1 Monday, 27 November 2006
2 [The accused is not present in the courtroom]
3 [Open session]
4 --- Upon commencing at 11.21 a.m.
5 JUDGE ORIE: Good morning to everyone.
6 Mr. Registrar, would you please call the case.
7 THE REGISTRAR: Good morning, Your Honours. This is case number
8 IT-03-67-T, the Prosecutor versus Vojislav Seselj.
9 JUDGE ORIE: Thank you, Mr. Registrar.
10 May I have the appearances for the Prosecution first.
11 MS. UERTZ-RETZLAFF: Thank you, Your Honour. For the Prosecution,
12 Mr. Dan Saxon, Ms. Melissa Pack. My name is Hildegard Uertz-Retzlaff, and
13 with us is Ana Katalinic, our case manager.
14 JUDGE ORIE: For the Defence.
15 MR. HOOPER: As assigned counsel, David Hooper, with Dr. Andreas
16 O'Shea, assisted by Lea Kulinowski, who is our case manager.
17 JUDGE ORIE: Thank you, Mr. Hooper.
18 The accused is not present. During a Pre-Trial Conference held
19 this morning, this Chamber was informed about why he is not present. The
20 Chamber has, on its mind, to proceed even where the accused is absent.
21 Before, however, finally deciding to do so, if any of the parties would
22 like to make any submissions on this matter, they are invited to do so.
23 Madam Uertz-Retzlaff.
24 MS. UERTZ-RETZLAFF: No, thank you, Your Honour.
25 JUDGE ORIE: Mr. Hooper.
1 [Defence counsel confer]
2 MR. HOOPER: This morning, we understand that the Prosecution are
3 due to present their opening of the case, and that is a matter which Dr.
4 Seselj can see from the transcript or video or audio that he would
5 doubtless be provided with, and we take no objection at all in those
7 We do raise concerns as to the medical health of Dr. Seselj. He's
8 no longer a young man. We understand that he has in the past, as a result
9 of activities in Serbia or former Yugoslavia, suffered periods of
10 imprisonment where he has, in fact, engaged in hunger strikes, and some of
11 them have gone on for quite a long time. He's no longer that young man.
12 We are concerned about his health. We understand that he is being seen by
13 a Dr. Falke at the Detention Unit. We would be particularly concerned
14 that, for example, his weight loss is something that is attended to or has
15 regard -- has regard to, and is something which you, the Judges, are
16 provided with some information. Because my understanding is that in a
17 hunger strike or an absence of food, as the Registry, we heard, would
18 nominate it, that in such circumstances, one of the key factors is loss of
19 weight and the attended risks to health that poses.
20 I don't know what regime is presently in place for the Chamber to
21 be made aware of Dr. Seselj's position. We understand that there was
22 certainly a daily report provided to the Registry, and we assume that
23 comes to you, the Judges.
24 Those are all my submissions.
25 JUDGE ORIE: Thank you, Mr. Hooper. I do understand that you take
1 no objection to the Chamber proceeding in the absence of the accused, at
2 least for today, as you said. I'll later say a few words about the other
3 submissions you've made -- you made.
4 Before delivering a decision of the Chamber to proceed in the
5 absence of the accused, I do understand that the Prosecution will start
6 giving its opening statement. I'm not certain, Mr. Hooper, about where
7 Mr. Seselj earlier expressed that he would like to postpone his opening
8 statement until a later stage and only to make an unsworn statement,
9 whether that's the course you have in mind as well, which would mean that
10 once we had heard the opening statement by the Prosecution, that we'd
11 then, at least if Mr. Seselj would be present in court tomorrow, that we'd
12 then hear an unsworn statement from him, unless you, now as assigned
13 counsel, would like to make an opening statement or whether you'd follow
14 the earlier course decided by Mr. Seselj to delay an opening statement.
15 MR. HOOPER: Of course, the Defence have the option of making an
16 opening statement now or deferring it just before the defence case, under
17 the Rules.
18 JUDGE ORIE: Yes.
19 MR. HOOPER: I wouldn't at this stage assume, even if I was in a
20 position to do so, which I'm not, to make an opening statement. I
21 wouldn't make that opening statement now because to do so would intrude, I
22 think, over much into Dr. Seselj's position, and his right to make such an
23 opening statement at an appropriate time can be preserved in that way.
24 JUDGE ORIE: Yes. I would say that Mr. Seselj, of course, under
25 the supervision of the Chamber, can make an unsworn statement at the
1 beginning, but his right to make an opening statement, I would say the
2 Defence has a right to make an opening statement, because, since this
3 morning, Mr. Seselj is not in a position anymore to address directly this
4 Chamber. Of course, if he wants to participate in it, he can ask, through
5 you, for permission to do so.
6 So for the time being, the Chamber could expect that after the
7 opening statement of the Prosecution, that either we hear an unsworn
8 statement of Mr. Seselj, or if he doesn't appear and if he doesn't want to
9 make such an unsworn statement, that we'd then proceed and start hearing
10 evidence early December.
11 MR. HOOPER: Yes. Our position at the moment is, as the Chamber,
12 I'm sure, is aware, that there's been no contact, absolutely no contact
13 between ourselves and Dr. Seselj, and I see no imminent change in that
14 position. We will seek to make contact with him this afternoon. I
15 understand that it's anticipated that the Prosecution opening may not
16 conclude today. I don't know if I'm correct about that. But we'll see in
17 any event. But if that's the case, then we will obviously go over until
18 tomorrow, where, in any event, court time is allocated, and perhaps we can
19 generally re-address the position, not that I feel for a moment that I'd
20 be in a position to make an opening statement, but we can re-address the
21 position tomorrow --
22 JUDGE ORIE: Yes.
23 MR. HOOPER: -- perhaps in the light of our inquiries today. And
24 obviously Dr. Seselj will be invited, if there is a hearing again
25 tomorrow, to attend this trial.
1 JUDGE ORIE: Yes, of course.
2 MR. HOOPER: And we'll see if he takes that opportunity to do so.
3 JUDGE ORIE: Yes. The Chamber can only confirm that Mr. Seselj,
4 of course, is not only entitled, but that the Chamber even would prefer
5 him to be present at trial, because that would better serve the interests
6 of justice.
7 That being clarified, I informed the parties that if we might run
8 out of time today, of course, Madam Uertz-Retzlaff, then you'll be in a
9 position to continue tomorrow. Tomorrow we have not the full morning
10 session available to ourselves. We have to stop a bit earlier, after
11 the -- before the second break, approximately. If need be, since Mr.
12 Seselj has been attributed a certain amount of time as well, we would then
13 continue Friday, in the afternoon, not Wednesday, not Thursday.
14 Then I'll deliver the decision of this Chamber to proceed in the
15 absence of the accused.
16 The Chamber establishes that the accused is aware of this trial to
17 start. The accused has put forward claims, although not by himself
18 directly addressing this Chamber, claims including that the Chamber
19 changes certain decisions it previously took. Among these decisions,
20 there are some for which a legal avenue to challenge them was or still is
21 open to the accused. Apparently, the accused wants to put pressure to
22 have his claims honoured by his refusal to take any food offered by the
23 United Nations Detention Unit, which has resulted in, as the Chamber
24 understands, a deterioration of his health.
25 The absence of the accused is thus caused by, if not a deliberate
1 decision not to appear, by a self-induced weak physical condition and
2 cannot be accepted by this Chamber as a reason to postpone the start of
3 this trial.
4 In addition to this decision, the Chamber regrets that the accused
5 is not present at the start of this trial, as I said before. The Chamber
6 further expresses its concerns about consequences of the accused's
7 decision to refuse to take food provided by the UNDU and not to take his
8 medication, consequences unfavourable to his physical condition.
9 Finally, the Chamber encourages the accused to choose legal
10 avenues if he seeks to challenge any decision this Trial Chamber takes or
11 has taken.
12 In response to one of your questions, Mr. Hooper, the Chamber has
13 invited the Registrar to keep the Chamber, at regular intervals, to keep
14 acquainted with any development in relation to the physical condition of
15 the accused. If there's any need to further discuss that in this
16 courtroom, we'll hear either from you or from the Prosecution or take the
17 initiative ourselves. The Chamber stresses, however, that the first
18 responsible authority for medical care to be provided to those who are
19 detained in the Detention Unit is the Registrar of this Tribunal.
20 Then, having dealt with these preliminary matters, Madam
21 Uertz-Retzlaff, I'd like to invite you to make the opening statement on
22 behalf of the Prosecution.
23 [Prosecution Opening Statement]
24 MS. UERTZ-RETZLAFF: Thank you, Your Honour.
25 Your Honours, this case has its origin in the process of the
1 disintegration of the former Yugoslavia and the emergence of new
2 independent states, among them Croatia and Bosnia and Herzegovina.
3 It is a case about Serb leaders, among them the accused Vojislav
4 Seselj, in Serbia and Montenegro, as well as in Croatia and Bosnia and
5 Herzegovina, who resisted this process and insisted that their vision of a
6 state for all Serbs, or a new Yugoslavia, or, as the accused said, a
7 Greater Serbia, must prevail no matter what the cost. As it became
8 increasingly less likely that they would achieve their objectives by
9 negotiations, these leaders resorted to the politics of violence, often
10 invoking old historical grudges and wrongs to instil fear and hatred in
11 their people and incite them to violence against their neighbours. Their
12 ethnocentric politics became the politics of separation where the
13 suffering of the enemies, namely, the Croat and the Muslim populations, as
14 well as other non-Serbs, was viewed as a harsh but necessary cost of
15 achieving their goal of a new Serbian state. The events themselves were
16 notorious and the term "ethnic cleansing" came into common use.
