1 Thursday, 16 September, 2010
2 [Open session]
3 [The accused entered court]
4 --- Upon commencing at 2.13 p.m.
5 JUDGE MOLOTO: Good afternoon to everybody in and around the
6 courtroom. Mr. Registrar, would you please call the case.
7 THE REGISTRAR: Good morning, Your Honours. Good morning to
8 everyone in and around the courtroom. This is case number IT-04-81-T,
9 the Prosecutor versus Momcilo Perisic. Thank you.
10 JUDGE MOLOTO: Thank you so much. Could we have the appearances
11 for the day, starting with the Prosecution.
12 MR. THOMAS: Good afternoon, Your Honours. Good afternoon to
13 everyone in and around the courtroom. Inger de Ru, Rafael La Cruz, and
14 Barney Thomas for the Prosecution.
15 JUDGE MOLOTO: And for the Defence.
16 MR. GUY-SMITH: Good afternoon. Tina Drolec, our new intern
17 Mr. Morrison, my name is Gregor Guy-Smith, and Boris Zorko on behalf of
18 Mr. Perisic. Mr. Zorko will be leading the next witness.
19 JUDGE MOLOTO: Thank you very much, Mr. Guy-Smith. Mr. Zorko.
20 MR. ZORKO: [Interpretation] Thank you, Your Honour. I will only
21 need a couple of moments to get organised.
22 Your Honours, our next witness is Mr. Drago Covilo.
23 JUDGE MOLOTO: Thank you. Is Mr. Covilo still coming from the
25 MR. ZORKO: [Interpretation] Your Honour, he is here. I'm waiting
1 for him to appear in the courtroom. There he is, Your Honour
2 [The witness entered court]
3 JUDGE MOLOTO: May the witness please make the declaration.
4 THE WITNESS: [Interpretation] I solemnly declare that I will
5 speak the truth, the whole truth, and nothing but the truth.
6 JUDGE MOLOTO: Thank you very much. You may be seated, sir.
7 THE WITNESS: [Interpretation] Thank you.
8 JUDGE MOLOTO: And good afternoon to you.
9 THE WITNESS: [Interpretation] Good afternoon to everyone in the
10 courtroom. Good afternoon, Your Honours.
11 JUDGE MOLOTO: Thank you so much. Yes, Mr. Zorko.
12 MR. ZORKO: [Interpretation] Thank you, Your Honour.
13 WITNESS: DRAGO COVILO
14 [Witness answered through interpreter]
15 Examination by Mr. Zorko:
16 Q. Good afternoon, Mr. Covilo.
17 A. Good afternoon, Mr. Zorko.
18 Q. My name is Boris Zorko and I'm attorney-at-law, and together with
19 Miss Tina Drolec and Mr. Gregor Guy-Smith I will be representing the
20 Defence for Mr. Perisic. Before.
21 We proceed, we need to bear in mind the fact that the
22 interpreters have to interpret what we say and the transcribers have to
23 record everything, so please pause before answering my question so that
24 everything can be properly recorded.
25 A. Very well.
1 Q. Can you first state your full name for the transcript.
2 A. My name is Drago Covilo.
3 Q. Give us your date and place of birth.
4 A. I was born on the 24th of September, 1946, in Nevesinje,
6 Q. Thank you. In order to be as efficient as possible, I'll present
7 to you -- I'll put to you some of the facts relating to your professional
8 career. Please hear me out and then let me know if the information is
9 correct. You graduated from the military academy in 1968 in the field of
10 communications; is that right?
11 A. Yes.
12 Q. In 1972 you graduated from the political college, is that right,
13 with an associate degree?
14 A. Yes.
15 Q. In 1979, you graduated from the high military academy?
16 A. I don't know if it was in 1979 or 1980, but that's true that
17 around about that time I graduated from the associate degree military
19 Q. Thank you. After 1979 you were assigned to a communications
20 regiment with the Supreme Command of the Yugoslav People's Army in
22 A. Yes. As I graduated from the post-secondary military academy, I
23 was posted to the communications regiment or regiment of signalmen with
24 the Supreme Command.
25 Q. Thereafter you were assigned to the General Staff of the JNA,
1 specifically to the communications administration, and you held the post
2 of a desk officer for communications; is that right?
3 A. Yes, that's right. After awhile with the communications regiment
4 a year or two, I assigned to the General Staff of the JNA with the
5 department of communications.
6 Q. Thereafter you were head of the communications department as well
7 as the department charged with the development of communications?
8 A. Yes. For a while I served with the department for the
9 preparation of communications, system for the setup of the communications
10 system. And then as of 1992, I was assigned to the department for the
11 development of communications.
12 Q. As of August 1992 through to the end of 1993 you held the post of
13 chief of department for the development and use of the branch of
14 communications with the Army of Yugoslavia; is that right?
15 A. Yes.
16 Q. In 1993 you were assigned to the post of chief of department for
17 operations and staff affairs in the communications sector, or rather, the
18 sector for communications, information technology, and electronic warfare
19 with the General Staff of the Army of Yugoslavia?
20 A. Yes. I don't recall the exact date. I think this was in late
21 1993 that the secretary for communications, information technology, and
22 electronic warfare was set up. And I was assigned to be the chief of
23 department within that sector and the department was charged with
24 operational and staff affairs.
25 Q. You held that post up until 1999 when you became director of the
1 sector for combat preparations with the Ministry of Defence; is that
3 A. Yes. This was in the Ministry of Defence but I was within the
4 PTT of Serbia
5 telecommunications and telegraph.
6 Q. Thank you, Mr. Covilo. Was it in May of 1992 that you spent a
7 period of time in Bosnia and Herzegovina; and if so, on which duties?
8 A. As the Army of Yugoslavia was set up and as a decision was issued
9 to the effect that the JNA units would withdraw from the territory of
10 Bosnia-Herzegovina, sometime in the month of May, I was tasked by the
11 chief of the communications administration with a mission to Bosnia
13 present there. There was a large operational contingent there, part of
14 which was an element of a unit of the Supreme Command, i.e., elements of
15 the communications regiment from Belgrade
16 My task was to assist in the unhindered departure of men and
17 equipment from Bosnia-Herzegovina to Yugoslavia. Since the civilian
18 communications system had been set up through the node in Mostar because
19 of the operations that were well known, all the PTT lines in
20 Bosnia-Herzegovina were severed. Since I was a communications planner
21 and was quite familiar with the communications setup in all the republics
22 of the former Yugoslavia
23 these communications up and running.
24 Since I knew that the Army of Republika Srpska was being set up
25 in Bosnia-Herzegovina, the main question I put to the chief as soon as he
1 told me that I was to go on a mission there was for how long I was to be
2 in Bosnia-Herzegovina and when was the date of my return planned. I
3 asked this because I knew that individuals who hailed from
4 Bosnia-Herzegovina were given the possibility to stay behind in
6 Q. I apologise for interrupting you, but it will be very difficult
7 to follow such long answers, so please try and be as concise as possible
8 in your answers.
9 A. I understand.
10 Q. And I'll try and be as brief as possible as well.
11 A. In other words, I was given assurances that I would return, and
12 as soon as I completed my mission in early August, the chief the
13 communications administration recalled me to the General Staff of the
14 Army of Yugoslavia
15 Q. Thank you, Mr. Covilo.
16 JUDGE MOLOTO: Do I understand you, sir, to be saying that you
17 were sent by the JNA to go and set up the communication lines around
18 Mostar which had been cut off, and who were you setting these up for? In
19 other words, for whose benefit were you setting them up?
20 THE WITNESS: [Interpretation] Yes. In principle, Mr. President,
21 your understanding is correct. I was supposed to assist in restoring
22 communications lines, PTT systems in Bosnia-Herzegovina, in Bileca,
23 Trebinje, Nevesinje, and Gacko.
24 JUDGE MOLOTO: My question is, for whose benefit?
25 THE WITNESS: [Interpretation] For the benefit of the PTT systems
1 in these areas.
2 JUDGE MOLOTO: Thank you. Yes, Mr. Zorko.
3 MR. ZORKO: [Interpretation] Thank you, Your Honour.
4 Q. Let us be quite clear on this issue: The PTT system of the time,
5 was it considered good? It had been considered civilian communications
7 A. The PTT system was considered to be a civilian communications
8 system at all times save for the fact that part of these lines could be
9 used for military purposes.
10 Q. Thank you. To make the matter quite clear, during your
11 professional career you were a member of which army?
12 A. Throughout my professional career I was a member of the JNA and
13 subsequently of the Army of Yugoslavia.
14 Q. Thank you, Mr. Covilo. On your return to the General Staff of
15 the Army of Yugoslavia, and bearing in mind the fact that you hail from
16 Bosnia-Herzegovina, were there requests made for your posting to the VRS,
17 if you know?
18 A. Yes, I do know. The Main Staff of the Army of Republika Srpska
19 did make such requests, and as far as I know, General Mladic himself
20 requested that I be posted there. This because I was deemed by some at
21 the time to be a connoisseur of the communications system and that I
22 would be the man for the job. I had always made it clear that I didn't
23 want to go to the area, that I was a member of the VJ, and my superior
24 officers showed consideration for my views and believed that I should
25 remain a member of the Army of Yugoslavia.
1 Q. Thank you, Mr. Covilo. Now, your decision or your choice to stay
2 with the Army of Yugoslavia, did it have any negative bearing on you
4 A. No.
5 JUDGE MOLOTO: Just to be clear, you said your superiors believed
6 that you should remain a member of the Army of Yugoslavia. Are you
7 saying by your next answer that indeed you did remain a member of the
8 Army of Yugoslavia
9 THE WITNESS: [Interpretation] Yes, Your Honour.
10 MR. ZORKO: [Interpretation]
11 Q. Mr. Covilo, your duties and obligations, did they change with the
12 establishment of the Army of Yugoslavia; and if so, in what sense?
13 A. Your Honour, did they change. Well, partly they did. This was a
14 new army and for the better part of it there was a new system of
15 organisation put in place.
16 Q. Thank you, Mr. Covilo.
17 MR. ZORKO: [Interpretation] I should like to show to the witness
18 Exhibit D200, specifically page 17 in Serbian, and the English
19 translation page 43, doc ID 1D120972. For efficiency of proceeding, I
20 have prepared a binder which I would like to be shown first to the
21 Prosecutor and to be then handed to the witness who will use it during my
23 JUDGE MOLOTO: By all means, Mr. Zorko.
24 MR. ZORKO: [Interpretation] If need be, I can repeat that the
25 English translation has doc ID 1D120972.
1 Q. Mr. Covilo, while we are waiting for the English translation,
2 please tell us in simple terms what the main powers of the sector for
3 communications were, that's to say the department you were a member of as
4 of 1992.
