Tribunal Criminal Tribunal for the Former Yugoslavia

Page 14035

 1                           Thursday, 5 February 2009

 2                           [Open session]

 3                           --- Upon commencing at 2.15 p.m.

 4                           [The accused entered court]

 5             JUDGE ANTONETTI: [Interpretation] Registrar, can you call the

 6     case, please.

 7             THE REGISTRAR:  Good afternoon, Your Honours.  This is case

 8     number IT-03-67-T, the Prosecutor versus Vojislav Seselj.

 9             JUDGE ANTONETTI: [Interpretation] Today is Thursday, the 5th of

10     February, 2009.  I would like to greet all the people present in the

11     courtroom, the representatives of the OTP, Mr. Seselj, as well as all the

12     people assisting us in the courtroom.

13             I would like the registrar to make a correction on one of our

14     exhibits.

15             THE REGISTRAR:  Thank you, Your Honour.  This is a correction to

16     the document that was tendered yesterday and originally numbered P831,

17     under seal.  The correct number should read Exhibit P830, under seal.

18     Thank you.

19             JUDGE ANTONETTI: [Interpretation] Thank you, Registrar.

20             Now a housekeeping matter I'd like to deal with straight away.

21     Mr. Seselj has two hours for his cross-examination.  There might be a

22     re-examination after that.  Let's reckon on two to three hours.  We were

23     supposed to finish at 6.30 so we will have a break at five to 4.00 until

24     20 past 4.00 and then run through until 6.00 so that we gain some time.

25     We will gain 20 minutes.  This is what I wanted to announce.

Page 14036

 1             Mr. Seselj, you will have two hours for your cross-examination.

 2     We will bring the witness into the courtroom.

 3             Let me specify, I won't give the name of the witness due to come

 4     next week.  I asked the witness to be there as of Wednesday onwards.  I

 5     hope that's not a problem.

 6             Mr. Mundis.

 7             MR. MUNDIS:  Should be no problem, Mr. President.  That's the

 8     only witness we have for next week.

 9             JUDGE ANTONETTI: [Interpretation] Very well.  So we will hold our

10     hearing on Wednesday.

11             THE ACCUSED: [Interpretation] I would just like to warn you that

12     the Prosecution has just 7 hours left, 7 hours at its disposal and a few

13     minutes plus.  And I suggest that you put a suggestion to the Prosecution

14     that during those 7 hours, they should bring forward only relevant

15     witnesses which have to do with the indictment, testifying about the

16     indictment, not as witnesses from locations that don't exist in the

17     indictment at all because if after everything, the Trial Chamber is given

18     addition -- the Trial Chamber gives the OTP additional time, that will be

19     a scandal for the public, the broader public, after all this wasted time

20     to add more time to the Prosecution.  And the Prosecution has 7 hours and

21     a few odd minutes left.

22                           [The witness entered court]

23             JUDGE ANTONETTI: [Interpretation] What you have said is on the

24     transcript.  We are in open session.  Mr. Seselj, I'll give you the floor

25     now.  Please make sure that you don't say anything which would lift the

Page 14037

 1     identity of the witness because I will then have to redact parts of the

 2     transcript.

 3             So I trust you will be careful.

 4                           WITNESS:  WITNESS VS-2000 [Resumed]

 5                           [Witness answered through interpreter]

 6                           Cross-examination by Mr. Seselj:

 7        Q.   Mr. VS-1066 [as interpreted], what I'm most interested in,

 8     looking at the whole of your testimony, is the meeting in Mali Zvornik,

 9     and I'm sure you will understand why I'm most interested in that because

10     that is a rally that is incorporated into the indictment.  Everything

11     else that you testified more or less has got nothing to do with the

12     indictment against me but that rally and the one you described to me is

13     directly quoted in the indictment, so I would like it to be clear to you

14     while you -- why I insist on that.

15             You mentioned the rally and you explained to us the attending

16     features.  Now I'm not clear on one point.  You said that the rally was,

17     first of all, scheduled to be held out in the open and that when we saw

18     how many people had rallied there we asked to go inside.  Did you say

19     something like that, something similar?

20        A.   Yes, exactly that.

21        Q.   Now I'd like to remind you that several days before the meeting,

22     quite a few days before, there were posters stuck up all over Mali

23     Zvornik and some posters across the Drina River in Veliki Zvornik; isn't

24     that right?

25        A.   Well, I didn't move around Mali Zvornik much so I didn't see them

Page 14038

 1     all.  There were a few posters right across the bridge, but in Veliki

 2     Zvornik there were many posters, almost on every building.

 3        Q.   As far as I remember, we scheduled the meeting in the large hall

 4     of the cultural centre, and I have two pieces of evidence to prove that

 5     that really was the case.

 6             First, that we scheduled the meeting to be held, the rally to be

 7     held outside where there was a stage set up and loud speakers and

 8     everything else that is done when you hold an outside rally.

 9             Now, you weren't able to see the stage and weren't able to see --

10     to hear any loudspeakers or anything; right?  Is that what you said?

11        A.   Can I answer?

12        Q.   Go ahead.

13        A.   I came a little late, as I said in my testimony yesterday just

14     before the meeting began, the rally began so I saw no stage, no sound

15     systems or anything but the Serbs whom I worked with, as far as I was

16     able to gather from them and their colleagues, actually we learned that

17     the rally would be held outside.  Now, I didn't enter into the details as

18     to whether that was true or not but I wanted to attend the rally and what

19     happened happened.

20             JUDGE HARHOFF:  I apologise for interrupting you.  My

21     recollection is slightly different and I would like you to clarify this

22     with the witness, if possible.  I think I heard the witness indicate

23     yesterday that the reason why the meeting was moved to take place inside

24     was for security reasons because such a large crowd in which there would

25     be a number of persons who would be hostile to the war issue could be

Page 14039

 1     dangerous for you.  So that was why, if I understood the witness

 2     correctly, but I would invite you to clarify this.  That was why it was

 3     decided ultimately to move the meeting inside, that would be safer.

 4             THE ACCUSED: [Interpretation] Mr. Harhoff, we're going to deal

 5     with that rally for at least an hour and I do wish to convince you that

 6     we are going to clarify during that hour all the details concerning that

 7     rally because you know the sentence that is ascribed to me is entered

 8     directly into the indictment, because it's very interesting that we clear

 9     up all the details in that regard.

10        Q.   So let me ask you:  Your information according to which the rally

11     was supposed to be outside, out in the open, was something you heard from

12     the people when you arrived but you didn't say it -- you didn't see it on

13     the poster, did you?

14        A.   No, I didn't see it up on the poster.  I didn't have time.

15        Q.   Since there was no stage and no sound system, and loud speakers,

16     it was logical to suppose that the meeting wasn't scheduled, the rally

17     wasn't scheduled to be held outside.  And let me tell you that the

18     cultural centre is right by the main road which passes through Mali

19     Zvornik, along the Drina River valley.

20        A.   Yes, for 50 metres.

21        Q.   And had we held a rally there, we would have blocked the whole

22     main road, right?

23        A.   No, it's a large space.  You can turn off the road to go to the

24     cultural centre.  There is a large parking lot so several thousand people

25     could have been there, and what I saw was, say, a little over a thousand

Page 14040

 1     people.

 2        Q.   There might have been 2.000, I seem to remember a lot of people

 3     for such a small place.  Of course it's difficult to say exactly how

 4     much.

 5        A.   Well, more than a thousand, certainly.

 6        Q.   The second reason which goes to show -- well, if we had scheduled

 7     a meeting to be held out in the open and then go into a building, that

 8     would be impossible to arrange with the cultural centre because if you

 9     want to go inside, you would have to rent out the space in advance, you

10     have to pay for the hall you're going to use and ensure all the other

11     prerequisites for a rally?

12        A.   Well, I don't know what you thought attended the scheduling of

13     meetings and rallies, but there were always alternatives for security

14     reasons.  There was always another option and that's why you changed your

15     decision and decided to hold it inside in the hall.

16        Q.   So the rules and regulations in Serbia were the same as in

17     Bosnia-Herzegovina which said that every political party had to inform

18     the police that they intended to hold a rally, inform them in advance?

19        A.   I don't know.  I never organised such things.

20        Q.   Well, I can tell you that that was the law.  If you wanted to

21     hold a rally, you had to inform the police thereof at least two days

22     before the rally, say where the rally was going to take place, how long,

23     whether security service was organised and so on and so forth, and had

24     the OTP conducted a serious investigation, they would have provided us

25     with the documents to show us where the rally was scheduled first.  And I

Page 14041

 1     insist that it was scheduled to take place inside.

 2             Now, you gave us some facts.  You said that many people turned up

 3     and that many people who were hostile to us turned up too, more hostile

 4     people than those who supported us.  What would you say?

 5        A.   I never said that there were more people who were hostile towards

 6     you.  It was to be assumed that it might have been a 50:50 ratio.  Why?

 7     Because Veliki Zvornik is mostly Muslim and mali Zvornik is a 50:50 ratio

 8     of percentage of the population, so we could assume that there were those

 9     from both sides; those who were for you, for the rally and the things you

10     propagated and those who were opposed, against.  It was difficult to

11     assess all this to see who was in favour of whom.

12        Q.   Those who were against us were mostly Muslims, but there were

13     Serbs, Communists who opposed us, too, together with the Muslims, right?

14        A.   How would I know that?  How would I know whether someone was a

15     Communist and whether they were opposed or not?

16        Q.   But you do know that there were many Serbs that took the Muslim

17     side against us?

18        A.   Many honourable and decent people were against the war.

19        Q.   We're not talking about who was honourable and decent and who was

20     not.  Those are value arguments and not facts.  Let's stick to the facts

21     for the time being.  I'm not saying whether you're honest or not honest;

22     I'm not interested in that.  All I want is, with your help, to clarify

23     the facts.  Do we understand each other on that score?

24             Now, we arrived there and some people greeted us with ovations

25     and applause, a portion of the people there; whereas the others abused

Page 14042

 1     us, swore at us.  Did you see that they carried Tito's photographs, too?

 2        A.   I entered the hall before you.  I didn't see you when you

 3     arrived.  I just saw you when you were in the room because I learned that

 4     the rally would be held in the hall and not outside, so I couldn't see

 5     those pictures or the applause or the ovations or whatever.

 6        Q.   Well the pictures were brought in before we arrived.

 7        A.   I don't know what the pictures had to do with it.

 8        Q.   Well, I'd like to remind you.  If you remember those photographs,

 9     well and good; if not -- and don't try and speed me up.  I have two

10     hours.  There is no need to speed up the proceedings.

11        A.   Well, I was just trying to help you out.

12        Q.   Well, thank you, then.  Thank you for helping me on that score,

13     but some people who were opposed to us had photographs of Tito, framed

14     photographs that they'd taken off walls and they were protesting.  You

15     didn't see that?

16        A.   No, because I went into the hall before you, as I said.

17        Q.   But you discussed the situation with some of the people after the

18     rally, right?

19        A.   Yes.

20        Q.   And the rally resounded in the public, newspapers went on writing

21     about it for days?

22        A.   Why?

23        Q.   Because of the incident that took place, so you had a chance of

24     talking to people and hearing of their impressions from the rally and

25     they could have told you that when we arrived there, that there were a

Page 14043

 1     lot of policemen.  You saw the policemen too, didn't you?

 2        A.   Yes.

 3        Q.   And that police made a cordon so that we could enter the cultural

 4     centre building safely and securely, me together with my associates,

 5     seven or eight of us.  And do you remember that there was a police line,

 6     a cordon, they cordoned off the area so that we could enter?

 7        A.   You entered with another man and you sat down, you occupied a

 8     chair that was intended for you, and I saw two or three bodyguards who

 9     stayed up by the door but I didn't see anybody else.  I saw you and this

10     other man who sat down at the table that you were meant to use and your

11     bodyguards state behind at the door.

12        Q.   All right.  Now, the rally started and do you remember that, from

13     time to time, you could hear people outside who were in opposition?  Did

14     you hear that?

15        A.   Yes.

16        Q.   How many people did you say were in the hall?

17        A.   Well, it wasn't a large hall.  I would say that there were up to

18     80 people, not more than 80.

19        Q.   You see it's the largest cinema hall that Mali Zvornik has,

20     right?

21        A.   I was never in that cultural centre, but I don't remember.  I

22     would say 80 people and you could see this on the basis of your speech,

23     when you said, I'm sorry that we couldn't hold the meeting outside so

24     that everybody can hear what I have to say and hear you, and you said, I

25     hope that you are worthy representatives of your organisations and that

Page 14044

 1     you will be able to convey to them what I'm going to say here.

 2        Q.   All right.  Fine.  Now you said that you were sitting in the last

 3     row with some other 15 or 20 Muslims?

 4        A.   Right.

 5        Q.   If that last line has 20 seats, that last row has 20 seats, I

 6     don't suppose this cinema hall had just four rows.  As far as I remember,

 7     it had at least 20 rows, although I can't remember exactly; isn't that

 8     right?

 9        A.   Well, I can count them because I remember it all.

10        Q.   Well, how many rows, then?

11        A.   I remember every detail and I would say in my assessment there

12     were not more than 80 people in the hall.

13        Q.   Well, precisely because you are reducing that number, you're

14     telling me a smaller number, that is something I find intimately

15     unacceptable.  I'm trying to show you how many seats the hall had and all

16     the seats were full; right?

17        A.   I don't know whether all the seats were occupied, but that's how

18     many people I thought there were.

19        Q.   Now, we went outside and once again, there was this cordoned

20     offer area by the police in front of the entrance and we were moving

21     towards our cars which were parked a little further away, and stones and

22     other objects were being thrown at us; is that right?  Do you remember

23     that?  Do you remember that that was how it was?

24        A.   In my statement yesterday, I said that in the parking lot, there

25     was a group of people and one of them opened the boot of the car --

Page 14045

 1        Q.   Let's take it one by one.  Let's take it in order.  This car and

 2     the boot of the car came later.

 3        A.   Well, precisely as you were coming out.

 4        Q.   We were coming out of the hall, we were being -- stones were

 5     being thrown from the crowd, there was a lot of people moving around,

 6     some members of the police tried to spit at us.  Was it like that?

 7        A.   I wasn't close to you but I saw that you were knocked down to the

 8     ground and that your bodyguards were on top of you.

 9        Q.   And we were the target of stones.  We came out to this broader

10     plateau and stones began to hit the people who were on top of me; isn't

11     that correct?  Now you claim that I was hit.  I actually was not hit.

12     You also claimed that the next day, you saw me on television with

13     bandages on my head.  This is simply not true.  I was not hit by a single

14     stone but the stone did -- stones did hit people who were around me,

15     Miladin Todosijevic was one of them who was hit by a stone.  There was

16     Vineta Marinovic, journalist from Velika Serbia, she was hit by a stone

17     in the chest, and some other people also were hit by stones.  Then the

18     people from our municipal committee from Mali Zvornik took out these

19     wooden bats from the trunk of the car, perhaps a metre long or something.

20        A.   A little bit shorter than that.

21        Q.   And you could see that these were freshly cut pieces of wood, and

22     then people started to run away, some people were running towards the

23     bridge and others were running along the road next to the cafe that was

24     opposite from the culture hall.  I recall this large number of people who

25     were running in that direction.  Did you se that?

Page 14046

 1        A.   I wasn't paying attention.  I wasn't able to see where people

 2     were running.  I was trying to save myself so that I don't get pulled

 3     into this whole game so that I pulled back, I hid myself.

 4        Q.   All right.  So then there was a big fight that occurred, a lot of

 5     people were hurt, and then after that, I with my associates left for

 6     Banja Koviljaca, we had dinner there and we spent the night at the Banja

 7     Koviljaca hotel.  I wasn't hurt and you could not have seen my head in

 8     bandages.  Not then, no.

 9        A.   I don't recall saying yesterday that I saw you on television but

10     I saw you in the media, in the newspapers, your photograph with a

11     band-aid on the left, or I don't know what side of your face, and your

12     hand was bandaged also so this could have been something that happened

13     overnight.  Were you hurt in Banja Koviljaca?

14        Q.   No, it didn't happen there.

15        A.   So how come had you a band aid there?

16        Q.   I never had a band aid on my head.  I don't know where you saw

17     that.

18        A.   Well let's look at that perhaps in the newspapers.  After 17

19     years it won't be so hard to find that.

20        Q.   A lot of newspapers wrote about that and there was a wide, broad

21     debate about that.  Do you know that the Serbian Radical Party has its

22     own newspaper, the newspaper called Velika Serbia?

23        A.   I wasn't able to read that paper.

24        Q.   Does it still have that newspaper?

25        A.   Yes, probably.

Page 14047

 1        Q.   Well, regardless of the fact that those newspapers made you sick,

 2     we will have to read a little bit from that newspaper.

 3             THE ACCUSED: [Interpretation] Can we put on the ELMO, please,

 4     this article from Velika Serbia which talks about the promotion of our

 5     party in Mali Zvornik.  I asked the registrar to provide copies, the

 6     Prosecution has a copy.  Do you have the whole newspaper?  All right.  We

 7     will look at the newspaper later.

 8             Now what we are going to look at is just this particular article.

 9     Have you put it on ELMO, please?

10        Q.   Now, can you look at the title of this article.  Do you see what

11     it says here?  Serbian Chetnik Movement promoted the party in Mali

12     Zvornik.  So we promoted the Serbian Chetnik Movement, this is what we

13     called it.  It could have been the Serbian Radical Party promotion but

14     this was a Chetnik promotion, wasn't it?  Can you see that?

15        A.   Yes, I can.

16        Q.   You can see from the contents in the culture hall, you can see

17     the Chetnik flags, pictures of Draza Mihajlovic, and so on and so forth;

18     is that correct?

