Tribunal Criminal Tribunal for the Former Yugoslavia

Page 12166

 1                           Wednesday, 26 November 2008

 2                           [Open session]

 3                           --- Upon commencing at 2.18 p.m.

 4                           [The accused entered court]

 5             JUDGE ANTONETTI: [Interpretation] Madam Registrar, please call

 6     the case.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  Good afternoon to

 8     everyone in the courtroom.  This is case number IT-03-67-T, the

 9     Prosecutor versus Vojislav Seselj.

10             JUDGE ANTONETTI: [Interpretation] Thank you.

11             Today is Wednesday.  Let me greet first the representatives of

12     the OTP, Ms. Dahl and Mr. Mundis.  Good afternoon, Mr. Seselj, and good

13     afternoon, witness in Belgrade.  I can see you on my screen.

14             We are going to proceed with the cross-examination of the

15     witness.

16             Mr. Seselj, you may proceed.

17                           WITNESS:  ALEKSANDER STEFANOVIC [Resumed]

18                           Cross-examination by Mr. Seselj:  [Continued]

19                           [Witness testified via videolink]

20        Q.   Mr. Stefanovic, we will now briefly deal with the method of

21     financing, first of all, the Serbian Chetnik Movement, and later of the

22     Serbian Radical Party.  As you were then informed about all these party

23     affairs, you ought to be aware that in 1990, I personally funded all the

24     expenses of the Serbian Chetnik Movement; is that correct?

25        A.   Mr. Seselj, if I may say something before this.  The torture

Page 12167

 1     which I experienced yesterday before my testimony continued during the

 2     night and this morning.  At about 2130 hours this evening, I wasn't at

 3     home, but my wife and my mother-in-law and father-in-law were at home.

 4     The police came to our door, or a para-police.  I really don't know who

 5     sent them.  But I've been living in that flat for years, and never have

 6     the police come to my door, except tonight.

 7             Allegedly, Borislav Nikolic sued me for offending His Honour or

 8     something like that.  And my wife alarmed me this morning, told me not to

 9     come home.  She said things were getting serious, as she's a lawyer by

10     profession.  I spent the night outside my home.

11             However, the Republican Parliament, after two hours of debate --

12     or, rather, for two hours they debated about me, and then

13     Tomislav Nikolic called upon the state organs of Serbia to allegedly

14     investigate my property.  They said that I had obtained my property by

15     suspect means, that it should be confiscated.  And he called upon the

16     state to put an end to witnesses like me.

17             This is now an orchestrated campaign against me, and in the

18     course of today or in the next few days, the state prosecutor will

19     probably react.  Whether this is a directive that has come from The Hague

20     or somewhere else, I don't know, but this is no longer a case of

21     paranoia.

22             The police came to my door at 2130 to arrest me, to bring me in.

23     If the police don't know I'm testifying and that The Hague is superior to

24     our judiciary, there's nothing for me to say.

25             Another matter is the following:  There was a verbal attack on me

Page 12168

 1     from the rostrum in the Assembly, and this was wholly inappropriate.  And

 2     the state organs were called upon to investigate me.  One can see that

 3     there is something that has been agreed behind the scenes.

 4             You can arrest me right now and take me wherever you like, but I

 5     feel much worse at present than the accused Seselj does, or anybody else,

 6     for that matter.

 7             JUDGE ANTONETTI: [Interpretation] Witness, two things.

 8             I can do nothing with respect to the discussions that took place

 9     at the Parliament, but when it comes to what happened last night at 9.30

10     p.m., we are going to inquire with the relevant authorities about what

11     happened.  This is the first time I've heard about this.

12             So to sum up, the Parliament members do whatever they like.  We

13     have nothing to say about this.  But about the police coming to your

14     door, we are going to try and find out what happened exactly and under

15     what circumstances that took place.

16             Mr. Seselj, please proceed with your cross-examination.

17             MR. SESELJ: [Interpretation]

18        Q.   Mr. Stefanovic, you and I have been involved in the political

19     life of Serbia for a long time, and I hope you're not surprised by

20     anything that's happening to you now.  Is this what you expected when,

21     two years ago, you decided to stop being obedient to Djindjic and his

22     heirs and refused to bear false testimony against me; did you expect to

23     suffer unpleasantness?

24        A.   Well, there's nothing to expect or not to expect.  I'm telling

25     you specifically, the moment when, through Judge Dilparic, I sent written

Page 12169

 1     confirmation to The Hague Tribunal in what capacity I wanted to appear

 2     before the Tribunal, the following things have happened.  I'll give you a

 3     list now.

 4             In one night, my car, valued at 65.000 Euros, which was only five

 5     months old, went missing.  It was taken away not by thieves or criminals,

 6     but I assume by state organs.  I won't name them now.  My car was stolen.

 7     My documentation, belonging to my company, was stolen, as was an

 8     expensive watch I had.  And when I made a statement, the police did not

 9     oppose what I said, they were silent, and this confirmed that I was

10     right.

11             And then when the first subpoena arrived a month or a month and a

12     half ago, that same moment the criminal police, dealing with economic

13     crime, and the financial police arrived at my company, as well as some

14     sort of state police and inspectors.  Seventeen different inspections

15     arrived.  They dragged me out.  They interrogated me.  I could not devote

16     myself to my business or to preparations for this testimony.

17             When the second subpoena arrived, and I really don't know why

18     subpoenas had to be sent to me, because I never tried to run away from

19     this Tribunal, but quite simply the police arrived in my company and

20     handed over to me this subpoena, and I was -- I'm only then expecting an

21     avalanche, you who concealed this fact.  This is now very serious,

22     because my life is at stake and my family.

23             What do I care about The Hague Tribunal and trials and so on?

24     Yesterday, you kept silent about this.

25             In 1994, there was a polemic between the UN and I, a tete-a-tete,

Page 12170

 1     and you can deny that. (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11             JUDGE ANTONETTI: [Interpretation] Witness --

12             THE WITNESS: [Interpretation] Just a minute, let me tell the

13     accused.

14             JUDGE ANTONETTI: [Interpretation] Witness, let me stop you.

15     You've just mentioned Mr. Nikolic, using totally inappropriate language

16     about him.  You can talk about his political views, but you can't go into

17     any personal attacks against him.  We are going to redact that part of

18     your statement.

19             Mr. Seselj, you have the floor.

20             THE ACCUSED: [Interpretation] Mr. President, I wanted to let

21     Mr. Stefanovic know that I'm not willing to discuss this topic.  But I

22     absolutely disagree with your redacting the record, because

23     Mr. Stefanovic is not speaking about what he measured, himself, but what

24     was published in the newspapers and what was scandalous.  So please do

25     not redact the transcript, because that's been done too often in these

Page 12171

 1     proceedings.  I'm truly not interested in this topic, and I don't want to

 2     discuss it.

 3        Q.   Mr. Stefanovic --

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, the Trial Chamber

10     has been extremely clear.  Please refrain from any personal attacks about

11     the behaviour or the sex life of anyone.  You're not going here to settle

12     accounts with Mr. Nikolic or whoever.  You are not going to manipulate

13     this Trial Chamber.

14             And what happens in this courtroom is being broadcast in your

15     country, so I'm going to be very clear.  In your cross-examination, you

16     are to focus only on what he said in his statements of 2003 and 2006, and

17     you also have to focus on your responsibility in the charges levelled

18     against you.

19             The attacks against Mr. Nikolic and Mr. Vucic have nothing to do

20     in these proceedings.  Do not use this Tribunal to settle accounts in

21     your own country.

22             We are all aware that you held very high political positions.  We

23     know that you're a prominent political leader in your country.  Please do

24     not overstep the mark, and proceed with your cross-examination, focusing

25     on everything related to the SRS during the years of 1991, 1992, or even

Page 12172

 1     1993.  That's what we are interested on.

 2             THE ACCUSED: [Interpretation] It's not clear to me in what way

 3     I'm dealing with Nikolic and Vucic through these proceedings and settling

 4     accounts with them.  You are now holding this against me.  I did not

 5     proof this witness.  This is a witness of the Prosecution, not of the

 6     Defence.  He should have been a Defence witness, and he himself wanted to

 7     be a Defence witness.  He refused to be a Prosecution witness, and he was

 8     brought here under duress.  But I did not proof this witness, and I,

 9     myself, am surprised by what the witness is saying now.  And yet you're

10     telling me that I am settling accounts with people.

11             Yesterday, I prepared the questions I was going to put during

12     cross-examination, which has nothing to do with what has been said now,

13     so why are you holding this against me?

14             JUDGE ANTONETTI: [Interpretation] Ms. Dahl.

15             MS. DAHL:  Your Honour, the witness is not here under duress.  He

16     is here under order of the Trial Chamber to appear and give testimony.

17             THE ACCUSED: [Interpretation] Who said that the witness had been

18     arrested?  What is this an objection to?  I don't understand this.  Did I

19     say the witness had been arrested?  I didn't say that.  Now, why this

20     objection?

21             JUDGE ANTONETTI: [Interpretation] Well, Mr. Seselj, please

22     proceed with your cross-examination.

23             MR. SESELJ: [Interpretation]

24        Q.   Mr. Stefanovic, it was clear to me in advance that you were going

25     to have major problems, as do other witnesses who refuse to be

Page 12173

 1     Prosecution witnesses and ask to be Defence witnesses.  I am not in a

 2     position to help you in solving these problems or to protect you from

 3     here, but what I know from my own experience is that the force of the

 4     public is the best protection against such problems.

 5             If you're able to, now please focus on my questions.

 6             JUDGE ANTONETTI: [Interpretation] Ms. Dahl.

 7             MS. DAHL:  Mr. Seselj is giving advice and information to the

 8     witness, rather than asking questions pertinent to the indictment.  I'd

 9     ask that his cross-examination be focused on the relevant issues and not

10     directed at the witness.

11             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, please put your

12     questions to the witness.  You said earlier that you were going to put

13     questions to him.

14             MR. SESELJ: [Interpretation]

15        Q.   Mr. Stefanovic, are you able to answer my specific questions?  If

16     not, I will give up my cross-examination right away.

17        A.   Well, look here.  Even if I were in a much worse physical and

18     psychological state than I am now, I would be able to answer your

19     questions and the questions of the Court.  But it's incredible that

20     neither yesterday nor today have I been able to put together a sentence

21     about the situation concerning my family, my property, my very life, but

22     all this is being passed over as if the campaign against me is something

23     that should not be interfered with.  That campaign has been transferred

24     to lower-level organs in Serbia, the Republican prosecutor, the police,

25     or informal para-police groups or para-secret service groups.  Well, not

Page 12174

 1     for a single moment have I been allowed to say anything, either yesterday

 2     or today.  I'm being accused of being like this or like that.

 3             A woman came to my door unannounced when I was not at home.  The

 4     police came in the middle of the night, when everybody was getting ready

 5     for bed, and I'm not allowed to talk about this.  I'm not allowed to tell

 6     the reason why I left the party.  It began with these staffing solutions,

 7     and they said, "Keep quiet.  What are you talking about?  Answer

 8     questions about silly things," about things I never said or signed.

 9             Yesterday, I analysed those signatures.  They're not my

10     signatures.  They were scanned and only copied onto the Serbian language,

11     because when I was signing, there was no translation into Serbian.

12             JUDGE LATTANZI: [Interpretation] Witness, yesterday you,

13     yourself, confirmed that this was, indeed, your signature.

14             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, please put

15     questions to the witness to develop your case.

16             MR. SESELJ: [Interpretation]

17        Q.   Mr. Stefanovic, we are now talking about the method of funding

18     first the Chetnik Movement and then the Serbian Radical Party in 1991 and

19     1992.

20        A.   Very well.

21        Q.   I asked you whether you were aware of the fact, in 1990, even

22     before you and your party collectively joined the Serbian Chetnik

23     Movement, that I personally funded all the activities of the Serbian

24     Chetnik Movement?

25        A.   That's correct.

Page 12175

 1        Q.   And do you know how I came by the money I used to fund this

 2     movement?

 3        A.   Yes, I do.

 4        Q.   How?

 5        A.   From the lectures that you held mostly in Australia and America.

 6        Q.   You know that I gave 97 lectures in Canada, America, Australia,

 7     France, Germany, Switzerland and Great Britain in 1989, 97 lectures, and

 8     that two of my books were published abroad, one in Australia and one in

 9     Canada; is this correct?

10        A.   Yes.  Part of that European tour I attended.

11        Q.   That was the second tour.  We'll come to that.

12        A.   Very well.

13        Q.   I'm now speaking about the year 1989.  Is that an indisputable

14     fact?

15        A.   Yes, correct.

16        Q.   As we were on good terms and close in those years, you know that

17     all the money I made, I didn't bring back to the homeland with me, that I

18     left some of that money in Canada and America; is that correct?

19        A.   Yes.  I remember there was a sum of about $100.000, maybe a

20     little more, maybe a little less.

21        Q.   I will be precise.  When interest was added, it came to $70.000

22     in a bank in New York, and this was blocked illegally when I came here to

23     The Hague.  $42.000 I withdrew from Canada in the early 2000s, and

24     another sum, $15.000, from a bank in California I withdrew when I bought

25     the house in Batajnica.

Page 12176

 1             You remember that the two of us together had a tour of Western

 2     Europe in January and February 1991; is that correct?

 3        A.   Yes.

 4        Q.   We gave lectures to Serb migrant workers in Austria, Germany,

 5     Switzerland and France, and to Serbian emigres in Great Britain; is that

 6     correct?

 7        A.   Yes.

 8        Q.   We stayed there for longer than a month or a month and a half?

 9        A.   Forty-four days.

10        Q.   And at these lectures, were tickets sold and were donations

11     collected, and were newspapers -- was the newspaper 'Greater Serbia'

12     sold, and were my books sold, and all this went into the party cash box?

13        A.   Yes.

14        Q.   And you brought a large quantity of cockades which you sold, and

15     this was your personal revenue, because you were unemployed at the time

16     and had no income; is that correct?

17        A.   Yes.

18        Q.   Do you remember what sum of money we collected when we came back

19     to the homeland?  If you can't remember, I seem to remember that it was

20     47.000 German marks, from different currencies, but that was the total in

21     German marks.  Am I right?

22        A.   Well, if I give it some thought, I think it was about 47 or

23     48.000 German marks.

24        Q.   Was that the first money that we used to finance the Serbian

25     Radical Party in 1992?

Page 12177

 1        A.   Yes.  Immediately upon our arrival, it was set up, and you used

 2     that money for that.

 3        Q.   As the secretary-general, yourself, your basic duty was to

 4     collect financial resources for the Serbian Radical Party; right?

 5        A.   Yes.

 6        Q.   Now, in the Serbian Radical Party, did we pay strict attention to

 7     every dinar spent, every dinar coming in and every dinar coming out?

 8        A.   Yes.  Since there weren't many of those dinars, we did pay strict

 9     attention to expenditure and incoming financial resources.

10        Q.   Did we have two types of record-keeping; one was on the official

11     account of the Serbian Radical Party and the Social Accounting Service,

12     and the other was internal records within the party about the monies

13     coming in?

14        A.   Yes, and in the Social Accounting Service account, I had the

15     right to sign for money to be withdrawn.

16        Q.   And you did this for the party; right?

17        A.   Yes.

18        Q.   Now, is it true and correct that we were very strict towards

19     anybody who would try to embezzle even one dinar of party money?

20        A.   Yes.

21        Q.   Do you remember that Vojin Vuletic, for example, at the end of

22     1992, tried to appropriate 2.000 German marks belonging to the party and

23     that he was uncovered in doing this by Secretary Ducic, and that he had

24     to relinquish all his party posts and give up his work in the party?

25        A.   Well, that was 2.200 German marks that an immigrant worker --

Page 12178

 1     migrant worker had brought from Berlin.  Dobric was his name, I think.

 2     And this was written into the book the secretary kept, and when Vojin

 3     embezzled this, he rubbed out the part -- the money trail.  And when he

 4     was uncovered, he tendered his resignation, himself, I think, and then he

 5     went off and became a member of the Democratic Party.  But soon

 6     afterwards, he became ill and then left again.

 7        Q.   And then Vojin Vuletic attacked us in the media when he left the

 8     party; do you remember all that?

 9        A.   [No verbal response].

10        Q.   In the weekly magazine Knin, on television in some newspapers; do

11     you remember that?

12        A.   Yes.  He moved and joined the Democratic Party.

13        Q.   Do you remember that my suggestions were that the attacks

14     launched by Vojin Vuletic, that we should not react to them at all

15     because I knew that he was, in fact, not a well man?  So do you remember

16     that we didn't launch counter attacks and didn't respond to those attacks

17     of his, not by a single word?

18        A.   Yes, I can confirm that, that despite the attacks that he

19     launched when Vojin Vuletic was hospitalised, when he went to the

20     municipal hospital, that the two of us, and I think somebody else went

21     with us, but, anyway, we went to visit him in hospital, after -- despite

22     those attacks.

23        Q.   Vojin Vuletic afterwards died, did he not?

24        A.   He was in hospital, he was hospitalised, and, yes, he did die.

25        Q.   He suffered from a heart condition; right?

Page 12179

 1        A.   Yes.

 2        Q.   Now, do you remember, several years after that, my political

 3     adversaries, my political enemies, when they were angry with me, attacked

 4     me through the media and said that I had liquidated Vojin Vuletic; do you

 5     remember that?

 6        A.   Yes, I do.  I do remember that, yes.

 7        Q.   Yesterday, you were talking about the killing of Pasko Jovic, who

 8     is the wife of Slobodan Jovic; is that right?

 9        A.   Yes.

10        Q.   Now, did we throw Slobodan Jovic out of the Serbian Radical Party

11     already in 1993 and justified doubts that he was working for the

12     Security Service of Serbia?

13        A.   Yes.  Before he came to the Serbian Radical Party, he was an

14     active member of the Serbian Security Service.  He was sent abroad to

15     carry out liquidations of our political enemies.  And we did not know all

16     this before he became a member, but when we did learn about his past,

17     I think it was in 1993 -- maybe I'm wrong.  Anyway, to be quite frank, he

18     was a man who had a very negative past and was ready to do anything.  He

19     had very little education, although he did have some diploma or other

20     saying that he had graduated from, I think, the Engineering Faculty, but

21     in fact he was ready to take on anything.