5 A. In order for you to fully understand my future evidence, I will
6 tell you how the sector was organised briefly. At the head of the
7 sector, and I'll use an abbreviation, VA, there was the assistant Chief
8 of the General Staff. My department had a role of a staff of an HQ to
9 play for that organ. The sector was an administrative and specialist
10 body of the General Staff tasked with the use and development as well as
11 equipping of the communications systems, IT, and electronic warfare.
12 JUDGE MOLOTO: If I may interrupt you, Mr. Covilo. The document
13 that is appearing in the English does not look to me like it's a
14 translation of the document that appears in the B/C/S. I don't whether
15 you can see it, Mr. Zorko.
16 MR. ZORKO: [Interpretation] Your Honours, I apologise for
17 interrupting but I might be of assistance. We should be looking at page
18 43 of the document, where we see the description of the sector we are
19 talking about.
20 JUDGE MOLOTO: We now see a document that looks like it could be
22 MR. ZORKO: [Interpretation] Thank you very much, Your Honour.
23 JUDGE MOLOTO: Sorry, Mr. Covilo, you may proceed.
24 THE WITNESS: [Interpretation] Should I repeat what I just said?
25 MR. ZORKO: [Interpretation]
1 Q. No, need, Mr. Covilo. You may continue.
2 A. Thank you. It comprised all of the functions of the directly
3 subordinated organisational units. Each of the administrations had its
4 own component organisational units.
5 In the briefest of terms, what were their obligations? The main
6 principal purpose of the sector was to keep down the manning figures in
7 the administrations and to pool some of these obligations together;
8 financing, providing equipment, mobilisation, personnel related issues,
9 and frequency distribution. I won't elaborate any further but those were
10 the principal duties of the sector for communications, information
11 technology, and electronic activity.
12 Q. Thank you very much, Mr. Covilo.
13 Mr. Covilo, how did the planning work for the communications
14 sector back in the JNA?
15 A. Your Honours, Mr. Zorko, the same thing applied to any army
16 throughout the world. The communications sector was planned by
17 communication organs in keeping with their own documents and regulations,
18 specifically, different sets of instructions and rules governing their
19 work. The communications programme would be drafted for each separate
20 command level.
21 Q. Thank you very much, Mr. Covilo. Were there any differences in
22 terms of the planning process in relation to communications after the VJ
23 had been established?
24 A. Nothing particularly noteworthy in terms of differences. The
25 same system was kept. There were some peculiarities that characterised
1 the new system, but nothing real essential.
2 Q. Thank you very much, Mr. Covilo. As far as communications
3 planning is concerned, which is something you mentioned, who was familiar
4 with these plans in the VJ?
5 A. I will try to provide an accurate answer to this question. In
6 order to do that, I have to point out that in the JNA the division worked
7 as follows: There were two types of communications; operating or
8 stationary communications, and communications at the ready, or on
9 standby. As for operating communications, all of the users were
10 familiar. As for standby communications, only the organs actually
11 drafting those plans were familiar with those.
12 Q. Thank you very much, Mr. Covilo. Can you tell us what types of
13 communications existed that were used by the VJ?
14 A. The same ones as for the JNA. In addition to the basic division
15 that I mentioned in my previous answer, I should add that there was radio
16 relay, there was analogue communication, there was protected
17 communication, wire communication, radio communication, courier
18 communication, and signal communication at lower levels.
19 Q. Thank you very much, Mr. Covilo. You mentioned several different
20 types of communications. Could you please explain in the briefest of
21 terms what each of them mean. What is the exchange of information that
22 these types of communication enable us to have?
23 A. The most acceptable answer would be that a line of communication
24 is a line between two persons, between two centres, two towns, two
25 garrisons. The system of communications in the JNA, the VJ, or any other
1 army in the world is not very different from such systems as are used by
2 civilian bodies; it fulfills the basic need for two persons to
4 Q. Thank you very much, Mr. Covilo. Among other things, you
5 mentioned stationary communications systems. What would that imply?
6 A. A stationary system provides the backbone for the communications
7 system in its entirety. It comprises stationary communications centres
8 and stationary communication hubs. There are external routes between the
9 stationary centres and the stationary hubs.
10 Q. Thank you very much, Mr. Covilo. When you speak of the
11 stationary communications system, what sort of lines could be established
12 by using this system? What does that mean in practical terms?
13 A. A stationary communications system is a small PTT centre within a
14 garrison. Depending on a garrison's size, various types of
15 communications were used. For example, you have the town of Bar in
17 centre that can be accessed by wire alone. For example, Podgorica in
19 types of communication lines emanated; radio, wire, courier, and radio
21 Q. Mr. Covilo, how many units could such a stationary communications
22 centre in the JNA cover?
23 A. Your Honours, allow me to use an example. Suppose we have a
24 small PTT centre in the town of Visegrad
25 inhabitants. This is a stationary communications system in the town of
1 Visegrad. It comprises all of the units and institutions located at a
2 point in time within the area covered by that particular garrison.
3 Q. Mr. Covilo, let's try to make this as clear as possible. The
5 centre cover, communication-wise?
6 A. A garrison was any location at all at which a unit of the JNA
7 were stationed. If this was a battalion, a single battalion, then that's
8 what was covered. If it was some sort of a merged or joint unit, there
9 could have been any number of those; five brigades, six brigades. In
10 larger garrisons such as Podgorica, Montenegro
11 Bosnia-Herzegovina; and Nis, Serbia
12 Q. If my understanding is correct, a garrison like that could
13 establish a communication line to any other garrison throughout the SFRY
14 at the time; right?
15 A. Yes, that's right. That was the fundamental purpose of the
16 stationary communications system. It enabled communication to any unit
17 and institution throughout the SFRY. For example, you have a garrison in
18 Vipava, Slovenia
19 stationed in Bitola, Macedonia
20 but one needed an intercession, a mediation, on behalf of other
21 intermediary communications centres that lay between the two.
22 Q. Mr. Covilo, were all of the garrisons throughout the former JNA
23 linked up or connected in the same way?
24 A. Yes. If you consider my previous answers, you could tell there
25 were a number of, peculiarities there. Smaller garrisons had one type of
1 communications alone and larger garrisons had several different types of
2 communication that were available to them.
3 Q. You mentioned something you called the stationary communication
4 hub [Realtime transcript read in error "had you been"]. Can you please
5 try to explain what that means?
6 A. Your Honours, in one of my previous answers I said that the
7 stationary system provided the background to the communications system in
8 its entirety. This was a true backbone, this communication hub. The
9 stationary communication hub is normally an installation built at some
10 sort of elevation. From there, one establishes several radio relay lines
11 and a smaller number of radio lines. The stationary hubs would normally
12 be found in underground installations. The only thing that was above the
13 ground were the antennae. Likewise at a stationary communications hub,
14 in addition to establishing radio relay lines, one performed the
15 commutation; that is, there was a switchboard there for different
16 communication lines.
17 JUDGE MOLOTO: Yes, Mr. Thomas.
18 MR. THOMAS: Your Honour, I'm sorry to interrupt my learned
19 friend. There's, at page 14, line 1, just a correction required to the
20 transcript. The question at the moment as recorded reads: "You
21 mentioned something called a stationary communication had you been," and
22 obviously it's "stationary communication hub," and that needs to be
23 reflected, Your Honours.
24 JUDGE MOLOTO: I'm trying to look at page 14, line 1. I'm not
25 seeing what you are talking about.
1 MR. THOMAS: Sorry, Your Honour, the question actually begins
2 page 13, line 25: "You mentioned something called the stationary
3 communication --" and what should follow is the word "hub."
4 JUDGE MOLOTO: Thank you, Mr. Thomas. Yes. Mr. Zorko.
5 MR. ZORKO: [Interpretation] Thank you, Your Honours. Thank you
6 also to my learned friends. I myself have a point to raise about the
7 transcript. [Overlapping speakers] ...
8 JUDGE MOLOTO: Okay. What I was hearing is quiet now. Can you
9 raise your point, Mr. Zorko.
10 MR. ZORKO: [Interpretation] Likewise a small intervention. Page
11 14, lines 9 and 10. The transcript reflects something the witness didn't
12 actually say, "Han Pijesak," whereas it should be "hub." Because that's
13 what the witness was talking about.
14 JUDGE MOLOTO: The name "Han Pijesak" should come out. Thank
16 MR. ZORKO: [Interpretation] Thank you, Your Honours.
17 Q. Mr. Covilo, who was it that manned those stationary
18 communications centres? Who was in charge of operating those centres on
19 the ground?
20 A. Again I have to go back to something that I have often been
21 pointing out. It depends on the centre's size. If we are talking about
22 the relatively small communications centre with battalions there, you
23 would have ordinary private soldiers doing their regular military term
24 manning those. If you look at a centre of an average size, normally one
25 would have civilians serving in the JNA and any given number of active
1 duty officers manning those centres. It is noteworthy that the civilians
2 normally came from the area in which the communications centre was
4 Q. Thank you very much, Mr. Covilo.
5 MR. ZORKO: [Interpretation] Could we please have OTP Exhibit P469
6 brought up on our screens. This is a map.
7 Q. Mr. Covilo, you won't find this map in your binder.
8 JUDGE MOLOTO: Before we go to that map, Mr. Zorko, I'm advised
9 that this document that's on the screen is not part of the original
10 document, and whether you -- what would you like to do with it?
11 MR. ZORKO: [Interpretation] Your Honour, since D200 was MFI'd at
12 one point in time, we shall in due course be tendering it. Nevertheless,
13 I do hope that we can work with our colleagues from the OTP to see
14 whether there might be any objections against the admission of this
16 We are still waiting to see whether the translation is accurate
17 and are content to leave it as an MFI for the time being. We need a full
18 translation for this document to be revised. This is quite a
19 substantial, comprehensive document. For the time being, we are happy to
20 leave it as it is. In due course we shall be asking for that document
21 and a number of other documents to be properly admitted into evidence.
22 [Trial Chamber and Registrar confer]
23 JUDGE MOLOTO: Can you correct me, this D200 is marked for
25 MR. ZORKO: [Interpretation] Yes, that's right, Your Honour.
1 JUDGE MOLOTO: But [Overlapping speakers] ... only [Overlapping
2 speakers] ...
3 MR. ZORKO: [Interpretation] That's right, Your Honour, yes.
4 JUDGE MOLOTO: What you want to do is to add this page to the
5 pages that are marked for identification?
6 MR. ZORKO: [Interpretation] Yes.
7 JUDGE MOLOTO: Pending that translation?
8 MR. ZORKO: [Interpretation] I do apologise, I'm probably creating
9 some confusion in relation to this document. It has been used with
10 certain witnesses, some portions of it were. We have submitted it to be
11 fully translated and the translation that you have been looking at is the
12 full translation. Therefore, we shall be asking to have the full
13 translation cross-referenced to the original document that runs into a
14 total of 29 pages, the original being in B/C/S.