19        A.   Yes, that is correct.

20        Q.   We had all of that.

21             THE ACCUSED: [Interpretation] Please can you be a little bit

22     patient.  This is such an interesting discussion.  Please have a little

23     bit of patience.

24             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen.

25             MR. MARCUSSEN:  It's indeed a very interesting discussion.  I'm

Page 14048

 1     wondering if the accused would let us know whether he is conceding that

 2     the article is about the rally that took place in Mali Zvornik in

 3     March of 1992 or whether he's putting something else before the witness?

 4             THE ACCUSED: [Interpretation] Mr. Marcussen, I'm not going to be

 5     explaining to you in advance what my goal is.  Please have some patience.

 6     You are directly interfering in the concept of my cross-examination.

 7     Please don't do that.

 8        Q.   Please turn to the next page.

 9             MR. MARCUSSEN:  Your Honours, if the witness is being led to

10     believe that this article is about the rally that he has described in his

11     testimony, that's the way it's being presented to the witness, I think

12     it's significant that we are aware of what the accused's position is on

13     that because otherwise he is setting the witness up.  So we need to know

14     what the date of this article is.

15             THE ACCUSED: [Interpretation] It is that rally.  There is no

16     other rally where a fight broke out, only -- a fight broke out at only

17     one meeting.

18             THE WITNESS: [Interpretation] Well, in the first line of this

19     article it says, "On the 4th of August this year, a delegation of the

20     Serbian Chetnik Movement came to Mali Zvornik."  Why is the 4th of August

21     being mentioned here if this was in March?  What is this?

22             MR. SESELJ: [Interpretation]

23        Q.   Well, it could be a typo.  Now let us look at those photographs.

24     Do you see here two people in the hall holding up a photograph of

25     Draza Mihajlovic?

Page 14049

 1        A.   Yes.

 2        Q.   Do you see the first row, the front row of the hall?

 3        A.   Well, it's a little bit blurred.

 4        Q.   So you cannot see Branko Grujic in the first row, and do you see

 5     this photograph where you can the crowd outside and the police, there is

 6     a policeman prominent in the front of picture?

 7        A.   No, I don't really see that very well.

 8        Q.   Well, you can see the police cap in the photograph, it's towards

 9     the bottom of the photograph.  The introductory part of the article talks

10     about our arrival and I'm giving an interview there for the Radio

11     Podrinje and Radio Sabac.  And then you can turn to the following page.

12     On the following page, we can see how the stage is decorated, where we

13     were sitting, the podium and you can see the president of our Mali

14     Zvornik municipal board who opened this rally and you can see Vojin

15     Vuletic who at the time was our general secretary; is that correct?

16        A.   I don't know these people.

17        Q.   Well, you don't know these people.  Anyway, turn to the next

18     page.  On the next page, you can see Vojin Vuletic and then below that

19     you can see the working Presidency where I am sitting.  The first to the

20     left is lawyer Milorad Vukosavljevic.  At the time he was our

21     vice-president; he died a few years after that.  And then we see our

22     officials from Mali Zvornik.  In the middle there is myself, then next to

23     me Aleksander Stefanovic, the general secretary; and lawyer Olivera

24     Jelkic.  I can recognise them all.  This is a central photograph.  In a

25     small photograph you can see Oliver Jelkic entering the hall and then

Page 14050

 1     below you can see lawyer Milorad Vukosavljevic entering.

 2             All right.  And then on this page, we can see that it says that

 3     the article is written by Vineta Marinovic, who was actually hit by a

 4     stone at that rally.  This is the central part of it.  Maybe we can zoom

 5     it up a little bit.

 6             Then members of the central Serbian Chetnik Movement entered the

 7     hall and then our president of the executive hall welcomed the speakers,

 8     Glamocanin was there, who was the member of the inner leadership, and

 9     then the first speaker was Aleksandar Stefanovic.  Please turn to the

10     next page.

11             You can see a part of the hall here and then a part of the

12     working Presidency.  You can see myself and then Aleksandar Stefanovic.

13     You can see this text on the side where he talks about Draza Mihajlovic.

14     Do you remember that the first speaker was Aleksandar Stefanovic and that

15     he talked about Draza Mihajlovic?

16        A.   I don't know that man.  Please don't ask me about the names, I

17     don't know any of these people by name.  I was talking about your speech,

18     about your address, what you said.

19        Q.   All right.  Let's skip his speech because he talks about the life

20     of Draza Mihajlovic as whole here?

21             JUDGE ANTONETTI: [Interpretation] A few seconds, if this meeting

22     was held on August 4th, we can understand that because we see that

23     Mr. Seselj is in a shirt, short-sleeved shirt, it was probably hot, so it

24     might be on August 4th.  But if I understood right, in this room we saw

25     photographs and you should be at the very end of the room, at the -- in

Page 14051

 1     the far -- at the very far end of the room so we should see you,

 2     normally.

 3             THE ACCUSED: [Interpretation] You don't see the whole of the

 4     hall, Mr. President.

 5             JUDGE ANTONETTI: [Interpretation] Just a minute.  Here we see the

 6     far end of the room.  There's probably less than 80 people but we see

 7     people sitting in all those rows; and if you are there, you should be in

 8     the bottom row, in the last row; right?

 9             THE WITNESS: [Interpretation] I'm sorry.  Is the question

10     addressed to me?

11             JUDGE ANTONETTI: [Interpretation] Yes.  If you actually attended

12     this meeting on August 4th, you would be at the far end of this room.

13             THE WITNESS: [Interpretation] The last row where I was sitting, I

14     was sitting there with people whom I mentioned, Muslims, in the last row

15     next to the wall, and you cannot clearly see my face.  You cannot see my

16     face in the back row.  The photograph -- I mean, was taken, if it was

17     taken from this rally, but since this is a text that was written and

18     talks about a rally of the 4th of August, and Seselj is standing at the

19     podium in short sleeves, but in March in Bosnia, it's quite cold.  You

20     cannot walk around in T-shirts.

21             JUDGE ANTONETTI: [Interpretation] Absolutely.

22             THE WITNESS: [Interpretation] I apologise, these people who were

23     sitting here, they're wearing T-shirts, short-sleeved T-shirts.  This

24     doesn't -- this could not be a photograph from the time that we are

25     discussing.  I am definitely sure about that.

Page 14052

 1             JUDGE ANTONETTI: [Interpretation] Very well.  Continue.  Yes,

 2     proceed, Mr. Seselj.  We'll see as we proceed.

 3             MR. SESELJ: [Interpretation]

 4        Q.   All right.  Let's go to the following page, please.  Now, well,

 5     here you can see the front row here.  On the following page, Aleksandar

 6     Stefanovic finished his speech and now Srdjan Glamocanin is speaking and

 7     he is a member of the government.  And in the photograph, in the middle,

 8     you can see the front row.  In the front row we can see the journalist of

 9     Velika Serbia, Vineta Marinovic, and we can see some other people and you

10     cannot see Branko Kljuic anywhere.  Srdjan Glamocanin again is speaking

11     about Serbdom, about the Serbian history, the traditions of its heros,

12     and then you can see a photograph of the crowd in front of the hall, this

13     is the bottom photograph.  Can you please scroll up?  You can see this

14     crowd in front and now please turn to the following page.

15             You can see the police cordon in front and they are trying to

16     secure a safe passage for us, these are the first two photographs, and

17     then the third photograph was taken at some point during the meeting.  In

18     front of the hall you can see police and some citizens.  Please turn to

19     the following page.  On the following page you can see lawyer Milorad

20     Vukosavljevic who is the vice president of the central homeland

21     administration.  He gave quite a long speech.  Can you please turn to the

22     next page.  You've skipped a page.  Look at page 30, please.  This is

23     page 30.

24             There is no photograph on this page.  And then here it would be

25     interesting to read what he says about Muslims.  So could you please read

Page 14053

 1     what I have marked here?

 2             THE INTERPRETER:  The interpreter's note:  We need to know

 3     exactly where the accused is reading from in the English version.

 4             MR. SESELJ: [Interpretation] Perhaps your copy is not marked.  I

 5     marked it on my copy.

 6        Q.   On that page, you can see at the bottom, Tito Ustasha, get the

 7     House of Flowers out.  And then it says, Natasha Vukosavljevic.  I am

 8     having a problem with these blurred letters.

 9        A.   Underneath this text, Tito Ustasha, House of Flowers, I don't

10     know why you are asking me.  The second reason that may be particularly

11     happy when I was called to -- when I was invited to speak to you --

12        Q.   All right.  Well, perhaps it will be easier for me to read.  Let

13     me do it.  That you people are the living proof of the brazen life that

14     the Yugoslav army committed genocide against Muslims in the fatherland.

15     I think that in your midst, more than half of Muslims might be of Serbian

16     origin.  Some remember the stories of their ancestors, that once they

17     were part of the Serbian people.  Draza Mihajlovic was the Defence

18     Minister of the emigre government or the government in exile in London.

19     You know that, you're quite an educated man.

20        A.   Well, yes, but I don't know why you are interested in that.

21        Q.   Well, you don't need to know that.  You're here to testify about

22     facts.  Who cares why I want to know.  Perhaps I went mad during the

23     night.  And a lot of people think that I am mad anyway and you agree with

24     them, don't you?

25        A.   Well, yes, a lot of people do think that.

Page 14054

 1        Q.   Well let's continue in a more jovial atmosphere.  Some -- I will

 2     continue.  Some remember the stories of their ancestors, that once they

 3     were part of the Serbian people.  Some do not remember this while other

 4     even think they are Turks.  However, at the moment, we do not need to

 5     focus on this at this time.  It is very difficult to define the ethnic

 6     origin of your fellow citizens.  These are Serbs who lost their awareness

 7     and memory.  It was easy to mercilessly push them, especially the

 8     so-called "fukara," scum, into a fratricidal war in 1941 as surrogates,

 9     where they slaughtered their innocent neighbours and yesterday's friends

10     when they were offered Serbian property.

11             Therefore, your duty here above all --

12             JUDGE LATTANZI: [Interpretation] Mr. Seselj.  Mr. Seselj, I'm

13     totally confused now regarding your cross-examination.  Before starting

14     to read this document, could you please stop and try and determine

15     whether this is the rally which the witness testified or whether it's

16     another rally.  Just a minute.  Hold on.  Otherwise we're wasting time.

17     Normally, when the Prosecution is presenting documents, you always want

18     him to tell you exactly what the context is, what the date is for this

19     document, and so forth and so on, and we always say you're right and

20     grant you this opportunity.  So you should do the same thing for the

21     other side.

22             JUDGE ANTONETTI: [Interpretation] For everyone, I will read this

23     quickly.

24             In the Prosecution's pre-trial brief on Zvornik, this is what the

25     Prosecution says:  In March 1992, the Serbian Bosnian forces had created

Page 14055

 1     their own police in Zvornik and had declared that this city was a Serbian

 2     municipality and was about to -- was about to attack to -- supported by

 3     the JNA.  In the same month, in March, Vojislav Seselj gave a speech in

 4     Mali Zvornik, a municipality in front of Zvornik, on the other side of

 5     the Drina, and he said on that occasion, and I quote what he allegedly

 6     would have said:

 7             "My Chetnik brothers, and I am mainly to talking to those of you

 8     who are on the other side of the Drina, you, the bravest of the bravest,

 9     we are about to cleanse Bosnia of the unfaithful and to show them the way

10     that will take them back to the east, the east where they belong."

11             Mr. Seselj's words which are quoted or footnoted, footnote 291

12     and on footnote 291, it says, "VS-2000."  Therefore, these words, these

13     underlying words are quoted from what the witness heard and what he heard

14     in March.

15             Mr. Marcussen.

16             MR. MARCUSSEN:  If I may further address this issue,

17     Your Honours.  The accused is, in my respectful submission, misleading

18     the witness.  I have here the full copy of Velika Serbia in which this

19     article is drawn from and it is an issue of Velika Serbia that is dated

20     the 15th of August, 1990.  And this was why I asked the accused earlier

21     on whether he agreed that this meeting was actually about the same

22     meeting that the witness has testified about.  The article has nothing to

23     do with the meeting that the witness has testified about, and these

24     attempts of showing photographs and getting the witness confused about

25     the presence of various people is completely appropriate.  And the

Page 14056

 1     accused is laughing now, he's fully aware of what's going on.  If Your

 2     Honours would like to see the copy, I can hand it up to you.

 3             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, the indictment, in

 4     the indictment, the speech was made in March.

 5             THE ACCUSED: [Interpretation] Mr. President, how does the

 6     Prosecution know what it talks about?  I assume I've shown you and proved

 7     that all the Prosecution witnesses were false witnesses.  You didn't have

 8     a single one brought in here by the Prosecution who was not a false

 9     witness and tried to support the thesis in the indictment, not a single

10     one.  This is a rally that took place at the beginning of August -- go

11     on, just you interrupt me.  Interrupt me, go ahead.

12             JUDGE LATTANZI: [Interpretation] Mr. Seselj, this has nothing to

13     do with the question you were being asked.  We want to you determine what

14     this refers to and then we'll see, but right now you cannot start

15     lecturing or making speeches on all the witnesses we've heard up until

16     now.  You are just making fun of the Trial Chamber right now.

17             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, the document we

18     have here is dated August 15, 1990.  So this might be a document that is

19     edited with prior articles, maybe, maybe, so what we have seen, maybe

20     that's August 4th, 1992, I don't know, but please try and figure out what

21     actually happened.

22             THE ACCUSED: [Interpretation] It seems that I have turned out to

23     be the silliest here.  Mr. President, isn't it obvious the witness takes

24     the meeting from August 1990 and testifies about it, representing it to

25     be a meeting from March 1992.  That's what he's doing.  Am I an idiot or

Page 14057

 1     is it the Prosecution?  One of the sides must be.  He's describing a

 2     rally that took place in 1990, and I'm going to prove that to you now by

 3     looking at the last page of that article, and may we look at page 36 now,

 4     please.

 5             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, we're not accusing

 6     anyone, we're not accusing you, we're not accusing the witness.  But we

 7     have a problem.  The witness told the Prosecutor that this meeting, rally

 8     had been held in March 1992, and you are saying that this was in

 9     August 1992.

10             THE ACCUSED: [Interpretation] Mr. President, well, the witness

11     could have told the Prosecution that I personally killed a million

12     people.  What do I care what the witness told the Prosecution.  I am

13     going to overthrow his testimony here and every time you interrupt me in

14     cross-examination, you want to undermine my cross-examination.  The more

15     perfect it is, the more you want to undermine it and you want to prevent

16     me from saying that these are false witnesses.  From all the indices, all

17     the indicators show -- well, why don't you listen to me?

18             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, don't say that

19     we're trying to undermine your cross-examination.  We're doing everything

20     to try to shed light on this.  I took time to read the pre-trial brief in

21     order to know what the Prosecution's case was.  And the Prosecution's

22     case here is based on what this witness said.  And now, I'm all ears to

23     listen to your cross-examination and your demonstration and your case, so

24     please put your case.

25             THE ACCUSED: [Interpretation] This is the only witness through

Page 14058

 1     which the Prosecution wishes to base its thesis that in March 1992, I

 2     held a rally in Mali Zvornik and said what is quoted in the indictment,

 3     "Dear brother Serbs, we should expel those who do not believe in God and

 4     so on."  There's not another one.

 5             And I want to show you that the meeting in Mali Zvornik did not

 6     take place in March 1992 but in August 1990 and that this witness is

 7     describing that meeting and then adding false words to what he's saying.

 8             Listen, we have the coordinates for this meeting.  There was a

 9     brawl, a physical settling of accounts.  The police intervened, members

10     of my party took out poles from their cars to chase away the rabble that

11     attacked us, so we have all the right coordinates.  The whole of Serbia,

12     the whole of Bosnia-Herzegovina knows full well that the only rally at

13     which this mass brawl broke out was in Mali Zvornik in 1990.

14             In March 1992, look at all the Serbian press, there was no

15     meeting in Mali Zvornik.  What do I care what the Prosecution is writing,

16     as if that were the only silly things they wrote.  We're talking about a

17     1990 rally and here is proof.  The last page of the article, and we're

18     going to read it all, at least the whole of my speech or I'm not going to

19     carry on my cross-examination.

20             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, one small detail

21     that you provided us with that might be interesting.  This rally would

22     allegedly have been held in August 1990.

23             THE ACCUSED: [Interpretation] Yes.

24             JUDGE ANTONETTI: [Interpretation] Very well.

25             THE ACCUSED: [Interpretation] And here's proof.  The last page of

Page 14059

 1     the article, page 36.  Can we have that page, please.

 2             The rally ends.  Can we scroll down, please.  Scroll up.  The

 3     upper part.  Above the photograph.  And zoom in on that, please.  This is

 4     what Vineta Marinovic, the journalist, writes in Velika Serbia in a 3rd

 5     issue in August 1990.  This is what she writes:

 6             "Everybody gets up and leaves the room quietly and calmly.  We

 7     have no idea what is waiting for us outside.  In the meantime, the police

 8     has arrived and formed a human shield with the aim of allegedly

 9     protecting us from the mass of Muslim fundamentalists gone mad who were

10     shouting outside.  We soon realised that it would be much better if the

11     police hadn't come at all, and this alleged protection of theirs

12     jeopardised us even further.

13             "The militant fundamentalists fought in their typical way.

14     Literally protected by the police, they threw big stones at us, they spat

15     at us and they yelled at the top of their voices.  They were swearing at

16     us and using words like infidels and welakins [phoen], welakin mothers,"

17     and that is the term they use for the Orthodox.  I'm reading it rather

18     quickly because you have the English translation.