17 Let me quote from Exhibit 429, a report of the Special Rapporteur
18 of the UN Commission on Human Rights, dated 27 October, 1992. Your
19 Honour, my colleague, Ms. Katalinic, will always show you the exhibits I
20 talk about on the screen.
21 JUDGE ORIE: Yes. We have no exhibits yet. I take it we have,
22 until now, ERN numbers. Whenever you introduce -- at least that's my
23 understanding, but I'm new in e-court as well. But as soon as you
24 introduce any document, that it will be given an identifying number later
25 to become an exhibit number once the exhibit has been admitted.
1 MS. UERTZ-RETZLAFF: Your Honour, today we have no e-court.
2 Today, we actually go with Sanction, so you would have to press, actually,
3 which button? ELMO, the ELMO button.
4 JUDGE ORIE: And I was under the misapprehension that we would
5 start immediately in e-court, but we'll start only on the second day.
6 MS. UERTZ-RETZLAFF: So if you press the ELMO ...
7 [Trial Chamber and registrar confer]
8 JUDGE ORIE: I had some practical problems, but they are resolved
10 Mr. Hooper.
11 MR. HOOPER: Sorry to interfere. It may have been a matter I
12 should have raised right at the outset, but with Dr. Seselj not being
13 here, my understanding is that there are facilities, if he wishes to avail
14 himself of them, to follow the proceedings today. I don't know if that
15 extends to exhibits. I understand there's a videostream which can be
16 accessed from a distance. I don't know ...
17 JUDGE ORIE: What was offered to Mr. Seselj, as far as I remember,
18 is that where he earlier received videos of the proceedings, that at least
19 video coverage of the proceedings, which would include everything that's
20 shown on the ELMO, is made available to him. That does not necessarily
21 mean that he can always keep them under his own control, and this is
22 raised by some security concerns envisaged by the Registrar. But at least
23 what now appears on our screens is accessible to Mr. Seselj as well.
24 MR. HOOPER: Thank you, Mr. President.
25 JUDGE ORIE: Please proceed, Madam Uertz-Retzlaff.
1 MS. UERTZ-RETZLAFF: You see on your screens the report of the
2 Special Rapporteur of the UN Commission on Human Rights, dated the 27th
3 October, 1992. In paragraph 6, he states that "the principal objective of
4 the military conflict in Bosnia and Herzegovina is the establishment of
5 ethnically homogeneous regions. Ethnic cleansing does not appear to be
6 the consequence of the war, but rather the goal. This goal, to a large
7 extent, has already been achieved through killings, beatings, rape,
8 destruction of houses and threats."
9 This part of the report refers to Bosnia and Herzegovina; however,
10 in the same report, in paragraph 17, the unbearable living conditions in
11 Sarajevo are mentioned, a mass grave in Vukovar is mentioned in paragraph
12 18, and ethnic cleansing of non-Serbs in Vojvodina at paragraph 22 of that
13 same report. I will come to these events later.
14 Vojislav Seselj, along with others, pursued the goal of a new
15 homogeneous Serbian state through a massive state-sponsored persecution
16 campaign in parts of Croatia, Bosnia and Herzegovina, and in Serbia
17 itself, including killing, detention, deportation or forcible transfer,
18 plunder, destruction of religious sites, and razing of entire villages and
20 The accused in this case, Vojislav Seselj, was and is a
21 politician, a well-educated, a professor, a shrewd and calculating man, an
22 extreme Serb nationalist, a master of political manipulation masked with
23 patriotic rhetoric.
24 He said about himself the following during his testimony in the
25 Milosevic case, and I refer here to our Exhibit 2828, at the session of
1 the 31st August, 2005. He said: "There is no greater scandalmonger in
2 Serbian political life than me over the past 15 years. When I needed this
3 kind of scandal out of political interests, I was the one who could do
4 that the most skillfully." You'll find that at T43500.
5 He also admitted during the cross-examination in that case that he
6 would resort to untruths when waging a political propaganda war. You'll
7 find that at page 43807 and 43443.
8 He even admitted that many of his statements during the events
9 relevant to the indictment may have resembled warmongering, and you'll
10 find that quote at 43385 of the transcript of the Milosevic case.
11 Let me show you how Vojislav Seselj often presented himself during
12 the events. You see him here wearing a Serbian hat with a kokarda and a
13 rifle. This is Exhibit 632.
14 During the events relevant to the indictment, the accused was the
15 president of the Serbian Radical Party, the SRS. He was a charismatic
16 face of an ultra-nationalist policy that promoted a homogeneous Greater
17 Serbia, with its western borders along the infamous
18 Karlobag-Ogulin-Karlovac-Virovitica line.
19 In addition, Vojislav Seselj was the head of the Serbian Chetnik
20 Movement, the SCP, a movement that, according to the statute of the SRS
21 party, was a collective member of this party and became the military wing
22 of the SRS during the conflict. In fact, one can call it the party army.
23 Seselj called himself in an order, that you see here on your screen, order
24 124 of the 13th May 1993, he calls himself "the only Serbian Chetnik
25 Vojvoda directly engaged in the ongoing liberation movement of the Serbian
1 people, following in the tradition of the Serbian Chetniks."
2 On the last page of that same document, he signs as the President
3 of the Central Homeland Administration of the Serbian Chetnik Movement,
4 the highest organ of the movement. That's Exhibit 2015.
5 The SRS/SCP volunteers, in fact, considered him to be their
7 In this case, you will hear evidence from witnesses and see
8 documents about the various individuals and organs of the SRS and the SCP,
9 both in Belgrade and in the regions, and how they took part in the events.
10 I will address some of these structures and individuals when speaking
11 about specific locations.
12 At this point just this, the evidence will show that despite the
13 organs that were set up in the SRS party and the SCP movement, there was
14 only one leader of both and that was Vojislav Seselj. The accused would
15 be informed of the smallest details of these organs -- by these organs,
16 and only he would make the decisions. He was an autocrat by nature and
17 made decisions independently. When communicating with persons from the
18 party or the movement, he would always do so in raised voice, making it
19 obvious that what he was proposing had to be executed no matter what.
20 In this case, the Prosecution will prove that together with others
21 Vojislav Seselj implemented policies to expel non-Serbs from territories
22 claimed to be Serbian lands. The accused not only promoted the expulsion
23 of non-Serbs from specific targeted territories and incited his audience
24 to do so, in addition, he recruited and indoctrinated volunteers and set
25 up a party army that pursued this course brutally. Through his extreme
1 rhetorics, the accused attracted many young men who volunteered and became
2 part of the thousands of SRS volunteers who participated in the conflict
3 in Croatia and Bosnia and Herzegovina, many of them undisciplined, violent
4 and even criminal.
5 The Prosecution will lead evidence, both in writing and orally,
6 showing how the radical speeches of the accused affected not only
7 volunteers associated with the SRS or the SCP, but also other volunteers,
8 reservists, regular soldiers of the JNA and the VJ, and local Serbs,
9 instilling in them fear and hatred.
10 In addition, we will hear that the radical speeches had also a
11 strong immediate effect on the non-Serbs who listened to them. Hearing
12 the accused and his threats was enough to many of the non-Serbs to leave
13 their homes, fearing for their lives. My colleague, Mr. Saxon, will
14 address these aspects of the accused's criminal conduct in more details
15 later on.
16 However, this case is not only about the accused's words. The
17 accused and his associates in the SRS and the SCP party -- SCP movement
18 took part in the financing, supply, transfer, and direction of the actions
19 of the volunteers participating with other Serb forces in the persecution
20 of non-Serbs. In this trial you will hear evidence and receive
21 documentation that despite the subordination of these volunteers under the
22 regular military commanders in the field, the volunteers often stayed
23 together in units commanded by SRS company, detachment or squad leaders
24 who would report back not only to the regular military command on the
25 front lines but also to the accused and his associates in the party
1 offices in Belgrade.
2 The criminal charges against Vojislav Seselj in the Redacted
3 Modified Amended Indictment are three counts of crimes against humanity,
4 those being persecution, deportation and inhumane acts-forcible transfer;
5 and six counts of violations of the laws and customs of war, those being
6 murder, torture, cruel treatment, wanton destruction of villages or
7 devastation, destruction or wilful damage done to institutions dedicated
8 to religion and plunder.
9 The Prosecution alleges that the accused, under Article 7(1) of
10 the Statute, is responsible for the crimes listed because he planned,
11 instigated, ordered, committed or otherwise aided and abetted their
12 planning, preparation or execution.
13 As far as the term "committed" is used, the Prosecution alleges
14 that the accused physically committed the crimes of persecution, that's
15 count 1, by direct and public incitement and denigration with respect to
16 his speeches in Vukovar, Mali Zvornik, and Hrtkovci; and also counts 10
17 and 11, deportation and forcible transfer, with respect to his speech in
19 In addition, when using the term "committed," the Prosecution
20 refers to his participation in a joint criminal enterprise, the objective
21 of which was the permanent forcible removal of Croat, Muslims and other
22 non-Serbs from large areas of Croatia and Bosnia and Herzegovina claimed
23 to be Serbian through the commission of crimes.
24 The Prosecution will present evidence that the specific crimes
25 identified in the indictment were within the objective of the joint
1 criminal enterprise. The Prosecution's position is that the crimes of
2 deportation and forcible transfer constituted the JCE's common objective
3 from the very start. Whether the other crimes, such as murder, detention,
4 torture, beatings, sexual assaults and destructions of property, were
5 originally -- were original to the objective of the JCE from the very
6 start or added later due to the circumstances on the ground is irrelevant.