15 JUDGE MOLOTO: Mr. Zorko, you are interpreted as having said "We
16 have submitted it to be fully translated and the translation that you
17 have been looking at is the full translation." Now it can't be, we've
18 been looking at one page and you are telling us that the whole thing is
19 about, what, 29 pages or even more. It does seem as if some pages have
20 been admitted but marked for identification, and it seems to me that the
21 procedure that we would like to follow is to say that the page that we
22 saw today be added to the marked -- to the pages that are marked for
23 identification. And as and when you use the pages that have not been
24 marked so will you be asking that they be added to those.
25 MR. ZORKO: [Interpretation] You are quite right, Your Honour. I
1 do apologise for unnecessarily causing confusion.
2 JUDGE MOLOTO: Not a problem. Not a problem. Okay. Then yes,
3 this page then will be added to the marked for identification part of
4 D200. We may call P469 on the screen.
5 MR. ZORKO: [Interpretation] Thank you, Your Honour.
6 Q. Mr. Covilo, you have a map before you.
7 Could we have usher's assistance so that you may mark on this map
8 the location of the place that you called the stationary communications
9 hub or the backbone of the communications system, to the best of your
10 recollection, in Croatia
11 A. Your Honour, Mr. Zorko, the map is so small that I'm really
12 unable to get my bearings here. I don't even see the territory of the
13 former SFRY.
14 JUDGE MOLOTO: My concern, Mr. Zorko, is that you are -- again
15 you are interpreted as asking the witness to mark it to the best of his
16 recollection in Croatia
17 of a town, not a middle of a country. Unless you tell me what town this
19 THE REGISTRAR: Your Honours, apologies on behalf of the Registry
20 as the wrong document was shown.
21 JUDGE MOLOTO: Thank you, Mr. Registrar.
22 Yes, Mr. Zorko.
23 MR. ZORKO: [Interpretation] Thank you, Your Honour.
24 Q. Mr. Covilo, you should be able to see a map now. It's perhaps
25 not the most visible of maps and I'm not asking for absolute precision on
1 your part. What I would like you to do is to mark in Croatia,
2 Bosnia-Herzegovina, and the FRY the location of the stationary
3 communications hubs as you recall them.
4 A. Your Honours, Mr. Zorko, I will do my best, but please do
5 understand that it's been 20 years since I last dealt with the system.
6 At any rate, I will do this to the best of my recollection, but don't
7 hold it against me if I omit to mark any of the hubs or mismark them.
8 Let's start from Croatia
9 sure that it's going to be the exact location because I can't see it
10 correctly but I'll say the name of the location.
11 One of them was Sunj; number 2 is Papuk; 3, Drinska Gora; 4,
12 Petrova Gora; 5, Moslavacka Gora; 6, Licka Pljesevica; 7, Celavac; 8,
14 In Bosnia
15 10, Bjelasnica; 11, Borasnica; 12, Velez; 13, Kmur; 14, Kozara; 15,
16 Vitorog; 16, Majevica; 17, Cvrsnica; and 18 Klekovaca, I believe.
17 In Serbia
18 22, Cer; 23, Jagodnja; 24, Cigota; 25, Strazbenica; 26, Maljen; 27,
20 In Kosovo, number 28, Butovacki Breg; and 29, Mokra Gora. And I
21 believe I forget to mark Crni Vrh.
22 This is roughly the communications hubs that I can recall.
23 Q. Thank you.
24 MR. ZORKO: [Interpretation] Can we please save the marked map.
25 Let me just state that number 6 relates to a communications hub you said
1 was in Croatia
2 A. Licka Pljesevica, yes, it's in Croatia.
3 Q. That's number 6?
4 A. Yes, Licka Pljesevica was in Croatia. Yes, apologies, pardon me.
5 Q. Mr. Drago, please do not make any additional markings on the map
6 because we want to save it as it is now.
7 JUDGE MOLOTO: Before we save it, I'm not quite sure that later
8 when we look at the map we will be able to recognise 14, 15, and 25 --
9 oops, it's all gone. Mr. Registrar. I was going to ask whether there
10 was a way in which, one, we could delete only that 6 that was inside
11 Bosnia-Herzegovina and perhaps also try to rewrite 14, 15, and 25 so that
12 it's readable later when we do read it. Mr. Registrar assures me that he
13 will be able to bring it back.
14 MR. ZORKO: [Interpretation] Thank you, Your Honour.
15 [Trial Chamber and Registrar confer]
16 JUDGE MOLOTO: Mr. Registrar has brought back the map as marked,
17 but before the correction, before the shifting of the 6 out of BiH into
19 Now, Mr. Covilo, you corrected yourself at number 6. You
20 remember, you took out number 6 out of Bosnia-Herzegovina and put it into
23 THE WITNESS: [Interpretation] Your Honour, I can, but please bear
24 in mind that I did not place the numbers on the exact locations because I
25 can't see them.
1 JUDGE MOLOTO: Yes, we understand that, Mr. Covilo. Now,
2 Mr. Registrar, is it possible for the witness to correct 14, 15, and 25
3 without erasing the whole thing? Are you able to help him there?
4 [Trial Chamber and Registrar confer]
5 JUDGE MOLOTO: I'm told that cannot happen. We'll have to accept
6 it as it is. Are you tendering that? Mr. Zorko.
7 MR. ZORKO: [Interpretation] Yes, Your Honours, though it should
8 be said for the transcript that we have two number 6 and that the one to
9 the left is in the Republic of Croatia
10 in fact.
11 JUDGE MOLOTO: That's why I asked if that could be corrected.
12 Mr. Covilo, can you strike off the 6 that's inside
14 THE WITNESS: [Interpretation] Yes, Your Honour.
15 JUDGE MOLOTO: Thank you. Thank you. I'm told the only
16 amendment that you can do to 14 and 15 is to strike them out and write
17 the correct numbers, but if you try to erase them, you are going to erase
18 all of the numbers. Now, Mr. Covilo, do you still see where you wrote
19 number 14?
20 THE WITNESS: [Interpretation] Yes. It's wrong; it says 154.
21 JUDGE MOLOTO: Right. Can you strike that out and try to write
22 14 neatly next to it.
23 THE WITNESS: [Interpretation] Thank you, Your Honour.
24 JUDGE MOLOTO: Now, do you see what is 15?
25 THE WITNESS: [Interpretation] Yes, Your Honour.
1 JUDGE MOLOTO: What does it look like to?
2 THE WITNESS: [Interpretation] 5 is not properly written. Can I
3 correct it?
4 JUDGE MOLOTO: Yes, please do. Thank you. I'm trying to look
5 for number 25 because I thought I had a similar problem with it. Yes, I
6 do. It looks like an incomplete 28 just below 27. No, below 24, below
8 THE WITNESS: [Interpretation] Yes, yes, Strazbenica. Can I
9 correct it?
10 JUDGE MOLOTO: Can you correct it, please. Good. Thank you so
12 THE WITNESS: [Interpretation] Your Honour, I just remembered that
13 I forgot the hub in Serbia
14 I please mark it?
15 JUDGE MOLOTO: Please mark it. We already have a 30, Mr. Covilo.
16 Could you make that a 31?
17 THE WITNESS: [Interpretation] Apologies, Your Honour.
18 JUDGE MOLOTO: It must now look like 301. Thank you so much.
19 Right. Yes, Mr. Zorko.
20 MR. ZORKO: [Interpretation] Thank you, Your Honour. Let's try
21 and proceed with the map.
22 I can see that Mr. Barney [Realtime transcript read in error
23 "Tolimir"] is on his feet.
24 JUDGE MOLOTO: Mr. Thomas.
25 MR. THOMAS: I'm sorry, Your Honours, I don't know if we are at
1 the point yet where this image is going to be tendered. Just to make
2 matters a little more confusing, at page 19, line 9, Mr. Covilo had very
3 helpfully marked number 29, Mokra Gora, and then he says at line 9, "I
4 believe I forgot to mark Crni Vrh." And I see on the map a number 30 has
5 been entered on the map but it's not clear from the transcript whether
6 Crni Vrh has actually been marked on the map as number 30 or not. I'm
7 just lost as to whether number 30 actually is Crni Vrh and whether Crni
8 Vrh has actually been recorded on the map.
9 JUDGE MOLOTO: Are you able to help us, Mr. Covilo?
10 THE WITNESS: [Interpretation] Your Honour, I really don't
11 remember the time-line. I can tell you that Fruska Gora is 20, Avala is
12 21, Cer is 22, et cetera. So I know that I did say Crni Vrh but I'm not
13 sure which number I correlated it to. It might be 30 or 24.
14 JUDGE MOLOTO: You said page, Mr. Thomas?
15 MR. THOMAS: Page 19, line 9, sir. Perhaps I could suggest that
16 to avoid all doubt we simply give Crni Vrh a number 32 now. We just put
17 it on the map now, number 32, and then it's clear.
18 JUDGE MOLOTO: Are you able to mark Crni Vrh now, Mr. Covilo?
19 THE WITNESS: [Interpretation] Since it's quite occupied, the
20 place here, I'm going to place it elsewhere. There, 32, Crni Vrh.
21 JUDGE MOLOTO: Thank you so much. Mr. Zorko.
22 MR. ZORKO: [Interpretation] Thank you, Your Honour. We are not
23 that lucky with the technology today. Let's correct the transcript, line
24 22 -- or rather page 22, line 9, I said that I saw Mr. Thomas on his feet
25 and Mr. Tolimir's name can be read in the transcript.
1 JUDGE MOLOTO: Page 22, line 9.
2 MR. ZORKO: [Interpretation] That's right, Your Honour.
3 JUDGE MOLOTO: Yes, I do see Mr. Tolimir. You wanted to say
4 Mr. Thomas.
5 MR. ZORKO: [Interpretation] I don't see him at the movement.
6 JUDGE MOLOTO: It is duly corrected. Okay. You may proceed.
7 MR. ZORKO: [Interpretation] Thank you, Your Honour.
8 Q. Mr. Covilo, now that you've marked these stationary
9 communications hubs, can you tell us where the communications system was
10 at its densest when we are talking about former Yugoslavia?
11 A. Your Honour, Mr. Zorko, let me again place a caveat and say that
12 I may have omitted some of the hubs, I don't recall them. Let me tell
13 you that the communications system was best developed in the central part
14 of the country, that's to say in Bosnia-Herzegovina, in Serbia, and it
15 was somewhat poorer in Croatia
16 Q. Thank you, Mr. Covilo. The stationary communications hubs, as
17 they were dispersed across the territory, did they, in view of their
18 locations, best serve their role?
19 A. Well, I don't know if you could put it that way, but they did
20 make possible unhindered communication in these republics with the units
21 that had the requisite operational equipment. If I may, let me say that
22 there were at least three to four radio relay routes from each of these
23 hubs and that all of these hubs were interconnected.