22             And later on -- I don't think you know this, but in 2000 -- or,

23     rather, from 1999 to the year 2000, he showed his true colours, and I

24     felt them on my very own skin.  We were attending the party Saint's Day,

25     and his party was the Nikolic Pasic Radical Party, I believe.  Anyway, in

Page 12180

 1     the presence of my party colleagues, Miloje Mikisevicevic [phoen] and

 2     Mladen Bakic, in the presence of a large number of people from the very

 3     top positions of the DB Serbia, he said very ugly things about you.  And

 4     then at one point, after having a brandy to drink, he started attacking

 5     me, too, and it was all I could do to escape that.

 6        Q.   Well, we'll have to cut that story short, the story about him.

 7     But what is interesting here and what it says in the alleged statement

 8     written by the Prosecution, which they say you signed, is -- refers to

 9     the killing of his wife.  He had a very beautiful young wife, did he not,

10     and she owned a bookstore somewhere in Rakovica; right?

11        A.   Well, yes, it was near my flat, and I explained that yesterday.

12             After the statement, I conducted a detailed investigation.

13        Q.   We don't have to repeat that.  We heard what you said yesterday.

14     I remembered it all, so we needn't go into that again.  But what I'm

15     concerned about is this:  Do you remember that for the first time, this

16     man, Slobodan Jovic, for whom we know without doubt that he worked for

17     the Security Service, during the silence prior to the elections, at the

18     elections -- presidential elections in 1997, when I was a candidate who

19     entered into the second circle, second round, that he published, in a

20     daily paper called 'The Daily Telegraph,' on half a page, which was a

21     violation of all the electoral laws, that I had killed his wife, and is

22     that the first time he came out with that assertion?

23        A.   Now, I would be lying if I said I knew exactly when that

24     happened, but I know an article appeared in the 'Sunday Telegraph,' but I

25     don't know -- or 'Nedelja Telegraph,' but I don't know but I don't know

Page 12181

 1     when that was, whether it was the pre-electoral campaign or the silence

 2     before the elections.

 3        Q.   All right.  If you don't know for sure, we can move on.

 4             Now, Mr. Stefanovic, was I ever known as a greedy man; greedy,

 5     wealth, money, luxury living?  Was that something that I was known for?

 6        A.   I always said how reticent you were and how you didn't like

 7     spending money, and in fact you preferred to take your meals at home

 8     rather than spend money in restaurants and so on.

 9        Q.   So what you're saying is that I led a modest life; is that right?

10        A.   Yes, very modest.  You wouldn't flaunt your money around.  You

11     were frugal.

12        Q.   Did I ever drive expensive cars or have any other luxuries,

13     luxury items?

14        A.   As far as I know, no.

15        Q.   And is that how -- the spirit in which I led the party, too, that

16     the party should be frugal, save money, keep a strict reign on money and

17     just use it for actual party needs?

18        A.   While I was there, yes, that is true.

19        Q.   Now, could anybody ever bribe me, a politician or some newfangled

20     tycoon or anybody like that?  Was I susceptible to bribery, was I greedy

21     in any way?

22        A.   No, and I can even quote examples.  When somebody tried to do

23     something like that, that they were publicly held to task.

24        Q.   And when Zoran Djindjic forced you to give your statement to

25     The Hague investigators against me and to discredit me politically, then

Page 12182

 1     one of the forms of that political discreditation, pursuant to his

 2     suggestions, was to show me up to be as a greedy man who loved money more

 3     than his family and his party; isn't that right?

 4        A.   Well, it's like this:  There's my statement.  I went there

 5     contrary to my -- against my own will to give this statement to The Hague

 6     Tribunal.  I don't know what was awaiting me there.  I thought that they

 7     would hide things or -- I don't know.  I resisted.  This went on for two

 8     or three days, this resistance on my part, but they had focused on me so

 9     strongly that I had to give in.  And the last conversation that I had,

10     and I'm sure there's a witness of that, I was asked whether there was

11     written trace of that, there's oral trace, because I went there with

12     Mr. Batic, who at that time was the minister, and I asked for Mr. Batic's

13     protection because I said I simply didn't want to appear in the Hague

14     Tribunal, not because of Seselj, not because of who knows what, but

15     because of me, personally, because if I did that, I would slam the doors

16     to my political activity by doing that.  It's what I live on.  I have

17     dealt in politics for 20 years.  And he said, "Well, if Zoran promised

18     you that you needn't appear, then why would you?  And you know what the

19     role of Carla Del Ponte was; not only the influence on the DOS, but on

20     the 5th of October preparations and so on."  And then as I was well aware

21     of all those things, I agreed to talk to them.

22             But this has turned into a never-ending set of games, and when I

23     was thinking of this -- conducting this discrimination in the proper way,

24     in a very correct way, then I had to use some political tricks.  I had to

25     resort to political ruse and say that the man was greedy.

Page 12183

 1             JUDGE ANTONETTI: [Interpretation] Ms. Dahl.

 2             MS. DAHL:  I would like to remind the witness that he is under

 3     oath and can be prosecuted for perjury.

 4             JUDGE ANTONETTI: [Interpretation] Witness, you are under oath.

 5     You know better than anyone that you could be prosecuted for perjury.

 6     You know that, don't you?  So are you telling the truth right now?

 7             THE WITNESS: [Interpretation] Please explain to me why the

 8     Prosecutor -- Madam Prosecutor doubts that I'm telling the truth.  Why is

 9     that?  Where does she feel that that has been the case?

10             JUDGE ANTONETTI: [Interpretation] I'm going to explain to you

11     why.

12             I have before me a statement which you gave in 2003, and you

13     repeated it in 2006.  And in that statement, you said that Mr. Seselj was

14     more interested in money than in politics.  That's what you stated then.

15             THE ACCUSED: [Interpretation] And "more than his family," that's

16     what it says there too.

17             THE WITNESS: [Interpretation] Mr. President --

18             JUDGE ANTONETTI: [Interpretation] Yes, "family" too, I saw that,

19     what you stated, and you added "or your family," but that's secondary.

20     I'm interested in the money matter.

21             And then Mr. Seselj asked you questions as to the financing of

22     the SRS, and it seems that, based on his questions, the SRS was financed

23     by the product of lectures he gave throughout the world.  And you know

24     that there are bank accounts abroad, into which the outcome of the

25     lectures might have been transferred.

Page 12184

 1             So with regard to what you said in 2003 and 2006, there is an

 2     inconsistency with regard to your statement now, and the Prosecutor

 3     recalls you that if you were to say something that is not true, you can

 4     be prosecuted for perjury.

 5             You are under oath, so I'm asking you whether you are telling the

 6     truth now.  Can you confirm that?

 7             THE WITNESS: [Interpretation] Your Honour, what I'm saying now,

 8     I'm saying under oath, and it's absolutely the truth.  The statement

 9     given -- well, I wasn't under oath then, I hadn't taken the solemn

10     declaration then when I wrote the statement.  So please believe me when I

11     say that this was geared towards discrediting Mr. Vojislav Seselj, so

12     that statement was just given for those reasons exclusively.

13             Now, I am under oath, I am telling the truth.  We can look at the

14     SD -- the accounts, we can go through the accounts and see where all

15     these accounts are, all the cash inflow and expenditures, and things like

16     that, the monies spent on television programmes, advertisements,

17     pamphlets and so on.  We have the SDK, Social Accounting Service,

18     accounts, and we also have our own records in the notebooks that we kept.

19     We can go through all that.

20             And I am telling the truth.

21             JUDGE ANTONETTI: [Interpretation] We know that you say you're

22     telling the truth, Witness.

23             Very well.  Proceed, Mr. Seselj.

24             MR. SESELJ: [Interpretation]

25        Q.   I think that we've dealt with the question of financing, then.

Page 12185

 1     I'd just like to focus on a number of details still.

 2             Do you remember that when the political parties in Serbia were

 3     being formed, that the pro-Western political parties were financed from

 4     abroad by different governmental and nongovernmental organisations; do

 5     you remember that?

 6        A.   Yes, but not our party.  Our party wasn't financed that way.

 7        Q.   The Socialist Party and Kindred Parties, the League of Communist

 8     Movement for Yugoslavia and the Yugoslav Leftist Party, had at their

 9     disposal all these states institutions, did they not?

10        A.   They had firms within the state.

11        Q.   The Serbian Radical Party, did it ever have any large sponsor or

12     financier who, for example, in the space of one year, provided it with a

13     sum larger than 10.000 German marks, for instance, some financier or

14     company or whatever?  Can you quote any such example or any such case?

15        A.   I know full well how I collected money, that it was very arduous

16     and it was difficult to make ends meet, and the expenditure was always

17     greater than the money coming in.  It was difficult.  There was the

18     financing of the Greater Serbia for posters.  I gave 50.000 to Tijanic,

19     for instance, when he was director of TV Politika, and then Studio B,

20     Stojdinovic [phoen], just for one campaign, and that was in 1993;

21     December, in fact.  Or 1994, perhaps.  I'm not quite sure.

22             JUDGE ANTONETTI: [Interpretation] I have a question for the

23     witness, Mr. Seselj.

24             At the time you were secretary-general of the Serbian Radical

25     Party, does that mean that you could control its budget?  Was that part

Page 12186

 1     of your remit?

 2             THE WITNESS: [Interpretation] It was like this:  Not only did I

 3     have authority to control it, but I was the number-one man for collecting

 4     money, so I had to go around.  I kept the treasury, I was in charge of

 5     the treasury, and so on.

 6             JUDGE ANTONETTI: [Interpretation] One moment.  You're going to

 7     see why I'm raising this issue.

 8             Witness --

 9             THE WITNESS: [Interpretation] [Realtime translation

10     continues] ... deposited at the Social Accounting Service.  It was the

11     only signature deposited there, which meant that I could withdraw money

12     on the basis of that signature.

13             JUDGE ANTONETTI: [Interpretation] Witness, we heard a witness who

14     was a member of the Serb Radical Party, and he said the following:  I say

15     this from memory, because I don't have the transcript before me, but this

16     question just crossed my mind.  But I know the case file inside out, so

17     I can make a reference to it without having the transcript in front of

18     me.

19             That witness explained to us that it would happen that the SRS

20     would send some of its men, volunteers, for them to guard plants,

21     factories.  He mentioned the guarding of a factory which gave rise to

22     donations, sums of money, for the SRS.  You were in charge of keeping

23     accounts.  You've just confirmed that.

24             Do you have any memory, any recollection, of the SRS receiving

25     monies from companies as part of surveillance activity by SRS volunteers?

Page 12187

 1             THE WITNESS: [Interpretation] That's a very good question,

 2     Mr. President.  Bring that witness into the courtroom here so that he can

 3     face me.  Who is this witness that says things like that, and who made

 4     him say things like that?  That's all lies, and I say that with full

 5     responsibility.

 6             I have taken the solemn declaration here.  I'm a Christian.  I

 7     never lie.  So, Your Honour, you are dealing with a man here who does not

 8     lie, who never lies.

 9             So that man was saying ludicrous things.  He was telling

10     untruths.  And for as long as I've been a Radical, I've never accepted

11     money from any companies.  What companies, what guarding of factories,

12     what's he all about?  That's just not true.  Bring him in here so that he

13     can face me, and you can close the session.

14             MR. SESELJ: [Interpretation]

15        Q.   Do you remember, Mr. Stefanovic, that as the secretary-general of

16     the Serbian Radical Party in those years, you travelled to Australia and

17     spent a month there collecting donations for the party?

18        A.   Yes.  I was there for about two and a half months.

19        Q.   Well, in my recollection, it was a month, but all right.  Do you

20     remember that you brought from Australia about 30.000 German marks?

21        A.   Yes.

22        Q.   That's how much you managed to collect.  Do you remember the

23     largest amount you collected at one of your tours?  This was during the

24     pre-election campaign in 1993, when you came back from Berlin.  Do you

25     remember the sum you brought to the party treasury?  What was the sum?  I

Page 12188

 1     don't want to put leading questions to you.  Do you recall that?

 2        A.   I know I gave all the money to Tijanic.  I can't recall the

 3     precise amount, but I know I travelled from Berlin to Budapest by plane,

 4     and then as there were no planes flying to Belgrade, I came from Budapest

 5     to Belgrade by coach, and the election campaign was already on.  I handed

 6     over the money.  I can't remember the amount and the year.  It's hard for

 7     me to remember those figures.

 8        Q.   Let me jog your memory.  You brought 50.000 German marks back

 9     from Berlin, and we went to see Tijanic together.  We went to Studio B,

10     the television, and we went to 'Politika,' and we bought ads and we

11     bought time, air time, for our broadcasts.  And that was a time of huge

12     inflation, comparable to that in Weimarkt Germany; is that correct?

13        A.   I remember that the money I brought back did not cover those two

14     television broadcasts.  I know that we had to add more money to those

15     50.000 marks.

16        Q.   And do you remember how surprised they were in the 'Politika' TV

17     when we brought various currencies; German marks, French francs, Swiss

18     francs, Italian lira, Austrian shillings, Danish crowns, Swedish crowns.

19     What else was there?

20        A.   Dutch guilders.

21        Q.   And, yes, Greek drachmas.  Do you remember that we brought along

22     various currencies to pay for those TV broadcasts?

23        A.   Whatever was in the treasury, we brought along.

24        Q.   Did we always go together when those payments were made and those

25     contracts concluded?

Page 12189

 1        A.   Yes, and I carried the money.

 2        Q.   Well, you were at that time the most reliable man for money.

 3        A.   Well, I -- I was strong enough to carry the bag.

 4        Q.   Thank you, Mr. Stefanovic.  We won't talk about finances anymore.

 5             So that was the first form of my political discreditation on

 6     which Zoran Djindjic insisted.  His aim was to eliminate me completely

 7     from the political life of Serbia; is that correct?

 8        A.   Yes.  In 2001, I personally proposed, because they kept saying

 9     that the Serb Radical Party was upsetting democracy, the young democracy,

10     the fledgling democracy in Serbia, and so on and so forth, I advocated

11     the proposal that the state prosecutor ban the work of the Serbian

12     Radical Party by a decree.  And then a group of legal experts was

13     established, which was supposed to draw up a text which would be sent to

14     the prosecutor, and I think that this text was compiled referring to

15     certain provisions of the Constitution and the various laws, I don't know

16     what.  And then they evaluated, and this was not something I wanted.  I

17     would have passed that law, but they said that it would be no good, that

18     you would continue your work in other ways, that you would work

19     underground, that you would continue your opposition work by other means.

20     And someone from the top leadership of the state gave up this idea, and

21     then they tried to eliminate you in other ways.

22             There were some conversations which I heard with my own ears,

23     where it was said that the Radical Party should not be interfered with,

24     that it was sufficient to remove Seselj; that some foreign intelligence

25     organisations were already influencing the Radical Party.  And a year and

Page 12190

 1     a half or five years ago, I said that to some members of your party.  I

 2     said that in 2003.

 3             There was an instructor called Steve or Steven, an American

 4     intelligence agent, who was brought by Zoran Korac to his flat, and

 5     before the elections for the mayor of Belgrade, they simulated a

 6     scenario.  Zoran Korac pretended to be the television announcer, and this

 7     Steven, who was a drug addict and a homosexual and who was later found

 8     dead in a hotel, he pretended to be Bogdanovic.  What was his name, Nenad

 9     Bogdanovic.  And they did a role play, simulating the television

10     broadcast that Vucic was supposed to have with Bogdanovic.

11             I drew the attention of some people in the top party leadership

12     to this, but they didn't pay much attention to it.

13             Later on, foreign intelligence services exerted influence.  When

14     a group of the Serbian Radical Party went to Strasbourg, to the European

15     Parliament, and then I had clear information as to who, when and was

16     having meetings when they went to in Strasbourg.  Foreign intelligence

17     agents meant them there.  Among them, Mr. Nikolic was recruited by a

18     intelligence agency.  So it wasn't just our own state security service

19     that took part in Vukic and Nikolic's new political party.

20             I was well informed.  Mr. Seselj, you have not been in Serbia for

21     several years, and you don't have the best information.

22             Yesterday, I saw how wrong you were when you put forward the

23     information about those three agents in Pristina.  You don't know that

24     America and Russia agreed to have their interest zones in the Balkans.

25     Russia got Serbia; America got Kosovo.  But some Jewish and Russian

Page 12191

 1     intelligence structures contacted Germany, and they want to expel America

 2     from its influence in Kosovo.  They want Germany back there.

 3             You know that for a long time, there's been a love affair between

 4     Germany and Russia.  It's been very intensive over the past few years.

 5        Q.   Well, Mr. Witness, we won't deal with geopolitical topics now,

 6     because my time is running out, and I doubt that this time the Chamber

 7     will extend my time.  I would like to ask you to focus on more specific

 8     questions.

 9             When did you first learn that an indictment was being prepared

10     against me in The Hague?  You were one of the leaders of the DOS, you

11     were in the very top leadership there, and you probably had this

12     information.

13        A.   I was in the top political leadership in DOS, and there were many

14     people there who were very inexperienced.  They had never been in

15     Parliament before, and I had good contacts with Zoran Djindjic, the

16     prime minister, because his sister, Slavica, who was married in my

17     village, the last name was Filipovic.  And I visited his uncle Dusanic in

18     Bosnia, and Ruzica, his wife, came from Valjevo.

19             And you, yourself, know that in 1990, while Zoran was still

20     wearing a ponytail and earring and jeans, that we were on good terms with

21     him.  For a long time, this went on.

22             They rejected my idea which I still say would have been better

23     had the Serbian Radical Party been banned in 2001, and the Socialist

24     Party as well.  They would have been eliminated from the political scene

25     for a few years.  But they took power and they, themselves, drowned in

Page 12192

 1     that power.