19             "They looked like savage beasts -- ravaged beasts.  However, we

20     did not run away from them and we did not respond to their barking.  We

21     did not want to give them that pleasure.  We did not wish to leave our

22     brothers, the Orthodox Serbs from Mali Zvornik.  We did not want to run

23     away from our Serbian land.  We all stood together with the Vojvoda at

24     the head.  We stood there unprotected, calmly talking the insults, stones

25     and humiliations as only the Orthodox Serbs know how.

Page 14060

 1             "Encouraged by the help and protection of the police, the

 2     gathered Muslims became even more furious and began throwing stones at

 3     the nearby parked cars of the Serbs who were parked there.  Almost all

 4     the windows of the cars were broken, and Miladin Todosijevic, a member of

 5     the central fatherland department, was hit in the head by a stone which

 6     made a huge cut on his forehead and blood gushed forth.

 7             When the men from the Serbian Chetnik Movement of Mali Zvornik

 8     saw this, they grabbed some wooden poles and in self-defence, charged at

 9     the crowd which, small wonder -- little wonder, started fleeing as fast

10     as their legs could carry them.  They showed once again that they were

11     capable of fighting only with a dagger, hammer or small knife in their

12     hand, with tied or captured Serbs, women, children, the elderly.  It was

13     pathetic to see them fleeing, but that is in their blood and that will,

14     as it seems, never change.

15              "When everything calmed down, we all got into the cars and the

16     column headed towards Banja Koviljaca where the hosts prepared a small

17     feast for us, and during that feast, Vojvoda Seselj found time to talk to

18     each and every one of those brave young Serbs, to listen to their

19     problems, their difficulties, and troubles, the kind that they

20     encountered daily and to advise them.  Relief was visible on their faces,

21     on their troubled faces, and a mild-note of gratitude was fell in their

22     words.  In spite of everything, they will now be able to sleep more

23     calmly in the knowledge that they are not alone.  The Serbian people and

24     the Serbian Chetniks are with them."

25             That was something that Vineta Marinovic wrote to describe the

Page 14061

 1     rally that the witness was talking about.  It's the same rally, and she

 2     was bitten because she was hit by a stone too and had to seek medical

 3     assistance.  And that is the bitter tone of the text out of that

 4     incident; but that is the sole rally, the only rally where this incident

 5     happened, no other rally -- there was no other rally like that.  And this

 6     was published by the papers, the Muslim papers, and Radio Zvornik had

 7     broadcast the whole of the following day about that.  And in March 1992,

 8     there was nothing in any of the papers, no trace of us having held a

 9     rally in Mali Zvornik at all.

10             Why didn't the Prosecution investigate this?  Because there's no

11     intelligent man in the Prosecution to find this out on time and prevent

12     them from making such stupid mistakes.  That's not my fault.  I'm here to

13     demolish the indictment, and I have succeeded in demolishing it.  So far

14     there is not a single witness so far who had a successful piece of

15     testimony that the Prosecution can use, and the fact that you hold closed

16     sessions, that is just a sort of -- make people think that something was

17     happening here.  The public has to know that at the closed sessions, the

18     false witnesses fair far worse than they do in open session, and my

19     cross-examinations are even more successful during those sessions.  That

20     is something that they should know about.  And this is proof and evidence

21     that this was a rally held in August 1990.

22             I wanted to do that in a calmer atmosphere, but you didn't let me

23     do that.  There was no other rally where an incident like this broke out.

24     That was the only one.

25             JUDGE ANTONETTI: [Interpretation] Witness, according to this

Page 14062

 1     newspaper, and the photographs that we see where there was incidents

 2     which corresponds to what you said, but here the date is August 1990.

 3     Why is it that you said that the rally was held in March 1992.  Maybe you

 4     mixed things up?

 5             THE WITNESS: [Interpretation] I did not confuse or mix up

 6     anything, absolutely nothing.  And after all this I can provide at least

 7     10 people, the names of 10 people that you can call, talk to them and

 8     hear their statements.  The rally was held exactly in mid-March 1992,

 9     possibly there was another meeting in August, as it says in the papers,

10     because I did notice the date.  It says the 4th of August, 1992,

11     possibly, but at that time, there was war in Zvornik municipality and

12     there was shooting from Serbia into Bosnia.

13             JUDGE ANTONETTI: [Interpretation] Very well.  I'm starting from

14     the assumption that you're telling the truth and that in March 1992,

15     there was a rally that was held; and in March 1992, stones were thrown,

16     Mr. Seselj was hit and injured, et cetera, et cetera.  But if that's the

17     case, and if that is true, then it would just be a rerun of what actually

18     had already happened in August 1992 because in August 1992, we had

19     exactly the same problem.  And the media who was very closely following

20     Mr. Seselj would have written and -- so if what you are saying is true,

21     if in March 1992, a rally was actually held, the media that was closely

22     following Mr. Seselj should have written about this saying, Just like

23     this August 1990, once again the members of the Serbian Radical Party

24     were aggressed and so forth and so on, and we have nothing.  So I'm

25     really wondering whether you haven't mixed up the dates?  I mean it's

Page 14063

 1     easy to understand, you know, with everything that happened and all the

 2     years that have gone by you might have mixed up the dates.  Are you

 3     absolutely 100 percent sure of the date?

 4             THE WITNESS: [Interpretation] May I be allowed to observe

 5     something, to note something?

 6             On the 4th of August, 1992, there were no Muslims in Zvornik

 7     anymore.

 8             MR. SESELJ: [Interpretation]

 9        Q.   But who's talking about August 1992?  We're talking about August

10     1990.  The 4th of August, 1990, two years before the war?

11             THE WITNESS: [Interpretation] There were then, but if we are

12     talking about August 1992, then there weren't any.

13        Q.   Well nobody's mentioning August 1992.  This is the 4th of August,

14     1990, that we're talking about, two years before the war.  That's the

15     rally we were referring to.

16             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen.

17             MR. MARCUSSEN:  Your Honours, I'm on my feet because the accused

18     has essentially been testifying -- making submissions and so on, and he

19     has asserted with some -- that -- excuse me --

20             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, please don't

21     indulge in procedure because here we are on a very important issue.  We

22     need to know whether Mr. Seselj said this in March, which is what the

23     witness is saying or whether the speech was delivered in August 1990.

24     This is crucial.

25             MR. MARCUSSEN:  Your Honours, and I'm on my feet because when the

Page 14064

 1     accused testified in the Milosevic case, he was asked about this meeting

 2     on the 5th of September, 2005.  And Mr. Milosevic asked him whether there

 3     had been a meeting in Mali Zvornik in March where he had made this

 4     particular statement, and he confirmed this, and he corrected the

 5     interpreter.  And I have copies of the transcript here if you like, or it

 6     is at page 43.724 and the two following pages.  So he has testified under

 7     oath about this in another case.

 8             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, Mr. Milosevic asked

 9     you this question, and you said that the meeting had been held in March.

10             THE ACCUSED: [Interpretation] Mr. President, let me see the

11     transcript.

12             JUDGE LATTANZI: [Interpretation] Witness, I have a question for

13     you.

14             JUDGE ANTONETTI: [Interpretation] In the transcript I have in my

15     hands, the question is as follows:

16              "Is it true that in March, I believe that in your indictment it

17     says March 1992, you delivered a speech in Mali Zvornik?  Is this true?

18     Did this happen?"  Et cetera.  Et cetera.  And there, "Dear Chetnik

19     brother, notably you who are across," blah, blah, and so forth and so on.

20     It is your answer.  This is partial forgery.

21             THE ACCUSED: [Interpretation] President, in my answer -- well, I

22     don't know English at all, but I can that in my answer, I deal with the

23     contents and not the date.  I completely leave the date aside.  I am

24     proving to Mr. Milosevic that it was impossible for me to say something

25     about pagans and so on - I'm calling the Muslims - I'm not an uneducated

Page 14065

 1     man, I'm explaining that the greatest Serbian bishop of the 20th century,

 2     Nikolaj Velimirovic represented Islam as the first radical variant of

 3     Protestantism in Christianity, and I go on to explain that.  I don't deal

 4     with dates here.

 5             Milosevic is reading what it says in his indictment, I assume,

 6     and I can completely leave aside the date.  I don't refer to that at all.

 7     I'm just showing that it was impossible for me to say something like that

 8     with my -- the education I have, but I don't confirm the date anywhere

 9     and you can see that the Prosecution is telling lies here in front of the

10     public.

11             JUDGE ANTONETTI: [Interpretation] Let me refer to what you've

12     said, Mr. Seselj, during the Milosevic trial did not say that he agreed

13     with the months of March because when the question was put to him, he

14     doesn't answer as regards the months of March, he says that this is a

15     distortion of what he has said; and then he moves on to other topics.  He

16     doesn't admit this.  He doesn't admit that it was in March.

17           So you may have made a mistake, Mr. Marcussen.

18             MR. MARCUSSEN:  We submit, in light of the significance of this

19     particular issue which is the subject of the indictment of the accused,

20     it is quite significant that all he corrects is -- he just addresses,

21     Well I didn't say pagan, there's a mistake in the translation, the error

22     is actually I said something that means waste or feces when he talks

23     about the Muslims.  That is a correction that he made.  He has no other

24     problem with the proposition that is being put to him.

25             I'm not putting it forward for any other purpose but in our

Page 14066

 1     submission is the only thing he has to correct is this rather

 2     [Overlapping speakers] ...of the translation.

 3             THE ACCUSED: [Interpretation] Mr. President, Mr. President, when

 4     I testified in the Milosevic case, I was responding to Mr. Milosevic's

 5     questions.  I did not have any papers or documents in front of me in

 6     order to be able to corroborate everything.  What was the most important

 7     thing to me at that time, to deny that it is absolutely impossible to

 8     give such a definition of Muslims as pagans and Godless people from my

 9     mouth and from my head.  I was not concerned with the date.  I did not

10     link the dates with anything at that time.

11             JUDGE HARHOFF:  Mr. Seselj and Mr. Marcussen to find out whether

12     or not there was a rally on the 7th of March, 1992, I think should be a

13     simple thing, and I would invite the Prosecution to provide further proof

14     of this because it is in the indictment and in the pre-trial brief; and

15     so when you have that proof, and if you can find it, you can bring it

16     back and from thereon, I think we should just move on now.

17             THE ACCUSED: [Interpretation] Let them find --

18             JUDGE LATTANZI: [Interpretation] I have a question for the

19     witness, as I said a while ago.

20             Usher, could you please place on the ELMO the third page of this

21     newspaper article.

22             93, 93.  Yes, Witness, we have here at the bottom far right,

23     could you scroll the page up a little bit.  Yes.

24             What we have here are people who are sitting on the podium.  Did

25     these people attend the rally which you have referred to, i.e., the

Page 14067

 1     4th of March, 1992?

 2             THE WITNESS: [Interpretation] I don't see the faces very well

 3     here, and I didn't really try that much to notice who the people were,

 4     what they looked like.  I didn't know them.  I came out of curiosity, as

 5     I said yesterday, to see who this Seselj was.

 6             JUDGE LATTANZI: [Interpretation] I'm not asking you to recognise

 7     these people, to give us their identity, just could you tell us whether

 8     these four people sitting next to Mr. Seselj, whether, among these four

 9     people, there was a woman.  You might be able to remember that.  I don't

10     know.  Do you remember that?

11             THE WITNESS: [Interpretation] At the table where he was sitting

12     at that meeting, no women were sitting at the table.  There were no women

13     sitting at the same table as Seselj at that meeting.  There was a man

14     with a beard like this man in the dark jacket in the photograph, I

15     remember that, but I definitely remembered that there were no women

16     sitting next to him at that meeting when I was there.

17             THE ACCUSED: [Interpretation] Gentlemen, Judges, it would be the

18     best thing if the Prosecution searched all the Serbian and Bosnian press

19     from March 1990 to see if there were any rallies of the Serbian Radical

20     Party in Mali Zvornik.  No such rally can go without being recorded by

21     the press.  If this incident did take place in March 1992, then it must

22     have been written about and commented upon.

23             The witness himself said that there were many comments in the

24     press after that, but this was exclusively in August 1990 and nowhere

25     else, and after that, they refused at the Ministry of Justice in Serbia

Page 14068

 1     to register our party.  We thought that we had met all the requirements

 2     and that we would be able to register the party, but this did not happen;

 3     and we even suspected that perhaps these people were brought in by the

 4     regime to create some kind of disorder as a pretext based on which they

 5     would not register our party.  There were no incident like this one that

 6     happened in Mali Zvornik at any other of the Serbian Radical Party,

 7     nothing like this ever happened before.

 8             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen, as my colleague

 9     Judge Harhoff has said, and I agree with him on this, if the Prosecution

10     feels or holds that the rally was held on the 4th of March, 1992, you

11     have to adduce evidence in support of this.  For the time being, we don't

12     have this evidence.  There can be a lot of evidence.  There can be press

13     articles as Mr. Seselj has said.  There can be police reports because

14     when there is an incident, there is automatically a police report.

15             So you could lay your hands on that.  Otherwise, we have one

16     rally which was held in March 1990 in -- in August, I apologise, in

17     August 1990, and there were incidents during that rally.

18             MR. MARCUSSEN:  Your Honours, we will, of course, look further

19     into this.  There is evidence on record obviously from this particular

20     witness, and I believe we have some other -- an intelligence report and

21     some other evidence that supports this, but we'll probably get back to

22     this later.

23             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, please proceed.

24             THE ACCUSED: [Interpretation] Mr. President, Mr. Marcussen again

25     is making things up, and this is not fitting for a Prosecutor of an

Page 14069

 1     international Tribunal.  Look at the file that we were given by the

 2     Prosecutor.  And the Prosecutor, to my surprise, did not use this in his

 3     examination in chief.  This is Exhibit 1021.  The Prosecutor has a police

 4     document of the 20th of April, 1992.  I hope you found that.

 5             In the first paragraph, they talk about important events because

 6     the whole thing refers to a longer period of time and then the first

 7     paragraph -- sub-paragraph, the last sentence, says:

 8              "In Mali Zvornik on the 17th of March, 1992, was visited by the

 9     people's deputy Vojislav Seselj, who after a short talk went to

10     Ljubovja."

11             I wasn't just anybody then.  I was a people's deputy.  You don't

12     believe then at that time, some kind of unruly crowd could lynch a

13     people's deputy.  The police says, who monitored my movements, he passed

14     through Mali Zvornik.  I briefly had a meeting with somebody there and

15     then I went on to Ljubovja, and then after that to Bajina Basta, where I

16     had a scheduled appearance on a radio programme.

17             Here in this report, definitely it would be noted that there was

18     some kind of incident.  Had there been an incident where I was at the

19     meeting, this definitely would have appeared in this report.  The

20     Prosecution would have received from the Serbian police all the documents

21     where my name is mentioned.

22             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, what is the number

23     of that document, did you say 1021.

24             THE ACCUSED: [Interpretation] 1021, I think.  That is another

25     piece of evidence that there was no rally or meeting in Mali Zvornik.

Page 14070

 1             Well this is not good.  How can this be good for the Prosecution?

 2             JUDGE ANTONETTI: [Interpretation] I have document 1021.

 3             Mr. Marcussen, in this document 1021, we see that this is a

 4     report stemming from the Ministry of Defence regarding --

 5             THE ACCUSED: [Interpretation] Interior, it's the police ministry.

 6             JUDGE ANTONETTI: [Interpretation] On my first page, it says

 7     Ministry of Defence.

 8             THE ACCUSED: [Interpretation] Of the Defence, I apologise, it's

 9     my mistake, Ministry of Defence.

10             JUDGE ANTONETTI: [Interpretation] Right.  Ministry of Defence.

11             Mr. Marcussen, at the time Mr. Seselj was an MP.  When an MP

12     travels, the intelligence services reports on this.  If he came on the

13     4th of March to Mali Zvornik, there must have been a police report.  It

14     couldn't have been otherwise.  Otherwise, the witness may be confused.

15     Perhaps he thinks many years later that it happened in March, whereas it

16     happened in August.

17             Witness, when you said that this had happened in March 1992, in

18     what year did you say that?

19             THE WITNESS: [Interpretation] 1996, on the 26th and the 27th of

20     August.

21             JUDGE ANTONETTI: [Interpretation] 1996.  On a personal note, I

22     have attended a number of meetings at this Tribunal, and if you asked me

23     which meeting I attended four years ago, I would be unable to tell you

24     unless something extraordinary happened; for instance, if the President

25     of the Tribunal has a heart attack, otherwise I would find it very

Page 14071

 1     difficult to remember that.

 2             So it was in 1996 that you said that you mentioned what had

 3     happened on -- in March 1992.  This was in 1996, and you are quite sure

 4     about it.

 5             Mr. Seselj, you may proceed.

 6             MR. MARCUSSEN:  Considering that we have been discussing the

 7     contents of Prosecution Exhibit 65 ter number 1021, I would suggest that

 8     we admit it into evidence so that we have the document when the record is

 9     to be assessed.

10             THE REGISTRAR:  Yes, Your Honours, that will be --

11             JUDGE ANTONETTI: [Interpretation] No problems let's give it an

12     exhibit number.

13             THE REGISTRAR: Your honours, that will be Exhibit P831.

14             JUDGE ANTONETTI: Mr.Seselj, continue with your questions, if any.

15             THE ACCUSED: [Interpretation] Is this an exhibit of the Defence

16     or the Prosecution because the Prosecutor didn't want to use it

17     yesterday?

18             JUDGE ANTONETTI: [Interpretation] It's the Prosecution, it's you

19     who raised the issue so ... please proceed.

