Tribunal Criminal Tribunal for the Former Yugoslavia

Page 13810

 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

24     region?

25             MR. ZORKO: [Interpretation] Your Honour, he is here.  I'm waiting

Page 13811

 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.

Page 13812

 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,

 5     Bosnia-Herzegovina.

 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

18     academy.

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

21     Belgrade; is that right?

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,

Page 13813

 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

Page 13814

 1     sector for combat preparations with the Ministry of Defence; is that

 2     right?

 3        A.   Yes.  This was in the Ministry of Defence but I was within the

 4     PTT of Serbia, post, telecommunications and telegraph.  Post,

 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 and

12     Herzegovina aimed at providing assistance in the pullout of the JNA units

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, one of my basic tasks was to assist in making

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

Page 13815

 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

 5     Bosnia-Herzegovina.

 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

Page 13816

 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

 6     system?

 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.

Page 13817

 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

 3     personally?

 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?  You were not transferred to the VRS?

 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

22     examination.

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.

Page 13818

 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

21     it.

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]

Page 13819

 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

Page 13820

 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

Page 13821

 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

 3     communicate.

 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

16     Montenegro.  There's a battalion there.  They have a communications

17     centre that can be accessed by wire alone.  For example, Podgorica in

18     Montenegro, there is another communications centre there from which all

19     types of communication lines emanated; radio, wire, courier, and radio

20     relay.

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.  It covers all of Visegrad's

25     inhabitants.  This is a stationary communications system in the town of

Page 13822

 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

 4     Zagreb garrison, while the JNA were still around, how many units did that

 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; Sarajevo,

11     Bosnia-Herzegovina; and Nis, Serbia, there were many joint units there.

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.  One could have unhindered communication to a garrison

19     stationed in Bitola, Macedonia.  It wasn't a hot line, as we called it,

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

Page 13823

 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.

Page 13824

 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

15     you.

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

Page 13825

 1     duty officers manning those centres.  It is noteworthy that the civilians

 2     normally came from the area in which the communications centre was

 3     located.

 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

15     document.

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

24     identification?

25             MR. ZORKO: [Interpretation] Yes, that's right, Your Honour.

Page 13826

 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

Page 13827

 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.  The map we have before us looks like a middle

17     of a town, not a middle of a country.  Unless you tell me what town this

18     is.

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

Page 13828

 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, from numbers 1 onwards, and I'm not

 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,

13     Kozjak.

14             In Bosnia-Herzegovina, as far as I can remember, 9, Veliki Zep;

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, let's start from number 20, Fruska Gora; 21, Avala;

18     22, Cer; 23, Jagodnja; 24, Cigota; 25, Strazbenica; 26, Maljen; 27,

19     Jastrebac.

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

Page 13829

 1     was in Croatia.  Can you please confirm if that's correct or not.

 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

18     Croatia.

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

21     Croatia because, according to your testimony, it was supposed to be in

22     Croatia.  Can you do that again, please.

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.

Page 13830

 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, and that number 14 looks like 154

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

13     Bosnia-Herzegovina.

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.

Page 13831

 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

 7     24.

 8             THE WITNESS: [Interpretation] Yes, yes, Strazbenica.  Can I

 9     correct it?

10             JUDGE MOLOTO:  Can you correct it, please.  Good.  Thank you so

11     much.

12             THE WITNESS: [Interpretation] Your Honour, I just remembered that

13     I forgot the hub in Serbia called Kopaonik, which is very important.  Can

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

Page 13832

 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.

Page 13833

 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

Page 13834

 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 to communicate with Serbia if they did not

 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

 9     later?

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

24     vehicles.

25        Q.   Is there any connection between these and the stationary

Page 13835

 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

 9     centre.

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

14     level.

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

Page 13836

 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 military district, this command post was

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.

Page 13837

 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 area, yet another underground

14     facility.

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, those were fully equipped, including

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

Page 13838

 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,

Page 13839

 1     communications equipment, which was not in the stationary hubs and

 2     centres?

 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, if you know?

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 is a specific city with a large

25     military presence, and in that single garrison there were several

Page 13840

 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 stationary centre, which army,

 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.  Probably the Muslim side used it as

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

16     Croatia, Slovenia, the Serb army of the Krajina, the VRS, and the Army of

17     Bosnia-Herzegovina.

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

Page 13841

 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, it had a sufficient number of stationary hubs

 5     and centres.  In Slovenia, Svetigora, Krhin, and Bos [phoen] were the

 6     three stationary communications centres, and in terms of Slovenia's size,

 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

10     system.

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 in order to have a functioning communications

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

25     autonomous.

Page 13842

 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 and Belgrade, one needs to have a

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

Page 13843

 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

 4     Yugoslavia and Croatia.

 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

10     administration.

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

23     Hungary.

24             The second meeting followed closely behind and the teams on both

25     sides were basically the same.  That meeting took place in Slavonski

Page 13844

 1     Brod.

 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

13     army.

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

22     garrisons.

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

Page 13845

 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

 5     case.

 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.

Page 13846

 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

11     Yugoslavia given the stage of development it had reached by this point.

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, Egypt,

16     Israel, the purpose being to exchange our experiences and to enhance our

17     communications system and command and information systems.

18             If I may just digress.  There was a very fruitful collaboration

19     with Romania and that continued.  As far as I remember, a year or two ago

20     we had a joint drill that was held and communications centres were

21     jointly set up by the telecommunication units from Romania and

22     Yugoslavia; that is, Serbia.

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

Page 13847

 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

10     imply?

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

Page 13848

 1     activities was established.  This shows that the army had limited

 2     resources and that this was established at the expense of other

 3     structures.

 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

Page 13849

 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.

Page 13850

 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

 8     number.

 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

Page 13851

 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

 3     so.

 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

22     Honour.

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

Page 13852

 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

Page 13853

 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.

Page 13854

 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

Page 13855

 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

13     administration.

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

Page 13856

 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.

Page 13857

 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

13     now.

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

16     Drina.  We don't see any Drina on the English page and our page doesn't

17     look like it's the first page.  It has no heading.

18             MR. ZORKO: [Interpretation] This is page 2 in English.  My

19     apologies.

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

Page 13858

 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

Page 13859

 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

 7     Honour.

 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

11     question.

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

21     B/C/S.

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.

Page 13860

 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

 7     diagram?

 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 plan was drafted, and I certainly

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.

Page 13861

 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

Page 13862

 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.

Page 13863

 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:

Page 13864

 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,

11     sir?

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.

Page 13865

 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; correct?

 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?

Page 13866

 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

21     garrisoned?

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

Page 13867

 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 Staff of the VRS wished to communicate with

 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

17     speculate.

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

Page 13868

 1     the Main Staff of the VRS at Veliki Zep and Bijeljina.

 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

 9     Honours.

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?

Page 13869

 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

 7     much.

 8        Q.   Would you accept, sir, that communications between Bijeljina and

 9     Veliki Zep pass through the Cer communications centre?  Do you accept

10     that?

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.  So all I'm doing, sir, to be fair, is

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

Page 13870

 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, and of course there may have been simpler routes of

 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.  And of course there may have been

25     simpler routes of doing this rather than going through Cer."

Page 13871

 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

Page 13872

 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?

Page 13873

 1        A.   Until the end of my professional service with the Army of

 2     Yugoslavia.

 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]

Page 13874

 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

24     adjourned.

25                           --- Whereupon the hearing adjourned at 6.08 p.m.

Page 13875

 1                           to be reconvened on Monday, the 20th day of

 2                           September, 2010, at 9.00 a.m.