 2             THE INTERPRETER:  The speakers are overlapping.  It's impossible

 3     to interpret.

 4             MR. SESELJ: [Interpretation]

 5        Q.   What year was that?

 6        A.   In 2002.

 7        Q.   Very well.  This was quite some time before I went to The Hague.

 8     The indictment against me was brought in mid-February 2003, and I heard

 9     that on the 25th of January, 2003, that's when I heard about the

10     indictment.

11             Did you hear about it before I did, and how long before?

12        A.   Well, I believe I heard about it in 2002.

13        Q.   Very well.  I have a newspaper text here.  Could the Registrar

14     please put it on the ELMO.  I had it photocopied previously.  I also had

15     copies made for the Prosecution and the Chamber.  This is a newspaper

16     article I found last night when I got back to my prison cell, and it's

17     from a newspaper published in Frankfurt called 'Vesti.'

18             You're aware there's a newspaper called 'Vesti' published in

19     Frankfurt?

20        A.   I know the owner, Vidakovic.

21        Q.   Well, that journal has been publishing a series,

22     Tomislav Nikolic's confessions.  And I got hold of this article which was

23     published on the 21st of November, so let's see what Tomislav Nikolic

24     said when Djindjic told him that an indictment was being prepared against

25     me.

Page 12193

 1             Can this be put on the ELMO and can Mr. Stefanovic see this in

 2     Belgrade?

 3        A.   I have the text before me.  Just telling if that's it:  "The

 4     killer changed his mind."  "The would-be killer changed his mind."

 5             JUDGE ANTONETTI: [Interpretation] Ms. Dahl .

 6             MS. DAHL:  This document is not readily accessible to either the

 7     Prosecution or the Chamber because it is not in a working language.  And

 8     I also question the relevance of the information -- that the witness can

 9     be asked questions and give answers regarding his knowledge.

10             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, as to the

11     relevance.

12             THE ACCUSED: [Interpretation] First of all, I ask that the

13     original be given back to me so that I can use it.  It's relevant because

14     it refers to what the witness is now talking about.

15             The witness is talking about the role of Zoran Djindjic, who

16     tried to recruit him to be a Prosecution witness against me, whereas

17     Tomislav Nikolic, in this article, says that Zoran Djindjic informed him

18     that an indictment against me was being prepared.  And I'll read the

19     relevant part of the text to you now.

20             MS. DAHL:  [Previous translation continues]... test the witness's

21     knowledge and understanding of facts relevant to the indictment.  I

22     object to Mr. Seselj reading a newspaper article to the witness, thereby

23     giving the witness an opportunity to adopt information in a newspaper

24     article.  The point of cross-examination is to test the witness's own

25     knowledge, not to feed him information to regurgitate.

Page 12194

 1             THE ACCUSED: [Interpretation] First of all, I don't have the

 2     limitations that the Prosecution has in the examination-in-chief.  I'm

 3     allowed to put leading questions.

 4             And I obtained this information only last night.  You can check

 5     whether this issue of 'Vesti' was distributed to us last night.  It was

 6     distributed in the prison yesterday, because it arrives with a delay.  I

 7     saw this last night.  I tore it out of the newspaper and brought it here.

 8     This is something very important for me.  I could not have handed it over

 9     or disclosed it earlier.

10             JUDGE LATTANZI: [Interpretation] Mr. Seselj, you know very well

11     that this is not the first time this issue has been raised.

12             The article is in Serbian, in Cyrillic.  We're not familiar with

13     that language, unfortunately.  So you could very well ask your questions

14     based on your reading of the article, but you are trying to know what the

15     witness can say to your questions, but without him reading the article.

16             JUDGE ANTONETTI: [Interpretation] Yes.  My fellow Judge has just

17     said how you should go about it.  Just say to the witness, "Here's an

18     article.  It was published in Germany on such-and-such a date, and the

19     following was said in that article."  You can sum it up very quickly, and

20     thereafter you can ask your question.

21             THE ACCUSED: [Interpretation] Mr. President, I have the right to

22     quote a few articles from this article.  I have no intention of reading

23     the entire article.

24             JUDGE ANTONETTI: [Interpretation] You may quote a few sentences,

25     but please try to be as short as possible.  We don't want to spend too

Page 12195

 1     much time on an article which has not been translated for us.  My fellow

 2     Judge has just mentioned it.

 3             THE ACCUSED: [Interpretation] Mr. President, it's impossible for

 4     you to have this in translation.  That's a force majeure.  I have marked

 5     the sentences I intend to quote.

 6             First, you see the paragraph before the last.  Tomislav Nikolic

 7     says -- he says that he and Djindjic were in a specific sort of

 8     friendship and that they treated each other correctly, and that Djindjic,

 9     at the bar in the Republican Assembly, where they were having tea, said

10     to him that an indictment against Seselj was being prepared.  And he says

11     that he told me that right away, but I know that's not correct.

12     Tomislav Nikolic never told me that Djindjic had told him that an

13     indictment against me was being prepared.  Tomislav Nikolic confirms that

14     he knew that an indictment against me was being prepared and that

15     Zoran Djindjic told him about that personally.

16        Q.   What do you think about that, Mr. Stefanovic?

17        A.   I think that Tomislav Nikolic is right.  I think that either Cedo

18     or Djindjic told him that.

19        Q.   Well, first it was Cedo and then it was Djindjic?

20        A.   Yes, yes.  I know that they had a specific sort of relationship,

21     a special relationship, and Nikolic -- what Nikolic says here, that's

22     correct.

23        Q.   Does that mean that Zoran Djindjic was already preparing the

24     ground before I left for The Hague to take over the Serbian Radical

25     Party?

Page 12196

 1        A.   Yes.  As I've already said in my testimony, the entire

 2     Radical Party did not have to be eliminated.  They said that only

 3     Vojislav Seselj had to be eliminated.  That's what I heard.

 4        Q.   And then they could deal with the party easily; was that the

 5     idea?

 6        A.   Yes.

 7        Q.   And did you hear that recently Tomislav Nikolic accused me of

 8     having ordered his murder, commissioned his murder?

 9        A.   Yes, Tomislav Nikolic said something about Ruma.

10        Q.   And there was a big public outcry about what he said, and then

11     some restrictions were put on my telephone calls here.  And now

12     Tomislav Nikolic is denying that.  He says that he had a clear signal

13     about a possible assassination, and that's in the second passage.  And he

14     says it was not prepared by Vojislav Seselj, "but he spoke so badly about

15     me in The Hague, as did his associates, that I know more or less who

16     could have said, 'Let's go and liquidate that traitor.'"

17             JUDGE ANTONETTI: [Interpretation] Ms. Dahl.

18             MS. DAHL:  This question has no relevance to the witness's fund

19     of knowledge.

20             THE ACCUSED: [Interpretation] Mr. President, originally

21     Mr. Stefanovic's statement was compiled so as to depict my character in

22     the blackest possible colours.  I was the person who called Pasko Jovic,

23     and then I had Vojin Vuletic killed, and the Prosecution has a witness

24     they haven't called yet who will say that, and now Tomislav Nikolic says

25     I ordered his murder.  So I'm constantly commissioning assassinations,

Page 12197

 1     and no one can prove that I have any links to those.  And here

 2     Tomislav Nikolic denies that it was I who commissioned his murder, and

 3     you here are convinced that I did.  I could feel that in the courtroom

 4     here.

 5             And now I would like to continue.

 6             JUDGE ANTONETTI: [Interpretation] Please ask your question to the

 7     witness.

 8             MR. SESELJ: [Interpretation]

 9        Q.   Mr. Stefanovic, did I ever engage in any type of business?

10        A.   Except for politics, unless you -- is lecturing at university a

11     business?

12        Q.   I didn't ask you whether I was employed.  But was I a capitalist

13     and engaged in any kind of business undertakings?  That's what I meant.

14        A.   No.

15        Q.   The other way to discredit me, on the basis of what

16     Zoran Djindjic said, was to link you up with Slobodan Milosevic and

17     Jovica Stanisic as much as possible; right?

18        A.   Yes, and the DB.

19        Q.   Yes, and the State Security Service of Serbia.  Well, in what the

20     Prosecution has presented here as being your statement, it says that you

21     allegedly said that I had excellent contacts with Slobodan Milosevic and

22     the structures of the State Security Service, including Jovica Stanisic.

23             JUDGE ANTONETTI: [Interpretation] Yes, Ms. Dahl.

24             MS. DAHL:  Your Honour, I hate to interrupt, but I wish to put on

25     the record that Judge Lattanzi has left the courtroom and ask whether a

Page 12198

 1     break would be appropriate or if her absence will be extended.

 2             JUDGE ANTONETTI: [Interpretation] We may proceed without her.

 3     This is provided for by the Rules.

 4             Mr. Seselj, you may proceed.

 5             MR. SESELJ: [Interpretation]

 6        Q.   Do you know, Mr. Stefanovic, when I first met Slobodan Milosevic?

 7        A.   Well, I -- if you want the time, the period, it was sometime in

 8     1992, mid-1992, I think.  I don't know.

 9        Q.   I'll tell you in detail.  We met briefly in the Republican

10     Assembly sometime in April 1992, and we just became acquainted and shook

11     hands.  And then in May 1992, Slobodan Milosevic called me for the first

12     time to come to his offices and to talk to him.  Am I telling the truth?

13        A.   Yes, but that conversation was an official talk because it was

14     with respect to the establishment of the federal Parliament.  That's what

15     it was linked to.

16        Q.   It had to do with the first federal elections in Yugoslavia, the

17     Federal Republic of Yugoslavia?

18        A.   Yes.

19        Q.   You should know, I think, that my political adversaries and

20     enemies, the pro-Western media, on several occasions launched strong

21     campaigns against me; right?

22        A.   Yes.

23        Q.   In those campaigns, did they use the worst possible lies and

24     inventions, fabrications?

25        A.   Yes.

Page 12199

 1        Q.   Was it possible at all for me to respond to each of those

 2     newspaper articles or information put out on the radio or television

 3     about me?  Was that feasible?

 4        A.   It was impossible, even if you formed a team.

 5        Q.   Do you remember that I collected all those worst attacks against

 6     me and published them in special collections of documents attached to my

 7     books?  Do you remember I did that and that I was very fastidious in

 8     doing that?

 9        A.   Yes.  Katarina Ducic was in charge in the party with her daughter

10     in collecting all these newspaper clippings and any footage in the media

11     about you and so on and so forth.

12        Q.   Zorica Zirovic was there, too, and a number of other party

13     activists engaged in that.  But not Zorica; Nada Zirovic.  Do you

14     remember her?

15        A.   Yes.

16        Q.   All right, fine.  Now, I was accused of committing crimes, too,

17     engaging in crimes?

18        A.   Yes.

19        Q.   And could anybody ever link me to any crime?

20        A.   Well, I would say no, I had no knowledge or awareness that you

21     engaged in any kind of criminal activity at all.

22        Q.   Do you remember that in 1990, I was in Milosevic's prison three

23     times?

24        A.   Whether you were just taken into custody or put into prison.

25        Q.   It was like this:  In 1990, in September, for 15 days in Padinska

Page 12200

 1     Skela, because of my demonstrations in front of the National Assembly,

 2     then for 20 days because of a rally on Republic Square, then 25 days for

 3     another rally, a repeated rally.  Do you remember that you came to visit

 4     me in prison in Padinska Skela at that time?

 5        A.   At the end of those 25 days, you didn't want to leave the prison

 6     five days early, and they forced you to leave.  You didn't want to be

 7     released.  You took it to the end.

 8        Q.   Our party wasn't registered, and while I was in prison, you

 9     personally organised a collection of signatures --

10             JUDGE ANTONETTI: [Interpretation] One moment, please.

11             Mr. Seselj, you raised a very relevant issue with respect to the

12     indictment, and I would like to ask the witness to confirm that point for

13     me.

14             Witness, in the indictment, it is stated that Mr. Seselj took

15     part in a joint criminal enterprise as of the 1st of August, 1991, until

16     December -- or, rather, September 1993.  Mr. Seselj asked you when he

17     first met with Mr. Milosevic.  I understand that you stated that it

18     happened mid-1992.  Could you be extremely specific and tell me when, to

19     your knowledge, Mr. Seselj met with the late Slobodan Milosevic?

20             THE WITNESS: [Interpretation] I'll be very precise in answering

21     that.

22             That first meeting, I know from what Seselj said.  He said, "You

23     know what?  Today --" he was a deputy in the Parliament.  Milosevic

24     happened to be there for some reason.  I wasn't a deputy, so I wasn't

25     there, myself.  But I remember him saying that he came and said -- we

Page 12201

 1     have a joke that we say "Pinky saw Tito," and he said, "Well, I

 2     saw Milosevic for the first time today."  Seselj never went alone to see

 3     Milosevic.  He was always accompanied by someone from the party, he

 4     always took someone from the party with him, so that whether it was one

 5     day earlier or later, but the elections were held in May 1992, and he

 6     contacted him with respect to an official meeting between the head of

 7     state and the head of a party.

 8             And I remember that on the 11th of June, I think it was, in the

 9     federal Assembly, that Slobodan Milosevic turned up and that the two of

10     us were standing there together.  Seselj and myself were standing

11     together.  Slobodan Milosevic came up to us, who had just entered the

12     building, entered the hall, and he greeted him, and then for the first

13     time with me, and said, "Good morning, Mr. Stefanovic."  I didn't think

14     he knew me, but he did know me.  He knew my name and everything, and I

15     was surprised by that.

16             So that's what I know about that.

17             JUDGE ANTONETTI: [Interpretation] Fine, Witness.  What you're

18     saying is of great relevance.

19             If I understand correctly, on the 11th of June, 1992,

20     Mr. Milosevic came up to you, called you by your name and shook your

21     hand.  You were quite surprised.  And he also shook the hand of

22     Mr. Seselj.  At the time, you were very close to Mr. Seselj.  Can you

23     tell us if, before that time, Mr. Seselj had already seen Mr. Milosevic,

24     or was it the first time?

25             THE WITNESS: [Interpretation] He'd seen him before that.  And

Page 12202

 1     according to what he told me, the story he told me, he came from the

 2     Republican Parliament, where he was the only deputy of the Serbian

 3     Radical Party.  And he said --

 4             JUDGE ANTONETTI: [Interpretation] When exactly did he see him?

 5             THE WITNESS: [Interpretation] I don't know the date, but before

 6     that, several months before.

 7             JUDGE ANTONETTI: [Interpretation] All right.  Several months

 8     before.  In any case, when Mr. Seselj testifies later, I'll ask the

 9     question.

10             Please proceed.

11             MR. SESELJ: [Interpretation]

12        Q.   Mr. Stefanovic, do you know when I met Jovica Stanisic for the

13     first time?

14        A.   No.

15        Q.   Well, I'll remind you.  It was sometime in November 1992.  There

16     was a meeting of the Republican Parliament, and a deputy from the ruling

17     Socialist Party came and said to me, "The head of the State Security

18     Service, Jovica Stanisic, would like to have a meeting with you."  I

19     agreed, and he told me to go out in front of the Republican Parliament

20     meeting and that Jovica Stanisic would come by in his own car.  And

21     that's what I did, I went outside.  And several minutes later, a luxury

22     car with dark windows drove up.  The back door opened, I got in, and

23     Jovica Stanisic shook hands with me.

24             Did I tell you about that meeting of ours?  And Jovica Stanisic

25     on that occasion informed me that in Montenegro, an assassination against

Page 12203

 1     me was being prepared, whereas I had planned to go to Montenegro for the

 2     pre-electoral campaign.  Do you remember that?

 3        A.   Yes.  I didn't think you should go to Montenegro.

 4        Q.   And do you remember that I could not travel anyway because I had

 5     severe back pains, and I wasn't even able to stand on my own two feet

 6     during the election campaign, and on the election day I had a spine

 7     operation; do you remember that?

 8        A.   Yes.  It was Sunday, the 19th of December, 1992, in the morning.

 9     I went to the clinic where I operated discus hernia and I prepared -- or

10     you did, and I prepared the elections in the party premises, and I wasn't

11     able to go and visit you either that day or the next day because I was

12     absolutely inundated with work.  I remember that very well, and I

13     remember the date very well, and the diagnosis, discus hernia.  Is that

14     right?

15        Q.   Well, I suppose it is.  Now, do you know when I met

16     Frenki Simatovic, Frenki, for the first time in my life?

17        A.   I don't know that.  I met him two years ago.

18        Q.   Well, I met him earlier on, and I'll disclose that secret to you.

19     I met him in 2003, when Franko Simatovic, Frenki, was first brought to

20     The Hague prison.  That's when I first met him in my life.  Do you

21     believe me?

22        A.   Yes, Frenki Simatovic told me that, too.  Yes, I do believe you.

23        Q.   All right, fine.  Now, they ascribed to you that you had said the

24     following:  "I'm convinced, although I can't prove it, that Seselj was

25     the executor of orders given by Milosevic."  That is a sentence to be

Page 12204

 1     found in paragraph 20 of your alleged statement given in 2006.  Did you

 2     indeed tell The Hague investigators that; is that what you actually said?

 3        A.   Well, nobody wanted to note down what I was saying about

 4     paragraph 21 and 26, but it's the same thing there.  I never saw my

 5     statement, as I said yesterday.  I asked at least ten times for the

 6     Tribunal to send me the statement in written form.  I never received the

 7     statement, and it was -- I saw those pages for the first time yesterday,

 8     and these numbered paragraphs.  I never gave a statement in the form of

 9     numbered paragraphs.  That's quite unusual.  So it's something that I

10     cannot link to logic.

11             And I just read points 21 and 26, 062436 is the document number,

12     and that particular paragraph says that Frenki Simatovic did something.

13     I don't remember what.  But in paragraph 26, it says that your political

14     advisers, or whoever, Professor Marjanovic and Mika Sprajc --

15        Q.   Just a moment.  Do you deny having said this to The Hague

16     Tribunal, that I was the executor of orders given by Milosevic?  Let's

17     take this one by one.  Is that what you said?  Do you deny it?