7 The Prosecution will prove that these crimes were adopted by the JCE
8 members during the events and incorporated into the criminal plan. The
9 evidence will show that the common objective of the JCE never changed, but
10 that the implementation of this common objective evolved, and as a matter
11 of fact, all the crimes charged in the indictment became part of the
12 criminal means through which the JCE pursued its goal throughout the
13 period relevant to the indictment.
14 The indictment alleges, alternatively, that the crimes enumerated
15 in some of the counts of the indictment were the natural and foreseeable
16 consequences of the execution of the JCE and that Vojislav Seselj was
17 fully aware of the horrific consequences that the implementation of the
18 objective of the JCE would bring to the non-Serb population in the
19 targeted areas.
20 To this end, let me quote from an interview he gave on the 24th of
21 May, 1991, and I refer here to Exhibit 569. He said, after returning from
22 Bosnia and Herzegovina, where he inter alia had met Radovan Karadzic, the
24 "We have already deployed several Chetniks groups in Zagreb and
25 other towns across Croatia, which are trained in sabotage and terrorist
1 activities. If Serbian civilians start to be massacred, the Chetniks will
2 strike at Zagreb and other concentrations of Croats, using their full
3 strength. You know, when one retaliates, revenge is blind. There would
4 be innocent victims, but what can you do. Let the Croats think about that
5 first. We shall not strike first, but if they should strike, we are not
6 even going to bother where our blows land. Also, unless the army disarms
7 the Ustashas immediately, there will be a lot of blood."
8 "And in a Radio B-92 interview, on the 30th of September, 1993,"
9 and I refer here to Exhibit 772, "a listener asks whether Seselj ever
10 worries about the non-Serbian population that is innocent and suffering
11 due to his views, and Seselj answers: 'Why would I have a guilty
12 conscience? So many innocent Serbs suffered in this war, and I need to
13 worry about those who belong to another enemy people, if possibly there
14 was an innocent one among them that suffered. You know, in war one
15 experiences great turmoil, great troubles, and I, in war, above all, worry
16 about those who belong to my own people.'"
17 Vojislav Seselj participated in the joint criminal enterprise
18 together with all the individuals and groups listed in paragraph 8 of the
19 indictment. It was a vast JCE, including a large group of persons. There
20 was a core group of JCE members in Belgrade, including politicians, such
21 as the accused and Slobodan Milosevic, members of the SFRY Presidency,
22 high-ranking officials of the JNA and the VJ and the Serbian MUP. There
23 were also core groups in specific regions, such as in the SAO Krajina in
24 Croatia, including Milan Martic and Milan Babic, who pled guilty in this
25 Tribunal; and in the SAO Eastern Slavonia, you have the core group Baranja
1 and Western Srem - sorry - you have the core group including Goran Hadzic,
2 Radovan Stojicic, better known by his nickname Badza, and in Bosnia and
3 Herzegovina, you had the core group, including Radovan Karadzic, Momcilo
4 Krajisnik, and Biljana Plavsic, who also pled guilty here in this
6 There were also local components of the JCE in the municipalities,
7 including Zeljko Raznjatovic, better known as Arkan, and the so-called
8 Vojvodas, the latter all close associates of the accused. I will give
9 more details regarding these local components of the JCE later when I
10 address the regions.
11 The Prosecution is not in a position, nor is it necessary in this
12 case, to identify all the members of the JCE by name. What the evidence
13 will show is that the accused was a member in it and sufficiently
14 connected and concerned with persons who committed the crimes in pursuit
15 of the common objective or who engaged other perpetrators to do so.
16 By now, the history of the disintegration of the former Yugoslavia
17 is well known, and I do not want to spend much time on this. I also do
18 not want to address the details of the implementation of the structures of
19 the JCE in the targeted regions. Insofar, I refer to the Prosecution's
20 brief where all the details are laid out.
21 Instead, I will review with you the goals of the JCE as they
22 relate to certain territories, in particular, the goals of this accused
23 and how they evolved due to major political events.
24 Vojislav Seselj left no doubt about what his goal was at the
25 beginning of the conflict. It was a homogeneous Greater Serbia. We will
1 hear and see a lot of evidence to this effect. Seselj himself called this
2 idea of Greater Serbia the raison d'etre of the SRS till the present day,
3 and I refer here to his testimony in the Milosevic case, at page 42887.
4 The territory of Greater Serbia is described by the accused in
5 many speeches, of which I will only give one, and it's the speech of the
6 4th of August, 1990, and it's Exhibit 776. And I quote:
7 "But, we are warning them that never, at any cost, will we allow
8 this Croatian state to be established covering the Serbian population. We
9 will never allow any Serbian territory, any Serbian settlement, destroyed
10 church or torched village, any Serbian mass grave, camp, pit,
11 slaughterhouse, to find itself beyond the borders of the Serbian state."
12 And a bit later, he said, during that same speech:
13 "We always proceed from the Croatian people being the one that
14 marked the borders of the Serbian state. Marking them with Serbian mass
16 And he further said, referring to Tudjman's election victory in
17 Croatia, he said the following:
18 "That victory has shown that the vast majority of the Croatian
19 people are with the Ustasha movement, just as the Croats had massively
20 welcomed and supported Pavelica's regime in WWII. We have no illusions
21 regarding the Croatian national nature, we have no illusions regarding
22 their ultimate goals. Therefore, we won't even negotiate with them. For
23 these negotiations and rotten compromises have always been at the expense
24 of the Serbian national interests. We, regarding our territories and
25 regarding our graves, will not negotiate with anyone in this wide world."
1 Let me show you now the platform of the Serbian Chetnik Movement,
2 and it's Exhibit 2018. In the programme of the Serbian Chetnik Movement
3 in 1990, among the goals we find under (i), the restoration of a free,
4 independent and democratic Serbian state in the Balkans which will include
5 all Serbian people and all Serbian territories, including the Republic of
6 Serbia, Serbian Macedonia, Serbian Montenegro, Serbian Bosnia, Serbian
7 Herzegovina, Serbian Dubrovnik, Serbian Lika, Serbian Kordun, Serbian
8 Banija, Serbian Slavonia, and Serbian Baranja.
9 An almost identical first goal is formulated in the SRS Manifesto
10 of February 1991. You find it here in the -- it's Exhibit 2019, and you
11 find it here in -- as the first goal, and you find actually it's
12 absolutely the same text except for one change. Added in the list of
13 territories is also now "Serbian Dalmatia," right after Dubrovnik, you
14 find Serbian Dalmatia.
15 JUDGE ORIE: If you'd allow me to interfere for one second. You
16 started reading a portion of it, and then you left out two or three lines
17 and then you read the last couple of lines. Perhaps it would be good if
18 you take several portions of a text you read, Mr. Seselj, if he would
19 review the video, could not follow the English, that you make clear that
20 these are separate portions and that it's not one portion you're reading,
21 so to say I leave out a couple of lines, I continue them. Best would be
22 to read all of it so that the context is not lost if Mr. Seselj listens to
23 the video.
24 MS. UERTZ-RETZLAFF: Your Honour, are you referring to the speech
25 that he gave or rather to the --
1 JUDGE ORIE: No, to the -- you said the goals we find number 1,
2 and then the restoration of a free, independent, and democratic Serbian
3 state, and then you left out a couple of lines and then you -- and that's
4 not clear, when reading or listening to you, that you did not read two
5 lines "imposed upon us," et cetera.
6 MS. UERTZ-RETZLAFF: Yes.
7 JUDGE ORIE: Please keep that in mind.
8 MS. UERTZ-RETZLAFF: I will do that, yes.
9 Vojislav Seselj, in his many speeches, referred to the western
10 borders of the Serbian state as the Karlobag-Ogulin-Karlovac-Virovitica
11 line. And you see here a map, and it's Exhibit 1891, and you see the
12 black line. That's actually a line that connects these places that I just
13 mentioned, and it shows actually the territory that the accused had in
14 mind when he was speaking about Greater Serbia with these western borders.
15 The accused and his associates did not only claim territory in
16 which Serbs constituted the majority population, but also areas such as
17 Dubrovnik and other locations in Croatia and Bosnia and Herzegovina where
18 Serbs were in a minority. To this end, the Serb suffering during the
19 Second World War was utilised by the accused and others not only to instil
20 fear in the Serb people, but also to revoke a birthright to certain
21 so-called historical lands.
22 The accused himself, during the testimony in the Milosevic case,
23 and I refer here to transcript 437 -- 43275, said the following:
24 "The SRS made a geographical map of Greater Serbia, and from that
25 map, which we published countless times on the cover page of the colour
1 back side of our magazine, one can say that the western borders of the
2 Greater Serbia is on the Karlobag-Ogulin-Virovitica line. That does not
3 contain only territories where Serbs are in the majority. It contains
4 also many territories where Croats, Macedonians and Muslims are majority
6 Not accidentally is the map with the
7 Karlobag-Ogulin-Karlovac-Virovitica line very similar to the territories
8 of the old Serbian Chetnik -- that the old Serbian Chetnik Movement
9 pursued before during the First and the Second World War. And you can see
10 here a map of Greater Serbia that our technical people actually put into
11 the regular time smack of the Balkans, and you can see that it is
12 basically the same that was published on the back side of the magazine of
13 the party organ, Velika Srbija. And here, this map will later be Exhibit
15 The accused and his followers saw themselves as successors of this
16 old Serbian Nationalist Movement. In relation to the volunteers of the
17 SRS, a document, "Basic Military Organs of the Serbian Radical Party
18 Volunteers," you'll see here, adopted by the SRS Main Board in June 1991.
19 That's Exhibit 1261. And I refer here only to paragraph 3, where it says:
20 "The volunteers of the Serbian Radical Party are continuing the
21 honourable patriotic traditions of the volunteers and Chetniks of the
22 Serbian liberation rebellions, uprisings and wars until the end of 1918;
23 Chetnik organisation 1902-1918; and Serbian Chetniks in World War II ..."
24 This text, of course, continues.
25 The Prosecution will present evidence, including expert testimony,
1 on what this old nationalist movement stood for, namely, an aggressive and
2 violent pursuit of a homogeneous Serbian state.