20             THE ACCUSED: [Interpretation] It's important to me now,

21     gentlemen, Judges, to study my entire speech from this meeting, so that

22     we can see whether this speech contains the sentence that the witness

23     asserts it contains.  Now we have clarified when the meeting took place.

24     There was no other meeting except this one.  There was only a fight at

25     this one, there were only poles in the trunk of the car at this meeting

Page 14072

 1     and our members chased away the crowd that was throwing stones at us.

 2             Again, can you scroll this up on the ELMO.  We're not going --

 3     [No interpretation] -- the following page, this is page 31.

 4        Q.   The first photograph shows us coming out of the culture hall and

 5     then us walking down the street and stones flying all about us and then

 6     we have Vineta Marinovic, a journalist of Velika Serbia holding her chest

 7     where she was struck by a stone and Miladin Todosijevic is holding his

 8     head, which was bleeding.  Immediately after the meeting we took them to

 9     Banja Koviljaca, to the emergency medical service.

10             Can we scroll up, we can see Vineta Marinovic, journalist of

11     Velika Serbia, holding her chest where she was hit on the head and next

12     to her is Miladin Todosijevic, whose head is bleeding.  He's holding some

13     sort of handkerchief or something on his forehead.  After that, we took

14     the two of them to Banja Koviljaca to the emergency room.

15             Can we now look at the next page, Vineta Marinovic ...

16             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, before you

17     continue.

18             Witness, assuming that in August 1990 these events occurred with

19     this woman holding her head because she's been hit by a stone, and in

20     light of the events that occurred, do you think that two years later the

21     same political party will hold a rally in exactly the same place without

22     taking the necessary measure to ensure that public law and order is

23     abided by?  Do you think one could contemplate that, that people who have

24     been attacked come and hold the same rally to be attacked again?  Do you

25     think this makes sense?

Page 14073

 1             THE WITNESS: [Interpretation] Well, it seems to me that there

 2     have to be precautions, and if this meeting was held in 1990, there must

 3     have been precautions taken; and for that reason, it must have been held

 4     inside the hall because of this number of people, the possibility of an

 5     incident occurring.  So because of these precautionary measures, the

 6     meeting was held in the hall.

 7             JUDGE ANTONETTI: [Interpretation] [Previous translation

 8     continues] ... is that if in 1990, if in August these incidents occurred

 9     and these incidents were serious despite the fact that there were a

10     number of policemen around and stones were thrown and people were

11     wounded, do you think that the people who organised this rally would

12     organise it again a year and a half later.  And a year and a half later,

13     when you are a Muslim person, you walk into the room, you walk into the

14     room in March of 1992, if what you are saying is true.  Do you think this

15     makes any sense at all?  To my mind, there is something which we need to

16     reflect upon.

17             You have told us that you were in the room.

18             THE WITNESS: [Interpretation] I was in the hall, that is true.

19     And it's true that nobody checked our IDs, and there were 15 to 20

20     people.

21             THE ACCUSED: [Interpretation] Mr. President, up to 20 days before

22     the armed conflict in Zvornik, there was so many weapons among the

23     people, had something happened like then, there would have been hundreds

24     of dead.  You don't think that at a time like that, people would have

25     been using stones and wooden poles.  At that time, guns were already in

Page 14074

 1     play.  Zvornik was full of weapons and volunteers.  You don't believe for

 2     a minute that Muslims from Zvornik would come to Mali Zvornik to attack

 3     us with stones at that time.  They -- there would have been a lot of

 4     casualties if they had done that at that time.  I mean this is just a

 5     logical conclusion.

 6             JUDGE ANTONETTI: [Interpretation] Proceed.

 7             THE ACCUSED: [Interpretation] Well I hope you managed to hear me.

 8     What I was saying is had this incident taken place in March 1992, two

 9     days before the armed conflict, there was so much weapons and so many

10     soldiers and volunteers, at least 100 people would have been killed.

11     There would not be an incident involving stones and wooden poles, March

12     1992 was an electrified atmosphere.  It never entered our head to conduct

13     the promotion of our party because an armed conflict was looming, and

14     there was already various incident so that is why that is impossible.

15     But there we go, the Prosecutor seems to think everything is possible.

16     Let's move on.

17        Q.   After Olivera Jelkic on the next page, page 32 and now a little

18     patience, bear with me, because we're going to have to look at the whole

19     of my speech to see if it contains that sentence.

20             Last paragraph, can we see that, middle of the last paragraph?

21     The president of the Serbian Chetnik Movement, Dr. Vojislav Seselj is

22     speaking, and I say:  Brothers and sisters, Serbian men and women, God be

23     with us, God be with you.  That's what you heard.  Now would you help me

24     out here, and let's take it paragraph by paragraph.  Let's move it down

25     one paragraph, please.  A little more so we can see the top of the page.

Page 14075

 1     And then the last paragraph.  The top of the page, please.  The top.

 2     Well, it's the last column, my mistake.  The third column.  And the top

 3     of the page.  It would be better if it were somebody who knew Serbian.

 4     Anyway.  There we have it.

 5              Brothers and sisters, Serbian men and women, God be with you,

 6     and then the response is God be with you.  That's a traditional Serb

 7     meeting, right?  You heard at the beginning of the rally?

 8        A.   Yes.

 9        Q.   Now, would you read out that first paragraph?

10        A.   Brothers and sisters, Serbian men and women, God be with us, God

11     be with you.

12        Q.   Next.

13        A.   We are gathered here today in Serbian Mali Zvornik at the

14     promotion of the Serbian Chetnik movement party, it took almost half a

15     century to restore the Serbian Chetnik sentiments and feeling in our

16     people.  The Serbian people lived for half a century in slavery akin to

17     that of the Turks, and the Serbian people suffered during that slavery.

18     During the last 50 years, the Serbian people did not --

19        Q.   Shall I take over.  I think I can see better:

20             The Serbian people did not resemble the Serb heros, the kind we

21     know from Serbian ethnic poems.  They did not look like the Serbs that

22     fought wars with the Turks and won two Balkan wars, in the First World

23     War.  The Serbian people mostly looked like the people of sycophants and

24     toadies.  So I'm characterising the Serb people there under the Communist

25     dictators, if that's quite obvious.  There's nothing about the Muslims

Page 14076

 1     there, do you agree?  Can I move on?

 2             Then I go on to say why was that so.  Because all that was great

 3     in the Serbian people was killed in two Balkan wars and two World Wars,

 4     or took refugee in the emigration after the Second World War or was

 5     killed in Tito's camps and prisons.

 6             Now move the text down a bit.

 7             The Serbian people were biologically blemished and it took

 8     several decades for new generations to grow, to start straightening up

 9     and to bring back the old glory of the Serbian people, Serbian national

10     pride and dignity.  And right now we are living in that period of history

11     and it is during this period of our history that the Serbian youth, in

12     particular, are finding their own two feet, standing up against Communist

13     dictatorship and all traditional Serbian enemies.

14             So this is an anti-Communist and anti-regime speech, do you

15     agree, Mr. 2000?

16        A.   I don't want to make any assessments and comments as to the

17     nature of the speech.

18        Q.   But you see that there is no mention of Muslims there?

19        A.   Well, do you think, Mr. Seselj, that somebody would be so clever

20     as to write the blackest of what you said, and I said yesterday that you

21     said that the Drina was not a boundary between Serbia and Bosnia --

22        Q.   That's what I think today.  I don't think the Drina River can be

23     a border.

24        A.   But in that text, is there what I said when you got up and said

25     categorically, brothers Chetniks and especially those of you across the

Page 14077

 1     Drina River, you are the bravest.

 2        Q.   Let's take it in order.  We'll come to that.  But I still

 3     maintain that the Drina is only a temporary border and cannot be a proper

 4     border dividing the Serbian people into two parts.

 5            "Today when we are finally bringing the anti-Serbian Communist

 6     dictatorship to an end we can see that as a people we really have to

 7     start from scratch.  Communism destroyed almost all the Serbian

 8     traditional values.  We have to restore our Serbian state.  We, the

 9     Serbian Chetniks, want neither the Communist system nor Yugoslavia

10     anymore.  We realise that Yugoslavia was a stepmother to the Serbian

11     people and that the Serbian people, especially in Communist Yugoslavia,

12     lost almost everything they had."

13             Is this an ultra-Serb nationalist speech; is that right?  Right?

14     Can you hear me?  Is it a speech by a great Serbian nationalist?

15        A.   Yes.

16        Q.   Yes, it is.  So we'll move on.  I'm just asking you.

17             "The villain and criminal Josip Broz Tito did all he could to

18     disfigure Serbia by following orders of the Communist International and

19     Vatican, and he almost succeeded in that.  Three artificial ethnicities

20     were created out of the Serbian national being:  Montenegro, Macedonia

21     and Muslim."  Do you remember me saying that?  Did I say that the Muslim

22     nation was an artificial nation?

23        A.   You say that at all your meetings.

24        Q.   Did I say that then?

25        A.   I can't remember.

Page 14078

 1        Q.   Okay.  Let's move on.  "Serbian lands were divided and torn

 2     apart.  A large number of separate federal units were created out of the

 3     Serbian countries and lands.  He made the Serbs quarrel amongst

 4     themselves.  He introduced unrest and discord amongst the Serbian people.

 5     Throughout their history, the Serbian people had never been as broken up

 6     as they are today.  However, the Serbian people in all Serbian states and

 7     lands are waking up.  We, the Serbian Chetniks, have put out the old

 8     flags of glory.  We are the Serbian Chetniks are fighting - turn to the

 9     next page, please - for the restoration of a free and independent Serbian

10     state in the Balkans.  We will never be satisfied with Serbia as it now

11     stands, as it now exists, narrowed down, almost reduced to the Belgrade

12     district pashalic [phoen].  We, the Serbian Chetniks, only recognise the

13     kind of Serbia which will comprise Serbian Macedonia, Serbian Montenegro

14     Serbian Bosnia, Serbian Herzegovina, Serbian Dubrovnik, Serbian Dalmatia,

15     Serbian Lika, Serbian Banija, Serbian Kordun, Serbian Slavonia, and

16     Serbian Baranja."  Did I say that at the rally?

17        A.   I don't remember.

18        Q.   "We, the Serbian Chetniks, will not stop" -- you have the

19     translation of the text in English.  I'm being cautioned by the

20     interpreters to slow down but, well, all right.  Yes, for the French

21     booth so I will slow down.

22             "We, the Serbian Chetniks, will not stop until we realise this

23     main goal of ours.  We, the Serbian Chetniks, on all sides and in all

24     Serbian states and lands, develop our political activities.

25             "A while ago we saw this mob outside, this crowd outside that

Page 14079

 1     came to prevent us from what we intend to do."  And what is in brackets

 2     is the response from the crowd so I'm not going to read it.

 3             "We, the Serbian Chetniks and Serbian people as a whole, the

 4     Orthodox Serbs, stretch out our hands towards our brothers, the Serbs of

 5     the Muslim faith."

 6             Do you remember me saying something like that?

 7        A.   No.

 8        Q.   All right.  "Throughout the course of Serbian history, there have

 9     always been great men of Muslim faith amongst our Serbian people.  Let us

10     just remember Mesa Selimovic, one of our greatest writers.  We will never

11     forget that the vice-president of the National Committee of Draza

12     Mihajlovic was the heroic Mustafa Mulalic.  We will never forget that one

13     of the Chetnik military leaders, Vojvodas belonging to Draza Mihajlovic

14     was Ismet Pupovac, a hero who commanded 2.000 Serbs of Muslim faith.

15     However, we will also never forget this unruly crowd.  It was people like

16     these who killed Serbs throughout Bosnia, Herzegovina, both before and

17     during the First World War and in this restricted and narrowed down

18     Serbia of today.

19             "We will never forget that such an unruly crowd in 1941 was the

20     first to put on Ustasha uniforms and set off to slaughter the Serbs.

21             "We will also never forget that throughout the course of Serbian

22     history such an unruly crowd was always ready to serve all Serbian

23     enemies to the very end, both the Austrians and the Germans, and

24     everybody who attacked Serbia.  We will never negotiate with an unruly

25     crowd like that."

Page 14080

 1             Do you remember me saying that?

 2        A.   You always delivered the same speech, almost word for word, at

 3     all your meetings and rallies, and the people you mentioned, Ismet

 4     Pupovac and Mustafa Mulalic and the figure of 2.000 or 3.000 Serbs, you

 5     would always list those things at each of your meetings.

 6        Q.   Well, this was a specific meeting geared towards a specific text

 7     because Muslims lived there.  Where there were no Muslims I didn't say

 8     things like that, so I didn't repeat the same things everywhere.  It was

 9     the same policy, the politics was the same and coincided in many points

10     but not the same and not identical everywhere.

11             Let me continue.

12             "We, the Serbian Chetniks, are fighting for a Serbian state which

13     will be democratic and freedom loving.  A state of citizens completely

14     equal to each other, with religious tolerance.  We will, however, by no

15     means allow throughout the Serbian lands the Islamic fundamentalists to

16     roam and to dream about setting up a Pan-Islam Islamist state which would

17     spread across the Balkans.  They will see once again how heroic the

18     Serbian people are and how steadfast they are in their intent" -- I

19     haven't finished yet, don't move the text.  "In their intent to restore

20     the Serbian state, freedom, democracy," and now the next page or next

21     column, "and their old glory.

22              "We, the Serbian Chetniks, having waved our Serbian Chetnik flag

23     and banner this year in our freedom-loving capital of Belgrade, place

24     ourselves at the service of the Serb people and we will not give up on

25     that.  The Serbian Chetnik Movement is a party that enlists only the

Page 14081

 1     bravest, the most resolute and the most loyal to the Serbian people.  The

 2     Serbian Chetnik Movement was formed as a party as early on as January of

 3     this year when the Serbian Freedom Movement was formed," and now we can

 4     skip that portion unless the Trial Chamber insists that we read

 5     everything because I'm referring to how this was established, so we can

 6     move on.

 7             Now I introduce my associates, Srdjan Glamocanin, Olivera Jelkic,

 8     Aleksandar Stefanovic, and so on and provide data about them.  And then I

 9     go on to say all these associates that I've just mentioned, you can move

10     the text down:

11             "They were never afraid of police truncheons, they were never

12     afraid of cordons and bans enforced by the regime, and it is with people

13     like these, resolute, brave, and clever, that we managed to win

14     legitimacy for our party.  The communists banned at the beginning or from

15     the beginning.  Recently they wanted to stop us from holding a

16     commemorative ceremony to mark the anniversary of General Draza

17     Mihajlovic's death.  They did not manage to do that because we brought

18     out 10.000 people in front of the Prince Mihailo Obrenovic's monument in

19     the centre of Belgrade."

20             Do you remember the 17th of June, 1990, when we held a

21     commemorative meeting for Draza Mihajlovic in Belgrade.  All the papers

22     wrote about that.  Do you remember that?

23        A.   Yes.

24        Q.   Do you remember that the police banned the meeting but when they

25     saw how many of us they were, they did not want to ban us.  That's how it

Page 14082

 1     was.

 2             Now I go on to say the following.  May we have the next

 3     paragraph, please.

 4             Our party was officially registered on a Tuesday, that's when the

 5     Serbian Chetnik Movement was officially registered.  However, after this

 6     rally, we received a note saying that we were banned.  Do you remember

 7     that the regime, in August 1990, refused to register the Serbian Chetnik

 8     Movement in Belgrade?  All the papers wrote about that.

 9        A.   Yes, the papers did write about that but I am not sure I know

10     what happened.

11        Q.   All right.  Now, I go on to talk about the party programme, we

12     can move through that a little faster, we can skip some methods, but we

13     say we fulfill all conditions and we just use peaceful methods of

14     political struggle, and we act in conformity with the interests and aims

15     of the Serbian people.  And that is at the beginning of the third column,

16     second paragraph.

17             As such, the Serbian Chetnik Movement is at the service of its

18     people.  I spoke from my head then, I didn't have any paper in front of

19     me, right?  My speech was recorded and then a journalist of Velika Serbia

20     published it, put it down on paper and even put where the applause took

21     part -- took place.  The Serbian Chetnik Movement is in favour of a --

22     the restoration of a democratic political system, a multi-party system,

23     the setting up of the rule of law which means legitimate authorities and

24     the legality of their decisions.  It is for an independent court and

25     public attorney system and preventing any political party from recruiting

Page 14083

 1     the army and police into its ranks.

 2             You will remember that under the Communist regime, every

 3     policeman and every officer and lower ranking officer had to be a member

 4     of the League of Communists of Yugoslavia; that's true, isn't it?

 5        A.   Well, I'm not sure what you're asking me.

 6        Q.   Well, do you remember that?  It's important.

 7        A.   Well, it's not important as far as I am concerned.

 8        Q.   Is that how it was, though?

 9        A.   Ask me something else, Mr. Seselj.

10        Q.   I have a lot of time, an abundance of time.  I have more than an

11     hour so I can go through all these things.  And the time that the Judges

12     used up and the Prosecutor is deducted from my time so I have a lot of

13     time.

14             The Serbian Chetnik Movement supports abandoning the policy of

15     non-alignment and then I go on to condemn cooperation and alliances with

16     states led by Idi Amin, Bokassa and so on.

17             And then I made a mistake, because I'm a little more mature now

18     and [indiscernible] I say, We the Serb Chetniks promote the return of our

19     fatherland to Europe to a community of civilised and democratic nations

20     and states.

21             Later on we came to realise that there were the fewest civilised

22     states precisely in Europe, so we don't want that anymore.  So that's the

23     correction I would like to make after gaining a better understanding and

24     developing my consciousness.

25             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, we are not going

Page 14084

 1     read out this entire speech; it's pages long.