18        A.   I deny it.

19        Q.   Do you remember, Mr. Stefanovic, at the elections in December

20     1992, the Serbian Radical Party became invigorated and we came -- became

21     the second-strongest political party in Serbia; do you remember that?

22        A.   Yes, 73 deputies.

23        Q.   And the Republican government could not be formed without us;

24     right?

25        A.   Yes.

Page 12205

 1        Q.   Do you also remember that the two of us, you and I, went together

 2     to conduct negotiations with the leadership of the Socialist Party, to

 3     their headquarters in that skyscraper building at the Usce in Belgrade,

 4     the former Central Committee building?

 5        A.   Yes, Central Committee building, twelfth floor.

 6        Q.   Do you remember that Milo Minic, Nikola Sainovic, and somebody

 7     else of the Socialists greeted us there?

 8        A.   There was Bata Zivojinovic and Aleksandar Bercejg [phoen].  They

 9     were actors; right?

10        Q.   Do you remember that those functionaries of the Socialist Party

11     offered us to form a coalition government with them, made that offer?

12        A.   Yes.

13        Q.   And do you remember that I persistently rejected any kind of

14     coalition, but I said that we Radicals would agree to support a minority

15     government on condition that that government pull the country out of the

16     economic crisis and social poverty; do you remember that?

17        A.   Yes, yes, I do.

18        Q.   Now, afterwards, did we support the minority government, that is

19     to say, the Socialist Party government?

20        A.   Yes.

21        Q.   And six months later, did we start toppling the government, since

22     inflation had soared, poverty had soared, and the economic situation had,

23     in fact, worsened?

24        A.   Yes.  After that, when we started toppling the government, there

25     was a terrible attack by the Socialist Party or, rather, the parent

Page 12206

 1     authorities against the Radicals.  They launched an all-out attack, and

 2     the papers buzzed with all this, and as did all the other information

 3     media, who had very negative comments to make about the Radicals.  So

 4     there was an all-out campaign, an avalanche against us.

 5             JUDGE ANTONETTI: [Interpretation] Witness, here again we are

 6     dealing with a point of paramount importance.  We need, therefore, to be

 7     extremely precise and not to make any mistakes.

 8             You are challenging these statements that were taken in 2003 and

 9     2006.  You have explained to us why you challenge these statements.  In

10     this statement, it is stated that Slobodan Milosevic, together with

11     Simatovic and Stanisic, controlled the Serbian Radical Party.  That's

12     written in black and white in this statement at paragraph 21 and at

13     paragraph 20.  And through the questions put to you, we find out that at

14     some point in time, there was a meeting with the members of the Socialist

15     Party with a view to establishing an alliance with that party.  And in

16     response to a question just put to you by Mr. Seselj, you've just stated

17     that Mr. Seselj has refused any kind of alliance, and that's where we

18     have a problem.

19             If what is stated at paragraph 20 and 21 is true, we do not quite

20     understand why Mr. Seselj would have been opposed to this alliance.  If

21     he was against such an idea during that meeting, then that means that

22     what is stated at paragraph 20 and 21 is not true.

23             Sir, can you confirm that you attended a meeting that took place

24     with Mr. Seselj, yourself and members of the Socialist Party, with a view

25     to creating an alliance, and that Mr. Seselj rejected that idea?

Page 12207

 1             THE WITNESS: [Interpretation] Mr. President, I'll present two or

 2     three facts that can be borne out by people who are still alive and well

 3     and living in Belgrade today.

 4             I don't know whether Mr. Seselj remembers, but as a mark of

 5     goodwill, a gesture of goodwill, they prepared some cakes for us, some

 6     cream puffs.  Well, there were no cream puffs or eclairs, so they brought

 7     some other type of cake I can't remember what it was called.  Anyway, I

 8     remember something full well, and I don't think you know that today or

 9     knew it then, but when I went in to the other office, I was received by

10     Zoran Andjelkovic, who was a high-ranking official of theirs at the time

11     and today too, and we conducted a conversation in which he tried to

12     persuade me to wield my influence on you to agree to form a coalition

13     government and that he tried to recruit me by promising me a good

14     position in that government, me and some others.  And I said I did not

15     wish to discuss the matter on my own or secretly.  But I remember the

16     conversation full well, and I remember you saying to Minic, since Minic

17     was from my area and a school friend of mine, that if you cease to

18     negotiate with them, that there'll be a much more radical stream who

19     wouldn't want to give their support even to a minority government.  So

20     they agreed to your -- what you were offering him.

21             So those are the details of that meeting.  The meeting was held

22     on the 12th in the former CK building, Central Committee building, with

23     those eclairs and some Coca-Cola.  And in addition to Minic, who was

24     sitting there at the meeting, there was also Bercejg and Bata

25     Zivojinovic, two actors.  But Zoran Andjelkovic was sitting opposite

Page 12208

 1     them, and as I say, he conducted this conversation which you don't know

 2     about, which you've never heard about before today.  He wanted -- he

 3     offered me a place in the government and said that we'd be given some

 4     important posts.

 5             JUDGE ANTONETTI: [Interpretation] Witness, you've provided a

 6     wealth of information with respect to the cakes and everything about this

 7     meeting, but what was the date of that meeting, if you remember?

 8             THE WITNESS: [Interpretation] It's difficult to answer that,

 9     Your Honour.  You know what?  I have a different approach to matters.  I

10     don't tend to remember dates, telephone numbers, people's names.  I don't

11     think that's important.  So if you're asking about -- if there's a date

12     concerned, I write it down in my notebook, I record it in some way.  So I

13     don't know years or dates, but it was about 10 to 15 days after the

14     elections.  That is to say, it would be logical that it was, if you

15     worked it out and calculated it, it would be between the two Christmases,

16     that is to say, the 7th or 10th or 15th of January, 1994.

17             JUDGE ANTONETTI: [Interpretation] Good.  Mr. Seselj.

18             MR. SESELJ: [Interpretation]

19        Q.   Do you remember, Mr. Stefanovic, after we tabled a request to

20     topple -- overthrow the Socialist government, that the Socialist Party

21     issued a proclamation that was published quite literally in all the media

22     of Serbia and read out several times, in which they called me -- referred

23     to me as a war criminal, a criminal, a madman and an alcoholic?  Do you

24     remember that?

25        A.   Yes, yes.

Page 12209

 1        Q.   But they never managed to prove that I was a war criminal, did

 2     they?

 3        A.   That's correct.  I can talk about that.  That had to do with

 4     attempts to have you come to The Hague and face the then Prosecutor.  It

 5     was a woman.  I'm not sure what her name was, Louise Arbour or something

 6     like that.  And then through some embassies in Belgrade, because the

 7     Dutch wouldn't let you enter the country, they wouldn't give you a

 8     visa --

 9        Q.   When the regime in Serbia accused me of war crimes, did I

10     immediately express my willingness to go to The Hague, and did I ask for

11     a Dutch visa so I could travel there; is that true?

12        A.   Well, that's just what I'm talking about now, and the Netherlands

13     refused to issue a visa to you.

14        Q.   Had they issued me with a visa, I would have arrived in The Hague

15     in 1993, and I would have said, "Well, if you have something against me,

16     here I am."  Is that right?

17        A.   Yes.

18        Q.   And did I say that for all the media?

19        A.   Yes.  I'll tell you another detail.  I don't know if I told you

20     about it at the time, but I happened to be in the writers' club.  I was

21     having dinner with second secretary of the German embassy in Belgrade,

22     Lilke [phoen], and I asked him whether Seselj could get a German visa,

23     because you could use that visa to enter the Netherlands.  And he said --

24     when a woman working in the Dutch embassy came along, I didn't know her,

25     and this Lilke, who was the second secretary of the German embassy, said

Page 12210

 1     to her, "What sort of behaviour is that?  You're not brave enough to

 2     issue Seselj with a visa so he can go and face the Tribunal, but we

 3     Germans are willing to issue him with a visa."  I don't know what the

 4     woman answered.  He didn't tell me the entire conversation, but that

 5     confirms what you're saying.

 6             THE ACCUSED: [Interpretation] Very well.

 7             JUDGE ANTONETTI: [Interpretation] It's a quarter to 4.00.  We

 8     need to have a break now.

 9             One practical question.  Tomorrow, we are going to be sitting in

10     the morning at 8.30, instead of in the afternoon.  The Registrar will

11     take all the necessary steps for that.  If needed, we may be working

12     until 1.45 tomorrow, because we have two more witnesses to hear tomorrow.

13             But now we're going to have a 20-minute break for the

14     continuation of the cross-examination.

15             Madam Registrar, please tell me how much time there is left.

16             THE ACCUSED: [Interpretation] That's just what I was going to

17     ask.  How much time do I have left?

18             And another thing, Mr. President.  Of course, I can always adapt

19     to the time, but if the Registry can suggest that my transport be at a

20     quarter to 8.00.  If it's earlier than that, I have to ask the guards to

21     unlock my cell earlier, because I need at least 45 minutes to get ready,

22     to take a shower, to shave and so on.

23             JUDGE ANTONETTI: [Interpretation]  Fine.  The legal officer will

24     make the necessary arrangements.

25             Mr. Seselj, you've used one hour and ten minutes.  You have 50

Page 12211

 1     minutes left after the break.

 2             Let's have a 20-minute break.

 3                           --- Recess taken at 3.46 p.m.

 4                           --- On resuming at 4.09 p.m.

 5             JUDGE ANTONETTI: [Interpretation] The court is back in session.

 6             Mr. Seselj, you have 50 minutes left.  You may proceed.

 7             MR. SESELJ: [Interpretation]

 8        Q.   Mr. Stefanovic, there are two short questions I don't want to

 9     forget in connection with something we spoke about earlier.

10             We mentioned cockades.  You took those cockades when we went on

11     tour and sold them.  Did the Serb Radical Party ever manufacture its own

12     Chetnik cockades or did we, like other citizens, buy these cockades on

13     street stalls in the center of Belgrade and other towns?

14        A.   The Radical Party never manufactured its own cockades or any

15     other insignia.  I obtained them in Indija from a private manufacturer.

16        Q.   Please tell me, you know who Nikola Kavaja is?

17        A.   Yes.

18        Q.   He died recently.  He died recently.  Why am I asking you this.

19     I saw in some newspapers some photographs from his funeral.  There was a

20     guard of honour held by uniformed members of the Serbian guard of

21     Vuk Draskovic.  Did you see that?

22        A.   Yes.

23        Q.   Members of the Serbian Guard, they wore black uniforms.  Did you

24     observe that?

25        A.   Yes.

Page 12212

 1        Q.   Did the volunteers of the Serb Radical Party ever, ever, ever

 2     wear any kind of black uniforms?  Did any volunteers of the Serb

 3     Radical Party ever wear black uniforms?

 4        A.   Never.

 5        Q.   Are you sure?

 6        A.   Never.

 7        Q.   Very well.  We mentioned a little while ago this overthrow of the

 8     Socialist government and the communique issued by the Socialists against

 9     me and the Serb Radical Party.  You're aware that Milosevic's regime

10     arrested me on several other occasions as well?

11        A.   Yes.

12        Q.   Let me jog your memory.  In 1994, first they sentenced me to a

13     month and then to another three months?

14        A.   A total of four months in the central prison.

15        Q.   Yes, because of the incident in the federal Assembly; is that

16     correct?

17        A.   Yes.

18        Q.   When Drasko Markovic, our federal deputy, threw water over the

19     speaker of the Assembly, Radovan Bozovic, and the Assembly voted to expel

20     him, and we did not allow the Assembly police to take him out of the

21     room, and there was an incident, is that correct, and we wrestled with

22     the police, literally?

23        A.   Yes.  I participated in that.

24        Q.   And then I was sentenced to four months in prison.  I was the

25     only one who served a prison sentence, is that correct, because I was the

Page 12213

 1     strongest?  All right.

 2             And do you remember that a group of associates and I - you were

 3     not with us at the time - were arrested again in Gnjilan in June 1995

 4     because we had organised a rally there which was banned by the regime,

 5     and we went to Gnjilan anyway?

 6        A.   Yes.  You were in prison.

 7        Q.   Yes.  And then the police --

 8        A.   Intervened.  They beat you up and took you to prison, and I came

 9     to visit you there.

10        Q.   And I spent two months there in prison with my associates; is

11     that correct?

12        A.   Yes, yes.

13        Q.   When Slobodan Milosevic was in power, did anyone ever attack

14     Slobodan Milosevic and his wife, who was the director of the Yule [phoen]

15     Direction, another ruling party, more fiercely than I did?

16        A.   No, I don't think so.  I know that you even wrote several books

17     about this.  There was a large number of public appearances, appearances

18     in the media, in newspapers, on TV.  Let me remember -- let me try to

19     remember the title of one of your books.  "Mirjana Markovic was the Red

20     Witch," and they were at Dedinje and so on.

21        Q.   Well, I gave all these books to the Prosecution a long time ago.

22     The regime managed to arrest me only because of some incidents that had

23     been provoked and that were quite innocent?

24        A.   Yes.

25        Q.   Had they had any information that I was involved in any sort of

Page 12214

 1     crime, or war crime, or anything of that nature, would not have they been

 2     eager to arrest me immediately and deal with me in that way at the time?

 3        A.   I think so, yes.

 4        Q.   Do you remember when there was a reconciliation between the

 5     Serbian Radical Party and Milosevic and his party in 1998, and what was

 6     the occasion?

 7        A.   I had already left then, but I think it was --

 8        Q.   The situation in Kosovo and Metohija?

 9        A.   Yes, yes, the Kosovo crisis, that's right.

10        Q.   In your statement, it says here that "Milosevic gave me means and

11     funds to implement the policies of the Milosevic regime."  Did you ever

12     tell that to The Hague investigators?

13        A.   Certainly not in this way.

14        Q.   Did Milosevic's regime ever help the Serbian Radical Party in any

15     way, either with funds or infrastructure or in terms of organisation?

16        A.   While I was a member, no.  That I know for certain.

17        Q.   It says here in your alleged statement that I was often on the

18     telephone with Radmilo Bogdanovic.  Are you aware or do you remember that

19     Radmilo Bogdanovic was a favourite functionary of the Socialist Party and

20     that I -- he was the one whom I always liked best to attack from the

21     rostrum in the Assembly?

22        A.   Well, I was on good terms with Radmilo Bogdanovic, and I

23     continued being on good terms with him.  And it's correct that for

24     whatever reason, Radmilo Bogdanovic was often exposed to your criticism.

25        Q.   In paragraph 21, it says that the Serb Radical Party cooperated

Page 12215

 1     with Frenki Simatovic, the leader of the Red Berets.  Is that correct, is

 2     that what you said?

 3        A.   I spoke about this yesterday.  It has nothing to do with common

 4     sense.

 5        Q.   When there were fierce conflicts with the Milosevic regime, I

 6     often provoked Jovica Stanisic and Frenki Simatovic and so on, expecting

 7     them to respond in a nervous manner.  Do you remember that?

 8        A.   Yes.  There were quite a few attacks against the two of them.

 9        Q.   I would launch a provocation through the media and wait for their

10     nervous reaction, thinking that then I could exploit it politically; was

11     that what happened?

12        A.   Yes, precisely so.

13        Q.   And I introduced a lot of confusion so that nobody could make

14     head or tail of what was really going on?

15        A.   Yes.

16        Q.   Was I a master in producing these propaganda effects?

17        A.   I have never met a bigger master, someone more proficient than

18     you in that respect.

19        Q.   You said, it says here, that we cooperated with members of the

20     JNA General Staff; for example, with General Domazetovic.

21             But you don't have precise data with how we cooperated with him,

22     do you?

23        A.   I don't know whether you know Domazetovic at all.  I met

24     Domazetovic only in 2002 or 2003.  Do you know him?

25        Q.   I met him late.  He was already retired.  But with my knowledge

Page 12216

 1     and my approval, Ljubisa Petkovic went to meetings with him to agree to

 2     the sending of volunteers.  That's no secret.  But you were not able to

 3     speak about this because you weren't involved or familiar with that?

 4        A.   I was not in contact with Ljubisa Petkovic at all, which is why,

 5     in my statement -- well, I say now he should have been sent to The Hague

 6     rather than you.

 7        Q.   Who?

 8        A.   Ljubisa Petkovic.

 9        Q.   Well, he's already been in The Hague.  He was sentenced, and he

10     served his sentence.

11        A.   Yes, but that's what's going to happen to me, too, because the

12     Prosecutor says the same thing that Tomislav Nikolic said at the rostrum.

13     She's telling me that I'm not telling the truth.  That's something that

14     has been orchestrated, and all I can expect now is a prison sentence.

15             Ljubisa Petkovic got off easy.  He had a good time in The Hague

16     for four months.  He was assisted by Croats, Serbs, all sorts of people,

17     and he got a place in Parliament as a deputy.  And I will get a spanking.

18     And it was said two hours ago that the state should take measures against

19     those who are testifying in The Hague.

20        Q.   Mr. Stefanovic, the Prosecution cannot prove that you are lying.

21     They cannot prove that you are lying, because everything you have said up

22     to now in the cross-examination can be documented and it can be proved to

23     be true.

24        A.   Well, I'm telling you the truth quite sincerely.  Yesterday and

25     today, I've been speaking the truth, and nothing but the truth, and I've

Page 12217

 1     been speaking under oath.

 2        Q.   Very well, very well.

 3        A.   But that's propaganda.

 4             THE ACCUSED: [Interpretation] May I proceed, Your Honour?  Have

 5     you intervened?

 6             THE INTERPRETER:  Microphone, please, Your Honour.

 7             JUDGE ANTONETTI: [Interpretation] The interpreters can't hear me.

 8     The microphone is on now.  There must be a problem, because I don't seem

 9     to be able to speak -- it's working now.

10             Witness, you said something.  It was a minor detail.  It may have

11     been a mistake in translation, but earlier on, you spoke about Petkovic.

12             THE ACCUSED: [Interpretation] Mr. President, the interpreter

13     cannot hear you.  They are complaining to me, the interpreters.

14             JUDGE ANTONETTI: [Interpretation] Could you turn off your

15     microphone, Mr. Seselj.

