Under seal.

4 D1195, which was the document, the text document, should have

5 been admitted under -- should have been marked for identification under

6 seal then, as well, I take it?

7 MR. IVETIC: That's correct.

8 JUDGE ORIE: And are there similar questions as to the provenance

9 of that document?

10 MR. McCLOSKEY: Mr. President, that -- it looks like a BiH

11 document, and I don't right now have reason to have any problems with it.

12 I think it's got an ERN on it. We best take a look, though.

13 JUDGE ORIE: Okay. But for the time being, therefore, we leave

14 it to you whether you want to make any further submissions in relation to

15 that.

16 Then we can move on, I think, Mr. Ivetic.

17 MR. IVETIC: Yes.

18 JUDGE ORIE: Although I think you went well over your time, but

19 please proceed.

20 MR. IVETIC: It's all very important and I'm trying to respond to

21 questions raised by Your Honours several times today to try to make the

22 technical matters understood for all of us.

23 If we could now move to 1D1082, and this also should not be

24 broadcast.

25 Q. We had earlier looked at a photograph of antenna from the

Page 37819

1 so-called northern facility. This is dated in, I think, February of 1995

2 from the northern facility and is an overview of posts and equipment.

3 Now, looking at the antenna listed for these three posts that we

4 have here - 1, 2, and 3 - have we seen them all in the one picture that

5 we have looked at thus far?

6 A. I apologise. I didn't -- I didn't understand the question.

7 Q. If we look at the document, we have listed three work positions

8 or posts, and we have three devices, an ICR-100 two times and an

9 ICR-7100. And in the column "Antenna" we have listed Helical AH-7000 and

10 log periodic. Which of these antennae have we already seen in the one

11 photograph that we have looked at?

12 A. We have these AH-7000 antennas, that's the umbrella antenna. I

13 described it as that. Then we have the regular logo ones. And then we

14 have the Helical antennas. But they're not here in the picture. We've

15 got the parabolic ones, not the Helical.

16 Q. Now, first of all, post 1 has an ICR-100 receiver and a TS-430S

17 transceiver and a converter 150/18 megahertz. What does that tell you

18 about the probable use of this post, including if it is suitable for

19 listening to VRS radio relay transmissions?

20 A. If there was a Helical antenna here, then you could intercept

21 multichannel communications. That kind of antenna does have the range

22 for the RRU-800, the TS-430S splitter can split channels 1 to 12 or 1

23 to 8 if a different device is involved. And then the Helical antenna can

24 receive all of that. This converter then is not needed in that case for

25 this particular post. Perhaps if there was a different device of a high

Page 37820

1 frequency when you are switching from a higher to a lower frequency in

2 order to split it, then you would have some special post. But in this

3 case, there isn't one.

4 Q. Now, post number 2 has an ICR-7100 device attached to the AH-7000

5 which you've identified as the parabolic antenna. Based on your

6 knowledge, experience and expertise, what use do you foresee of this

7 post? Can it effectively intercept VRS radio relay transmissions at

8 the -- at the northern location?

9 A. I understood it as post number 2. Post number 2 has a discount

10 antenna, so it cannot receive multi-channel signals from an RRU-800 or an

11 FM200.

12 Q. I apologise. I misspoke. Thank you for correcting me. And I

13 think you've already identified the use of the log-periodic antenna in

14 one of your previous answers, so I'd like to then try to save time by

15 first tendering this document under seal.

16 JUDGE ORIE: Yes, could I ask a very short question.

17 MR. IVETIC: Sure.

18 JUDGE ORIE: The document refers to tape recorders as UHER4000,

19 U-H-E-R. In your report, you are referring to UHR, that is U-H-R tape

20 recorders. Is that the same? I take it it is, UHER being a well-known

21 company producing professional recording devices? It's in paragraph 2.

22 THE WITNESS: [Interpretation] Your Honour, in my document there

23 is a photograph of an UHER tape recorder where we have written the

24 letters UHER4000 report, IC. If anything else is written, then it must

25 mean that it's a typo. But it's that one.