 2             THE ACCUSED: [Interpretation] All right.  I'll skip over some

 3     sections.

 4             JUDGE ANTONETTI: [Interpretation] Witness, do you remember

 5     whether a Muslim took the floor during this meeting; yes or no?

 6             THE WITNESS: [Interpretation] No.

 7             JUDGE ANTONETTI: [Interpretation] Because Mr. Seselj, at the very

 8     end, there is a person taking the floor called Sakib Kavazovic saying, "I

 9     am a Muslim."  It might be interesting to see what this person has to

10     say.

11             THE ACCUSED: [Interpretation] Mr. President, let us first find if

12     this sentence that is being quoted in the indictment can be found in this

13     speech.  This is what I was thinking of.  If you permit me, I have time

14     and I was planning.  Look, if the sentence is not in my speech then that

15     whole part of the indictment can be dropped.  I don't have any further

16     reason to examine this witness.

17             JUDGE ANTONETTI: [Interpretation] This sentence is not in the

18     document that we have in our hands.  That's very obvious.

19             THE ACCUSED: [Interpretation] So do you want me to just discard

20     everything that I was intending to read?

21             JUDGE ANTONETTI: [Interpretation] If this sentence was actually

22     said on August 4th, no, it's not in the speech that you delivered on

23     August 4th, that's absolutely sure.  We don't need to read the entire

24     thing just to conclude the sentence is not included.

25             MR. SESELJ: [Interpretation]

Page 14085

 1        Q.   Very well.  When I finished this speech then the citizens present

 2     began to ask questions; isn't that right?

 3        A.   Yes.

 4        Q.   And the first question was put by a person who did not introduce

 5     himself.  He asked something about Tito's mausoleum in Dedinje, and this

 6     is on the page before last and then I answered his question.  And then

 7     the next person is Ratko Cvetkovic who introduced himself as the Serbian

 8     National Renewal member from Milici.  This is a different municipality

 9     next to Bratunac, isn't it?

10        A.   Yes.

11        Q.   He asked a question so I answered him.  Then another person who

12     did not give his name said that he would have complications at work

13     because of attending our meeting.  And then the fourth question, a

14     citizen asks about the position of the peasants and what is our position

15     on that.  And then again the fifth question is by a person who begins

16     putting the question with the words, "Comrades," and at the end when we

17     wanted to finish there was someone coming towards the lectern.  And now

18     look, a person broke through, this is the 36th page, he began to speak

19     but the frenetic applause made it impossible to hear him, Vojvoda, look,

20     well, it is obvious that I am the only Vojvoda present.  So then he says,

21     God be with you.  Actually, I say first, "Brothers, please wait for this

22     gentleman to say what he wants to say and then we will go outside

23     together to see who is threatening us."  And then the crowd replied,

24     "Hear, hear," and then this person came up to the lectern and he said,

25     "God be with us Serbian brothers and sisters."  And the crowd replied,

Page 14086

 1     "God be with you."

 2             Then he said, "I am a Muslim, Sakib Kavazovic from Semberija.  In

 3     1951 I was forced to cross over to Serbia and I have lived in Serbia

 4     since 1951.  I built one house there but I couldn't say.  I went amongst

 5     Serbian brothers.  Now I lived in Novo Selo in Macva for five years, four

 6     years in Lesnica.  I have lived here for 25 years now and I am not afraid

 7     of anyone.  I have my children here, my son got married in Valjevo, I

 8     live with Valjevo people, I fight for Serbia and I will die for Serbia."

 9             Then the journalist comments, "Everybody rises fervently

10     greeting brother Muslim with applause.  The Vojvoda goes up to him and

11     kisses him.  The crowd greets this gesture with even more fervour."  The

12     president of the Mali Zvornik local board of the Serbian Chetnik

13     Movement, addresses the crowd again, If there are no further questions, I

14     would like to ask us all to go out with dignity and without provocations,

15     no provocations from our side, but then when we went out, we were hit by

16     stones.  That's how it was.

17             Do you remember the Muslim who came out?

18        A.   Well, Mr. Seselj, I left before this happened because I was taken

19     out by your security.  I wanted to say something, some people reacted but

20     you said, Let him say what he wants to say, then these two people took me

21     by the arms and without an incident, without harming me, they took me

22     outside.

23        Q.   You didn't speak at this meeting in any case, why would anyone

24     throw you out no matter what you said at my meeting.  I was able to hold

25     rallies before large groups of people where more than 90 per cent of the

Page 14087

 1     people were against me and my sympathisers, but I still could deal with

 2     them.

 3             So whatever you wanted to say at this meeting, no one would have

 4     taken you out of the hall.  This is just pure fabrication.  You were not

 5     removed from the meeting, only somebody who was provoking violence or was

 6     violent would have been taken out of the meeting.

 7             So, since now we have finished this, are you still claiming that

 8     this meeting in Mali Zvornik was held in March 1992?

 9        A.   Yes, you did have that meeting in March 1990.

10        Q.   All right.  Then by next week the Prosecutor will assemble all

11     the articles from the newspapers and then we can see it here.  As you

12     know I have no associates and I have nobody who would be able to help me

13     to search for these things myself.  All that I have here in front of me

14     is the things that I have received from the Prosecution.

15             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, before the break,

16     the Trial Chamber has one question.

17             Is there an audiotape of the speech you delivered on August 4th,

18     1990?  Is there an audiotape?  An audio recording of this speech?  Do you

19     know?

20             THE ACCUSED: [Interpretation] This is something that you would

21     need to ask journalist Vineta Marinovic, I have no contacts with her.  If

22     the Prosecution is able to find her but this is not very likely.  This

23     took place more than -- or almost 20 years ago, so I doubt it.

24             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you identified

25     quite justly that this part of the indictment was very crucial and you

Page 14088

 1     wondered whether someone really heard what was said.  You knew that a

 2     newspaper article had been drawn up from it.  Fine.

 3             Now, the news reporter who transcribed your speech might have

 4     done so from an audiotape recording that she would have had.  If that's

 5     the case, one of your associates, and you have many, could have went to

 6     see this reporter, ask her for the audiotape and that would be an

 7     evidence for you, you know, to say that, Listen to this speech, you can

 8     listen to the entire speech and I never said this sentence.  But didn't

 9     think about this, did you?

10             THE ACCUSED: [Interpretation] Mr. President, as -- in the same

11     way that somebody, when they publish an article can drop something, omit

12     saying something, they can also delete something from a tape.  I mean it

13     never occurred to me that that would be something important.  What is

14     important here is actually when the meeting was held, the date, and then

15     only after what was actually said at the meeting.  I could have said the

16     worst things in the world at a meeting in 1990.  This is two years before

17     the war in Bosnia.

18             JUDGE ANTONETTI: [Interpretation] Yes, Mr. Seselj.  But you'll

19     reckon with me, if this audiotape does exist, maybe the news reporter

20     kept it or maybe it's in the archives of the newspaper.  It could be very

21     useful for you as evidence for your case.

22             Furthermore, Mr. Seselj, you have many associates, and these

23     associates should have scrutinised all the newspapers, all issues of this

24     newspaper at the time to prove that nothing had happened in March 1992.

25             THE ACCUSED: [Interpretation] Mr. President, my collected works

Page 14089

 1     already number about 104 or 105 volumes of 1.000 pages each and almost

 2     all my text about myself and about the Serbian Party and about the

 3     Serbian Chetnik Movement are published in those tomes.  The Hague

 4     Prosecution has an earlier edition of those works.  They have some

 5     80 volumes.  So every speech from the Radical Party is in that collection

 6     especially from volumes 41 to 50.  Everything that was ever written about

 7     the Radical party would be in that, so if there had been a meeting in

 8     Mali Zvornik it would be contained there.

 9             You're behaving as if I had the burden of proof.  Actually this

10     burden is on the Prosecution, the very fact that the meeting did not take

11     place in March 1992 but in August 1990 is enough to overturn the whole

12     indictment.

13             JUDGE ANTONETTI: [Interpretation] Absolutely, Mr. Seselj, you're

14     right.  The burden of proof is on the Prosecution, everyone knows that.

15     But you are the accused in this case and you have to defend yourself so

16     you should say, I'm being accused of something because it was something I

17     said in a speech, I would have said in a speech allegedly, I'm going to

18     prove and demonstrate that this is not the right speech and that in the

19     speech I actually gave I never said this.  If you have an audiotape, an

20     audio recording that could back this, this would be crucial evidence for

21     you.

22             You're saying my speech is in my book.  Fine.  But your speech

23     could have been redacted, you know, you could have cut off some sensitive

24     excerpts whereas in an audiotape we have the reality of things.  We can

25     know technically whether the audiotape has been tampered with or not.

Page 14090

 1             THE ACCUSED: [Interpretation] Mr. President, this is

 2     Velika Serbia issue number 3 magazine of the 15th of August, 1990, when

 3     no one in the Balkans knew that war was imminent.  This is August 1990.

 4             The least they knew was that at some point, there would be

 5     The Hague International Tribunal for War Crimes which would be

 6     established and where I would be expected to defend myself against war

 7     crimes, the illegal Tribunal.

 8             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, don't make things

 9     worse.  You're talking -- you're saying -- just said "illegal Tribunal."

10     You could have spared that.  You could have not said this and proof of --

11     we're really trying to do our job as Judges here, full independence.  But

12     now we'll break for 20 minutes.

13                           --- Recess taken at 4.06 p.m.

14                           --- On resuming at 4.34 p.m.

15             MR. SESELJ: [Interpretation]

16        Q.   Mr. VS-2000, do you consider me to be an uneducated person?

17        A.   No, why?

18        Q.   Do you believe that I lack some elementary theological knowledge

19     pertaining to modern religions that I have no idea what that is about?

20        A.   Well, I wouldn't wish to discuss that with you, but at no point

21     did I say that you were an uneducated man.  Actually, as a matter of

22     fact, and you heard me well, I said yesterday that you were the youngest

23     lawyer with a Ph.D. in Yugoslavia and you must have and had to have

24     learned something.

25        Q.   In my indictment, it says that I had called Bosnian Muslims

Page 14091

 1     pagans and in the pre-trial brief that I had called them Godless.  Would

 2     any educated person refer to Muslims as Godless at all?

 3        A.   Well, that is up to you.

 4        Q.   For example, if I know that Mohammed created a new religion based

 5     on Christian and Judaic heritage and that he adopted their beliefs and

 6     formed them, gave them a new form but kept the faith in the one and only

 7     God, how can I then refer to them as Godless?  You know that Muslims

 8     recognise Christ as a prophet, you know that, you're a Muslim, aren't

 9     you?  How do Muslims call Jesus Christ?

10        A.   Isa.

11        Q.   Isa Messiah or Isa the prophet and you know that in the Koran,

12     when the day of judgement comes, it says that Isa Meremi [phoen], Jesus

13     of Mary will judge the living and the dead.  Is this mentioned in the

14     Koran?

15        A.   Yes, it is.

16        Q.   The Muslims only do not recognise Jesus as the son of God but

17     they do recognise him as a God's prophet, Islam recognises that.  And do

18     you know that in Syria, there is a mosque dedicated to Jesus Christ, Ici

19     Pedombet [phoen].  It's a mosque that is God knows how old that is

20     dedicated to Jesus.  Do you know about that?

21        A.   Well I'm not that informed about it.

22        Q.   Yes, but I am.  What I'm trying to let you know is that it is

23     quite impossible for me to use this term and as much as my speeches are

24     quite radical and forceful, sometimes even extreme, still I do not commit

25     such stupidities in my speeches.

Page 14092

 1             My speeches are logical and coherent, aren't they?  Do you

 2     disagree with that logic?  You cannot say that my speeches have no

 3     internal logic and coherence, would you agree with that?  You're quiet?

 4     Did you study law in Sarajevo?

 5        A.   Yes, but I don't know what to answer other than yes or no.

 6        Q.   Well, you can say yes or no?

 7        A.   Well this is your theory.  I do not want to get involved in your

 8     theories and your views.  I don't want to take any part in that.

 9        Q.   All right.  Let's move to a new question and let's hope it's

10     something that is a much calmer atmosphere.  Would a more calm atmosphere

11     suit you or a more turbulent one?

12        A.   A more turbulent one.

13        Q.   Well I'm going to proceed calmly.  You gave two statements to The

14     Hague Prosecution; isn't that right?

15        A.   Yes.

16        Q.   You gave a statement in 1996 --

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

18     would rather have a very smooth and quiet hearing.

19             You haven't understood.  Well you're asking the witness whether

20     he'd rather have a quiet hearing.  I associate myself with you and I can

21     tell you that the Trial Chamber also would rather have a very quiet

22     hearing.

23             THE ACCUSED: [Interpretation] All right.  On my part, I'm going

24     to do my best but you saw what happened earlier.  I had a concept of

25     cross-examination.  The Prosecutor wanted to break that up right at the

Page 14093

 1     beginning, disrupt that so I couldn't deal with it in the way that I

 2     wished.  The Prosecutor got stuck to this point what year and so on so I

 3     have to go down another track.  I mean the over ambition of the

 4     Prosecutor spoiled things this time but now we are going to improve

 5     things.  We will make them better.

 6        Q.   You gave your first statement in 1996; is that correct?

 7        A.   Yes.

 8        Q.   And then you provided a statement in 2002; is that correct?

 9        A.   Yes.

10        Q.   The first statement you referred to the things that were asked of

11     you yesterday during the examination in chief and the second statement

12     was part of the preparation by the Prosecution for the Naser Oric trial

13     but then they never called you to testify; is that correct?

14        A.   No.

15        Q.   I see that they asked you here about some things about your war

16     experiences or work together with Naser Oric and events from 1993 but

17     we're not going to go into that.  The second statement has nothing to do

18     with this case; isn't that right?  Do you remember your second statement?

19        A.   Yes, I do remember it but we didn't discuss the Oric trial at

20     all.  What was discussed was for me to state my story and to say what I

21     knew that would make some sense.

22        Q.   But you talked about some other things, they probably didn't tell

23     you why they were seeking your statement but judging by the contents of

24     that statement, I see that they insisted on that because there are names

25     here of various Muslim leaders, military leaders and so on, but we're not

Page 14094

 1     going to go into that.  This is not so important now.

 2             In this first statement, you first talk about how you set up a

 3     checkpoint at the stone quarry and arrested four Serb police officers and

 4     seized their car; is that correct?

 5        A.   Yes.

 6        Q.   What date was that?

 7        A.   The 8th of April, in the morning, in 1992.

 8        Q.   In the morning.  So this was before this armed clash in Zvornik

 9     which occurred during the day; is that correct?

10        A.   Yes, during the day or a little bit earlier.

11        Q.   During the morning?

12        A.   Before the attack on Zvornik, the proper attack on Zvornik.

13        Q.   What was your authority to stop a police vehicle, first of all?

14     Secondly, to arrest four policemen, and then to confiscate their car?

15        A.   You know very well Mr. Seselj that before the beginning of the

16     war, checkpoints were set up everywhere where the Serb and the Muslim

17     populations lived close by, so these were set up to separate them.  So

18     wherever it suited anyone, they would set up a checkpoint and they would

19     monitor who was moving along that particular road, what did they have in

20     the car, what was their business.

21        Q.   So in Vlasenica, there were no combat actions?

22        A.   As far as I know, the situation was the same as Zvornik.  There

23     was some preparations but nothing was happening.

24        Q.   All right.  So these were policemen from Vlasenica, they wore the

25     same uniforms as any police officers in the former Yugoslavia?

Page 14095

 1        A.   They were in civilian clothing.  Only one of them had camouflage

 2     uniform with a red polo neck top.

 3        Q.   It doesn't say that here, only that they were police officers and

 4     that you confiscated their car?

 5        A.   We saw that they were police officers on the basis of their IDs.

 6     Three of them were wearing civilian clothing and one --

 7        Q.   All right.  You as a group of citizens with weapons stopped a

 8     police car and arrested four policemen.  They showed you their IDs and

 9     you looked at them and on the basis of their documents, you could see

10     that they were ethnic Serbs.  They were not Serb police officers.  There

11     was no Serb police in Vlasenica, the police were still one united force

12     at the time?

13        A.   I don't know that.  Throughout the whole territory of eastern

14     Bosnia, the police had separated already, so the police in Vlasenica were

15     separated just as it was in Mali Zvornik so the Vlasenica police had its

16     own -- Serb police had its own direction and why we stopped them was

17     because they had weapons, they had explosives and they also had casks in

18     their car.

19        Q.   And then when you stopped them, you called the Zvornik police?

20        A.   Yes, correct.

21        Q.   And a Muslim policeman from Zvornik told you to release them?

22        A.   Yes, he checked the names of the people that we dictated to them

23     and he said that they should be returned to -- towards Vlasenica through

24     the checkpoints of Konjevic Polje which was done.

25        Q.   How did you return them if you seized their vehicle, you didn't

Page 14096

 1     give them the car back?

 2        A.   One of those people who was driving gave it back.  They drove

 3     them in that car to the Serb checkpoint in Vlasenica and seized the car.

 4        Q.   They seized the car?

 5        A.   Yes.

 6        Q.   On what grounds?  On the grounds of the rules of war; is that

 7     right?  All right.  Very well.

 8             So now you're taking this car and you went to Zvornik to the

 9     police station and then you say, On the first floor of the police station

10     building, I saw three men who were tied or attached one to another with

11     handcuffs, they were handcuffed one to another.  How many of them were,

12     three or four?

13        A.   They were four.

14        Q.   And that fourth one you didn't see?

15             THE INTERPRETER:  Could the witness please repeat his answer, the

16     speakers are overlapping.