3 Other members of the JCE did not use the term "Greater Serbia."
4 Witness evidence will show that Slobodan Milosevic insisted that Serbs
5 remain in one state, and stated that divisions of Yugoslavia into several
6 states which would separate Serbian people and force them to live in
7 separate sovereign states of others would be out of the question.
8 Milosevic officially seemed to have been in favour of the old Yugoslavia
9 during parts of 1991.
10 For the accused Seselj, Federal Yugoslavia was only an interim
11 solution in the struggle for a Greater Serbia.
12 However, by June 1991, Milosevic and the Serbian and Montenegrin
13 members of the SFRY Presidency were pursuing the creation of a new Serbian
14 state and were discussing the redeployment of the JNA along the new
15 Serbian borders of the Yugoslavia. As Borisav Jovic put it in his
16 book, "the last days of the SFRY," it will become Exhibit 1869. He also
17 wrote in this book: "By working to destroy and break up Yugoslavia,
18 Croatia and Bosnia themselves are working to create a Greater Serbia."
19 Let me show another map. I have here a map. That was --
20 JUDGE ORIE: Madam Uertz-Retzlaff, I'm trying to follow your maps
21 as well. May I draw your attention to the following: You seem to have
22 taken over what I consider, personally, a bad habit by the Prosecution,
23 that is, to use projected maps at the same time as -- if you look at map
24 14 and 15, although you'll see that it's the same area, one is projected
25 and the other is giving a real picture. It makes it completely impossible
1 to do any measurement on maps which are projected. Therefore, to the
2 extent possible, could you please provide us with non-projected maps, and
3 just the ones that look from top to bottom and not from a certain angle,
4 which really changes all the dimensions. I hope you understand what I
6 MS. UERTZ-RETZLAFF: I'm not really sure, Your Honour.
7 JUDGE ORIE: If you look at 14 and 15, on 14 you get a real map as
8 you would find it whatever -- the other one, you see all the dimensions
9 are quite different. North/south becomes smaller; east/west becomes
10 larger. That's because of a certain projection technique which is used.
11 In that way, all the maps of Bosnia and Herzegovina start looking
12 different. For example, you'll find the same two maps before that. You
13 also have this projected one of strategic objectives, which makes it very
14 difficult to compare maps.
15 MS. UERTZ-RETZLAFF: Mm-hm.
16 JUDGE ORIE: Perhaps you'd give it some attention, some thought,
17 not to act upon it immediately.
18 MS. UERTZ-RETZLAFF: Yes, thank you, Your Honour, for this remark.
19 JUDGE ORIE: Please proceed.
20 MS. UERTZ-RETZLAFF: So this is now a map that was published on
21 the 22nd of October, 1991, in the magazine Epoha, and it is Exhibit 2880.
22 This is a map that relates to the targeted territory for the new Serb
23 dominated Yugoslavia pursued at that time, in October 1991, by the Serbian
24 leadership around Slobodan Milosevic.
25 There is Cyrillic text in this, but I can assist you in finding
1 your way in this map. If you look at the territory indicated as number 1,
2 that indicates the SAO Krajina. When you look at number 2, that's Western
3 Slavonia. Number 3 is SAO Western Slavonia, Baranja, and Western Srem.
4 Number 4 is Western Herzegovina. Number 5 is the Posavina Corridor.
5 Number 6 is the Dubrovnik Republic. And the curved line on -- at the most
6 western part of the map, that's, again, the line -- the line
7 Karlobag-Ogulin-Karlovac-Virovitica line, and in this Epoha article, it's
8 meant -- this line is called the optimal western borders of Serbian
9 countries. That's, in October, what the plan of the JCE had evolved to.
10 As can be seen from the map that Milosevic territory shows and the
11 previous map of Greater Serbia, it's almost identical; it's, indeed, the
12 same territory.
13 The evidence will further show that the relevant time -- in the
14 relevant time period, the JCE members in the regions in Croatia were fully
15 in line with Slobodan Milosevic, as well as Vojislav Seselj. The evidence
16 will show that the Serbian leaders in the SAOs in Croatia, in
17 collaboration with the JCE members in Belgrade, set up the political,
18 police, and military structures that engaged in a war for territory to
19 create the western borders of the new state. One of those engaged was the
20 accused, and he was personally present in these territories from the
21 beginning to the end. He was present when, on the 25th of July, 1990, at
22 a gathering in Srb, near Knin, Milan Babic and other SDS Krajina leaders
23 established a Serb Assembly and a Serbian National Counsel and passed a
24 declaration on the sovereignty and autonomy of the Serbian nation in
25 Croatia. Vojislav Seselj was present during the first violent clashes in
1 Plitvice in the SAO Krajina on 31 March 1991. Seselj's men were involved
2 in the violence in Borovo Selo on the 2nd of May, 1991, in Eastern
3 Slavonia. The accused was present in Vukovar before it fell to the Serb
4 forces and he was also present in Vocin in Western Slavonia. The evidence
5 will show that he was in constant contact with the Croatian Serb
6 leaderships in all the SAOs. The accused even supported Milan Babic by
7 the end of 1991 in his opposition to the Vance plan, but later on
8 Mr. Seselj then bent to the greater power, meaning Slobodan Milosevic.
9 Let me briefly address the military leadership that participated
10 in the JCE. The Prosecution will provide written and witness evidence
11 that the military, namely, the JNA generals and the -- in the Main Staff,
12 at the beginning of the disintegration of the Yugoslavia, were not in
13 favour of a new Serbian state, but rather pursued the continuation of the
14 old Yugoslavia. However, in July 1991, with Slovenia gone, Generals
15 pressured by Milosevic and the Serbian and Montenegrin members of the
16 Presidency, gave up the idea of the unitary Yugoslavia and moved their
17 main forces to the future borders of the new Serb-dominated state along
18 the lines just shown before.
19 When the Serbian and Montenegrin leadership on the 1st of October,
20 1991, took over the SFRY Presidency and thus the Supreme Command of the
21 JNA, the JNA sided openly with the Serbian leadership. In a report of the
22 1st of October, 1991 - and that's Exhibit 3009 - they warned the Croatian
23 government and other organs that they would now retaliate for any Croatian
24 military action.
25 The events of the 1st October 1991 reveal the amount of
1 coordination within the JCE; namely, on that same day, not only the
2 Serbian leadership and the JNA leadership took actions, on that same day,
3 the Montenegrin leadership acted in coordination and mobilised their
4 special police unit for the attack on Dubrovnik which started the
5 following day.
6 And you can just -- I invite you to briefly look at the order of
7 the 1st of October. It's Exhibit 3008, in which Momcilo Bulatovic
8 actually mobilised the police for the attack on Dubrovnik. And the SRS in
9 Belgrade acted as well. And here you see their decision, this is a
10 decision of the 1st of October, 1991, from the -- from the SRS Crisis
11 Staff. It's Exhibit 1959. In the minutes of this Crisis Staff meeting,
12 it states: "Pursuant to proposals by Vojvoda V. Seselj and Mr. Ljubisa
13 Petkovic, and in accordance with the current political situation in the
14 country, it was decided to change the name of the SRS Crisis Staff into
15 SRS war staff."
16 JUDGE ORIE: Madam Uertz-Retzlaff, this is not the second page of
17 the document we saw before which was totally illegible to me. I don't
18 know what you said, 3008, in which Mr. Bulatovic mobilised the police
20 MS. UERTZ-RETZLAFF: Yes.
21 JUDGE ORIE: That previous one, this is what I saw. I have no
22 idea what it is.
23 MS. UERTZ-RETZLAFF: Oh, Your Honour, I'm sorry. This is actually
24 the order of the 1st of October, 1991, and you see here, under number 1 --
25 JUDGE ORIE: Yes, if that could be shown on your screens.
1 MS. UERTZ-RETZLAFF: Yes, that's number 1.
2 JUDGE ORIE: Yes.
3 MS. UERTZ-RETZLAFF: It's mobilisation, and in paragraph 2, you
4 can see --
5 JUDGE ORIE: If you can just give me the time, to see what it is.
6 MS. UERTZ-RETZLAFF: Can you go back to 1.
7 JUDGE ORIE: It's 1 and 2 together.
8 MS. UERTZ-RETZLAFF: Yes. I think that's actually the best. You
9 see here, the mobilisation of the special police, and it's in 2, it's
10 referred to the Dubrovnik front.
11 JUDGE ORIE: And then at the bottom we see that it's
12 Mr. Bulatovic.
13 MS. UERTZ-RETZLAFF: Yes, it's Mr. Bulatovic. And the other
14 order, perhaps again, also the other order, if you see it, we can actually
15 make it bigger, the whole -- it's not so difficult to read. It's actually
16 minutes taken by the secretary of the SRS, and you see here, in paragraph
17 1, this reference that there would be now --
18 JUDGE ORIE: That one was read to us, so we're able to follow
19 that. But not the previous one.