16             Witness, you mentioned a detail that was very quick, but I

17     wondered whether there was a mistake or not.  You said that Mr. Petkovic,

18     he was convicted to a prison sentence, that he was assisted by Croats and

19     Serbs, and that he -- he was now a deputy in Parliament.  Is he now a

20     deputy -- a member of Parliament?

21             THE WITNESS: [Interpretation] Yes, I think he is.  Yes.  I'm not

22     sure, but I think he is, yes.

23             JUDGE ANTONETTI: [Interpretation] Which party is he a member of?

24             THE WITNESS: [Interpretation] Radical, the Serbian Radical Party.

25             JUDGE ANTONETTI: [Interpretation] Very well.

Page 12218

 1             Please continue.

 2             THE INTERPRETER:  The interpreters --

 3             MR. SESELJ: [Interpretation]

 4        Q.   As you mentioned this, we'll have to clarify.  Are you aware,

 5     Mr. Stefanovic, that Ljubisa Petkovic returned to the Serbian Radical

 6     Party some time ago?

 7        A.   Yes.  He doesn't have to be on the party ticket to be a deputy.

 8     He participated in the election campaign, he participated in rallies of

 9     the Serbian Radical Party.

10        Q.   And he spoke at the rallies?

11        A.   Yes, yes.

12        Q.   Very well.  And the party ticket was drawn up some two months

13     before the elections; is that right?

14        A.   Yes.  It had to be, under the law, and he had to be on the

15     ticket.

16        Q.   The elections were held in early May?

17        A.   On the 12th.

18        Q.   So in March, he had to be put on the party ticket; is that right?

19        A.   At the latest, maybe even before that.

20        Q.   And he was arrested in late May; is that correct?  Do you

21     remember when he was arrested?

22        A.   He was taken from the madhouse in late May.

23        Q.   Don't say that he was taken from the madhouse, from the asylum.

24        A.   He was kidnapped.

25        Q.   Well, he was in a hospital, in an asylum, not in a madhouse.

Page 12219

 1     Don't demonstrate your intolerance towards Mr. Petkovic in this way.

 2        A.   I'm not demonstrating my intolerance.  I'm just saying that he

 3     was kidnapped.

 4        Q.   Any one of us, because of torture, various pressures and so on,

 5     can ask for the assistance of a psychiatrist; is that right?  It's not

 6     immoral, it's not something to be sneered at, if someone in a difficult

 7     situation had to ask for help from a psychiatrist?

 8        A.   I think you misunderstood me, this whole story.  In my public

 9     appearances and in newspaper articles, and still today, even 'Glas

10     Javnosti' is writing about the torture of Serbian witnesses and the

11     failure to punish other Siptar, Croat and Muslim criminals.  So you

12     misunderstood me.  Please don't hold this against me, because I am trying

13     to defend Ljubisa Petkovic, and I condemn what the Tribunal did.

14             It's true that he was brought to the edge of reason, and it's

15     quite normal that he should ask for help from a doctor.  Every person has

16     the right to get medical assistance when he's in difficulties.

17             You didn't understand me properly.

18        Q.   Very well.  Mr. Stefanovic, did you hear we had an eminent

19     deputy, Dragan Tasic, who graduated in law in Montpellier in France, who

20     was a very good lawyer, an excellent connoisseur of French and English,

21     he spoke French and English very well, and he played an important role in

22     the team assisting in my Defence?  Have you heard of Dragan Tasic, he

23     died?

24        A.   I didn't know him personally, but I have heard of him.

25        Q.   Unfortunately he died at the age of 49 last summer, and when

Page 12220

 1     Ljubisa Petkovic returned from prison, the Central Homeland

 2     Administration decided that Ljubisa Petkovic should become a national

 3     deputy in place of the late Dragan Tasic.  Are you aware of that?

 4        A.   It's the first time I've heard of it.

 5        Q.   And as the Serbian Radical Party is a fierce opponent of

 6     The Hague Tribunal, the Central Homeland Administration felt that this

 7     was a way to honour Ljubisa Petkovic for his heroic deeds, because even

 8     at the cost of serving a prison sentence did he agree to testify for the

 9     Prosecution in the proceedings against me; is that how it was?

10        A.   Well, I support what you say.

11        Q.   Very well.  Mr. Stefanovic, just as I'm opposed to anyone showing

12     intolerance towards you, I am also against anyone showing intolerance

13     towards Ljubisa Petkovic.

14        A.   No, I wasn't trying to do that.  You misunderstood me.

15        Q.   All right.  Let's move on.

16             Did the Serbian Radical Party ever, through its section, the

17     Serbian Chetnik Movement, establish units in the interior of Serbia by

18     municipality and local commune?  Did we ever do this in the interior of

19     Serbia?

20        A.   There was no need.

21        Q.   So when volunteers were sent to the front, they would first come

22     to Belgrade, then go to the barracks in Bubanj Potok, where they would be

23     issued with weapons and uniforms and sent to the front-line.  And when

24     they came back, each one went to his own home; is that right?

25        A.   Yes, that's just how it was.

Page 12221

 1        Q.   And here in this alleged statement of yours, on page 7, I see it

 2     says that -- they said:

 3             "Here I describe the hierarchy of the War Staff and the units on

 4     the ground which call themselves Chetniks."

 5             Did this exist in Serbia at all, a unit in Lapovo, for example,

 6     or in Gornji Milanovci or in Valjevo, where you were, and was there a

 7     commander of such a unit in Valjevo, for example?  Did those ever exist?

 8        A.   Well, what would those units be used for, what purpose would they

 9     serve?  That's not true, there was no organised group of Chetniks on the

10     territory of Serbia, because there was no need.

11        Q.   Well, I'm asking you this because we had a Prosecution witness

12     here, whose testimony I challenged, who claimed that we had units in

13     every municipality and that this military structure --

14        A.   2s and 3s?

15        Q.   Well, we won't go into this any further.  Let's see what else we

16     can clarify in what time we have left.  There are some other things I

17     have noted here.

18             Mr. Stefanovic, in the course of the examination-in-chief, you

19     spoke about something that is very significant to me.  You said that you

20     were recruited by the Tribunal to contact the Serbian Radical Party and,

21     through the party, to offer me a trial in Belgrade, and that I would be

22     released provisionally and given a sentence of only ten years, and that I

23     refused this.  Let's explain this in greater detail.

24             First of all, who called you and who talked to you about this?

25        A.   Bruno Vekaric from the Tribunal.  He said to me that he was asked

Page 12222

 1     from The Hague to try and contact the Radicals, and I told him I could.

 2     I had in mind that I could always come in contact with Dragan Todorovic,

 3     for instance, who was one of the men at the very top of the leadership in

 4     the Radical Party, and I did indeed come into contact with him.  I rang

 5     him up on the phone, and we discussed it.  I said -- in the Atos Pizzeria

 6     in Belgrade, and he came -- I said I was there, and he came several

 7     minutes later.  And then we went up to the motorway so that we wouldn't

 8     be overheard by anyone, and I told him all this.

 9             And the story was as follows:  That you should come and be tried

10     in front of our own -- in our own courts, and that you would be given a

11     prison sentence whereby you would be provisionally released immediately

12     after the trial, and that would be the best possible solution for you.

13        Q.   And you told Dragan Todorovic that?

14        A.   Yes.

15        Q.   And Dragan Todorovic conveyed that to me, and I categorically

16     refused with indignation; isn't that right?

17        A.   Yes, that's the information, the feedback information I got from

18     him.  Dragan Todorovic rang me up, he said, "Let's meet," so we in the

19     same place by the motorway; and that's what he told me.  I didn't comment

20     myself.  I just listened to what he had to say, and he said no, he won't

21     hear of it and so on and so forth, and then I told Bruno Vekaric the

22     outcome, and some other people who were there when I told him, and then

23     they all said out loud, "Well, heavens, he's a madman.  Why doesn't he

24     accept that?  It's not a bad solution for him."  And I said, "I don't

25     know.  I'm not his adviser, nor can I decide on his behalf.  I did what

Page 12223

 1     you asked me to do as an intermediary."  So I considered myself to be an

 2     intermediary of some sort, a go-between for the Tribunal, working for the

 3     Tribunal in one way in the morning and in another way in the afternoon.

 4        Q.   And he was a spokesman of who, the Tribunal or the Special War

 5     Crimes Tribunal, he's a spokesman, isn't he, of the special prosecutor

 6     for war crimes, right?

 7        A.   Yes.

 8        Q.   Who were the other people present when you provided them with

 9     this feedback information?

10        A.   I can't remember their names, although I could find out, because

11     I know the people.  They work in the OTP, but I don't know what their

12     names are.

13             THE ACCUSED: [Interpretation] Judges, I request that you demand

14     Bruno Vekaric's written statement, the spokesman of the Tribunal in

15     Belgrade, War Crimes Tribunal in Belgrade.  I think that this is an

16     important piece of information, and that he should be asked to state it

17     all in writing.

18             THE WITNESS: [Interpretation] Mr. Seselj, can I ask you

19     something?  Did anybody, on behalf of Dragan Todorovic, ask you what I've

20     just been talking about?

21             THE ACCUSED: [Interpretation] Dragan Todorovic told me about it

22     personally, and I refused with indignation, because I never agreed to any

23     bargaining or anything like that with relation to this trial, and I abhor

24     anybody who entered into a plea agreement with the Prosecution.  And I

25     suppose that is common knowledge to everyone.

Page 12224

 1        Q.   Mr. Stefanovic, after my departure to The Hague, you took part in

 2     propaganda activities of the regime against me, personally, and against

 3     the Serbian Radical Party; isn't that right?

 4        A.   Yes.

 5        Q.   And during your stay here, you spoke against me, against my party

 6     and the Radicals, too, those Radicals?

 7        A.   [No interpretation].

 8        Q.   All right.  Now, what influenced you?  Was it my hunger strike

 9     that made you change your opinion and attitude straight away and then to

10     offer yourself for my Defence team, to be a Defence witness?

11        A.   Well, many things influenced me.  It wasn't just one thing that

12     was decisive.  But when I saw that it was all a farce, after the incident

13     we've just been talking about, about your being tried in Belgrade,

14     et cetera, and many other things that seemed to me -- or, rather, many

15     bad things that had happened to me, I was treated here as if I was a

16     mentally-retarded child.  I remember when the Prosecutor, the lady

17     Prosecutor came, the one sitting opposite you, she said, "Good morning,

18     Mr. Stefanovic."  I said, "Good morning, madam."  "Are you a Chetnik?"  I

19     said, "Yes, I am, I'm a Chetnik."  And she said, "Well, you have

20     honours -- honour and morals," and then I saw the aim of the question was

21     different from what I thought it was, that people who were less educated

22     say, "Yes, we Chetniks are special people, we don't lie and so on," so

23     you can say something that should be said and should not.  But my answer,

24     the answer I gave her, was, "Madam Prosecutor, I am a politician, I deal

25     in politics, and I can't be put in any category."  And she was astonished

Page 12225

 1     and then we discussed this.

 2             Unfortunately, we haven't got the transcript of that or the

 3     recording of that conversation and what I said, but many circumstances

 4     and many things, especially when I saw the campaign launched by the whole

 5     of the West, and The Hague Tribunal as well, led by the OTP and the

 6     Prosecutor, for example, the state of Serbia is in a ghetto here, thanks

 7     to the Tribunal's insistence that we do something that they can't do.

 8     They can't capture Ratko Mladic, they can't capture Goran Hadzic, and

 9     unless we can capture him in the next ten years, we'll be punished.

10     Who's going to punish us?  The Prosecution and others will be punished

11     for 100 years to come, and there will be no negotiation.  They treat us

12     like a banana state, a banana republic.

13             So what I am experiencing today is something that I could never

14     have envisaged.  I don't think anybody -- I could never imagine that

15     anybody would ever tell me to my face that I was lying, saying to a man

16     that he's lying, who has never lied before.

17             THE INTERPRETER:  Could the speakers kindly be asked to slow

18     down.  Thank you.

19             JUDGE LATTANZI: [Interpretation] Witness, I understand that you

20     are a politician, but this is not the place for you to launch, as you

21     keep doing during this cross-examination, to launch into political

22     statements.

23             JUDGE ANTONETTI: [Interpretation] Witness, there is an important

24     part --

25             THE ACCUSED: [Interpretation] Mr. President, the interpreters

Page 12226

 1     cannot hear you.

 2             THE INTERPRETER:  The interpreters note that the microphone is

 3     not working.  Thank you.

 4             JUDGE ANTONETTI: [Interpretation] Witness, can you hear me?

 5             Witness, you just said something that might prove relevant.

 6             When Mr. Seselj asked you whether you had led a campaign against

 7     him, you said you did.  But after that, it would appear that you decided

 8     to be a witness for him, and this is an important point.  Was it you,

 9     yourself, who decided to tell the OTP and Mr. Seselj's Defence that you

10     then felt that it was your duty to be a Defence witness, or were you

11     forced to do so, to change your mind?

12             THE WITNESS: [Interpretation] Yes, I understand the question,

13     Mr. President, and I'll give you a very precise answer.

14             When I gave my first statement here at the Tribunal, in these

15     premises here, three floors above, I said quite resolutely to the

16     investigators that this statement of mine can be used not only by the

17     OTP, but that the Defence can use it, too.  Now, the fact that they might

18     not have recorded that is something that I did say.  You can call the

19     person that was there and heard it.  So at that first interview, I told

20     him that my statement could be used both by the Prosecution and by the

21     Defence.  So -- well, a witness is a witness.  There's no Defence or

22     Prosecution, as far as I understand it, in our system, at least, in my

23     country.  If you're a witness, you're a witness.  Whether you're going to

24     be a Prosecution or Defence witness or whatever, I don't know.

25             But anyway, I was resolved at the time to be a Prosecution or a

Page 12227

 1     Defence witness, and then later on, who was going to exert pressure on me

 2     from the Radicals?  They couldn't exert pressure on me for ten years, and

 3     now you expect Toma, who fled with the Americans, is he going to exert

 4     pressure on me?  No, nobody can exert pressure on me.  But quite simply,

 5     I thought it necessary to address the Tribunal in written form and state

 6     that in -- of sound mind, I am writing to the Tribunal to inform them of

 7     my intentions.

 8             JUDGE ANTONETTI: [Interpretation] Very well.

 9             Mr. Seselj.

10             MR. SESELJ: [Interpretation]

11        Q.   The prime minister, Zoran Djindjic at the time, suggested that

12     you talk to The Hague investigators about me.  When that happened, did

13     anybody -- was anybody present at the meeting?

14        A.   Vladan Babic knew about this.  It went on for two or three days,

15     this persuasion, and then individually, too.  And the final instance was

16     that I was thrown out of his office, and I said I didn't know what to do.

17     And quite frankly, at that point in time I didn't know whether I did or

18     did not have to respond to the summons from the Prosecution, to be quite

19     frank.  If I knew that I didn't need to do that -- well, they kept saying

20     that, "Well, you're a Radical and you don't want to help, you asked that

21     the Radical Party be banned, you know them best," and things like that.

22     That's how it was.

23        Q.   Vladan Batic was the Minister of Justice at the time, is that

24     right?

25        A.   Yes.

Page 12228

 1        Q.   And he's still alive, luckily, so he could confirm your words?

 2        A.   Yes, Carla Del Ponte and Batic, they are both alive and can

 3     confirm that, I think.

 4        Q.   Did you personally have a meeting with Carla Del Ponte?

 5        A.   No, no.  It was in the Cabinet, in Djindjic's offices.  I knew

 6     that Djindjic was on good terms with Carla Del Ponte and that he said

 7     that he had managed to gain assurances that I needn't appear.

 8        Q.   Did Djindjic tell you what his motives were to send me to

 9     The Hague?

10        A.   Well, I talked about that an hour ago, about the political scene,

11     and that as far as you were concerned, all that was acceptable.

12        Q.   Now, this DOS, the Democratic Opposition of Serbia that came to

13     power when Milosevic was overthrown; right?

14        A.   Yes.

15        Q.   Now, at the head of this party of yours, the DOS, did they feel

16     that you would take over the whole party, the control of the whole party

17     if I were to leave?

18        A.   Well, I don't know.  Cedo was in charge of that on behalf of the

19     DOS.  I dealt with the Socialists more, and I managed to fulfill my

20     assignment and to split the Socialist Party into two streams.  If you

21     remember that time, Baki and Bani and Ivkovic and so on, so I was in

22     charge of dealing with the Socialist Party of Serbia.

23        Q.   You mean Cedomir Jovanovic?

24        A.   Yes, Cedomir Jovanovic.

25             THE INTERPRETER:  Could the speakers kindly be asked to slow down

Page 12229

 1     for the benefit of everyone.  Thank you.

 2             MR. SESELJ: [Interpretation]

 3        Q.   In paragraph 26 of your statement, it says the following:  That

 4     the Serbian Radical Party had its intelligence organs and that you knew

 5     two men who worked as military intelligence organs.  And to be quite

 6     true, I was astounded when I read here that you named Professor Jovan

 7     Marjanovic from the Faculty of Political Sciences, and also Colonel

 8     General Bozidar Stevanovic, also known as Mika Sprajc.  Now, why was I

 9     astonished to hear that?  Because you, Mr. Stefanovic, knew full well

10     that within the frameworks of the political alliance, we really did have

11     a group of retired military officers who dealt in intelligence.  Do you

12     remember that we had that?

13        A.   Yes, I do, but I don't remember that these two men were there.

14        Q.   Well, do you remember who was there?  Let me remind you.  Do you

15     remember Colonel Milos Dimitrijevic, for instance, whom we called Stojan

16     in order to cover up his presence?  Do you remember Stojan?

17        A.   Well, he's a good friend of mine today, and we're still in

18     contact.  I remember Miso Dimitrijevic very well, and in 2002 or '3 he

19     shared an office with me in Nemanjema [phoen] Street.

20        Q.   Do you remember that he would bring to my office every morning

21     intelligence reports on the events on the political scene that happened

22     the previous day?