17             MR. SESELJ: [Interpretation]

18        Q.   Now let's deal again with those four people who were arrested,

19     who were arrested at the checkpoint at the entrance to Zvornik; is that

20     correct?

21        A.   Yes, from the northern side and there's a river there called

22     Zlatica [phoen].

23        Q.   You say one of them wore a camouflage uniform and the other two

24     were in civilian clothes; right?

25        A.   No.  When I referred to the uniforms, they were policemen.  The

Page 14097

 1     others all wore uniforms, all four of them.

 2        Q.   I see.  Because on page 5 of your statement here, the last

 3     paragraph, you describe them, those thee men and this is what you say,

 4     One of them had a camouflage uniform and the other two were in civilian

 5     clothes.  That's what it says in this statement.

 6             Were they all wearing uniforms?

 7        A.   I don't know what I said in my statement but anyway, one was in a

 8     pattern camouflage uniform, the others were in regular, ordinary

 9     uniforms.

10        Q.   Here it says civilian clothes and that shows the lack of

11     seriousness on the part of the OTP.

12             "The fourth colleague, Repic, I saw in Fadil Mujic's office."

13        A.   Right.

14        Q.   And he was chief of -- a chief in the Zvornik police and he works

15     in the MUP of Tuzla today.  And you say:

16              "I saw a heap of scrap wire, the kind of wire you use for

17     suffocating people.  Wires and injection and some other objects with you

18     the police uncovered during the interrogation.  I saw the wires in the

19     hall outside the room in which the three men were held."

20        A.   72 pieces of wire.  The people counted them, and on the table

21     there were 72 pieces of wire.

22        Q.   And what did Fadil Mujic say to you when you saw these people?

23     Who are they?  Did he say anything about them?

24        A.   He was conducting his interrogation, his questioning, and I told

25     him, I said Fadil, the shooting had already started from the northern

Page 14098

 1     part of the municipality from the nearby hill, from where the Chetniks

 2     started to take over the territory, this shooting, the war has started

 3     officially and you're sitting here questioning people.  Now if you

 4     consider that they should be released then release them.  Let's not make

 5     any more -- any incident about this.  Let's try and calm the situation

 6     again and that's what he did.

 7        Q.   So your idea was to have the people released.  That was your

 8     first idea?

 9        A.   Yes.

10        Q.   And were they beaten during the interrogation?

11        A.   Nobody touched them.

12        Q.   You didn't see any traces of blows on their body?

13        A.   No, I talked to one of them, I was at a distance of say two

14     metres, and I just asked him some things.

15        Q.   Do you know the names of those people today?

16        A.   No, I just know that the man that Fadil was examining had the

17     nickname Repic.

18        Q.   Do you know that it's Dusko Vuckovic, nicknamed Repic one of the

19     greatest criminals in the Zvornik area?

20        A.   No.

21        Q.   Do you know that he was taken to trial in Serbia for crimes

22     committed in the Zvornik area and that he committed suicide in prison,

23     you don't know any of that?

24        A.   No, I didn't ask around.

25        Q.   All right let's see what you go on to say here:

Page 14099

 1             "When I saw Repic for the first time, he was sitting on a chair

 2     with his back to me.  He had broad shoulders, a broad neck."  This is on

 3     page 6, second paragraph, and he had his hair in a ponytail.  The lower

 4     half the his neck was shaved.  He might have been 25 or 26 years old at

 5     the time and although he was sitting down I think he was probably tall,

 6     about 1 metre 80.  He had light brown hair and when he turned towards me,

 7     I saw that he had side burns.  His face was red, and he didn't have a

 8     beard or mustaches.  He had bald patches above his ears.  He turned to me

 9     and he asked Fadil, what did they tell me to release the policemen from

10     Vlasenica, and Fadil said that the chief of police Osman Mustafic, who

11     lives in Germany today, knew the four men and that's why he told me to

12     release them.

13             And that refers to the Serb policemen from Vlasenica whom you

14     released; right?  And this is your description of Repic, and it

15     corresponds to a great measure to what the man actually looks like.  It's

16     a reliable description of Dusko Vuckovic, aka Repic so you have a very

17     good memory if I can note that.

18             Now, there's another paragraph, and I'll quote that.  You say:

19             "I went back into the room in which the three men were kept.  I

20     sat next to one of them who was thin and I turned to him and said, 'You

21     scum, who sent you here and what are you doing here?'  And he introduced

22     himself.  I don't remember what his name was," that's your comment.  And

23     he said that he was from Pancevo and that the media, it was the media's

24     fault that he was there because he said that he spent a month and a half

25     with many others in quarantine because they kept saying that the Muslims

Page 14100

 1     in Zvornik are slaughtering and putting Serbs on the spit and rubbing

 2     salt into their wounds.  He didn't say where he was in quarantine with

 3     these other Serbs."  So that is your statement.

 4             Now on that occasion, did you have any information as to how

 5     these people identified who they were, anything like that?

 6        A.   No, I didn't have any information on paper but people told me,

 7     the people that I found in the corridor outside, they said that they were

 8     Chetniks and that wires were found on them and so on, and all the other

 9     objects, but I didn't ask for any identifications.

10        Q.   Did you hear that some documents were found on them?

11        A.   Well, some documents were found but I didn't see them.

12        Q.   So you don't know what documents ID cards or anything like that?

13        A.   No.

14        Q.   Now I'm going to tell you who these people were.  Milorad Ulemek,

15     nicknamed Legija was one; Vojin Vuckovic, nicknamed Zuca was another;

16     Dusko Vuckovic -- or Dusan Vuckovic, nicknamed Repic was another; and

17     then there was Miroslav Bogdanovic.

18             Do you know today who those people are?

19        A.   No.

20        Q.   Vojin Vuckovic later on, after the fall of Kula Grad, within the

21     Territorial Defence he set up a detachment called Igor Markovic and

22     afterwards, that detachment came to be known of the Yellow Wasps.  Have

23     you heard of that?

24        A.   Yes.

25        Q.   His brother Repic was well known for some atrocious crimes that

Page 14101

 1     were committed there and for which he was tried.  Milorad Ulemek, Legija,

 2     he later became one of Arkan's men and then transferred to the police of

 3     Serbia.  He was the commander of a unit there, a special police unit and

 4     had the rank of colonel, and then he was arrested and taken to trial

 5     because of his alleged involvement in the killing Prime Minister Zoran

 6     Djindjic.  Did you ever link those things up on the basis of what the

 7     papers wrote and so on?  Did you ever bring them into contact with their

 8     roles later on?

 9        A.   Well, I read various articles about some of them, the ones you

10     mention and the dirty things they were involved in, but I didn't enter

11     into any details.

12        Q.   Miroslav Bogdanovic died in 1993.  Now, my associates in June

13     last year visited Milorad Lukovic aka Legija in the central prison in

14     Belgrade, took a statement from him.

15             THE ACCUSED: [Interpretation] And could I ask the usher to

16     provide a copy of the statement to the Trial Chamber and the Prosecutor

17     and place one on the ELMO.

18        Q.   It's a statement written over five pages by hand, it's in

19     handwritten form, so let's read it through together and see what it says

20     because Milorad Ulemek, Legija, for a time had the surname of Lukovic.

21     He explains how he came to be Zvornik, so let's see how he describes

22     those events, the events that you refer to.

23             THE ACCUSED: [Interpretation] Can we have it up on our screens,

24     the screen that the public can see, because this is a public matter.

25        Q.   Now, this was sent to me on the 23rd of January this year from

Page 14102

 1     Belgrade; it was faxed to me, in fact.

 2             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen.

 3             MR. MARCUSSEN:  Your Honours, you will notice that yesterday, in

 4     direct examination, I led no evidence on this point whatsoever.  I don't

 5     know why the accused is now going to read out a long statement from

 6     someone who had given no evidence about this and it is irrelevant to the

 7     evidence of the witness.

 8             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, the

 9     cross-examination is not the right you have to ask any question.  You

10     should base your questions on those questions that have been put during

11     examination-in-chief.  Which topic are you addressing now?

12             THE ACCUSED: [Interpretation] Mr. President, the witness

13     testified about the war events in Zvornik as he experienced them, and

14     from his statement I can see that he met these four men and even talked

15     to them.

16             Secondly, some other witnesses earlier on referred to these

17     people as well.  We discussed them.  There was a witness who claimed that

18     two of them had membership cards of the Serbian Radical Party, if you

19     recall.  I'd like to remind you of those witnesses.  I didn't have

20     Milorad Lukovic's statement at the time, we had Vojin Vuckovic, Zuco's

21     statement.  Vojin Vuckovic, Zuco, is the one I quoted, so let's deal with

22     this matter because it's important for me.

23             What the witness testified about --

24             JUDGE LATTANZI: [Interpretation] I would like to specify that the

25     fact that topics are being discussed during cross-examination which were

Page 14103

 1     not addressed during examination-in-chief, this is not a problem as far

 2     as I'm concerned because cross-examination deals with the defence of the

 3     accused; but as far as this particular statement is concerned, I would

 4     like to emit reservations and I have already done this on a number of

 5     times.  Every time the accused shows us statements like this one, I don't

 6     need to repeat those reservations I have already made, I would just like

 7     to say that I don't agree with such statements that have no probative

 8     value, not even prima facie, so I cannot accept these.

 9             This is my personal view, as you know, Mr. Seselj.  I have

10     repeated this many a time.  I just need to repeat it again today.

11             JUDGE ANTONETTI: [Interpretation] Mr. Marcussen.

12             THE ACCUSED: [Interpretation] Judge Lattanzi, I'm not offering up

13     any statements into evidence here; I'm just using these statements as a

14     ground work for the cross-examination.  I want to ask the witness whether

15     he has some of his own knowledge about what Milorad Ulemek aka Legija

16     speaks about in his statement, nothing more than that.

17             JUDGE LATTANZI: [Interpretation] All right, but since I have said

18     this several times before, as far as I am concerned, you may put these

19     questions but you shouldn't read this statement and you shouldn't put it

20     on the ELMO.

21             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you say to the

22     witness, right, we have this statement.  In this statement, Mr. Legija

23     says such and such and then you ask the witness what he thinks about it.

24             THE ACCUSED: [Interpretation] Very well.  Do you want me to

25     continue or Mr. Marcussen?

Page 14104

 1        Q.   Here, Milorad Ulemek - let's have it on the ELMO - and his

 2     nickname was Legija, provides data about himself, when he was born, who

 3     his parents were.  The statement was certified by the prison authorities

 4     and it was signed as well, it's signed at the end.

 5             The statement was sent to me, to the detention unit fax machine,

 6     and it's not very legible because the detention unit usually makes a

 7     photocopy when a fax comes in for me and then provides me with the

 8     photocopy and put the original in my file.  However, I think we will be

 9     able to make due with this, at least I hope so.

10             In the first paragraph he says that he was in the foreign legion

11     in Chad and when he saw what was going on in Yugoslavia, he escaped from

12     the foreign legion and in 1992, arrived in Yugoslavia to help his own

13     people out.  And he says that he decided to go to Bosnia to help the

14     Serbs there and protect them, as far as he could, for them to defend

15     themselves against the Muslim terrorists.

16             Now, witness, do you know whether these four men, during the

17     interrogation, which went on for a long time because they were arrested

18     on the 7th at the barricade and spent the whole night in the police

19     station and only the next day towards evening were released; right?

20        A.   On the 8th in the morning at 4.30 a.m., and the distance is one

21     kilometre and they were in the police station within 15 minutes.

22        Q.   Did they say where they went and why?

23        A.   Later on, talking to the people who took them in and questioned

24     them, I learned that they wanted to infiltrate the town and be a point of

25     support for other people coming in from the hills to reconnoitre.

Page 14105

 1        Q.   Is that what they said?

 2        A.   That's what I was told they had said.

 3        Q.   All right.  Now, here Legija says that he wanted to join the

 4     Vuk Draskovic Guard, first of all, commanded by the late Giska but that

 5     he changed his mind because Vuk was unreliable and you couldn't count on

 6     him.  And then he goes on to say that before he went to the foreign

 7     legion he knew Nedjo Boskovic.  Do you know who Nedjo Boskovic was at the

 8     time?

 9        A.   I have heard that but I don't know that, I don't know that very

10     well.

11        Q.   Well, I'm sure you don't know him but he was the chief of the

12     military security service in the JNA; right?

13        A.   Yes, but I don't know him personally.

14        Q.   And he was head of the security service in the Yugoslav Army for

15     a few months, so that's the position he occupied, and he said that he

16     knew him before he went to join the foreign legion because he was the

17     father of a friend of his from primary school, a little girl.  And he

18     says that when he returned in 1992 to the homeland, Nedjo Boskovic came

19     into contact with me straight away, he says.  Now while these four men

20     were at the police station in Zvornik, did Nedjo Boskovic call up from

21     Belgrade to ask about them?  Did you hear about that?

22        A.   No, I don't know about that.

23        Q.   You don't know.  Very well, because we had testimony about that

24     from a witness.  Did you know who Milan Petrovic, Zuda [phoen], was?

25        A.   He's from your parts.  Now Pusula, that nickname, I knew somebody

Page 14106

 1     from his family who was a hauler but --

 2        Q.   He was a hauler himself, and do you know that he was well known

 3     for black marketeering in weapons?

 4        A.   Well, one of them was a black marketeer so it must have been that

 5     one.

 6        Q.   Yes, that's him.  So you knew that he was a black marketeer in

 7     weapons, dealt in weapons.

 8             Now here is what Legija says.  He says that Nedjo Boskovic, at

 9     the beginning of April, told him that a certain Milan Petrovic, nicknamed

10     Pusula, was bringing weapons in clandestinely to Zvornik and that he

11     ought to be arrested, and that he took on this assignment as a patriotic

12     act because he found it intolerable that a Serb should supply Muslims

13     with weapons clandestinely, because they used those weapons to kill

14     Serbs.  So he said that was the assignment given him by the chief of the

15     military security service whom he knew earlier on, General Nedjo Boskovic

16     to go to Zvornik and in the Zvornik area, to arrest Milan Petrovic,

17     nickname Pusula?

18        A.   Did he have an address this Pusula man?

19        Q.   Well, he doesn't say.

20        A.   Pusula didn't live in the town of Zvornik.

21        Q.   He was in the Zvornik municipality.

22        A.   Correct, but not in town.

23        Q.   He later on says that they lost their way.  You didn't know that

24     they were criminals at the time and they weren't criminals at the time.

25        A.   Well, that's something you're telling me now.

Page 14107

 1        Q.   When I say that this man Repic was a criminal later on, that

 2     Vojin Vuckovic formed the Yellow Wasps, that Miroslav Bogdanovic died in

 3     that of 1993 and wasn't involved in any criminal affairs, and that Legija

 4     was first of all in Arkan's unit and then he transferred to work in the

 5     police station and reach the rank of Colonel, that's what I'm saying.

 6        A.   Mr. Seselj, if you permit me.  I will say that in your speeches,

 7     and I've been following that, you keep saying that some members of some

 8     other parties, some other units, the Wasps, the Wolves, that they all

 9     were in the Chetniks in the area of the Zvornik municipality.  The fact

10     that later they found pretty names, attractive names like Eagles, Wasps

11     and Eagles, actually, basically they were all Chetniks.

12        Q.   All the Serbian fighters actually were Chetniks.

13             JUDGE ANTONETTI: [Interpretation] [Previous translation

14     continues] ... has no value but this Legija seemingly wrote this document

15     whilst he was in prison.  We can see that it says something in Italian on

16     the letterhead of the paper, [Italian spoken], 23rd of January, 2009,

17     11 hours 10.  Can you explain to us how you received this document?

18             THE ACCUSED: [Interpretation] Mr. President, this document was

19     received by the detention unit at their fax, and this is the marking

20     that -- or the stamp that that fax machine makes recently.  I don't know

21     what this means [Italian spoken], or whatever it says but it arrived at

22     the detention unit on the 23rd of January, 2009 at 1110 hours.

23             JUDGE ANTONETTI: [Interpretation] Right all the faxes you receive

24     read [Italian spoken] that's on the letterhead.  Continue please.

25             MR. SESELJ: [Interpretation]

Page 14108

 1        Q.   He says here that he went to Zvornik with Miroslav Bogdanovic,

 2     with the two Vuckovic brothers, Zuco and Repic; and that the two of them,

 3     the Vuckovics, he saw them then for the first time, probably he knew

 4     Miroslav Bogdanovic from earlier, and he doesn't say that.

 5             In the night, between the 7th and the 8th of April 1992, we lost

 6     our way after crossing the bridge at the entrance to Zvornik.  He says he

 7     didn't know that area and then instead of going to the right, they turned

 8     and went to the left, and they came up against an ambush of armed Muslims

 9     who captured us and take us -- took us to the SUP premises.  Is it true

10     that Muslims had set up barricades around Zvornik, and that there were

11     armed Muslims at those barricades?

12        A.   If they had crossed the bridge, could not have gone -- they could

13     only have gone to the left, if we're talking about these two bridges,

14     there are only two bridges, there's one in Karakaj.  They didn't cross

15     that bridge.  If they had taken the city bridge, then they could have

16     gone to the right, and they were found, concealed in a ditch that goes

17     through there.

18             THE INTERPRETER:  The speakers are overlapping.

19             THE WITNESS: [No interpretation]

20             MR. SESELJ: [Interpretation]

21        Q.   They passed by the Serbian barricade?

22        A.   No, the Muslim barricade at the entrance of the town.

23        Q.   If they had crossed at Karakaj they would have crossed to the --

24     turned to left and went directly to the town.  Had they turned to the

25     right they would have encountered the Serb barricade.

Page 14109

 1        A.   They couldn't have gone to the right.  It was the Karakaj

 2     industrial facility, and there were no Muslims there.