20 MS. UERTZ-RETZLAFF: Thank you.
21 JUDGE ORIE: Please proceed.
22 MS. UERTZ-RETZLAFF: The evidence will show that at that time, on
23 the 1st of October, 1991, Vojislav Seselj and his associates in the SRS
24 and SCP already cooperated fully with the JNA and the leaderships in the
25 regions in recruiting, transferring, and engaging volunteers on the front
1 lines, in particular, in relation to Vukovar and Dubrovnik.
2 Were the goals of the JCE regarding the Serb territories in
3 Croatia achieved? Unfortunately, yes. We will hear from witnesses,
4 including an expert, about the demographic changes in the SAOs in Croatia
5 that left the claimed areas basically free of non-Serbs, in particular
7 The western borders along the Karlobag-Ogulin-Karlovac-Virovitica
8 line were not achieved fully given the resistance of the Croatian forces,
9 but they were achieved almost.
10 Seselj himself said on the 6th of March, 1992, in a TV interview
11 in Belgrade, that will be Exhibit 1849 the following:
12 "Well, I am of the opinion that we did not manage to achieve that
13 ideal western border of ours: Karlobag-Ogulin-Karlovac-Virovitica. We
14 did not succeed with Karlobag, but we are somewhere in the vicinity of the
15 former Maslenicki Bridge, and that is several kilometres away from
16 Karlobag. We did not succeed with Ogulin; however, we are close to
17 Ogulin. We did not succeed with Karlovac; however, we are holding the
18 suburbs of Karlovac. We did not succeed with Virovitica, but we are
19 holding the suburbs of Pakrac, one part of Pakrac and parts of Western
21 Let me show you now a map that's the official map of the RSK.
22 It's Exhibit 2829. It's a bit hard to see, but if you follow the brownish
23 lines, you can see, first --
24 JUDGE ORIE: Could you tell us which number this is in the bundle?
25 MS. UERTZ-RETZLAFF: It's 2829 -- oh, in the bundle, I'm sorry.
1 It's number 10.
2 JUDGE ORIE: Thank you.
3 MS. UERTZ-RETZLAFF: And the translation -- there is quite some
4 text on it, and the translation is 10A.
5 JUDGE ORIE: Yes.
6 MS. UERTZ-RETZLAFF: You can see here actually outlined the
7 achievements in relation to the SAOs, Eastern Slavonia, Western Slavonia,
8 and the SAO Krajina.
9 JUDGE ORIE: Yes.
10 MS. UERTZ-RETZLAFF: By the end of 1991, given the military and
11 political situation on the ground, the focus of the JCE shifted to Bosnia
12 and Herzegovina. In a conference organised by the Rump Presidency in
13 Belgrade on the 3rd of January, 1992, with representatives of the
14 leaderships of the SAOs in Croatia, the Bosnian Serbs and members of the
15 SRS as well as other Serb parties, a slightly revised map of targeted
16 areas evolved. And this map was actually published in the magazine Epoha
17 on the 7th of January, 1992, and that will be Exhibit 1879.
18 If you look at the light blue territories, these are actually the
19 territories that at that time were pursued, and you can see that Dubrovnik
20 Republik is gone. The Dubrovnik Republik is no longer light blue. And
21 also Western Slavonia is basically also now dark blue and no more
22 considered to be part of the plan.
23 One point that I would like to point out. You'll find the
24 word "Krajina" several times on the map.
25 JUDGE ORIE: Yes. Could we zoom in on the screen so that whoever
1 wants to watch this by video also has an opportunity to better follow what
2 you're saying.
3 MS. UERTZ-RETZLAFF: Yes. You'll see, actually "Krajina" pointed
4 here. That's here where just the marker is. That's the SAO -- the SAO --
5 the former SAO Krajina that at that time was already evolving into RSK.
6 You'll find on top -- on top you'll find also "Krajina." That's referring
7 to Eastern Slavonia, Baranja and Western Srem, and please do not confuse
8 it with the autonomous region of Krajina. That's in Bosnia. What you can
9 see is the Posavina Corridor, which is called here "SAO Semberija." You
10 can see it here linking the territories within Bosnia and also the
11 territory in Croatia to Serbia.
12 That's all I want to say at this stage. We'll deal with this map
13 during the trial.
14 On the 9th of January, 1992, the Bosnian Serb Assembly proclaimed
15 the Serbian Republic of Bosnia-Herzegovina. In relation to its
16 territories, it was stated that it included "areas where the Serbian
17 people are a minority because of the genocide conducted against it in the
18 Second World War." And that will be Exhibit 3012. Let me remind you that
19 that is the terminology very similar to that used by Seselj when he refers
20 to the Serbia graves as marking the borders of Greater Serbia.
21 The evidence will show that throughout the indictment period,
22 Seselj and the Bosnian Serb leadership pursued basically the same goals in
23 relation to Bosnia and Herzegovina. Seselj had contacts with the Bosnian
24 Serb leaders throughout the indictment period and even supported them in
25 1993 in their opposition to Milosevic regarding the Vance-Owen Plan.
1 Here I want to give you one example, and it's Exhibit 2029, a
2 speech that Mr. Seselj gave on the 11th of March, 1993.
3 "We believe that no one has the right to accept the Vance-Owen
4 ultimatum in the name of the Serbian people concerning the internal
5 borders in the territory of the former Bosnia and Herzegovina.
6 Particularly, we believe that no one has the right to give the corridor
7 between Bosnian Krajina and Semberija to the Croats, the Muslims or
8 UNPROFOR, in the same of the Serbian people. The Serbian Radical Party
9 maintains its position that the only just and firm boundary determination
10 in the territory of the former Bosnia and Herzegovina can be at the front
11 lines reached."
12 Over this issue, the accused finally split with Slobodan
13 Milosevic, at least temporarily, and that is why the Prosecution
14 restricted this indictment to the time period between the 1st of August,
15 1991, to September 1993.
16 But let me go back to 1992. On 12 May 1992, during the 16th
17 session of the Serbian Assembly, Radovan Karadzic pronounced the six
18 strategic objectives of the Bosnian Serbs. However, these objectives were
19 not established at that time.
20 In May 1992, they had, in fact, been ruthlessly implemented in
21 several municipalities by forces, including the SRS and SCP volunteers,
22 namely, in Bosanski Samac, Bijeljina, Brcko, and Zvornik.
23 What were these objectives? And I'll show you here Exhibit 74.
24 It's the text of the objectives.
25 First is, establish state borders separating the Serbian people
1 from the other two ethnic communities.
2 Second, set up a corridor between Semberija and Krajina.
3 Third, establish a corridor in the Drina river valley, that is,
4 eliminate the Drina as a border separating Serbian states.
5 Four, establish a border at the Una and Neretva rivers.
6 Five, divide the city of Sarajevo into Serbian and Muslim parts
7 and establish effective state authorities in both parts.
8 And six, ensure access to the sea for Republika Srpska.
9 JUDGE ORIE: Madam Uertz-Retzlaff, I see on what you've just shown
10 us on television, that this was signed by Mr. Krajisnik, President of the
11 Assembly. You earlier said the Serbian Assembly. Could you please always
12 clearly indicate what assembly we're talking about. The Serbian Assembly
13 could be the assembly of the Republic of Serbia, but from what I see, it
14 seems that it might not be the assembly of the Republic of Serbia.
15 MS. UERTZ-RETZLAFF: No, Your Honour --
16 JUDGE ORIE: Would you please always express yourself very clearly
17 on these matters.
18 MS. UERTZ-RETZLAFF: Yes. The Serbian assembly of course in --
19 the Bosnian Serb Assembly.
20 In that same session, on the 12th of March -- May, 1992, Karadzic
21 also mentioned in relation to the first objective, that it meant
22 the "separation from those who are our enemies and who have used every
23 opportunity, especially in this century, to attack us, and who would
24 continue with this practice if we were to stay together in the same
1 And in relation to the second goal, he mentioned that "the second
2 strategic goal is a corridor between Semberija and Krajina ... this is of
3 utmost strategic importance for the Serbian people because it integrates
4 the Serbian countries ... the alliance of Serbian states is infeasible if
5 we do not secure this corridor ..."
6 Now, Your Honour, I have now the map that you said we need to
7 reconsider, but I have planned to show it and I can't change it right now.
8 So here is actually indicated on this map the objective -- objectives that
9 Karadzic spoke about. That map is Exhibit 3007. And the Assembly session
10 that I just mentioned is the Assembly, Exhibit 241.
11 And what was in store for the non-Serbs in Bosnia and Herzegovina
12 is clearly stated by members of the JCE. At a session of the Assembly of
13 Bosnia and Herzegovina, I mean now the official Assembly of Bosnia and
14 Herzegovina, held on the 15th of October, 1991, the Assembly considered
15 inter alia a platform on the position of Bosnia and Herzegovina in the
16 future of Yugoslavia, and Radovan Karadzic said the following, that warned
17 the Muslims if they persisted in pursuing independence:
18 "This is the road that you want Bosnia and Herzegovina to take,
19 the same highway to hell and suffering that Slovenia and Croatia went
20 through. Don't think you won't take Bosnia and Herzegovina to hell and
21 Muslim people to possible extinction."
22 Now let me quote what Seselj put in writing in relation to the
23 non-Serbs, and I have here a document 1261. It's actually from a chapter
24 of his book, "In Sinisa Aksentijevic's Focus, Philippics of Chetnik's
25 Vojvoda" regarding Septa was the headline, "treatment of non-Serbs in the
1 process of unification ..." The headline is longer but I just referred to
2 this part. And the accused said the following about the non-Serb
3 population in the new Serb state:
4 "That is inevitable formation of a civilian state, the state of
5 the Serbs equal (loyalty is implicit) citizens, members of other nations,
6 ethnic minorities and groups. If such state is formed, other nations,
7 ethnic minorities and groups should not exceed more than 8% of the total
8 population; they should not exceed the said percentage in any larger
9 settlement, region or administrative unit, and there should be no
10 possibility to change their percentage through birth rate."