24 Q. Mr. Covilo, if my understanding is correct, in order for these
25 stationary hubs to have mutual communication in Bosnia-Herzegovina, was
1 it necessary for them to resort to the hubs in Serbia, or rather, in the
2 Federal Republic of Yugoslavia?
3 A. Your Honour, Mr. Zorko, in order for a communications to exist
4 between two participants, there have to be two participants at two ends,
5 so each of these hubs could communicate with either of the others. There
6 was no need for them in Bosnia
7 want to or if this was not planned.
8 Q. Was a system like this in place between 1993 and 1995 as well as
10 A. Following the withdrawal of the JNA units, most of the stationary
11 communication hubs and communications centres remained outside Serbia
12 The damage to the communication lines varied.
13 Q. Thank you very much, Mr. Covilo. You also mentioned standby
14 communications, talking about the overall infrastructure. Can you
15 explain what that means, standby communication?
16 A. I'll try to be as brief as possible. We said that operating
17 communication lines were communication lines for peacetime conditions.
18 Standby communication lines are used when units go to certain areas based
19 on their deployment plans. This may be a situation of combat or an
20 emergency, such as an earthquake, floods, or anything like that. That
21 type is used whenever a unit leaves its peacetime assignment area.
22 Communication lines are organised depending on a unit's level from a
23 facility where their command is located, or mobile communication
25 Q. Is there any connection between these and the stationary
1 communication hubs? Can this in any way affect the quality or indeed the
2 density of communication lines?
3 A. There is a relation between the two, that much is certain. The
4 stationary communications system is part of this system, it is a
5 component of this system. A certain number of channels is only ever used
6 for operative units leaving their peacetime locations.
7 Q. Thank you very much, Mr. Covilo. Could you please in the
8 briefest of terms also explain what you mean by a mobile communications
10 A. A mobile communications centre is a centre normally set up in an
11 open area, on open ground, including communication units and equipment
12 borne by a transport vehicle, or mounted on a transport vehicle. This
13 begins at battalion level and goes all the way up to the Supreme Command
15 MR. ZORKO: [Interpretation] Another small intervention. Page 25,
16 line 12, the witness mentioned that there were connections between
17 stationary communication hubs and mobile communications centres. That
18 was not recorded. Page 25, line 12.
19 JUDGE MOLOTO: Yes, Mr. Zorko. Where you see that little cap,
20 the stenographer denotes that she is going to check that during the break
21 because she missed that and she's trying to keep up pace with us, so it
22 will be checked.
23 MR. ZORKO: [Interpretation] Thank you, thank you very much.
24 JUDGE MOLOTO: Now moving on to standby and mobile communication
25 hubs, what do you want to do with this exhibit on the screen? Those are
1 stationary ones.
2 MR. ZORKO: [Interpretation] At this point in time, I would like
3 to have this admitted into evidence and marked as an exhibit.
4 JUDGE MOLOTO: Thank you so much. It's admitted into evidence.
5 May it please be given an exhibit number.
6 THE REGISTRAR: Your Honours, this document shall be assigned
7 Exhibit D468 [Realtime transcript read in error "D648], this final
8 marking on the map.
9 JUDGE MOLOTO: Thank you.
10 MR. ZORKO: [Interpretation]
11 Q. Mr. Covilo, what exactly are command facilities and were there
12 any in the JNA?
13 A. Command facilities or installations are locations or buildings
14 from which certain groups exercise command over units subordinated to
15 them. A command facility or installation would normally be a fortified
16 one, very often an underground facility, where communications centres
17 were on standby. Normally it was the Supreme Command as well as certain
18 military district command that had certain facilities and installations.
19 If memory serves, in the case of the Zagreb military district, there was
20 a command post that was partially equipped, and this command post was at
21 Sl unj. As for the Sarajevo
22 somewhere in the broader area of Han Pijesak.
23 JUDGE MOLOTO: Just before we lose this page, I note that at page
24 26 line 15 that exhibit has been given D648 instead of D468. Let's just
25 make sure we correct that.
1 Okay. Thank you, Mr. Zorko, you may proceed.
2 MR. ZORKO: [Interpretation] Thank you, Your Honour.
3 Q. Mr. Covilo, what about the Supreme Command of the JNA; did it
4 have one or several command posts?
5 A. The Supreme Command, as the highest-ranking body in the military
6 forces of the country, had a number of different command posts. Its
7 principal command post was in the general Belgrade area. It was a
8 fortified underground installation. The next command post was in the
9 general Konjic area in Bosnia-Herzegovina. Likewise, this was a fully
10 equipped and fully fortified underground installation. There was a
11 reserve command post too in the Gorazde area. Another underground
12 facility but only partially equipped and fortified. There was also a
13 rear command post in the general Sarajevo
15 Q. Mr. Covilo, we have all these command posts, what were the links
16 between these? What sort of communications system did they have, and was
17 there communication between these command posts and other units?
18 A. Your Honours, Mr. Zorko, I'm somewhat worried that I might make
19 this a little too meticulous and detailed. I'll try to be as succinct as
20 I can. As I said, most of those installations had a full set of
21 communications equipment. For example, the one in Belgrade, in Konjic,
22 in part also the one in Sarajevo
23 standby communications equipment, which means that the systems could be
24 operated at any point in time and lines could be established and used by
25 the relevant command. These communication lines were established to lead
1 to each and every group in all of the military districts and there were
2 also links connecting the command posts between them.
3 MR. ZORKO: [Interpretation] Your Honours, I note the time. This
4 might be a good time for our break.
5 JUDGE MOLOTO: Thank you very much. We'll take a break and come
6 back at 4.00. Court adjourned.
7 --- Recess taken at 3.30 p.m.
8 --- On resuming at 4.00 p.m.
9 JUDGE MOLOTO: Mr. Zorko.
10 MR. ZORKO: [Interpretation] Thank you, Your Honour.
11 Q. Mr. Covilo, you are aware of the JNA withdrawal which took place
12 during a certain period of time and the latter formation of the VJ. Can
13 you tell us what happened in terms of the communications structure as it
14 existed in the JNA once it withdrew?
15 A. Your Honours, Mr. Zorko, in some of my previous answers, I stated
16 that the stationary communication hubs for the most part were located in
17 underground facilities and that the stationary communications centres
18 were located in the various garrisons representing the peacetime
19 locations of institutions and units. When JNA units withdrew, in most of
20 the cases communications equipment remained in those stationary centres.
21 As for the hubs, the stationary hubs, the equipment sustained greater or
22 lesser damage after the withdrawal of some parts of the equipment. The
23 stationary centres and hubs remained basically as such in the locations
24 where they had been.
25 Q. Thank you, Mr. Covilo. What happened with the equipment,
1 communications equipment, which was not in the stationary hubs and
3 A. When the JNA units withdrew, a certain amount of equipment was
4 withdrawn as well, especially regarding the mobile communications centre
5 as well as some equipment from the stationary communications centres.
6 However, most of the equipment remained in the locations where the JNA
7 had been.
8 Q. Thank you, Mr. Covilo. To your knowledge, who made use of the
9 existing infrastructure and systems you mentioned once the JNA withdrew?
10 A. To my knowledge, it would be difficult to answer, but it is my
11 guess that if most of the equipment remained, that equipment was then
12 used by the newly-established armed forces.
13 Q. Can you tell us what happened with the PTT communications system.
14 Was it still used for civilian purposes?
15 A. Each of the republics had an autonomous PTT system in place.
16 After our withdrawal, we no longer received information about those, but
17 I presume those systems were used for the needs of the population in
18 those republics, as well as partially, and I presume that, for the needs
19 of the newly-created armies in those areas.
20 Q. Mr. Covilo, what happened with the stationary communications
21 centre in Sarajevo
22 A. The stationary communications centre in Sarajevo was an enormous
23 one, given that it was centrally located in the country. I told you that
24 it even had a command post. Sarajevo
25 military presence, and in that single garrison there were several
1 communications centres. As far as I know, those centres remained in
2 operation to the extent possible. As far as I know, after the problems
3 the JNA had withdrawing its units from Sarajevo, it no longer had any
4 influence on the fate of those stationary communications centres because,
5 as we could see from the media, the JNA withdrawal from Sarajevo was a
6 difficult one.
7 Q. Do you know who used the Sarajevo
8 that is?
9 A. It's difficult for me to say since I was not familiar with the
10 disposition of forces in Sarajevo
11 well as the Serb side in certain parts, but I can't be any more specific.
12 Q. Thank you. In view of everything you have said so far, did the
13 JNA infrastructure and communications system -- could it enable the
14 functioning of an independent autonomous communications system in the
15 newly-created republics? Specifically I have in mind the armed forces of
18 A. Your Honours, Mr. Zorko, it is very difficult to give you a
19 specific detailed answer, but when we were marking the stationary
20 communications centres, we also mentioned there was a great many of them,
21 and given that, I can tell you with a high degree of certainty that the
22 existing communications system in Bosnia-Herzegovina was well developed,
23 including the PTT system, to the extent which made all of the
24 newly-formed armed forces with certain changes in terms of organisation,
25 it made it all possible for the armies to use those systems. The
1 situation in the area of the Serb Krajina was slightly worse because
2 there were fewer stationary communications centres because the number of
3 JNA units which had been stationed there was less.
4 As regards Croatia
5 and centres. In Slovenia
6 three stationary communications centres, and in terms of Slovenia
7 I believe it was sufficient for the armed forces of Slovenia, with
8 certain corrections and additions to the communications centres, could
9 use the existing infrastructure to set up their own communications
11 Q. Thank you, Mr. Covilo. When you marked the stationary
12 communication hubs, and that was on page 24 and lines 9 to 17, I asked
13 you about the extent of your knowledge, and I have a few more questions
14 about the system as it existed in the JNA.
15 Did the VRS have to use the stationary hubs in the Federal
16 Republic of Yugoslavia
17 system? And I would kindly ask to you speak slowly so that everything is
18 reflected in the transcript.
19 A. The number of hubs depends on the lie of land and whether the
20 facilities in question can be seen from the next such facility, as well
21 as whether the equipment located there was sufficient in any case. The
22 distance between two such hubs was not supposed to exceed 50 kilometres.
23 Each hub was independent and had two, three, or more radio relay routes.
24 All of the hubs together comprised the network and each of them was
1 As for any changes in the system, one needed to have a clear view
2 of the next facility and the distance should not have been greater than
3 50 kilometres.
4 Q. Mr. Covilo, I'd like to correct line 31 [as interpreted]. The
5 question was whether the Army of Republika Srpska had to use the
6 stationary hubs in the FRY in order to have a functioning communications
7 system. It is page 31, line 21. I will try to be more specific,
8 Mr. Covilo, and if possible, please answer with a yes or no.
9 A. No. The Army of Republika Srpska did not have to rely on the
10 stationary communication hubs in the FRY in order to have a functioning
11 communications system.