Page 37821

1 JUDGE ORIE: Then a number, Mr. Registrar.

2 THE REGISTRAR: It will be assigned Exhibit D1197. Thank you.

3 JUDGE ORIE: Admitted into evidence.

4 MR. IVETIC: If we could look at P164 -- under seal, yes.

5 JUDGE ORIE: Under seal.

6 MR. IVETIC: If we could look at P1648. And this will be the

7 original source of picture number 2 from page 54 and page 36 of your

8 report in the respective Serbian and English languages.

9 Q. And this is also represented as being the northern site. Now,

10 you have mentioned a couple of times a heliocodial [sic] antenna. In

11 this photograph, can you, with the assistance of the usher, circle the

12 heliocodial antenna.

13 A. That's number 1.

14 Q. Given the proximity of the two different types of antennas, I

15 would ask that you actually circle the heliocodial in addition to marking

16 it number 1.

17 A. The number 1 marks this antenna that is like a pipe, that is the

18 heliocodial antenna which listens into the RRU-800 or the FM200.

19 JUDGE ORIE: So it is not the red and white striped longer

20 antenna but the shorter one immediately left to the number 1?

21 THE WITNESS: [Interpretation] Yes.

22 JUDGE ORIE: Please proceed.

23 MR. IVETIC:

24 Q. And now this longer red and white antenna, which I believe is a

25 logo-periodic, in this configuration does it work in conjunction with the

Page 37822

1 heliocodial antenna or not? That is to say, does it add anything to what

2 the heliocodial antenna can do on its own?

3 A. It does not contribute to the operation of this antenna because

4 they are on different wavelengths. The heliocodial antenna receives the

5 frequency of range. It's not precise but it's approximately from 500 to

6 1.200 megahertz, and within that range the RRU-800 and FM200 go up to 960

7 megahertz; whereas, the log antenna receives frequencies up to 1300

8 megahertz. So they don't cancel each other out.

9 Q. And does the logo antenna in this picture -- what's your opinion

10 as to whether it is a professionally manufactured antenna or otherwise?

11 A. Judging by the photograph, you can tell that it's a handmade

12 antenna, constructed from materials and parts from other antennas. And

13 it can serve its purpose, definitely. It's not of any high quality, but

14 still it can serve the purpose.

15 MR. IVETIC: If we could tender the document under seal as marked

16 or --

17 JUDGE ORIE: Madam Registrar --

18 MR. IVETIC: I don't know if it needs to be under seal or not.

19 JUDGE MOLOTO: Is it not a P number?

20 MR. IVETIC: It is a P number, yes.

21 JUDGE ORIE: [Overlapping speakers] ...

22 MR. IVETIC: It's been marked though.

23 JUDGE ORIE: Now it's marked.

24 Mr. Registrar, the document now marked by the witness.

25 THE REGISTRAR: It shall be assigned Exhibit D1198. Thank you.

Page 37823

1 JUDGE ORIE: D1198 is admitted.

2 MR. IVETIC: I'd like to now look at D310 which is represented as

3 being from the southern location and again has a number of antenna or

4 antennae.

5 Q. And the one in the centre that has a pipe and a spiralling wire

6 or spiralling-something across it, what kind of an antenna is that?

7 A. This is also a heliocodial antenna intended for the reception of

8 RRU-800 and FM200. And it's a hand-manufactured antenna. One first

9 calculates the thickness of the pipe, the thickness of the wire that is

10 wrapped around the pipe, the distance between them, so that it is capable

11 of receiving a certain signal. When these calculations are made, usually

12 they are done for one frequency. But probably the person who constructed

13 it thought that they probably needed 800 megahertz in order to be able to

14 receive from 600 to 800, and then from 800 up to 960.

15 The quality is not as good as factory-manufactured antennas. The

16 problem is the cable that is seen here in the shape of a semicircle.

17 They have to be made from material which would ensure that there is good

18 connections as well as the possibility of adjusting the antenna, so I

19 don't know with this kind of home-manufactured antenna how much you could

20 receive on it. But definitely, it was substandard in quality in

21 comparison to factory-manufactured antennas.