11 The text, of course, is much more complex, but I can only quote
12 this for time reasons.
13 Of course, this view made resettlement of huge numbers of
14 non-Serbs necessary. The ethnic division on the ground that Karadzic and
15 Seselj requested meant expulsion of non-Serbs from claimed territories.
16 Even in territories dominated by Serbs, Muslims and Croats settlements had
17 to be uprooted and the non-Serbs driven out in order to ensure a
18 homogeneous territory.
19 And I would like to show you briefly two maps that will be
20 elaborated upon by our expert witness, Dr. Tabeau. The first one is
21 actually a map showing Bosnia-Herzegovina's ethnic minority population
22 roster, and as you can see, it's a patchwork picture in the
23 municipalities. It's based on the census of 1991. And you can, in
24 particular, see the Posavina Corridor, for instance, on the top. It would
25 actually be partly Croat, partly mixed. So it's in quite a mixed
1 territory with the populations.
2 And now I show you a later map that also Ms. Tabeau will speak
3 about. You can see here the effect of the conflict where you have
4 basically very special, clearly defined territories along ethnic lines.
5 The Serb forces executing the plan in Croatia and
6 Bosnia-Herzegovina were basically the same in all territories, with some
7 minor variations due to the circumstances on the ground. And also
8 basically the same were the crimes.
9 Our evidence will demonstrate beyond any doubt that the events in
10 the municipalities and the towns and villages were not random or
11 spontaneous acts of a few individuals but were the result of a policy
12 pursued by the accused and others and implemented by forces under their
13 control or influence.
14 Let me now turn to the crimes committed in specific towns and
16 At the outset, let me say this: Many cases have been conducted
17 and concluded in this court in which these crimes were addressed in
18 detail. Eyewitnesses to the crimes, mostly victims, have described their
19 ordeals and suffering.
20 In this case, there is no need to hear much so-called crime-base
21 evidence. Certain notorious criminal events, like the murder of the men
22 from Vukovar hospital, the abuse of victims in camps throughout
23 Bosnia-Herzegovina, are meanwhile common knowledge or at least
24 adjudicated. In this trial, the Prosecution will therefore introduce
25 crime-base evidence mostly in written form. The focus of this case will
1 be evidence dealing with the structures that were utilised to commit the
2 crimes and linking the accused to the crimes.
3 Let me now first turn to the events in Vukovar. And I'll show you
4 here a map of Vukovar. It's Exhibit 3127. And it depicts, basically, the
5 places that you will hear about from the witnesses. It's the Vukovar
6 hospital; Velepromet, a former economical complex; the JNA barracks; and
7 on the bottom, Ovcara.
8 JUDGE ORIE: Before you continue, Madam Uertz-Retzlaff, can you
9 give us an idea on how much time you'd still need? Of course, I have to
10 think about a break.
11 MS. UERTZ-RETZLAFF: It's quite -- I have basically more than
12 half, I have done, but it's still ...
13 JUDGE ORIE: Yes. Then I suggest that we take a break now, and
14 that we'll resume at five minutes past 1.00, and then have another 40
15 minutes this morning.
16 MS. UERTZ-RETZLAFF: Yes. Thank you, Your Honour.
17 JUDGE ORIE: We'll adjourn until five minutes past 1.00.
18 --- Recess taken at 12.42 p.m.
19 --- On resuming at 1.07 p.m.
20 JUDGE ORIE: Madam Uertz-Retzlaff, you may proceed.
21 MS. UERTZ-RETZLAFF: Thank you, Your Honour.
22 Before the break, we saw the town map of Vukovar with certain
23 places indicated. It's actually map 19 in the trial binder.
24 On the 18th of November, 1991, Vukovar fell to the Serb forces.
25 An elderly man and his wife, fearing the worst, went to the hospital to
1 find protection. The following day, the non-Serb men were taken away by
2 Serb forces, threatened and cursed on their way, and eventually arrived at
3 the Ovcara farm. There they were beaten by soldiers and subjected to all
4 sorts of cruelty. Some were killed right there in front or in the hangar.
5 The elderly man, who will be a witness together with a few others,
6 survived because he knew one of the soldiers personally and that soldier
7 saved his life. The other roughly 260 men and a few women were murdered
8 and buried in a mass grave.
9 What does this event have to do with the accused Seselj? The
10 Prosecution will provide written and oral evidence that in 1991, the
11 accused decided that the SRS should send as many volunteers as possible to
12 Vukovar. The SRS/SCP volunteers sent to Vukovar were placed under the
13 command of Milan Lancuzanin, also known as Kameni, commander of the Leva
14 Supoderica detachment, and were subordinated to the TO and the JNA.
15 Here you'll see a document. It's Exhibit 1415. It is a letter of
16 the chief of the staff of the SRS war staff dated 9 November, 1991.
17 JUDGE ORIE: It's still illegible to me. Is it my screen or ...
18 MS. UERTZ-RETZLAFF: No, it's actually bad. Perhaps we can
19 highlight --
20 JUDGE ORIE: If I don't watch it through the video but through the
21 e-court, then I get it better.
22 MS. UERTZ-RETZLAFF: Yes.
23 JUDGE ORIE: At the same time, I wonder what will be provided to
24 the accused. Therefore, I'll continue to watch video, and you should take
25 care that by zooming in or out, that one could follow that also, if one
1 receives a video, rather than to use the e-court facilities available
3 So I now move back to the video and ...
4 MS. UERTZ-RETZLAFF: And you can see here, it's from the Serbian
5 Radical Party War Staff --
6 JUDGE ORIE: If it will be on our screen, then I'll be able to see
7 that on the video. Could we move to the document with the assistance of
8 the technicians.
9 MS. UERTZ-RETZLAFF: It's actually there.
10 JUDGE ORIE: No, it's not on the -- if you use the video, which is
11 the one -- there now, there we are. Could it be zoomed in in such a way
12 that we can read the relevant portions.
13 MS. UERTZ-RETZLAFF: So you see the body of the text. What you
14 can't see right now is -- it's from the SRS War Staff, and it is addressed
15 to the commander of the Leva Supoderica detachment, referring to the
16 subordination of the volunteers to the Vukovar TO. And mentioned in the
17 first paragraph, I'm referring here particularly to the first and second
18 paragraph, there is mentioning of two other members of the SRS - that's
19 Slobodan Katic, who gets is -- is mentioned here as a commander, and also
20 you have mentioned in the second paragraph Branislav Vakic from Nis, who
21 is also appointed commander.
22 I don't want to go into more specifics of this document.
23 JUDGE ORIE: I take it that once it will be introduced in
24 evidence, then we'll get both versions, and legible for everyone.
25 MS. UERTZ-RETZLAFF: Yes, thank you.
1 JUDGE ORIE: Yes. Please proceed.
2 MS. UERTZ-RETZLAFF: The Prosecution will provide testimony of
3 soldiers regarding the cooperation of the man Kameni with the commanders
4 of the TO and the JNA Guards Brigade in Vukovar. The accused himself said
5 on TV Benkovac on the 23rd of November, 1991 - and that will be Exhibit
6 734 - that "Kameni, our main commander in Vukovar, plans his action with
7 the army major in the evening and executes it the next day. The army did
8 not have enough manpower to go around capturing each house because of
9 desertion - that is what our men did."
10 A few days before the massacre at Ovcara, the accused came to
11 Vukovar in order to visit the volunteers and boost their morale. He
12 participated in a meeting with the TO and the JNA commanders. During his
13 visit in Vukovar, the accused said the following:
14 "We are all one army. This war is a great test for Serbs. Those
15 who pass the test will become winners. Deserters cannot go unpunished.
16 Not a single Ustasha must leave Vukovar alive."
17 And the soldiers did what Seselj had requested them to do. When
18 the Serb forces occupied the city, hundreds of Croats were killed by Serb
19 forces. Among those committing the murders at Vukovar and in Ovcara and
20 elsewhere in Vukovar were the SRS/SCP volunteers, commanded by Kameni.
21 Let me show you a photo - Exhibit 2441 - that shows the accused in
22 the destroyed Vukovar. And to his left, the man with the cap, that is the
23 man Kameni, Lancuzanin, the commander of the Leva Supoderica detachment.
24 We will hear from witnesses present at the Ovcara farm, Vukovar
25 hospital, the barracks and Ovcara that the SRS/SCP volunteers led by
1 Kameni wanted revenge on those taken from the Vukovar hospital. The
2 evidence will show that many SRS/SCP volunteers participated in the mass
3 murder at Ovcara. And we will hear from witnesses that the man Kameni was
4 a close associate of the accused. He had direct access to the accused and
5 reported to him personally.
6 Kameni was recently convicted and sentenced to 20 years'
7 imprisonment in Belgrade for his participation in the atrocities at Ovcara
9 And I will show you now a photo of Kameni. He is here under
10 number 8. Under number 8 you can see the man Kameni.
11 And I'll show you another photo. Photo -- showing the person
12 inter alia, Branislav Vakic, who was also mentioned in the order that you
13 saw previously. There's a question mark behind the name "Vakic". That's
14 from an earlier stage. The witness -- you will see witnesses who clearly
15 identify this person.