12 Q. Thank you, Mr. Covilo. Once the JNA withdrew its units, given
13 the structure you described, did such a complex infrastructure enable the
14 communication of the garrisons, for example, in Zagreb and Belgrade
15 A. I will go back to the maxim stating that if there is going to be
16 any communication, one needs to have two participants. In order to have
17 a communication line between Zagreb
18 functioning communications system in place and there must be a will, of
19 course, on both sides.
20 Q. I'll try to be even more specific, Mr. Covilo: Did such
21 communication exist during a certain period of time?
22 A. Yes.
23 Q. Can you tell us when exactly?
24 A. When JNA units were still in the area of Bosnia-Herzegovina,
25 because of the well-known developments in Croatia, even the PTT
1 communications system was disrupted. International forces also invested
2 great effort in order to achieve a truce in that area. In view of all
3 that, there was a need for a meeting between representatives of
5 As far as I recall, that meeting actually took place in Bosanski
6 Brod in mid- or late 1991. It was attended by a number of FRY
7 representatives, such as the representatives of the federal
8 telecommunications ministry, the representatives of the PTT, and of the
9 army. I represented the army on behalf of the communications
11 On the Croatian side there was the chief of communications of the
12 Croatian army, Mr. Sisper [phoen] and a PTT representative. It took
13 place under the auspices of a number of international representatives who
14 wanted us to agree on the establishment of a communications system in
15 order to ensure that the truce agreement was abided by, and it was a
16 topical issue at the time.
17 The PTT service on both sides, given that the PTT communications
18 system was disrupted, required that it be re-established. At that
19 meeting, no final agreement was reached. It was agreed, though, that the
20 implementation of that task was to be agreed upon during a next meeting
21 or a set of meetings which were supposed to take place in Croatian
22 territory. Specifically, Zadar was mentioned as well as Pecu, or Pec, in
24 The second meeting followed closely behind and the teams on both
25 sides were basically the same. That meeting took place in Slavonski
2 Q. Witness, I would like to interrupt you because the answer is
3 getting very long. What was the final result of that meeting?
4 A. The final result was the PTT sides agreed to try to get the
5 disrupted communications systems back up and running. As far as I
6 remember, that was the last time it ever got disrupted. As far as the
7 army is concerned, there was now a direct line between the operations
8 centre of the Main Staff of Croatia's army and the operations centre of
9 the General Staff.
10 Likewise, approval was granted to lower-ranking subordinate
11 commands to establish communication lines to their neighbours. The same
12 thing applied to the JNA, which was still in the area, and the Croatian
14 Q. Mr. Covilo, what became of the communications system in the JNA
15 following its withdrawal and the establishment of the VJ? Did it now set
16 up an independent and autonomous communications system? What exactly was
17 the case?
18 A. Indeed, the VJ, in order to meet its own needs, set up an
19 autonomous and independent communications system. For that purpose, it
20 used the existing infrastructure and made some minor additions. They
21 formed all of the communications centres in all the newly established
23 MR. ZORKO: [Interpretation] I apologise, intervention. Page
24 35, line 4, it should be "formed" and not "informed."
25 Q. Mr. Covilo, were any communication lines set up between the VJ
1 and the armed forces of any of the neighbouring countries, as far as you
2 are aware?
3 A. Yes. Although at the time I was no longer working in the
4 communications field. I am, however, aware of that, and that was the
6 MR. ZORKO: [Interpretation] 65 ter Defence document 00503, could
7 that be brought up on our screens, please.
8 THE REGISTRAR: Should there been extension D?
9 MR. ZORKO: [Interpretation] 00503D. I do apologise.
10 Q. Mr. Covilo, have a look, please. Could you please pay close
11 attention to paragraph 1. There is mention there of establishing a
12 direct communication line between the Hungarian anti-aircraft Defence
13 operation centre and the operation centre in Novi Sad. Would that be
14 consistent with the kind of communication lines that you had in mind?
15 A. Yes, that's right. It was necessary for both sides to be able to
16 use their air force with no hindrance. I remember that there was a
17 communication line established between the VJ and Hungary so that they
18 could each announce flights to the other side and avoid any violations of
19 each other's air-space.
20 MR. ZORKO: [Interpretation] I move that this document be
21 exhibited, please, and could we have a number for it, please. Thank you.
22 JUDGE MOLOTO: The document is admitted into evidence. May it
23 please be given an exhibit number.
24 THE REGISTRAR: Your Honours, this document shall be assigned
25 Exhibit D469. Thank you.
1 JUDGE MOLOTO: Thank you so much.
2 Yes, Mr. Zorko.
3 MR. ZORKO: [Interpretation]
4 Q. Mr. Covilo, apart from this example involving Hungary, did the VJ
5 establish any contacts with the armed forces of foreign countries in the
6 sense of promoting an already-existing communications system?
7 A. Of course it did.
8 Q. Could you please elaborate on that?
9 A. This applies to any country in the world. The consequences of
10 operations such as these would have led to certain results, let alone
12 It was necessary to improve our credibility in the world and also to
13 organise a more effective system through the VJ. In my case it had to do
14 with the communications system. As far as that is concerned, I know that
15 we organised visits to the armed forces of Romania, Greece
17 communications system and command and information systems.
18 If I may just digress. There was a very fruitful collaboration
19 with Romania
20 we had a joint drill that was held and communications centres were
21 jointly set up by the telecommunication units from Romania and
23 Q. Thank you very much, Mr. Covilo.
24 Following the establishment of the VJ, were there any
25 organisational changes that occurred in terms of how the communications
1 system worked in the VJ?
2 A. The army was established and underwent a transformation. The two
3 processes were mutually dependent.
4 Q. Could you please repeat your answer. I think there is a problem
5 here. Could you please repeat. I think there's a problem here.
6 A. My answer was the VJ was established and its transformation
7 began. Of course, once the transformation was underway, one needed to
8 also transform the communications system.
9 Q. What exactly did this transformation of the communications system
11 A. Above all, the transformation implied new communications being
12 established in the newly-established garrisons. As well as
13 implementation of new instructions and rules that concerned this
14 organisation. Perhaps I should also say that organisational
15 informational changes were also made to communications units.
16 MR. ZORKO: [Interpretation] Could we please have Defence 65 ter
17 Exhibit 01057D. I think it is page 3 in the B/C/S, or perhaps we should
18 remain on page 1.
19 Q. Item 3, Mr. Covilo, please.
20 A. Yes, I've read it.
21 Q. Could you please comment briefly.
22 A. This is a very specific answer to the previous question. There
23 were some changes that occurred and, because of these changes, the army
24 had to adapt. That applied to communications units as well. The
25 training centre EI 5 for electronic surveillance and anti-electronic
1 activities was established. This shows that the army had limited
2 resources and that this was established at the expense of other
4 Paragraph 2. The stationary communication hubs were to be kept
5 under the jurisdiction of the communications administration. Throughout
6 that period in time a special centre was set up, the 235th communications
7 centre, which now unified all of the communications centres in the FRY.
8 This was also the one major organisational informational change that
9 occurred to the structure of communications units throughout the army.
10 Q. Mr. Covilo, let me ask you a simple question: Does that mean
11 that the transformation or the establishment of the VJ caused new
12 structures to arise in terms of what type of communications system was
13 being used for the VJ's purposes?
14 A. Yes, new structures, needless to say, nevertheless using an
15 already existing infrastructure.
16 Q. Very well, thank you. Mr. Covilo, you say there existed a very
17 elaborate communications system in the former Yugoslavia. Given the
18 elaborate nature of this system, was there any form of protection in the
19 VJ that was used to protect the system?
20 A. Let me say at the outset that I'm no specialist in encryption
21 myself. As a communications planner, I had to know what routes were to
22 be protected by what means. The JNA communications system was protected
23 by a written unspoken protection system at lower tactical levels and as
24 far as general command documents were concerned.
25 Q. You mentioned the JNA in your answer, Mr. Covilo, and I want to
1 know about the VJ. Was there a protection or encryption system in the
2 VJ, and did you mean the VJ and said the JNA? Did you perhaps misspeak?
3 A. The principle was similar, nevertheless there were some
4 peculiarities. This is a very peculiar field. Each army has peculiar
5 methods of protection. It was by default that once the army had been
6 established there had to be some sort of discontinuity in relation to the
7 previous protection system.
8 Q. Very well, thank you. Mr. Covilo, while you were working on the
9 General Staff of the VJ, did you know that demands were being made by the
10 Serbian Army of Krajina and the VRS in relation to certain pieces of
11 communication equipment in the VJ's possession?
12 A. Your Honours, Mr. Zorko. Given that the fact that I attended
13 some collegium meetings of the assistant commander of the General Staff
14 for communications, information technology and electronic activity, the
15 meeting also attended by heads of administrations, as a tactical agent, I
16 know that certain requests were made for certain equipment above all
17 certain pieces of communication equipment.
18 THE INTERPRETER: Microphone, please.
19 MR. ZORKO: [Interpretation]
20 Q. Mr. Covilo, for the purposes of the transcript, could you please
21 slow down a little. We are having some trouble recording what you are
22 saying, therefore please bear in mind the pace of your answers.
23 A. Thank you.
24 MR. ZORKO: [Interpretation] Could the witness please be shown OTP
25 Exhibit P1812.
1 JUDGE MOLOTO: Before you call that one, Mr. Zorko, what do you
2 intend doing with 1057D?
3 THE INTERPRETER: Microphone, please.
4 JUDGE MOLOTO: Microphone, Mr. Zorko.
5 MR. ZORKO: [Interpretation] I apologise, Your Honour. I do move
6 that this document be exhibited. Thank you.
7 JUDGE MOLOTO: It is admitted. May it please be given an exhibit
9 THE REGISTRAR: Your Honours, this document shall be assigned
10 Exhibit D470. Thank you.
11 JUDGE MOLOTO: Thank you, Mr. Zorko. Now, what do you want to
12 call, Mr. Zorko?
13 MR. ZORKO: [Interpretation] Your Honours, OTP Exhibit P1812.
14 Q. Mr. Covilo, have a look, please, and tell us what sort of
15 equipment it talks about. Could you briefly explain what type of
16 equipment we are looking at here.
17 A. Your Honours, Mr. Zorko, this is one of the documents where
18 certain pieces of equipment were approved. As far as I can tell, these
19 are types of equipment for the most part no longer being used by the VJ.
20 The first one is a radio device, AN/GRC-9, it's an old American radio
21 used at battalion and platoon level. And no longer used in the VJ.
22 RUP-12 was used in the VJ. Radio device PRC-147, same purpose as the
23 first one, AN/GRC-9, for the most part no longer used in the VJ.