23        A.   Yes, and he did all that while you were in prison in 1994.  And

24     then he came to see me one morning, and I sent him packing.

25        Q.   Something else happened, Mr. Stefanovic.  We'll come to that in

Page 12230

 1     due course.  I'm sure I'll jog your memory.  But do you remember the

 2     captain of the naval ship Rade Suljagic?

 3        A.   Yes.

 4        Q.   Was he one of the people who provided me with very important

 5     information as well and who, in a way, was an adviser, too, in certain

 6     areas?

 7        A.   Yes.

 8        Q.   Not every day, but Colonel Milos Dimitrijevic did, not to mention

 9     other people, because the general public doesn't know them.  But, anyway,

10     do you remember, when I was arrested in 1994, that recently afterwards,

11     Colonel Dimitrijevic was arrested too?

12        A.   Yes.

13        Q.   And do you remember that he was remanded in custody by the State

14     Security Service for several days?

15        A.   He wasn't officially arrested.  He was kidnapped.

16        Q.   Do you remember that four months later, upon leaving prison, I

17     broke up that party organ of ours, I disbanded it, because I considered

18     that the State Security Service was controlling it and that I was on the

19     lookout for new people who would work for the party leadership and deal

20     with those affairs; do you remember that?

21        A.   I remember discussions about that, yes.

22        Q.   Now, do you also remember that not until the present day, nobody

23     has managed to learn who those people are and who is the person behind

24     the name Laufer, whether it's just one person or more people; are you

25     aware of that?

Page 12231

 1        A.   No, I don't know about that.

 2        Q.   Well, you should know that I published a number of books.  Laufer

 3     has contacted me, Laufer hasn't forgotten me, a Chetnik head over the

 4     Osmanli [phoen] whatever.  Do you remember that the newspapers wrote

 5     about that in Serbia?

 6        A.   Yes.  A journalist told me about that.

 7        Q.   And they haven't managed to learn who those intelligence men were

 8     to this day, those people who provide me with reliable intelligence in

 9     various areas.  Not even Tomislav Nikolic knows that, knows their

10     identity; is that right?

11        A.   I assume so.

12        Q.   He said Jadranko Vukovic was allegedly a go-between between

13     myself and those intelligence men, but he never learned who those men --

14     those informers were, either.  So I've learned something when it comes to

15     intelligence work, have I not?  Am I right?

16             How much more time have I got, Judges?

17             JUDGE ANTONETTI: [Interpretation] Yes.  I was wondering also, how

18     much time you had left.

19             Madam Registrar.

20                           [Trial Chamber and registrar confer]

21             JUDGE ANTONETTI: [Interpretation] According to the Registrar, you

22     have 25 minutes left.  I found it rather surprising, but, yes, you have

23     25 minutes left.

24             THE ACCUSED: [Interpretation] Very well.  I might not use all the

25     25 minutes, but I'll do my best to use them all up.

Page 12232

 1        Q.   Yesterday, in response to a question from Judge Harhoff, you

 2     seemed a bit disoriented.  He asked you about the transport of the bodies

 3     of killed members or volunteers of the Radical Party.  And I decided that

 4     this was because -- that your confusion came from --

 5             THE INTERPRETER:  The interpreter didn't hear the rest.

 6        A.   The problem is that the War Staff -- now, when I looked at the

 7     recording again and transferred it again, and I'll let the Trial Chamber

 8     be the judges, I couldn't remember that it was the Crisis Staff before,

 9     that that's what it was called before.  And now in talking to people this

10     morning, it became clear to me.  So when the question of coffins was

11     brought up, and whatever else, that was something -- well, if they'd

12     asked me about surgery, I might have known more.  So I'm not the right

13     person to answer that kind of question.  But the man asked me, so I had

14     to answer.  So it wasn't that I was confused; it was that I didn't know

15     what to -- what answer to give.  And, quite frankly, I do know that some

16     people were killed over there, but what happened, I really don't know.

17             MR. SESELJ: [Interpretation]

18        Q.   I would like to remind you --

19             JUDGE HARHOFF:  You have to observe a pause between question and

20     answer.  Your last question, for instance, Mr. Seselj, was never

21     translated.  I didn't know what you were asking.  So please make sure

22     that you make a break.

23             THE ACCUSED: [Interpretation] Well, I'm referring to your

24     questions of last night, Mr. Harhoff.  I wish to remind Mr. Stefanovic

25     that all the work about transferring the bodies of volunteers who had

Page 12233

 1     been killed to Serbia was performed by the appropriate service of the

 2     JNA.  They used their medical vehicles and their helicopters to transport

 3     the bodies.  All the funerals were paid for by the state.  And starting

 4     from September 1991 onwards, a platoon of the army from the local

 5     garrison would fire a salvo every time there was a military band playing

 6     at the funeral.  And officials of our party were always present.  I was

 7     often present, personally.  We made speeches.

 8        Q.   Do you remember that, Mr. Stefanovic?

 9        A.   I never participated in any of the funerals.  I assume all this

10     is true.  It's all very logical.  These people were incorporated into the

11     units of the JNA, as it was -- or whatever it was called then.  But I was

12     confused by this insistence that we should do something that I was not

13     informed about.  I don't know how they were transferred, how the coffins

14     were transported.  It's logical that the army did that.  It's true that

15     there was always a military band playing.  It's true that a volunteer who

16     was killed was always buried with all the honours due to a soldier of the

17     JNA and of Yugoslavia.

18        Q.   And do you remember that volunteers who were wounded were treated

19     at the Military Academy Hospital in Belgrade?

20        A.   Yes.  They were treated just like every soldier.

21        Q.   And is years of service counted for every member of the Serbian

22     Radical Party who was a volunteer, and that those who became invalids

23     were given a pension and all the benefits they were entitled to?

24        A.   Yes.  They were always treated as regular soldiers of the

25     Yugoslav Army.

Page 12234

 1        Q.   Very well.  Judge Harhoff asked you how the exchange of prisoners

 2     took place.  Are you aware that a certain number of volunteers of the

 3     Serbian Radical Party were taken prisoner by the Croats in the course of

 4     the war?

 5        A.   Yes.

 6        Q.   Are you aware, for example, that 11 volunteers of the Serbian

 7     Radical Party, in December 1991, were killed defending Masicka Sargovina

 8     in Western Slavonia, and that some were wounded or taken prisoner?

 9        A.   Yes.  Dragan Jovanovic, a friend of mine, was killed there, and

10     Sigma [phoen] and Ducica [phoen] were taken prisoner.

11        Q.   It wasn't Dragan Jovanovic, it was Dragan Lazarevic, sir.

12        A.   Yes, yes, you're right, that's right.

13        Q.   He was a common friend of ours and a member of the party

14     leadership?

15        A.   Yes.  I made an error.

16        Q.   And he was killed there.  He was an only son; isn't that right?

17        A.   Yes.

18        Q.   Do you remember who conducted the negotiations concerning their

19     exchange?  They were arrested, put into a Croatian prison in Gradiska,

20     I think.  They are tortured in prison.  And who was in charge of

21     negotiations concerning their exchange; do you remember?

22        A.   Mr. Seselj, I was in Australia at the time, so I don't know the

23     details.

24        Q.   Well, I'll tell you that the JNA was in charge of all the

25     negotiations concerning exchanges, and we kept telephoning and trying to

Page 12235

 1     get the structure in the General Staff to get the exchange performed as

 2     soon as possible.

 3        A.   I was present on several occasions when you personally telephoned

 4     the chief of the General Staff concerning some other exchanges; saving

 5     someone, I don't know.  But it was always the army that was called up --

 6     that was contacted on the telephone.

 7        Q.   Is it correct that all the volunteers of the Serbian Radical

 8     Party taken prisoner by the Croats were ultimately exchanged and that not

 9     a single one was ever accused by the Croatian authorities of having

10     committed a war crime; is that correct?

11        A.   Yes.

12        Q.   Is it correct that not a single volunteer of the Serbian Radical

13     Party who went from Serbia to fight for the Serbian Krajina or for

14     Republika Srpska was ever accused of a specific war crime by the Croat or

15     Muslim authorities?

16        A.   That's correct, they had no reason.

17        Q.   So you confirm what I say in my question?

18        A.   Yes.

19        Q.   Explain one other thing to me.  Although you personally did not

20     work on this, but you explained how the volunteers were sent, what you

21     said was true.  They would come to the party headquarters, then they

22     would go to Bubanj Potok, to the barracks, and from there to the front.

23     But the following is very important.  Was there a frequent fluctuation of

24     volunteers?  For example, in one shift a man would leave as a volunteer

25     of the Serbian Radical Party, he would remain at the front for two or

Page 12236

 1     three months, he would come home, and then he would go to the front-line

 2     again, but he would join Arkan's men or the White Eagles or the Serbian

 3     Guard, and so on?  Did this fluctuation exist?

 4        A.   Yes, yes, yes, to the best of my knowledge, yes.  I have to say

 5     that in the park opposite the party, where Seselj saw them off, he didn't

 6     try to persuade them to commit crimes, to kill, to slaughter.  No.  He

 7     said, "Go and protect those people there."  And I think it's important to

 8     mention that.

 9        Q.   Did you attend any of my speeches when I was seeing them off,

10     when I told them how a volunteer of the Serbian Radical Party should

11     behave on the battlefield?

12        A.   Well, it transpires --

13        Q.   That he must behave in a chivalrous manner, that he must be

14     fearless, but that he must treat, in a noble and humane manner, children,

15     women, and so on and so forth?  Did I say those things?

16        A.   Yes, I confirm that that's true.

17        Q.   Did we, as a party, condemn severely all war crimes, including

18     looting, especially looting committed by others in the war-affected

19     areas?

20        A.   Yes, very often.  You criticised that very often.  Very often,

21     that would happen when we heard that someone had committed a crime on the

22     Serb side.

23        Q.   And do you remember my fierce attacks on Arkan and Arkan's men,

24     on Pantava [phoen] Guards, Mouseva's [phoen] Guard, the Serbian Guard,

25     the White Eagles and so on?

Page 12237

 1        A.   Yes, that's what I was referring to.

 2        Q.   Well, I'm surprised by one thing.  In this statement the

 3     Prosecution ascribes to you, you say the soldiers of the JNA were the

 4     most disciplined soldiers, that Arkan's men were very disciplined, and

 5     that the volunteers of the Serbian Radical Party were not disciplined,

 6     that they were of poor quality.  Did you really say that?

 7        A.   Well, I clarified this yesterday, but let me clarify once more.

 8             When I say "of poor quality," I don't mean that they were bad

 9     material, but these were people who are not trained.  They were not

10     trained professional soldiers and officers.  In the nature of things,

11     they should have gone through training and not been put in leadership

12     positions.

13             Well, let's not go into what I did or didn't say, but I think

14     that ordinary people should not be pushed into positions alongside

15     professional soldiers or men with military training, coming from the

16     police and so on and so forth, and sent to lead military operations,

17     because they don't know the rules of service, they don't know the

18     conventions on the protection of prisoners of war, and so on and so

19     forth.

20             There are many things that the Prosecution and others are

21     pressuring me to say about this statement, but I explained quite clearly,

22     and today with a clear conscience I still say that I did not make the

23     statement to the so-called investigators under oath and that it was not

24     my statement that made the Prosecution draw up the indictment against

25     you.  My statement came later, after the indictment, so I did not say

Page 12238

 1     anything that might have consequences for them or for you.

 2             And I was never shown what I said, because I would have said,

 3     "Wait a minute, I didn't say that," because a man can make a mistake.

 4     But someone shouldn't be made to pay for that with his freedom or to

 5     suffer for that reason or to waste money on false statements.  If I had

 6     been given a single statement of mine by the Tribunal or by the

 7     Prosecution, I would have objected and said, "Wait a minute, I didn't say

 8     it like this.  You didn't translate this properly, you didn't formulate

 9     it properly," and our job today would have been much easier, and the

10     Chamber and the Presiding Judge would have had an easier job.  So would

11     the Prosecutor and so would you, as the accused.  And I also, but I was

12     never given that statement of mine to look at, and to this day I don't

13     know what it says there.  And I'm afraid now what else I will hear read

14     out.

15             JUDGE LATTANZI: [Interpretation] Witness, we get your point, but

16     there's still something that is not clear to me.

17             Yesterday, we saw a signature on a page where it was stated that

18     the statement had been read back to you in your language, and at the

19     bottom of this we saw your signature.  And you confirmed that it was,

20     indeed, your signature.

21             Are you telling us today that you signed a document that was not

22     telling the truth, you signed a false statement; is that what you are

23     trying to tell us?

24             THE WITNESS: [Interpretation] Madam Judge, I'll explain this to

25     you.

Page 12239

 1             Yesterday and today, I say that the translation was never read

 2     out to me in Serbian.

 3             JUDGE LATTANZI: [Interpretation] Please respond by "yes" or "no."

 4             THE WITNESS: [Interpretation] The statement was never read to me.

 5             JUDGE LATTANZI: [Interpretation] You provided enough explanation

 6     yesterday.

 7             When you signed this acknowledgement, where you state that the

 8     statement had been read back to you and so on and so forth, you put your

 9     signature at the bottom of something that was not telling the truth,

10     because you signed this?  You signed this statement, where you said it

11     was your statement?

12             THE WITNESS: [Interpretation] But I said what it says there.

13     Well, yes, it's my signature, but the signature was always put on the

14     document in English and it was never translated to me.

15             Are you satisfied with my reply now, because that's the truth,

16     and the only truth, and the real truth.

17             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you only have a few

18     minutes left.

19             MR. SESELJ: [Interpretation]

20        Q.   Mr. Stefanovic, do you know of a single instance where volunteers

21     of the Serbian Radical Party participated in looting in war-affected

22     areas and brought war booty to Serbia in an organised manner?  Do you

23     know of a single instance of that?

24        A.   I don't know of a single instance.  Had they done this, by any

25     chance, they would have been punished or branded in public by the

Page 12240

 1     leadership of the party.  That was the standpoint of the party.

 2        Q.   And we expelled quite a few people from the Serbian Radical Party

 3     for lack of discipline, do you remember, because of individual instances

 4     of theft, failure to obey orders, and so on?

 5        A.   Yes.

 6        Q.   Do you remember that I was the only person in Serbia who dared to

 7     attack Arkan publicly, openly, looking him in the eye, because Arkan was

 8     all-powerful in Serbia?  Was he omnipotent in Serbia?

 9        A.   He did whatever he wanted, and I remember that TV debate very

10     well, when you told him some things, and later on I heard in person from

11     the cameraman and the person hosting the show that they were terrified

12     that he would take out a pistol and shoot you then and there.

13        Q.   Are you aware that after all those attacks of mine, that Arkan

14     sued me?

15        A.   Yes, yes, when you told him that he had worn more socks on his

16     head than you had worn on your foot.

17        Q.   I think that you came to the Palace of Justice at the time to

18     attend the trial, when I turned up in the courtroom, and the judge said

19     15 minutes before the start of the trial Arkan's lawyer arrived, Toma

20     Fila, and he withdrew the lawsuit against me; do you remember that?

21        A.   Yes, I remember that very well.

22        Q.   So they didn't dare face me in court either; is that how it was?

23        A.   Yes, yes.

24        Q.   Mr. Stefanovic, you must be aware that Ljubisa Savic, Mauser, the

25     commander of the Kadarda Pantovi [phoen] paramilitary unit, was the

Page 12241

 1     deputy prime minister under Djindjic?

 2        A.   Yes, of the Democratic Party for Bosnia-Herzegovina.

 3        Q.   And also in Serbia, and the president of the party branch in

 4     Republika Srpska?

 5        A.   Bosnia-Herzegovina.

 6        Q.   The party wasn't active all over Bosnia-Herzegovina, but only

 7     Republika Srpska; am I right?

 8        A.   Yes, yes.  Initially, it was Bosnia-Herzegovina.  Mauser was the

 9     president of the Democratic Party for Bosnia-Herzegovina in 1992.  But

10     you are talking about the time when Republika Srpska already existed, and

11     that was after 1995.  But the answer is "yes."

12        Q.   Are you aware that The Hague Prosecution, in its indictment,

13     accused me of crimes committed by Ljubisa Savic, Mauser, through my

14     alleged participation in a joint criminal enterprise; are you aware of

15     that?

16        A.   I don't know.  I'm surprised at this.

17        Q.   Well, from this, it follows that I was in a JCE with

18     Zoran Djindjic, because instead of accusing Zoran Djindjic for what

19     Ljubisa Savic, Mauser, did, they put this in the indictment against me.

20     Are you aware of that?

21        A.   In 1992, I know that Ljubisa, Mauser, established some sort of

22     camp, and we had to intervene.  Someone intervened to have this broken

23     up, dissolved, in Bijeljina, and when the conflict broke out, he had

24     already made false steps, and we had nothing in common with Mauser or any

25     kind of military cooperation on anything else, to the best of my

Page 12242

 1     knowledge.

 2        Q.   Do you know that it was the president of the Serbian Chetnik

 3     Movement and later the president of the Serbian Radical Party, for

 4     Semberija, Mirko Blagojevic, on several occasions publicly opposed to

 5     Mauser's persecution of the Muslim population from Semberija, even the

 6     Muslims that belonged to the Serb Army?

 7        A.   Yes, that is something I'm very familiar with, that that's

 8     precisely how it was.

 9        Q.   Well, we won't dwell there, because The Hague Prosecutor has all

10     the documents -- those documents in its possession, all the statements

11     made by Mirko Blagojevic in Bijeljina, when he stood up in defence of the

12     local Muslim population.

13             Now, do you know, for example, that even today, in the Serbian

14     Radical Party in Bijeljina, we have quite a number of Muslims, even from

15     "baj" [phoen] families, high-born families, and do you know that among

16     the volunteers of the Serbian Radical Party, there were Serb Catholics,

17     so-called Croats, that we had Muslims, that we had Hungarians, that we

18     even had Albanians?