16 The accused, on the 13th of May, 1993, promoted Kameni and Vakic
17 to the rank of Chetnik Vojvoda for their achievement during the Vukovar
18 campaign and elsewhere. And the photos that you saw are from the ceremony
19 appointing these Vojvodas.
20 And I will show you the document that I mentioned already earlier.
21 That's the promotion order number 124. You can see here, on top of it
22 there is the order, 124, and when you look at number 3, you see here that
23 Branislav Vakic is promoted. He is called "Chetnik Major" in this
24 paragraph. It says: "In April 1991 he was in Borovo Selo. He
25 participated in the liberation of Vukovar as deputy commander of the Leva
1 Supoderica volunteer unit. He also commanded the Serbian Chetnik units in
2 Serbian Herzegovina in May and June 1992." There are a references made to
3 a lot of places, including Mostar.
4 And under number 10, you see a description of Milan Lancuzanin,
5 Kameni, and I only want to draw your attention to the fact that he's
6 actually mentioned as the best of the best, and the excellent commander of
7 the Leva Supoderica detachment.
8 What the order does not say but what the evidence will show is
9 that wherever these two Vojvodas were active in the field, non-Serbs were
10 murdered. These two are not the only perpetrators of crimes against
11 humanity who were promoted by the accused on that occasion, on the 13th of
12 May, 1993. I will come to this later.
13 Topola, another SRS/SCP volunteer - his nickname is Topola - was
14 also present at Ovcara farm. He killed Croats also elsewhere in Vukovar,
15 including Velepromet, a commercial complex close to the JNA barracks, used
16 by the Serb forces as a detention facility. After the fall of Vukovar,
17 Topola and some other SRS/SCP volunteers removed detainees from the room
18 where they were detained and killed them. That's a separate charge in the
19 indictment related to Vukovar.
20 The evidence will show that when Seselj was informed about the
21 crimes committed by Topola, he simply said: "What can I do? Disarm the
22 man and send him home. He is tired."
23 The excused or his associates did not report these crimes to the
24 Serbian authorities in Belgrade. Instead, they later sent Topola as a
25 volunteer to Bosnia and Herzegovina, where he again committed serious
1 crimes against the non-Serb population.
2 Let me now briefly turn to Western Slavonia, and in particular,
3 Vocin in the Podravska Slatina municipality. That's the map 2 in the
4 binder. I just want to indicate to you where Podravska Slatina is
5 situated. As you can see, it's right east of Virovitica.
6 Looking at this map, it is obvious that if Seselj and others
7 wanted the JCE to establish the borders of Greater Serbia along the
8 Karlobag-Ogulin-Karlovac-Virovitica line, they needed to control the
9 Podravska Slatina municipality. And if they wanted a homogeneous Greater
10 Serbia, they needed to expel the Croatian population which amounted to
11 1.500 inhabitants in Vocin. And this is what, indeed, was done from
12 August to December 1991, when the Serb forces were in control in Vocin.
13 What connects the accused to these events? The JNA neither did
14 have the manpower to engage its units in this part of Western Slavonia or
15 did not want to. The evidence will show that the other JCE members, in
16 particular Slobodan Milosevic, did not pay much attention to Western
17 Slavonia. It was the accused who took a particular interest in the
18 take-over of this territory.
19 Throughout the fall of 1991, the SRS sent hundreds of hundreds of
20 volunteers to Western Slavonia. Had they not been brought to Western
21 Slavonia by Seselj, and had they not terrorised the non-Serb population,
22 both the Croats and the Serbs would have been a -- suffering of both the
23 Croats and the Serbs would have been avoided.
24 The Prosecution will not lead any crime-base evidence. However,
25 we will show, in relation to this particular place, how close and how
1 effective the SRS and the TO in Western Slavonia and elsewhere coordinated
2 their actions.
3 I want to show you four documents in a row.
4 The first one is a request of the Western Slavonia TO, of the 12th
5 of October, 1991, asking the SRS headquarters in Belgrade for the
6 provision of volunteers.
7 The next document is actually the reaction of the SRS War Staff of
8 the 16th of October, approving the dispatch of volunteers but asking for
9 certain technical matters in relation to the troops, about their
10 accommodation and the like.
11 The next document -- and I forgot to say, that's actually Exhibit
13 Exhibit 1414 is, again, a letter of the TO Western Slavonia to the
14 SRS, from the 19th of October, 1991, actually, addressing these particular
15 technical matters that were raised. And a few days later, volunteers were
16 dispatched with their SRS and SCP commander.
17 And I'll show you here the next document. It's the Exhibit 2144.
18 It's an authorisation of the 24th of October, 1991. Zoran Rankic, the
19 Deputy Chief of the SRS War Staff, informs the Podravska Slatina TO staff
20 that Radovan Novacic was authorised "on behalf of the SRS volunteer units"
21 to coordinate with them.
22 These documents show that within two weeks, volunteers, including
23 a commander, were dispatched after a TO request. And that is just one
24 example of how the SRS headquarters, the JNA, and the local authorities
25 acted "hand in glove" throughout the conflict in Croatia and
2 In this context, let me refer again to the basic military
3 organisation of the Serbian Radical Party volunteers. I have already
4 shown you this document briefly, and it's Exhibit 1261. And I would like
5 to draw your attention to Rule number 7, where it says that "the
6 volunteers of the Serbian Radical Party are engaged in combat and other
7 combat-related activities independently or as part of the appropriate unit
8 of the JNA, army of Republika Srpska, or army of Serbian Krajina,
9 according to the plans made by the commands of the aforementioned armies.
10 "Volunteer units are engaged in these armies only in their
11 entirety and under the command of the volunteer commanders, exceptions
12 possible if arranged."
13 In this connection, a volunteer commander, in full authority and
14 responsibility, is delegated to the specific command to coordinate
15 possibilities, requests, requirements, utilisation, and security of the
16 volunteer units.
17 And now let's go to paragraph 11, where the hierarchial command
18 structure in the SRS is described as follows:
19 "The Commands of the Serbian Radical Party Volunteers are
20 organised as commanding organs for all volunteer forces, their units and
21 their combat activities. They are formed analogously to commanding
22 structure of the party organs. The Homeland Command, commands of military
23 districts and commands of units."
24 And I told you in the beginning that Vojislav Seselj was actually
25 the chief of the Homeland Command.
1 Witnesses will tell us that at times the SRS transferred
2 volunteers of its party and other volunteers together to the front lines.
3 For the local population, the volunteers were just the same. Their
4 presence created a climate of fear by looting, threatening, abusing and
5 killing civilians. And what is important: They all considered themselves
6 Chetniks and associated themselves with the accused's goal of Greater
8 Again, in relation to Vocin, in November 1991, the accused visited
9 Vocin and met his volunteers, and we will hear from local witnesses that
10 the volunteers, after meeting Seselj, became more aggressive and there was
11 a sharp increase of crimes against Croat civilians after this visit.
12 In general, the SRS/SCP volunteers were widely known for their
13 brutality and ruthlessness. The Prosecution will provide numerous
14 documents from the military, the police and from NGOs that the bad
15 reputation of the SRS/SCP volunteers were not based on myth but based on
17 And I will show you only one example and -- for Croatia. That's a
18 letter from Helsinki Watch, from the 21st of January, 1992. It is Exhibit
19 1418. I just draw your attention to page 2, paragraph 3, where it says
20 the following:
21 "The Serbian government has also condoned and, in some cases,
22 supported the formation of at least three paramilitary groups in Serbia
23 which operate in Croatia. What appears to be the most brutal of these
24 groups is led by Vojislav Seselj, leader of the Serbian Radical Party and
25 the Serbian Chetnik Movement. Seselj's group of paramilitaries call
1 themselves Chetniks and operate throughout Croatia."
2 That will do. Just to mention the two other groups that are
3 referred to in this letter were actually Arkan's men and Mirko Jovic's
4 group, often remembered to as White Eagles.
5 And now one example for Bosnia and Herzegovina. It is Exhibit
6 1339. And it is a report prepared by the Main Staff of the VRS, on the
7 28th of July, 1992, and the document -- report prepared is
8 entitled "Report on Paramilitary Formations in the Territory of Serbian
9 Republic of Bosnia-Herzegovina." It reads as follows, and I quote:
10 "They are mostly composed of individuals of low moral quality, and
11 in many cases of persons previously prosecuted for crimes and offences and
12 even convicted of murder, robbery, larceny and the like. Very often, such
13 units have in their ranks pathological criminals whom the conditions of
14 war and general lawlessness have brought to the fore. Many formations of
15 this type display hatred of non-Serbian peoples and one can conclude
16 without reservations that they are the genocidal elements among the
17 Serbian people. War profiteering and looting are the motive for the great
18 majority of the paramilitaries ..."
19 And another point: "One common feature of all paramilitary
20 formations is that they do not take part in direct fighting with the
21 enemy. Instead, they are operating behind the lines of the regular
22 Serbian Republic Bosnian Army units, looting and burning property and
23 killing the innocent civilian population."
24 This report identifies various groups, but they name also
25 Seseljevci or Seselj's men, a term often used for the SRS/SCP volunteers.
1 The Prosecution will provide evidence that the accused Seselj was
2 fully apprised of the types of people that joined the ranks of the SRS and
3 SCP volunteers, and other volunteers he assisted in transferring to the
4 regions. Both the SRS members and local officials informed the accused
5 and his associates in the SRS office in Belgrade about the unruly and
6 cruel behaviour of the volunteers on the ground. Those providing such
7 information to the accused were met with indifference or even hostility.