22 MR. IVETIC:

23 Q. Can any of the other antennas we see in this photograph be used

24 in conjunction with the heliocodial homemade antenna to assist in its

25 reception of signal?

Page 37824

1 A. Well, heliocodial antennas, mostly you cannot increase the

2 signal. Perhaps at some lower frequencies. But in this particular one,

3 you cannot match. The only thing that is possible is to have two

4 antennas working in tandem.

5 Q. And if we can look at, first of all, briefly just D309. This is

6 also reported to be from the southern condition -- southern position.

7 I'd like to direct your attention first to the post on the right-hand

8 side that appears to have a piece of metal with a hole in it that is

9 detached from it.

10 Could you tell us what the significance is of that post and that

11 piece of metal that has a hole that is detached from the main post?

12 A. What you can see on the right-hand side is a metal pipe. It

13 probably carried an antenna at some point. You can see at the top that

14 there was some kind of item on the top, and it's 99.9 per cent sure that

15 it was grounding that was there that has become disconnected. I think it

16 wasn't done very well because the grounding would take care of the safety

17 of the personnel but would also maintain the signal in case of electric

18 discharges or lightening striking the pole.

19 THE INTERPRETER: Could the witness please repeat the last

20 sentence.

21 MR. IVETIC:

22 Q. Could you please repeat the last sentence of your answer so that

23 the translators can accurately translate it.

24 A. I apologise. When you look at this whole thing, you can see that

25 the personnel was not very conscientious because they didn't ensure

Page 37825

1 proper grounding which would safeguard the personnel as well as the

2 actual device from lightening or electrical discharge.

3 JUDGE ORIE: Mr. Lukic, I'm looking at the clock. Mr. Ivetic.

4 MR. IVETIC: Yeah. I guess we'll stop for today. I have

5 approximately, I'd say, 15 minutes more to cover three brief areas; one

6 document from the southern location, and two diagrams showing the optical

7 visibility from ...

8 JUDGE ORIE: We'll consider whether --

9 MR. IVETIC: Okay.

10 JUDGE ORIE: -- you'll be given such extra time, because I know

11 that you blamed the Chamber more or less for the time you took. Perhaps

12 evidence elicited should be so clear as not for the Chamber to ask for

13 further explanations.

14 And apart from that, you -- we noticed two things: First, that

15 you let the witness go often far beyond what your question is without

16 efficiently stopping him and getting him back on track. The second thing

17 is that you often dealt with such technical details that questions may be

18 put as to the relevance and the probative value of such questioning.

19 So, therefore, we'll consider - and you should prepare for even a

20 little bit less time - and focus on the most important matters.

21 Mr. Dosenovic, we would like to see you back. But we are not

22 sitting tomorrow, which means that we would like to see you back Monday

23 morning, 9.30 in the morning, and --

24 Mr. McCloskey.

25 MR. McCLOSKEY: Excuse me, Mr. President. Just one thing that

Page 37826

1 may be helpful. Those photographs or OTP photographs that were taken in

2 1998, just so you could have the context while we're still thinking about

3 them, is from the sites, as Mr. Ivetic mentioned.

4 JUDGE ORIE: That's comment. I think -- that's comment not

5 necessarily to be done in the presence of the witness. I also do not

6 fully grasp, but I'm not inviting you at this moment to further

7 elaborate, Mr. McCloskey, what the message exactly is you're sending to

8 us, because I was at this moment telling the witness that we expected him

9 back at 9.30 in the morning on Monday.

10 And I again instruct you that you should not speak or

11 communicate, not by any technical means, with anyone about your

12 testimony, whether that is testimony you have given already or testimony

13 still to be given on Monday, and hopefully not on Tuesday.

14 You may follow the usher.

15 [The witness stands down]

16 JUDGE ORIE: We adjourn and will resume Monday, the 17th of

17 August, 9.30 in the morning, in this same courtroom, I.

18 --- Whereupon the hearing adjourned at 2.17 p.m.,

19 to be reconvened on Monday, the 17th day

20 of August, 2015, at 9.30 a.m.