 3        Q.   The Serbs were there.  So instead of turning to the right, they

 4     turned to the left.

 5        A.   Why would they turn right if Zvornik is to the left?

 6             THE INTERPRETER:  The speakers are overlapping, the interpreter

 7     can no longer certify the accuracy of the interpretation.

 8             JUDGE ANTONETTI: [Interpretation] Please wait a few minutes

 9     before you answer.  Please continue.

10             MR. SESELJ: [Interpretation]

11        Q.   Look, they are going to do some confidential assignment for the

12     JNA military security service, and they probably got instructions that

13     after they crossed the Karakaj bridge if they turned left they would

14     encounter Serbian police.  Instead of turning to the right, they turned

15     to the left, and they encountered a Muslim barricade.  This is logical to

16     me.

17        A.   It's not logical to me, Mr. Seselj, that precisely on the day of

18     the attack on Zvornik, they set off to carry out some assignment.  Why

19     didn't they do it some days before if that is what they wanted to do, and

20     if the person that you are talking about happened to be in town on that

21     day, he could have been in town only before the attack on Zvornik took

22     place.

23        Q.   Well, you think that the conflict was planned on the 8th of

24     April.  It could have broken out on the 9th or the 11th.  It was evident

25     that the conflict would occur, but it wasn't planned to take place on

Page 14110

 1     that day; is that correct?  Maybe this capture of theirs speeded up the

 2     conflict.  Did you release them afterwards?  Somebody threatened, you

 3     released them, or we will attack?

 4        A.   There were no such threats because nobody knew that they had

 5     entered town.

 6        Q.   All right.  But Nedjo Boskovic called by phone to ask about them,

 7     and he sent a TV crew even requesting to speak to them; is that correct?

 8        A.   I don't know.

 9        Q.   Was there a Serbian television crew arrive?

10        A.   I don't know.  I don't know what happened after that.

11        Q.   Well let's see what he says after that.  He said that they were

12     taken to the SUP premises and then while they were being arrested, they

13     took our particulars and then he said these three immediately showed

14     their membership cards of Arkan's Serbian volunteer guards, and I had my

15     military ID with me which I presented to a Muslim senior officer; and I

16     told them I was on a special assignment.  That's what he told him.  Did

17     you find a military ID card on him?

18        A.   I don't know if we found a military ID card on him.  What I'm

19     saying is that I went had inside and I was in there perhaps for three

20     minutes at the most, while I told Fadil Mujic what I told him, that he

21     need today release these people so that we would avoid war and the worst

22     from occurring; and perhaps I asked in some 60 seconds one of those three

23     members what I asked them.

24        Q.   All right.  And then Legija said immediately they began to beat

25     us, and they handcuffed us, especially diligent in this was a police

Page 14111

 1     officer who was addressed as Asim, as far as I can recall.  This Asim

 2     beat us the most and soon -- with whatever he could lay his hands on.  At

 3     one point, he tried to cut my ear off and precisely when he wanted to do

 4     that, as he was holding my ear in one hand, and a knife in the other, a

 5     senior officer entered the room where all of this was happening and then

 6     stopped him from carrying this out.

 7             Do you know about any policeman called Asim who happened to be

 8     there at the time?

 9        A.   I know a man by the name of Asim, and it's true that he was one

10     of the senior figures in the police, but he wasn't there when I was

11     there.

12        Q.   What is his last name?

13        A.   I don't know.

14        Q.   All right.  After two hours of a group beating, we were locked up

15     in separate rooms.  I was all bloody from the beating and later I saw

16     that the others were in the same state.  This officer who saved me from

17     getting my ear cut off whispered at one point that he was going to try to

18     help us.  In the end, it turned out that this was Fadil Mujic, do you

19     know him?

20        A.   I do.

21        Q.   Do you know that he left Zvornik with Serb aid on that day?

22        A.   No, he didn't.  It's not true.  I have completely opposite

23     information, which is 100 percent accurate.

24        Q.   Legija said that in the morning, members of the green berets

25     arrived at the SUP, and I heard that they were asking these local

Page 14112

 1     policemen to hand us over to them so they could take us to Kula Grad and

 2     that's where they would execute us, this is what he heard.  When these

 3     members of the Green Berets were talking to the policemen, were there any

 4     green berets there present in the police station?

 5        A.   No, I didn't know about such a formation of the Green Berets.

 6        Q.   You never heard of the Green Berets?

 7        A.   Yes, I heard with them, but there was no such formation among the

 8     Muslims.

 9        Q.   Did you hear about the Patriotic League?

10        A.   Yes, it exists.

11        Q.   How long had it existed in the Muslim area?

12        A.   From the late 1991, perhaps just before the new year when the

13     conflicts broke out in Croatia and when these attempts at separation or

14     division of municipalities occurred.

15        Q.   Are you aware the Green Berets are a military formation of the

16     Patriotic League?

17        A.   I just heard about it, but I never saw these units and they

18     didn't have any documents or were never registered as Green Berets.

19        Q.   We will talk about that later.  I have some material, so it will

20     be interesting to discuss that later.  Legija said that while their

21     senior officers were talking amongst themselves the others began to beat

22     us again.  This lasted for a half an hour or so and I fainted from the

23     beating.  When I came to, I found out that a TV crew from Serbia had

24     stopped by.

25             Do you know that a TV crew from Serbia appeared before the police

Page 14113

 1     station Mali Zvornik.  This was in the morning on the 8th of April before

 2     the conflict broke out?

 3        A.   The conflict began early in the morning by very strong shelling

 4     of the whole of Zvornik especially the part where perhaps some resistance

 5     was being expected.

 6        Q.   Was the artillery being fired in the direction of Kula Grad?

 7        A.   It was being fired from the entrance to Zvornik towards the

 8     direction of Karakaj, so Zvornik was attacked already in the morning.  I

 9     don't know about this TV crew, but I imagine that they could not have

10     entered because the war had already began by then.

11        Q.   But we had witnesses who mentioned this.  Then he said, I knew

12     that they were sent by Nedjo Boskovic so that he would protect us and he

13     saw this footage later on television when he was released, perhaps on

14     Belgrade or Novi Sad television and since he had talked with Fadil Mujic

15     he knew what was happening to us.  So Legija claims that Nedjo Boskovic

16     had spoken by telephone with Fadil Mujic; do you know anything about

17     that?

18        A.   No, I don't.

19        Q.   When was this time because when these people were questioned, was

20     it then?  When they were questioned?  When they were beaten?

21        A.   I don't know.  I didn't really speak to Fadil about anything at

22     that time.

23        Q.   Legija said that he was told that the attack on Zvornik began

24     around noon and that the number of policemen and members of the

25     Green Berets in the SUP building went down considerably, that he heard

Page 14114

 1     firing, not far from the building.  And then at one point he asked one of

 2     the guards guarding us to unlock his hand cuffs.  I told him that I had

 3     unbearable pain, and that I couldn't stand it anymore since my hands were

 4     hand cuffed behind my back, and that he could put the hand cuffs back on

 5     but with my hands in front.  He did that and he notes that those guards

 6     were guarding them were all of proper behaviour, and they didn't beat

 7     them or abuse them.

 8             At that point in time, there were four of us in the office.  Not

 9     long after that, we were separated again.  Zuco and his brother were

10     taken to another office and the two of us stayed in one office at one

11     point.  There was an opportunity for me, and I managed to take a rifle

12     from one of the guards.  While I was disarming the other guard with a

13     pointed rifle at him ...

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

15     is really wondering what the point to this is?  We're wasting time.  What

16     is the point, please?

17             THE ACCUSED: [Interpretation] Mr. President, I think that in the

18     last year you have seen that everything I do has some sense.  We can see

19     that Zuco and his brother arrived as a volunteer of the Serbian Radical

20     Party to Zvornik, and I am denying that I -- I deny that in 1992, he had

21     anything to do with the Serbian Radical Party.  I already presented

22     evidence that he formed the Igor Markovic Detachment only after the 26th

23     of April after Kula Grad fell.  I mean, what do you mean, what does it

24     serve?  This is the purpose of it.  This is why I'm doing it.

25             JUDGE ANTONETTI: [Interpretation] Put the question to him.  He

Page 14115

 1     was at the police station.  Saw the four of them.  Put the question to

 2     him.

 3             THE ACCUSED: [Interpretation] Mr. President, this witness who has

 4     the tendency to exaggerate his wartime role said that it was his idea to

 5     free these or release these four people you heard that with his own ears.

 6             Well let's see what Legija says about them being released, how

 7     Fadil Mujic freed them and how then he made it possible for Mujic to

 8     leave and to go abroad through Serbia.

 9             Why are you preventing me from doing this?  I don't have anything

10     to talk about regarding the conflict in his village of birth and the

11     neighbouring villages.  This is not in my indictment.  I didn't research

12     that, and I have no idea what was going on there about a fight where --

13     or if there was a house where women were detained and sexually abused.  I

14     was nothing to do with that.  I am trying to clarify things that are

15     directly related to my indictment especially that I'm now all alone and

16     that I have no associates anymore.

17             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you need to know

18     whether these four were volunteers of the Serbian Radical Party.  That's

19     the essence of it.  So just put the question to him directly.  He'll say

20     yes or no, these were Arkan's men, this or that.  Put the question to

21     him.

22             THE ACCUSED: [Interpretation] Mr. President, this could be so in

23     case the witness were neutral in relation to the proceedings, and if he

24     wished to testify on facts; but you saw that the witness was hostile to

25     me even during the examination in chief.  I mean these direct questions

Page 14116

 1     mean nothing to me.  I have to ask questions in a roundabout way to drag

 2     out of the witness what is relevant if that is possible.  If it's not

 3     possible, then forget it.  You gave me two hours, then allow me to use

 4     those two hours.  I'm not an illiterate, uneducated person not to know

 5     what I'm doing.

 6             JUDGE ANTONETTI: [Interpretation] Okay, then go ahead.

 7             MR. SESELJ: [Interpretation]

 8        Q.   So then he said that he disarmed two guards and then Fadil Mujic

 9     entered who was afraid when he saw him with a gun inside and then he said

10     that Fadil Mujic told him then that he helped them that night when he

11     came in and found one of the police officers trying to cut his ear off.

12             This was something that Fadil Mujic prevented from happening and

13     he said that they would help them to escape from Zvornik.  Legija said he

14     kept that promise around 1600 hours, he managed to get them out of the

15     SUP building and to drive them towards the Zvornik barricade which was

16     held by the JNA and that on the way, Mujic asked him that he should help

17     him in turn by helping him to cross over into Serbia.  This is something

18     that Legija is saying.

19        A.   May I say something now?

20        Q.   Go ahead, I am stating this so you could give your comments.

21        A.   First of all, it's not true and does not make sense that I am

22     hostile towards you.  Why would I?  This is your case, and I am here a

23     witness; and I would like to honourably and honestly state what I know.

24             You are presenting some details to me here and already in my

25     statement I said that I don't know any details, but I explained all the

Page 14117

 1     things that I saw when I entered the police administration and what -- I

 2     saw these four people who were arrested, I didn't know their names at the

 3     time.  I told Fadil that he should release these people if he had no

 4     evidence, but I also suggested that he should get in touch with

 5     Asim Hadzic, who was at Kula Grad, and he was coordinating the defence

 6     efforts there.  I told him to get in touch with him and later I spoke

 7     with Asim Hadzic, later, I spoke with him about it, and he said that he

 8     had called Fadil Mujic on the phone and asked him to release them.

 9             Fadil Mujic released those people, and they went out through the

10     hydro-electric power plants close to the police administration.  He

11     didn't go to Serbia.  He couldn't leave through Serbia.  He passed

12     through my village and went, taking a different direction via Snagovo.

13     That's what that settlement is called, and then he went in the direction

14     of Kalesija and Tuzla.  This is the direction he took to leave.  So it's

15     not true that he left through Zvornik.

16        Q.   Well, gentlemen, you can see that we found out something

17     important, that Asim Hadzic intervened from Kula Grad with Fadil Mujic to

18     release these four people.  Kula Grad was a Muslim fortification near

19     Zvornik.  The Muslims were in a very good position there, and they were

20     prepared for combat there.

21        A.   Mr. Seselj, this is a very good thing, it's a very good deed that

22     this person did.

23        Q.   Well, we're not giving our value judgements here, only the facts

24     are important.

25        A.   Well this is an important fact that this man released these

Page 14118

 1     people.

 2        Q.   Now, we see that there was another man there and told Fadil Mujic

 3     to have the people released.  We didn't know that before.  Nobody's yet

 4     said that.  We saw earlier on that Fadil Mujic released these men, but we

 5     haven't heard so far that Asim was involved; and we didn't know about

 6     your role in all that either.

 7             So this is a very important question as far as I'm concerned.

 8             Now, Legija goes on to say that Asim told him or rather

 9     Fadil Mujic told him that his family was already in Serbia because he

10     transferred them when the conflict was imminent in Zvornik and Legija

11     says that his conduct was very proper, and he's referring to Fadil Mujic.

12     He said I helped him, and when we arrived across to Serbia, I managed to

13     find a car to have him drive to see his family.  I never heard or saw him

14     after that and I sincerely hope that he's alive and well and managed

15     today meet up with his family.

16             Now, I don't want to explain the reasons why this is important

17     for me how Fadil Mujic went from Zvornik, left from Zvornik; so let's

18     hear your version, but don't mention the name of the place you live?

19        A.   This is 100 percent correct.  Fadil Mujic did pass through my

20     village and he spent several nights there, he slept there for several

21     nights.

22        Q.   What date was that?

23        A.   I'm not quite sure about the date but after the people were

24     released, he spent three or four nights in my village and I know

25     personally, I know the man personally, and he knows me.  We talked and

Page 14119

 1     then he left via Snagovo and a built-up area towards Kalesija and the

 2     free territory of Tuzla.  So it is unfounded, an unfounded fact that --

 3        Q.   Very well.

 4        A.   100 per cent, that's 100 per cent correct.

 5        Q.   That's all I wanted to do, to clear that up and it's important to

 6     me for certain reasons of my own to explain how Fadil Mujic came to leave

 7     Zvornik.

 8             Now, Legija goes on to say that the four of them went to the

 9     Jezero Hotel in Mali Zvornik.  You know where the hotel is?

10        A.   Perhaps some 300 metres downstream from the hydroelectric power

11     plant that you mentioned.

12        Q.   Do you know that there was the JNA headquarters and Serbian

13     Territorial Defence staff was?

14        A.   Yes.

15        Q.   In Hotel Jezero.  And he says they reported to the staff there to

16     say that they were alive and well and he says despite the fact that he

17     had been beaten up, he wanted to become part and parcel of the struggle,

18     the fighting, and he explains his motives for fighting for the Serb

19     people.  And he says they told me at the Territorial Defence staff, at

20     Jezero hotel that there were certain forces in the factory in Karakaj.

21     Did you know what Serb forces were in Karakaj?

22        A.   I wasn't down there myself.

23        Q.   But you heard about this?

24        A.   Well of course but in that area from Karakaj further down, the

25     area was impopulated by a Serb majority and they were all part of

Page 14120

 1     Chetnik -- the Chetnik formations.  And of course in the factory they had

 2     their staff and headquarters or administration or whatever.

 3        Q.   Let's clear one thing up.  The Muslims called all Serb fighters

 4     in this war Chetniks, didn't they, and the Serb fighters usually referred

 5     to themselves as Chetniks.  That's not contentious.  You keep repeating

 6     they were all Chetniks.  I have nothing against that, you understand me

 7     but let's just clear that up.

 8             Now, this is what he says:  When I arrived in Karakaj, I noticed

 9     armed people in a factory there and I asked them who their commander was

10     and I learned that there were members of Arkan's guards there and members

11     of the Territorial Defence of Zvornik as well.  Did you know that Arkan's

12     men were in Karakaj?

13        A.   In my testimony I said that Arkan's men or the people's known as

14     Seselj's men were all over Serbia facing Karakaj and --

15        Q.   Now you're taking all this together.  They were volunteers of the

16     Serbian Radical Party there and you refer to them as Seselj's men, but

17     they joined the action across the bridge in Zvornik itself, whereas

18     Arkan's men started out from the direction of Karakaj.  They didn't leave

19     at the same time.  Do you agree with that?

20        A.   Well, yes, because you are better informed.

21        Q.   Yes, I am better informed.  There were at least 100 volunteers of

22     the Serbian Radical Party there, and I have certain Muslim information

23     here to the effect that they estimate that there were about 2.000

24     soldiers on the Serb side.  How many would you say there were, what would

25     you say the Serb forces were in the Zvornik area, how many soldiers, a

Page 14121

 1     total of how many?  What would you say?

 2        A.   Well, I really couldn't say.  I couldn't give you a figure, but

 3     if we know that there were 34 per cent -- that 34 per cent of the

 4     population was Serb in the area and they were all involved in one way or

 5     another --

 6        Q.   Well, don't do any guesswork if you don't know.  I have a book

 7     here provided me by The Hague Tribunal and it's Mirsad Hamdzic's book.

 8     He wrote a book called, "Zvornik:  From the elections to Dayton," and in

 9     that book he says that the Serb forces numbered about 2.000 soldiers at

10     the time, including policemen.  Everybody, the Territorial Defence, the

11     JNA, the volunteers of the Serbian Radical Party, Arkan's men, the White

12     Eagles and all the rest, and he enumerates them.  And we'll say later on

13     some the characteristic details from that book.  I have marked them if we

14     have time, but let's just finish with Legija's statements.

15             So you're not contending that it is possible that Arkan's men

16     were in Karakaj and the volunteers of the Serbian Radical Party were in

17     the town itself and that they went across the bridge into action.  You're

18     not challenging, are you, although you don't know for sure?