8 The accused was fully aware about the events on the front. His
9 staff in the region and in Belgrade kept him constantly informed. During
10 his many visits to the front lines both in Croatia and Bosnia and
11 Herzegovina, the accused would see with his own eyes the destruction done
12 by the Serb forces on Muslim and Croat settlements.
13 As a high-ranking politician and member of the Serbian parliament,
14 the accused, of course, had many means of receiving information. And let
15 us not forget, a large amount of information about military actions and
16 crimes was in the public domain.
17 Now let me turn to Bosnia and Herzegovina, and in particular,
18 Bosanski Samac -- just in passing, Bosanski Samac, Bijeljina, and Brcko.
19 I have already mentioned the speech of Radovan Karadzic of the
20 12th of May, 1992, stressing the crucial importance of the corridor. The
21 Serb leadership in Serbia and RSK were equally aware of the importance of
22 the Posavina Corridor as the lifeline to the Serbian motherland.
23 Therefore, members of the JCE from all territories and institutions were
24 involved in the planning, preparation, and execution of the military
25 operations in the corridor, including the accused Seselj. And I'm just
1 pointing out here the map -- the map number 2 in the binder, where you can
2 see that Bosanski Samac, Brcko, and Bijeljina lie in that corridor. And
3 there's also -- you can also already see that Zvornik is also important
4 for the corridor and for the goal in relation to the Drina River.
5 These three municipalities are -- before the war, the majority
6 population in Bosanski Samac was of Croat ethnicity; in Brcko, Muslims had
7 the majority; and in Bijeljina, the majority was Serb. However, in all
8 three locations, the same things happened. From April 1992 onwards,
9 non-Serbs were expelled from these municipalities by force.
10 The Prosecution will not hear any crime-base witnesses. Some
11 witnesses, however, will address the events there in general terms. And
12 their evidence will show that the attack on the non-Serb population in
13 Bosnia and Herzegovina actually started in Bijeljina.
14 In these three municipalities that are mentioned, the local
15 authorities as well as the Bosnian Serb leadership requested that the SRS
16 send volunteers to these municipalities. And, indeed, SRS volunteers did
17 arrive and participated in the initial attack on these locations and also
18 in the crimes that followed.
19 To Bosanski Samac, the SRS War Staff sent volunteers that were led
20 by Srecko Radovanovic, Debeli. And you see him here on this photo that's
21 Exhibit 3117 -- 3017. He is there on the right side.
22 And in Brcko and Bijeljina, Mirko Blagojevic was in charge of the
23 SRS/SCP volunteers. And you see him here, the man with the typical
24 Serbian hat and kokarda.
25 The SRS/SCP volunteers fought alongside JNA units, Bosnian Serb
1 TO, members of the Serbian MUP and Arkan's Tigers.
2 The Prosecution will provide evidence that the accused was
3 informed about the violent events in the said municipalities, yet he
4 promoted those two that I mentioned to Vojvodas. And it's actually the
5 same promotion order that you saw previously here. Mr. Debeli -- Debeli
6 is the nickname. Debeli is here under number 15, Srecko Radovanovic is
7 mentioned here, and he is mentioned as a Chetnik colonel who organised and
8 trained Chetnik units. He is mentioned as being a participant in Croatia
9 from April 1992, and then in Bosnia inter alia Bosanski Samac and Brcko
10 are mentioned. And number 2 of that same order shows Mirko Blagojevic,
11 who is mentioned in relation to the entire Semberija, in particular,
12 Bijeljina, Zvornik and Brcko.
13 I have already shown you where Zvornik is situated and how
14 important it was for both the goal in relation to the corridor and the
15 third goal in relation to the Drina River. The events in this
16 municipality illustrate, in the most shocking way, the pattern that
17 unfolded through Bosnia-Herzegovina.
18 To get firm control over Zvornik, the members of the JCE had to
19 expel in particular the Muslim population that made up 59% of the
20 population in Zvornik in 1991. By March 1992, the Bosnian Serbs had
21 established their own police force in Zvornik, had declared Zvornik a
22 Serbian municipality, and were preparing the attack on Zvornik.
23 Beginning in April, Serb forces attacked Muslims and Croats living
24 in town, villages, and small settlements, most of which were undefended
25 and contained no military targets. Muslims and Croats were mistreated and
1 killed during the attack, and even more so during the persecution campaign
2 that unfolded afterwards.
3 The non-Serb population, mostly men, were arrested and taken to
4 various detention facilities. The conditions in the detention facilities
5 were horrible. Many detainees were beaten, tortured and killed. They
6 were also forced to work. And thousands of non-Serbs, mostly Muslims,
7 were expelled from their municipality. Their homes were looted and
8 destroyed as well as religious and cultural monuments.
9 And just here, a map -- a town map of Zvornik, with the detention
10 facilities shown. You can see it also on the map 22 that you have in the
11 map binder, where you can see the photos better.
12 The Prosecution will provide evidence of the massacre of 88 Muslim
13 males at Drinjaca Dom Kulture between the 30th and the 31st of May, 1992;
14 the killing of 150 men at the Karakaj Technical School, between 7 and 9
15 June; the massacre of 150 Muslim males at Gero's slaughterhouse between 7
16 and 9 June; and the murder of more than 14 non-Serb detainees between the
17 1st and the 26th of June, at Celopek Dom Culture.
18 These figures alone show clearly the extraordinary brutality the
19 non-Serb population was subjected to in Zvornik.
20 Why is the accused charged with these crimes? In March 1992,
21 while the Bosnian Serbs were preparing the attack, the accused gave a
22 speech in Mali Zvornik, just across the Drina River from Zvornik, and he
23 declared: "Dear Chetnik brothers, especially you across the Drina River,
24 you are the bravest ones. We are going to clean Bosnia of pagans and show
25 them a road which will take them to the east, where they belong."
1 In April 1992, Branko Grujic, the president of the Crisis Staff in
2 Zvornik, requested SRS volunteers to come to Zvornik, and the accused
3 personally approved this request. We will hear from witnesses that SRS
4 leaders brought SRS volunteers from Loznica, commanded by Dragan
5 Cvetinovic, to Zvornik. Subsequently, when the war broke out, local Serbs
6 joined those SRS/SCP volunteers.
7 You will also hear evidence that SRS/SCP volunteers took part in
8 the violent takeover of Zvornik town and fought alongside Arkan's Tigers,
9 the local TO and the JNA and police forces. The SRS/SCP volunteers were
10 commanded by Miroslav Vukovic, also known as Cele. Both Miroslav Vukovic
11 and Dragan Cvetinovic were promoted in the same order that you now saw a
12 couple of times. Mr. Vukovic is under number 5. He's named as the
13 commander of the units of the Serbian Chetnik Movement and the SRS in
14 Slavonia, Baranja and Western Srem. And he's also mentioned in eastern
15 Slavonia. And we have number 16, Dragan Cvetinovic, who is mentioned as
16 commander of the Chetniks -- Chetnik unit from Loznica. We also have the
17 photos of these two persons. One is Exhibit 3036. We see here in the
18 middle, Miroslav Vukovic, and we have the photo of Cvetinovic as well.
19 And he is seen here next to Mirko Blagojevic.
20 The Prosecution will provide evidence that the SRS and SCP
21 volunteers took part in every mass killing that I just mentioned.
22 Many witnesses will refer to the crimes committed by the Yellow
23 Wasps, and the Prosecution will provide witness evidence that the
24 so-called Yellow Wasps, led by the Vuckovic brothers, were SRS/SCP
25 volunteers to begin with. They had joined the SRS in 1991 and had been
1 indoctrinated by Seselj's hate propaganda. They had fought already in
2 Croatia, and it was the SRS headquarters in Belgrade that brought them to
4 Finally, the Prosecution will provide evidence that throughout the
5 fighting and the persecution campaign in Zvornik, the accused was
6 regularly provided with information by SRS officials around Zvornik. Some
7 of the proceeds from the looting went to the fund of the SRS in Belgrade.
8 JUDGE ORIE: Madam Uertz-Retzlaff, I'm looking at the clock. It's
9 a quarter to 2.00.
10 MS. UERTZ-RETZLAFF: Yes.
11 JUDGE ORIE: So we have to finish for the day.
12 You used, until now, approximately 1 hour and 40 minutes, which
13 means that there are 50 minutes remaining for tomorrow. Two and a half
15 MS. UERTZ-RETZLAFF: Yes. In relation to what I have to say, but
16 there's also --
17 JUDGE ORIE: No, no, the Prosecution was granted two and a half
18 hours for the opening statement. The 8th of November, Status Conference,
19 I think I said the Prosecution should not take more than two and a half
20 hours for its opening statement, which means 150 minutes. You've used 100
21 minutes by now, so another 50 minutes remaining.
22 MS. UERTZ-RETZLAFF: Your Honour, yes, that's right. I misheard.
23 I heard you say 15 minutes, and I was thinking how can we finish. Sorry.
24 I misheard, 50 minutes that's fine.
25 JUDGE ORIE: So that means we'll resume tomorrow morning at 9.00,
1 in this same courtroom, and you'll then have until ten minutes to 10.00 to
2 finalise your opening statement. We'll then, depending on whether Mr.
3 Seselj is in this court or not, hear his unsworn statement. Since we have
4 to take an early break tomorrow, if we will not finish tomorrow, as I said
5 before, we will then continue on Friday afternoon.
6 We stand adjourned.
7 --- Whereupon the hearing adjourned at 1.45 p.m.,
8 to be reconvened on Tuesday, the 28th day of
9 November, 2006, at 9.00 a.m.