24 Telephone PTI-49, that's an old telephone first produced in 1949. It was
25 superseded by M-63. I'm not aware of a single instance of this type of
1 phone being used by the VJ. The telephone switchboard, there were newer
2 types, IT C-10, I don't know if it was used by the VJ, but I don't think
4 The PTK cable cord was used, the cord reel as well. UN AF device
5 11, 12, 13, 14, old devices used for permanent air routes. I can't say
6 with certainty whether these were used or not, but I think not, not in
7 the VJ.
8 MR. ZORKO: [Interpretation] Thank you, Mr. Covilo. Can the
9 witness please be shown Exhibit P1813.
10 Q. Mr. Covilo, take a look at the document and I'll ask for your
11 comments on the equipment contained therein.
12 A. Yes. The situation is similar to the one in the earlier
13 document. For the most part these are outdated devices that were used
14 rarely or not at all in that the last device listed here are UFM-200 is a
15 device that was used in the VJ but there was a shortage of them.
16 Q. Mr. Covilo --
17 JUDGE MOLOTO: Somehow I'm getting lost. Some names are being
18 called which I don't see on the screen. Like this very last one,
19 UFM-200. Am I looking at the right document?
20 MR. ZORKO: [Interpretation] If I may be of assistance, Your
21 Honour, this is on page 2 of the English version. Thank you, Your
23 Q. Mr. Covilo, generally speaking --
24 JUDGE MOLOTO: I am sorry, Mr. Zorko. Even on page 2 we don't
25 see UFM-200, we see RRU FM-12. This has been even the previous document
1 I had that problem, but I let it pass.
2 MR. ZORKO: [Interpretation]
3 Q. Mr. Covilo, please have a look at the last item listed in the
4 document before you. Can you please repeat your answer in reference to
5 that device. Which is it?
6 A. This is the radio relay device FM-200. RRU-800 is the one that
7 falls into the same category. This device was used for protected radio
8 relay lines.
9 Q. I do see that there's a difference between the two versions. The
10 English translation states "FM-12" in the last line, whereas the original
11 text in the B/C/S reads "FM-200," and it says at the very end "two
12 pieces." So there's an error in the translation there.
13 JUDGE MOLOTO: In fact, as I say, I had the same problem with
14 P1812. So I would request that those two exhibits be checked, the
15 translations be checked.
16 [Trial Chamber and Registrar confer]
17 JUDGE MOLOTO: I'm advised that they are MFI'd pending correct
18 translations, both of them. Maybe when you call them up, call them MFI
19 so that we know what is MFI'd and what is not MFI'd.
20 MR. ZORKO: [Interpretation] Thank you, Your Honour.
21 JUDGE MOLOTO: Thank you.
22 MR. ZORKO: [Interpretation]
23 Q. Mr. Covilo, if any requests came from the Serbian Army of Krajina
24 or the VRS to your administration, what sort of response was there?
25 A. Let me just correct you, Mr. Zorko, that I was in the department
1 for communications, IT, and electronic warfare and --
2 MR. THOMAS: Objection, Your Honours.
3 THE WITNESS: [Interpretation] -- the requests mostly came from
4 heads of administration --
5 MR. THOMAS: I do not believe, sir, that my learned friend has
6 laid a foundation for that question. He asked Mr. Covilo about requests
7 from the VRS and SVK, and Mr. Covilo said that, on the basis of collegium
8 meetings that he was able to attend, he was aware of some requests. So
9 unless he is able to lay a fuller foundation, he cannot put to Mr. Covilo
10 on the basis of the existing foundation what the general practice may or
11 may not have been, because as I understand Mr. Covilo's testimony, it is
12 that his knowledge of this comes from the isolated collegium sessions
13 that he attended.
14 JUDGE MOLOTO: Mr. Zorko.
15 MR. ZORKO: [Interpretation] Thank you. Your Honour, I will take
16 this from a different angle.
17 Q. Mr. Covilo, how often did the collegiums you referred to meet?
18 A. Once a week.
19 Q. Did you attend these collegium meetings?
20 A. Yes, I attended them at all times.
21 Q. Did the collegium meetings discuss, among other things, the issue
22 of requests for material assistance coming from the SVK and VRS?
23 A. Yes, whenever there were any such requests to be discussed.
24 MR. THOMAS: Your Honour, that's fine. That's sufficient
25 foundation for me.
1 THE INTERPRETER: Microphone.
2 MR. ZORKO: [Interpretation] I thank my learned friend. Thank
3 you, Your Honours.
4 Can the witness be shown Prosecution Exhibit P874.
5 JUDGE MOLOTO: Is it MFI or is it admitted?
6 THE REGISTRAR: It is exhibit, if I may be of some assistance.
7 JUDGE MOLOTO: Thank you, Mr. Registrar.
8 MR. ZORKO: [Interpretation]
9 Q. Mr. Covilo, take a look at the document. Can you give us your
10 comments which have to do with my earlier question; i.e., what was the
11 prevalent view that your administration or actually your sector took in
12 relation to such requests?
13 A. Your Honours, Mr. Zorko, I will give you the briefest of answers.
14 The position that the sector took was to approve such requests
15 restrictively insofar as there were assets available within the VJ.
16 Specifically, in this particular case in point we can see that the
17 tactical agents, i.e., the chief of the administration, is directly
18 addressing the office of the chief and informs them that it was not
19 possible to meet the request. In this particular instance, this request
20 was not discussed at the collegium meeting.
21 Q. I apologise, Mr. Covilo, but there's a problem with the
22 transcript again and could you repeat your answer. Because I think
23 there's a sentence that needs to be clarified.
24 A. Your Honour, Mr. Zorko, the position of the sector for
25 communications, IT, and electronic warfare was to grant these assets, to
1 approve these requests restrictively. This because the VJ did not have
2 assets in stock and the prevalent practice was that such assets were not
3 purchased or provided. As I said, in this particular piece of evidence,
4 as you call it, we can see that, probably for reasons of urgency, the
5 tactical agent concerned is directly addressing the office of the Chief
6 of the General Staff, informing him that he was unable to grant the
7 requested assets.
8 Q. Thank you, Mr. Covilo. What does maintenance of communication
9 devices in the VJ imply?
10 A. Maintenance of all assets, and particularly those that were in
11 use by various units, implied that such assets should be kept operational
12 at all times, and this falls within the purview of the technical
14 Q. Maintenance of communications assets in the VJ, was it subject to
15 some sort of standard procedure as to how it was dealt with?
16 A. Well, yes. All the armies have a standard procedure in place for
17 that. From the duties to be discharged by those operating the devices,
18 they need to check whether the assets are in order, all the way through
19 to the bodies that are set up which contain experts who are there to make
20 sure that the equipment is in order.
21 Q. Is it an activity of any continuity?
22 A. Of course it is.
23 Q. Does maintaining communications assets in the VJ refer to all the
24 communications equipment held by that army?
25 A. All the material and technical equipment, including the
1 communications assets, according to the instructions issued by the
2 technical administration, do have to be checked periodically. I don't
3 know what the period is. I have to say that there is a certain number of
4 working hours involved, and whenever that amount of hours is used up,
5 that's to say the piece of equipment has been used for such and such a
6 number of hours, it has to go and be officially checked.
7 Q. Thank you. Mr. Covilo, during your time in the General Staff of
8 the VJ did you ever hear of the plan called "Drina"?
9 A. No. As of 1992 I was no longer dealing with communications plans
10 and I was no longer privy to any plans for their use.
11 Q. Did you, during your service, see any other documents which had
12 to do with this particular plan?
13 A. No.
14 MR. ZORKO: [Interpretation] Can we call up Prosecution Exhibit
15 P1564. It doesn't have --
16 THE INTERPRETER: Microphone, please.
17 JUDGE MOLOTO: Microphone, Mr. Zorko.
18 MR. ZORKO: [Interpretation] Can we first turn to page 2, both in
19 Serbian and English.
20 JUDGE MOLOTO: You were going to tell us that it doesn't have
21 something, which you didn't complete, Mr. Zorko. What did you want to
22 say, it doesn't have what?
23 MR. ZORKO: [Interpretation] What I wanted to say was that it
24 wasn't an MFI'd document, but my microphone was switched off, so ...
25 It's an exhibit.
1 Q. Mr. Covilo --
2 MR. ZORKO: [Interpretation] Or rather, can we have page 2 of both
3 versions on our screens.
4 Q. I would like to have your comments on what you see on your
5 screen. Is there anything in particular that you note on this page?
6 A. Your Honours, Mr. Zorko, what I see is a list of documents
7 pertaining to the communications plan Drina, which was drawn up pursuant
8 to instructions concerning communications. I don't know why. It does
9 have a stamp but it doesn't bear a signature, which it normally would, of
10 both those who handed it over and received it.
11 Q. Thank you.
12 MR. ZORKO: [Interpretation] Could we turn to page 6 in the B/C/S
14 JUDGE MOLOTO: Before we do that, the witness is telling us by
15 reading from the B/C/S that these are communications items plan of the
17 look like it's the first page. It has no heading.
18 MR. ZORKO: [Interpretation] This is page 2 in English. My
20 JUDGE MOLOTO: It starts with number 1, Communications Order
21 number 1, 3, which seems to be the same entry in B/C/S. Then number 2,
22 radio communications schematic 1, 1. Looks like it's the same page, but
23 we don't have a heading.
24 MR. ZORKO: [Interpretation] Could we please go to page 1 in both
25 languages in order to see what document we are dealing with. Could we
1 please have page 2 in both next.
2 JUDGE MOLOTO: We have seen the word "Drina." Thank you so much.
3 MR. ZORKO: [Interpretation] Thank you, Your Honours.
4 Q. Mr. Covilo, what can you tell us about the fact that there is no
5 signature on this page?
6 MR. THOMAS: Objection.
7 JUDGE MOLOTO: [Overlapping speakers] ...
8 MR. THOMAS: Objection, Your Honours. That calls for
9 speculation. The plan is dated November 1993. Mr. Covilo has already
10 explained to us that from 1992 he would have not been in a position where
11 he would have been privy to such a plan. He has been showed one page of
12 the document and now he is being asked to speculate on how it may or may
13 not have been created.
14 JUDGE MOLOTO: That is true except that I thought in a previous
15 answer he did refer to the fact that it is unsigned and did try to
16 mention what he makes of that, but was -- may have been interrupted. I'm
17 trying to look -- okay. If you look at page 47, starting at line 7:
18 "Your Honours, Mr. Zorko, what I see is a list of documents
19 pertaining to the communications plan Drina which was drawn up pursuant
20 to instructions concerning communications. I don't know why it does have
21 a stamp but it doesn't bear a signature, which it normally would, of both
22 those who handed it over and received it."
23 MR. THOMAS: Yes, sir.
24 JUDGE MOLOTO: That was an unsolicited answer.
25 MR. THOMAS: Yes, but what I understand he is now being asked at
1 page 48, line 5, is to explain the fact that there is no signature on the
2 document or to -- well, that's one interpretation of the question.