19        A.   Yes.

20        Q.   Do you remember a case -- the case of a Hungarian who was a

21     volunteer of the Serbian Radical Party, who was killed on the front, and

22     the Roman Catholic priest in Vojvodina did not want to conduct a service

23     at his burial because he was a member of the Serbian Radical Party?

24        A.   Yes, I remember that well.

25        Q.   Do you know that as for the Chetnik vojvoda, I proclaimed an

Page 12243

 1     Albanian a Chetnik vojvoda, in fact?  His name was Mujo Bunjaku, and he

 2     had a new name, Oliver Dennis Barrett?

 3        A.   Yes.

 4        Q.   Do you remember that I promoted him to Chetnik vojvoda for

 5     bravery -- his bravery during the war?

 6        A.   Yes.

 7        Q.   Do you know that he was later killed in Belgrade?

 8        A.   Yes.

 9        Q.   Do you know why he was killed?  Let me remind you.  He was killed

10     by Vaso Djukanovic and Jozo Vujicic because he set up -- he lived

11     together with the wife of Vaso Djukanovic, cohabited with her?

12        A.   Yes, yes, that is correct.

13        Q.   Now, do you know that The Hague -- the OTP of The Hague procured

14     certain statements from witnesses who falsely accused me of having killed

15     Dennis Barrett, that there are people who are ready to do things like

16     that, too?  You find that funny?

17        A.   Well, not funny; strange.

18        Q.   Well, I find it funny, too, but I have to confront ludicrous

19     accusations of that kind.

20             Do you want to say something, Mr. Stefanovic?  If not, we can

21     move on.

22             Now, you contacted -- you sent a letter, in fact, to the

23     Prosecution on the 15th of May of this year, and in that letter, well,

24     you say information for the Tribunal, and especially for the Trial

25     Chamber, to the attention of the Trial Chamber in the Seselj trial, where

Page 12244

 1     you ask them to strike you from the list of Prosecution witnesses; isn't

 2     that right?

 3        A.   Yes.

 4        Q.   All right.  At that time, you stipulated that you were promised

 5     that you would not have to appear as a witness live in this trial and

 6     that you certainly wouldn't be travelling to The Hague, and that

 7     Zoran Djindjic suggested that you should not accuse me falsely of crimes

 8     but that you should try and discredit me as a political adversary.  And

 9     that is in paragraph 2 of that letter of yours that I was disclosed --

10     that was disclosed to me by the Prosecution.

11             And you also state that when you gave the statement, that there

12     was a man sitting in the room throughout, and that nobody told you who

13     that man was and why he was in the room where you were making your

14     statement, and that he was wearing a camouflage uniform; that he was

15     white, of short build, very nervous, and rigid in his conduct.  Is that

16     what you said?

17        A.   Yes.

18        Q.   Do you remember that man in uniform?

19        A.   Yes.

20        Q.   Can you -- were you able to recognise the uniform, whose army it

21     belonged to?

22        A.   Well, it wasn't actually a camouflage uniform.  It was -- well, I

23     don't know.  It was sort of dark green or whatever.

24        Q.   You say in your letter that the man left a negative effect on

25     you, and that he made you nervous and that you -- and made you afraid,

Page 12245

 1     and you wanted to get away from him and leave the room because you felt

 2     insecure and afraid?

 3        A.   Yes.  He was sitting behind me, and I had the feeling that he was

 4     some sort of security detail and that people from the Prosecution team

 5     might have been afraid that I might not attack them physically, so I had

 6     the impression that he was in the room because of that.  And I asked him,

 7     "What are you doing here, who are you?"  And I even had a brief

 8     conversation and said that nobody introduced him to me, nor did anybody

 9     tell me who he was and what he was doing there.  So I don't know anything

10     about that person, about that man.

11        Q.   In your letter, you say that The Hague OTP never told you in what

12     capacity they were interviewing you, but that they did not allow your

13     lawyer to attend the interview; isn't that right?

14        A.   That's right, and they won't -- wouldn't allow my lawyer to

15     attend my examination yesterday either, nor was my counsel allowed to

16     attend at any time.

17        Q.   Whereas according to the Serbian legal system, you have the right

18     to a lawyer, whoever is examining or interviewing you; isn't that right?

19        A.   Yes, and not only in the Serb system but in others too.

20        Q.   And when a municipal service calls you up, you have the right to

21     go there with a lawyer, accompanied by a lawyer, let alone when it's a

22     court prosecutor or the police?

23        A.   Yes.

24        Q.   And you told them at the time that you confirmed that you signed

25     the statements, but that you never saw what it actually said in those

Page 12246

 1     statements; that's what you state in the letter?

 2        A.   Yes, and I asked them to send me the statements.  That's what I

 3     asked them to do there.

 4             THE INTERPRETER:  The microphone is not working again.  Thank

 5     you.

 6             JUDGE ANTONETTI: [Interpretation] If you have one last question,

 7     could the court deputy make sure that a technician comes.  It should have

 8     been done, well, a long time ago.

 9             Madam Registrar, do make sure that an engineer can come in.  I

10     can't work in these conditions.

11             JUDGE HARHOFF: [Interpretation] It seems to be working now.

12             JUDGE ANTONETTI: [Interpretation] Your time is up.  You may have

13     one last question, Mr. Seselj.  Put it straight away.

14             MR. SESELJ: [Interpretation] I have one more question.

15        Q.   As you state here, and that is in paragraph 3 on page 2, that

16     your testimony was, in fact, made under duress because you weren't able

17     to refuse Zoran Djindjic's request, now, did The Hague Tribunal ask you

18     to have a meeting and discuss the letter with you, and then to show you

19     the statement so that you could go through your statement to see what you

20     actually said and what you didn't say and all the rest of it, because I'm

21     rather surprised and astonished that they never showed you the statement.

22     They must have had a proofing session with you before your testimony, and

23     during that proofing session they must have shown you -- they ought to

24     have shown you the statement and gone through the statement and informed

25     if you made any corrections to that statement.  So did any of that

Page 12247

 1     happen?

 2        A.   I'm telling you for the third time that none of that happened,

 3     and that that's why I wrote a letter to the Tribunal, and that is a

 4     document.  I'm sure there were other documents.  I sent two or three

 5     documents requesting the Prosecution, or the Tribunal, or whoever, to

 6     provide me with the statements so that I could look through them and

 7     state my views.  And I also asked them to -- well, I don't know -- to

 8     strike me from the list of witnesses, because my statement cannot be

 9     relevant.  And I wrote that, too.

10             THE ACCUSED: [Interpretation] Thank you.  That completes my

11     cross-examination.  Thank you, Mr. Stefanovic.

12             THE WITNESS: [Interpretation] You're welcome.

13             JUDGE ANTONETTI: [Interpretation] Do you have any redirect,

14     Ms. Dahl?

15             MS. DAHL:  Yes, please, Your Honour.

16                           Re-examination by Ms. Dahl:

17        Q.   Mr. Stefanovic, you said earlier today in your testimony that you

18     looked at today's newspaper, the 'Glas Javnosti'?

19        A.   Yes.

20        Q.   Your interview is in that paper today; correct?

21        A.   Yes.

22        Q.   Do you recall the instructions at the end of your testimony

23     yesterday from the Trial Chamber?

24        A.   I do recall the instructions I was given.  But what have

25     instructions got to do with it, with your question?

Page 12248

 1        Q.   You were instructed to refrain from any contact with the media;

 2     correct?

 3             THE ACCUSED: [Interpretation] Objection.

 4             THE WITNESS: [Interpretation] Well, I didn't contact the media.

 5     I gave the interview the day before yesterday.  And let me tell you again

 6     the time and place and journalist.  I gave an interview the day before

 7     yesterday.  The journalist's name was Milosevic, the 'Glas Javnosti'

 8     journalist.  We were sitting in the Atos Pizzeria in Belgrade where I'm a

 9     frequent guest.  And we sat there from half past 3.00 until 5.00, and she

10     recorded it all into a Dictaphone and then she went to the editorial

11     offices and she could have released it the same day or the next day or

12     two days later.  That's up to the editorial board.  But, anyway, I was

13     very angry because the interview was -- did not come out yesterday.

14             But what you're trying to do now has nothing to do with that,

15     because I didn't come into contact -- I didn't contact the journalist.  I

16     left here at about 7.30, waited for half an hour for my transportation,

17     which means that I was in town about 8.30.  So it was impossible to give

18     an interview after that.  That would have been 9.30 and so on, because

19     the papers go to the press at 8.00.  So there's no need for you to try

20     and do that.

21             The fact that it came out today, that's got nothing to do with

22     me.  I'm not a member of the editorial board.  It's up to the editors

23     when they decide to publish it, and I've just told you when I gave the

24     interview.

25        Q.   You've answered my question.  You said in your testimony earlier

Page 12249

 1     today that you analysed the signatures on your statement, and I'm quoting

 2     from the transcript:

 3             "They're not my signatures.  They were scanned and only copied

 4     onto the Serbian language, because when I was signing, there was no

 5     translation into Serbian."

 6             Do you remember giving that testimony?

 7        A.   Yes, I said something very similar to what you've just stated.  I

 8     never signed the Serbian version.  That's it, there you have it, never.

 9     If there's a signature there, then it's a forgery.  I only signed the

10     English version, which wasn't translated to me, nor was it read back to

11     me.

12        Q.   And let me make sure we're talking about the same documents.  I'm

13     referring to the 2006 statement in the Serbian language.  Is that the one

14     you're talking about?

15        A.   Yes, I challenge that this was my authentic statement, because as

16     far as I was able to see, many of the -- well, I don't have the integral

17     statement, I don't have the whole of it.  I don't know what it says in

18     this statement, either.  All I read here with my very own eyes is that it

19     was 0602436, paragraphs 21 and 26, and I stated my views about that

20     yesterday and today.  So they are totally untrue, and I say with full

21     responsibility that I never said any of that.

22             MS. DAHL:  For the Chamber's convenience, I have obtained from

23     the evidence vault at the Tribunal the original signed copies bearing

24     Mr. Stefanovic's original signature in blue ink on both the English and

25     Serbian versions, and I'd like to tender them into evidence to supplement

Page 12250

 1     the copies that you received and marked for identification yesterday.

 2     The ERN number on the top of the Serbian language document is 0601-2431,

 3     and it ends at 0601-2455.  The English original --

 4             JUDGE ANTONETTI: [Interpretation] Can I see the documents in

 5     Serbian, because we didn't have them before.

 6             MS. DAHL:  For the record, the English signed original bears ERN

 7     range 0601-2396 and concludes --

 8             JUDGE ANTONETTI: [Interpretation] Witness, I have here in front

 9     of me your statement in Serbian.  I also have in front of me your

10     signature in blue ink.  What do you have to say to that?

11             THE WITNESS: [Interpretation] Well, I really can't remember what

12     it says here.  Well, I don't know all that it says there.  I never read

13     it all, and I say that with full responsibility, that I never read that

14     document.  And I don't know what the document -- what it says in the

15     document.  So why didn't you provide me with that document?

16             JUDGE ANTONETTI: [Interpretation] I'm going to ask for the first

17     page to be put on the ELMO.  Can it be put on the ELMO, Madam Registrar,

18     so that the first page can be seen and shown to the witness in his

19     language.

20             THE WITNESS: [Interpretation] There's no need to put that on the

21     overhead projector.  I don't deny that it's my signature.  But what I'm

22     telling you is this:  Why wasn't I provided with the statement, when I

23     requested in writing that the Prosecution provide me with it?  And I'm

24     telling you that I never read it, and many of the things that are written

25     in there are not what -- are things I did not say.  I say that under

Page 12251

 1     oath.  So there's no need to put it on the overhead projector.  That is

 2     my signature.  It couldn't have been signed by anyone else but me, but I

 3     don't remember.

 4             JUDGE ANTONETTI: [Interpretation] You admit that you signed the

 5     text in your own language and the text in English.  You signed both

 6     versions.  Well, we have here material evidence of it.

 7             THE WITNESS: [Interpretation] I don't remember what I signed.

 8     All I remember is that I signed everything, but that nobody told me what

 9     it says in those documents.

10             JUDGE ANTONETTI: [Interpretation] Madam Registrar, give us a

11     number for the B/C/S version.

12             JUDGE LATTANZI: [Interpretation] But each and every page was

13     signed, not just the first one, Witness.

14             JUDGE ANTONETTI: [Interpretation] An MFI number, please, because

15     we shall determine the final admission later on.

16             THE REGISTRAR:  Exhibit P656 marked for identification, Your

17     Honours.

18             MS. DAHL:  Your Honour, to complete the record, the last page of

19     the English language statement, signed by the witness, was 0601-2430.  It

20     is the same document translated into English as the original Serbian that

21     I have tendered.  If the Chamber would like to see this, which also has

22     the original signature of the witness, I'm at your convenience or I can

23     put it back in the vault.

24             JUDGE ANTONETTI: [Interpretation] But with regard to the English

25     version, we already had it.  But we shall check the original.  Yes, we

Page 12252

 1     can see the signature in blue ink.

 2             Good, you can put it back into the vault.

 3             Do you have other questions?

 4             MS. DAHL:  Yes, Your Honour, very briefly.

 5        Q.   Mr. Stefanovic, you've just --

 6             JUDGE ANTONETTI: [Interpretation] Go ahead.

 7             MS. DAHL:

 8        Q.   You've just told the Chamber that you were never given a copy of

 9     your statements to review in advance of your testimony.  Did I understand

10     you correctly?

11        A.   Yes.

12        Q.   Do you deny that we had an appointment for last Friday in

13     Belgrade?

14        A.   Yes.

15             THE INTERPRETER:  The answer was yes, the interpreter didn't

16     know.

17             MS. DAHL:

18        Q.   So we did not have an appointment; is that what you're saying?

19        A.   We didn't have a meeting, but I asked for that in May.

20        Q.   I offered to provide you with a full set of your statements this

21     past Friday in Belgrade, didn't I?

22        A.   Well, yes, but you could have given it to me on Saturday.  I

23     couldn't have gone on Friday, which was a saints day, so I couldn't have

24     done that on the Friday.

25        Q.   After I travelled to Belgrade to meet with you, you didn't show

Page 12253

 1     up for the appointment?

 2        A.   I was absent for justified reasons.

 3        Q.   You didn't call me to tell me you weren't coming?

 4        A.   No.

 5        Q.   And I told you the Registry officer would be bringing a full set

 6     of your statements for you in preparation for the videolink, didn't I?

 7        A.   I don't understand.  I don't understand.  What is it you just

 8     said?

 9        Q.   The Registry has a full set of your statements there with you for

10     your testimony right now; correct?

11        A.   Yes, correct.

12        Q.   You met with the Prosecution investigators in February 2003?

13        A.   But nobody showed me these documents here.

14        Q.   Mr. Stefanovic, you met with the Prosecution investigators in

15     February 2003; correct?

16        A.   Yes.

17        Q.   And you signed a statement dated 12 February 2003?

18        A.   Yes.

19        Q.   That's the same statement we talked about in court yesterday and

20     today?

21             THE ACCUSED: [Interpretation] Objection.  Judges, on that

22     statement, I have an objection.  Mr. Stefanovic, you'll have to keep

23     quiet while I present my objection.

24             On this statement dated 2003, there is no signature of

25     Mr. Stefanovic's in the Serbian version.  However, at the bottom of the

Page 12254

 1     page, it always says "signed."  But I assume that applies to the English

 2     version, not the Serbian version.  In the 2003 Serbian version,

 3     Mr. Stefanovic's signature is not there.

 4             JUDGE ANTONETTI: [Interpretation] There was no need to say that.

 5     We knew that already.

 6             Please continue, Ms. Dahl.

 7             MS. DAHL:

 8        Q.   Mr. Stefanovic, you remained in contact with the Prosecution the

 9     following year, 2004?

10        A.   Yes, probably.  I don't know.

11        Q.   You remained in contact with the Prosecution throughout 2005?

12        A.   Yes.

13        Q.   You had a meeting with a Prosecution investigator in the

14     beginning of 2006, in February, at the field office; correct?

15        A.   Yes.

16        Q.   You reported that you had some safety concerns?

17        A.   Yes.

18        Q.   You said you were willing to testify before this Tribunal, but

19     you wanted protection?

20        A.   No.

21        Q.   You told the investigator that Mr. Petkovic was negotiating to

22     become a witness for the Defence?

23        A.   No.

24        Q.   You told the investigator that a bodyguard of Mr. Seselj's was

25     trying to contact you, and you perceived that to be a threat?

Page 12255

 1        A.   I don't know which bodyguard.  I was in contact with him, not

 2     Seselj.

 3        Q.   Mr. Panic.

 4        A.   Mr. Panic?  Well, I was in contact with him.  Why would I be

 5     afraid of him?  He was in conflict with Seselj, as far as I know.

 6        Q.   You told the investigator, when you met on 19 February 2007, that

 7     Mr. Panic was trying to contact you over the phone?

 8        A.   I don't know what the investigator wrote, but I always talked to

 9     Mr. Panic, who was not on good terms with Seselj, so I don't know where

10     the problem is.  Why would I be afraid of him?

11             THE ACCUSED: [Interpretation] Objection.  Mr. President, I didn't

12     intervene straight away because I was inquisitive and interested to know

13     what the answer would be of Mr. Stefanovic to -- what his response to the

14     Prosecutor would be, but these were impermissibly leading questions, and

15     you never ruled that Mr. Stefanovic should be proclaimed a hostile

16     witness vis a vis the Prosecution, which would allow Madam Dahl to put

17     leading questions.  These are all leading questions.

18             JUDGE ANTONETTI: [Interpretation] The question is not whether the

19     questions are leading or not.  We just need to know why he asked to be

20     protected and why he no longer requests protective measures.  That's the

21     mystery.

22             MS. DAHL:

23        Q.   Mr. Stefanovic, can you answer my question, please?  You told the

24     investigator that Mr. Panic was trying to contact you; correct?

25        A.   No, I didn't tell the investigator that.  It was impossible that

Page 12256

 1     I was afraid of Panic then, now, or any time, since Panic is in conflict

 2     with Seselj since 2000 or 2001, so there's no reason why I should be

 3     afraid of Panic.  So that means that that's not true.