19        A.   I don't know for sure where they were deployed.  That's what I

20     said.

21        Q.   All right.  Fine.  Now, he goes on to say, I didn't know Arkan

22     personally until then but I respected him as a patriot and fighter.

23     Arkan arrived in Karakaj that night.  When we got to know each other, I

24     explained who I was and everything that had happened to us and said that

25     I wanted to join the fighting, if possible as a member of his unit.  So

Page 14122

 1     that night was when Arkan and Legija met for the first time.

 2             The next morning was the last time I saw Miki, and that was the

 3     nickname for Miroslav Bogdanovic, and Zuco and Repic, they're the

 4     Vuckovic brothers, I never saw them after that.  They simply disappeared

 5     somewhere.

 6             And then Legija goes on to say, Later on I heard that Zuco formed

 7     a unit of his own which was active as a paramilitary formation.  With the

 8     Serbian volunteer guard, I took part in the liberation of Zvornik and

 9     later on Kula Grad, after which the guard withdrew because at Kula Grad

10     Major Zika was killed.  He was a fighter and officer in the Guard whom

11     Arkan respected highly and loved.

12             I assume you've heard of the Yellow Wasps?

13        A.   Yes.

14        Q.   Do you know when they were formed?

15        A.   No.

16        Q.   Did you hear before you heard of the Yellow Wasps that there was

17     a Niko Markovic detachment attached to the Territorial Defence of

18     Zvornik?

19        A.   No, this is the first time I have heard of that.

20        Q.   All right.  That completes this statement of Legija's.  He goes

21     on to describe how he went with Arkan's men to Sarajevo and says that he

22     agrees that this statement be used in the trial at The Hague Tribunal,

23     and that he was ready to be a defence witness but not via videolink but

24     that he wanted to come in personally and testify in open session.

25             All right.  That's that.

Page 14123

 1             Now, before we go on to looking at some interesting details from

 2     this book, let me ask you this:  When you enumerated the political

 3     parties active in Zvornik you mentioned the SDA party, the party of

 4     Democratic Action that rallied Muslims and that was formed first; right?

 5        A.   Now whether it was formed first, I don't think so but they were

 6     formed parallelly, the political parties.

 7        Q.   It was formed a little before the Serbian Democratic party?

 8        A.   Maybe half an hour before.

 9        Q.   Oh, no, let's not say things like that.  You mention the Serbian

10     Democratic party, now did you mention the party of the former Communist

11     that's changed its name, the League of Communists became the SDP party,

12     the Party for Democratic Change?

13        A.   Yes.

14        Q.   They took part in the elections?

15        A.   Yes, they did.

16        Q.   And they had a certain number of deputies in the municipal

17     assembly?

18        A.   Two or a few, yes.

19        Q.   Well, we have a list of those deputies in this book but that's

20     not important.  And you said that at the time the Serbian Radical Party

21     existed too.  You are the first witness who said here that the Serbian

22     Radical Party existed in Zvornik before the conflict.  Where did you get

23     that piece of information from?

24        A.   You formed the Serbian Radical Party far before and the fact is

25     that you spoke about meetings, rallies, and the war in Zvornik started on

Page 14124

 1     the 8th of April, therefore the party existed throughout Yugoslavia a

 2     long time before that.

 3        Q.   Well, no, it didn't.  That's the problem.  It didn't.  The party

 4     was still being organised in Serbia and you know that we were the last

 5     serious party to be registered in Serbia.  We held a founding assembly of

 6     the unification of the Serbian Chetnik movement and most of the radical

 7     party was held only on the 23rd of February, 1991, in Kragujevac.  And

 8     that's when the party began to branch out to different parts of Serbia.

 9             We had three initiation boards in the -- in Bosnia-Herzegovina,

10     Sarajevo, Bijeljina and Banja Luka, we had nothing in Zvornik.  And you

11     can't name a single man from the Serbian Radical Party from Zvornik

12     before the war.  I guarantee that.  I guarantee that you cannot name a

13     single name.

14        A.   But the deputies were from among the Serb people and they went

15     for consultations, the deputies of the SDS and the Serbian Radical Party.

16        Q.   The Serb Serbian Radical Party did not have a single deputy how

17     could they have gone for consultations.  It didn't even take part in the

18     elections.  It's not there.  It didn't exist and I have a list of parties

19     that took part in the election.  We have a list of those parties here by

20     name.  Lists.

21        A.   But the Serbs, amongst themselves, did not agree.  There were the

22     SDS men, Seselj's men, and they quarrelled amongst themselves.  People

23     couldn't agree.

24        Q.   Now, please, if they had -- didn't have a united stand, there was

25     far greater division amongst the Muslims?

Page 14125

 1        A.   They called themselves Seselj's men and the SDS.

 2        Q.   Who did?

 3        A.   Amongst themselves they did.

 4        Q.   The Serbian Radical Party didn't exist.  It had no headquarters

 5     in Zvornik at all.  It didn't take part in the elections and it didn't

 6     have any deputy, not a single one.  The party was formed only later in

 7     1993 or 1994 in Zvornik but the first deputies were in the municipal

 8     assembly of Zvornik after the Dayton Accords, and then the Serbian

 9     Radical Party was the ruling party in Zvornik.  After the Dayton Accords,

10     did you hear that Seselj's radicals were in charge in Zvornik and in

11     control there, not only Zvornik but other municipalities too?  Did you

12     hear about that?

13        A.   Yes.

14        Q.   However, up until 1992, the party did not exist.  You say that

15     the whole of Snagovo was in the hands of the Serbian Radical Party when

16     we didn't have a single member at the time.

17        A.   That's how they declared themselves as Chetniks.

18        Q.   Well, listen here.  If somebody declares themselves a Chetnik, it

19     doesn't mean that they are Serb radicals.  Not all Chetniks were Serb

20     radicals, I would like them to be but they're not, they weren't.  The

21     Chetniks were Draskovic's men and members of the SDS and Jovic's men and

22     all sorts of -- you called all Serb soldiers, you Muslims, Chetniks,

23     whereas 95 per cent of the Serb soldiers referred to themselves as

24     Chetniks; isn't that right?

25        A.   That is right.

Page 14126

 1        Q.   So this is just arbitrary.  If they say they are Chetniks they

 2     must be Seselj's men; is that your deduction?

 3        A.   Well, I don't really know.  I never entered into the details of

 4     all that, to see who the Chetniks were, who Seselj's men were.  As far as

 5     I was concerned, they were all Chetniks and Seselj's men.  And this goes

 6     back to the Second World War, where the Chetniks did the same in

 7     World War II is you did in this war.

 8        Q.   Well, a serious historian would be able to explain all that to

 9     you.  I don't have the time to explain to you what the Chetniks did in

10     World War II, and you are susceptible to Communist propaganda.  But never

11     mind, let's leave that for a moment.  And now let's look at this little

12     book that the Prosecution also has.

13             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, you have five

14     minutes left.

15             THE ACCUSED: [Interpretation] Just five minutes?

16             JUDGE ANTONETTI: [Interpretation] Yes, you have five minutes

17     left.  And this question, I already dealt with it yesterday -- if you

18     want to talk about it again, fine, but this topic has already been

19     addressed yesterday.  You have five minutes.

20             THE ACCUSED: [Interpretation] Very well.

21        Q.   Now, the Muslims, did they arm themselves prior to the conflict

22     in Zvornik?

23        A.   I have no information that they armed themselves because until

24     the very last day, they fought to avoid a conflict and war.

25        Q.   Was there a plan for the defence of Zvornik by the Muslims?

Page 14127

 1        A.   A defence plan was only elaborated after Abdul Pasic [phoen]

 2     returned and the Chief of Staff of the Territorial Defence Alija

 3     Kapidzic, from the meeting on the 7th, when it was officially stated that

 4     there was no talks or negotiations, no divisions but that we had to

 5     solve -- resolve the situation through military means.

 6        Q.   Was there a conflict in the Muslim Crisis Staff?

 7        A.   No, why.

 8        Q.   Was there conflict in the Party of Democratic Action, the SDA?

 9        A.   At the time there were no conflicts but differences of opinion

10     did exist a year before that in the Serb party, but there was no conflict

11     then.

12        Q.   Was there conflict as to the way in which the Muslims should be

13     armed?

14        A.   I don't know.  I'm not aware of that.  All that was said in the

15     Crisis Staff was that all those people who had hunting weapons or --

16        Q.   All right.  Now, we have a quotation from Mirsad Hamdzic's book,

17     on page 71.  The Patriotic Leagues were formed in the 26th of July, 1991,

18     in the youth library at Kula Grad, the 26th of July, 1991.  We formed the

19     Crisis Staff but the commander was not nominated.  In talks, Hadzic

20     Uzbasic [phoen] -- in the Hadzic-Uzbasic talks, Uzbasic's wing was asked

21     to provide a commander and there was a meeting at which it was decided

22     that Sakik Halilovic [phoen], Kibe [phoen], should be appointed

23     commander.

24             The organisation existed at the time, the defence plan had been

25     elaborated, the network for supplying arms was in place, weapons were

Page 14128

 1     bought in Vienna and was brought in by ship where a network of the

 2     Patriotic League existed.  There were black marketeers who provided

 3     weapons and sold them, and of the names who should be mentioned here,

 4     Avdija Muratovic is one who went on several occasions to Brod and Gradac

 5     to pick up the weapons and they could earn 100 German marks per barrel.

 6             They tried to get firms and companies to provide them -- with

 7     money to buy, to purchase weapons.  There was a meeting with a major firm

 8     when the Chetniks started in Karakaj and Celopek and resources were

 9     sought but only Muhamed Jelkic [phoen], head of the health centre,

10     offered money for weapons to protect the population.

11             Similarly, we worked to pull out our young men who were in the

12     JNA and to prevent the mobilisation of the reserve force.  And on

13     page 72, another brief quotation, despite this fact, and he is a he

14     referring to the unity among the ranks, through the Patriotic League

15     channels, the SDA managed in Zvornik municipality to bring in about 4.000

16     barrels, 4.000 pieces and at one of the municipal assembly meetings, the

17     deputies put forward the piece of information that the Bosniaks were

18     arming themselves, and then there was a extensive discussion about this.

19             Do you deny that?

20        A.   I don't know about any of that.  There are a lot of untruths in

21     that book as regards the number of pieces, weapons, the channels, and

22     network.  I know nothing about that, nor did I discuss it with anyone.

23        Q.   Well just a minute, were there Muslims armed to the extent that

24     they had 4.000 new rifles?

25        A.   If the Muslims had 4.000 new rifles as you claim, and as you also

Page 14129

 1     claim that the Chetniks only had about 3.000 armed persons, what would

 2     the logic be of attacking somebody with 4.000 rifles if you only

 3     had 2.000.  You would be routed.  There would be no logic in that.

 4        Q.   Well they were routed because they stood up to the leadership and

 5     we have this in Himzo Tulic's book, have you heard of him?

 6        A.   Yes.

 7        Q.   He wrote a book too.  Now let's see what this Muslim author says

 8     along with all the reservations that I can make and have towards him.  As

 9     an engaged author, he says who took part in the struggle for Zvornik on

10     the Serb side with the paramilitary units, Arkan's, and Seselj's men,

11     units of the JNA, which were made up of part of the light infantry

12     division of the JNA of Bijeljina and under the control of Colonel

13     Miletic; for the most part reinforced by local Serbs.  And

14     Major Jovanovic, Zoran was in command, he was from Valjevo.  There was an

15     armed battalion of the same name, Colonel Tacic and

16     Captain Dragan Obrenovic was commander of that unit and another mobilised

17     unit of the Mali Zvornik municipality in Loznica.  They were armed to the

18     teeth and well-equipped, and this created an armed force for attacking

19     Zvornik, et cetera, et cetera.  So that is on page 87 and this was a

20     Muslim author, Hamdzic.  He describes this and says who fought on the

21     Serb side and he adds and says the following on page 92 --

22             JUDGE ANTONETTI: [No interpretation]

23             THE ACCUSED: [Interpretation] May I put one more question?

24             JUDGE ANTONETTI: [Interpretation] Last question and then it's

25     finished.

Page 14130

 1             MR. SESELJ: [Interpretation] This is what this author says who

 2     began the attack.  This is according to him, and he is a Muslim author

 3     who began the attack on the 8th of April.  This is on page 92.

 4        Q.   Units of the JNA of the Tuzla, Novi Sad, and Uzice Corps enjoyed

 5     coordination with the Pancevo's Specials, Arkan's men, Seselj's Chetniks,

 6     and members of the White Eagles, units of the TO, of the Republic of

 7     Serbia, and the TO of the municipalities of Mali Zvornik and Loznica and

 8     paramilitary formations of the Serbian Democratic Party of the BiH of the

 9     so-called Territorial Defences of the municipality of Zvornik.

10             Was it clear to you that throughout that whole time you were in

11     conflict with the JNA and all the forces were under the direct command of

12     the JNA?

13        A.   I don't know under whose direct command they were, but you did

14     say which forces participated in the attack including your forces we're

15     discussing.  You here and your ideas.

16        Q.   How did you know what we are discussing here?  Don't lecture.

17     I'm asking you.  Did you know that all the Serbian forces were under the

18     direct control of the JNA?  That is the question.

19             JUDGE ANTONETTI: [Interpretation] Mr. Seselj, it's finished.  You

20     put the question to him and he answered quite clearly.

21             Mr. Marcussen, do you have any re-examination?

22             MR. MARCUSSEN:  Two very brief questions, Your Honours, but

23     before that I just wish to put on record --

24             JUDGE ANTONETTI: [Interpretation] Proceed.

25             MR. MARCUSSEN:  -- that the accused did not, as he was supposed

Page 14131

 1     to, notify of us to his intention to use Mr. Tulic's book in his

 2     cross-examination.  Now he has referred to this book endlessly, so I did

 3     not object.  I do wish to put this on the record.  VS-2000 --

 4             THE ACCUSED: [Interpretation] I must respond to that.  I received

 5     this book from the Prosecution under 68(1), that rule, and the

 6     Prosecution marked this book with its numbers.  Every page has a number,

 7     so why would I have to inform the Prosecutor about this particular

 8     matter?

 9             JUDGE ANTONETTI: [Interpretation] We have discussed this for

10     hours.  The Prosecution is entitled to this, i.e., that he is informed

11     before the cross-examination of what documents will be used.  We have

12     gone over this ground time and time again.

13             Mr. Marcussen, put your question.

14                           Re-examination by Mr. Marcussen:

15        Q.   I'd like to ask you about the meeting at the culture centre in

16     Mali Zvornik in March 1992, and I have two questions.

17             My first question is how long a time was there between the

18     accused, Dr. Seselj, inside the hall and you were taken out of the hall?

19     How long time do you estimate past there?

20        A.   Not more than ten minutes, maybe five to ten minutes, just that

21     much.

22        Q.   And how long time passed from you had been taken out of the hall

23     until you saw Seselj come out of the hall?

24        A.   Exactly that, ten minutes, not more than that, probably less by a

25     minute or two, so it was maybe in eight minutes, not longer than that.

Page 14132

 1        Q.   So the accused was present at the meeting for 20 minutes or

 2     something like that?

 3        A.   Very briefly, perhaps 20 minutes past until the time I went out

 4     and then after I was taken out, some eight to ten minutes, so it was very

 5     brief.  So he could not have read all of these things just off the top of

 6     his head that he had read out.  He mentioned so many details, and he

 7     needed two hours to do it.

 8             MR. MARCUSSEN:  I have no further questions, Your Honour.

 9             JUDGE ANTONETTI: [Interpretation] Witness, I would like to thank

10     you for having come to testify at the request of the Prosecution.  I wish

11     you a safe journey home.

12             As I mentioned a few moments ago, at 8.30 on Wednesday, we have

13     our next witness.  Two hours have been scheduled for the Prosecution and

14     two hours for Mr. Seselj.

15             Mr. Seselj.

16             THE ACCUSED: [Interpretation] I have two administrative matters.

17     First of all I understood ...

18             JUDGE ANTONETTI: [Interpretation] Very briefly because the

19     audiotape is going to stop.

20             THE ACCUSED: [Interpretation] First of all, I understood that you

21     gave -- issued and order for the Prosecution to obtain material evidence

22     about the date of the rally of the radical -- or the Chetniks in

23     Mali Zvornik.  Perhaps I hope that this should be done by Wednesday when

24     we reconvene.  That's one thing.

25             The other thing is I received another one in a series of requests

Page 14133

 1     from the Prosecution that statements by deceased witnesses should be

 2     submitted under specific rules.  This is the statement by Matija Boskovic

 3     under Rule 92 quater, and I absolutely oppose this because this is

 4     something that cannot be done even under Anglo-Saxon law, even under the

 5     modified form that is being used in this Tribunal, so I hope that you

 6     will not be violating procedural rules just the way so other

 7     Trial Chambers are doing.  Some Chambers are doing that, some Trial

 8     Chambers by admitting these types of statements, and I don't believe that

 9     this can be done if the accused disagrees with it.

10             JUDGE ANTONETTI: [Interpretation] Regarding the second item,

11     the -- it's on the record now.

12             The Prosecution, for the first point, if on Wednesday morning if

13     you can tell us that after research that you have a number of documents

14     that would deal with this meeting allegedly held in March 1992, that

15     would be a really good thing.  You have all weekend to do your research,

16     and on Wednesday you will tell us what you found.

17             We will reconvene on Wednesday at 8.30.

18                           --- Whereupon the hearing adjourned at 5.52 p.m.

19                           to be reconvened on Wednesday, the 11th day of

20                           February, 2009, at 8.30 a.m.