3 JUDGE MOLOTO: The other interpretation is you've told us that it
4 should normally have a signature, what does it mean even if it doesn't
5 have a signature; what is the effect?
6 MR. THOMAS: Then that's how the question should be framed, Your
8 JUDGE MOLOTO: Okay. Mr. Zorko.
9 MR. ZORKO: [Interpretation] Thank you, Your Honour. And another
10 thank you goes to my learned friend. I'll more or less repeat my
12 Q. Mr. Covilo, what does the fact that there's no signature here
13 tell you?
14 A. To couch it in the mildest possible terms, it tells me there was
15 no compliance on how communication documents should be compiled. The
16 normal procedure during a hand-over of a document like this would be to
17 have a signature of both the sender and the recipient.
18 MR. ZORKO: [Interpretation] Could the witness now please be shown
19 page 6 in the B/C/S and page 6 in the English as well.
20 Q. Mr. Covilo, you see a diagram there. It's much clearer in the
22 JUDGE MOLOTO: Do I take it we don't have it in the English, this
23 diagram, with the annotations in English?
24 [Trial Chamber and Registrar confer]
25 THE REGISTRAR: The diagram should be at English page number 7.
1 Thank you.
2 MR. ZORKO: [Interpretation] My apologies. This is only the lower
3 part, but we don't have the upper portion of the diagram. We will press
4 on no matter what.
5 Q. Mr. Covilo, based on your knowledge, was a communications system
6 like this established in the VJ, and what can you tell us about this
8 A. Your Honours, Mr. Zorko, what I can tell is this: This is a
9 perfectly standard diagram compiled in keeping with the documents setting
10 out the rules for communications system. It's difficult to specify
11 anything else. I'm not sure if this is out of its proper context or
12 whatever, I'm not sure why the Drina
13 had no chance to see for myself whether this communications system
14 specifically ever got off the ground or not.
15 Q. Thank you very much, Mr. Covilo.
16 MR. ZORKO: [Interpretation] I'm done with this document.
17 Mr. Covilo, we'll be showing you another document. This is an OTP
18 document, P2622, please. Thank you. It's not an MFI'd document.
19 JUDGE MOLOTO: P?
20 MR. ZORKO: [Interpretation] 2622, Your Honours. Your Honours, we
21 are facing some minor e-court problems right now.
22 JUDGE MOLOTO: And what is the nature of --
23 MR. ZORKO: [Interpretation] I'm not sure if perhaps ...
24 [Trial Chamber and Registrar confer]
25 THE INTERPRETER: The interpreter didn't hear the counsel.
1 THE WITNESS: [Interpretation] Yes, I do.
2 MR. ZORKO: [Interpretation]
3 Q. Have you read the document?
4 A. Yes, I have.
5 Q. Mr. Covilo, at the time of this document, did the VJ have an
6 evolved command and communications system?
7 A. No, there was information support but it didn't have a command
8 and communications system that was evolved.
9 Q. Do you know when the VJ eventually developed one?
10 A. If memory serves, it wasn't until after 1995. There was an
11 experimental development of the command and communications system. I
12 remember the Assistant Chief of General Staff for communications,
13 information technology, and electronic activity was late Colonel Zugec
14 [Realtime transcript read in error "General Djukic"] --
15 JUDGE MOLOTO: Slow down.
16 THE WITNESS: [Interpretation] Sometime after 1995.
17 JUDGE MOLOTO: But slow down, sir. The interpreter was running
18 at a thousand miles trying to keep up pace with you.
19 THE WITNESS: [Interpretation] I apologise. I'll try to make sure
20 I don't do that again.
21 MR. ZORKO: [Interpretation] Your Honours, I believe we are
22 talking about the command and information system and again we have a
23 small problem with the interpretation. I'll repeat my question.
24 Q. If you look at this text, Mr. Covilo, it talks about the
25 development of a command and information system. Is that the system that
1 you had in mind a minute ago?
2 A. Yes. Command, control, communication, and reconnaissance.
3 Q. All of these are elements of the system you are talking about?
4 A. Yes.
5 Q. Thank you very much, Mr. Covilo.
6 MR. ZORKO: [Interpretation] The document is no longer required.
7 Thank you. Again intervention, Your Honours, line 51 -- page 51, line
8 14, General Djukic was mentioned although the witness in fact never
9 mentioned a General Djukic.
10 JUDGE MOLOTO: Thank you, Mr. Zorko.
11 THE INTERPRETER: Microphone for the President, please.
12 JUDGE MOLOTO: Thank you, Mr. Zorko. I'm very sorry. I believe
13 that is corrected.
14 MR. ZORKO: [Interpretation]
15 Q. Mr. Covilo, do you know that at one point in time the FRY
16 introduced or imposed sanctions on the Republika Srpska?
17 A. Yes. All the people of the FRY knew about that because it was
18 something that was published in the media.
19 Q. Do you know about the exact point in time the sanctions were
20 imposed, and when did they take effect?
21 A. I believe sometime in late 1994. I hope I'm not mistaken.
22 Q. Thank you very much, Mr. Covilo. What about this very fact, the
23 fact that the sanctions were imposed? Did that in any way affect the
24 existing communication lines to Republika Srpska?
25 A. Yes.
1 Q. In what way? Please explain.
2 A. I remember a collegium meeting with the assistant commander of
3 the General Staff for the communication, information technology, and
4 electronic activity. When he came back from a meeting with the Chief of
5 the General Staff, he conveyed an order to the chief of the
6 communications administration. The order said that all communication was
7 to cease to the VRS.
8 Q. Just to be perfectly clear, whose order was that about severing
9 communication lines?
10 A. The chief of the General Staff, Mr. Momcilo Perisic, issued an
11 order to the assistant, General Obradovic, the assistant of the chief of
12 the communication, information technology, and electronic activity
13 administration, and he issued the order or conveyed to Mr. Zelkovic, the
14 chief of the communication administration, and who Perisic got the order
15 from, I don't know.
16 MR. ZORKO: [Interpretation] Thank you, very much. Your Honours,
17 I have no further questions for this witness. This might be a convenient
18 time for our break.
19 JUDGE MOLOTO: Thank you very much. It is indeed. We'll take a
20 break and come back at quarter to 6.00. Court adjourned.
21 --- Recess taken at 5.14 p.m.
22 --- On resuming at 5.44 p.m.
23 JUDGE MOLOTO: Mr. Thomas.
24 MR. THOMAS: Thank you, Your Honours.
25 Cross-examination by Mr. Thomas:
1 Q. Mr. Covilo, good afternoon. My name is Barney Thomas. I'm a
2 lawyer with the Prosecution. I'm sure my friend Mr. Zorko has explained
3 this to you already but what happens now, sir, is I have an opportunity
4 to ask you some questions about the testimony that you have given this
5 afternoon. I can tell you now that we won't be keeping you long, sir. I
6 don't have a lot of questions for you. But what I do ask is that,
7 please, you listen to my questions carefully, answer only the question
8 that I have asked you. If there is anything about my question which you
9 do not understand, please say so and I'll rephrase my question or
10 otherwise deal with the difficulty that we have. Is that clear enough,
12 A. It is, thank you, sir.
13 Q. Sir, at the beginning of your testimony this afternoon, you spoke
14 about how you were sent to the area of Mostar to assist in the
15 reinstatement of PTT systems and several municipalities. Do you recall
16 that testimony?
17 A. Yes. To the Bileca area specifically, not Mostar.
18 Q. The transcript isn't quite complete, but you referred to being
19 sent to Bileca, Trebinje, and Gacko to work on the PTT systems. Are
20 those municipalities correct?
21 A. Yes. Trebinje, Bileca, Nevesinje, and Gacko.
22 Q. At the time that you travelled and worked in those
23 municipalities, those had already been taken by the VRS, hadn't they?
24 A. That's right. When I arrived, the JNA was there and later the
25 VRS came.
1 Q. All right. Later on in your testimony, sir, you spoke about
2 radio relay communications, and I wish to explore that issue with you
3 just for a few moments.
4 We know from your testimony that at the time of the JNA
5 withdrawal, there were radio relay stations located throughout each of
6 the republics; well, specifically, Croatia, Bosnia, and Serbia
7 A. Yes.
8 Q. And in talking about the ability of the VRS to conduct its
9 communications without needing to rely on VJ communications structure,
10 you mentioned that there would not be a need for the VRS to use any radio
11 relay stations that were located in Serbia. Do you recall that
12 statement, sir?
13 A. Yes. It had involved infrastructure of both the stationary
14 communication hubs and centres. And a total of five command facilities.
15 Q. Now, the ability of one unit to communicate with another is
16 dependent upon, amongst other things, whether or not they have a direct
17 line of sight to a radio relay station, and the range of that radio relay
18 station; is that right?
19 A. Yes, that's right. In terms of radio relay, in addition to an
20 open line of sight, the distance should not exceed 50 kilometres.
21 Q. Would you accept, sir, that depending on where a unit of the VRS
22 was garrisoned, radio relay communication, for example, with the Main
23 Staff of the VRS, may have to be routed through communication centres
24 located on the territory of the FRY? Would you accept that that was
25 sometimes necessary?
1 A. As far as I'm --
2 JUDGE MOLOTO: Just a second, Mr. Covilo. Yes, Mr. Zorko.
3 MR. ZORKO: [Interpretation] Your Honours, I'm looking at the
4 question and I see a rather broad approach, asking the witness to
5 speculate. The witness is being asked to speculate because we don't know
6 where specifically this unit that my learned friend is referring to is
7 supposed to be located. We don't know about the distance involved. I
8 think this question can hardly be answered without speculating.
9 JUDGE MOLOTO: Mr. Thomas.
10 MR. THOMAS: The witness has stated, sir, that there would be no
11 need for VRS units to resort to FRY radio relay stations, and I'm asking
12 him whether he can exclude the possibility of that being necessary,
13 depending on the location of a unit. I'm asking him to qualify his
14 earlier unequivocal statement, sir, or at least giving him the
15 opportunity to qualify his earlier unequivocal statement.
16 JUDGE MOLOTO: Except in that if he has already said there would
17 be no need, he has said there would be no need. Maybe you might confront
18 him with a specific situation where it did happen.
19 MR. THOMAS: I can do that, sir.
20 Q. General, where were the Eastern Bosnian Corps of the VRS
22 A. Your Honours, Mr. Prosecutor, I'm not fully familiar with the
23 deployment of the forces of the VRS. As far as I know, that location
24 would be somewhere in the Bijeljina sector.
25 Q. All right. Let's deal with Bijeljina for the moment. Where was
1 the Main Staff of the VRS located?