 4             And the second key point, the question raised by the Judge, I'll

 5     respond to that, if I may.

 6             JUDGE ANTONETTI: [Interpretation] Go ahead.

 7             THE WITNESS: [Interpretation] It's like this:  From the very

 8     beginning, I never asked for any protective measures.  Yesterday, when I

 9     came here to this office, I was told that there would be some protective

10     measures put in place.  I don't know what they were called.  That I would

11     be protected, anyway.  And I told you that I do not wish to have

12     protective measures, nor did I ever want protective measures, and that

13     everything that I was going to say would be the truth, and that I don't

14     want to hide behind my own testimony.  And then you decided to lift the

15     protective measures which I'd never asked for.  And then there was some

16     code name, 009, or some pseudonym or whatever.  Some code was assigned

17     initially.

18             JUDGE ANTONETTI: [Interpretation] Ms. Dahl.

19             MS. DAHL:

20        Q.   You continued to be cooperative with the Prosecution until the

21     letter that you sent on -- in May 2008 to us?

22        A.   Yes, I informed you before that, because I had at least 100

23     telephone calls a year.

24        Q.   So on 16 May 2008, you asked to be removed from the witness list?

25        A.   Yes.

Page 12257

 1        Q.   And that was the first mention that you made of an agreement that

 2     you allege with Prime Minister Djindjic that you would never be a witness

 3     in this case?

 4        A.   I told you in 2007, in September, that this agreement existed.  I

 5     told you, personally.

 6        Q.   Mr. Stefanovic, I put it to you that that is a lie.  Do you deny

 7     that?

 8        A.   Give me the record of that meeting.

 9        Q.   You --

10        A.   Is there a record of that meeting?

11        Q.   You never mentioned that man's name in my presence ever before;

12     isn't that the truth?

13        A.   Whose name, excuse me?

14        Q.   Mr. Djindjic.

15        A.   I tell you that I did.  If you have the record, let's look at the

16     record of that meeting.

17        Q.   Mr. Stefanovic, at that meeting you told myself and other

18     representatives of the Prosecution that the Radicals were putting

19     pressure on Prosecution witnesses, didn't you?

20        A.   Give me the record and let me see what I said.  I can't remember

21     now.  I'm excited and I can't remember what I said.  Show me the record.

22        Q.   And we discussed that you would be the first witness at the

23     trial?

24        A.   I don't remember that.

25        Q.   And you said that you were agreeable to testifying, didn't you?

Page 12258

 1        A.   No, that's not correct, certainly, because from the summer --

 2     well, I don't know when the trial started.  The telephone kept ringing

 3     non-stop.  You kept looking for me, looking for me, looking for me.

 4     Whether it's true or not, I think it is, and I persistently tried to let

 5     you know that I wasn't supposed to come to the trial.  I sent medical

 6     documentation, I sent you letters, I sent -- I don't know what I didn't

 7     send, thinking that there was no need for me to appear.

 8        Q.   And you said you wanted to be a Defence witness?

 9        A.   Yes.

10        Q.   And in fact, you gave a press interview in October 2008 in which

11     you said you were still a member of the Radical Party?

12        A.   That is not correct.  That's a misinterpretation in the daily

13     paper 'Courier,' which has introduced a lot of confusion.  I said --

14        Q.   You told the reporter who wrote the story that appeared in

15     'Courier' that you were still willing to help the party where you could?

16        A.   I think that was after the conflict between Nikolic and the

17     Radicals.

18        Q.   You said you still had the membership card in your wallet, didn't

19     you?

20        A.   Yes, I still have it.

21             MS. DAHL:  Your Honour, I have no further questions.

22             JUDGE ANTONETTI: [Interpretation] I am now checking that it can

23     be heard and interpreted into English.  That's the main thing.

24             Thank you for testifying, Witness.  We are now going to break for

25     20 minutes, Witness.  The court deputy is going to look after you and

Page 12259

 1     look after the issue of costs for your day.

 2             We are now going to have a 92 ter witness with protective

 3     measures, so we'll have to lower the blinds first, and I ask the court

 4     deputy to make sure that my mike is repaired.

 5                           [Videolink concluded]

 6                           --- Recess taken at 5.46 p.m.

 7                           [The witness entered court]

 8                           --- On resuming at 6.10 p.m.

 9                           [Open session]

10             JUDGE ANTONETTI: [Interpretation] Very well.

11             Good afternoon, sir.  We are in closed session.  You have been

12     granted protective measures.  You have been granted a pseudonym, VS-1068.

13     When we move back into open session, your face will be distorted on the

14     screen.

15             Now I'm going to ask you to state your first name, last name, and

16     date of birth.

17                           [Private session]

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 12260











11 Pages 12260-12261 redacted. Private session.















Page 12262

 1   (redacted)

 2   (redacted)

 3   (redacted)

 4   (redacted)

 5                           [Open session]

 6             THE REGISTRAR:  Your Honours, we're back in open session.

 7             THE ACCUSED: [Interpretation] Mr. President, what I've just been

 8     handed is something I have here, but I'd like to draw your attention to

 9     the fact that this is not the 92 ter statement, because all the 92 ter

10     statements have that in the title, stating that they're 92 ter

11     statements, and that's what it says in the Prosecution request for

12     witnesses under 92 ter.  This is just the 2004 witness statement that I

13     have.  I haven't mislaid that, but I don't have the 92 ter statement.

14             JUDGE ANTONETTI: [Interpretation] Madam Prosecutor, this

15     statement we have here was to be admitted pursuant to Rule 92 bis; is

16     that correct?

17             MS. PRASAD:  92 ter, yes, Your Honour.  There are two statements,

18     two written statements of Witness 1068, dated 18 March, 1995, and 13 June

19     2004, marked respectively ERN RR04-7394 - RR04-7404, and

20     0357-8609 - 0357-8616.

21             Your Honours, by the Trial Chamber's second decision dated 27

22     February 2008, we were granted permission to admit both of these

23     statements to the Court.  We were granted under the 92 ter decision.

24             THE ACCUSED: [Interpretation] Mr. President, I'm quite so sure,

25     and I don't know why I'm sure about this, but I seem somehow to be sure

Page 12263

 1     that you and your fellow Judges will not allow this to be admitted under

 2     statement 92 ter.

 3             The first statement was given in the Centre of the Security

 4     Services of Bosnia-Herzegovina in Mostar.  It's a statement taken by the

 5     police of Bosnia-Herzegovina, whereas this statement taken by the

 6     Prosecution is not an integral statement, because it follows on to the

 7     statement given to the Bosnian authorities or, rather, the Muslim --

 8     authorities of the Muslim-Croatian federation.

 9             JUDGE ANTONETTI: [Interpretation]  Mr. Seselj, let us check all

10     this.  I have here a statement by the witness dated 13th of June, 2004.

11     And you're quite right, there is another statement from the Ministry of

12     the Interior of Bosnia-Herzegovina, dated 18th of March, 1995, after the

13     first one.  So the Prosecutor is requesting the admission of the second

14     statement, the statement of 13th of June, 2004.

15             Madam Prosecutor, is that right?  The statement that's to be

16     admitted pursuant to Rule 92 ter is the one dated the 13th of June, 2004?

17             MS. PRASAD:  Your Honour --

18             THE ACCUSED: [Interpretation] No, Mr. President.

19             MS. PRASAD:  Your Honours, we are seeking to -- seeking for both

20     the statements to be admitted under 92 ter, as per the DC decision we

21     were allowed.  And, Your Honours, for your information, the 13th June

22     2004 statement is basically the witness basically expanded on the

23     information provided and clarified certain issues discussed in his

24     statement dated 1995, which he gave to the Mostar Security Services.

25             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, in the decision of

Page 12264

 1     the 27th of February, the Trial Chamber authorised the application of the

 2     92 ter statement for both statements, because the second statement, given

 3     to the authorities of the Republic of Bosnia and Herzegovina, was a

 4     supplement to the first statement.  So, actually, the 92 ter statement

 5     covers both statements, the one dated 23rd of June, 2004, and the one

 6     dated 18th of March, 1995.

 7             THE ACCUSED: [Interpretation] Mr. President, the statement given

 8     to the Prosecutor in 2004 is, in fact, a supplement to the statement

 9     given to the Muslim authorities in 1995.  Now, I'd like to draw attention

10     to the fact that thus far it has never happened that any Trial Chamber of

11     The Hague Tribunal accepts a statement given to the Serbian, Muslim, or

12     Croatian authorities as a statement under 92 ter or 92 bis.  Under 92 bis

13     or 92 ter, what was accepted was statements given exclusively to

14     The Hague Tribunal, whereas these two statements, one to the Muslim

15     authorities and one to The Hague Tribunal, is something that the

16     Prosecution is treating as a whole, which is impossible, in my opinion.

17             JUDGE ANTONETTI: [Interpretation] Mr. Mundis.

18             MR. MUNDIS:  Thank you, Mr. President, and good afternoon, Your

19     Honours.

20             It's certainly been the practice of Chambers of the International

21     Tribunal to admit statements, irrespective of to whom those statements

22     were given, as long as the specific terms of Rule 92 ter or 92 bis have

23     been complied with.  Mr. Seselj is absolutely wrong when he states that

24     The Hague Tribunal, as he puts it, has never accepted a statement given

25     to the Serbian, Muslim, or Croatian authorities.  That is simply not

Page 12265

 1     true.

 2             The only requirements for the admission of written statements are

 3     those that are set forth in the Rule, and there is no specific

 4     requirement that a written statement be provided to an investigator of

 5     the Tribunal in order for it to be admissible pursuant to Rules 92 bis,

 6     92 ter, or even under Rule 89(F).

 7             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, your submissions

 8     have been recorded on the transcript, and I will personally keep that in

 9     mind when the Chamber rules on the admission of these statements.

10             THE ACCUSED: [Interpretation] One more sentence and I won't

11     interrupt anymore.

12             Mr. President, it was the practice of certain Trial Chambers that

13     statements given to the local authorities were taken under 89(F), because

14     it says there that any statement can be taken under certain conditions.

15     But in practice -- or, rather, the practice to have two statements

16     treated as one statement under 92 ter is something that I am not aware

17     of.  So Mr. Mundis can tell me which Trial Chamber accepted something

18     like that and when.

19             Here we have two quite separate statements, and the Prosecution

20     is treating them as one statement under 92 ter, whereas in other cases

21     the Prosecution prepares special 92 ter witnesses, and if the witness

22     gave more than one statement, then they make a compilation of all those

23     statements and provide one text, whereas here you, in fact, have two

24     statements, and there are contradictions in those two statements.

25     Unfortunately, I'm not able to point out those contradictions, because as

Page 12266

 1     you know, a priori, I refuse to accept that type of testimony.

 2             JUDGE ANTONETTI: [Interpretation] The Trial Chamber will rule on

 3     the matter in due course.  I'm not aware of this practice.  It's a first

 4     for me.  The Trial Chamber will rule on this.

 5             Ms. Prasad, we are in open session.  Please give us the summary

 6     of these two statements, since we are talking about two statements.

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12             JUDGE ANTONETTI: [Interpretation] But can you read the first part

13     in open session, and then we should move into private session.  Okay, so

14     when the time comes, please ask for private session.

15             MS. PRASAD:  Thank you, Your Honours.

16             The witness is a Bosniak Muslim.  In 1992, he was 21 years old

17     when the events unfolded in Mostar.

18             On 3rd April 1992, there was a tank explosion near the Northern

19     Camp in Zalik, Mostar.  As a result, around 500 to 600 people, including

20     Serbs, Croats and Muslims, took refuge in a shelter in Zalik, as they

21     felt safer there.

22             In May 1992, the Serbs took over the area and restricted the

23     movement of all non-Serbs.  On 7th May, few reservist troops entered the

24     shelter and selected ten non-Serbs and took them away.  The when they

25     were brought back, the detainees informed the rest that they were taken

Page 12267

 1     to Northern Camp barracks, where they were forced to kneel with their

 2     heads bowed down the entire night.

 3             Around 13 May 1992, a Chetnik entered the shelter and announced

 4     that more Chetniks were advancing and he was about to begin cleansing

 5     Bijelo Polje.

 6             On 22nd May 1992, a Chetnik police commander from Zalik came to

 7     the shelter and made a list of people who would clean the city and the

 8     ruins.  The detainees were labour to clean streets and garbage at

 9     locations where shooting and shelling was ongoing, endangering their

10     lives, and using them as human shields.

11             On 13 June 1992, having heard that the Northern Camp would be

12     mined, the witness and several hundred people gathered at the shelter,

13     but the number of people kept increasing as Chetniks were forcing them

14     out of their apartments and bringing them to the shelter.  A few Chetniks

15     came to the shelter and demanded that all male detainees line up outside

16     with their ID cards.  Then they were taken to Northern Camp barracks.

17             From there, the witness, along with 15 other detainees, was

18     transported in a truck to a town cemetery building.  They were imprisoned

19     in a room and taken one by one for interrogation.  They could hear moans

20     and cries for help.  Most of the detainees, including the witness's

21     father, never returned.

22             The witness was also taken for interrogation, during which he was

23     beaten and a knife was held to his throat, and a loaded gun to his head,

24     and one of the interrogators threatened him to answer or he would pick

25     his eyes out and cut off his ears and throat.  After 20 minutes, the

Page 12268

 1     witness was thrown into a dark room full of interrogated people.

 2             Your Honour, at this point can we move into private session.

 3                           [Private session]

 4   (redacted)

 5   (redacted)

 6   (redacted)

 7   (redacted)

 8   (redacted)

 9   (redacted)

10   (redacted)

11   (redacted)

12   (redacted)

13   (redacted)

14   (redacted)

15   (redacted)

16   (redacted)

17   (redacted)

18   (redacted)

19   (redacted)

20   (redacted)

21   (redacted)

22   (redacted)

23   (redacted)

24   (redacted)

25   (redacted)

Page 12269

 1   (redacted)

 2   (redacted)

 3                           [Open session]

 4             THE REGISTRAR:  Your Honours, we're back in open session.

 5             MS. PRASAD:  Your Honours, with your permission, I would like to

 6     proceed with questions regarding the statement to the witness.

 7             Thank you, Your Honours.

 8                           Examination by Ms. Prasad:

 9        Q.   Witness, did you give a statement on 18 March 1995 to the

10     Ministry of Interior, Mostar Security Services?

11        A.   Yes, I did.

12        Q.   And then on 13 June 2004, when you met with the representatives

13     of this Tribunal?

14        A.   Yes, I did.

15        Q.   Did you have the opportunity to review your written statement in

16     your own language?

17        A.   I looked through my statement, yes, in my own language.

18             MS. PRASAD:  Usher, could you please display a hard copy of the

19     B/C/S version of the statement dated 18 March 1995, and we can hand a

20     copy to the witness, bearing 65 ter number 5035B.  And, please, it's not

21     to be broadcasted, the statement.  Thank you.

22        Q.   Witness, could you look at the first page of the B/C/S statement?

23        A.   Yes.

24             MS. PRASAD:  Your Honours, I wanted to check if he has the 1995

25     statement, dated 18 March 1995.  Are we -- we have to give him the

Page 12270

 1     1995 -- 18th March 1995.  Thank you.

 2        Q.   Witness, could you look at the first page of the statement.  Do

 3     you recognise your signature at the bottom of the page?

 4        A.   Yes, that's my signature.

 5        Q.   Please flip through the pages and look at page 11 of the

 6     statement.

 7        A.   Yes.

 8        Q.   Do you recognise your signature?

 9        A.   Yes, I do recognise my signature.

10             MS. PRASAD:  Now, Usher, can you please hand out the hard copy of

11     the English and the B/C/S version of the statement dated 13 June 2004.

12        Q.   Witness, do you recognise your signature on the first page of the

13     English version?

14        A.   Yes, I do recognise my signature.

15        Q.   Can you flip through the pages and turn to page 7?

16        A.   Yes.

17        Q.   Do you recognise your signature?

18        A.   Yes, I do recognise my signature.

19             MS. PRASAD:  Your Honours, I would like to bring to your

20     attention that the B/C/S version of the 13 June 2004 statement was signed

21     by the witness subsequently in November 2004, bearing ERN

22     0363-1619 - 0363-1627.  This range is different from the ERN range that

23     was granted pursuant to the DC decision.

24        Q.   Witness, do these statements together accurately reflect your

25     recollection of the events described in it?

Page 12271

 1        A.   Yes, they accurately reflect what I remember.

 2        Q.   And if you were asked questions about those events today, would

 3     you give the same answers that are contained in the statement?

 4        A.   Yes, I would give the same answers.

 5             MS. PRASAD:  Your Honours, we would move for the admission, under

 6     seal, of the two written statements of the witness, dated 18 March 1995

 7     and 13 June 2004, bearing 65 ter number 5035B and 5035A.

 8             JUDGE ANTONETTI: [Interpretation] We're going to give two MFI

 9     numbers, because the trier will have to hand down a decision as to the

10     final tendering into evidence.  Two MFI numbers.

11             THE REGISTRAR:  P658 and P659, both MFI'd, Your Honours.

12             JUDGE ANTONETTI: [Interpretation] Under seal?

13             THE REGISTRAR:  [Previous translation continues]... statement

14     will become Exhibit P658 and the 2004 statement will become Exhibit P659,

15     both marked for identification.

16             JUDGE ANTONETTI: [Interpretation] Indeed.  But remember that it

17     should be under seal, because this is a protected witness.

18             THE REGISTRAR:  [Previous translation continues]... Your Honours.

19             JUDGE ANTONETTI: [Interpretation] Thank you.  I have to keep

20     everything in mind.

21             Madam Prosecutor.

22             MS. PRASAD:  Your Honours, with your permission, I would like to

23     ask the witness two questions in private session.

24             JUDGE ANTONETTI: [Interpretation]  Let's move into private

25     session.

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21                           --- Whereupon the hearing adjourned at 7.03 p.m.,

22                           to be reconvened on Thursday, the 27th day of

23                           November, 2008, at 8.30 a.m.