2 A. As far as I know, in the general Han Pijesak area.
3 Q. And which was the main communications hub that was used by the
4 VRS Main Staff?
5 A. The main hub was at Veliki Zep.
6 Q. If the Main Staff of the VRS wished to communicate with the
7 eastern -- no, if the Main
8 the unit garrisoned at Bijeljina, what would be the radio relay route?
9 MR. ZORKO: [Interpretation] Your Honour.
10 JUDGE MOLOTO: Yes, Mr. Zorko.
11 MR. ZORKO: [Interpretation] Your Honours, again I think the
12 witness is being asked to speculate as to how a certain unit, in this
13 case the Main Staff of the VRS, would establish a line of communication
14 with another unit. The witness was never a member of the VRS and he is
15 being asked to address matters that he is not directly familiar with.
16 Therefore, I think this is another case of asking the witness to
18 JUDGE MOLOTO: Mr. Thomas.
19 MR. THOMAS: With respect, Your Honour, the witness has been
20 called, amongst other things, to talk about the location of the radio
21 relay communications centres, how they operated before the break-up,
22 where they were positioned after the break-up. He has given testimony
23 that they could -- that the VRS could communicate without resorting to
24 any communications centres in the FRY, I'm being very specific now of
25 giving him an example of radio relay communications between the hub of
1 the Main
2 JUDGE MOLOTO: Yes, Mr. Zorko.
3 MR. ZORKO: [Interpretation] I do apologise, Your Honours, if I
4 may be of assistance. Mr. Covilo was never involved with VRS
5 communications systemS, and my learned friend is asking him to answer a
6 question that directly addresses something that he could only ever know
7 if he was involved with the systems. The witness is still being asked to
8 speculate from where I stand, therefore I stand by my objection, Your
10 JUDGE MOLOTO: You see, I hear what you say, but the problem is
11 that Mr. Covilo said the VRS -- and I'm relying on Mr. Thomas's
12 characterisation of the evidence, I don't remember this from --
13 independently. He says the VRS would not need, would never need to use
14 the FRY communication system, which would be different from saying they
15 did not use it. So if he says they would never need and he claims to
16 have certain knowledge of why they wouldn't need to do so, on that basis
17 assuming that you are nodding of the head together with madam next to
18 you, suggests that you agree with that characterization of the evidence.
19 MR. THOMAS: Thank you, Your Honour.
20 JUDGE MOLOTO: Thank you. Let me just rule formally for the
21 record. Then the objection is overruled.
22 MR. THOMAS: Thank you, Your Honours.
23 Q. Mr. Covilo, let me just repeat my question for you. If the Main
24 Staff of the VRS wish to communicate with a unit garrisoned at Bijeljina,
25 what would be the radio relay route?
1 A. Your Honours, Mr. Prosecutor, I'd be hard put to remember the
2 exact radio relay route. Nevertheless, what I can tell you is this:
3 Take any route you like along radio relay line. One could set up two or
4 three radio relay stations, meaning if you want to have a line from point
5 A to point B, the distance could be as much as 150 kilometres. Now,
6 between Bijeljina and Veliki Zep, I don't think the distance is that
8 Q. Would you accept, sir, that communications between Bijeljina and
9 Veliki Zep pass through the Cer communications centre? Do you accept
11 A. I really don't know, Your Honours.
12 Q. Well, see, the difficulty, Mr. Covilo, is that you gave what
13 appeared to be an unequivocal statement, that statement being that they
14 would not need to resort to any radio communications or radio relay
15 towers on the territory of Serbia
16 I'm giving you the opportunity to qualify that statement, if you wish.
17 Would you accept that it's entirely possible, given the location
18 of units, that they needed to resort to radio relay communications
19 passing through radio relay stations situated on the territory of the
20 FRY? Would you accept that as a possibility?
21 A. Yes, I would. I'm in no position to rule that out, the fact that
22 there was a simpler way of establishing a line of communication.
23 Q. So if there was testimony to that effect from other Defence
24 witnesses, you wouldn't challenge that testimony?
25 A. I don't see why I would. I really don't know what sort of
1 communication line was set up. I do stand by the fact that -- which I
2 said before, and that's that had I been a VRS commander, I would have
3 easily organised a communications system of the VRS without resorting to
4 the hubs in Serbia
5 doing this rather than going through Cer.
6 Q. So do I understand your position to be, sir, that in theory it
7 could be done? In other words, communications could be established
8 without needing to route them through Cer or through Crni Vrh or through
9 Strazbenica but you can't say with any degree of certainty whether in
10 practice those radio relay stations were indeed avoided? Is that a fair
11 characterization of your position?
12 JUDGE MOLOTO: Yes, Mr. Zorko.
13 MR. ZORKO: [Interpretation] Your Honour, I still maintain that
14 the witness is called to speculate, and I think that witness answered on
15 page 59, line 23, that he didn't really know ...
16 JUDGE MOLOTO: Are you done, Mr. Zorko?
17 MR. ZORKO: [Interpretation] Yes, I am, Your Honour. That's it.
18 JUDGE MOLOTO: Mr. Thomas.
19 MR. THOMAS: Sir, at page 60, line 13, the witness has said:
20 "I don't really know what sort of communication line was set up.
21 I do stand by the fact that which I said before --" which he didn't say,
22 but -- "which I said before and that's that had I been a VRS commander, I
23 would have easily organised a communications system of the VRS without
24 resorting to the hubs in Serbia
25 simpler routes of doing this rather than going through Cer."
1 So given that answer, sir, what I'm trying to do now is to get
2 him to commit to a position. If his position is that his answer is
3 limited to what could be done in theory and that he can't really speak
4 about what was actually done by the VRS commanders in practice, then
5 that's something we need to know.
6 JUDGE MOLOTO: I think that would be allowed.
7 THE WITNESS: [Interpretation] Yes, Mr. Prosecutor, there did
8 exist a technical possibility for communications to be set up only on the
9 side of the VRS, and there also existed the technical possibility to use
10 communications hubs of the Army of Yugoslavia.
11 MR. THOMAS:
12 Q. And as far as whether the VRS commanders actually used
13 communications hubs on the territory of the FRY, is it true that you
14 can't tell us? You can't be certain yourself whether they did or they
15 didn't? Is that your position?
16 A. Yes, that's my position. At this time I was not privy to the
17 communications system used either by the Army of Yugoslavia or the army
18 -- or the VRS.
19 MR. THOMAS: Mr. Covilo, thank you. Your Honours, that concludes
20 my cross-examination.
21 JUDGE MOLOTO: Thank you very much, Mr. Thomas.
22 Mr. Zorko, any re-examination?
23 Re-examination by Mr. Zorko:
24 MR. ZORKO: [Interpretation] I have to make a clarification for
25 the transcript. In -- on page 62, line 3, you said that you were not
1 privy to the communications system used either by the Army of Yugoslavia
2 or by the Army of Republika Srpska. Is really the Army of Yugoslavia of
3 what you have in mind? I wasn't sure whether that was a mistake.
4 A. Yes, the army of Yugoslavia
5 Q. Can you explain what you meant by this?
6 A. What I meant was that at that time I was not a communications
7 planner and it was not within my duties to go into any details and to see
8 where the various radio relay routes had been organised, and to see
9 whether possibly any of the communication hubs was placed at the disposal
10 of someone for a stretch of these routes. What I can tell you is that at
11 no point in time was access or entry to the communications system of the
12 VJ allowed, which doesn't mean to say that a communications hub could not
13 have been used as an intermediary radio relay station to ensure
14 communication that went further. In that case, a hub would be used as a
15 passageway, really, like in the case of somebody being allowed to use
16 someone else's meadow.
17 MR. ZORKO: [Interpretation] Thank you, Your Honours. I have no
18 further questions.
19 JUDGE MOLOTO: Just one question.
20 Questioned by the Court:
21 JUDGE MOLOTO: When you say at that time -- you say, What I meant
22 was that at that time I was not a communications planner. Which time
23 specifically are you referring to here?
24 A. I'm referring to the period starting with August of 1992.
25 JUDGE MOLOTO: Until?
1 A. Until the end of my professional service with the Army of
3 JUDGE MOLOTO: If you could just remind us, when was that?
4 A. I don't understand, Mr. President.
5 JUDGE MOLOTO: When was the end of your professional service with
6 the Army of Yugoslavia
7 A. In 1999 I was assigned or transferred to the Ministry of Defence
8 to work within the PTT system as director of the sector for defence
9 preparations. And in December 2003, I retired.
10 JUDGE MOLOTO: Thank you. So until December 2003, that's the
11 short answer?
12 A. Yes, yes.
13 JUDGE MOLOTO: Thank you very much, then, Mr. Covilo. This
14 brings us to the conclusion of your -- I beg your pardon. I am sorry, we
15 haven't reached that stage. Any questions arising from the questions by
16 the Bench? Mr. Zorko?
17 MR. ZORKO: [Interpretation] No, Your Honour, thank you.
18 MR. THOMAS: No, sir, thank you.
19 JUDGE MOLOTO: Then that brings us to the end of your testimony
20 for the day. Thank you so much for taking the time off to come and
21 testify at the tribunal. You are now excused, you may stand down, and
22 please travel well back home.
23 THE WITNESS: [Interpretation] Thank you, Mr. President. I thank
24 the Trial Chamber for allowing me to give my testimony.
25 [The witness withdrew]
1 JUDGE MOLOTO: Mr. Zorko.
2 MR. ZORKO: [Interpretation] Your Honour, I would like to give the
3 floor to Mr. Guy-Smith. Thank you.
4 JUDGE MOLOTO: Mr. Guy-Smith.
5 MR. GUY-SMITH: Yes, Your Honour, that would be the concluding
6 the testimony of those witnesses that we have for the balance of this
7 week. Our next witness is scheduled to testify on Monday. We do not
8 have further witnesses for this week.
9 JUDGE MOLOTO: Okay.
10 MR. GUY-SMITH: The next witness will be Mr. Borovic.
11 JUDGE MOLOTO: Now, can somebody help me --
12 THE INTERPRETER: Microphone, please.
13 JUDGE MOLOTO: Can somebody help me. I don't seem to have the
14 latest court schedule with me. Is Courtroom II operational? Will it be
15 operational by Monday, or is it still not?
16 MR. GUY-SMITH: I'm not sure whether it is or is not.
17 JUDGE MOLOTO: Microphone for you, Mr. Guy-Smith.
18 MR. GUY-SMITH: I'm not sure whether it is or is not. I've been
19 given mixed messages on that.
20 [Trial Chamber and Registrar confer]
21 JUDGE MOLOTO: Thank you very much, Mr. Registrar. I'm advised
22 we are in Courtroom I next week, in the morning. So we stand adjourned
23 to Monday morning on the 20th of September at 9.00 in Courtroom I. Court
25 --- Whereupon the hearing adjourned at 6.08 p.m.
1 to be reconvened on Monday, the 20th day of
2 September, 2010, at 9.00 a.m.